Text

Safety Evaluation Supporting Amends 203 & 206 to Licenses DPR-44 & DPR-56,respectively
	ML20086B525
Person / Time
Site:	Peach Bottom
Issue date:	06/06/1995
From:	; Office of Nuclear Reactor Regulation
To:	;
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ML20086B515	List: ML20086B514; ML20086B525;
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	NUDOCS 9507050429
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k UNITED STATES

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,j NUCLEAR REGULATORY COMMISSION l

't WASHINGTON, D.C. 20606-0001 r

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SAFETY-EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 203 AND 206 TO FACILITY OPERATING i

LICENSE NOS. DPR-44 and DPR-56 I

PECO ENERGY COMPANY PUBLIC SERVICE ELECTRIC AND GAS COMPANY DELMARVA POWER AND LIGHT COMPANY ATLANTIC CITY ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION. UNIT NOS. 2 AND 3 l

DOCKET NOS. 50-277 AND 50-278 i

1.0 INTRODUCTION

By letter dated September 26, 1994, as supplemented by letters dated January 5, and March 23, 1995, the PECO Energy Company (PECO or the licensee) submitted a request for changes to the Peach Bottom Atomic Power Station (PBAPS), Unit Nos. 2 and 3, Technical Specifications (TSs).

The requested changes would extend the surveillance test intervals and allowable out-of service times for the testing and or repair of instrumentation that actuate the Reactor Protection System, Primary Containment Isolation, Core and Containment Cooling systems, Control Rod Blocks, Radiation Monitoring systems and Alternate Rod Insertion / Recirculation Pump Trip. The supplemental letters provided clarifying information and did not change the initial proposed no significant hazards r.or. sideration determination.

2.0 EVALUATION j

By letter dated September 26, 1994, PECO Energy Company, the licensee for PBAPS, Units 2 and 3, proposed to revise the TS requirements regarding l

surveillance test intervals (STIs) and allowed outage times (A0Ts) for the actuation instrumentation for the following:

TS 3.1.1 Reactor Protection System; TS 3.2.A Primary Containment Isolation; TS 3.2.B Core and Containment Cooling Systems; TS 3.2.C Control Rod Block; TS 3.2.0 Radiation Monitoring Systems; TS 3.2.E Drywell Leak Detection; TS 3.2.F Surveillance Information Readouts; and TS 3.2.G Alternate Rod Insertion and Recirculation Pump Trip.

The proposed A0T and STI changes are based on the most recently approved BWR Owners' Group letters which were used in establishing A0Ts and STIs for the l

new BWR Standard Technical Specifications, NUREG-1433, " Standard Technical 1

Specifications, General Electric Plants, BWR/4." The licensee also provided 9507050429 950606 PDR ADOCK 05000277 P

PDR information regarding plant-specific evaluations which are contained in reports MDE-87-04B5-1, " Technical Specification Improvement Analysis for the Reactor Protection System for Peach Bottom Atomic Power Station, Units 2 and 3," dated October 1987 and RE-020, " Technical Specification Improvement Analysis for Emergency Core Cooling System Actuation Instrumentation for Peach Bottom Atomic Power Station, Units 2 and 3," dated December 1986.

Additionally, the format and wording of NUREG-1433 were selected to improve the clarity and useability of the PBAPS Technical Specifications. Therefore, incorporation of the extended STIs and A0Ts into PBAPS TSs is based on the guidance provided in NUREG-1433.

The proposed changes to the PBAPS TSs fall into three categories.

a.

Changes to the minimum surveillance test intervals and maximum allowable out-of-service times for the testing and/or repair of instrumentation.

These changes are based on and justified by the results of generic analyses in licensing topical reports (LTRs).

b.

Changes to conditions, required actions, and completion times needed to make PBAPS TS requirements for instrumentation consistent with the assumptions used in the analyses in LTRs, and additional changes to conditions, required actions, and completion times needed to make PBAPS TS requirements for instrumentation consistent with the BWR Standard Technical Specifications, Changes that reformat, renumber, and/or reword existing requirements to c.

incorporate the changes described above into the PBAPS plant-specific TSs.

These changes are also consistent with and use the same approach ar.d specific requirements in NUREG-1433.

The reformatting, renumbering, and rewording resulted in no technical changes (either actual or interpretational) to the PBAPS TSs except where specifically discussed in this evaluation.

i NRC Generic letter (GL) 83-28, Item 4.5.3, required an evaluation of the

~

intervals specified in the TSs for on-line functional testing of the Reactor Protection System (RPS).

To complete this evaluation, the BWR Owners' Group (BWR0G), in conjunction with the General Electric Company (GE), developed a i

methodology that evaluates the impact on RPS reliability. The methodology and results of the generic analysis for each major type of actuation instrumentation were published in LTRs.

The BWROG sponsored studies by GE to apply probabilistic analytical methods in order to justify an increase in STIs and A0Ts for various BWR instrumentation. All proposed STI and A0T changes in accordance with these studies resulted in a series of GE LTRs which have been previously reviewed and approved by the NRC staff. Also, A0Ts are provided in accordance with the most recently approved BWROG letters which were used in the development of NUREG-1433.

The PBAPS TS changes will permit specified j

Channel Tests to be conducted quarterly rather than weekly or monthly based on the licensee's commitment to several plant-specific conditions.

1 I 2.1 Backaround The proposed changes to the TSs extend STIs and A0Ts for the testing and/or repair of instrumentation that actuates the Reactor Protection System, Primary Containment Isolation, Core and Containment Cooling Systems, Control Rod Blocks, Radiation Monitoring Systems, and Alternate Rod Insertion-Recirculation Pump Trip in accordance with the following GE LTRs:

i 1.

NEDC-30851P-A, " Technical Specification Improvement Analyses for BWR Reactor Protection System," dated March 1988.

2.

NEDC-30936P-A (Parts 1 and 2), "BWR Owners' Group Technical Specification Improvement Methcdology (With Demonstration for BWR ECCS Actuation Instrumentation)," dated December 1988.

3.

NEDC-30851P-A (Supplement 1), " Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation," dated October 1988.

4.

NEDC-30851P-A (Supplement 2), " Technical Specification Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation," dated March 1989.

5.

NEDC-31677P-A, " Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation," dated July 1988.

6.

GENE-770-06-1, " Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," dated April 1992.

7.

GENE-770-06-2, " Bases for Changes to Surveillance Test Intervals and Allowed Out-of Service Times for Selected Instrumentation Technical Specifications," dated December 1992.

2.2 Reactor Protection System (TS 3.1)

The proposed changes to PBAPS TS Section 3.1, Reactor Protection System, are described below.

a.

Proposed Limiting Conditions for Operation (LCO) 3.1.A deleted the 5

existing TS statements of Applicability and the Objective (TS 3/4.1) for the Reactor Protection System (RPS) instrumentation that does not establish any requirements or provide any information specific to the RPS.

The proposed statements of the LCO 3.1.A and Applicability are consistent with NUREG-1433.

These changes improve clarity and establish the numbering and format necessary to support technical changes.

t

, b.

Proposed LCO 3.1.A contains a new heading, " Conditions and Required Actions." The proposed change will extend A0Ts for RPS instrument channels.by inserting required actions and completion times that are 4

consistent with NUREG-1433, Section 3.3.1.1, Reactor Protection System Instrumentation, Conditions A, B, C, and D.

To implement this change, the conditions and required actions, which are needed to support the assumptions used in the analysis that justified extending the instrumentation A0Ts and STIs, were incorporated into the PBAPS TS. The proposed conditions and required actions satisfy the assumptions and j

conditions in NEDC-30851P-A.

The resulting changes to the existing requirements are described below in Sections 2.1.c through 2.1.h.

c.

Proposed LCO 3.1.A, Condition 1: 'The condition description in Table 3.1.1, Note I was moved into the LCO and modified to clarify that the i

condition could be simultaneously applied to more than one trip function and more than one trip system within a trip function by changing the wording to "one or more channel (s) required by Table 3.1.1 inoperable in one or more Trip Functions." This change is consistent with the statement j

in NUREG-1433, Section 3.3.1.1, that allows separate conditional entry for RPS functions.

d.

Proposed LCO 3.1.A, Condition 1: The required action for an inoperable channel currently in Table 3.1.1, Note 1, was changed to "pla'ce the inoperable channel or associated trip system in trip." The proposed 1

action results in the same condition as tripping the channel.

This change 1

improves clarity and_is consistent with NUREG-1433.

i e.

Proposed LC0 3.1.A, Condition 1: The A0T for an inoperable RPS channel currently in Table 3.1.1, Note 1, is extended from "immediately" to "within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ." This change is justified based on staff approval of NEDC-30851P-A and MDE-87-0485-1.

The proposed change is consistent with NUREG-1433.

f.

Proposed LCO 3.1.A, Condition 2: A condition, "With one or more Trip Functions with one or more channels required by Table 3.1.1 inoperable in both trip systems," is established. The associated required action is to, place a channel in one trip system in trip or place one trip system in 1

trip within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

This change is more restrictive than the requirement in existing LC0 4.1.C which allows an 8-hour A0T for the same situation.

1 This change is required to satisfy assumptions in NEDC-30851P-A and MDE-87-0485-1.

The proposed change is consistent with NUREG-1433.

g.

Proposed LC0 3.1.A. Condition 3: A new condition and required action, "With one or more automatic trip functions or two or more manual trip functions (Mode Switch in Shutdown, Manual Scram and RPS Channel Test Switches) with RPS trip capability not maintained, restore RPS trip capability within one hour," was established. This new condition and w-required action is necessary to justify extending the A0T (proposed LC0 3.1.A, Condition 1) for an inoperable channel.

This change prevents the extended A0T from resulting in an extended loss of trip capability.

The PBAPS design for the manual scram functions (Manual Scram and Reactor Mode Switch in Shutdown) differs from the generic BWR 4 in that these functions actuate the scram function using instrument channels (Channels A3 and B3) separate from the channels used to actuate the automatic scram functions (Channels A1, A2, B1, and 82). Therefore, testing the manual scram function does not exercise the automatic function scram contacts as was assumed in NEDC-30851P-A.

In MDE-87-0485-1, the licensee states that this difference has no effect on the applicability of NEDC-30851P-A to PBAPS because "each channel has a test switch which is functionally the same as the manual scram switch in the generic model." Therefore, to satisfy the requirement that the manual scram function be exercised weekly to demonstrate the operability of the scram contacts associated with the automatic scram function, the licensee proposed requirements for weekly Channel Functional Testing of the RPS Channel Test Switches.

The RPS Channel Test Switches were added to Table 3.1.1 in order to establish appropriate operability requirements and appropriate required actions and completion times for an inoperable channel.

The difference between PBAPS and the generic BWR 4 requires that PBAPS, Units 2 and 3, have TSs governing 3 separate manual scram functions in the control room: Mode Switch in Shutdown; Manual Scram; and the four RPS Channel Test Switches.

The PBAPS Mode Switch in Shutdown and Manual Scram have only two channels, i.e., one channel per trip system.

Therefore, the loss of a single channel of the Manual Scram or the Mode Switch in Shutdown will result in a loss of function at PBAPS but not in the generic BWR 4 which has 4 channels for these manual functions.

The proposed PBAPS TS that will govern loss of trip capability in one of the three manual trip functions (Mode Switch in Shutdown or Manual Scram or RPS Channel Test Switches) will allow 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to restore trip capability for the function as long as trip capability in the other two manual scram functions is maintained.

By requiring only two of the three manual scram functions in the control room to maintain trip capability, the proposed PBAPS TS is equivalent tu the recommendations in NUREG-1433 in that it will allow the extended A0T to be applied if there is a loss of a channel in either the Manual Scram or the Mode Switch in Shutdown.

PBAPS procedures and operator training will be revised to recognize that RPS Test Switches are an alternate manual scram function in the control room.

Therefore, the proposed change is equivalent to the requirements for the generic BWR 4 which ensures that a minimum of two manual scram functions in the Control Room are operable, and is consistent with NUREG-1433.

h.

Proposed LC0 3.1.A, Condition 4: This change incorporates into the proposed LC0 a requirement currently located in Table 3.1.1, Note 1, that specific actions must be performed whenever the required actions and completion times of proposed Actions 1 or 2 or 3 cannot be met.

