ML20083B975
| ML20083B975 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/04/1995 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-1433 NUDOCS 9505150036 | |
| Download: ML20083B975 (23) | |
Text
flat 6ea support separtment
[ j'y 10CFR50.90 J.N,%
eeco c"erav co-a "r l
PECO ENERGY.
Nuclear Group Headquarters 965 Chesterbrook Boulevard Wayne. PA 19087 5691 May 4,1995 e
i
~
Docket Nos. 50-277 '
50-278 License Nos. DPR-44
~!
DPR-56 l
i r
U. S. Nuclear Regulatory Commission j
Attn: Document Control Desk Washington, DC 20555
]
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3
{
Supplement 3 to TSCR 93-16 Conversion to improved Technical Specifications
References:
(1)
Letter from G. A. Hunger, Jr. (PECO Energy) to USNRC dated September 29,1994
Dear Sir:
In Reference (1), PECO Energy Company submitted Technical Specifications Change Request j
(TSCR) 93-16, requesting changes to Appendixes A and 3 of the Facility Operating Licenses for l
Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. This TSCR proposed an Jverall conversion of the current PBAPS Technical Specifications (TS) to the improved Technical.
j Specifications (ITS), as contained in NUREG 1433, " Standard Technical Specifications, General l
Electric Plants, BWR/4."
l in response to questions from the U. S. Nuclear Regulatory Conw,:.e:On (USNRC) concoming ITS Sections 3.6 and 3.7, PECO Energy Company is supplying the enclosed responses.
If you have any questions, please contact us.
Very truly yours, i
fn G. A. Hunger, Jr.,
l Director - Licensing TRL/bgr l
Affidavit, Enclosure cc:
T. T. Martin, Administrator, Region I, USNRC W. L Schmidt, USNRC Senior Resident inspector, PBAPS l
R. R. Janati, Commonwealth of Pennsylvania 1
9505150036 950504 PDR ADOCK 05000277 P
PDR1 12C027 MDDi',,
1
I COMMONWEALTH OF PENNSYLVANIA l
l ss.
l 1
COUNTY OF CHESTER i
v W. H. Smith, III, being first duly sworn, deposes and says:
i l
That he is Vice President of PECO Energy Company; the Applicant herein; that he has read the attached response to j
questions concerning Technical Specifications Change Request l
(TSCR 93-16, Supplement 3) for changes to the Peach Bottom j
I Facility Operating Licenses DPR-44 and DPR-56, and knows the contents thereof; and that the statements and matters set forth i
therein are true and correct to the best of his knowledge, information and belief.
1 Vice Presiden f
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Subscribed and swo:
to
[
before me this day of 7
1995.
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Notary Public NotabSea!
Erica A.Santor vMah%gPsiled%
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~ ENCLOSURE' j
PEACN BOTTON ATONIC POWER STATION, UNITS 2 AND 3 RESPONSE TO QUESTIONS REGARDING INPROVED TECENICAL SPECIPICATIONS SECTIONS 3.6 AND 3.7 l
OUESTION FOR ITS LCO 3.6.1.3 DOC 1 l
9 This DOC reduces the volume required in the CADS nitrogen storage
. tank specified in CTS 4.7.E.3.a from 2500 gallons to.16" WC which i
I equates to-less than 2500 gallons.
1.
What is the actual volume of-nitrogen which equates to 16" l
WC in the CADS nitrogen storage tank?
2.
What is the purpose of this specification if it is always.
,I met by the CAD system requiring >2500 gallons of nitrogen in Modes 1, 2,
and 3?
RESPONSE
{
Item 1.
The actual volume of nitrogen which equates to 16" WC.
l in the' CADS nitrogen storage tank is 865 gallons.
This volume is the amount necessary to provide a 7 day supply of nitrogen to each of the components supplied i
by the Safety Grade Instrument Gas (SGIG) System.
The SGIG System supplies pressurized nitrogen gas-(from the-containment Atmospheric Dilution (CAD). System liquid nitrogen storage tank) as a safety grade pneumatic l
source to the CAC System purge and exhaust isolation valve inflatable seals,.the reactor building-to-tl suppression chamber vacuum breaker. air operated isolation valves and inflatable seal, and the CAC and CAD Systems vent control air operated valves.
