ML15275A265
| ML15275A265 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/02/2015 |
| From: | Jim Barstow Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC ME9631, TAC ME9632 | |
| Download: ML15275A265 (36) | |
Text
Exelon Generation October 2, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278
Subject:
License Amendment Request Proposed Changes to the Technical Specifications for High Pressure Coolant Injection and Reactor Core Isolation Cooling Surveillance Test Pressure and Clarification of Surveillance Requirements
Reference:
- 1. NRC Letter to Exelon, 11Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendments Re: Extended Power Uprate (TAC Nos.
ME9631 and ME9632),
11 dated August 25, 2014 (ADAMS Accession No. ML14133A046)
Pursuant to 1 O CFR 50.90, 11Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos.
DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, respectively.
The proposed changes revise PBAPS Unit 2 and Unit 3 TS Surveillance Requirement (SR) 3.5.1.8 and SR 3.5.3.3 for the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) Surveillance Test Pressure bands, respectively. More specifically, as a result of the Extended Power Uprate (EPU) License Amendments 293/296 approved by the NRC on August 25, 2014 (Reference 1 ), it has been determined that the lower pressure limit value needs to be lowered for the HPCI and RCIC system pump flow test surveillance pressure bands. This change will reduce challenges to the control of reactor pressure and reactivity when performing the surveillances during plant startup operations.
Additionally, the proposed changes revise PBAPS Unit 2 and Unit 3 TS SRs 3.1.7.10, 3.6.2.4.3 and 3.6.2.5.3 to remove changes provided in the PBAPS EPU Amendments (Reference 1) that have been determined to be unnecessary or overly conservative. TS SR 3.1.7.10 is revised to remove reference to the Surveillance Frequency Control Program and provide a frequency consistent with Standard Technical Specifications. TS SRs 3.6.2.4.3 and 3.6.2.5.3 are to be deleted.
U.S. Nuclear Regulatory Commission License Amendment Request HPCl/RCIC Test Pressure and Surveillance Requirement Changes Docket Nos. 50-277 and 50-278 October 2, 2015 Page 2 Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92.
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 Exelon Quality Assurance Program.
This amendment request contains no regulatory commitments. provides the evaluation of the proposed changes. Attachment 2 provides a copy of the marked up TS pages that reflect the proposed changes. Attachment 3 provides a copy of the marked up TS Bases pages that reflect the proposed changes (information only).
Exelon requests approval of the proposed amendment by October 2, 2016. Upon NRC approval, the amendment shall be implemented within 60 days of issuance.
In accordance with 10 CFR 50.91, 11Notice for public comment; State consultation, 11 paragraph (b), Exelon 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.
If you have any questions or require additional information, please contact Mr. David Neff at 61 0-765-5631.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of October 2015.
Respectfully,
~~~
James Barstow Director, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments:
- 1. Evaluation of Proposed Changes
- 2. Markup of Proposed Technical Specifications Pages
- 3. Markup of Proposed Technical Specifications Bases Pages (Information Only) cc:
USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS R. R. Janati, Commonwealth of Pennsylvania S. T. Gray, State of Maryland w/attachments
Subject:
ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES License Amendment Request Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278 Proposed Changes to the Technical Specifications to Change the High Pressure Coolant Injection and Reactor Core Isolation Cooling Surveillance Test Pressure and Clarification of Surveillance Requirements 1.0
SUMMARY
DESCRIPTION 2.0 DETAILED DESCRIPTION
3.0 TECHNICAL EVALUATION
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedence 4.3 No Significant Hazards Consideration 4.4 Conclusions
5.0 ENVIRONMENTAL CONSIDERATION
6.0 REFERENCES
Evaluation of Proposed Changes License Amendment Request HPCl/RCIC Test Pressure Change and Surveillance Requirements Changes Docket Nos. 50-277 and 50-278 1.0
SUMMARY
DESCRIPTION Page 1 of 11 Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, respectively.
The proposed changes revise PBAPS Unit 2 and Unit 3 TS Surveillance Requirement (SR) 3.5.1.8 and SR 3.5.3.3 for the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) Surveillance Test Pressure bands, respectively. More specifically, as a result of the Extended Power Uprate (EPU) License Amendments 293/296 approved by the N RC on August 25, 2014 (Reference 1 ), it has been determined that the lower pressure limit value needs to be lowered for the HPCI and RCIC system pump flow test surveillance pressure bands.
This will reduce challenges to the control of reactor pressure and reactivity when performing the surveillances during plant startup operations.
Additionally, the proposed changes revise PBAPS Unit 2 and Unit 3 TS SRs 3.1.7.10, 3.6.2.4.3 and 3.6.2.5.3 to remove changes provided in the PBAPS EPU Amendments (Reference 1) that have been determined to be unnecessary or overly conservative. TS SR 3.1.7.10 is revised to remove reference to the Surveillance Frequency Control Program (SFCP) and provide a frequency consistent with Standard Technical Specifications. TS SRs 3.6.2.4.3 and 3.6.2.5.3 are to be deleted.
2.0 DETAILED DESCRIPTION The current PBAPS TS SR for the HPCI and RCIC system pump flow surveillance tests (SR 3.5.1.8 and SR 3.5.3.3, respectively) require the test to be performed with a reactor pressure
.::s. 1053 psig and?. 940 psig to confirm that the required pump flow can be achieved. As a result of the PBAPS Units 2 and 3 EPU License Amendments, the reactor pressure at rated EPU conditions remains the same as pre-EPU license conditions. To retain the reactor pressure the same at full power, the steam pressure at the main turbine stop valves must be lowered from 940 to 915 psig to accommodate the increase in steam flow rate and the resulting higher steam pressure drop across the main steam lines and valves. The lower reactor pressure limit for performing the HPCI and RCIC system tests should also be changed from 940 to 915 psig to align with plant startup operations. This change will reduce challenges to the control of reactor pressure and reactivity when performing the surveillances during plant startup.
During plant startup operations, the pressure regulator is set at a value that will support the desired reactor pressure value for steady state operations at 100% reactor thermal power.
Based on PBAPS Unit 2 operation at EPU conditions, this pressure regulator value has been determined to be 915 psig. During reactor startup, plant conditions are established to support testing the HPCI and RCIC systems to ensure proper pump flow rates. The current TS SR allowed test pressure band is.::s. 1053 psig and ?. 940 psig. The desired test pressure band is
.::s. 1053 psig and?. 915 psig. The current TS SR test pressure band requires a reactor pressure and reactivity perturbation associated with adjusting reactor steam dome pressure from 940 to 915 psig following the completion of HPCl/RCIC system testing. The proposed change would revise the lower test pressure value from 940 to 915 psig in SR 3.5.1.8 for the HPCI system and
Evaluation of Proposed Changes License Amendment Request HPCl/RCIC Test Pressure Change and Surveillance Requirements Changes Docket Nos. 50-277 and 50-278 Page 2 of 11 SR 3.5.3.3 for the RCIC system and avoid the unnecessary pressure adjustment during power ascension.
