ML110970067

License Amendment Request to Revise Operability Requirements and Actions for RCS Leakage Instrumentation

ML110970067
Person / Time
Site:	Peach Bottom
Issue date:	04/06/2011
From:	David Helker Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML110970067 (25)

Text

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ExelonWey Ket netS Square, S419348 10 CFR 50.90 April 6, 201 1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 USNRC Docket Nos, 50-277 and 50-278

Subject:

License Amendment Request to Revise Operability Requirements and Actions for RCS Leakage Instrumentation

References:

1.

TSTF-514-A, Revision 3, Revised BWR Operability Requirements and Actions for RCS Leakage Instrumentation, dated November 24, 2010.

2.

Notice of Availability of the Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation, dated December 17, 2010.

In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, Exelon Generation Company, LLC (EGC) requests an amendment to the Technical Specifications (TS) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.

The proposed amendment modifies the Required Actions to be taken when the atmospheric gaseous radioactivity monitor is the only operable leakage detection instrument. The modified Required Actions require additional, more frequent monitoring of other Reactor Coolant System (RCS) leakage indications and provide appropriate time to restore another instrument to Operable status. This change is consistent with the U.S. Nuclear Regulatory Commission (USNRC) approved Safety Evaluation on Technical Specification Task Force (TSTF) Traveler, TSTF-514-A, Revision 3, Revised BWR Operability Requirements and Actions for RCS Leakage Instrumentation dated November 24, 2010 (Reference 1), as made available in the Federal Register on December 17, 2010 (Reference 2). of this submittal provides a description of the proposed change, the requested confirmation of applicability, plant specific verifications, and variations in the proposed PBAPS TS changes from the approved TSTF-51 4-A, Revision 3 (Reference 1). Attachment 2 provides the existing TS page markups showing the proposed changes. Attachment 3 provides the associated TS Bases markups for information only.

The proposed changes have been reviewed by the PBAPS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.

10 CFR 50.90 April 6, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 USNRC Docket Nos. 50-277 and 50-278

Subject:

License Amendment Request to Revise Operability Requirements and Actions for RCS Leakage Instrumentation

References:

1.

TSTF-514-A, Revision 3, "Revised BWR Operability Requirements and Actions for RCS Leakage Instrumentation," dated November 24, 2010.

2.

Notice of Availability of the Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation,"

dated December 17, 2010.

In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to the Technical Specifications (TS) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.

The proposed amendment modifies the Required Actions to be taken when the atmospheric gaseous radioactivity monitor is the only operable leakage detection instrument. The modified Required Actions require additional, more frequent monitoring of other Reactor Coolant System (RCS) leakage indications and provide appropriate time to restore another instrument to Operable status. This change is consistent with the U.S. Nuclear Regulatory Commission (USNRC) approved Safety Evaluation on Technical Specification Task Force (TSTF) Traveler, TSTF-514-A, Revision 3, "Revised BWR Operability Requirements and Actions for RCS Leakage Instrumentation" dated November 24, 2010 (Reference 1), as made available in the Federal Register on December 17, 2010 (Reference 2). of this submittal provides a description of the proposed change, the requested confirmation of applicability, plant specific verifications, and variations in the proposed PBAPS TS changes from the approved TSTF-514-A, Revision 3 (Reference 1). Attachment 2 provides the existing TS page markups showing the proposed changes. Attachment 3 provides the associated TS Bases markups for information only.

The proposed changes have been reviewed by the PBAPS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.

U.S. Nuclear Regulatory Commission April 6,2011 Page 2 EGC requests approval of the proposed amendment by April 6, 2012. Once approved, the amendment shall be implemented within 60 days.

There are no regulatory commitments contained in this letter.

In accordance with 10 CFR 50.91, Notice for public comment; State consultation, paragraph (b), EGC is notifying the Commonwealth of Pennsylvania of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

Should you have any questions concerning this letter, please contact Ms. Wendy E. Croft at (610> 765-5726.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 6th day of April2011.

Respectfully, David P. Helker Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1.

Evaluation of Proposed Changes 2.

Markup of Technical Specifications Pages 3.

Markup of Technical Specifications Bases Pages (For Information Only) cc:

USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS R. ft Janati, Bureau of Radiation Protection S. T. Gray, State of Maryland U.S. Nuclear Regulatory Commission April 6, 2011 Page 2 EGC requests approval of the proposed amendment by April 6, 2012. Once approved, the amendment shall be implemented within 60 days.

There are no regulatory commitments contained in this letter.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), EGC is notifying the Commonwealth of Pennsylvania of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

Should you have any questions concerning this letter, please contact Ms. Wendy E. Croft at (610) 765-5726.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 6th day of April 2011.

Respectfully, David P. Helker Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1.

2.

3.

Evaluation of Proposed Changes Markup of Technical Specifications Pages Markup of Technical Specifications Bases Pages (For Information Only) cc:

USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS R. R. Janati, Bureau of Radiation Protection S. T. Gray, State of Maryland

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(.11 ATTACHMENT 1 Evaluation of Proposed Changes Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56

Subject:

Revise Operability Requirements and Actions for RCS Leakage Instrumentation 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

Subject:

Revise Operability Requirements and Actions for RCS Leakage Instrumentation 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

Revise Operability Requirements and Actions for RCS Leakage Instrumentation : Evaluation of Proposed Changes Page 1 of 4 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Renewed Operating Licenses DPR-44 and DPR 56 for Peach Bottom Atomic Power Station (PBAPS) Units 2 and 3, respectively.

The proposed changes would revise the Operating Licenses to modify the Required Actions to be taken when the atmospheric gaseous radioactivity monitor is the only operable instrument.

The modified Required Actions require additional, more frequent monitoring of other Reactor Coolant System (RCS) leakage indications and provide appropriate time to restore another instrument to Operable status. This change is consistent with the U.S. Nuclear Regulatory Commission (USNRC) approved Safety Evaluation on Technical Specification Task Force (TSTF) Traveler, TSTF-514-A, Revision 3, Revised BWR Operability Requirements and Actions for RCS Leakage Instrumentation dated November 24, 2010 (Reference 6.1), as referenced in the Federal Register on December 17, 2010 (Reference 6.2).

Variations from the USNRC-approved TSTF-514-A, Revision 3 are detailed in Section 3.0 of this submittal.

2.0 DETAILED DESCRIPTION The background for this application is stated in the referenced model safety evaluation in the USNRCs Federal Register Notice of Availability published on December 17, 2010 and TSTF 514-A, Revision 3.

Consistent with NRC-approved TSTF-514-A, Revision 3 the proposed changes are as follows:

Technical Specification (TS) Limiting Condition for Operation (LCO) 3.4.5, RCS Leakage Detection Instrumentation is revised to add Required Actions applicable when the atmospheric gaseous radioactivity monitor is the only Operable instrument (i.e., all other monitoring instruments are inoperable). The proposed Required Actions require analyzing grab samples of the primary containment atmosphere and monitoring RCS leakage using administrative means every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and restoring another instrument to Operable status within 7 days.