This is an administrative change that improves clarity by establishing a link i

between the LC0 and the associated required actions in the Notes to Table 3.1.1.

This change is consistent with NUREG-1433.

i.

Proposed LC0 3.1.A, Conditions and Required Actions: Two notes were added to provide clarification concerning implementation of required actions.

The first note will allow initiation of required actions to be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months when a channel is placed in an inoperable status solely for performance of required surveillances, provided the associated trip function maintains trip capability. This change is more restrictive than the requirement in existing LCO 4.1.C which allows an 8-hour A0T in the same situation.

The second note provides clarification that an inoperable channel or trip system need not be placed in the tripped condition where this would cause the Trip Function to occur.

In these cases, if the inoperable channel is not restored to operable status within the required time, the action required by Table 3.1.1 for that trip Function shall be taken.

Both notes are justified based on NEDC-30851P-A and are consistent with NUREG-1433.

i j.

Proposed deletion of existing TS Section 4.1.C: The requirement in existing TS Section 4.1.C allowing the trip system containing an unsafe failure to be placed in the untripped condition for a period of up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months while surveillance testing is being performed on the other RPS channels is superseded by proposed LC0 3.1.A, Condition 2, and proposed LCO 3.1.A, Note 1 to the conditions and required actions. This change is necessary to make A0Ts for RPS consistent with the assumptions in NEDC-30851P-A and MDE-87-0485-1 and the change is consistent with NUREG-1433.

k.

Reformatting associated with the proposed changes described above allows all of the requirements of TS Sections 3/4.D.1 and 3/4.1.D.2 to be placed on page 36. Therefore, the requirements of 3/4.1.D.2 will be moved from page 36a to 36. This is an administrative change to improve useability.

1.

The temporary note marked with a double asterisk on existing page 36a is deleted.

This note specifies that the requirements of TS Sections 3/4.1.D.1 and 3/4.1.D.2 will be " Effective upon installation of the protective trip devices." The referenced protective trip devices were installed during 1988. Therefore, the temporary note is deleted.

m.

Proposed change to Table 3.1.1: References to Note 1 in the column headed

" Minimum Number of Operable Instruments per Trip System" are deleted because the conditions and required actions associated with inoperable RPS instrument channels are located in proposed LC0 3.1.A, Conditions and Required Actions 1, 2, 3, and 4.

The references to Note 1 in the Table 3.1.1 column headed " Action" provides direction to the specific action required for individual trip functions in conjunction with proposed LCO 3.1.A, Condition 4, when the actions and completion times in proposed TS Section 3.1.A cannot be satisfied. This is an administrative change for clarity.

l k-I n.

Proposed change to Table 3.1.1, Note 1: The existing requirement in Table 3.1.1, Note 1, was relocated to proposed LCO 3.1.A.

The conditions and l

required actions specified in Table 3.1.1, Note I were superseded by

?

proposed LC0 3.1.A, Conditions 1, 2, 3, and 4.

This is an administrative change for clarity.

o.

Proposed change to Table 3.1.1: The proposed change adds the RPS Channel Test switches to Table 3.1.1 to support the changes described in 2.1.g i

above. The RPS Channel Test switches were added to Table 3.1.1 as Item

18. This function is identified as having 4 instrument channels with 2 l

channels required per trip system. The requirements for operability and the required actions for an inoperable channel are the same as those currently required for the Manual Scram and the Mode Switch in Shutdown.

This change establishes operability requirements and required actions and completion times for the RPS Channel Test switches to satisfy assumptions in MDE-87-0485-1.

i p.

Proposed change tu Table 3.1.1: The proposed change increases the number of required Main Steam Line (MSL) Isolation valve closure channels per trip system from 4 to 8 and increases the number of channels provided by design from 8 to 16 channels.

PBAPS, like the generic BWR 4, has eight main steam line isolation valves with 2 valve stem position switches (one associated with each trip system) for each valve. The proposed change defines this configuration as 16 channels (i.e., the number of switches) with 8 channels per trip system and adopts tL cavention used in NUREG-1433. This ensures that proposed changes to LC0 3.1.A are implemented consistent with NUREG-1433.

q.

Proposed change to Table 4.1.1: The minimum frequency specified for the performance of Instrument Channel Functional Tests is extended from once per month (or once per week for APRM Trip Functions and Main Steam Line Isolation Valve Closure Trip) to once every 3 months for the following instruments: APRM Inoperative; APRM Downscale;.APRM Flow Bias; High Reactor Pressure; High Drywell Pressure; Reactor Low Water Level; High Water Level in Scram Discharge Volume; Turbine Condenser Low Vacuum; MSL j

i High Radiation; MSL Isolation Valve Closure; Turbine Control Valve EHC 011 Pressure; and Turbine Stop Valve Closure. This change is justified by the analyses in NEDC-30851P-A and is consistent with NUREG-1433.

r.

Proposed change to Table 4.1.1: The minimum frequency specified for the

{

performance of Instrument Channel Functional Tests for the RPS Channel Test Switches is increased from "every refueling outage or after channel maintenance" to "once per week or after channel maintenance." This more restrictive change is an assumption in NEDC-30851P-A and a prerequisite for extending RPS A0Ts and STIs.

The analysis in NEDC-30851P-A determined that RPS failure was insensitive to changes in instrument channel failure rates but was highly sensitive to commen cause failures of the scram contacts and/or operator error during testing. However, the design of the manual scram function at PBAPS differs from the design of the manual scram function in the generic model because scram channels cannot be tripped individually.

In MDE-87-0485-1, it was determined that this difference has no effect on the applicability of NEDC-30851P-A to PBAPS because "each channel has a test switch which is functionally the same as the manual scram switch in the generic model." MDE-87-0485-1 also indicates that "the manual scram on separate channels is functionally the same as the manual scram circuit in the generic model." Therefore, the proposed change maintains the Functional Test frequency for the manual scram function at "every 3 months" but increases the frequency for the Functional Test of the RPS Channel Test Switches from "every refueling outage or after channel maintenance" to "once per week or after channel maintenance." The change satisfies the assumptions of NEDC-30851P-A for weekly testing of scram contacts.

s.

Proposed change to Table 4.1.1:

Note 1 to Table 4.1.1 and References to Note 1 were deleted. Note 1 states that frequency of performance for functional tests is " initially once every month" but that the frequency could be changed based on failure rate data if the proposed change and supporting failure rate data was reviewed and approved by the NRC. NEDC-30851P-A and MDE-87-06-0485-1 document failure rate data, and provide the justification for extending the functional test interval from once per month to once every 3 months.

These documents were reviewed and approved by the staff.

The conditions that Note 1 identifies for extending the RPS functional test frequency beyond the currently existing interval are satisfied by this submittal and therefore, Note 1 is no longer applicable.

t.

Table 3.1.1, Note 1, Action A:

The existing action requires initiation of the insertion of operable control rods and completion of this action within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months whenever the trip system cannot be placed in trip within the required completion time for the applicable functions.

The proposed change will require completion of insertion within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This is equivalent to the NUREG-1433, TS 3.3.1.1, Condition G requirement, to be in Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months under the same conditions.

u.

Table 3.1.1, Note 1, Action B: The proposed change decreases the time allowed to reduce power level to the Intermediate Range Monitor (IRM) and place the mode switch in the startup position (i.e., bring the plant to Mode 2) from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The proposed change is equivalent to the NUREG-1433, TS 3.3.1.1, Condition F requirement, to be in Mode 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months under the same conditions.

v.

Table 3.1.1, Note 1, Action C:

The proposed change decreases the time allowed to reduce power level and close the Main Steam Isolation Valves (MSIVs) from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The proposed change is equivalent to the

i

{

_g_

NUREG-1433, TS 3.3.1.1, Condition F requirement, to be in Mode 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months under the same conditions.

w.

Table 3.1.1, Note 1, Action D: The proposed change establishes 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months as the time allowed to reduce power level to less than 30% whereas no time limit is currently specified. This change eliminates an existing ambiguity.

The proposed change is equivalent to the NUREG-1433, TS 3.3.1.1, Condition E requirement, to reduce power within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months under the same conditions.

i The Bases for TS Section 3/4.1.A were revised to reflect the changes x.

discussed above and to correct typographical errors.

2.3 Primary Containment Isolation Functions (TS 3.2.A)

The changes proposed for PBAPS TS Section 3.2.A, Primary Containment Isolation Functions, are described below.

]

The proposed change deletes the existing statements of Applicability and a.

Objective for Section 3.2, Protective Instrumentation (TS 3/4.2), because these statements do not establish any requirements. The proposed change establishes for each separate category of protective instrumentation, 1

concise and complete statements of the LC0 and Applicability which are consistent with NUREG-1433.

i.

The proposed change separates existing LC0 3.2.A into separate statements for the LC0 and the Applicability under appropriate headings with no technical changes.

ii. Proposed LC0 3.2.A clarifies the existing LCO requirement concerning the number of required trip systems by relocating, from Table 3.2. A, Note 1, an existing requirement that there shall be two Operable or tripped trip systems for each Primary Containn,ent Isolation (PCI)

Function in Table 3.2.A.

Each of the changes above are not technical, but merely improve clarity and/or establish the numbering and format necessary to support technical changes.

These chan;es are consistent with NUREG-1433.

b.

Proposed LC0 3.2.A contains a new heading, " Conditions and Required Actions." The conditions resulting from an inoperable instrument channel, i

the associated required actions and the completion times, currently in Table 3.2.A, Note 2, were incorporated as TS Sections 3.2.A.1 through 3.2.A.3.

These conditions, required actions, and completion times were modified as necessary to satisfy the assumptions and conditions in NEDC-30851P-A, NEDC-30936P-A, NEDC-30851P-A (Supplement 2) and NEDC-31677P-A

, which were used to justify extension of A0Ts and STIs for PCI Instrumentation.

The proposed conditions, required actions and completion times which are consistent with NUREG-1433, Section 3.3.6.1, Primary Containment Isolation Instrumentation, Conditions A, B, and C.

c.

Proposed LC0 3.2.A, Condition 1: The condition description currently in Table 3.2.A, Note 2, was modified to clarify that the condition could be simultaneously applied to more than one trip function and more than one trip system within a trip function by changing the wording from "if the first column cannot be met for one of the trip systems" to "with one or more channel (s) required by Table 3.2.A inoperable." This change is consistent with the statement in.NUREG-1433, Section 3.3.6.1.A.

This is t

an administrative change that improves clarity because there is no change to the existing interpretation of the requirements.

d.

Proposed LC0 3.2.A, Condition 1: The required action for an inoperable channel currently in Table 3.2.A, Note 2, was changed from "that trip system shall be tripped" to " place channel (s) in trip." This change is consistent with NUREG-1433, Section, 3.3.6.1.A.

This is an administrative change that improves clarity because the proposed required action results in the same condition as tripping the channel and there is no change to the existing interpretation of the requirements.

e.

Proposed LC0 3.2.A, Condition 1: The repair A0T for an inoperable Primary Containment Isolation function channel was extended from immediately (interpreted as within one hour from Table 3.2. A _ Note 2) to within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for functions common to RPS (Table 3.2. A, Items 1, 4, and 5); and, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for functions common to ECCS and/or not common to RPS or ECCS (Table 3.2.A, Items other than 1, 4, and 5). The A0Ts specified for each PCI instrument function are based on the analyses in NEDC-30851P-A, NEDC-30851P-A (Supplement 2), and NEDC-31677P-A. The condition description, required actions and completion time are consistent with NUREG-1433, except Item 5, High Radiation Steam Line Tunnel, which is being maintained at PBAPS even though it is not included in NUREG-1433.

f.

Proposed LCO 3.2.A, Condition 2: A new condition, "With one or more automatic functions with primary containment isolation function not maintained," was established.

This condition will have required actions that will restore primary containment isolation capability within one hour or, take the action required by the existing Table 3.2.A, Note 2, within one hour for a loss of isolation function. This new condition and required action are necessary because the analyses in NEDC-30851P-A, NEDC-30851P-A (Supplement 2), and NEDC-31677P-A did not consider that extending the A0T could result in an extended loss of trip capability and NEDC-30851P-A (Supplement 2) and NEDC-31677P-A were used to justify 1

)

i I

-u extending A0Ts (proposed LCO 3.2.A, Condition 1) for an inoperable channel. The condition description, required actions and completion time are consistent with NUREG-1433.

l 1

9 Proposed LCO 3.2.A, Condition 3: This change clarifies and incorporates into the LCO a requirement currently located in Table 3.2.A, Note 2, that specific actions be performed whenever the required actions and completion times of proposed conditions 1 or 2 cannot be met. This is an administrative change that improves clarity because it establishes a link between the LCO and the associated required actions.