The proposed changes include revising PBAPS Unit 2 and Unit 3 TS SR 3.1.7.1 O for testing the sodium pentaborate enrichment of the Standby Liquid Control (SLC) System. The SR frequency is revised from "In accordance with the Surveillance Frequency Control Program AND Once within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after addition to SLC tank", to 11Prior to addition to SLC tank.
11 This specific change deletes the unnecessary requirement of controlling the SR frequency within the SFCP since no new frequency was added in the EPU License Amendment. The appropriate SR frequency is specified in the SR 3.1.7.10 directly and not in the SFCP. This SR frequency tied to the SFCP was added with the PBAPS EPU License Amendment and it has subsequently been determined that this requirement is unnecessary. The timing for conducting the SR is revised to provide a frequency consistent with NUREG 1433, Revision 4, Standard Technical Specifications, General Electric BWR/4 Plants. This aligns SR 3.1.7.1 O with the other SLC system TS SRs and the Standard Technical Specifications wording.
The proposed changes include revising PBAPS Unit 2 and Unit 3 TS SRs 3.6.2.4.3 and 3.6.2.5.3 for testing the manual transfer capability of the normal and alternate power supplies for certain Residual Heat Removal (AHR) and High Pressure Service Water (HPSW) motor operator valves actuators. These specific changes delete the SR 3.6.2.4.3 from the Suppression Pool Spray (SPS) TS section and delete SR 3.6.2.5.3 from the Drywall Spray (DWS) TS section since the alternate power supply capability is not necessary for the SPS or DWS sub-systems of the RHR system to perform their design functions. This SR frequency was added with the PBAPS EPU License Amendment and it has subsequently been determined that this requirement is overly conservative and unnecessary.
3.0 TECHNICAL EVALUATION
HPCI and RCIC System Function HPCI is part of the emergency core cooling systems which are designed, in conjunction with the primary and secondary containment, to limit the release of radioactive materials to the environment following a loss of coolant accident (LOCA). The HPCI System consists of a steam driven turbine pump unit, piping, and valves to provide steam to the turbine, as well as piping and valves to transfer water from the suction source to the core via the feedwater system line, where the coolant is distributed within the reactor pressure vessel (RPV) through the feedwater sparger. The steam supply to the HPCI turbine is piped from a main steam line upstream of the associated inboard main steam isolation valve. The HPCI System is designed to provide core cooling for a wide range of reactor pressures (150 psig to 1170 psig). Upon receipt of an initiation signal, the HPCI turbine stop valve and turbine control valve open and the turbine accelerates to a specified speed. As the HPCI flow increases, the turbine governor valve is automatically adjusted to maintain design flow.
The RCIC System is designed to operate either automatically or manually following RPV isolation accompanied by a loss of coolant flow from the feedwater system to provide adequate core cooling and control of the RPV water level. Under these conditions, the HPCI and RCIC systems perform similar functions. The RCIC System consists of a steam driven turbine pump unit, piping, and valves to provide steam to the turbine, as well as piping and valves to transfer
Evaluation of Proposed Changes License Amendment Request HPCl/RCIC Test Pressure Change and Surveillance Requirements Changes Docket Nos. 50-277 and 50-278 Page 3 of 11 water from the suction source to the core via the feedwater system line, where the coolant is distributed within the RPV through the feedwater sparger. The steam supply to the turbine is piped from a main steam line upstream of the associated inboard main steam line isolation valve. The RCIC System is designed to provide core cooling for a wide range of reactor pressures (150 psig to 1170 psig). Upon receipt of an initiation signal, the RCIC turbine accelerates to a specified speed. As the RCIC flow increases, the turbine governor valve is automatically adjusted to maintain design flow.
HPCI and RCIC Flow Testing This periodic Surveillance is performed to verify that the HPCI pumps will develop the flow rates required by the design analyses. The HPCI pump flow rates ensure that adequate core cooling is provided. The pump flow rates are verified against a system head equivalent to the RPV pressure expected during a LOCA. The total system pump outlet pressure is adequate to overcome the elevation head pressure between the pump suction and the vessel discharge, the piping friction losses, and RPV pressure present during a LOCA. The flow tests for the HPCI System are performed at two different pressure ranges such that system capability to provide rated flow is tested at both the higher and lower operating ranges of the system. Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the HPCI or RCIC Systems divert steam flow during testing. Reactor steam dome pressure must currently be.::s, 1053 and~ 940 psig to perform SR 3.5.1.8 and SR 3.5.3.3. Adequate steam flow is represented by at least two turbine bypass valves open. Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these tests.
The RCIC pump flow rates ensure that the system can maintain reactor coolant inventory during pressurized conditions with the RPV isolated. The flow tests for the RCIC System are performed at two different pressure ranges such that system capability to provide rated flow is tested both at the higher and lower operating ranges of the system. Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the RCIC System diverts steam flow. Reactor steam pressure must currently be.::s, 1053 and~ 940 psig to perform SR 3.5.3.3. Adequate steam flow is represented by at least two turbine bypass valves open. Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these SRs.
HPC/ and RCIC Test Band Changes Required as a Result of EPU Implementation of EPU at PBAPS Units 2 and 3 requires maintaining the reactor steam dome pressure for EPU operating conditions the same as pre-EPU operating conditions for 100%
steady state power operations. With the EPU License Amendment, the TS 3.4.1 O maximum reactor pressure of 1053 psig remained unchanged. In order to provide more available energy to the main turbine under the EPU reactor steam dome pressure conditions, an increased flow rate from the reactor to the main turbine occurs. This increased flow rate causes an increased pressure drop between the reactor steam dome and the main turbine control valves and requires a lower pressure at the main turbine control valve inlets. As a result, the electro-hydraulic control (EHC) pressure regulator setpoint at the turbine control valves has been lowered from 940 psig to 915 psig for 100% steady state power operations.
Evaluation of Proposed Changes License Amendment Request HPCl/RCIC Test Pressure Change and Surveillance Requirements Changes Docket Nos. 50-277 and 50-278 Page 4 of 11 During startup and power ascension testing, it is desirable to set the pressure regulator at a value that will support 100% steady state power operations without the need to adjust the pressure regulator. Unnecessary adjustments to the pressure regulator can result in reactivity and reactor pressure perturbations. A pressure regulator setpoint of 915 psig will control pressure in the reactor steam dome at approximately 1030 to 1035 psig at 100% steady state power operations. This provides margin to the TS 3.4.1 O reactor steam dome pressure limit of 1053 psig. However, during low power operations there is much less steam flow and therefore, a pressure regulator setpoint of 915 psig results in the reactor steam dome pressure value being close to 915 psig. This pressure is below the required pressure band of.s 1053 and~ 940 psig for the HPCl/RCIC TS SR 3.5.1.8 and 3.5.3.3. Maintaining the current lower test pressure of 940 psig would result in an unnecessary perturbation of reactivity and reactor pressure since the pressure set value would need to be increased to 940 psig to perform HPCl/RCIC testing and then once again lowered to 915 psig to facilitate higher Mode 1 power operations.