The TS Bases are revised to clearly define the RCS leakage detection instrumentation Operability requirements in the LCO Bases and to eliminate discussion from the TS Bases that could be erroneously construed as Operability requirements. The TS Bases are also revised to reflect the changes to the TS and to more accurately reflect the existing TS.

NOTE: Proposed revisions to the TS Bases are also included in this application for information only. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.

3.0 TECHNICAL EVALUATION

Exelon Generation Company, LLC, (EGC) has reviewed the Federal Register Notice of Availability dated December 17, 2010. This review also included the referenced information provided in TSTF514-A, Revision 3. EGC has concluded that the justifications presented in the TSTF proposal and the Federal Register Notice of Availability prepared by the USNRC staff are applicable to PBAPS, Units 2 and 3, with the variations noted below, and justify this amendment for the incorporation of the changes to the corresponding TS.

Revise Operability Requirements and Actions for RCS Leakage Instrumentation : Evaluation of Proposed Changes Page 1 of 4 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Renewed Operating Licenses DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS) Units 2 and 3, respectively.

The proposed changes would revise the Operating Licenses to modify the Required Actions to be taken when the atmospheric gaseous radioactivity monitor is the only operable instrument.

The modified Required Actions require additional, more frequent monitoring of other Reactor Coolant System (RCS) leakage indications and provide appropriate time to restore another instrument to Operable status. This change is consistent with the U.S. Nuclear Regulatory Commission (USNRC) approved Safety Evaluation on Technical Specification Task Force (TSTF) Traveler, TSTF-514-A, Revision 3, "Revised BWR Operability Requirements and Actions for RCS Leakage Instrumentation" dated November 24, 2010 (Reference 6.1), as referenced in the Federal Register on December 17, 2010 (Reference 6.2).

Variations from the USNRC-approved TSTF-514-A, Revision 3 are detailed in Section 3.0 of this submittal.

2.0 DETAILED DESCRIPTION The background for this application is stated in the referenced model safety evaluation in the USNRC's Federal Register Notice of Availability published on December 17, 2010 and TSTF-514-A, Revision 3.

Consistent with NRC-approved TSTF-514-A, Revision 3 the proposed changes are as follows:

Technical Specification (TS) Limiting Condition for Operation (LCO) 3.4.5, "RCS Leakage Detection Instrumentation" is revised to add Required Actions applicable when the atmospheric gaseous radioactivity monitor is the only Operable instrument (Le., all other monitoring instruments are inoperable). The proposed Required Actions require analyzing grab samples of the primary containment atmosphere and monitoring RCS leakage using administrative means every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and restoring another instrument to Operable status within 7 days.

The TS Bases are revised to clearly define the RCS leakage detection instrumentation Operability requirements in the LCO Bases and to eliminate discussion from the TS Bases that could be erroneously construed as Operability requirements. The TS Bases are also revised to reflect the changes to the TS and to more accurately reflect the existing TS.

NOTE: Proposed revisions to the TS Bases are also included in this application for information only. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.

3.0 TECHNICAL EVALUATION

Exelon Generation Company, LLC, (EGC) has reviewed the Federal Register Notice of Availability dated December 17, 2010. This review also included the referenced information provided in TSTF-514-A, Revision 3. EGC has concluded that the justifications presented in the TSTF proposal and the Federal Register Notice of Availability prepared by the USNRC staff are applicable to PBAPS, Units 2 and 3, with the variations noted below, and justify this amendment for the incorporation of the changes to the corresponding TS.

Revise Operability Requirements and Actions for RCS Leakage instrumentation : Evaluation of Proposed Changes Page 2 of 4 Additional reviews have determined that the proposed changes do not require any exemption or relief from regulatory requirements, other than the Technical Specifications, and do not affect conformance to any General Design Criteria differently than described in the UFSAR.

PBAPS, Units 2 and 3 are Improved Standard Technical Specifications (ISTS) plants; however, their TSs differ from the BWR/4 ISTS used as the TS reference/markup in TSTF-514-A, Revision 3. A list is provided below of the variations in the proposed PBAPS TS changes from the approved TSTF-514-A, Revision 3:

The proposed TSTF-514-A Condition [D] is applicable when the gaseous primary containment atmospheric radioactivity monitor is the only available instrument. This is equivalent to the current PBAPS TS 3.4.5 Condition A. Therefore, no new Condition was proposed for the PBAPS TS.

The PBAPS TS 3.4.5 Condition As Required Actions requires restoration of the drywell sump monitoring system within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the gaseous primary containment atmospheric radioactivity monitor is the only available instrument. The proposed modification to PBAPS TS 3.4.5 Condition As Required Actions allows operation of the plant with the drywell sump monitoring system inoperable for 7 days with 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> compensatory grab samples of the primary containment atmosphere and 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> administrative monitoring of RCS leakage. A review of past operating experience from 1/1/2006 to 2/11/2011 at PBAPS Units 2 and 3 identified that TS 3.4.5 Action A.1 was not entered during the applicable modes (1, 2, and 3).

Although the proposed change to the PBAPS TS is an increase in the amount of time the plant is allowed to operate with the drywell floor drain sump flow monitoring system inoperable, the change adds both 12-hour compensatory grab samples of the primary containment atmosphere and 12-hour administrative monitoring of RCS leakage, is consistent with the approved TSTF-514-A intent, and has operating experience to suggest it will be an infrequently entered Action statement.

The proposed TS Bases have been edited from the proposed ISTS changes to reflect the PBAPS configuration, which has only the gaseous primary containment atmospheric radioactivity monitor, as opposed to the ISTS which has both particulate and gaseous primary containment atmospheric radioactivity monitors.

These changes to the TSTF-514-A for the PBAPS submittal have been evaluated in the PBAPS-specific No Significant Hazards Consideration determination in Section 4.3 of this submittal.

The only variations or deviations in EGCs proposal have been delineated above. The remainder of the EGC proposed changes are consistent with the TS changes described in the Federal Register Notice of Availability dated December 17, 2010 or the referenced information provided in TSTF514-A, Revision 3.

4.0 REGULATORY EVALUATION

4.1 Alicable Reciulatory Reciuirements / Criteria A description of these proposed changes and their relationship to applicable regulatory requirements and guidance was provided in the December 17, 2010 Federal Register Notice of Availability referenced information in TSTF514-A, Revision 3.

Revise Operability Requirements and Actions for RCS Leakage Instrumentation : Evaluation of Proposed Changes Page 2 of 4 Additional reviews determined that the proposed changes do not require any exemption or relief from regulatory requirements, other than the Technical Specifications, and do not affect conformance to any General Design Criteria differently than described in the UFSAR.

PBAPS, Units 2 and 3 are Improved Standard Technical Specifications (ISTS) plants; however, their TSs differ from the BWR/4 ISTS used as the TS reference/markup in TSTF-514-A, Revision A list is provided below of the variations in the proposed PBAPS TS changes from the approved TSTF-514-A, Revision 3:

The proposed TSTF-514-A Condition [0] is applicable when the gaseous primary containment atmospheric radioactivity monitor is the only available instrument. This is equivalent to the current PBAPS TS 3.4.5 Condition A. Therefore, no new Condition was proposed for the PBAPS TS.