The SGIG System thus performs two distinct' post-LOCA functions:
(1) supports containment isolation and (2) supports CAD
-l System vent operation.- SGIG' System requirements are addressed for each of the supported system and i
components in LCO 3.6.1.3 " Primary Containment Isolation valves (PCIVs)," LCO 3.6.1.5,
" Reactor Building-to-Suppression Chamber Vacuum Breakers," and i
" Containment Atmospheric Dilution (CAD)
System."
l Item 2.
The purpose of adding SGIG System requirements into the individual Specifications is as follows:
l The CAD System nitrogen storage tank level specified in SR 3.6.3.1.2 (33" WC) will ensure at least a 7 day supply for both the CAD System and the SGIG System is available.
As a result, if the CAD System requirements were met, then the SGIG System nitrogen level requirements (16" WC) would also be met.
The CAD System OPERABILITY requirements are only applicable in MODES 1 and 2, 1
l e
l
but tho OPERA 5ILITY rcquircaento' of tho priccry containment isolation valves and the vacuum breakers supported by the SGIG System are applicable in MODES 1, 2 and 3.
In addition, if the CAD System nitrogen storage tank level falls below 33" WC but is equal to or above 16" WC in MODE 1 or 2, then Condition A of Specification 3.6.3.1,
" CAD System" would be entered.
In this situation, the nitrogen supply in the storage tank is sufficient to supply all the SGIG System supported components.
As a result, these l
components would still be OPERABLE and the l
Conditions of Specification 3.6.1.3 " Primary l
Containment Isolation Valves (PCIVs)" and i
Specification 3.6.1.5,
" Reactor Building-to-Suppression Chamber Vacuum Breakers" would not be entered.
l l
OUESTION FOR ITS LCO 3.6.1.4 DOC M 3 i
ITS LCO 3.6.1 Rev 0 required "Drywell average air temperature l
shall be 5 135'F."
1.
What is the justification for the change in the drywell average air temperature LCO from 135'F to 145'F?
2.
Should the change in the LCO limit from 135*F to 145'F be a less restrictive change?
3.
Why is the second to last sentence of DOC M discussing a i
3 l
"drywell pressure limit of less than 145*F"?
I r
RESPONSE
Item 1.
In NUREG-1433, the value for the drywell average air temperature LCO is in brackets which signifies that the value is plant specific.
In this case, the value is the initial drywell average air temperature assumed in the design basis analysis.
The PBAPS specific analysis was performed assuming an initial drywell average air temperature of 145'F as documented in the Applicable Safety Analyses section of the Bases for Specification 3.6.1.4.
Item 2.
The change to the drywell average air temperature LCO is not considered to be a less restrictive change since PBAPS does not currently have any Technical Specification limits for drywell average air temperature.
l Item 3.
The second to last sentence of Discussion of Change M2
(
for ITS 3.6.1.4 should have stated "drywell temperature i
limit of less than or equal to 145'F".
I 2
OUESTION FOR ITS If0 3. 6. 2. 2 DOC M2
.This DOC should address " Suppression Pool Water' Level" as' stated in CTS; requirement 3.7.A.1, not " Suppression Pool Average
. Temperature."
" Suppression Pool Average Temperature" was
- previously discussed in ITS LCO 3.6.2.1, DOC M.
2 L
RESPONSE
This DOC should have addressed suppression pool. water level not suppression pool average temperature.
The DOC will be revised.
OUESTION FOR ITS LCO 3.6.4.3 DOC L2 ITS LCO 3.6.4.3, DOC L is used to justify deleting CTS 2
requirement 3.7.B.3.
What is the justification for deleting CTS 3.7.B.3; "provided that during such 7 days all active components of one standby gas treatment system train shall be operable."
The DOC referenced does not apply to CTS 3.7.B.3.
RESPONSE
In the PBAPS current Technical Specifications, the type of statement in CTS 3.7.B.3 (provided that during such'7 days all active components of one standby gas treatment system train shall be operable) have typically been tied to a conditional surveillance that requires demonstrating the OPERABILITY of the redundant components (in this case CTS 4.7.B.3.b).
As a result, Discussion of Change L for ITS 3.6.4.3 was considered to also 2
apply to the subject statement in CTS 3.7.B.3.
