ML101940378
| ML101940378 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/30/2010 |
| From: | John Hughey Plant Licensing Branch 1 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| Hughey J, NRR/DORL, 301-415-3204 | |
| References | |
| TAC MD9449, TAC MD9450 | |
| Download: ML101940378 (31) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 30,2010 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - ISSUANCE OF AMENDMENTS RE: ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE (TSTF) TRAVELER 439, REVISION 2, "ELIMINATE SECOND COMPLETION TIMES LIMITING TIME FROM DISCOVERY OF FAILURE TO MEET AN LCO [LIMITING CONDITION FOR OPERATION]"
(TAC NOS. MD9449 AND MD9450)
Dear Mr. Pacilio:
The Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment Nos. 277 and 280 to Renewed Facility Operating License Nos. DPR-44 and DPR-56 for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated August 7, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML082240520), as supplemented by letters dated May 7,2009, and January 19, 2010 (ADAMS Accession Nos. ML091280686 and ML100200086). The August 7,2008, submittal contained several areas of review that have been dispositioned as separate amendment requests.
The amendments issued with this letter revise the PBAPS Units 2 and 3 TSs to adopt TSTF Traveler 439, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO [Limiting Condition for Operation]" (ADAMS Accession No. ML051860296). The amendments revise Section 1.3 of the PBAPS Unit 2 and 3 TSs altering the discussion contained in Example 1.3-3 removing second completion times. Consistent with this change, the second completion times associated with TS 3.1.7, "Standby Liquid Control (SLC) System," Required Actions A.2 and B.1, TS 3.8.1, "AC Sources - Operating," Required Action A.3, and TS 3.8.7, "Distribution Systems - Operating," Required Actions C.1 and 0.1, are being deleted.
M. Pacilio
- 2 All work is complete on TAC Nos. MD9449 and MD9450. Accordingly, these TAC Nos. will be closed. A copy of our Safety Evaluation is enclosed and a Notice of Issuance will be included in the Commission's biweekly Federal Register notice. SP[)#
John D. Hughey, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278
Enclosures:
- 1. Amendment No. 277 to Renewed DPR-44
- 2. Amendment No. 280 to Renewed DPR-56
- 3. Safety Evaluation cc w/encls: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 EXELON GENERATION COMPANY, LLC PSEG NUCLEAR LLC DOCKET NO. 50-277 PEACH BOTTOM ATOMIC POWER STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 277 License No. DPR-44
- 1.
The Nuclear Regulatory Commission (the Commission) has found that A.
The application for amendment by Exelon Generation Company, LLC (Exelon Generation Company), and PSEG Nuclear LLC (the licensees), dated August 7,2008, as supplemented by letters dated May 7,2009, and January 19, 2010, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Renewed Facility Operating License No. DPR-44 is hereby amended to read as follows:
- 2 (2)
Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment NO.277 are hereby incorporated in the license. Exelon I
Generation Company shall operate the facility in accordance with the Technical Specifications.
- 3.
Implementation Requirements:
This license amendment is effective as of the date of issuance, and shall be implemented within 60 days of issuance. Coincident with the implementation of this amendment, the licensee shall modify the current revision of Exelon procedure OP-PB-108-104, "Regulatory Compliance Action Logs," to incorporate administrative controls to limit the maximum time allowed for any combination of Technical Specification conditions that result in a single contiguous occurrence of failing to meet a Limiting Condition for Operation. The administrative controls shall ensure that the Technical Specification Completion Time for a condition is not inappropriately extended.
FOR THE NUCLEAR REGULATORY C MMISSION if(d:'aff' Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the License and Technical Specifications Date of Issuance: Jl::ll y 30, 2010
ATTACHMENT TO LICENSE AMENDMENT NO. 277 RENEWED FACILITY OPERATING LICENSE NO. DPR-44 DOCKET NO. 50-277 Replace the following page of the Facility Operating License with the attached revised page.
The revised page is identified by amendment number and contains marginal lines indicating the areas of change.
Remove Page 3 Page 3 Replace the following pages of the Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove 1.3 - 2 1.3 - 2 1.3 -6 1.3 -6 1.3 -7 1.3 -7 3.1 - 20 3.1 - 20 3.8-2 3.8-2 3.8 -42 3.8 -42 3.8 -43 3.8 -43
(5)
Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not to separate, such byproduct and special nuclear material as may be produced by operation of the facility.