The PBAPS TS 3.4.5 Condition A's Required Actions requires restoration of the drywell sump monitoring system within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the gaseous primary containment atmospheric radioactivity monitor is the only available instrument. The proposed modification to PBAPS TS 3.4.5 Condition A's Required Actions allows operation of the plant with the drywell sump monitoring system inoperable for 7 days with 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> compensatory grab samples of the primary containment atmosphere and 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> administrative monitoring of RCS leakage. A review of past operating experience from 1/1/2006 to 2/11/2011 at PBAPS Units 2 and 3 identified that TS 3.4.5 Action A.1 was not entered during the applicable modes (1,2, and 3).

Although the proposed change to the PBAPS TS is an increase in the amount of time the plant is allowed to operate with the drywell floor drain sump flow monitoring system inoperable, the change adds both 12-hour compensatory grab samples of the primary containment atmosphere and 12-hour administrative monitoring of RCS leakage, is consistent with the approved TSTF-514-A intent, and has operating experience to suggest it will be an infrequently entered Action statement.

The proposed TS Bases have been edited from the proposed ISTS changes to reflect the PBAPS configuration, which has only the gaseous primary containment atmospheric radioactivity monitor, as opposed to the ISTS which has both particulate and gaseous primary containment atmospheric radioactivity monitors.

These changes to the TSTF-514-A for the PBAPS submittal have been evaluated in the PBAPS-specific No Significant Hazards Consideration determination in Section 4.3 of this submittal.

The only variations or deviations in EGC's proposal have been delineated above. The remainder of the EGC proposed changes are consistent with the TS changes described in the Federal Register Notice of Availability dated December 17, 2010 or the referenced information provided in TSTF-514-A, Revision 3.

4.0 REGULATORY EVALUATION

4.1 Applicable Requlatory Requirements / Criteria A description of these proposed changes and their relationship to applicable regulatory requirements and guidance was provided in the December 17, 2010 Federal Register Notice of Availability referenced information in TSTF-514-A, Revision 3.

Revise Operability Requirements and Actions for RCS Leakage Instrumentation : Evaluation of Proposed Changes Page 3 of 4 4.2 Precedent This change is consistent with the U.S. Nuclear Regulatory Commission (USNRC) approved Safety Evaluation on Technical Specification Task Force (TSTF) Traveler, TSTF-51 4-A, Revision 3, Revised BWR Operability Requirements and Actions for RCS Leakage Instrumentation dated November 24, 2010, as referenced in the Federal Register Notice of Availability on December 17, 2010.

4.3 No Significant Hazards Consideration Determination In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, Exelon Generation Company, LLC (EGC) requests an amendment to the Technical Specifications (TS) for Peach Bottom Atomic Power Station, Units 2 and 3. The proposed amendment modifies the Required Actions to be taken when the atmospheric gaseous radioactivity monitor is the only operable instrument. The modified Required Actions require additional, more frequent monitoring of other Reactor Coolant System (RCS) leakage indications and provide appropriate time to restore another instrument to Operable status.

EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1.

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes clarify the Operability requirements for the RCS leakage detection instrumentation and modify the time allowed for the plant to operate when the only Operable RCS leakage detection instrumentation monitor is the atmospheric gaseous radiation monitor. The monitoring of RCS leakage is not a precursor to any accident previously evaluated. The monitoring of RCS leakage is not used to mitigate the consequences of any accident previously evaluated. Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes clarify the Operability requirements for the RCS leakage detection instrumentation and modify the time allowed for the plant to operate when the only Operable RCS leakage detection instrumentation monitor is the atmospheric gaseous radiation monitor. The proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Revise Operability Requirements and Actions for RCS Leakage Instrumentation : Evaluation of Proposed Changes Page 3 of4 4.2 This change is consistent with the U.S. Nuclear Regulatory Commission (USNRC) approved Safety Evaluation on Technical Specification Task Force (TSTF) Traveler, TSTF-514-A, Revision 3, "Revised BWR Operability Requirements and Actions for RCS Leakage Instrumentation" dated November 24, 2010, as referenced in the Federal Register Notice of Availability on December 17, 2010.

4.3 No Significant Hazards Consideration Determination In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to the Technical Specifications (TS) for Peach Bottom Atomic Power Station, Units 2 and 3. The proposed amendment modifies the Required Actions to be taken when the atmospheric gaseous radioactivity monitor is the only operable instrument. The modified Required Actions require additional, more frequent monitoring of other Reactor Coolant System (RCS) leakage indications and provide appropriate time to restore another instrument to Operable status.

EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes clarify the Operability requirements for the RCS leakage detection instrumentation and modify the time allowed for the plant to operate when the only Operable RCS leakage detection instrumentation monitor is the atmospheric gaseous radiation monitor. The monitoring of RCS leakage is not a precursor to any accident previously evaluated. The monitoring of RCS leakage is not used to mitigate the consequences of any accident previously evaluated. Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes clarify the Operability requirements for the RCS leakage detection instrumentation and modify the time allowed for the plant to operate when the only Operable RCS leakage detection instrumentation monitor is the atmospheric gaseous radiation monitor. The proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Revise Operability Requirements and Actions for RCS Leakage Instrumentation : Evaluation of Proposed Changes Page 4 of 4 3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed changes clarify the Operability requirements for the RCS leakage detection instrumentation and increase the time allowed for the plant to operate when the only Operable RCS leakage detection instrumentation monitor is the atmospheric gaseous radiation monitor from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 7 days. Increasing the amount of time the plant is allowed to operate with only the atmospheric gaseous radiation monitor Operable does not significantly decrease the margin of safety due to the addition of compensatory Required Actions to analyze grab samples of the primary containment atmosphere once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and monitor Reactor Coolant System leakage by administrative means once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The overall likelihood that an increase in RCS leakage will be detected before it potentially results in gross failure is maintained with the addition of the Required Actions. Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions 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.

5.0 ENVIRONMENTAL CONSIDERATION

EGC has reviewed the environmental evaluation included in the model safety evaluation provided in the December 17, 2010 Federal Register Notice of Availability referenced information in TSTF-51 4-A, Revision 3. ECG has concluded that the staffs findings presented in that evaluation are applicable to PBAPS, Units 2 and 3, and the evaluation is hereby incorporated by reference for this application.

6.0 REFERENCES

6.1 TSTF-514-A, Revision 3, Revised BWR Operability Requirements and Actions for RCS Leakage Instrumentation dated November 24, 2010.

6.2 Notice of Availability of the Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation, dated December 17, 2010.

Revise Operability Requirements and Actions for RCS Leakage Instrumentation : Evaluation of Proposed Changes Page 4 of 4 3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed changes clarify the Operability requirements for the RCS leakage detection instrumentation and increase the time allowed for the plant to operate when the only Operable RCS leakage detection instrumentation monitor is the atmospheric gaseous radiation monitor from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 7 days. Increasing the amount of time the plant is allowed to operate with only the atmospheric gaseous radiation monitor Operable does not significantly decrease the margin of safety due to the addition of compensatory Required Actions to analyze grab samples of the primary containment atmosphere once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and monitor Reactor Coolant System leakage by administrative means once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The overall likelihood that an increase in RCS leakage will be detected before it potentially results in gross failure is maintained with the addition of the Required Actions. Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public 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.