The required actions specified by proposed Condition 3 are still located in Table 3.2.A (Note i

2, Actions A, B, C, D, E and F) and the introductory paragraph was revised to make it consistent with proposed LCO 3.2.A, Condition 3.

h.

Proposed LC0 3.2.A, Conditions and Required Actions: Three new notes were added to provide clarification concerning implementation of required actions.

The first note will allow initiation of required actions to be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months when a channel is placed in an inoperable status solely for performance of required surveillances, provided the associated i

trip function maintains primary containment isolation capability.

The second note provides clarification that an inoperable channel or trip system need not be placed in the tripped condition where this would cause l

the trip function to occur.

In these cases, if the inoperable channel is i

not restored to operable status within the required time, the action required by Table 3.2.A for that trip function shall be taken.

Both notes i

are justified based on NEDC-30851P-A, NEDC-30851P-A (Supplement 2), and NEDC-31677P-A.

h Additionally, a third note specifies that the requirement to restore isolation capability within one hour is not applicable to Item 11, Reactor Cleanup System High Temperature. This exception is acceptable because the reactor cleanup system high temperature function is for equipment protection only (prevents reactor water cleanup system demineralizer resin overheating) and is not assumed in the P8APS safety analysis.

i.

Proposed change to Table 3.2.A, Note 1:

References to Note 1 in the column headed " Minimum No. of Operable Instrument Channels per Trip System" on Table 3.2.A were deleted because these requirements regarding i

the number of trip systems and the applicability were incorporated directly into the statements of the LC0 and Applicability in TS Section 3.2.A.

This is an administrative change to in. prove clarity and useability.

J.

Proposed change to Table 3.2.A, Note 2:

The wording of the condition description and required action in Table 3.2.A, Note 2, was revised from "if the first column cannot be met for one of the trip systems, that trip system shall be tripped or the appropriate action listed below shall be taken" to "if the required actions and associated completion time of i

)

i l Specification 3.2.A, Actions 1 or 2 are not met, take the action listed below for the affected trip function as required by Table 3.2.A."

This is an administrative change necessary to implement the other changes described above in Sections 2.2.b through 2.2.1.

k.

Proposed change to Table 4.2.A: The minimum frequency specified for the I

performance of Instrument Channel Functional Tests is extended from once per month to once every 3 months for the following instruments: Reactor High Pressure (Shutdown Cooling Permissive); Reactor Low-Low-Low Water Level; Main Steam High Temperature; Main Steam High Flow; Main Steam Low i

Pressure; Reactor Water Cleanup High Flow; Reactor Water Cleanup High Temperature; and Rear. tor Pressure (Feedwater Flush Permissive). These changes to the STI for Instrument Channel Functional Tests are justified by NEDC-30851P-A (Supplement 2), NEDC-31677P-A, MDE-87-0485-1, and RE-020 and the change is consistent with NUREG-1433, except for Reactor Pressure (Feedwater Flush Permissive) which is being maintained at PBAPS even though it is not included in NUREG-1433.

1.

Proposed change to Notes for Tables 4.2.A through 4.2.F: Note 1 of the combined Notes for Tables 4.2.A through 4.2.F and References to Note 1 on Table 4.2.A were deleted. Note 1 states that frequency of performance for functional tests is " initially once every month" but that the frequency could be changed based on failure rate data if the proposed change and supporting failure rate data was reviewed and approved by the NRC. GE LTRs constitute the review and approval of failure rate data and provide the justification for extending functional test intervals from once per month to once every 3 months. Therefore, Note 1 is no longer applicable.

Deletion of Note 1 to notes for Tables 4.2.A through 4.2.F and deletion of i

references to Note 1 on Table 4.2.A is an administrative change.

m.

Proposed Table 3.2. A, Note 2, Action B: The proposed change to Note 2, Action B allows 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (instead of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ) to isolate the Main Steam Lines whenever the trip system associated with isolating MSIVs is inoperable and cannot be placed in trip within the required completion time.

This change is justified because 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is the completion time in NUREG-1433, Specification 3.3.6.1, Condition D.

The proposed change is acceptable because:

isolation capability is still provided by the redundant MSIV isolation instrument channels; there is a new concurrent requirement in proposed Condition 2 to isolate the MSL within one hour if automatic MSL isolation capability is lost; the additional 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months will allow for a more orderly reduction in power and isolation of the MSL and, the change will not allow continuous operation with plant conditions such that a single failure will preclude the affected isolation function from being performed. As a result, the change does not affect the current analysis assumptions and.is consistent with NUREG-1433.

- n.

Proposed Table 3.2.A, Note 2, Actions C, D and F: The proposed change to Note 2, Actions C, D and F, specifies a completion time of "within one hour" for isolation of the affected penetration whenever the trip system associated with isolating the penetration is inoperable and cannot be placed in trip within the required completion time.

The existing requirements do not specify a completion time. -This change is consistent with NUREG-1433, Section 3.3.6.1, Condition F.

The Bases for TS Section 3/4.2.A were revised to reflect the changes o.

discussed above and to correct typographical errors.

2.4 Core and Containment Coolina Systems (TS 3.2.8)

The changes proposed for PBAPS TS Section 3.2.B, Core and Containment Cooling Systems, are described below.

The proposed change deletes the existing statements of Applicability and a.

Objective'for Section 3.2, Protective Instrumentation (TS 3/4.2), because these statements, as currently written, do not establish any requirements.

The proposed change establishes for each separate category of protective instrumentation, concise and complete statements of the LC0 and Applicability which are consistent with NUREG-1433. The changes to the statements of LC0 requirements and Applicability for TS Section 3.2.8, Core and Containment Cooling Systems (CCCS), are as follows:

1.

The proposed change creates a new page, 57a, for the CCCS requirements and separates the LC0 requirements and the Applicability requirements into separate sections under appropriate headings.

2.

Proposed LC0 3.2.8 incorporates and provides additional clarification to an existing requirement in Table 3.2.B, Note 1, that there shall be two Operable trip systems for each function.

The proposed LC0 states "there shall be two Operable or tripped trip systems for each Trip Function except as noted in Table 3.2.B."

These changes clarify that either of the two trip systems can be Operable or tripped and that some of the Trip Functions listed in Table 3.2.8 do not have two trip systems per function.

3.

There were no changes to the Applicability requirements other than the reformatting which places the Applicability statement under a new and separate heading.

The above changes are administrative and provide clarity.

b.

Proposed LC0 3.2.8 contains a new heading, " Conditions and Required Actions." This change establishes a common description of the conditions associated with inoperable channels for the instruments in Table 3.2.B and directs completion of specific required actions for each function i

f

I identified on Table 3.2.B.

The proposed section will state, "With one or more channel (s) required by Table 3.2.B inoperable in one or more Trip Functions, take the Action required by Table 3.2.B."

This is an administrative change that improves clarity because it establishes a link between the LCO and the associated required actions. This change is consistent with NUREG-1433.

Proposed LC0 3.2.B, Conditions and Required Actions:

The specific c.

conditions and required actions for inoperable CCCS instrument channels were retained in the Notes to Table 3.2.8 because the multiple categories of instruments in Table 3.2.8 require different required actions and completion times to satisfy the assumptions in the LTRs. The categories of instruments in Table 3.2.B include: ECCS common to RPS (NEDC-30851P-A);

ECCS not common to RPS (NEDC-30936P-A);

Containment Isolation common to RPS or ECCS (NEDC-30851P-A (Supplement 2)); Power Monitoring Instruments (NEDC-30936P-A); Undervoltage and Degraded Voltage Instruments (not evaluated in LTRs); and, indication only instrumentation without any actuation function.

Separate Conditions and Required Actions for each of these categories are included as Notes to Table 3.2.B to ensure that the assumptions used in LTRs that justified extending the instrumentation A0Ts and STIs for each category of instruments were incorporated into this Section. The proposed conditions and required actions are consistent with NUREG-1433, Sections 3.3.1.1, 3.3.5,1,.3.3.5.2, and 3.3.6.1, as appropriate.

The resulting changes to the existing requirements are described below in Sections 2.3.d through 2.3.n.

j d.

Proposed Note I to Table 3.2.B:

The existing requirement in Table 3.2.B.

Note 1, that "there shall be two operable trip systems" for each function in Table 3.2.B was incorporated into the statement of proposed LC0 3.2.B i

as discussed in Section 2.3.a.ii, above.

This is an administrative change to improve clarity and useability.

e.

Proposed Note 1 to Table 3.2.B:

The proposed change modifies Table 3.2.8 and Note 1 to Table 3.2.B so that Note 1 identifies the conditions and required actions for those actuation functions in Table 3.2.B that are not within the scope of analysis of LTRs.

These functions include:

1 4 kV Emergency Bus Undervoltage Relay (HGA) 4 kV Emergency Bus Sequential Loading Relay Emergency Transformer Undervoltage Relay Degraded Voltage (27N) (non-LOCA relay)

Degraded Voltage (27N) (LOCA relay)

Emergency Transformer Degraded Voltage Relay In conjunction with this change, the following changes were made to the conditions and required actions in Note 1:

l

i.

t

-f 15 -

1.

The condition description currently in Table 3.2.B. Note 1, was modified to clarify that the condition could be simultaneously applied to more than one trip function and more than one trip system within a trip function. This change is consistent with the present interpretation and the approach in NUREG-1433 for similar instrumentation. This is an administrative change that improves clarity because there is no change to the existing interpretation of the requirements.

2.

The repair A0Ts for inoperable channels for the trip functions listed above were specified as "within one hour." The_ existing Note 1 does not specify a completion time which is interpreted as the action that is required within one hour. This is an administrative change that improves clarity because there is no change to the existing interpretation of the requirements.

3.

Proposed Note 1 maintains the existing requirement to place the reactor in "the Cold Shutdown Condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " if the required action or completion time are not met.

f.

Proposed Note 6 to Table 3.2.B: The proposed change deletes Table 3.2.B.

Note 6, because it is superseded by proposed Note 10 which is discussed below in Section 2.3.i.

Note 6 specifies actions and completion times for the inoperability of an instrument channel that transfers RCIC suction to the suppression pool when there is a condensate storage tank low level.

This is an administrative change required to support other proposed changes.

g.

Proposed Note 8 to Table 3.2.B: The proposed change adds Note 8 to Table _3.2.B and marks Table 3.2.B.

Proposed Note 8 replaces existing Note 1 and establishes conditions, required actions, and completion times for the following subset of trip functions in Table 3.2.B:

Reactor Low-Low-Low Water Level; Reactor Low Level (inside shroud);

Containment High Pressure; High Drywell Pressure; RHR (LPCI) Trip System Bus Power Monitor; Core Spray Trip System Bus Power Monitor; ADS Trip System Bus Power Monitor; HPCI Trip System Bus Power Monitor; RCIC Trip System Bus Power Monitor; and,

~

Core Spray Sparger to Reactor Pressure Vessel d/p.

The proposed conditions, required actions and completion times in proposed Note 8 satisfy the assumptions and conditions used in NEDC-30936P-A to justify extension of A0Ts and STIs for ECCS instrumentation. The proposed conditions and required actions are consistent with NUREG-1433, Section 3.3.5.1, Emergency Core Cooling System Instrumentation, Conditions A, B (except HPCI) and H.

The specific changes included in proposed Note 8 are discussed below:

1.

The condition description currently in Table 3.2.B. Note I was modified to clarify that the condition could be simultaneously applied to more than one trip function and more than one trip system within a trip function by changing the wording from "if the first column cannot be met for one of the trip systems" to "with one or more required channels inoperable in one or more Trip Functions."

2.

The A0Ts for inoperable ECCS channels for the trip functions listed above (Note 8, Action 1) were extended to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the requirement currently in Table 3.2.8, Note 1, to place the channel in trip immediately (interpreted as within one hour).

This change is consistent with NEDC-30936P-A.

3.