C.
This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:
(1)
Maximum Power Level Exelon Generation Company is authorized to operate the Peach Bottom Atomic Power Station, Unit 2, at steady state reactor core power levels not in excess of 3514 megawatts thermal.
(2)
Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 277,are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications.
(3)
Physical Protection Exelon Generation Company shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans1, submitted by letter dated May 17, 2006, is entitled: "Peach Bottom Atomic Power Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, Revision 3." The set contains Safeguards Information protected under 10 CFR 73.21.
(4)
Fire Protection The Exelon Generation Company shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report for the facility, and as approved in the NRC Safety Evaluation Report (SER) dated May 23, 1979, and Supplements dated August 14, September 15, October 10 and November 24, 1980, and in the NRC SERs dated September 16, 1993, and August 24, 1994, subject to the following provision:
The Exelon Generation Company may make changes to the approved The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.
Renewed License No. DPR-44 Revised by letter dated October 28, 2004 Revised by Letter dated May 29, 2007 Amendment No. 277 Page 3
Completion Times 1.3 1.3 Completion Times OESCRI PTION (continued)
However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended.
To apply this Completion Time extension, two criteria must first be met.
The subsequent inoperability:
- a.
Must exist concurrent with the iiLi1 inoperability; and
- b.
Must remain inoperable or not within limits after the first inoperability is resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
- a.
The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
- b.
The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry.
These exceptions are stated in individual Specifications.
The above Completion Time extension does not apply to a Completion Time with a modified "time zero."
This modified "time zero" may be expressed as a repetitive time (i.e.,
"once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery... "
(continued)
PBAPS UNIT 2
- 1. 3-2 Amendment No. 277
Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
One Function X subsystem inoperable.
A.1 Restore Function X subsystem to OPERABLE status.
7 days B.
One Function Y subsystem inoperable.
B. 1 Restore Function Y subsystem to OPERABLE status.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> C.
One Function X subsystem inoperable.
MQ One Function Y subsystem inoperable.
C.1 Restore Function X subsystem to OPERABLE status.
Q.R C.2 Restore Function Y subsystem to OPERABLE status.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 12 hours (continued)
PBAPS UNIT 2 1.3 -6 Amendment No.277
Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)
When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable.
The Completion Times for Condition A and Condition B are tracked separately for each subsystem, starting from the time each subsystem was declared inoperable and the Condition was entered.
A separate Completion Time is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was di scovered).
If Required Action C.2 is completed within the specified Completion Time, Conditions Band C are exited.
If the Completion Time for Required Action A.l has not expired, operation may continue in accordance with Condition A.
The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e., initial entry into Condition A).
It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO.
- However, doing so would be inconsistent with the basis of the Completion Times.
Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO.
These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.
(contjnued)
PBAPS UNIT 2
- 1. 3-7 Amendment No.2??
3.1.7 SLC System 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC) System LCO 3.1.7 Two SLC subsystems shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, and 3.
ACTIONS CONDITION REOUIRED ACTION COMPLETION TIME A.
Concentration of boron in solution> 9.82%
weight.
A.1 Verify the concentration and temperature of boron in solution and pump suction piping temperature are within the limits of Figure 3.1.7-1.
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter A.2 Restore concentration of boron in solution to ~ 9.82% weight.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B.
One SLC subsystem inoperable for reasons other than Condition A.
B.1 Restore SLC subsystem to OPERABLE status.
7 days (cont i nued)
PBAPS UNIT 2 3.1-20 Amendment No. 277
3.8.1 AC Sources-Operating ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - -. - - - - - - - - - - - - - - - - - - - - -- - - - - - -
LCO 3.0.4.b is not applicable to DGs.
CONDITION REQUIRED ACTION COMPLETION TIME A.
One offsite circuit inoperable.
A.l ill A.2 Perform SR 3.8.1.1 for OPERABLE offsite circuits.
Declare required feature(s) with no offsite power available inoperable when the redundant required feature(s) are inoperable.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from di scovery of no offsite power to one 4 kV emergency bus concurrent with inoperabilityof redundant required feature(s)
A.3 Restore offsite circuit to OPERABLE status.