In the ITS, the statement "provided that during such 7 days all active components of one standby gas treatment system train shall be operable" is addressed by the use of the Conditions of the ACTIONS Table.
One Standby Gas Treatment (SGT) subsystem inoperable requires entry into Condition A of Specification 3.6.4.3, and two SGT subsystems inoperable requires entry into Condition D or E of Specification 3.6.4.3.
OUESTION FOR ITS LCO 3.7.3 DOC A.
Where is this DOC identified on the CTS markup?
Is the change inadvertently identified as A, LCO 3.7.3 ("The Emergency Heat 2
Sink shall be operable: Modes 1, 2, and 3") located below 3.11.C.1?
RESPONSE
Yes, the change was inadvertently identified as A, LCO 3.7.3, 2
("The Emergency Heat Sink shall be' operable: Modes 1, 2, and 3")
located below 3.11.C.l.
It should have been labeled A -
2 3
I OUESTION8 1
The following clarification is requested in the support of documentation for RELOCATED requirements.
In'each of the following Discussion of Changes, add a
' discussion of_the reasons why relocation of the subject item (s) is justified.
l 3.6.1.1 R & 3.6.1.1 R.
2 3.6.1.2 R t
3.6.1.3 R,
- 3. 6.1. 3 P4,
- 3. 6.1. 3 R, 3.6.1.3 Re, 3.6.1.3 3
7 R,,
3.6.1.3 Ro, & 3.6.1.3 R l
i 32 1
3.6.1.6 R 3 3.6.2.3 R & 3.6.2.3 R 3
2 3.6.2.4 R3 3.6.3.1 R i
3 3.6.4.1 R & 3.6.4.1 Ra 1
3.6.4.2 R3 3.6.4.3 R2
RESPONSE
The following clarifications are provided in support of the relocated items.
3.6.1.1 R2 1
The details of the performance of the Integrated Leak Rate Test (ILRT), reduced pressure testing acceptance criteria, i
and the testing frequency for bolted double gasketed seals are procedural details that are not necessary for assuring the OPERABILITY of primary containment.
SR 3.6.1.1.1 and the requirements of 10CFR50 Appendix J, as modified by approved exemptions, provide adequate assurance primary containment is maintained OPERABLE.
t 3.6.1.1 R.
The requirements to perform visual inspections of the interior and exterior surfaces of the primary containment and visual inspections of the suppression chamber-to-drywell vacuum breakers are not necessary for assuring the OPERABILITY of primary containment.
SR 3.6.1.1.1 and the requirements of 10CFR50 Appendix J (as modified by approved exemptions), SR 3.6.1.1.2, and the SRs of Specification 3.6.1.6,
" Suppression Chamber-to-Drywell Vacuum Breakers,"
b 1
4 l
bq provida ad2quato accurancs prinary containmnt la naintainsd
' OPERABLE.
3.6.1.2:R2 The minimumLtest duration requirement is not necessary for-
. assuring the OPERABILITY'of the primary containment air lock.
SR 3.6.1.2.1=and the requirements of 10CFR50 Appendix J, as modified by approved exemptions, provide adequate assurance-the primary containment air lock is maintained-OPERABLE.
3.6.1.3 R3 The requirement to perform a full stroke test on normally open primary containment isolation valves (PCIVs) is not required to be in Technical Specifications to assure the:
OPERABILITY of the applicable PCIVs since the Inservice Testing (IST) Program, required by 10CFR50.55a, provides stroke test requirements for ASME Code Class.1, 2,
and 3 valves in accordance with Section XI of the ASME Code.'
Compliance with 10CFR50.55a, and as a result the IST Program and implementing procedures, is required by the PRhPS, Units 2 and 3 Operating Licenses.
These controls are adequate to ensure the required testing to demonstrate'PCIV OPERABILITY:
is performed.
3.6.1.3 R6 l
The requirement for. reactor power to be < 75% to perform MSIV stroke time testing is a procedural detail that is not
]
necessary to assure the OPERABILITY of the MSIVs.
The i
requirements of SR 3.6.1.3.9 are adequate to assure MSIV I
stroke times are within required limits.
3.6.1.3 Ry The requirement to exercise the MSIVs by a partial stroke test is not required to be in Technical Specifications to l
assure the OPERABILITY of the MSIVs~since the IST Program, required by 10CFR50.55a, provides partial stroke test requirements for these valves.