Specific requirements, Note 8, Actions 2 and 3, were added to prevent the proposed extended A0T from resulting in an extended loss of e

function since a loss of function was not considered in NEDC-30936P-A.

4.

Proposed Note 8 eliminates the requirement currently in Table 3.2.B, Note I to place the reactor in "the Cold Shutdown Condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " if the required action or completion time are not met.

Proposed Note 8 requires only that the associated supported features be declared inoperable immediately. This change is acceptable because the worst case result of an inoperable channel is that the supported feature or system may not perform its intended function when required.

By declaring the supported feature or system inoperable and taking the required actions for that system or feature, the plant is within the bounds of the TSs and approved actions. Additionally, with the supported feature or system inoperable, the inoperable channel is no longer required to be operable.

The above is consistent with NUREG-1433.

5.

Proposed Note 8, Condition 2, states that "Within one hour from discovery of loss of initiation capability in both trip systems for feature (s) supported by this trip function, declare supported feature (s) inoperable." Proposed Note 8, Condition 2, is modified by footnote (1) which states that the required actions associated with this condition is "only applicable to the High Drywell Pressure and Reactor Low-Low-Low Water Level functions." This change prevents an extended loss of function of ECCS equipment initiated by High Drywell Pressure and Reactor Low-Low-Low Water Level functions but allows operation to continue for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with loss of functions which prevent inadvertent initiation of containment spray and/or loss

i

- 17 _

of ECCS bus power monitors. This change is consistent with NUREG-1433, LCO 3.3.5.1, Required Action B.I.

6.

The ECCS channels 7or'the trip functions listed above are also modified by proposed Note l', or 16 that will allow initiation of required actions to be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months when a channel is placed in an inoperable status solely for performance of required surveillances.

Note 15, applied to those instrument functions which actuate CCCS equipment, permit the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months delay in the initiation of required actions only if the associated trip function maintains trip capability. Note 16, applied to those functions which provide indication only, permits the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months delay in the initiation of required actions without qualification.

The proposed changes resulting from the addition of Notes 8, 15, and 16, are justified based on the analyses in NEDC-30936P-A and RE-020 and are implemented consistent with the terminology and approach used in NUREG-1433, Section 3.3.5.1, Emergency Core Cooling System Instrumentation, Conditions A, B (except HPCI), and H.

i h.

Proposed Note 9 to Table 3.2.B: The proposed change adds Note 9 to Table 3.2.B and marks Table 3.2.B so that proposed Note 9 replaces i

existing Note 1 and establishes conditions, required actions, and completion times for the following subset of trio functions in i

Table 3.2.B:

Reactor High Water Level (Trips HPCI & RCIC);

Reactor Low Pressure (400-500 psig);

Reactor Low Pressure (200-250 psig);

Core Spray Pump Start Timer; and, i

LPCI Pump tart Timer (Four pumps).

j Each of the functions listed above provides an interlock or permissive for an ECCS injection signal.

The changes incorporated in proposed Note 9 are the same as the changes in proposed Note 8 described above except as follows:

1.

Proposed Note 8 requires that an inoperable channel be placed in trip

'i (if not restored to Operable) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the associated supported features must be declared inoperable immediately.

Proposed Note 9 specifies that an inoperable channel must be restored to Operable within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the associated supported features must be declared inoperable immediately. This difference recognizes that, in a one out-of-two taken twice logic, placing an inoperable channel in trip has two consequences:

it provides greater assurance that an actuation will occur when required; and, it increases the potential i

for an inadvertent actuation. Therefore, Note 9 does not permit

. continued operation with an inoperable channel in trip for an instrument channel that provides an interlock or permissive because an inadvertent actuation is undesirable. This is consistent with NUREG-1433.

2.

Proposed Note 9, Condition 2, states that "Within one hour from discovery of loss of initiation capability in both trip systems for feature (s) supported by this trip function, declare supported feature (s) inoperable." Proposed Note 9, Condition 2 is modified by footnote (2) which states that the required actions associated with this condition is "Not applicable to Reactor High Water Level Function." The proposed Note allows HPCI and/or RCIC to remain Operable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following the loss of the functions which stop injection when reactor water level has been re-established. This function is not assumed in any accident analysis.

This change is consistent with NUREG-1433, LC0 3.3.5.1, Required Action C.I.

The proposed conditions and required actions in proposed Note 9 satisfy the assumptions and conditions in NEDC-30936P-A and RE-020 used to justify extension of ECCS A0Ts and STIs. The proposed conditions and required actions are consistent with NUREG-1433, Section 3.3.5.1, Emergency Core Cooling System Instrumentation, Conditions A, C and H.

i.

Proposed Note 10 to Table 3.2.B: The proposed change adds Note 10 to Table 3.2.B and marks Table 3.2.B so that proposed Note 10 replaces existing Note 1 and establishe., conditions, required actions, and completion times for the following subset of trip functions in Table 3.2.B:

Condensate Storage Tank (CST) Low Level (HPCI);

Suppression Chamber High Level; and, Condensate Storage Tank Low Level (RCIC).

Proposed Note 10 establishes conditions, required actions and completion times for those functions which transfer the HPCI and RCIC pump suctions from the CST to the suppression pool.

Proposed Note 10 replaces existing Note 1 for functions associated with HPCI and replaces Note 6 for the function associated with RCIC.

The specific changes that proposed Note 10

)

makes to the existing required actions for an inoperable channel are

~

discussed below:

1.

The condition description currently in Table 3.2.B, Note 1 (HPCI) and Note 6 (RCIC) were modified to clarify that the condition could be simultaneously applied to more than one trip function and more than one trip system within a trip function by changing the wording to "with one or more required channel (s) inoperable in one or more Trip Functions."

i 2.

The proposed change modifies the~ required actions if an inoperable

[

channel cannot be restored or placed in trip within the completion time. The prorosed change allows aligning the affected (RCIC or HPCI) pump suction to the suppression pool or declaring the affected system inoperable.

Currently, Note 1 requires placing the channel in trip a

(equivalent to transferring suction to the suppression pool) or l

requiring a plant shutdown (Note 1 for HPCI) or declaring RCIC inoperable (Note 6 for RCIC). The proposed requirement to declare the affected system (HPCI or RCIC) inoperable is equivalent to or an acceptable alternative to existing Table 3.2.B because both the existing and proposed required action places the plant within the bounds of TS approved actions or in a condition where the inoperable channel (s) is no longer required to be operable. Aligning the pump suction from the CST to the suppression pool is an acceptable alternative required action because it completes the intended function of instruments listed above, and is consistent with NUREG-1433.

3.

Proposed Note 10 extends the A0Ts for inoperable channels for the trip i

functions listed above (Action 1) to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the existing i

requirements currently in Table 3.2.B. Notes 1 and 6 to place the channel in trip immediately (interpreted as within one hour). This change for HPCI and RCIC is justified by NEDC-30936P-A and NEDC-31677P-A, respectively.

4.

Specific requirements, Note 10, Actions 2 and 3, were added to prevent the proposed extended A0T from resulting in an extended loss of function since an extended loss of function was not considered in the 1

NEDC-30936P-A analysis justifying the extended A0T.

5.

The ECCS channels for the trip functions listed above are also modified by proposed Note 15 that allows initiation of required actions to be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months when a channel is placed in l

an inoperable status solely for performance of required Surveillances provided the associated trip function maintains trip capability.

The proposed conditions, required actions and completion times in proposed Note 10 satisfy the assumptions and conditions used to justify extension of ECCS A0Ts and STIs in NEDC-30936P-A, &31E-770-06-1, GENE-770-06-2, and RE-020. The proposed condition. and raautred actions are consistent with l

NUREG-1433, Sections 3.3.5.1, Conditions A, D and H (HPCI) and Sections i

3.3.5.2, Conditions A, D and E (RCIC).

l J.

Proposed Note 11 to Table 3.2.B: The proposed change adds Note 11 to Table 3.2.B and marks Table 3.2.B so that proposed Note 11 establishes

p.-

l !

t i

conditions, required actions, and completion times and replaces Note I for the following subset of trip functions in Table 3.2.B.

~

Confirmatory. Low Level (ADS permissive);

High Drywell Pressure (ADS);

Reactor low-Low-Low Water Level (ADS).

l

'The proposed conditions, required actions.and completion times in proposed Note 11 adopt the A0Ts from NUREG-0123 (previous BWR Standard Technical Specifications), and then add the extended'A0Ts justified in l

NEDC-30936P-A. This combination of changes is consistent with NUREG-1433 and satisfies the assumptions in NEDC-30936P-A used in.the.

1 justification of extensions of ECCS A0Ts and STIs for instrumentation that i

provide'actuations or permissives.for ADS. These-assumptions and conditions include the interrelationship between TS requirements for ADS-HPCI and RCIC. Because of the diversity of sensors available to. provide i

initiation signals for ADS and the redundancy of the core cooling function

'i (HPCI, RCIC' and ADS), an allowable out of service time of 8 days has been :

previously accepted in NUREG-0123 (7-days extended by 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as justified by NEDC-30936P-A). This combination of A0Ts is reflected in NUREG-1433, LCO 3.3.5.1, Condition F.

If either HPCI or RCIC.is' i

inoperable, the A0T is shortened to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months per NUREG-0123 (72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months extended by.24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as justified by NEDC-30936P-A). This combination of A0Ts is reflected 'in NUREG-1433, LCO 3.3.5.1, Condition F.

If the status-of HPCI or RCIC changes such that the completion time changes from 8 days to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months , the 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months begins upon discovery-of HPCI or RCIC l

inoperability and the total time for an inoperable, untripped channel cannot exceed 8 days.

The proposed conditions, required actions and completion times are consistent with NUREG-1433, Section 3.3.5.1, Actions a

A, F and H.

The specific changes included in proposed Note 11 are discussed below:

1.

The condition description currently in Table 3.2.B Note 1, was modified to clarify that the condition could be simultaneously applied to more than one trip function and more than one trip system within a trip function by changing the wording from "if the first column cannot be met for one of the trip systems" to "with one or more required channel (s) inoperable in one or more Trip Functions."

2.

The A0T for placing an inoperable channel in trip was extended from the requirement currently in Table 3.2.B. Note 1,.to place the channel in trip immediately (interpreted as within one hour) to the following:

within 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months from discovery of an inoperable channel concurrent with HPCI or RCIC inoperable; and, within 8 days from discovery of an-inoperable channel if both HPCI and RCIC' are operable.

These contingent assumptions are consistent with the assumptions used in NEDC-30936P-A as implemented in NUREG-1433.

'l i

~.

-l

, 3.

Specific requirements, Note 11, Actions I and 3, were added to prevent the proposed extended A0T from resulting in an extended loss of function since a loss of function was not considered in NEDC-30936P-A.

4.

Proposed Note 11 eliminates the requirement currently in Table 3.2.B, Note 1, to place the reactor in "the Cold Shutdown Condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " if the required action or completion time are not met.

Proposed Note 10 requires only that ADS valves be declared inoperable immediately. This change is acceptable because the worst case result of an inoperable channel is that ADS may not perform its intended function when required.

By declaring ADS valves inoperable and taking the required actions, the plant is within the bounds of the Technical Specifications and approved actions. Additionally, with ADS valves inoperable, the inoperable channel is no longer required to be operable.

5.

Finally, the instrument channels for the trip functions listed above are also modified by proposed Note 15 that will allow initiation of required actions to be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months when a channel is placed in an inoperable status solely for performance of required surveillances. Note 15, applied to those instrument functions which actuate CCCS equipment, permits the 6-hour delay in the initiation of required actions only if the associated trip function maintains trip capability.

The above proposed conditions, required actions and completion times are consistent with NUREG-1433, Section 3.3.5.1, Actions A, F and H.

k.

Proposed Note 12 to Table 3.2.B: The proposed change adds Note 12 to Table 3.2.B and marks Table 3.2.B so that proposed Note 12 establishes conditions, required actions, and completion times and replaces Note 1 for the following subset of trip functions in Table 3.2.B:

ADS Actuation Timer; ADS Bypass Timer; RHR (LPCI) Pump Discharge Pressure Interlock; and, Core Spray Pump Discharge Pressure Interlock.

Each of the functions listed above provides an interlock or permissive related to the actuation of ADS.

The changes incorporated in proposed Note 12 are the same as the changes in proposed Note 11 described above except as follows.