7 days (continued)
PBAPS UN IT 2 3.8-2 Amendment No. 277
3.8.7 Distribution Systems-Operating ACTIONS A.
CONDITION One or more required Unit 3 AC electrical power distribution subsystems inoperable.
REQUIRED ACTION
- - - - - - - - - - - - -NOTE - - - - - - - - - - -
Enter applicable Conditions and Required Actions of LCO 3.8.4, "DC Sou rces Ope rat i ng," when Condition A results in a de-energization of a required Unit 3 125 V battery charger.
A.1 Restore required Unit 3 AC electrical power distribution subsystem(s) to OPERABLE status.
COMPLETION 7 days TIME B.
One required Unit 3 DC electrical power distribution subsystem inoperable.
B.1 Restore Unit 3 DC electrical power distribution subsystem to OPERABLE status.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C.
One Unit 2 AC electrical power distribution subsystem inoperable.
C.l Restore Unit 2 AC electrical power distribution subsystem to OPERABLE status.
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (continued)
PBAPS UNIT 2 3.8-42 Amendment No. 277
3.8.7 Distribution Systems-Operating ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D.
One Unit 2 DC electrical power distribution subsystem inoperable.
D.l Restore Unit 2 DC electrical power distribution subsystem to OPERABLE status.
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> E.
Required Action and associated Completion Time of Condition A, B, C, or D not met.
E. 1 Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F.
Two or more inoperable electrical power distribution subsystems that result in a loss of function.
F.l Enter LCO 3.0.3.
Immediately SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREQUENCY SR 3.8.7.1 Verify:
7 days
- a.
Correct breaker alignments to required AC electrical power distribution subsystems; and
- b.
Indicated power availability to required AC and DC electrical power distribution subsystems.
PBAPS UNIT 2 3.8-43 Amendment No.2??
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC PSEG NUCLEAR LLC DOCKET NO. 50-278 PEACH SODOM ATOMIC POWER STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 280 License No. DPR-56
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Exelon Generation Company, LLC (Exelon Generation Company), and PSEG Nuclear LLC (the licensees), dated August 7,2008, as supplemented by letters dated May 7,2009, and January 19, 2010, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; S.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Renewed Facility Operating License No. DPR-56 is hereby amended to read as follows:
- 2 (2)
Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 280,are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications.
- 3.
Implementation Requirements:
This license amendment is effective as of the date of issuance, and shall be implemented within 60 days of issuance. Coincident with the implementation of this amendment, the licensee shall modify the current revision of Exelon procedure OP-PB-108-104, "Regulatory Compliance Action Logs," to incorporate administrative controls to limit the maximum time allowed for any combination of Technical Specification conditions that result in a single contiguous occurrence of failing to meet a Limiting Condition for Operation. The administrative controls shall ensure that the Technical Specification Completion Time for a condition is not inappropriately extended.
FOR THE NUCLEAR REGULATORY COMM SION
~~hief £---0--
Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the License and Technical Specifications Date of Issuance: Ju1y 30, 2010
ATTACHMENT TO LICENSE AMENDMENT NO. 280 RENEWED FACILITY OPERATING LICENSE NO. DPR-56 DOCKET NO. 50-278 Replace the following page of the Facility Operating License with the attached revised page.
The revised page is identified by amendment number and contains marginal lines indicating the areas of change.
Remove Page 3 Page 3 Replace the following page of the Appendix A, Technical Specifications, with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.
Remove 1.3 - 2 1.3 - 2 1.3 - 6 1.3 - 6 1.3 -7 1.3 -7 3.1 - 20 3.1 - 20 3.8 -2 3.8 -2 3.8 -42 3.8 - 42 3.8 -43 3.8 -43
(5)
Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not to separate, such byproduct and special nuclear material as may be produced by operation of the facility.
C.
This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:
(1)
Maximum Power Level Exelon Generation Company is authorized to operate the Peach Bottom Atomic Power Station, Unit No.3, at steady state reactor core power levels not in excess of 3514 megawatts thermal.
(2)
Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 280, are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications. 1 (3)
Physical Protection Exelon Generation Company shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans2, submitted by letter dated May 17, 2006, is entitled: Peach Bottom Atomic Power Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, Revision 3." The set contains Safeguards Information protected under 10 CFR 73.21.