Compliance with 10CFR50.55a, and as a result the IST Program and implementing procedures, is required by the PBAPS, Units 2 and 3 Operating Licenses.,
J These controls are adequate to ensure the required testing to demonstrate MSIV OPERABILITY is performed.
3.6.1.3 Rs The requirement to compare Local Leak Rate Test (LLRT) results to previously measured leak rates for large containment ventilation isolation valves to detect excessive valve degradation is a predictive maintenance type surveillance and is not necessary for assuring the
. OPERABILITY of these valves.
SR 3.6.1.1.1 and the requirements of 10CFR50 Appendix J, as modified by approved 5
,s 9
cxemptiens, providi cdsquats cccurenca larga centninm:nt ventilation isolation valves are maintained OPERABLE.
3.6.1.3 R, l
l The limit on the number of hours'for primary. containment I
purging has been relocated from the Technical
{
Specifications.
This requirement has no impact on primary containment purge and exhaust valve OPERABILITY.
The primary containment purge valves and exhaust. valves have been blocked so.that opening is restricted to less than or equal to the maximum allowed opening angle.
The primary l
containment purge and exhaust valve opening angles are l
f Verified to be within limits by SR 3.6.1.3.15.
From this position the valves have been demonstrated to be capable of closing following a design basis accident, thus the number of hours for which purging is allowed has no-impact on the primary containment isolation function.
In addition, the Note to SR 3.6.1.3.3, which limits the activities for which these valves may be opened, provides adequate assurance that the number of hours for primary containment purging are minimized.
3.6.1.3 Ra 3
The detailed listing of the penetration and flow path valves which are subject to the primary containment purge and exhaust valve specification in the CTS are related to design i
and are not necessary for assuring the OPERABILITY of the i
primary containment purge and exhaust valves.
3.6.1.3 R 33 The details that constitute primary containment integrity with respect to PCIVs are also attributes of PCIV OPERABILITY that~are adequately addressed by Surveillance Requirements (SRs) of Specification 3.6.1.3.
Therefore, i
these details are not necessary for. assuring the OPERABILITY of PCIVs.
3.6.1.6 R
[
3 The allowance to use a leak test to verify that the vacuum breakers are closed if a position indicator is inoperable is not necessary to assure the suppression chamber-to-drywell vacuum breakers are closed.
SR 3.6.1.6.1 provides adequate assurance the vacuum breakers are closed.
3.6.2.3 R 3 The requirements of Current Technical Specification (CTS) 4.5.B.1(d) for RHR suppression pool cooling motor operated valve testing are proposed to be relocated to procedures and the Inservice Testing (IST) Program.
These testing requirements do demonstrate the RHR suppression pool cooling valves are OPERABLE.
However, the IST Program, required by
}
6
u.
~10CFR50.552, providOc rcquirCDcnto for tho.tOsting of ASME
' Code class 1, 2,, and 3 valves in 'accordance with Section XI l
Jof the ASME Code. _ Compliance with 10CFR50.55a, and as a l
result ~the IST-Program and implementing procedures, is required by-the PBAPS,. Units 2 and 3 Operating Licenses.
These'controis-are adequate to ensure the required testing i
-to demonstrate' OPERABILITY is performed.
l 3.6.2.3.R l
2 i
The details of what constitutes an OPERABLE RHR supptession l
pool cooling subsystem have been relocated to the Bases consistent with NUREG-1433.
As stated in NEDC-31681, "BWR.
Owners' Group Improved BWR Technical Specifications," dated l
April 1989, details for system OPERABILITY are not necessary
)
in the LCO.
The defihition of OPERABILITY suffices.
NEDC-j 31681 was the BWR Owners' Group Topical Report from which NUREG-1433 was developed.
3.6.2.4 R2 1
The requirements of Current Technical Specification (CTS)
- 4. 5. B.1 ( f) for RHR suppression pool spray motor operated valve testing are proposed to be relocated to procedures and the Inservice Testing (IST) Program.
These testing l
requirements'do demonstrate the RHR suppression pool spray valves are OPERABLE.
However, the IST Program, required by l
10CFR50.55a, provides requirements for the testing of ASME Code Class 1, 2, and 3 valves in accordance with Section XI of the ASME Code.