5.0 ENVIRONMENTAL CONSIDERATION

EGC has reviewed the environmental evaluation included in the model safety evaluation provided in the December 17, 2010 Federal Register Notice of Availability referenced information in TSTF-514-A, Revision 3. ECG has concluded that the staff's findings presented in that evaluation are applicable to PBAPS, Units 2 and 3, and the evaluation is hereby incorporated by reference for this application.

6.0 REFERENCES

6.1 TSTF-514-A, Revision 3, "Revised BWR Operability Requirements and Actions for RCS Leakage Instrumentation" dated November 24, 2010.

6.2 Notice of Availability of the Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation," dated December 17, 2010.

ATTACHMENT 2 Markup of Technical Specifications Pages Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 REVISED TECHNICAL SPECIFICATIONS PAGES 34-12 ATTACHMENT 2 Markup of Technical Specifications Pages Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 REVISED TECHNICAL SPECIFICATIONS PAGES 3.4-12

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Regimi red primary 13.1 Analyze grab samples Once per containment of primary 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> a tmo spheric mon i tori 119 con inment system inoperable.

atmosphere.

AND B.2 Restore required 30 days primary containment atmospheric monitoring system to OPERABLE status.

(continued)

PBAPS UNIT 2

3.4-12 Amendment No.

REACTOR COOLANT Y

r' n

r' t

LCD

.4.

llow nq RC o

RABL' on in r'LHnent ion flail be Dr'ywell ump moni ring tern; and tJ.

One hannl monitor nq n ainment tma r

qd eou APPLICABILITY:

ACTION CONDITION REQUIR D ACTION COMPLETION TIME A.

0rywe 11 ump manitarinq system i napE~rabl B.

ired primdry B.1 containment atmo ric monitoring system inaperabl B.2 PBAPS UNIT 2 Analy r b ampl of primary containment atmo phe Restore required primary containment atmo pheric monitoring sy tem to OPERABLE status.

3.4-12 On e per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 30 days (continued)

Amendment No. ~

CCC I eakage rrt-J ion Instrumentat inn 1

. S C.4 REAL FOR CODIAN F SYSTEM (CCC) 4.0 I 00 LOgO he to C F 1 ill I n t

imen Fl Eion ECU

.4.5 Fhn Coil OW rig RCS 1 er kiqo detecti on in; F rumenta t ion

ha 1 1

he OPERABLE:

a.

Dryweli sump monitoring system; and b.

One channel of primary containment atmospheric gaseous morn toring system.

APPI ICABTI

[ FY:

MODES 1,

2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Drywell sump

.1 star drywell sump monitoring system monitoring system t inoperable.

?

RABLE sttus INSEr B.

Regui ed primary 8.1 Analyze grab samples Once per contal nment of primary 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> atmospheric monitoring containment system inoperable, atmosphere.

AND B.2 Restore required 30 days pnrnary containment atmospheric monitoring system to OPERABLE status.

(continued)

PBAPS UNIT 3

3.4-12 Amendment No.

RC CDOLAN EM (

ion rn trumen

()n

,4, rumen a ion

.4.

nl 11 owi n RC OP I~AB ka ion in rument tion hall rywe11 ump monitoring em; nd I),

On moni h nne1 of primary containmen rinq tern.

atmo ric gaseou f\\PPLICAB rTY:

ACTIONS i~OO 1,

. and CONDITION REQUIRED ACTION COMPLETION TH1E A.

rywe 11 ump 1

~

24 I,ou,

!J R..

l.

\\_JuV

\\..

U JVV\\..

.JU'I-'

monitorinq system I'I0 Ilit 0' ; " g sy.) t ~ 111 t ~

inoperabl

~Ei,.-~

"U"uo.

B.

ired primary B.1 Analyze qrab samples Once per containment of primary 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> tmo ric monitoring containment 5Y tem inoperable.

atmosphere.

AND B.2 Restore required 30 days primary containment atmospheric monitoring system to OPERABLE status.

(continued)

PBAPS UNIT 3 3.4-12 Amendment No. ~

Insert I A.1 Analyze grab samples of the primary containment Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> atmosphere.

AND A.2 Monitor RCS LEAKAGE by administrative means.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND A.3 Restore drywell sump monitoring system to 7 days OPERABLE status.

Insert 1 A.1 Analyze grab samples of the primary containment Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> atmosphere.

A.2 Monitor ReS LEAKAGE by administrative means.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> A.3 Restore drywell sump monitoring system to OPERABLE status.

7 days

ATTACHMENT 3 Markup of Technical Specifications Bases Pages (For Information Only)

Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3.4-24 B 3.4-25 B 3.4-26 B 3.4-28 ATTACHMENT 3 Markup of Technical Specifications Bases Pages (For Information Only)

Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3.4-24 B 3.4-25 B 3.4-26 B 3.4-28

RE I

ikage DtoJ.

on InstrummH oi

[3

[.1.

3.d RH\\c [DR 411)1 ANt 3YSF[M (RCS) 3 LLS Oct lcakage [ieto:riori instrumentation

[IA St S BACKGROUND UFSAR Safety Design Bas (Ref.

1) regui res means (or detecting and, to the extent practical i dent i fyi rig the I oca ti on o t the source of OCt LEAKAGE.

Regu 1 a tory Guide

[.45 (Ref.

2) describes acceptable methods for so oct ing tec Li on systems.

Limits on EA AGE from the reactor cool ant pressure bnurmdary RCPB) are requl red so that appropriate action can be taken betore the integrity of the RCPB is impaired (Ref.

2).

Leakage detecti on systems for the RCS are provided to alert the operators when leakage rates above normal backgroun levels are detected and also to supply guantitative iNRT2_

measurement ot leakage rates.

The Bases for LLO 3.4.4, RCS Operational

LEAKAGE, discuss the limits on RCS LEAKAGE rates.

Systems for separating the LEAKAGE of an identified source from an unidentified source are necessary to provide prompt and guanti tati ye information to the operators to permit them to take immediate corrective action.

LEAKAGE from the RCPB inside the drywell is detected by at least one of two independently monitored variables, such as sump level changes and drywell gaseous radioactivity levels.

The primary means of quantifying LEAKAGE in the dryweli is the drywell floor drain sump monitoring system.

The drywell floor drain sump monitoring system monitors the LEAKAGE collected in the floor drain sump.

This unidentified LEAKAGE consists of LEAKAGE from control rod

drives, valve flanges or packings, Hoor drains, the Reactor Building Closed Cool ing Water System, and drywell air cooling unit condensate drains, and any LEAKAGE not collected in the drywell equipment drain sump.

An alternate to the drywell floor drain sump monitoring system is the drywell equipment drain sump monitoring

system, but only if the drywell floor drain sumiip is overflowing.

The dryweil equipment drain sump collects not only all leakage riot collected in the drywell floor drain

sump, but also any overflow from the drywell floor drain sump.

Therefore, if the drywell floor drain sump is (continued)

PBAPS UNIT 2

B 3.4-24 Revision No.

ka ion [n t r' IJ rnen i n

.4.