(4)
Fire Protection The Exelon Generation Company shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report for the facility, and as approved in 1Licensed power level was revised by Amendment No. 250, dated November 22, 2002, and will be implemented following the 14th refueling outage currently scheduled for Fall 2003.
2The training and Qualification Plan and Safeguards Contingency Plan and Appendices to the Security Plan.
Renewed License No. DPR-56 Revised by letter dated October 28, 2004 Revised by letter dated November 5, 2004 Revised by letter dated May 29, 2007 Amendment No. 280 Page 3
Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)
However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended.
To apply this Completion Time extension, two criteria must first be met.
The subsequent inoperability:
- a.
Must exist concurrent with the fiL21 inoperability; and
- b.
Must remain inoperable or not within limits after the first inoperability is resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
- a.
The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
- b.
The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry.
These exceptions are stated in individual Speci fi cat ions.
The above Completion Time extension does not apply to a Completion Time with a modified "time zero."
This modified "time zero" may be expressed as a repetitive time (i.e.,
., 0 nce per 8 h0 urs," where the Com p1et ion Time i s referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery... "
(continued)
PBAPS UI~IT 3
- 1. 3 - 2 Amendment No.280
Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)
ACTIONS COND IT ION REQUIRED ACTION COMPLETION TIME A.
One Function X subsystem inoperable.
A.1 Restore Function X subsystem to OPERABLE status.
7 days B.
One Function Y subsystem inoperable.
B.1 Restore Function Y subsystem to OPERABLE status.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> C.
One Function X subsystem inoperable.
Mill One Function Y subsystem inoperable.
C.1 Restore Function X subsystem to OPERABLE status.
OR C.2 Restore Function Y subsystem to OPERABLE status.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 12 hours (continued)
PBAPS UNIT 3
- 1. 3-6 Amendment No. 280
Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)
When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable.
The Completion Times for Condition A and Condition B are tracked separately for each subsystem, starting from the time each subsystem was declared inoperable and the Condition was entered.
A separate Completion Time is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).
If Required Action C.2 is completed within the specified Completion Time, Conditions Band C are exited.
If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A.
The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e.. initial entry into Condition A).
It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO.
- However, doing so would be inconsistent with the basis of the Completion Times.
Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO.
These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.
(continued)
PBAPS UNIT 3
- 1. 3 - 7 Amendment No. 280
3.1.7 SLC System 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC) System LCO 3.1.7 Two SLC subsystems shall be OPERABLE.
APPLICABILITY:
MODES I, 2, and 3.
ACTIONS A.
CONDITION Concentration of boron in solution> 9.82%
weight.
A.l A.2 REQUIRED ACTION Veri fy the concentration and temperature of boron in solution and pump suction piping temperature are within the limits of Figure 3.1.7-1.
Restore concentration of boron in solution to ~ 9.82% weight.
COMPLETION 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> TIME B.
One SLC subsystem inoperable for reasons other than Condition A.
B.l Restore SLC to OPERABLE subsystem status.
7 days (continued)
PBAPS UNIT 3 3.1-20 Amendment No ?80
3.8.1 AC Sources-Operating ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - -
LCO 3.0.4.b is not applicable to DGs.
CONDITION REOU I RED AC TI ON COMPLETION TIME A.
One offsite circuit inoperable.
A.1 Perform SR 3.8.1.1 for OPERABLE offsite circuits.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter A.2 Declare required feature(s) with no offsite power available inoperable when the redundant required feature(s) are inoperable.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of no off site power to one 4 kV emergency bus concurrent with i noperabi 1i ty of redundant required feature(s)
A.3 Restore offsite circuit to OPERABLE status.
7 days (continued)
PBAPS UN IT 3 3.8-2 Amendment No. 280
3.8.7 Distribution Systems-Operating ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
One or more required Unit 2 AC electrical power distribution subsystems inoperable.
- - - - - - - - - - - - - NOTE -- - - - -.. -
Enter applicable Conditions and Required Actions of LCO 3.8.4, "DC Sou rces Opera t i ng," when Condition A results in a de-energization of a required Unit 2 125 V battery charger.
A.1 Restore required Unit 2 AC electrical power distribution subsystem(s) to OPERABLE status.
