Text

License Amendment Request to Add LCO 3.0.8 on the Lnoperability of Snubbers Using the Consolidated Line Item Improvement Process
	ML12243A286
Person / Time
Site:	Peach Bottom
Issue date:	08/29/2012
From:	Jesse M; Exelon Generation Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	Download: ML12243A286 (28)
	v • d • e

10 CFR 50.90 August 29, 2012 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 Add LCO 3.0.8 on the lnoperability of Snubbers Using the Consolidated Line Item Improvement Process

References:

1. TSTF-372, Revision 4, "Addition of LCO 3.0.8, lnoperability of Snubbers,"

dated April 23, 2004.

2. Notice of Availability of Model Application Concerning Technical Specification Improvement to Modify Requirements Regarding the Addition of Limiting Condition for Operation 3.0.8 on the lnoperability of Snubbers Using the Consolidated Line Item Improvement Process, dated May 4, 2005 (70 FR 23252).

In accordance with the provisions of 10 CFR 50.90 Exelon Generation Company, LLC (EGC), is submitting a request for an amendment to the Technical Specifications (TS) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.

The proposed amendment would modify TS requirements for inoperable snubbers by adding Limiting Condition for Operation (LCO) 3.0.8. The change is consistent with NRC approved Revision 4 to Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-372, "Addition of LCO 3.0.8, lnoperability of Snubbers" (Reference 1).

The availability of this TS improvement was announced in the Federal Register on May 4, 2005 as part of the consolidated line item improvement process (Reference 2).

The proposed amendment has been reviewed by the PBAPS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the Exelon Quality Assurance Program. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides revised (clean) TS pages. provides a summary of the regulatory commitments made in this submittal. provides the existing TS Bases pages marked up to show the proposed change (for information only).

U.S. Nuclear Regulatory Commission August29,2012 Page 2 Exelon requests approval of the proposed License Amendments by August 29, 2013, with the amendment being implemented within 60 days.

In accordance with 10 CFR 50.91, a copy of this application is being provided to the Commonwealth of Pennsylvania.

Should you have any questions concerning this submittal, please contact Ms. Wendy E. Croft at (61 0) 765-5726.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 29th day of August 2012.

Respectfully, Director, Licensi a egulatory Affairs Exelon Generation Company, LLC Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes

3. Revised Technical Specification Pages .

4. Regulatory Commitments

5. Proposed Technical Specification Bases Changes (For Information Only) cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Senior Project Manager, PBAPS R. R. Janati, Bureau of Radiation Protection S. T. Gray, State of Maryland

ATTACHMENT 1 Description and Assessment Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56

LCO 3.0.8 on the lnoperability of Snubbers Using the CLIIP : Description and Assessment Page 1 of 4

1.0 DESCRIPTION

The proposed amendment would modify Technical Specifications (TS) requirements for inoperable snubbers by adding Limiting Condition for Operation (LCO) 3.0.8.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved lndustryffechnical Specification Task Force (TSTF) Standard Technical Specification (STS) change TSTF-372, Revision 4. The availability of this TS improvement was published in the Federal Register on May 4, 2005 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Exelon Generation Company, LLC (EGC) has reviewed the Model Safety Evaluation (SE) dated May 4, 2005 as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-372, Revision 4. EGC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Peach Bottom Atomic Power Station (PBAPS),

Units 2 and 3, and justify this amendment for incorporation of the changes to the PBAPS TS.

2.2 Optional Changes and Variations EGC is not proposing any variations or deviations from the TS changes described in the TSTF-372, Revision 4 or the NRC staff's Model SE dated May 4, 2005.

EGC proposes the following minor variations from the TS Bases changes described in the TSTF-372, Revision 4:

The Model SE, Section 3.1.2 provided in the Notice of Availability published in the Federal Register on May 4, 2005, contains restrictions, applicable to Boiling Water Reactor (BWR) plants, to prevent potentially high-risk configurations. The specific restrictions identified in the Model SE are being added to the proposed TS Bases for LCO 3.0.8.

The Model SE, Section 3.2, Item 1(e) provided in the Notice of Availability published in the Federal Register on May 4, 2005, contains the statement "LCO 3.0.8 does not apply to non-seismic snubbers." This does not appear to be captured in the implementation process of the approved TSTF-372, Revision 4. Therefore, EGC proposes to include this statement in the LCO 3.0.8 Bases (Attachment 5). Further guidance associated with the intent of this statement, as discussed in Section 3.0 of the Model SE and in TSTF-IG-05-03, Implementation Guidance for TSTF-372, Revision 4, "Addition of LCO 3.0.8, lnoperability of Snubbers," is also included in the proposed Bases for LCO 3.0.8 (Attachment 5).

These variations are insignificant with regard to ensuring proper application of TSTF-372, Revision 4 intent.

LCO 3.0.8 on the lnoperability of Snubbers Using the CLIIP : Description and Assessment Page 2 of 4 3.0 REGULATORY ANAL VSIS 3.1 No Significant Hazards Consideration Determination Exelon Generation Company, LLC (EGC) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No The proposed change allows a delay time before declaring supported Technical Specification (TS) systems inoperable when the associated snubber(s) cannot perform its required safety function. Entrance into Actions or delaying entrance into Actions is not an initiator of any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The consequences of an accident while relying on the delay time allowed before declaring a TS supported system inoperable and taking its Conditions and Required Actions are no different than the consequences of an accident under the same plant conditions while relying on the existing TS supported system Conditions and Required Actions. Therefore, the consequences of an accident previously evaluated are not significantly increased by this change. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No The proposed change allows a delay time before declaring supported TS systems inoperable when the associated snubber(s) cannot perform its required safety function.