COOLANT Y rEM (RC d

i n [n rurnent tion r

(Ref.

1) ui mean r'

n pr'dcti al, jejenti inq the of RCS LEAKAGE.

ulatory cri s a bl method tion sy tems.

I

~15Ion~

Limit AGE from the rea tor coolant pre sure boundary (RCPB) are required 0 that appropriate a tion can be taken fo the in rity of th RCPB is impaired (Ref. 2).

Leakage detection sy terns for the RCS are provided to alert he 0

rat rs.when 1 akage rates above norma 1 bac ro~

1 1

are detected and 131 a u

ly quantitativ ~

measurement of leakage rates.

The Bases for LCO 3.4.4, "RCS rational LEAKAGE," discus the limits on RCS LEAKAGE rates.

KGROUND terns for eparating the LEAKAGE of an identified source from an unidentified ource are necessary to provide prompt and quantitative information to the operators to permit them to take immediate correctiv action.

LEAKAGE from the RCPS inside the drywell is detected by at 1

t one of two i dently monitored variables, such as ump level changes and drywell gaseous radioactivity levels.

The primary means of quantifying LEAKAGE in the drywell is the drywell floor drain sump monitoring system.

The drywell floor drain sump monitoring system monitors the LEAKAGE collected in the floor drain sump.

This unidentified LEAKAGE consists of LEAKAGE from control rod driv s, valve flanges or packings, floor drains, the Reactor Bui 1di ng Closed Cool i ng Water System, and drywell ai r cooling unit condensate drains, and any LEAKAGE not collected in the drywell equipment drain sump.

An alternate to the drywell floor drain sump monitoring system is the drywell equipment drain sump monitoring system, but only if the drywell floor drain sump is overflowing.

The drywell equipment drain sump collects not only all leakage not collected in the drywell floor drain sump, but also any overflow from the drywell floor drain urnp.

Trlerefore, if the drywell floor drain sump is PBAPS UNIT 2 8 3.4-24 Revision No.?

RES Leak 1(JP fltCtlOIl In trumpntation 4

H B 3.4 REACTOR COOLANT SYSTEM RCS)

B34.5 UGH Leakage Detection Instrumentiti on BASE H UlAR ThEety Do; ign Ia s

(Ref.

1) r?gui detecting find, to the extent practic:

location of the source of RCS LEAKAGE.

Guide 1.45 (Ret.

2) descrHbes dcceptabl so I ecti ng I oafr( (C ce ecti on systems.

Limits Ofl

AKAG rom the reactor cool ant pressure boundary REPO) are required so that anpropriate action can be taken botore the I ntegr I Ly of the RCPB is mpa I red (Ref.

2).

Leakage detect ion systems for the RCS are provi (led to alert 01 measurement of leakage rates. 4The Bases for LEO.3,4.4, RCS Ouerational

LEAKAGE, discuss the limits on RCS LEAKAGE r a I: e s.

Systems for separating the LEAKAGE of an identified source from an unidenti tied source are necessary to provide prompt and quantitative information to the operators to permit them to take immedi ate corrective acti on.

LEAKAGE from the RCPB inside the drywell is detected by at least one of two independently monitored variables, such as somp level changes and drywel 1

gaseous radioactivity levels.

the primary means of quanti ng LEAKAGE in the drywel I

is the drywell floor drain sump monitoring system.

The drywell floor drain sump monitoring system monitors LEAKAGE collected in the floor drain sump.

This unidentified LEAKAGE consists of LEAKAGE from control r

drives, valve flanges or packings, floor drains, the Re Building Closed Cooling Water System, and drywell air cooling unit condensate drains, and any LEAKAGE not collected in the drywell equipment drain sump.

An alternate to the drywell floor drain sump monitoring system is the drywell equipment drain sump monitoring

system, but only if the drywell floor drain sump is overflowing.

The dryweil equipment drain sump collects not only all leakage not collected in the drywell floor drain

sump, but also any overflow from the drywell floor drain sump.

Therefore, if the drywell floor drain sump is (rnnti niind)

BAG K C ROl I N I) re s ne Ins for i dent,) tying the Regul a tory e methods for the od actor PBAPS UNIT 3

B 3.4-24 Revision No.

k R

fOR COOLANT Y

EM (

SAC ROUND U

d 1

Gui 1

i n In rumen i n r

r he tems for eparating the LEAKAGE of an identified source from an unidentified sour are nary 0 provide prompt nd quantita iv in rmation to he rator to permit them tak immediate correctiv action.

LEAKAGE from the RCPB inside the drywell is detected by at 1 a t one of two i ly monitored vari bles, uch as ump level changes and drywell gaseous radioactivity levels.

fhe primary mean of quanti ing LEAKAGE in the drywell is th drywell floor drain ump monitoring sy tem.

Th drywell floor drain ump monitoring system monitors the LEAKAGE collected in the floor drain sump.

Thi unidentified LEAKAGE consists of LEAKAGE from control rod drives, valve flanges or packings, floor drains, the Reactor Building Closed Cooling Water stem, and drywell air cooling unit condensate drain, and any LEAKAGE not collected in the drywell equipment drain sump.

An alternate to the drywell floor drain ump monitoring system is the drywell equipment drain sump monitoring system, but only if the drywell floor drain sump is overflowing.

The drywell equipment drain sump collects not only all leakage not collected in the drywell floor drain sump, but also any overflow from the drywell floor drain sump.

Therefore, if the drywell floor drain sump is PBAPS UNIT 3 B 3.4-24 Revision No. ~

Insert 2 In addition to meeting the OPERABILITY requirements, the monitors are typically set to provide the most sensitive response without causing an excessive number of spurious alarms.

Insert 2 In addition to meeting the OPERABILITY requirements, the monitors are typically set to provide the most sensitive without causing an excessive number of spurious alarms.

PEG Ho koqe Detection fri t corneri ti tin overflowing to the 1 rywnl equi pment Ira n

sump, the dcvwnl i Hent Ira in cump non tori ng system can he used to bonn ty LLAKA(E.

Fri th F; condi Lion, oil LEAKAtE seasoned by the drywe Ii equi pment dci in sump moni tor F ng system assumed to be unident I Ii ed LEAKAGE.

Fine floor drain suinl[)

level indicators have swi tches that start and stop the suinip pumps when requl red.

If the suinp tills to the high high level

setpoint, an alarm sounds in the control

room, F rid i ci Li rig a

LEAKAGE rate in to the sump in excess of 50 gpm.

A fl ow t r a n s ii F f 1 00 r ci r a i n s u COil t r 0 1 ron m.

control room.

t to r I n t h e d F s c h a r go 1

rnp pumps provides flow The p u liPS C a n a 1 s o be inc of the drywell indication in the started from the The primary containment air monitoring system continuously moni tors the primary contai nmerrt atmosphere for ai rborne gaseous radioactivity.

A sudden significant increase of radioactivity, which may be attributed to RCPB steam or water

LEAKAGE, is annunciated in the control room.

b--1-rY cont&iement atmosphere gaseous radioactivit--

nt I fyIog -LE*K*iE of t e-tpoint *re rnooitord-ft r&s4-prw-within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Largcee-nges in L[AKA tes ar dcteed in p+/-pord-lly zorter times (Rcf.