7 days B.
One Unit 2 DC electrical power distribution subsystem inoperable.
B.1 Restore Unit 2 DC electrical power distribution subsystem to OPERABLE status.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C.
One Unit 3 AC electrical power distribution subsystem inoperable.
C.1 Restore Unit 3 AC electrical power distribution subsystem to OPERABLE status.
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (continued)
PBAPS UNIT 3 3.8-42 Amendment No.280
3.8.7 Distribution Systems-Operating ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D.
One Unit 3 DC electrical power distribution subsystem inoperable.
D.1 Restore Unit 3 DC electrical power distribution subsystem to OPERABLE status.
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> E.
Required Action and associated Completion Time of Condition A, B, C, or D not met.
E.1 Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F.
Two or more inoperable electrical power distribution subsystems that result in a loss of function.
F.l Enter LCO 3.0.3.
Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify:
7 day s
- a.
Correct breaker alignments to required AC electrical power distribution subsystems; and
- b.
Indicated power availability to required AC and DC electrical power distribution subsystems.
PBAPS UNIT 3 3.8-43 Amendment No.280
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 277 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-44 AND AMENDMENT NO. 280 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-56 EXELON GENERATION COMPANY, LLC PSEG NUCLEAR, LLC PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278
1.0 INTRODUCTION
By letter dated August 7,2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML082240520), Exelon Generation Company, LLC, the licensee for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, requested to amend the Technical Specifications (TS), Appendix A, of Renewed Facility Operating License Nos. DPR-44 and DPR-56 for PBAPS Units 2 and 3. The submittal included a request to adopt Technical Specification Task Force Traveler 439 (TSTF-439), Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO [Limiting Condition for Operation]" (ADAMS Accession No. ML051860296). The change revises Section 1.3 of the PBAPS Units 2 and 3 TSs to alter the discussion contained in Example 1.3-3 to eliminate second completion times. Consistent with this change, the second completion times associated with TS 3.1.7, "Standby Liquid Control (SLC) System," Required Actions A.2 and B.1, TS 3.8.1, "AC Sources - Operating," Required Action A.3, and TS 3.8.7, "Distribution Systems Operating," Required Actions C.1 and D.1 are being deleted.
By letter dated January 19, 2010 (ADAMS Accession No. ML100200086), the licensee supplemented its amendment request with additional information regarding adoption of TSTF-439, Revision 2. The supplemental information clarified the amendment request, did not expand the scope of the scope of the application as originally noticed, and did not change the Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration as published in the Federal Register on May 5, 2009 (74 FR 20744)
The NRC staff has completed its review and finds that that the requested TS modifications are acceptable, as discussed in this safety evaluation (SE).
- 2 The August 7, 2008, submittal contains amendment requests for five changes in addition to elimination of TS second completion times. Three of the proposed changes were approved as described in NRC letter dated August 31,2009 (ADAMS Accession No. ML092250339), and a fourth request was approved as described in NRC letter dated April 30, 2010 (ADAMS Accession No. ML100900319). The January 19, 2010, supplement withdrew the remaining request to incorporate TSTF Traveler 363-A, Revision 0, "Revise Topical Report references in ITS [Improved Technical Specifications] 5.6.5, COLR [core operating limit report]."
2.0 REGULATORY EVALUATION
The NRC staff reviewed the proposed changes to eliminate TS second completion times against the criteria of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36 and the precedent as established in NUREG-1433, "Standard Technical Specifications (STS), General Electric Plants, BWRl4," Revision 3. Section 182a of the Atomic Energy Act (the Act) requires applicants for nuclear power plant operating licenses to include TSs as part of the license.
These TSs are derived from the plant safety analyses. In 10 CFR 50.36, the NRC established its regulatory requirements related to the content of TSs. In accordance with 10 CFR 50.36(c)(3), Surveillance Requirements (SRs) are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. The proper use and application of SR frequency requirements are described in Section 1.4 of the PBAPS Units 2 and 3 TS.
A second completion time was included in the STS for certain Required Actions to establish a limit on the maximum time allowed for any combination of conditions that result in a single continuous failure to meet the LCO. The intent of the second completion time was to preclude entry into and out of the actions for an indefinite period of time without meeting the LCO. The second completion time provides a limit on the amount of time that an LCO would not be met for various combinations of conditions.