Compliance with 10CFR50.55a, and as a l
result the IST Program and implementing procedures, is required by the PBAPS Units 2 and 3 Operating Licenses.
These controls are adequate to ensure the required testing to demonstrate OPERABILITY is performed.
3.6.3.1 R
]
1 The. detail that the Containment Atmospheric Dilution-(CAD)
System must be capable of supplying nitrogen to either the Unit 2 or Unit 3 containment for atmosphere dilution if required by post-LOCA conditions has been relocated to the Bases.
This detail is an attribute of CAD System OPERABILITY.
Details for system OPERABILITY are not necessary in the LCO.
The definition of OPERABILITY l
suffices.
j 3.6.4.1 R
)
3 The requirement to verify secondary containment capability to maintain 1/4 inch vacuum " prior to refueling" is not necessary to ensure secondary containment is OPERABLE during applicable MODES or specified conditions.
The SRs of Specification 3.6.4.1,
SR 3.0.1 and the requirements of the ACTIONS of Specification 3.6.4.1 are adequate to assure secondary containment is OPERABLE.
7
'1 3.6.4.1'R -
3 The-requirements related to maintenance of secondary j
containment during crane. operations associated with' fuel-cask movement are proposed to be relocated to procedures j
governing control of heavy loads since the movement of loads other.than fuel assemblies is administratively controlled j
based on heavy loads analyses.
As stated in NEDC-31681, i
"BWR Owners' Group Improved BWR Technical Specifications,"
{
dated April 1989, the movement of other. loads over irradiated fuel-assemblies is administratively controlled l
based on available analysis for an-individual load.
The i
references to " crane operations with loads" has therefore been relocated to these administrative controls.
NEDC-31681 was the BWR Owners' Group Topical Report from which NUREG-f 1433 was developed.
As such, secondary containment
{
requirements during crane operations associated with loads i
l other than fuel assemblies are also adequately controlled administratively based on heavy loads analyses.
]
3.6.4.2 R1 The requirements related to maintenance of secondary j
containment (and as a result secondary containment isolation valves) during crane operations associated with fuel cask movement are proposed to be relocated to procedures governing control of heavy loads since the movement of loads other than fuel assemblies is administratively controlled based on heavy loads analyses.
As stated in NEDC-31681,.
i "BWR Owners' Group Improved BWR Technical Specifications,"
dated April 1989, the movement of other loads over irradiated fuel assemblies is administratively controlled based on available analysis for an individual load.
The references to " crane operations with loads" has therefore been relocated to these administrative controls.
was the BWR Owners' Group Topical Report from which NUREG-l 1433 was developed.
As such, secondary containment requirements during crane operations associated with loads i
other than fuel assemblies are also adequately controlled i
administratively based on heavy loads analyses.
i 3.6.4.3 R l
2 The details of what constitutes an OPERABLE Standby Gas Treatment (SGT) subsystem have been relocated to the Bases.
Details for subsystem OPERABILITY are not necessary in the l
LCO.
The definition of OPERABILITY suffices.
QUESTION Identify any differences between the Unit 2 ITS and the Unit 3 ITS for Section 3.6.
8
l
RESPONSE
The differences between the PBAPS Unit 2 ITS and the Unit 3 ITS for Section 3.6 are identified in the marked up pages in Attachment A.
QUESTION f
DOCS Pas and Pas discuss words in the NUREG added or modified by BWR-15, C4.
BUR-15, C4 was not approved for Revision 1 of the improved STS, and, therefore, should not be referenced in the DOC or the NUREG markup.
Please revise the DOC and the NUREG markup to delete all references to BWR-15, C4.
RESPONSE
The DOC and the NUREG markup will be revised to delete reference to BWR-15, C4.
This change will not have any impact on the ITS or the Bases.
i QUESTION:
The following clarification is requested in the support of documentation for RELOCATED requirements.
j In each of the following Discussion of Changes, add a discussion of the reasons why relocation of the subject item (s) is justified.
3.7.1 R3 3.7.2 R2 3.7.3 R2 i
3.7.5 R2 3.7.7 R 3
RESPONSE
The following clarifications are provided in support of the relocated items.