App LI CABLE SAFETY ANALYSES A threat of significant compromise to the RCPB exists if the barrier conto ins a crack that is large enough to propagate rapidly.

LEAKAGE rate limits are set low enough to detect the LEAKAGE emitted from a single crack in the RCPB fReEs.

3

(

andj).

e-h-of th lekge detection oysters inisid h te w&Nl kt&eting LE**

than the establishod LEAKAGE rpte limt-The allowed LEAKAGE rates are well below the rates predicted for critical crack sizes (Ref.

6).

Therefore, these actions orovide adequate response before a significant break in the RCPB can occur.

RCS leakage detection instrumentation satisfies Criterion t

of the NRC Policy Statement.

(continued)

HA E

iIACKEFliJUNLi of 13

.I.

PBAPS UNIT 2

B 3.4-25 Revision No.

4Q-L k

n rn 11 u

i u pment rain

ump, ring n

u ondi tin,

11 LEA KAG in ump monitoring sy LEAKAGE.

o he (lrywell lowin uipmen r in qu nti L

KAGE.

he drywe II a

umed uni ov fhe floot~ din ump lev indi ator flav swi he tart nd top the ump pump when required.

If the ill the high high 11 point, an al rm ound h

trol r'CJorn, indi ting a LEAKAG rat into the of qpm.

[1 t

urnp n

urnp in A flow ransrnitter in rlf:: di charqe lin f the drywell floor drain ump pump provide flow indi ation in the ontrol room.

The pumps can al 0 be tarted from th control room.

fhe primary containment air monitoring sy tem continuou ly monitor the primary containment atmo re for airborne gaseou radioactivi A sudden significant increase of r diod tivity, whi h may attributed to RCPB team or water LEAKAGE, is annunciated in the control room.

~

APPLICAB SAFETY ANALYSES A threat of signifi ant compromise to the RCPB exists if the barri r contains a crack that is large enough to propagate rapidly.

LEAKAGE rate limits are set low enough to detect the LEAKAGE emi tted from a si ngl e crac kin the RCPB (Refs. ~

~

and..i).

Each of th~

leQkElg~ det~ctioli JysLellls irlside Lne-C!

~"Fll is des; gl'H~d vd th the capabi 1i ty of detecti Ag LEAKA&ez res,)

LIIal1 Lile establ isl1ed LEAIUs:GE 1 ~tel il'li ts.CL The allowed LEAKAGE rates are well below the rates predicted for critical crack sizes (Ref.

6),

Therefore, these actions provide adequate response before a significant break in the RCPB can occur.

RCS leakage detection instrumentation satisfies Criterion 1

of the NRC Policy Statement.

(continued)

PBAPS UNIT 2 B 3.4-25 Revision No. ~

RCS I

akage Detect.

on InstrumentaL ion f3 45 hAL IfALKGROUNI) ovtlowing to the drywel I equipment drain

sump, the drywel 1 continued) equi pment drain sinnp non i torinq system can be used to juanti ty LEAKAGE.

in this condi ton, il 1

lEAKAGE measured by the drywe 11 ego pment Oral n sump mnni tor iej system is i55Hfl1[d to he on I lent tied LEAKAGE.

the floor drain sump level nd i cators have swi tches thu t start and stop the sump pumps when required.

If the sump fills to the high high level

sotpoint, an alarm sounds in the control

room, iou ic1t,ing a

LEAKAGE rare into the sump in excess ot EU qpm.

A flow transmitter in the discharge line of the drywell floor drain sump pumps provides flow indication in the control

room, The pumps can also be started from the con t no 1 room.

The primary containment air moni toring system continuously mon i tors the primary con ti 3 nment atmosphere for a i rhorne gaseous radioactivity.

A sudden significant increase of radioactivity, which may be attributed to RCPB steam or water

LEAKAGE, is annunciated in the control room.

r}e--mary containment atmosphere cow; rodioactivi-t-rfii t-n4n-tj-s-s-tem is uol capable of iqiu-artti fyi n}

LLAKACE r-tes.

Al though the a 1 arm setpo lot I s set i n aeco cdnc w th R-e4-e-ence 3

tcr avoid recc i iog many unnecessary a Ia a-n-U the frequent resetting of the setpoin-t, the monitor

-t-ern is srsns-i-t+/-ve enough to indicte-is ood LEAKAG wtcs of I

gprn within

-1 hour.

Larger changes in LEAkA%

-tes wee detected in propu-r-t I onal ly shorter times (Ref.

3)--

APPLICABLE A threat of significant compromise to the RCPB exists if the SAFETY ANALYSES harrier contains a crack that is large enough to propagate rapidly.

LEAKAGE rate limits are set low enough to detect the LEAKAGE emitted from a single crack in the RCPB (Refs. /4 3 arid i Eih u the loukage detection systems irid q

e1l is designed with the capa1ity of detecting L[A s than the established LEAKAGE rate limit The allowed LEAKAGE rates are well below the rates predicted for critical crack sizes (Ref.

6).

Therefore, these actions provide adequate response before a significant break in the RCPB can occur.

RCS leakage detection instrumentation sati sTies Criterion 1

of the NRC Policy Statement.

(con t 3 no ed)

PBAPS UNIT 3

B 3.4-25 Revision No.

n KCROUN[J (i n 11 rol

room, of

() qprn.

A flow ransmi t r in di loor rain ump pump provi on t ro 1 r'oom.

Trle pumps ontrol room.

h t ump in ump in lin 0

he drywell indication in ttl t rted from the Th primary containment air monitoring sy tern continuously monitor the primary cont inment tmo re for airborne ga eou radioactivi A

udden ignifi ant increa e of radi ctivity, whi h may attributed to RCPB team or wa r LEAKAGe i

annunciated in the control room.

~

APPLICABLE A threat of ignifi nt compromi e to the RCPB exists if the SAFETY ANALYSE barri r contain a crack hat i large enough to propagate rapidly.

LEAKAGE rate limits are set low enough to detect the LEAKAGE emitted from a single crack in the RCPB (Refs. A=-@

/Y.')

ang,,)f).

Eaell of tile leakage deteeticil S)St~ITl3 ili3ide tll\\~S2-

~e.l.l is des i gned

'OI'i th the capabi 1i ty of detecti ng LEAKA8~

.eSG than the established LEAI<AGE pate lifftit~~

The allowed LEAKAGE rate are well below the rates predicted for critical crack izes (Ref. 6).

Therefore, these actions provide uate response before a significant break in the RCPB can occur.

RCS leakage detection instrumentation satisfies Criterion 1 of the NRC Policy Statement.

(continued)

PBAPS UNIT 3 B 3.4 25 Revision No. ~

k(,)

L 1dJO l)tct ion lnLrurrOa1.

cii B

31.0 RA,L S cit i iii Fty!T1 sump morn toring sys tern is requl red to quantify the unidenti Hod LEAKAGE from the REt.

Thus, for the system to be considered

OPERABLE, the system must he capable of measuring reactor coolant leakage.