Changing the lower test pressure value from 940 to 915 psig in SR 3.5.1.8 for the HPCI system and SR 3.5.3.3 for the RCIC system will reduce the potential for a plant transient.
Test Pressure Band for HPC/ and RCIC SR 3.5. 1.8 and SR 3.5.3.3 The proposed revised SRs 3.5.1.8 and 3.5.3.3 state:
Verify, with reactor pressure.s 1053 psig and~ 915 psig, the HPCI [RCIC] pump can develop a flow rate~ 5000 [600] gpm against a system head corresponding to reactor pressure.
The previous and proposed lower values of 940 [915] psig are consistent with the minimum EHC pressure setpoint at which reactor power can be increased without the need to adjust the EHC pressure setpoint during operation in Mode 1. Lowering the lower test pressure from 940 to 915 psig does not impact when the performance of the test is required. The required HPCI
[RCIC] pump flow rates of 5000 [600] gpm and the pump discharge pressures are not being changed. The SRs 3.5.1.8 and 3.5.3.3 are intended to verify the operation of the HPCI and RCIC systems at the upper end of the reactor pressure operating range and such operation has been found to be safe, as authorized in amendments 290/293 and 293/296 (References 1 and 2). Based on operating experience associated with the HPCI and RCIC system operations, there is margin in the turbine-pump systems that ensure that both HPCI and RCIC pumps will successfully pass the surveillance tests at the lower steam pressure. Lowering the pressure band at which the surveillance tests are performed provides a benefit by reducing the potential for a plant transient.
SR 3. 1. 7. 1 O Frequency Clarification The proposed changes include revising PBAPS Unit 2 and Unit 3 TS SR 3.1.7.1 O for testing the sodium pentaborate enrichment of the Standby Liquid Control (SLC) System. The SR frequency is revised from "In accordance with the Surveillance Frequency Control Program AND Once within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after addition to SLC tank, 11 to "Prior to addition to SLC tank.
11 This specific change deletes the unnecessary requirement of controlling the SR frequency within the SFCP since no new frequency was added in the EPU License Amendment. The appropriate SR frequency is specified in the SR 3.1.7.10 directly and not in the SFCP. This SR frequency tied to the SFCP was added with the PBAPS EPU License Amendment and was intended to make the SR frequency consistent with the other SLC system SRs in TS Section 3.1.7. It has
Evaluation of Proposed Changes License Amendment Request HPCl/RCIC Test Pressure Change and Surveillance Requirements Changes Docket Nos. 50-277 and 50-278 Page 5 of 11 subsequently been determined this added SR frequency requirement is unnecessary and should be deleted. The pre-EPU SR frequency requirement to perform the SR 3.1.7.1 O "Once within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after addition to SLC tank," is revised to provide a frequency consistent with NUREG 1433, revision 4, TS SR 3.1.7.10. This aligns the PBAPS TS SR 3.1.7.10 with the other SLC system TSs and the Standard Technical Specifications wording. The pre-EPU SR frequency requirement was established in PBAPS Unit 2 and Unit 3 License Amendments 122/126 in 1987 when PBAPS implemented the requirements of 10 CFR 50.62, Requirements for Reduction of Risk from Anticipated Transients Without SCRAM (A TWS) Events for Light-Water-Cooled Nuclear Power Plants (Reference 3). With the other EPU related changes to the SLC system TS and SRs, the previous wording is no longer appropriate.
SR 3.6.2.4.3 and SR 3.6.2.5.3 Deletions These specific changes delete the SR 3.6.2.4.3 from the SPS TS section and delete SR 3.6.2.5.3 from the DWS TS section since the alternate power supply capability is not necessary for the SPS or DWS sub-systems of the RHR system to perform their design functions. This SR frequency was added with the PBAPS EPU License Amendment and it has subsequently been determined that these SRs are overly conservative and unnecessary.
The EPU License Amendment removed Containment Accident Pressure (CAP) credit from the PBAPS licensing basis and required installation of alternate power supply capability to certain RHR and HPSW system valves to assure containment cooling capability in the event of a loss of offsite power and a single failure. The power supply modification provided the Control Room operator with the capability to transfer the power supply of the motor-operated RHR cross-tie, RHR flow control and RHR heat exchanger High Pressure Service Water (HPSW) outlet valves from a safety-related normal source to a safety-related alternate source in the event of a loss of offsite power and the failure of an emergency AC electrical source. These changes included additional TS SRs to verify the operability of the alternate power transfer switch function.
This SR was added to the RHR sub-system functions of Suppression Pool Cooling (SPC), SPS and DWS. A subsequent review of the accident and the failure modes and effects analyses (FMEA) revealed that the alternate power supply is only needed for the SPC function of the RHR system. The routine testing of the capability to transfer the power supply of the motor-operated RHR cross-tie, RHR flow control and RHR heat exchanger HPSW outlet valves will still be required by SR 3.6.2.3.3 for the SPC sub-system. While the use of the alternate power supply could be used for operation of the SPS and DWS sub-systems, the need for this capability would involve more than a single failure. The alternate power supply capability for the specific RHR valves is not relied upon for the design function of the SPS and DWS sub-systems. The accident analyses do not rely on the use of the alternate power supply for the SPS and DWS sub-systems assuming any single failure. The License Amendment Request for the PBAPS EPU misinterpreted the FMEA to rely on the use of the alternate power supply for all modes of containment cooling instead of only the SPC function. The regulation for determining when a SR is necessary, 1 O CFR 50.36(c)(3), states, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met.
11 Since the routine test of this power supply transfer capability does not meet the 1 OCFR50.36{c)(3) criteria to be included as a SR for the SPS and DWS sub-systems, SR 3.6.2.4.3 and SR 3.6.2.5.3 may be deleted.
Evaluation of Proposed Changes License Amendment Request HPCl/RCIC Test Pressure Change and Surveillance Requirements Changes Docket Nos. 50-277 and 50-278
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria The following regulatory requirements have been considered:
Page 6 of 11 Title 1 O of the Code of Federal Regulations (1 O CFR), Section 50.36, 'Technical specifications," in which the Commission established its regulatory requirements related to the contents of the TS. Specifically, 1 O CFR 50.36(c)(2) states, in part, "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility." 10 CFR 50.36(c)(3) states, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met.