3.7.1 R 3 The requirements of Current Technical Specification (CTS) 4.5.B for High Pressure Service Water (HPSW) pump OPERABILITY and capacity testing and HPSW motor operated valve testing are proposed to be relocated to procedures and the Inservice Testing (IST) Program.
These testing t
requirements do demonstrate the HPSW pumps and valves are OPERABLE.
However, the IST Program, required by 10CFR50.55a, provides requirements for the testing of all ASME Code Class 1, 2,
and 3 pumps and valves in accordance 9
=,
with Shction XI of tha ASME Cod 2..
Ccaplianca with 10CPR50.55a,-andLas a result the.IST Program and-implementing procedures, is required by the PBAPS Units 2 and 3 Operating Licenses.
These controls-are adequate to ensure the required testing to demonstrate OPERABILITY is performed.
3.7.2 R2 The requirements.of CTS 4.9.C.1 for Emergency. Service Water (ESW) pump OPERABILITY and capability testing.and ESW-automatic valve. testing are proposed to be relocated to procedures and the IST Program.
These testing requirements do demonstrate the ESW pumps and valves are OPERABLE.
However, the IST Program, required by 10CFR50.S5a, provides requirements for the testing of all ASME Code Class 1, 2,
and 3 pumps and valves in accordance with Section XI of.the ASME Code.
Compliance with 10CFR50.55a, and as a result the IST Program and implementing procedures, is required by the PBAPS Units 2 and 3 Operating Licenses.
These controls are adequate to ensure the required testing to demonstrate OPERABILITY is performed.
3.7.3 R2 The requirements of CTS 4.11.B.1 for. Emergency Cooling Water (ECW) pump OPERABILITY and capability testing and ESW booster pump testing are proposed to be relocated to procedures and the IST Program.
These testing requirements do demonstrate the ECW pump and ESW pumps ara OPERABLE.
However,'the ECW pump is not credited.in the mitigation of design basis accidents or transients.
As a result, not.
performing the ECW pump testing will not affect the plant's capability to mitigate.the consequences of any analyzed event.
The IST Program, required by 10CFR50.55a, provides requirements for the testing of all ASME Code Class 1, 2,
and 3 pumps and valves in accordance with Section XI of the ASME Code.' Compliance with 10CFR50.55a, and as a result the IST Program and implementing procedures, is required by the PBAPS Units 2 and 3 Operating Licenses.
These controls are adequate to ensure the required testing to demonstrate OPERABILITY is performed.
3.7.5 R2 The requirements of CTS 4.8.C.7.d related to the details of performance of the main condenser offgas activity rate surveillance (performed by an isotopic analysis of a representative sample) are not necessary to be included in the Technical Specifications to assure that main condenser offgas activity rate is within limits.
SR 3.7.5.1 provides adequate assurance the main condenser offgas activity rate is within limits.
10
r C
1
- +
13.7.7 Rr i
In the event spent fuel. water level is not within limits, i
CTS 3.10.C.2 requires suspension of movement of fuel i
' assemblies and. crane operations'with loads-in the spent fuel
. pool area after placing-fuel assemblies and crane loads in a l
safe condition.
The requirements related to. crane operations are proposed to'
~
be relocated to procedures _ governing control of. heavy loads since the movement of loads other than' fuel' assemblies is administratively controlled based-on heavy loads analyses.
.i As stated in NEDC-31681, "BWR Owners' Group Improved BWR Technical Specifications," dated April.1989, "The bounding design basis fuel handling accident over the spent fuel storage pool assumes an irradiated fuel assembly.is dropped onto an array of irradiated fuel assemblies seated in~the j
spent fue.? storage pool (typical bounded by the fuel handling accident over the RPV).
The movement of other l
loads over irradiated fuel assemblies is-administratively I
controlled based on available analysis for an-individual-load.
The references to " crane operations with loads" has therefore been relocated to these administrative controls" NEDC-31681 was the BWR Owners' Group Topical Report from which NUREG-1433 was developed.
The allowance to place fuel assemblies in a safe condition prior to suspending fuel movement is proposed to be relocated to the Bases.
This allowance is not necessary for assuring, in the case of spent fuel water level not within limits, actions are taken to preclude a spent fuel handling accident from occurring.