On June 20,2005 (ADAMS Accession No. ML051860296) the commercial nuclear electrical power generation industry owners group TSTF submitted a proposed change, TSTF-439, Revision 2, to the STS on behalf of the industry (TSTF-439, Revisions 0 and 1, were prior draft iterations). TSTF-439, Revision 2, was approved by the !\\IRC in a letter dated January 11, 2006, to the TSTF (ADAMS Accession No. ML060120272). TSTF-439, Revision 2, deletes the second completion times from the affected Required Actions from the STSs.
3.0 TECHNICAL EVALUATION
3.1 Proposed TS Changes
A revision to TS Example 1.3-3 is proposed to remove the second completion time for Required Actions A.1 and B.1 and replace the discussion in the example with a discussion on procedural limits for failing to meet the LCO. In accordance with TSTF-439, Revision 2, and consistent with the changes to TS Example 1.3-3, the following changes to the PBAPS Unit 2 and 3 TSs are also proposed:
- 3
- The second completion times associated with TS 3.1.7, "Standby Liquid Control (SLC)
System," Required Actions A.2 and B.1, which state, "AND 10 days from the discovery of failure to meet the LCO," are being deleted.
Required Action A.3, which states, "AND 14 days from the discovery of failure to meet LCO 3.8.1.a or b," is being deleted.
- The second completion times associated with TS 3.8.7, "Distribution Systems Operating," Required Actions C.1 and 0.1, which state, "AND 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from the discovery of failure to meet LCO 3.8.7.a," are being deleted.
3.2 Evaluation Additional secondary completion times (such as limits on the period of time from discovery of the failure to meet the LCO) were specified for these instances to prevent repeated entry and exit from alternating TS Required Actions. Administrative controls will replace second completion times as described in the licensee's supplemental letter dated January 19, 2010. In addition, two programs provide a strong disincentive to licensees continuing operation with alternating Required Actions as described above. These programs are the Maintenance Rule program and the Reactor Oversight Process (ROP).
The licensee's application states the following regarding the Maintenance Rule:
Under 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance. The risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed maintenance is acceptable.
Prior to 10 CFR 50.65, TSs were the primary rules governing operations, including what equipment must normally be in service, how long equipment can be out of service, compensatory actions, and surveillance testing to demonstrate equipment readiness. The goal of TSs is to provide adequate assurance of the availability and reliability of equipment needed to prevent, and if necessary mitigate, accidents and transients. The Maintenance Rule shares this goal and operates through a dynamic and comprehensive process.
- 4 10 CFR 50.65 assesses and manages inoperable equipment; however, the rule also considers all inoperable risk-significant equipment. Under the TSs, the Completion Time for one system within an LCO is not generally affected by inoperable equipment in another LCO. However, the second completion time influenced the Completion Time for one system based on the condition of another system, but only if the two systems were required by the same LCO.
Plant Maintenance Rule programs implement risk-based configuration management programs that augment the deterministic Completion Times in the TSs. The NRC Resident Inspectors also monitor the licensee's Corrective Action process and could take action if the licensee's maintenance program allowed the systems required by a single LCO to become concurrently inoperable multiple times. The performance and condition monitoring activities required by 10 CFR 50.65 identify maintenance practices that would result from multiple entries into the Actions of the TSs which contribute to unacceptable unavailability of these SSCs.
The licensee's application states the following regarding the Rap:
NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," describes the tracking and reporting of performance indicators to support the NRC's Reactor Oversight Process (RaP). The NEI document is endorsed by RIS [Regulatory Information Summary] 2001-11, "Voluntary Submission Of Performance Indicator Data." NEI 99-02, Section 2.2 describes the Mitigating Systems Cornerstone. NEI 99-02 specifically addresses emergency AC
[alternating current] Sources (which encompasses the AC Sources Distribution System LCOs). Extended unavailability due to multiple entries into the ACTIONS would affect the NRC's evaluation of the licensee's performance under the Rap.