Proposed Note 11 requires that an inoperable channel be placed in trip (if not restored to Operable) within the A0T (8 days if both HPCI and RCIC are Operable and 96 1

hours if either HPCI or RCIC is not Operable) or ADS valves must be declared inoperable within one hour.

Proposed Note 12 does not permit i

l l

operation to continue when the inoperable channel is placed in trip.

Instead, Note 12 specifies that an inoperable channel must be restored to Operable within the A0T or ADS valves must be declared inoperable. This difference recognizes that, in a one out-of-two taken twice logic, placing an inoperable channel in trip has two consequences: it provides greater assurance that an actuation will occur when required; and, it increases the potential for an inadvertent actuation. Therefore, Note 12 does not permit continued operation with an inoperable channel in trip for an instrument channel that provides an interlock or permissive because both the failure to actuate and an inadvertent actuation are undesirable.

The proposed conditions and required actions in proposed Note 12 satisfy the assumptions and conditions in NEDC-30936P-A and RE-020 used to justify extension of ECCS A0Ts and STIs.

The proposed conditions and required actions are consistent with NUREG-1433, Section 3.3.5.1, Emergency Core Cooling System Instrumentation, Conditions A, G and H.

1.

Proposed Note 13 to Table 3.2.B: The proposed change adds Note 13 to Table 3.2.B and marks Table 3.2.B so that proposed Note 13 establishes conditions, required actions, and completion times and replaces Note 1 for the following subset of trip functions in Table 3.2.B:

Reactor Low Pressure (50 s P s 75 psig);

RCIC Turbine High Flow; RCIC Turbine High Flow Time Delay; RCIC Turbine Compartment Wall Temperature; RCIC Steam Line Area Temperature; RCIC Steam Line Low Pressure; HPCI Turbine Steam Line High Flow; HPCI Turbine High Flow Time Delay; HPCI Steam Line Low Pressure; HPCI Turbine Compartment Temperature; HPCI Steam Line Area Temperature; and, HPCI/RHR Valve Station Area Temperature.

The proposed conditions, required actions and completion times in proposed Note 13 satisfy the assumptions and conditions used in NEDC-31677P-A to justify extension of A0Ts and STIs for isolation actuation instrumentation.

The proposed conditions and required actions are consistent with NUREG-1433, Section 3.3.6.1, Primary Containment Isolation Instrumentation, Conditions A, B and F.

The specific changes included in proposed Note 13 are discussed below:

1.

The condition description currently in Table 3.2.B. Note I was modified to clarify that the condition could be simultaneously applied to more than one trip function and more than one trip system within a trip function by changing the wording from "if the first column cannot be met for one of the trip systems" to "with one or more required channels inoperable in one or more Trip Functions."

, 2.

The A0Ts for inoperable isolation actuation channels for the trip l

functions listed above (Action 1) were extended to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the requirement currently in Table 3.2.B, Note 1, to place the thannel in trip immediately (interpreted as within one hour).

This change is consistent with NEDC-31677P-A.

3.

Specific requirements, Note 13, Actions 2 and 3, were added to prevent the proposed extended A0T from resulting in an extended loss of function since a loss of function was not considered in NEDC-30936P-A.

4.

Proposed Note 13 eliminates the requirement currently in Table 3.2.B, Note 1, to place the reactor in "the Cold Shutdown Condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " if the required action or completion time are not met.

Proposed Note 13 requires only that the penetration flow path with isolation capability not maintained be isolated within 25 (24 + 1) hours. This change is acceptable because the worst case result of an inoperable channel is that the affected penetration will not automatically isolate when required.

By isolating the affected penetration flow path and taking the required actions for the affected system, the plant is within the bounds of the Technical Specifications and approved actions. Additionally, with the affected penetration flow path isolated, the inoperable channel is no longer required to be operable.

5.

The isolation instrumentation channels for the trip functions listed above are also modified by proposed Note 15 that will allow initiation of required actions to be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months when a channel is placed in an inoperable status solely for performance of required surveillances.

Note 15, applied to those instrument functions which actuate CCCS equipment, permit the 6-hour delay in the initiation of required actions only if the associated Trip Function maintains trip capability.

The proposed changes resulting from the addition of Notes 13 and 15 are

~

justified based on the analysis in NEDC-31677P-A and are consistent with NUREG-1433, Section 3.3.6.1, Conditions B, A and F.

m.

Proposed Note 14 to Table 3.2.B:

The proposed change adds Note 14 to Table 3.2.B and marks Table 3.2.B so that proposed Note 14 establishes conditions, required actions, and completion times and replaces Note I for the Reactor Low-Low Water Level trip function in Table 3.2.B.

This function initiates HPCI and RCIC.

The proposed condition _, required actions and completion times in propcsed Note 14 satisfy the assumptions and conditions used in NEDC-30936P-A (for HPCI) and GENE-770-06-2 (for RCIC) to justify extension of A0Ts and STIs for HPCI and RCIC actuation instrumentation.

The proposed conditions and

, required actions are consistent with NUREG-1433, Section 3.3.5.1, Emergency Core Cooling System Instrumentation, Conditions A, B and H (for HPCI) and Section 3.3.5.2, Reactor Core Isolation Cooling System Instrumentation, Conditions A, B and E (for RCIC).

The specific changes included in proposed Note 14 are discussed below:

1.

The condition description currently in Table 3.2.B, Note I was modified to clarify that the condition could be simultaneously applied to more than one trip function and more than one trip system within a trip function by changing the wording from "if the first column cannot be met for one of the trip systems" to "with one or more required channels inoperable in one or.more Trip Functions."

2.

The A0Ts for inoperable HPCI and RCIC initiation channels were extended to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the requirement currently in Table 3.2.B, Note 1 to place the channel in trip immediately (interpreted as within one hour).

This change is consistent with NEDC-30936P-A and NEDC-31677P-A.

3.

Specific requirements, Note 14, Actions 1 and 3, were added to prevent the proposed extended A0T from resulting in an extended loss of function since a loss of function was not considered in NEDC-30936P-A and NEDC-31677P-A.

4.

Proposed Note 14 eliminates the requirement currently in Table 3.2.B.

Note 1, to place the reactor in "the Cold Shutdown Condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " if the required action or completion time are not met.

Proposed Note 14 requires only that the affected system (HPCI or RCIC) be declared inoperable.

This change is acceptable because the worst case result of an inoperable channel is that the affected system may not perform its intended function when required.

By declaring the affected system inoperable and taking the required actions for that system, the plant is within the bounds of the Technical Specifications associated with Core Standby Cooling System approved actions.

Additionally, with the affected system inoperable, the inoperable channel is no longer required to be operable.

5.

The HPCI and RCIC initiation channels are also modified by proposed Note 15 that will allow initiation of required actions to be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months when a channel is placed in an inoperable status solely for performance of required surveillances.

Note 15, applied to those instrument functions which actuate CCCS equipment, permits the 6-hour delay in the initiation of required actions only if the associated trip function maintains trip capability.

i The proposed changes resulting from the addition of Notes 14 and 15 are justified based on the analyses in NEDC-30936P-A and GENE-770-06-2 and are

. consistent with NUREG-1433, Section 3.3.5.1, Conditions A, B and H (for HPCI) and Section 3.3.5.2, Conditions A, B and E (for RCIC).

n.

Proposed Notes 15 and 16 to Table 3.2.B: The addition of proposed Notes 15 and 16 to Table 3.2.B is discussed above in Sections 2.3.g through 2.3.m.

The addition of these notes is justified by NEDC-30936P-A and GENE-770-06-2 and is consistent with NUREG-1433.

O.

Proposed change to Table 4.2.B: The minimum frequency specified for the performance of Instrument Channel Functional Tests is extended from once per month to once every 3 months for the following instruments:

Reactor Water Level; Drywell Pressure; Reactor Pressure; Reactor Pressure (PCIS/LPCI Interlock),

ADS (LPCI and CS Pump discharge Pressure Interlocks);

Trip system Bus Power Monitors; Core Spray Sparger d/p; Steam Line High Flow (HPCI and RCIC);

Steam Line High Flow Timers (HPCI and RCIC);

Steam Line High Temperature (HPCI and RCIC);

Safeguards Area High Temperature; HPCI and RCIC Steam Line Low Pressure; and, HPCI Suction Source Levels.

These changes to the STI for Instrument Channel Functional Tests are justified by NEDC-30936P-A, NEDC-30851P-A (Supplement 2), NEDC-31677P-A, and RE-020 and the change is consistent with NUREG-1433.

p.

Proposed change to Notes for Tables 4.2.A through 4.2.F: Note 1 of the combined Notes for Tables 4.2.A through 4.2.F and Referenres to Note 1 on Table 4.2.8 were deleted. Note 1 states that frequency of performance for functional tests is " Initially once every month" but that the frequency could be changed based on failure rate data if the proposed change and supporting failure rate data was reviewed and approved by the NRC.

LTRs constitute the review and approval of failure rate data and provide the justification for extending functional test intervals from once per month to once every 3 months. The requirements for extending instrumentation functional test frequency beyond the currently existing interval that Note 1 identifies are satisfied by this TS change proposal; therefore, Note 1 is no longer applicable. Deletion of Note 1 for Tables 4.2.A through 4.2.F and References to Note 1 on Table 4.2.B is an administrative change.

q, The Bases for TS Section 3/4.2.B were revised to reflect the changes discussed above or to correct typographical errors.

2.5 Control Rod Block Actuation (TS 3.2.C)

The changes proposed for PBAPS TS Section 3.2.C, Control Rod Block Actuation, are described below, The propesed change deletes the existing statements of Applicability and a.

the Objective for Section 3.2, Protective Instrumentation (TS 3/4.2),

because these statements, as currently written, do not establish any requi r c:::cr.t s.

The proposed change establishes for each separate category of protective instrumentation, concise and complete statements of the LC0 and Applicability which are consistent with NUREG-1433.

The changes to the LCO requirements for TS Section 3.2.C, Control Rod Block Actuation, are as follows:

1.

The proposed change establishes an explicit statement of the LCO requirements for Control Rod Block instrumentation that is consistent with NUREG-1433.

2.

The proposed LC0 3.2.C clarifies the existing LCO regirement concerning the number of required trip systems by relocating from Table 3.2.C, Note 1, the requirement that there shall be two Operable or tripped trip systems for each control rod block function and including that requirement in the LCO that "there shall be two Operable or tripped trip systems for each function except as noted in Table 3.2.C."

In conjunction with this change, proposed Note 15 will be added to Table 3.2.0 indicating that there is only one trip system associated with the control rod block actuated by the Scram Discharge Instrument Volume High Level.

3.

The proposed change eliminates the requirement that the cumulative time a Rod Block Monitor (RBM) is inoperable must be less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in any 30-day period. This limitation on the amount of time a channel may be inoperable is not in NUREG-0123 and was not an assumption used in NiDC-30851P-A and; therefore, is not needed to ensure RBM system reliability.

This change is acceptable because the remaining operable channel is adequate to perform the control rod block function. Additionally, PBAPS Technical Specifications include a requirement (TS Section 3.3.B.5) that requires both RBM channels be operable when operating with a limiting control rod pattern. This additional restriction is being maintained although it is not found in NUREG-0123 and is not an assumption in NEDC-30851P-A (Supplement 1).

Therefore, elimination of the cumulative time limit of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in 30 days will not increase the amount of time that the plant operates with less than the full complement of RBM systems and PBAPS will not operate with a limiting control rod pattern with an inoperable RBM channel.

L :

i b.

The proposed changes improve the clarity and useability of the Applicability requirements for TS Section 3.2.C, Control Rod Block Actuation, by locating all of the existing applicability requirements in a i

single location under the appropriate heading. The changes to the applicability requirements are as follows:

i.

The proposed applicability for LC0 3.2.C clarifies the existing LCO i

requirement for the Rod Block Monitor Function with a specific applicability statement that "The Rod Block Monitor (RBM) shall be Operable with setpoints as required by Table 3.2.0 and the Core Operating Limits Report." This change makes the statement of the applicability for the RBM complete by incorporating the requirements l

in the existing LC0 and the requirements in existing Table 3.2.C, Note 11, which states that the values for the Rod Block Monitt.r high t

trip setpoint, intermediate trip setpoint, low trip setpoint, and downscale trip setpoint are located in the Core Operating Limits Report (COLR).