11 The proposed changes to the SLC, HPCI, RCIC and RHR system SRs do not affect compliance with these regulations.
The applicable 10 CFR Part 50, Appendix A, General Design Criteria, was considered as follows:
Criterion 12-Suppression of reactor power oscillations. The reactor core and associated coolant, control, and protection systems shall be designed to assure that power oscillations which can result in conditions exceeding specified acceptable fuel design limits are not possible or can be reliably and readily detected and suppressed.
Criterion 33-Reactor coolant makeup. A system to supply reactor coolant makeup for protection against small breaks in the reactor coolant pressure boundary shall be provided. The system safety function shall be to assure that specified acceptable fuel design limits are not exceeded as a result of reactor coolant loss due to leakage from the reactor coolant pressure boundary and rupture of small piping or other small components which are part of the boundary. The system shall be designed to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished using the piping, pumps, and valves used to maintain coolant inventory during normal reactor operation.
Criterion 35-Emergency core cooling. A system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that ( 1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts.
Evaluation of Proposed Changes License Amendment Request HPCl/RCIC Test Pressure Change and Surveillance Requirements Changes Docket Nos. 50-277 and 50-278 Page 7 of 11 Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.
Criterion 38-Containment heat removal. A system to remove heat from the reactor containment shall be provided. The system safety function shall be to reduce rapidly, consistent with the functioning of other associated systems, the containment pressure and temperature following any loss-of-coolant accident and maintain them at acceptably low levels.
Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.
The proposed changes to the TS SRs do not alter the design of the SLC, HPCI, RCIC or RH R systems.
4.2 Precedence The proposed changes to revise the lower test pressure value from 940 to 915 psig in SR 3.5.1.8 for the HPCI system and SR 3.5.3.3 for the RCIC system are similar to changes approved in PBAPS Unit 2 and Unit 3 Amendments 212/217 issued on January 11, 1996 (Reference 4). These amendments revised the same pressure parameter to accommodate for a change in the minimum EHC pressure regulator setpoint at the turbine control valves that occurred with the previous power uprate. The changes in Amendments 212/217 were based on operating experience gained from the rerated conditions. Amendments issued since 1996, such as the Safety Relief Valve Lift Setpoint Tolerance Amendments 290/293 and EPU Amendments 293/296, resulted in changes to the plant conditions making the older information less applicable to the proposed changes in this request.
The proposed changes to the SLC system SR 3.1.7.1 Oare consistent with the industry standard wording provided in NUREG 1433 revision 4.
The proposed changes to the RHR system SR 3.6.2.4.3 and SR 3.6.2.5.3 do not have any applicable precedents.
4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, 11Application for license, construction permit, or early site permit, 11 Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos.
Evaluation of Proposed Changes License Amendment Request HPCl/RCIC Test Pressure Change and Surveillance Requirements Changes Docket Nos. 50-277 and 50-278 Page 8 of 11 DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, respectively.
The proposed changes revise PBAPS TS Surveillance Requirement (SR) 3.5.1.8 and SR 3.5.3.3 for the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) Surveillance Test Pressure bands, respectively. More specifically, as a result of the Extended Power Uprate (EPU) License Amendments 293/296 approved by the NRG on August 25, 2014, it has been determined that the lower pressure of the HPCl/RCIC flow test surveillances pressure band needs to be lowered to minimize challenges to the control of reactor pressure and reactivity when performing the surveillances during plant startup operating conditions.
The proposed changes include revising PBAPS Unit 2 and Unit 3 TS SR 3.1.7.1 O for testing the sodium pentaborate enrichment of the Standby Liquid Control (SLC) System.
The SR frequency is revised from 11ln accordance with the Surveillance Frequency Control Program AND Once within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after addition to SLC tank, 11 to 11Prior to addition to SLC tank.
11 This specific change deletes the unnecessary requirement of controlling the SR frequency within the Surveillance Frequency Control Program (SFCP) since no new frequency was added in the EPU License Amendment. The appropriate SR frequency is specified in the SR 3.1.7.1 O directly and not in the SFCP. This SR frequency tied to the SFCP was added with the PBAPS EPU License Amendment and it has subsequently been determined this requirement is unnecessary. The timing for conducting the SR is revised to provide a frequency consistent with NUREG 1433, revision 4, Standard Technical Specifications, General Electric BWR/4 Plants. This aligns SR 3.1.7.10 with the other SLC system TS SRs and the Standard Technical Specifications wording.
The proposed changes include revising PBAPS Unit 2 and Unit 3 TS SRs 3.6.2.4.3 and 3.6.2.5.3 for testing the manual transfer capability of the normal and alternate power supplies for certain Residual Heat Removal (RHR) and High Pressure Service Water (HPSW) motor operated valves actuators. These specific changes delete the SR 3.6.2.4.3 from the Suppression Pool Spray (SPS) TS section and delete SR 3.6.2.5.3 from the Drywall Spray (DWS) TS section since the alternate power supply capability is not necessary for the SPS or DWS sub-systems of the RHR system to perform their design functions. This SR frequency was added with the PBAPS EPU License Amendment and it has subsequently been determined that this requirement is overly conservative and unnecessary.
Exelon 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.
Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed changes for testing the HPCI System and the RCIC System at a lower pressure value do not affect the ability of the systems to perform their
Evaluation of Proposed Changes License Amendment Request HPCl/RCIC Test Pressure Change and Surveillance Requirements Changes Docket Nos. 50-277 and 50-278 Page 9 of 11 design functions. Testing at a lower pressure prevents unnecessary reactivity and reactor pressure perturbations and is considered to be conservative with respect to proving operability of these systems.
The revision to the SLC system SR 3.1.7.10 and deletion of the SPS and DWS sub-system SRs 3.6.2.4.3 and 3.6.2.5.3 do not affect the ability of these systems to perform their design functions. These proposed changes are administrative in nature and have no effect on plant operation.
The proposed changes do not adversely affect plant operations, design functions or analyses that verify the capability of systems, structures and components to perform their design functions. Performances of the involved SRs are not initiators of any accident previously evaluated. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed changes for testing the HPCI System and the RCIC System at a lower pressure value do not alter the system design, create new failure modes, or change any modes of operation. The proposed changes do not involve a physical alteration of the plant; and no new or different kind of equipment will be installed.
The revision to the SLC system SR 3.1.7.10 and deletion of the SPS and DWS sub-system SRs 3.6.2.4.3 and 3.6.2.5.3 are administrative in nature and have no effect on plant operation. These proposed changes do not alter the physical design, safety limits, or safety analysis assumptions associated with the operation of the plant.
These proposed changes do not introduce any new accident initiators, nor do they reduce or adversely affect the capabilities of any plant system, structure, or component to perform their safety function. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3.
Do the proposed changes involve a significant reduction in a margin of safety?
Response: No.