Fhi s may he accomplished by use of the associated drywel I

sump How integrator, How r co rle r or the pump curves and drywri 1 I

sump pump out time Ihe system consists of a) the drywel]

floor drain suinp moni toring system, or 0) the drywel 1

equipment Ira in sum won i tor ing system, but only when the drywel 1 floor drain sompH overt 1 owing.

closer -exaimination of othc

-ctton systems }l be IN S Ei 1

APPLICABILITY In MODES H

2, and 3, leakage detection systems are required to be OPERABLE to support LEO 3.4.4.

Ehis Applicability is consistent with that for LCO 3.4.4.

ACTIONS (f 6 monitoring system inopera-b+/-ii, iu u1iTrT frm of sampI i nq ea-n th-tify eakage.

However, the primary containment itmusphori c radi cactI vi ty n+/-tr--

Hpr

+-d--frrdtcuttoirmP

&--I*.

to r i n orati on may conti nu for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Th 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CumpleL i un Time is acccptabl+/-a-3ed on eperating oxpcrio ivjilbl.

B.i arid B.2 With the gaseous primary contairlment atmospHeric monitoring channel inoperable, grab samples of the primary containment atmosphere must be taken arid analyzed for gaseous radioactivity to provide periodic leakage information.

Provided a

sample is obtained and analyzed once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the plant may be operated for up to 30 days to allow restoration of the required monitor.

(continued)

PBAPS UNIT 2

3 3.4-26 Revision No.

n t i Ofl n

r'urnr:n tin APPLICABILITY ACTION ui r'ed Trw for Ule rnu t pabl fhi may ccompli hed low in

rator, low urnp pump out ime.

loor drain ump ump loor drain In MODE

, and 3, leakage detection systems are required to be OPERABLE to upport LCD 3.4.4.

fhis Applicability is consi tent with that for LCD 3.4.4.

With the gaseous primary containment atmospheric monitoring channel inoperable, grab samples of the primary containment atmosphere must be taken and analyzed for gaseous radioactivity to provide periodic leakage information.

Provided a sample is obtained and analyzed once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the plant may be operated for up to 30 days to allow restoration of the required monitor.

PBAPS UNIT 2 B 3.4-26 Revision No *...fIl

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fhi may be hed ump flow in r,

flow urve and drywell ump pump out time.

)

he ejrywe 11 loor dra in ump or b) the drywell uipment drain ump but nly when drywell floor drain APPLICABILITY In MODES 1, 2, and 3, 1 akage detection systems are required to be OPERABLE to upport LCO 3.4.4.

Thi li bili is on i tent with that for LCO 3.4.4.

qual'1tifj' lcakdgc.

HO'i~e'lfer, the priFflary centail'lIi1Cllt

(?

dLlllospller Ie lddiudctivity IliOliitOI will plovide il,d;e~tiol! o~

chal'1gcs in 1Cd kage ~

~~

Wit I' t lie d I Y'evell SUIf!P ACTIONS Wi tli tile dl ywell

,UliiP 111011 i tor i 119 S.9 5tell!

i Ilopel abl~

ope r ~ t i 0 I i III Z'l}

COli til i Ue f 0 I 24 II CJ UI~.

f I it~

24 II 0uleuIIIp1eLl 0 I"'~

j

irflc is acccptable, bd~ed all opel atill9 expel iellce,<

COllsidel illy 110 otller metliod to qUdliti fy leaKage i,s"l" aVi'tilZ'ible.Q.

With the gaseous primary containment atmospheric monitoring channel inoperable, grab samples of the primary containment atmosphere must be taken and analyzed for gaseous radioactivity to provide periodic leakage information.

Provided a sample is obtained and analyzed once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the plant may be operated for up to 30 days to allow restoration of the required monitor.

PBAPS UNIT 3 B 3.4-26 Revision No. ~

Insert 3 This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide confidence that small amounts of unidentified LEAKAGE are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation.

The LCO requires two instruments to be OPERABLE.

Insert 4 The identification of an increase in unidentified LEAKAGE will be delayed by the time required for the unidentified LEAKAGE to travel to the drywell sump and it may take longer than one hour to detect a 1 gpm increase in unidentified LEAKAGE, depending on the origin and magnitude of the LEAKAGE. This sensitivity is acceptable for containment sump monitor OPERABILITY.

The reactor coolant contains radioactivity that, when released to the primary containment, can be detected by the gaseous primary containment atmospheric radioactivity monitor. Only one of the two detectors is required to be OPERABLE. A radioactivity detection system is included for monitoring gaseous activities because of its sensitivities and rapid responses to RCS LEAKAGE, but it has recognized limitations. Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel element cladding contamination or cladding defects.

If there are few fuel element cladding defects and low levels of activation products, it may not be possible for the gaseous primary containment atmospheric radioactivity monitor to detect a 1 gpm increase within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during normal operation. However, the gaseous primary containment atmospheric radioactivity monitor is OPERABLE when it is capable of detecting a 1 gpm increase in unidentified LEAKAGE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> given an RCS activity equivalent to that assumed in the design calculations for the monitors (Reference 6).

The LCO is satisfied when monitors of diverse measurement means are available. Thus, the drywell sump monitoring system, in combination with a gaseous primary containment atmospheric radioactivity monitor provides an acceptable minimum.

Insert 5 A.1, A.2, and A.3 With the drywell sump monitoring system inoperable, the only means of detecting LEAKAGE is the primary containment atmospheric gaseous radiation monitor. The primary containment atmospheric gaseous radiation monitor typically cannot detect a 1 gpm leak within one hour when RCS activity is low.

In addition, this configuration does not provide the required diverse means of leakage detection. Indirect methods of monitoring RCS leakage must be implemented. Grab samples of the primary containment atmosphere must be taken and analyzed and monitoring of RCS leakage by administrative means must be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to provide alternate periodic information.

Administrative means of monitoring RCS leakage include monitoring and trending parameters that may indicate an increase in RCS leakage. There are diverse alternative mechanisms from which appropriate indicators may be selected based on plant conditions.

It is not necessary to utilize all of these methods, but a method or methods should be selected considering the current plant conditions and historical or expected sources of unidentified leakage. The administrative methods are drywell pressure and temperature, Reactor Recirculation System pump seal Insert 3 This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide confidence that small amounts of unidentified LEAKAGE are detected in time to allow actions to place the plant in a condition, when RCS LEAKAGE indicates possible RCPB degradation.

The LCO requires two instruments to be OPERABLE.

Insert 4 The identification of an increase in unidentified LEAKAGE will be delayed by the time required for the unidentified LEAKAGE to travel to the drywell sump and it may take longer than one hour to detect a 1 gpm increase in unidentified LEAKAGE, depending on the origin and magnitude of the LEAKAGE. This sensitivity is acceptable for containment sump monitor OPERABILITY.