2.

The proposed LC0 3.2.0 applicability for the Rod Block Monitor Function will be modified by a note that states, "Section 3.3.B.5 is applicable during operation with a limiting control rod pattern."

lhis cross reference is necessary because existing TS Section 3.3.B.5 supersedes the LCO and applicability requirements of TS Section 3.2.C by requiring that both channels (i.e., both trip systems because there i

is only one channel per trip system for the RBM function) must be operable, "During operation with limiting control rod patterns, as determined by qualified personnel." Therefore, the addition of this Note is necessary to make the LC0 and Applicability of TS Section 3.2.C complete.

3.

The proposed applicability for LC0 3.2.C clarifies the existing LC0 requirement for the Average Power Range Monitor (APRM), Intermediate Range Monitor (IRM), Source Range Monitor (SRM) and RBM Control Rod Block Functions by locating all of the existing applicability requirements in a single location and under the appropriate heading.

The proposed change combines the applicability requirements in the existing LC0 3.2.C.1 and the applicability requirements in Table 3.2.C, Note 1, and includes these requirements under the heading l

" Applicability" for proposed LC0 3.2.C.

lne applicability l

requirements in Table 3.2.C, Note 1, are deleted.

4.

The proposed change corrects an error in existing Table 3.2.C, Note 1, that states the APRM rod blocks need not be operable in the Startup Mode.

In accordance with existing Table 3.2,C, the APRM Upscale (Startup Mode) function provides a rod block when APRM power is less than 12% and the reactor mode switch is in startup. Therefore, when Note 1 from Table 3.2.C is transferred to the proposed applicability i

l

i

. i i

section of LC0 3.2.C it states:

"The APRM and RBM functions are not I

required to be operable when the Reactor Mode Switch is in Startup except for the APRM Upscale (Startup Mode) which is not required to I

be operable when the Reactor Mode Switch is in Run." This change is consistent with the current interpretation of the Technical

' Specifications.

J 5.

The proposed applicability for LCO 3.2.C combines the applicability requirements in the existing LCO 3.2.C.1 and the applicability requirements in Table 3.2.C, Note 9, and includes these requirements under the heading " Applicability" for proposed LC0 3.2.C.

The 1

applicability requirements in Table 3.2.C, Note 9, are deleted.

This change clarifies the existing LCO requirement for the scram discharge instrument volume Control Rod Block (CRB) Functions by locating all of the existing applicability requirements in a single location and under the appropriate heading.

Each of the changes listed in C.4.b above is an administrative change because there are no technical changes (either actual or I

interpretational) to the existing PBAPS Technical Specifications. The changes in the location, wording, numbering and formatting of the LC0 3.2.C described above were necessary to support other changes described elsewhere in this section or to improve the clarity or useability of the Technical Specifications.

Proposed LC0 3.2.C contains a new heading, " Conditions and Required c.

Actions." This change establishes a common description of the conditions associated with inoperable channels for the instruments in Table 3.2.C and directs completion of required actions in Table 3.2.C, Notes 1, 9 and 10, and proposed Note 12 which is discussed later. The proposed section will state, "With one or more channels required by Table 3.2.C inoperable in one or more Trip Functions, take the Action required by Table 3.2.C."

This is an administrative change intended to provide consistency between TS Section 3.2.0 and the other TS in Section 3.2.

d.

Proposed change to Table 3.2.C, Note 1: The LC0 applicability requirements for the SRM, IRM, and APRM control rod block functions are being deleted from Note 1 because these requirements are being relocated to the applicability statement incorporated into LCO 3.2.C.

This k an administrative change because there are no technical changes (either actual or interpretational) to the PBAPS Technical Specifications. Note 1 to Table 3.2.0 also contains the required actions or completion times for the SRM and RBM (power biased) control rod block functions. The condition description, required actions and completion times for the RBM functions are being relocated to proposed Note 12 and this change is discussed below in Section 2.4.e.

No changes were made to the required actions for the SRM control rod block functions because the A0Ts for these functions were not addressed in NEDC-30851P-A (Supplement 1).

Proposed Note 12 to Table 3.2.C, (Rod Block Monitor function): The e.

proposed change adds new conditions, required actions, and completion times for the Rod Block Monitor (Power Biased) and Rod Block Monitor Downscale functions.

The conditions, required actions and completion times for the RBM functions are located in proposed Note 12.

Currently, Table 3.2.C, Note 1, establishes the required actions and completion times for the RBH functions. Note I allows an inoperable channel to remain untripped for a period of 7 days provided that the operable system is functionally tested immediately and daily thereafter.

After 7 days, the inoperable RBM channel must be placed in trip.

If there is an inoperable channel in both trip systems, then both trip systems must be tripped immediately.

The conditions, required actions, and completion times for the RBM function in Note I were modified as necessary to satisfy the assumptions and conditions in NEDC-30851P-A (Supplement 1) which was used to justify extension of A0Ts and STIs for the RBM functions.

The proposed conditions, required actions and completion times are consistent with NUREG-1433, Section 3.3.2.1, Control Rod Block Instrumentation, Conditions A and B.

The changes to the existing requirements are described below:

1.

The condition description currently in Table 3.2.C, Note 1, was modified to clarify that the condition could be simultaneously applied to more than one trip function and more than one trip system within a trip function by changing the wording from "if the first column cannot be met for one of the two trip systems" to "With one or more required Rod Block Monitor channel (s) inoperable." This change is consistent with the statement in NUREG-1433, Section 3.3.2.1, Conditions A and B.

This is an administrative change that improves clarity because there is no change to the existing interpretation of the requirements.

2.

Proposed Note 12 requires an inoperable RBM channel to be restored to operable within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (instead of the existing requirement of within 7 days) or placed in trip within the following one hour.

This change is consistent with the assumptions and conditions used to justify extension of A0Ts and STis for the RBM functions in NEDC-30851P-A (Supplement 1) and is consistent with NUREG-1433, Section 3.3.2.1, Conditions A and B.

3.

Proposed Note 12 does not require that the operable RBM channels be functionally tested immediately and daily thereafter. This change 1

acknowledges that the inoperability of a subsystem is not I

I

.h II.

! k 5

i k

automatically indicative'of a similar condition in'the redundant l

subsystem unless a generic failure is suspected. :This change is justified because it: allows credit to be:taken for. normal periodic surveillances as a sufficient demonstration of operability; recognizes i

that functional capability is maintained by the remaining components'.

and the reduction in redundancy will be of limited duration; reduces-unnecessary challenges and wear to redundant components; and, 1

incorporates operating experience and analysis (NEDC-30851P-A

.i (Supplement 1)) that have demonstrated the normal STI is sufficient to-provide a very high degree of reliability of.an instrument channel.

This change is consistent with the assumptions and conditions used to justify extension.of A0Ts and STIs for the RBM functions in NEDC-1 30851P-A (Supplement 1) and is implemented consistent with NUREG-1433, 1

Section 3.3.2.1, Conditions A and B.

!q 4.

Proposed Note 12 requires that "With 2 RBM channels inoperable, place -

one RBM channel-in trip within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ." Placing either of the two l

channels in trip actuates a control rod block and satisfies the safety i

function of this instrument. This proposed change was added to prevent an extended loss of function since a loss of function was not j

considered in NEDC-30851P-A (Supplement 1). This is consistent with the existing requirement. in Table 3.2.C, Note 1, i.e., if there is an inoperable channel. in both trip systems, then both trip systems must be tripped immediately.. This change is administrative and is consistent with NUREG-1433, Section 3.3.2.1, Condition B.

f.

Addition'of proposed Table 3.2.C, Note 13: As discussed above in Section q

2.4.b.2, existing LCO 3.3.B.5 does not allow operation with an inoperable i

RBM channel during operation with a limiting control rod pattern.

Proposed Note 13 provides a cross reference from Table 3.2.C to existing LC0 3.3.B.5.

This cross reference is necessary because existing TS l

Section 3.3.B.5 supersedes the LC0 and applicability requirements of TS Section 3.2.C by requiring that both channels (i.e., both trip systems because there is only one channel per trip system for the RBM function) must be operable, "During operation with limiting control rod patterns, as i

determined by qualified personnel." This is an administrative change because there are no technical changes (either actual or interpretational) i to the Technical Specifications, g.

Addition of proposed Table _3.2.C, Note 14: A new note was added to i

provide clarification concerning implementation of required actions.

The i

note'will allow initiation of required actions to be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months when a channel is placed in an inoperable status solely for j

performance of required surveillances, provided the associated trip function maintains control rod block capability. This note is applicable-1 to the APRM and RBM rod block functions and is justified based on the analysis in NEDC-30851P-A (Supplement 1) and, for the RBM function, is consistent with NUREG-1433. The APRM rod block functions are not included i

ir. NUREG-1433.

j e

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h.

Addition of proposed Table 3.2.C, Note 15:

Proposed Note 15 will be added I

to Table'3.2.C indicating that there is only one trip system associated with the control rod block actuated by the Scram Discharge Instrument Volume High Level. This change is necessary because proposed LC0 3.2.C states " there shall be two Operable or tripped trip systems for each Trip Function except as noted in Table 3.2.C."

This is an administrative change because there are no changes to the existing TS requirements.

1.

Proposed change to Table 4.2.C: The minimum frequency specified for the performance of Instrument Channel Functional Tests is extended from once per month to once every 3 months for the following control rod block instruments: APRM - Downscale; APRM - Upscale; RBM - Downscale; and, RBM - Upscale.

These changes to the STI for Instrument Channel Functional Tests are justified by NEDC-30851P-A (Supplement 1) and the change is consistent with NUREG-1433.

J.

Proposed change to Notes for Tables 4.2. A through 4.2.F: Note 1 of the combined Notes for Tables 4.2.A through 4.2.F and References to Note 1 on Table 4.2.0 were deleted. Note 1 states that frequency of performance for functional tests is " Initially once every month" but that the frequency could be changed based on failure rate data if the proposed change and supporting failure rate data was reviewed and approved by the NRC. LTRs constitute the review and approval of failure rate data and provide the justification for extending functional test intervals from once per month to once every 3 months. The requirements for extending instrumentation functional test frequency beyond the currently existing interval that Note 1 identifies are satisfied by this TS change proposal; therefore, Note 1 is no longer applicable. Deletion of Note 1 for Tables 4.2.A through 4.2.F and References to Note 1 on Table 4.2.A is an administrative change.

k.

The Bases for TS Section 3/4.2.C were revised to reflect the changes discussed above or to correct typographical errors.

1 2.6 Radiation Monitorina Systems (TS 3.2.0)

The changes proposed for PBAPS TS Section 3.2.D, Radiation Monitoring Systems, are described below.

The proposed change deletes the existing statements of Applicability and a.

the Objective for Section 3.2, Protective Instrumentation (TS 3/4.2),

because these statements, as currently written, do not establish any i

requirements.

The proposed change establishes for each separate category of protective instrumentation, concise and complete statements of the LC0 I

and Applicability which are consistent with NUREG-1433.

For TS Section 3.2.D, Radiation Monitoring Systems, the proposed change creates separate statements for'the LC0 and Applicability as follows:

j Gp p,

l l

1.

The proposed LCO 3.2.D establishes, under an appropriate heading, an applicability requirement for LCO 3.2.D by relocating, from Table 3.2.D, Notes 1 and 3, existing requirements that:

Refuel Area.

Exhaust Monitors and Reactor Building Area Exhaust Monitors shall-be operable whenever the associated systems are required to be operable; and, the Main Stack Monitor shall be Operable whenever the containment is purging and primary containment integrity is required.

The propo~ed LCO 3.2.D clarifies the existing LCO requirement 2.

s concerning the number of required trip systems by adding the statement that there shall be two operable or tripped trip systems for i

each function listed in Table 3.2.D.

Each of the changes listed above is an administrative change because there are no technical changes (either actual or interpretational) to the Technical Specifications. These changes improve. clarity and/or establish the numbering and format necessary to support technical I

changes discussed elsewhere. These changes are consistent with NUREG-1433.

]

b.

Proposed LCO 3.2.0 contains a new heading, " Conditions and Required Actions." The conditions and required actions for inoperable channels, currently in Table 3.2.D, Notes 1 and 3, were incorporated into the Specification as 3.2.D.