The objective of the cornerstone is to monitor the availability, reliability, and capability of systems that mitigate the effects of initiating events to prevent core damage. Licenses also reduce the likelihood of reactor accidents by maintaining the availability and reliability of mitigating systems. Mitigating systems include those systems associated with safety injection, decay heat removal, and their support systems, such as emergency AC power systems (which encompasses the AC Sources Distribution System LCOs, as noted by the licensee), and the auxiliary feedwater system. Inputs to the mitigating systems cornerstone include both inspection procedures and performance indicators to ensure that all Rap objectives are being met. Satisfactory licensee performance within the mitigation systems Rap cornerstone prOVides reasonable assurance in monitoring the inappropriate use of TS condition completion times.
NRC inspection findings for each plant are documented in inspection reports in accordance with Inspection Manual Chapter (IMC) 0612 and summarized in Plant Issues Matrices. Inspection findings are evaluated using the significance determination process in accordance with IMC 0609 to evaluate the safety significance of the findings.
TS Example 1.3-3 is revised to eliminate the second completion time for Required Actions A.1 and B.1 and to replace the discussion regarding second completion time with the following:
It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the
- 5 LCD. However, doing so would be inconsistent with the basis of the completion times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCD. These administrative controls shall ensure that the completion times for those Conditions are not inappropriately extended.
The licensee's supplement dated January 19, 2010, states that Exelon procedure OP-PB-108-104, "Regulatory Compliance Action Logs," will be revised to incorporate a requirement to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the TS LCD and to prohibit inappropriate extension of condition completion times. A requirement is included in Section 3, "Implementation Requirements," of the NRC amendments associated with this SE to ensure that the proposed procedure change is incorporated coincident with the licensee's implementation of the amendments.
The second completion time associated with TS 3.1.7, "Standby Liquid Control (SLC) System,"
Required Actions A.2 and B.1 which states, "And 10 days from the discovery of failure to meet LCD," is also being deleted. It is important to note that the second completion time issue only applies if the LCD is not met for a continuous time period. If the LCD requirements are met, even for a short period of time, the second completion time issue does not apply. That is, an LCD could be exited upon declaring equipment operable, and then re-entered, thus undermining the intent of the second completion time by avoiding the limits of the second completion time altogether.
TS 3.8.1, "AC Sources - Operating," has a 7-day Completion Time for one required offsite circuit inoperable (Condition A) and a 14-day Completion Time for one diesel generator inoperable (Condition B). Condition E has a 12-hour Completion Time for both one required offsite circuit inoperable and one diesel generator inoperable (both Condition A and B inoperable). Condition A has a second completion time of "14 days from discovery of failure to meet LCD 3.8.1.a or b." If Condition A or B is entered, and before the applicable inoperable system is restored, the other Condition is entered, then Condition E applies. Should either inoperable Condition be restored, that Condition and Condition E is exited. The second completion time is limiting, if repetitive entry into the previously restored conditions results in the LCD not being met for an extended period of time.
TS 3.8.7, "Distribution Systems - Operating," has an 8-hour Completion Time for one AC electrical power distribution subsystem inoperable (Condition C), and a 2-hour Completion Time for one direct current (DC) electrical power distribution subsystem inoperable (Condition D).
Conditions C and D both have a second completion time of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from discovery of a failure to meet LCD 3.8.7.a. The second completion time limits repetitive entry into previously restored conditions that would result in the LCD not being met for an extended period of time.
The NRC staff finds that multiple, continuous entries into TS conditions, without meeting the LCD, will be adequately controlled by the licensee's administrative controls and configuration risk management programs, which were implemented to meet the requirements of the Maintenance Rule. In addition, the NRC staff finds that assessment of the licensee's
- 6 performance within the mitigation systems ROP cornerstone provides reasonable assurance in monitoring the inappropriate use of TS condition completion times.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The NRC staff has determined that the amendments change requirements with respect to installation or use of a facility's components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (74 FR 20744). The changes discussed in this safety evaluation meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the publjc will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: V. Cusumano C. Schulten Date: July 30, 2010
M. Pacilio
- 2 All work is complete on TAC Nos. MD9449 and MD9450. Accordingly, these TAC Nos. will be closed. A copy of our Safety Evaluation is enclosed and a Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/raJ John D. Hughey, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278
Enclosures:
- 1. Amendment No. 277 to Renewed DPR-44
- 2. Amendment No. 280 to Renewed DPR-56
- 3. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:
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