The proposed changes for testing the HPCI System and the RCIC System at a lower pressure value do not affect the ability of the systems to perform their design functions. Testing at a lower pressure prevents unnecessary reactivity and reactor pressure perturbations and is considered to be conservative with respect to proving operability of these systems. The revision to the SLC system
Evaluation of Proposed Changes License Amendment Request HPCl/RCIC Test Pressure Change and Surveillance Requirements Changes Docket Nos. 50-277 and 50-278 Page 10 of 11 SR 3.1.7.1 O and deletion of the SPS and DWS sub-system SRs 3.6.2.4.3 and 3.6.2.5.3 are administrative in nature and have no effect on plant operation. The HPCI, RCIC, SLC and AHR systems will continue to be demonstrated OPERABLE by performance of the revised and retained SRs. The proposed changes conform to NRC regulatory requirements regarding the content of plant TS.
Therefore, the proposed changes do not involve a significant reduction in a margin of sat ety.
Based on the above, Exelon 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 11 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
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 1 O 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 1 O 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.
6.0 REFERENCES
- 1.
NRC Letter to Exelon, "Peach Bottom Atomic Power Station, Units 2 and 3-lssuance of Amendments Re: Extended Power Uprate (TAC Nos. ME9631 and ME9632),
11 dated August 25, 2014 (ADAMS Accession No. ML14133A046).
- 2.
NRC letter to Exelon, "Peach Bottom Atomic Power Station, Units 2 and 3-lssuance of Amendments Safety Relief Valve and Safety Valve Lift Setpoint Tolerance (TAC Nos. MF1970 and MF1971)," dated May 5, 2014 (ADAMS Accession No. ML14079A102).
Evaluation of Proposed Changes License Amendment Request HPCl/RCIC Test Pressure Change and Surveillance Requirements Changes Docket Nos. 50-277 and 50-278 Page 11 of 11
- 3.
NRC letter to Philadelphia Electric Company, 11Standby Liquid Control System (TAC Nos. 64543 and 64544) RE: Peach Bottom Atomic Power Station, Unit NOS. 2 and 3, 11 dated June 2 1987 (ADAMS Accession No. ML011370656).
- 4.
NRC letter to Exelon, 11High Pressure Coolant Injection System Test Requirements, Peach Bottom Atomic Power Station, Units 2 and 3 (TAC Nos.
M94114 and M94120),
11 dated January 11, 1996. (ADAMS Accession No. ML011500051 ).
ATTACHMENT 2 Markup of Proposed Technical Specifications Pages License Amendment Request Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278 Proposed Changes to the Technical Specifications for High Pressure Coolant Injection and Reactor Core Isolation Cooling Surveillance Test Pressure and Clarification of Surveillance Requirements Unit 2 TS Pages 3.1-23 3.5-6 3.5-13 3.6-30 3.6-30b Unit 3 TS Pages 3.1-23 3.5-6 3.5-13 3.6-30 3.6-30b
SLC System 3.1. 7 SURVEILLANCE REQUIREMENTS (continued)
SR 3.1.7.7 SR 3.1.7.8 SR 3.1.7.9 SURVEILLANCE Deleted Verify each pump develops a flow rate
~ 49.1 gpm at a discharge pressure
~ 1275 psig.
Verify flow through one SLC subsystem from pump into reactor pressure vessel.
FREQUENCY In accordance with the Inservice Testing Program In accordance with the Surveillance Frequency Control Program.
SR 3.1.7.10 Verify sodium pentaborate enrichment is
~ 92.0 atom percent B-10.
In accordance
- .vith the Survei 11 ance Frequency Control Program PBAPS UNIT 2 3.1-23 Mt&
I Prior to~ Bnce vvithi n 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after addition to SLC tank Amendment No. 293
SURVEILLANCE REQUIREMENTS (continued)
SR 3.5.1.8 SURVEILLANCE
- - - - - - - - - - - - -- - - - - -NOTE- - - - -- - - - - - - - - - - - - - -
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
f915l---____ \\/Prify, with reactor pressure~ 1053 and L---1
~
psig, the HPCI pump can develop a SR 3.5.1.9 SR 3.5.1.10 PBAPS UNIT 2 flow rate~ 5000 gpm against a system head corresponding to reactor pressure.
- - - - - - - - - - - - - - - - - - -NOTE- - - - - - -- - - - - - - - -- - - -
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
V e r i f y, wit h r*e a ct o r p res s u re ~ 1 7 5 p s i g,
the HPCI pump can develop a flow rate
~ 5000 gpm against a system head corresponding to reactor pressure.
- - - - - - - - - - - - - - - -- -- NOTE- - - - - - - - - - - - - - - - - - - -
Vessel injection/spray may be excluded.
Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal.
3.5-6 ECCS-Operating 3.5.1 FREQUENCY In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
(continued)
Amendment No. 278
SURVEILLANCE REQUIREMENTS SR 3.5.3.1 SR 3.5.3.2 SR 3.5.3.3 SURVEILLANCE Verify the RCIC System p1p1ng is filled with water from the pump discharge valve to the injection valve.
Verify each RCIC System manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.
- - - - - - - - - - - - - - - - - - -NOTE -- - - - - - - -- - - - - - - - - --
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
~rify, with reactor pressure~ 1053 psig t.____J
~~-94& psig, the RCIC pump can develop a flow rate~ 600 gpm against a system head corresponding to reactor pressure.
SR 3.5.3.4 PBAPS UNIT 2
- - - - - - - - - - - - - - - - - - -NOTE- - -- - - - - -- - - - - - - - - --
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
Verify, with reactor pressure~ 175 psig, the RCIC pump can develop a flow rate
~ 600 gpm against a system head corresponding to reactor pressure.
3.5-13 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
(continued)
Amendment No. 278
RHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SR 3.6.2.4.1 SR 3.6.2.4.2 SR 3.6.2.4.3 I Deleted PBAPS UNIT 2 SU RV EI LLANCE Verify each RHR suppression pool spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.
Verify each suppression pool spray nozzle is unobstructed.
Verify manual transfer capability of powe-r-supply for the RHR motor operated flow
-&ntrol valve and the RHR cross tie motor operated valve from the normal source to the alternate source.
3.6-30 FREQUENCY In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
In accordance with the
-5urveillance Frequency Control
.P.rogram.
Amendment No. 293
SURVEILLANCE REQUIREMENTS SR 3.6.2.5.1 SR 3.6.2.5.2 SR 3.6.2.5.3 I Deleted PBAPS UNIT 2 SURVEILLANCE Verify each RHR d rywel l spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.
Verify each drywell spray nozzle is unobstructed.
- IJ-e-r-i-f.y---m-a-n u a l t r a n s f e r ca pa b i l i t y of po 'n' e r supply for the RHR motor operated fl m;
-Bfl-trol valve and the RHR cross tie motor operated valve from the normal source to the alternate source.
3.6-30b RHR Drywel l Spray 3.6.2.5 FREQUENCY In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
-l-fl-a-e-e o rd a n c e
'9vith the Surveillance Frequency Control Program.