The proposed change does 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 change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change allows a delay time before declaring supported TS systems inoperable when the associated snubber(s) cannot perform its required safety function.

The proposed change restores an allowance in the pre-Improved Standard Technical Specifications (ISTS) conversion TS that was unintentionally eliminated by the conversion. The pre-ISTS TS were considered to provide an adequate margin of safety for plant operation, as does the post-ISTS conversion TS. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

LCO 3.0.8 on the lnoperability of Snubbers Using the CLIIP : Description and Assessment Page 3 of 4 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.

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 proposed change will not be inimical to the common defense and security or to the health and safety of the public.

3.2 Verification and Commitments As discussed in the Model Application, Section 3.2, provided in the Notice of Availability published in the Federal Register on May 4, 2005 for this TS improvement, plant-specific verifications were performed as follows:

EGC proposes in this amendment for PBAPS, Units 2 and 3, a TS Bases for LCO 3.0.8 which provides guidance and details on how to implement the new requirements (see Attachment 5). LCO 3.0.8 will require that risk be managed and assessed. The proposed TS Bases states that while the Industry and NRC guidance on implementation of 10 CFR 50.65(a)(4), the Maintenance Rule, does not address seismic risk, LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative assessment of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function. EGC will revise the TS Bases as proposed above with implementation of the amendment.

PBAPS Units 2 and 3 have a TS Bases Control Program consistent with Section 5.5 of the STS.

In addition, as discussed in the Model SE, Section 3.1.2 provided in the Notice of Availability published in the Federal Register on May 4, 2005, the following restrictions, applicable to BWR plants, are provided to prevent potentially high-risk configurations (hereafter referred to as the

.. Tier 2 restrictions .. ). The specific information which describes how EGC proposes to ensure that operations at PBAPS, Units 2 and 3 will be in accordance with the Tier 2 requirements is provided below:

1. For BWR plants, one of the following two means of heat removal must be available when LCO 3.0.8.a is used:

a. At least one high pressure makeup path (e.g., using high pressure coolant injection (HPCI) or reactor core isolation cooling (RCIC) or equivalent) and heat removal capability (e.g., suppression pool cooling), including a minimum set of supporting equipment, not associated with the inoperable snubber(s), or

b. At least one low pressure makeup path (e.g., low pressure coolant injection (LPCI) or core spray (CS)) and heat removal capability (e.g., suppression pool cooling or shutdown cooling), including a minimum set of supporting equipment, not associated with the inoperable snubber(s).

LCO 3.0.8 on the lnoperability of Snubbers Using the CLIIP : Description and Assessment Page 4 of 4

2. When LCO 3.0.8.b is used at BWR plants, it must be verified that at least one success path exists, using equipment not associated with the inoperable snubber(s), to provide makeup and core cooling needed to mitigate Loss of Offsite Power (LOOP) accident sequences (i.e.

initiated by a seismically-induced LOOP event with concurrent loss of all safety system trains supported by the out-of service snubbers).

EGC has provided a regulatory commitment to satisfy the above requirements by ensuring the appropriate plant procedures and administrative controls will be revised with implementation of the amendment (Commitment 1, Attachment 4). Additionally, these requirements are documented in the proposed TS Bases (Attachment 5).

In addition to the Tier 2 restrictions, discussed above, Section 3.2, item 1(e), of the Model SE requires that appropriate plant procedures and administrative controls be used to implement the following restriction, described, and responded to by EGC below:

Every time the provisions of LCO 3.0.8 are used licensees will be required to confirm that at least one train (or subsystem) of systems supported by the inoperable snubbers would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads. LCO 3.0.8 does not apply to non-seismic snubbers. In addition, a record of the design function of the inoperable snubber (i.e., seismic vs. non-seismic), implementation of any applicable Tier 2 restrictions, and the associated plant configuration shall be available on a recoverable basis for staff inspection.

EGC has provided a regulatory commitment to satisfy the above requirement by ensuring the appropriate plant procedures and administrative controls will be revised with implementation of the amendment (Commitment 2, Attachment 4). Additionally, this requirement is documented in the proposed TS Bases (Attachment 5).

Finally, as required by 10 CFR 50.34(b), the Updated Final Safety Analysis Report (UFSAR)

"shall include information that describes the facility, presents the design bases and the limits on its operation, ... [emphasis added]:' EGC will revise the UFSAR with implementation of the amendment to describe the Tier 2 restrictions discussed above.

4.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

ATTACHMENT 2 Proposed Technical Specifications Pages Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 PROPOSED TECHNICAL SPECIFICATIONS PAGES 3.0-1 3.0-3

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 2 within 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months ;

b. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of continued PBAPS UNIT 2 3.0-1 Amendment No. *2-5-9

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other a icable ifications.

PBAPS UNIT 2 3.0 3 Amendment No. *2-1-Ef

LCO Applicabili 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicabili , except as provided in LCO 3.0.2 ane LCO 3.0.7.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 2 within 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months ;

b. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of continued PBAPS UNIT 3 3.0-1 Amendment No. *~

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

LCO 3.0.7 cial Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is o ional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in PBAPS UNIT 3 3.0 3 Amendment No. *2+4

INSERT 1 LCO 3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; or

b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

ATTACHMENT 3 Revised 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 3.0-1 3.0-3

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7 and LCO 3.0.8.