The reactor coolant contains radioactivity that, when released to the primary containment, can be detected by the gaseous primary containment atmospheric radioactivity monitor. Only one of the two detectors is required to be OPERABLE. A radioactivity detection system is included for monitoring gaseous activities because of its sensitivities and rapid responses to RCS LEAKAGE, but it has recognized limitations. Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel element cladding contamination or cladding defects. If there are few fuel element cladding defects and low levels of activation products, it may not be possible for the gaseous primary containment atmospheric radioactivity monitor to detect a 1 gpm increase within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during normal operation. However, the gaseous primary containment atmospheric radioactivity monitor is OPERABLE when it is capable of detecting a 1 gpm increase in unidentified LEAKAGE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> given an RCS activity equivalent to that assumed in the design calculations for the monitors (Reference 6).

The LCO is satisfied when monitors of diverse measurement means are available. Thus, the drywell sump monitoring system, in combination with a gaseous primary containment atmospheric radioactivity monitor provides an acceptable minimum.

Insert 5 A.1, A.2, and A.3 With the drywell sump monitoring system inoperable, the only means of detecting LEAKAGE is the primary containment atmospheric gaseous radiation monitor. The primary containment atmospheric gaseous radiation monitor typically cannot detect a 1 gpm leak within one hour when RCS activity is low. In addition, this configuration does not provide the required diverse means of leakage detection. Indirect methods of monitoring RCS leakage must be implemented. Grab samples of the primary containment atmosphere must be taken and analyzed and monitoring of RCS leakage by administrative means must be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to provide alternate periodic information.

Administrative means of monitoring RCS leakage include monitoring and trending parameters that may indicate an increase in RCS leakage. There are diverse alternative mechanisms from which appropriate indicators may be selected based on plant conditions. It is not necessary to utilize all of these methods, but a method or methods should be selected considering the current plant conditions and historical or expected sources of unidentified leakage. The administrative methods are drywell pressure and temperature, Reactor Recirculation System pump seal

pressure and temperature and motor cooler temperature indications, and Safety Relief Valves tailpipe temperature. These indications, coupled with the atmospheric grab samples, are sufficient to alert the operating staff to an unexpected increase in unidentified LEAKAGE.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval is sufficient to detect increasing RCS leakage. The Required Action provides 7 days to restore another RCS leakage monitor to OPERABLE status to regain the intended leakage detection diversity. The 7 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

and and motor cooler temperature indications, and Safety Relief Valves tailpipe temperature.

indications, coupled with the atmospheric grab samples, are sufficient to alert the operating staff to an unexpected increase in unidentified LEAKAGE.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval is sufficient to detect increasing RCS leakage. The Required Action provides 7 days to restore another RCS leakage monitor to OPERABLE status to regain the intended detection diversity. The 7 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

RL I

ikaqe

)eL(t lUll In,triilntit lUll BABE S BUeVE I LLANLL R

3.4.5.

U LOU I REM EU [B (continued)

[ii s

BR is for the performance of 1

CHANNEL FUNCTIONAL

[FBI of the requl red RCS leakage detection instrumentation.

The test ensures that the monitors can perform their function in She los red manner.

[he test aT so ver I H es the a) arm 0 tpo ii t and me) a Si ye accu ri cy of the i us t rumen t st r I nq.

lie Burvel 1 lance Frequency control led unler the Burvei 1 lance Frequency Control

Program,

[hi s SR i s for the per formance of a

CHANNEL CAL I BRAT ION of required leakage detection instrumentation channels.

The cal i brati on von fies the accuracy of the i nstrurnent string.

The Survei 11 once Frequency i s control led under the Surveillance Frequency Control Program.

REFERENCES 1.

UFSAR, Section 4.10.2.

2.

Regulatory Guide 1.45, GEAP-5620, Failure Behavior in ASTM A1O6B Pipes Containing Axial Through-Wall

Flaws, April 1968.

NUREG-75/067, Investigation and Evaluation of Cracking in Austenitic Stainless Steel Piping of Boiling Water Reactors, October

[975.

UFSAR, Section 4.10.4.

PBAPS UNIT 2

B 3.4-28 Revision No.

In r'

in.

nH::

i n in ram.

R i r

required RC I

ka ur that the man i

manner.

rhe tpoint and r I tiv file rv illan urv i 11 n

fhi R i for the performance of a CHANNEL CALIBRATION of required leakage detection in trumentation channels.

The calibration v rifi the a curacy 0

th in trument tring.

The Surv ill nce Frequency is controlled und r the urv illance Frequency Control Program.

REFERENCES 1.

UFSAR, Section 4.10.2.

latory Guide 1.45, ~ay 1973<~

GEAP-5620, "Failure Behavior in ASTM AI06B Pipes Containing Axial Through-Wall Flaws," April 1968.

NUREG-7 1067, "Investigation and Evaluation of Cracking in Austenitic Stainl ss Steel Piping of Boiling Water Reactors," October 1975.

UFSAR Section 4.10.4.

PBAPS UNIT 2 B 3.4-28 Revision No.r

I a kiqe He t in; t on I n s t riimn ti t on B

3.1.>

JR V E IL LA N C C H EQU I R EM ENT S (continued)

[his SR is for the performance of a

CHANNEL FUNCTIONAL TEST ot the requi red CCC leakage detection instrumentation.

The test ensures that the moni tors can perform their function in the desired manner, The test aHu verities the alarm

etpoint and relative accuracy ut the instrument string.

[lie Survei 1

ance Frequency is control led under the

)urvei ance trequency Control Program.

4CJ this SR is for the performance of a

CHANNEL CALIBRATION of requl red leakage detection instrumentation channels.

The calibration yen ties the accuracy of the instrument string.

The Surveillance Frequency is controlled under the Curve ill ance Frequency Cont rol Program.

REFERENCES I.

IJFSAR, Section 4.10.2.

2.

Regulatory Snide 1.45, 1.

UFSAR, 5-oction 4.lO.3n GEAP-5620, Failure Behavior in ASTM A1O6B Pipes Containing Axial Through-Wall Flaws, April 1968.

NUREG-75/067, Investigation and Evaluation of Cracking in Anstenitic Str3inleSs Steel Piping of Boiling Water Reactors, October 1975.

UFSAR, Section 4.10.4, PBAPS UNIT 3

B 3.4-28 Revision No.

ion rn umen al n B

in Th Surveillance urv ill n

F rforman of a CHANNEL CALIBRATION of t on in trumentation channels.

The the a uracy of the in trument tring.

requency is controlled under the uency Control Program.

REF RENC 1.

UFSAR, ion ul t ry Gui 4.10.2.

1.4

'j6) 19n£~

,~~~

~

{J)f:

GEAP 0,

If illlre Behavior in ASTM AI06B Pipes Can aining Axial Through-Wall Flaws," April 1968.

NUREG 75/067, IfInve tiqation and Evaluation of Cr eking in Au tenitic Stainless Steel Piping of Boilinq Wat r Reactor," October 1975.

UFSAR, Section 4.10.4.

PBAPS UNIT 3 B 3.4-28 Rev is i on No..J-'

• tC0fl UOIPOS NVSJfl

• 9 LVOSUI tL61 Aeii sweTsIS uopoejea ebeNBe] kiepunog OJflSS9Jd ;uepoo iopeeu, 0 UO!SIAeN 9 JGSUI Insert 6 Revision 0, "Reactor Coolant Pressure Boundary Leakage Detection Systems," May 1973.

Insert 7 6.

UFSAR, Section 4.10.3.2.