The conditions, required actions, and completion i

times were modified as described below in paragraphs 2.5.c through 2.5.f 1

to satisfy the assumptions and conditions in NEDC-31677P-A which were used to justify extension of A0Ts and STIs for Radiation Monitoring 3

Instrumentation that actuate containment isolation..The proposed conditions, required actions, and completion times are consistent with NUREG-1433, as follows: Sections 3.3.6.1, Primary Containment Isolation Instrumentation, Conditions A, B, C and F for the Main Stack Monitor; and, Sections 3.3.6.2, Secondary Containment Isolation Instrumentation, Conditions A, B and C for the Refuel Area Exhaust-Monitors and Reactor Building Exhaust Monitors.

t c.

Proposed LC0 3.2.D, Condition 1: The condition and required action currently in Table 3.2.D, Note 1, "the specified number of instrument channels shall be operable or placed in the tripped condition" was relocated to Condition 1 and modified as follows:

L 1.

The proposed condition description clarifies that the condition could i

be simultaneously applied to more than one trip function and more than one trip system within a trip function by changing the wording to "With one or more channel (s) required by Table 3.2.D inoperable in one

[.

or more Trip Functions." This change is consistent with NUREG-1433, Section 3.3.6.1.A, and the associated note allowing separate condition entry.

2.

The repair A0T for an inoperable channel currently in Table 3.2.0, Note 1, was extended from immediately (interpreted as within one hour) to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The A0Ts specified for each primary containment isolation instrument function are based on the analyses in NEDC-30851P-A (Supplement 2) and NEDC-30677P-A. The condition description, required actions and completion times are consistent with NUREG-1433.

Proposed Condition 1 and the associated required action and completion times are consistent with NUREG-1433, Sections 3.3.6.1 and 3.3.6.2, Primary and Secondary Containment Isolation Instrumentation, Condition A.

d.

Proposed LC0 3.2.D, Condition 2: A new condition, "With one or more automatic functions with containment isolation capability not maintained" was established. This condition will have Required Actions that will restore containment isolation capability within one hour. This new condition and required action is necessary because the analyses in NEDC-31677P-A did not consider that extending the A0T could result in an extended loss of trip capability and NEDC-31677P-A was used to justify extending A0Ts (proposed LC0 3.2.D, Condition 1) for an inoperable channel.

Proposed condition I and the associated required action and completion time are consistent with NUREG-1433, Sections 3.3.6.1 and 3.3.6.2, Primary and Secondary Containment Isolation Instrumentation, Condition B.

e.

Proposed LC0 3.2.0, Condition 3: This change clarifies and incorporates into the LCO the requirement currently located in Table 3.2.D, Note 2, that specific actions be performed whenever the required actions and completion times of proposed Conditions 1 or 2 cannot be met.

The required actions specified by proposed Condition 3 are still located in Table 3.2.A (Note 2, Actions A, B, and C) and were not modified. The required actions and completion times in proposed Condition 3 and Table 3.2.0, Note 2, are consistent with NUREG-1433, Sections 3.3.6.1 and 3.3.6.2, Primary and Secondary Containment Isolation Instrumentation, Condition C.

f.

Proposed LC0 3.2.D, Conditions and Required Actions:

Two new notes were added to provide clarification concerning implementation of required actions.

The first note will allow initiation of required actions to be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months when a channel is placed in an inoperable status solely for performance of required surveillances, provided the associated trip function maintains isolation capability. The seccad wqte provides clarification that an inoperable channel or trip system nc2d not be placed in the tripped condition where this would cause the trip function to occur.

In these cases, if the inoperable channel is not restored to i

operable status within the required time, the Action required by Table 3.2.0 for that trip function shall be taken.

Both notes are justified based on NEDC-31677P-A and are consistent with NUREG-1433.

i

i g.

Proposed change to Table 3.2.D, Notes 1, 2, 3 and 4: As discussed in Sections 2.6.a and 2.6.b, the proposed LCO 3.2.D contains applicability requirements and required actions that were relocated from Table 3.2.D, Note 1.

Existing Notes 1 and 3, and references to existing Notes 1 and 3 on Table 3.2.D are deleted.

Existing Table 3.2.D, Note 2 Action, and the Reference to Note 2 in Table 3.2.0 will be renumbered as Note 1.

Existing Note 4 and the reference to Note 4 in Table 3.2.D will be renumbered as Note 2.

These are administrative changes for existing requirements to be relocated, h.

Proposed change to Table 4.2.D: The minimum frequency specified for the performance of Instrument Channel Functional Tests is extended from once per month to once every 3 months for the Refuel Area Exhaust Monitors and i

Reactor Building Area Monitors. These changes to the STI for Instrument Channel Functional Tests is justified by NEDC-31677P-A and the change is consistent with NUREG-li33.

i.

Proposed change to Specification 3/4.2.D.2:

The proposed change to Section 3.2, Protective Instrumentation, requires that TS Section 3/4.2.D.2, Main Control Room, be moved from existing page 59 to a new page numbered 59a. The numbering of Notes associated with TS Section 3/4.2.D.2 on Table 3.2.D were changed to support other changes on Table 3.2.0 which are described above.

Each of the changes is an administrative change.

j.

The Bases for TS Section 3/4.2.0 were revised to reflect the changes discussed above or to correct typographical errors.

2.7 Leak Detection (TS 3.2.E)

The changes proposed for PBAPS TS Section 3.2.E, Drywell Leak Detection, are described below.

The proposed change deletes the existing statements of Applicability and a.

the Objective for Section 3.2, Protective Instrumentation (TS 3/4.2),

because these statements, as currently written, do not establish any requirements.

For TS Section 3.2.E, no changes were made to the existing requirements.

b.

The proposed change to Section 3.2, Protective Instrumentation, requires that TS Sections 3.2.E and 4.2.E, Drywell Leak Detection, be moved to a new page numbered 59a.

Table 4.2.E was modified to delete the references to Note 1 but the c.

Channel Functional Test frequency was maintained as once per month consistent with current requirements.

Each of the changes above is an administrative change.

m

, 2.8 Surveillance _Information Readouts (TS 3.2.F)

The changes proposed for PBAPS TS Section 3.2.F. Surveillance Information Readouts, are described below.

a.

The proposed change deletes the existing statements of Applicability and the Objective for Section 3.2, Protective Instrumentation (TS 3/4.2),

because these statements, as currently written, do not establish any requirements.

For TS Section 3.2.F, no changes were made to the existing requirements.

b.

The proposed change to Section 3.2, Protective Instrumentation, requires that TS Sections 3.2.F and 4.2.F, Surveillance Information Readouts, be moved to a new page numbered 59a.

Each of the changes above is an administrative change.

2.9 Alternate Rod Insertion (ARI) and Recirculation Pump Trio (RPT) (TS 3.2.G)

The changes proposed for PBAPS TS Section 3.2.G, Alternate Rod Insertion and Recirculation Pump Trip, are described below.

The proposed change deletes the existing statements of Applicability and a.

Objective for Section 3.2, Protective Instrumentation (TS 3/4.2), because these statements, as currently written, do not establish any requirements.

The proposed change establishes for each separate category of protective instrumentation, concise and complete statements of the LC0 and Applicability which are consistent with NUREG-1433.

For TS Section 3.2.G, the LCO and Applicability were established as follows:

1.

The proposed LC0 3.2.G retains, under an appropriate heading, the existing applicability requirement that ARI and RPT shall be operable "when the Reactor Mode Switch is in the Startup or Run positions."

2.

The proposed LC0 3.2.G retains the existing LC0 requirement that two trip systems, including the manual and automatic actuation logic and actuation devices of both trip systems, must be operable.

Each of the changes above is an administrative change and is consistent with NUREG-1433.

b.

Proposed change to Table 3.2.G:

Proposed LCO 3.2.G and proposed changes to Table 3.2.G will increase the minimum number of operable channels per trip system from one channel per trip system to two channels per trip system for both the reactor high pressure function and the reactor low-low i

water level function. This change is required to satisfy the assumptions used in GENE-770-06-1 which justified the ARI and RPT A0Ts and STIs by

'i assuming no loss of trip capability during the period that an inoperable channel is not in trip.

l GENE-770-06-1 evaluated two different Anticipated Transient Without Scram (ATWS)/RPT logic designs: one out-of-two taken twice for each ATWS function (rsactor high pressure and reactor low-low water level); and, two out-of-two taken twice for each ATWS function. The PBAPS ATWS/RPT logic, approved by the NRC in Amendment 141 dated March 22, 1989, uses a one out-of-four taken twice logic with the four channels consisting of two channels of the high reactor pressure function &nd two channels of the reactor low-low water level function.

Existing Table 3.2.G requires only one of the two channels of each function to be operable in each trip system.

In order for the generic analysis in GENE-770-06-1 to envelope the PBAPS design without additional analysis, the licensee proposed a change to the PBAPS Technical Specifications to require both channels of each function (level and pressure) to be operable in both trip systems.

This change will make the PBAPS design consistent with and more conservative than the one out-of-two taken twice design analyzed in GENE-770-06-1 and the change is more conservative than the existing requirements.

This change is consistent with NUREG-1433.

Proposed LC0 3.2.G contains a new heading, " Conditions and Required c.

Actions." The conditions and required actions for inoperable channels, currently in Table 3.2.G, Notes 1, 2, 3 and 4, were deleted and replaced with conditions and required actions consistent with NUREG-1433, LC0 3.3.4.2, ATWS-RPT instrumentation. The proposed conditions, required actions and completion times adopt the A0Ts from NUREG-0123, and add the extended A0Ts justified in GENE-770-06-1. This combination of changes is

' consistent with NUREG-1433 and satisfies the assumptions used in the justification of extensions of A0Ts and STIs for instrumentation that provide ATWS-RPT functions. The proposed conditions, required actions, and completion times are more conservative than the existing requirements because:

the change eliminates Table 3.4.G, Notes 3 and 4, which allow operation to continue for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months (plus an additional 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to reach the Shutdown or Refuel Mode) with a complete loss of one or both ATWS-RPT functions; and, eliminates current requirements that allow operation to continue indefinitely with a loss of single failure capability.

TS Section 3.2.G includes an ATWS/ Alternate Rod Insertion (ATWS/ARI) function that is not included in NUREG-0123 and, therefore, was not evaluated in GENE-770-06-1 or included in NUREG-1433.

The licensee's evaluation of GENE-770-06-1 determined that the justification for A0T and STI extensions for ATWS/RPT is applicable to ATWS/ARI because this function uses the same instruments and logic used for the ATWS/RPT function.

The only difference between the two functions is the device being actuated and the actuated device is not included in the generic analysis in GENE-770-06-1.

Therefore, proposed changes to ATWS-RPT which are being made consistent with NUREG-1433 and GENE-770-06-1 are also being i

applied to the ATWS/ARI function.

This change is conservative because the i

proposed changes, discussed below, require the operability of an additional channel per trip system and do not permit an extended loss of function as is allowed in the existing TS.

1

I d.

Proposed LC0 3.2.G, Condition 1:

Proposed Condition I specifies that "With one or more channels required by Table 3.2.G inoperable, restore the channel to Operable status or place the channel in trip within 14 days."

This change, when taken in conjunction with the proposed change that requires two operable channels per function (pressure and level) per trip system, will limit the amount of time the ARI/RPT system can be considered operable without being single failure proof for each function to a maximum of 14 days.

Existing Table 3.2.G, by requiring only one operable channel per function per trip system, does not require any allowance for single failure within a function. Therefore, this change is more conservative.

Proposed Condition 1 and the associated required action and completion time satisfy the assumptions used to demonstrate system reliability in GENE-770-06-1 and are consistent with NUREG-1433, Section 3.3.4.2, (ATWS-RPT), Condition A.

This change is applicable to both the RPT and ARI functions.

t e.

Proposed LCO 3.2.G, Condition 2:

Proposed Condition 2 specifies that "With one instrument function with trip capability not maintained, restore trip capability within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ." This change, when taken in conjunction with the proposed change that requires two operable channels per function (pressure and level) per trip system, will limit the amount of time the ARI/RPT system can be considered operable with the ability to trip on only one function (level or pressure) to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Existing Table 3.2.G, Notes 1, 2 and 3, allow a similar condition to exist for only 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months before reactor shutdown is required. However, proposed Condition 2 and the associated required action and completion time satisfy the assumptions used to demonstrate system reliability in GENE-770-06-1 and are consistent with NUREG-1433, Section 3.3.4.2, (ATWS-RPT), Condition B.