Amendment No. 293
SURVEILLANCE REQUIREMENTS (continued)
SR 3.1.7.7 SR 3.1.7.8 SR 3.1.7.9 SURVEILLANCE Deleted Verify each pump develops a flow rate
~ 49.1 gpm at a discharge pressure
~ 1275 psig.
Verify flow through one SLC subsystem from pump into reactor pressure vessel.
SR 3.1.7.10 Verify sodium pentaborate enrichment is
~ 92.0 atom percent B-10.
SLC System 3.1. 7 FREQUENCY In accordance with the Inservice Testing Program In accordance with the Surveillance Frequency Control Program.
In accordance vJith the Surveillance Frequency Control Program.
AN{}
IPriorto~ -
... ~once within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after addition to SLC tank PBAPS UNIT 3 3.1-23 Amendment No. 296
SURVEILLANCE REQUIREMENTS (continued)
SR 3.5.1.8 SURVEILLANCE
- - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - -- - - - - - - - -
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
f915l---__ VPrify, with reactor pressure $ 1053 and
~
psig, the HPCI pump can develop a SR 3.5.1.9 SR 3.5.1.10 PBAPS UNIT 3 flow rate ~ 5000 gpm against a system head corresponding to reactor pressure.
- -- - - - - - - - - - - - - - - - -NOTE- - - - - - - - - - - - - - - - - - - -
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
Verify, with reactor pressure $ 175 psig, the HPCI pump can develop a flow rate
~ 5000 gpm against a system head corresponding to reactor pressure.
- - - - - - -- - - - - - - - - - - -NOTE- - - - - - - - - - - - - - - - - -- -
Vessel injection/spray may be excluded.
Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal.
3.5-6 ECCS-Operat i ng 3.5.1 FREQUENCY In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
(continued)
Amendment No. 281
SURVEILLANCE REQUIREMENTS SR 3.5.3.1 SR 3.5.3.2 SR 3.5.3.3 SURVEILLANCE Verify the RCIC System p1p1ng is filled with water from the pump discharge valve to the injection valve.
Verify each RCIC System manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.
- - - - - - - - - - - - - - -- - -- NOTE- - - - - - - - - - -- -- -- - - - -
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
~rifv, with reactor pressure~ 1053 psig L--....J
~~.94{} psig, the RCIC pump can develop a flow rate~ 600 gpm against a system head corresponding to reactor pressure.
SR 3.5.3.4 PBAPS UN IT 3
-- -- - - - - - - - - - - - - - - -NOTE- - - - - - - - - - - - - -- - - - - -
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
Verify, with reactor pressure ~ 175 psig, the RCIC pump can develop a flow rate
~ 600 gpm against a system head corresponding to reactor pressure.
3.5 -13 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
(continued)
Amendment No. 281
RHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SR 3.6.2.4.1 SR 3.6.2.4.2 SURVEILLANCE Verify each RHR suppression pool spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.
Verify each suppression pool spray nozzle is unobstructed.
SR
- 3. 6. 2. :;Verify lflanual transfer ca pa Bili ty of power supply for the RHR motor operated
.:f+.e.\\J c o n t r o l v a l v e a n d t h e RH R c r o s s t i e
!Deleted motor operated valve from the normal source to the alternate source.
PBAPS UN IT 3 3.6-30 FREQUENCY In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
In accordance
'vv'ith the Survei 11 ance Frequency Control Program.
Amendment No. 296
SURVEILLANCE REQUIREMENTS SR 3.6.2.5.l SR 3.6.2.5.2 SR 3.6.2.5.3
!Deleted PBAPS UN IT 3 SU RV EI L LANCE Verify each RHR drywell spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.
Verify each drywell spray nozzle is unobstructed.
Verify manual transfer capability of power supply for the RHR motor operated fi-ew control valve and the RHR cross tic motor operated valve from the normal source to the alternate source.
3.6-30b RHR Drywel l Spray 3.6.2.5 FREQUENCY In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
In accordance
'9iith the Surveillance Frequency Control Program.
Amendment No. 296
ATTACHMENT 3 Marku osed Technical S ecifications Bases Pa es License Amendment Request Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278 Proposed Changes to the Technical Specifications for High Pressure Coolant Injection and Reactor Core Isolation Cooling Surveillance Test Pressure and Clarification of Surveillance Requirements Unit 2 TS Bases Page B 3.1-47 B 3.5-14 B 3.5-28 B 3.6-63 B 3.6-63d Unit 3 TS Bases Page B 3.1-47 B 3.5-14 B 3.5-28 B 3.6-63 B 3.6-63d
BASES SLC System B 3.1.7 SURVEILLANCE REQUIREMENTS (continued)
SR 3.1.7.10 Enriched sodium pentaborate solution is made by m1x1ng granular, enriched sodium pentaborate with water.
In order to ensure the proper B 10 atom percentage is being used, calculations must be performed to verify the actual B 10 enrichment within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after addition of the solution to the SLC tank.
The calculations may be performed using the isotopic tests on the granular sodium pentaborate The Frequency is considering that boron enrichment is verified procurement process and any time boron is added
+++-r-H+'-~~-+t..,...,..ai+nHEI<"""""'".
The Survei 11 a nee Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1.
- 2.
UFSAR, Section 3.8.4.
- 3.
Isotopic tests on the granular sodium pentaborate to verify the actual B-1 O enrichment must be performed prior to addition to the SLC tank in order to ensure that the proper B-10 atom percentage is being used. The tests may use vendor certification documents.
PBAPS UNIT 2 B 3.1-47 Revision No. 114
BASES SURVEILLANCE REQUIREMENTS PBAPS UNIT 2 SR 3.5.1.7. SR 3.5.1.8. and SR 3.5.1.9 ECCS-Operat i ng B 3.5.1 pressure when the HPCI System diverts team flow.
Reactor steam pressure must be ~ 1053 and ~ -948-psig to perform SR 3.5.1.8 and greater than or equal to the Electro-Hydraulic Control (EHC) System minimum pressure set with the EHC System controlling pressure (EHC System begins controlling pressure at a nominal 150 psig) and~ 175 psig to perform SR 3.5.1.9.
Adequate steam flow is represented by at least 2 turbine bypass valves open.
Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these tests.
Reactor startup is allowed prior to performing the low pressure Surveillance test because the reactor pressure is low and the time allowed to satisfactorily perform the Surveillance test is short.
The reactor pressure is allowed to be increased to normal operating pressure since it is assumed that the low pressure test has been satisfactorily completed and there is no indication or reason to believe that HPCI is inoperable.
Therefore, SR 3.5.1.8 and SR 3.5.1.9 are modified by Notes that state the Surveillances are not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the reactor steam pressure and flow are adequate to perform the test.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.5.1.10 The ECCS subsystems are required to actuate automatically to perform their design functions.