Required Action A.1 of Specification 3.7.7,
" Spent Fuel Storage Pool Water Level,"
is adequate to preclude a spent fuel handling accident from occurring.
OUESTION:
)
Identify any differences between the Unit 2 ITS and the Unit 3 ITS for Section 3.7.
RESPONSE
The differences between the PBAPS Unit 2 ITS and the Unit 3 ITS for Section 3.7 are identified in the marked up pages in Attachment B.
OUESTION:
ITS 3.7.3, Condition A.
Please provide additional justification for the 14-day completion Time when one required Emergency Cooling Tower fan is inoperable.
Specifically, please address how this Condition, Required Action, and Completion Time relate to that in the CTS (i.e., 7-day Completion Time for a total loss of function) and the consequences to the site when the Required 11
Actions and associatsd Completion Tim 3s of this LCO cannot bn mst
)
(i.e., dual unit shutdown).
RESPONSE
- ITS 3.7.3 (Emergency Heat' Sink), Condition A, provides a 14 day Completion Time when one required Emergency Cooling Tower fan is l
The 14 day Completion Time for this condition was J
determined by comparing the level of degradation associated when one required Emergency Cooling Tower fan is inoperable to the level of degradation associated with the loss of level in CTS 3.11.B.
With one required Emergency Cooling Tower fan
~t inoperable, a total loss of function has not occurred.
CTS 3.11.B allows a total loss of level in the Emergency Cooling Tower reservoir (a total loss of function) to exist for a period of 7 days.
Based on this comparison, the Completion Time for restoring one required Emergency Cooling Tower to OPERABLE status should be greater than 7 days.
Other factors taken into consideration in determining the 14 day Completion Time for Condition A were as follows:
l i
1.
the low probability of an event requiring the Emergency Cooling Tower fans (a loss of the Conoringo Pond due to a failure of the Conowingo dam or a floc. ding event beyond that i
which the conowingo dam is designed tc, mitigate) and i
i 2.
the consequences of a failure to meet the Required Actions i
and associated Completion Times of Specification 3.7.3 i
(since the Emergency Heat Sink, which includes the Emergency Cooling Tower fans, is a common system shared between the two units, a dual unit shutdown could be required).
As a result, the 14 day Completion Time for restoring one l
required Emergency Cooling Tower fan to OPERABLE status is i
considered te be justified based on the comparison to the PBAPS 4
specific licensing and design basis for the Emergency Heat Sink, the low probability of an event requiring the Emergency Cooling Tower fans and the safety benefit gained by potentially avoiding a dual unit shutdown.
j l
12
f4 b
i b
i i
t t
l I
t ATTACHMENT A i
SECTION 3.6, CONTAINMENT SYSTEMS 1
DIFFERENCES BETWEEN PBAPS UNIT 2 AND UNIT 3 ITS AND BASES l
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I r
i
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l t
h I
I t
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^^
p L
SGT System B 3.6.4.3 l
BASIS i
BACKGROUND the receipt of a' secondary containment isolation signal.
i (continued)
Maintaining this negative pressure is based upon the existence of calm wind conditions (up to 5 mph), a maximum SGT System flow rate of 10,500 cfs, outside air temperature i
of 95'F and a temperature of 150*F for air entering the SGT l
System from inside secondary containment.
j The demister is provided to remove entrained water in the air, while the electric heater reduces the relative humidity of the airstream to less.than 70% (Ref. 2). The prefilter removes large particulate matter, while the HEPA filter removes fine particulate matter and protects the charcoal from fouling. The charcoal-adsorber. removes gaseous elemental iodine and organic iodidss, and the final HEPA filter collects any carbon fines exhausted from the charcoal adsorber.
The SGT System automatically starts and operates in response-to actuation signals indicative of conditions or an acciden that' could require operation of the system.
11owing initiation, two charcoal filter train fans (
020 V d W
j OBV020) start. Upon verification that both bsystems are operating, the redundant subsystem is normally shut down.
APPLICABLE The design basis for the SGT System is to mitigate the 1
SAFETY ANALYSES consequences of a loss of coolant accident and fuel handling accidents (Ref. 2). For all events analyzed, the SGT System is shown to be automatically initiated to reduce, via filtration and adsorption, the radioactive material released to the environment.