This change is applicable to both the RPT and ARI functions.

f.

Proposed LC0 3.2.G, Condition 3:

Proposed Condition 3 specifies that "With both instrument functions or an actuation device with trip capability not maintained, restore trip capability for one function within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ." This change, in conjunction with proposed Condition 4, requires the initiation of a reactor shutdown within I hour of the discovery of a loss of ARI/RPT function. The existing requirements (Table 3.2.G, Notes 3 and 4) allow operation to continue for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months (plus an additional 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to reach the Shutdown or Refuel Mode) with a complete loss of one or both ATWS-RPT functions.

Proposed Condition 3 and the associated required action and completion time satisfy the assumptions used to demonstrate system reliability in GENE-770-06-1 and are consistent with NUREG-1433, Section 3.3.4.2, (ATWS-RPT), Condition C.

This change is applicable to both the RPT and ARI functions.

g.

Proposed LC0 3.2.G, Condition 4:

Proposed Condition 4 specifies that "If the required actions and associated completion times of Action 1, 2 or 3 are not met, place the reactor in shutdown or refuel mode within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ."

Proposed Condition 4 is consistent with the existing requirement in i

6

-.I Table 3.2.G, Note 4.

The proposed change is similar to NUREG-1433, Section 3.3.4.2, (ATWS-RPT), Condition D, because both require that the reactor be placed outside the applicable mode within a short period of time.

In NUREG-1433, this is satisfied by being in Mode 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; in the proposed change, this is satisfied by being in shutdown or refuel mode within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Proposed Condition 4 and the associated required action and completion time satisfy the assumptions used to demonstrate system reliability in GENE-770-06-1.

h.

Proposed LC0 3.2.G, Conditions and Required Actions: Three new notes were added to provide clarification concerning implementation of required i

actions. The first note will allow initiation of required actions to be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months when a channel is placed in an inoperable status solely for performance of required surveillances, provided the associated trip function maintains ARI/RPT trip capability.

The second note provides clarification that an inoperable channel or trip system need not be placed in the tripped condition where this would cause the trip function to occur.

In these cases, if the inoperable channel is not restored to operable status within the required time, the Action required by LCO 3.2.G, Condition 4, shall be taken. The third note specifies that placing an inoperable instrument channel in trip is not applicable if the inoperable channel is the result of an inoperable breaker.

These notes are justified based on GENE-770-06-1 and are consistent with NUREG-1433.

1.

Proposed change to Table 4.2.G: The minimum frequency specified for the performance of Instrument Channel Functional Tests is extended from once per month to once every 3 months for the Reactor High Pressure and Reactor Low-Low Water Level functions. As noted on Table 4.2.D, these instrument channels are the same ones used by the Core and Containment Cooling Systems.

These changes to the STI for Instrument Channel Functional Tests are justified by GENE-770-06-1 and the change is consistent with NUREG-1433.

j.

The Bases for TS Section 3/4.2.G were revised to reflect the changes discussed above or to correct typographical errors.

2.10 Justification For The Proposed Chances i

PECO Energy has determined that the generic analyses performed by GE for the BWR Owners' Group for revised A0Ts and STIs for the testing and/or repair of instrumentation that actuates RPS, Primary Containment Isolation, Core and Containment Cooling systems, Control Rod Blocks Radiation Monitoring systems, and Alternate Rod Insertion / Recirculation Pump Trip are applicable to the Peach Bottom, Units 2 and 3.

PECO Energy has completed plant-specific evaluations required by the NRC SERs which approved the LTRs for use by individual facilities. As stated in the SERs, three issues must be addressed to apply the RPS LTR (NEDC-30851P-A) and two issues must be addressed to apply the other LTRs to an individual facility when plant-specific TSs are I

. considered for revision.

These issues, the licensee's treatment and the staff's evaluation of them are as follows:

a.

Confirm the applicability of the generic analyses to the specific facility.

1.

The generic study in NEDC-30851P-A provides a technical basis to modify the SITS and A0Ts of the RPS. The generic study also provides additional analyses of different RPS configurations to support the application of the generic analysis on a plant-specific basis. A plant-specific evaluation for modifying the STIs and A0Ts of the RPS in the technical specifications of Peach Bottom, Units 2 and 3, has been performed by GE and is contained in the plant-specific evaluation report MDE-87-0485-1, Technical Specification Improvement Analysis for the Reactor Protection System for Peach Bottom, Units 2 and 3.

The evaluation utilized the generic analysis and additional analyses documented in NEDC-30851P-A. The results indicated that the RPS configuration for Peach Bottom, Units 2 and 3, has several differences compared to the RPS configuration in the generic evaluation.

The NRC staff has reviewed NEDC-30851P-A and MDE-87-0485-1 and verified that the generic analysis is applicable to Peach Bottom, Units 2 and 3.

The differences between the RPS at Peach Bottom, Units 2 and 3, and the generic plant analyzed in NEDC-30851P-A are discussed in item c.

below.

2.

GE Report NEDC-30936P-A provides an acceptable generic basis for supporting plant-specific Technical Specification changes that extend ECCS STIs and A0Ts for test and repair. The plant-specific evaluation contained in GE Report RE-020, Technical Specification Improvement Analysis for the Emergency Core Cooling System Actuation Instrumentation for Peach Bottom Atomic Power Station, Units 2 and 3, followed the procedures of NEDC-30936P-A to identify and evaluate the differences between the Peach Bottom, Units 2 and 3, ECCS configuration and the ECCS configuration used in the generic analysis.

The results of the staff's review indicate that while the ECCS configuration for Peach Bottom, Units 2 and 3, is slightly different than the generic configuration assumed, these differences do not affect the applicability of the TS changes developed based on the generic analysis. Therefore, the generic analysis in NEDC-30936P-A is applicable to Peach Bottom, Units 2 and 3.

3.

NEDC-30851P-A, Supplement 2, identifies PECO Energy as a participant in the BWR isolation Instrumentation Common to RPS and ECCS Instrumentation evaluation.

The staff reviewed the licensee's evaluation and verified that the generic analysis is applicable to Peach Bottom, Units 2 and 3.

4.

NEDC-31677P-A, Appendix E identifies PECO Energy as a participant in the BWR isolation Actuation Instrumentation evaluation.

The staff reviewed the licensee's evaluation and verified that the generic analysis is applicable to Peach Bottom, Units 2 and 3.

5.

NEDC-30851P-A, Supplement 1, Appendix B identifies PECO Energy as a participant in the BWR Control Rad Block Instrumentation evaluation.

The staff reviewed the licensee's evaluation and verified that the generic analysis is applicable to Peach Bottom, Units 2 and 3.

6.

GENE-770-06-1 identifies the application of changes to STIs and A0Ts for Selected Instrumentation Technical Specifications to all BWR plants. The staff reviewed the licensee's evaluation and verified that this LTR is applicable to Peach Bottom, Units 2 and 3, only to the limited extent that it identified A0Ts for Control Rod Block Instrumentation which NEDC-30851P-A, Supplement 1 did not explicitly address.

b.

Demonstrate, by use of current drift information provided by the equipment vendor or plant-specific data, that the drift characteristics for instrumentation used in RPS, ECCS, Isolation and Rod Block instrument channels in the plant are bounded by the assumptions used in the LTRs when the functional test interval is extended from weekly or monthly to quarterly.

The staff's generic SER of May 27, 1987 on GE NEDC-30844 and NEDC-30851P states the staff's position for confirmation of instrument setpoint drift allowance.

By a letter to the BWR Owners' Group from C. Rossi (NRC) dated April 27, 1988, the NRC requested licensees to confirm that the setpoint drift which could be expected under the extended STIs has been studied and either: (1) has been shown to remain within the existing allowance in the RPS and ESFAS instrument setpoint calculation, or (2) that the allowance and setpoint have been adjusted to account for the additional expected drift. No additional information need to be provided for staff review.

However, records showing the actual setpoint calculation and supporting data should be retained onsite for possible future staff audit.

In its submittal, the licensee has demonstrated that drift data of the affected instrumentation remained within the.,xisting allowance in the RPS and ESFAS instrument setpoint calculation when considered over the extended period.

Confirm that the differences between the parts of the RPS that perform the c.

trip functions in the plant and those of the base case plant were included in the plant-specific analysis done using the procedures of Appendix K of NEDC-30851P or present plant-specific analyses to demonstrate no appreciable change in RPS availability or Public risk.

GE Report HDE-87-0485-1, " Technical Specification Improvement Analysis for the Reactor Protection System for Peach Bottom Atomic Power Station, Units 2 and 3," provides a plant-specific evaluation to determine whether the

r

. generic study contained in NEDC-30851P-A is applicable to Peach Bottom, Units 2 and 3, to review STIs and add A0Ts in TSs for the RPS instrumentation.

This report utilizes the procedures in Appendix K of NEDC-30851P-A to identify and evaluate the differences between the parts of the RPS that perform the trip functions at Peach Bottom, Units 2 and 3, and those analyzed in the generic study.

PECO Energy performed an evaluation of NEDC-30851P-A and MDE-87-0485-1 to verify that the generic analysis is applicable to Peach Bottom, Units 2 and 3, and concluded that it remains applicable with differences as discussed above in Section 2.1.

The differences between the RPS at Peach Bottom, Units 2 and 3, and the generic model are bounded by the analysis contained in NEDC-30051P-A. As discussed above, the staff finds that the generic analysis for RPS operability remains applicable to Peach Bottom, Units 2 and 3.

2.11 Summary The staff has reviewed the proposed PBAPS TS changes to extend STIs and A0Ts for instrumentation associated with the RPS, Primary Containment Isolation, Core and Containment Cooling Systems, Control Rod Blocks, Radiation Monitoring Systems, and Alternate Rod Insertion / Recirculation Pump Trip. The changes have been the subject of generic LTRs which the NRC has previously reviewed and approved.

PECO Energy has addressed the implementation of the generic Technical Specification changes identified in the LTRs and incorporated into NURG-1433 on a plant-specific basis.

The licensee performed the required plant-specific analysis and justified the application of the generic analysis to the Peach Bottom, Units 2 and 3, plant-specific design. The information for setpoint drift supports the conclusion that instrument drift is not a concern in extending the functional test interval from monthly to quarterly.

The proposed changes also include editorial and administrative changes which ensure consistent use of nomenclature, correct typographical errors, reformat the instrumentation tables, and delete notes which are no longer applicable.

)

Based on the review of the proposed PBAPS TS changes, the staff concludes that the changes are consistent with the previously approved generic analyses and appropriate plant-specific evaluations have been performed.

The staff, therefore, concludes that the proposed instrumentation TS changes are consistent with NUREG-1433 and, are therefore, acceptable.

3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments.

The State official had no comments.

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4.0 ENVIRONMENTAL CONSIDERATION

I The: amendments change a requirement'with respect to installation or'use of a facility component located within the restricted area as defined in-10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that-the amendments involve no significant increase in the amounts, and no

--i significant change in the types, of any effluents that may be released.

j offsite, and that. there is no significant increase in individual or' cumulative o

occupational radiation exposure'..The Commission has previously, issued a I

. ' proposed-finding that the amendments involve no significant hazards i

consideration, and there has-been.no public comment on such finding (60 FR j

14027). Accordingly, the amendments. meet the eligibility criteria for

- categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to.10.CFR 51.22(b) no environmental impact. statement or environmental assessment need-be prepared in connection with the issuance of the amendments.

i

5.0 CONCLUSION

' The Commission has concluded, based on the considerations discussed above, that:

(1) there'is' reasonable assurance that the health and safety of the.

l public will not be endangered by' operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, j

i and-(3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

j

- Principal Contributor:

S. Rhow f

Date: June 6, 1995 i

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ML20086B525

Contents

Text

1.0 INTRODUCTION

3.0 STATE CONSULTATION

4.0 ENVIRONMENTAL CONSIDERATION

5.0 CONCLUSION

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ML20086B525

Text

1.0 INTRODUCTION

3.0 STATE CONSULTATION

4.0 ENVIRONMENTAL CONSIDERATION

5.0 CONCLUSION

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