This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCI, CS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup and actuation of all automatic valves to their required positions.
This SR also ensures that either the HPCI System (continued)
B 3.5-14 Revision No. 86
BASES SURVEILLANCE REQUIREMENTS PBAPS UNIT 2 RCIC System B 3.5.3 SR 3.5.3.2 (continued)
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.5.3.3 and SR 3.5.3.4 The RCIC pump flow rates ensure that the system can maintain reactor coolant inventory during pressurized conditions with the RPV isolated.
The flow tests for the RCIC System are performed at two different pressure ranges such that system capability to provide rated flow is tested both at the higher and lower operating ranges of the system.
Additionally, adequate steam flow must be passing throu the main turbine or turbine bypass valves to continue control reactor pressure when the RCIC System diverts flow.
Reactor steam pressure must be~ 1053 and~ 948-to perform SR 3.5.3.3 and greater than or equal to the Electro-Hydraulic Control (EHC) System minimum pressure set with the EHC System controlling pressure (the EHC System begins controlling pressure at a nominal 150 psig) and
~ 175 psig to perform SR 3.5.3.4.
Alternately, auxiliary steam can be used to perform SR 3.5.3.4.
Adequate steam flow is represented by at least 2 turbine bypass valves open.
Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these SRs.
915 Reactor startup is allowed prior to performing the low pressure Surveillance because the reactor pressure is low and the time allowed to satisfactorily perform the Surveillance is short.
Alternately, the low pressure Surveillance test may be performed prior to startup using an auxiliary steam supply.
The reactor pressure is allowed to be increased to normal operating pressure since it is assumed that the low pressure Surveillance has been satisfactorily completed and there is no indication or reason to believe that RCIC is inoperable.
Therefore, these SRs are modified by Notes that state the Surveillances are not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the reactor steam pressure and flow are adequate to perform the test.
(continued)
B 3.5-28 Revision No. 86
BASES (continued)
SURVEILLANCE REQUIREMENTS SR 3.6.2.4.1 RHR Suppression Pool Spray B 3.6.2.4 Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool spray mode flow path provides assurance that the proper flow paths will exist for system operation.
This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing.
A valve is also allowed to be ih the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis.
This is acceptable since the RHR suppression pool cooling mode is manually initiated.
This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.
This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.6.2.4.2 This Surveillance is performed to verify that the spray nozzles are not obstructed and that flow will be provided when required.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.6.2.4.3 jDeleted 1-j ---->-?Veri fi ca ti on of manual transfer bet*,.;een the normal and alternate power source (4kV emergency bus) for each RHR REFERENCES PBAPS UNIT 2 mot o r ope rated fl m.; cont r o l v a l v e a n d e a ch RH R c r o s s t i e mo t o r o p e r a t e d v a l v e d e Ff1 o n s t r a t e s t h a t--A-&-p o 'vv e r h' i l l b-e
-a-v-a++u b l e t o o p e r a t e t h e r e q u i r e d v a l v e s fo l l mvi i n g l o s s o f po'vver to any single 4kV eFflergency bus.
.ffie abi 1 i ty to provide power to each RHR motor operated flow control valve
~nd each RHR cross tie motor operated valve from either of
-hrn independent 4kV ertlergency buses ensures that a single fa i l u re of a D G 'vii l l not re s u l t i n fa i l u re of t he RH R mot o r ope rated fl o 'vrJ cont r o l v a l v e a n d t he RH R c r o s s t i e mot o r operated valve; therefore, failure of the manual transfer cap ab i l ity 'vrJ i 1 1 res u l t i n i nope r ab i 1 ity of the assoc i ate d RHR Suppression Pool Spray subsystem.
The Surveillance Frequency is controlled under the Surveillance Frequency f.efrt-rol Program.
- 1.
UFSAR, Sections 5.2 and 14.6.3.
- 2.
NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
B 3.6-63 Revision No. 114
BASES (continued)
SURVEILLANCE REQUIREMENTS SR 3.6.2.5.l RHR Drywel l Spray B 3.6.2.5 Verifying the correct alignment for manual, power operated, and automatic valves in the RHR drywell spray mode flow path provides assurance that the proper flow paths will exist for system operation.
This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing.
A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis.
This is acceptable since the RHR drywell mode is manually initiated.
This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.
This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.6.2.5.2 This Surveillance is performed to verify that the spray nozzles are not obstructed and that flow will be provided when required.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
~
7' Ve r i f i cat i on of FA an u a l t r a n sf e r bet 'uJ e en the no r FA a l a n d
~
al tern ate poHer source (4kV emergency bus) for each RHR motor operated flow control valve and each RHR cross tie REFERENCES PBAPS UNIT 2
- ~!~fagfgr~:e:P~~!~g ~~:
0
~~~:~~g~ !:~!e:cfgrr~:i=~
1
~o~~
B f po~' e r t o a n y s i n g l e 41< V em e r g e n c y b u s.
Th e a b i 1 i t y to p r o v i d e p o \\J e r to ea c h RH R FA o to r o p e r a t e d fl O'vJ cont r o 1 valve and each RHR cross tie motor operated valve from
-i-t-h e r o f t ~Jo i n d e p e n d e n t 4 kV e FA e r g e n c y b u s e s e n s u re s that a single failure of a DC will not result in failure of the RHR motor operated fl O'vv' control valve and the RHR cross tie motor operated valve; therefore, failure of the manual transfer capability will result in inoperability of the associated RHR Drywell Spray subsystem.
The Surveillance Frequency is controlled tinder the Surveillance Frequency Control Program.
- 1.
UFSAR, Sections 5.2 and 14.6.3.
- 2.
NEDC-33566P - "Safety Analysis Report for Exelon Peach Bottom Station Units 2 and 3, Constant Pressure Power Uprate" Revision 0.
B 3.6-63d Revision No. 114
BASES SR 3.1.7.10 SLC System B 3.1. 7 SURVEILLANCE REQUIREMENTS (continued)
Enriched sodium pentaborate solution is made by m1x1ng granular, enriched sodium pentaborate with water.
In order to ensure the proper B 10 atom percentage is being used, alculations must be performed to verify the actual B 10
-A-f-i chment
- ~vi thin 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after ad di ti on of the solution to the SLC tank.
The calculations may be performed using the results of isotopic tests on the granular sodium pentaborate or vendor certification documents.
The Frequency is acceptable considering that boron enrichment is verified during the procurement process and any time boron is added to the SLC tan I<.
The Survei 11 ance Frequency is controlled Dnder the Surveillance Frequency Control Program.
REFERENCES
- 1.
- 2.
UFSAR, Section 3.8.4.
- 3.
Isotopic tests on the granular sodium pentaborate to verify the actual 8-10 enrichment must be performed prior to addition to the SLC tank in order to ensure that the proper 8-10 atom percentage is being used. The tests may use vendor certification documents.