The SGT System satisfies Criterion 3 of the NRC Policy i
Statement.
i LC0 Following a DBA, a minimum of one SGT subsystem is required to maintain the secondary conteinment at a negative pressure with respect to the environment and to process gaseous releases. Meeting the LCO requirements for.two OPERABLE subsystems ensures operation of at least one SGT subsystem in the event of a single active failure.
t (continued)
I l
1 PBAPS UNIT 2 B 3.6-86 Revision 0
)
SGT System j
B 3.6.4.3
{
BASES y
l
~
LCO For Uni 2 one SGT sub tem is OPERABLE when one charcoal (continued) filter t in, one fan (
020) and associated ductwork, l
dampers, valves, and co rols are OPERABLE. The second SGT 1
subsystem is OPERABLE when the other charcoal filter train, one fan (0BV020) and associated ductwork, damper, valves, l
and controls are OPERABLE.
j l
' APPLICABILITY In MODES 1, 2, and 3, a DBA could lead to a fission product i
release to primary containment that. leaks to secondary containment. Therefore, SGT System OPERABILITY is required during these MODES.
In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature l
limitations in these MODES. Therefore, maintaining the SGT 1
System in OPERABLE status is not required in MODE 4 or 5, j
except for other situations under which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel
-l (OPDRVs), during CORE ALTERATIONS, or during movement of' irradiated fuel assemblies in the secondary containment.
ACTIONS Ad With one SGT subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status in 7 days.
In this-Condition, the remaining OPERABLE SGT subsystem is adequate to perform the required radioactivity release control function. However, the overall system reliability is reduced because a single failure in the OPERABLE subsystem could result in the radioactivity release control function.
not being adequately performed. The 7 day Completion Time j
is based on consideration of such factors as the i
availability of the OPERABLE re h "fant SGT subsystem and the l
low probability of a DBA occurr..; during this period.
l l
B.1 and B.2 If the SGT subsystem cannot be restored to OPERABLE status within the required Completion Time in MODE 1, 2, or 3, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within (continued)
PBAPS UNIT 2 B 3.6-87 Revision 0 2
ATTACHMENT B SECTION 3.7, PIANT SYSTEMS DIFFERENCES BETWEEN PBAPS UNIT 2 AND UNIT 3 ITS AND BASES
Emerg:ncy Heat Sink B 3.7.3 BASES (continued)
APPLICABLE The emergency heat sink is required to support removal of SAFETY ANALYSES heat from the Unit 2 and 3 reactors, primary containments, and other safety related equipment by providing a seismic Class I heat sink for the ESW and HPSW Systems for shutdown of the reactors when the normal non-safety grace heat sink (Conowingo Pond) is unavailable.
Sufficient water inventory is available to supply all the ESW and HPSW System cooling requirements of both units during shutdown with a concurrent loss of offsite power for a 7 day period with no additional makeup water available. The ability of the emergency heat sink to support the shutdown of both Units 2 and 3 in the event of the loss of the normal heat sink is presented in the UFSAR (Ref.1).
The Emergency Heat Sink satisfies Criterion 3 of the NRC Policy Statement.
LCO In the event the normal heat sink is unavailable and offsite power is lost, the emergency heat sink is required to provide the minimum heat removal capability for the ESW and HPSW Systems to safely shutdown both units. To ensure this requirement is met, the emergency heat sink must be OPERABLE.
The emergency heat sink is considered OPERABLE when it has an OPERABLE flow path from the ESW System with one OPERABLE ESW booster pump, an OPERABLE flow path from both the Unit 2 and Unit 3 HPSW Systems, two of the three cooling tower cells and two of the three associated fans OPERABLE, two OPERABLE gravity feed lines from the emergency heat sink reservoir into the pump structure bays with the Unit 2 and 3 pump structure bays connected or one OPERABLE avity ed line from the emergency heat sink to the Uni pu 8 W3 structure bay with the Unit 2 and 3 pump str ure ba not connected, and the capability exists to manually isolate the ESW and HPSW pump structure bays from the Conowingo Pond.
Valves in the required flow paths are considered OPERABLE if they can be manually aligned to their correct position. The OPERABILITY of the emergency heat sink also requires a minimum water level in the emergency heat sink reservoir of 17 feet.
t (continued)
PBAPS UNIT 2 B 3.7-12 Revision 0
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