PBAPS UNIT 3 B 3.1-47 Revision No.
296
BASES SURVEILLANCE REQUIREMENTS PBAPS UNIT 3 SR 3.5.1.7 SR 3.5.1.8 and SR ECCS-Operati ng B 3.5.1 (continued) pressure when the HPCI System diverts earn flow.
Reactor steam pressure must be~ 1053 and ~ 94-& psig to perform SR 3.5.1.8 and greater than or equal to the Electro-Hydraulic Control (EHC) System minimum pressure set with the EHC System controlling pressure CEHC System begins controlling pressure at a nominal 150 psig) and~ 175 psig to perform SR 3.5.1.9.
Adequate steam flow is represented by at least 2 turbine bypass valves open.
Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these tests.
Reactor startup is allowed prior to performing the low pressure Surveillance test because the reactor pressure is low and the time allowed to satisfactorily perform the Surveillance test is short.
The reactor pressure is allowed to be increased to normal operating pressure since it is assumed that the low pressure test has been satisfactorily completed and there is no indication or reason to believe that HPCI is inoperable.
Therefore, SR 3.5.1.8 and SR 3.5.1.9 are modified by Notes that state the Surveillances are not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the reactor steam pressure and flow are adequate to perform the test.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.5.1.10 The ECCS subsystems are required to actuate automatically to perform their design functions.
This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCI, CS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup and actuation of all automatic valves to their required positions.
This SR also ensures that either the HPCI System (continued)
B 3.5-14 Revision No. 87
BASES SURVEILLANCE REQUIREMENTS PBAPS UNIT 3 SR 3.5.3.2 (continued)
RCIC System 8 3.5.3 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.5.3.3 and SR 3.5.3.4 The RCIC pump flow rates ensure that the system can maintain reactor coolant inventory during pressurized conditions with the RPV isolated.
The flow tests for the RCIC System are performed at two different pressure ranges such that system capability to provide rated flow is tested both at the higher and lower operating ranges of the system.
Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the RCIC System diverts team flow.
Reactor steam pressure must be ~ 1053 and ~ 949-psig to perform SR 3.5.3.3 and greater than or equal to the Electro-Hydraulic Control (EHC) System minimum pressure set with the EHC System controlling pressure (the EHC System begins controlling pressure at a nominal 150 psig) and
~ 175 psig to perform SR 3.5.3.4.
Alternately, auxiliary steam can be used to perform SR 3.5.3.4.
Adequate steam flow is represented by at least 2 turbine bypass valves open.
Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these SRs.
Reactor startup is allowed prior to performing the low pressure Surveillance because the reactor pressure is low and the time allowed to satisfactorily perform the Surveillance is short.
Alternately, the low pressure Surveillance test may be performed prior to startup using an auxiliary steam supply.
The reactor pressure is allowed to be increased to normal operating pressure since it is assumed that the low pressure Surveillance has been satisfactorily completed and there is no indication or reason to believe that RCIC is inoperable.
Therefore, these SRs are modified by Notes that state the Surveillances are not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the reactor steam pressure and flow are adequate to perform the test.
(continued)
B 3.5-28 Revision No. 87
BASES (continued)
SURVEILLANCE REQUIREMENTS SR 3.6.2.4.1 RHR Suppression Pool Spray B 3.6.2.4 Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool spray mode flow path provides assurance that the proper flow paths will exist for system operation.
This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing.
A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis.
This is acceptable since the RHR suppression pool cooling mode is manually initiated.
This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.
This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.6.2.4.2 This Surveillance is performed to verify that the spray nozzles are not obstructed and that flow will be provided when required.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.6.2.4.3 I 0 1 t d I 7-V e r i f i c a t i o n o f ma n u a l t r a n s f e r be t ~" e e n t h e n o rm a l a oo e e e 1-----'?a l te rnate pmt'e r source ( 4kV emergency bus) for ea ch RH R REFERENCES PBAPS UNIT 3 mot o r ope r a t e d fl o 'vv cont r o 1 v a 1 v e a n d ea ch RH R c r o s s t i e mEJtor operated valve demonstrates th-a-t-A-ft3-ewe-r--w-=i-t+-fre available to operate the required valves following loss of power to any single 4kV emergency bus.
The ability to p r o v i de p mv' e r to ea ch RH R mot o r ope r a t e d fl mr cont r o 1 v a 1 *1 e and each RHR cross tie motor operated valve from either of twe i n depend en t 41< V em e r gen c y bus c s en s u r c s t hat a s i n g l c fa i 1 u re of a D G 'vt' i 1 l n o t re s u 1 t i n fa i 1 u re of t he RH R mot o r o p e r a t e d fl o 'vv c o n t r o l v a l v e a n d t h e RH R c r o s s t i e mot o r operated valve; therefore, failure of the manual transfer ca pa bi l ity 'h'i 11 result in i noperabi l ity of the associated RHR Suppression Pool Spray subsystem.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
- 1.
UFSAR, Sections 5.2 and 14.6.3.
- 2.
NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
B 3.6-63 Revision No.
BASES (continued)
SU RV EI LLANCE REQUIREMENTS SR 3.6.2.5.1 RHR Drywell Spray B 3.6.2.5 Verifying the correct alignment for manual, power operated, and automatic valves in the RHR drywell spray mode flow path provides assurance that the proper flow paths will exist for system operation.
This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing.
A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis.
This is acceptable since the RHR drywell mode is manually initiated.
This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.
This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.6.2.5.2 This Surveillance is performed to verify that the spray nozzles are not obstructed and that flow will be provided when required.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
!Deleted j1--~~~->71\\rt 1 e~r~i4f,i~c~a~t~itjottn-e-orf~m~a~n~u~arlt---tt~r~a~n~s~f~efr-tTbee~t*~ve~e~n't--1t~htte~n1to~r~m~a~l-aattnttd alternate po*vver source (41<V emergency bus) for each RHR motor operated flow control valve and each RHR cross tie motor operated valve demonstrates that AC power will be available to operate the required valves following loss o f p o 'vJ e r t o a n y s i n g l e 41< V e FR e r g e n c y b u s.
- f. h e a b i l i t y to provide power to each RHR motor operated fl~v control valve and each RHR cross tie mot~e from either of t~Jo independent 41<V emergency buses ensures that a single failure of a DC will not result in failure of the RHR motor operated flow control valve and the RHR e-r-e s s t i e mot O-F-&f1"Til t e d v a 1 v e ; t h e r e f o r e, f a-i+u re o f the manual transfer capability will result in inoperability of the associated RHR Drywell Spray subsystem.
fhe Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
- 1.
UFSAR, Sections 5.2 and 14.6.3.
- 2.
NEDC-33566P, "Safety Analysis Report for Exelon Peach Bottom Station, Units 2 and 3, Constant Pressure Power Uprate," Revision 0.
B 3.6-63d Revision No. EPlJ