ML22298A010

License Amendment Request to Adopt TSTF-273-A, (Safety Function Determination Program) SFDP Clarifications, Revision 2, as Amended by WOG-ED-23, Dated July 17, 1999

ML22298A010
Person / Time
Site:	Calvert Cliffs, Peach Bottom, Ginna
Issue date:	10/25/2022
From:	David Helker Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
Download: ML22298A010 (1)

Text

200 Exelon Way Kennett Square, PA 19348 www.ConstellationEnergy.com 10 CFR 50.90 October 25, 2022 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

Subject:

License Amendment Request to Adopt TSTF-273-A, [Safety Function Determination Program] SFDP Clarifications, Revision 2, as amended by WOG-ED-23, dated July 17, 1999 In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests amendments to the Technical Specifications (TS) for Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2, Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, and R. E. Ginna Nuclear Power Plant (Ginna).

The proposed changes incorporate the NRC-approved Technical Specification Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF-273-A, [Safety Function Determination Program] SFDP Clarifications, Revision 2, as amended by WOG-ED-23. The proposed changes add explanatory text to the LCO 3.0.6 Bases clarifying the "appropriate LCO for loss of function," and that consideration does not have to be made for a loss of power in determining loss of function. Explanatory text is also added to the programmatic description of the Safety Function Determination Program (SFDP) in TS 5.5.15 (CCNPP), TS 5.5.11 (PBAPS) and TS 5.5.14 (Ginna) to provide clarification of the same.

This request is subdivided as follows.

• Attachment 1 provides an evaluation of the proposed changes.

• Attachments 2a - d provide the markups of the affected TS pages for CCNPP, Units 1 and 2, PBAPS, Units 2 and 3, and Ginna, respectively.

• Attachments 3a - d provide the markups of the affected Bases pages for CCNPP, Units 1 and 2, PBAPS, Units 2 and 3, and Ginna, respectively (for information only).

License Amendment Request to Adopt TSTF-273-A October 25, 2022 Page 2 The proposed changes have been reviewed by the Plant Operations Review Committees at CCNPP, PBAPS, and Ginna in accordance with the requirements of the CEG Quality Assurance Program.

CEG requests approval of the proposed amendments by October 25, 2023. Once approved, the amendments shall be implemented within 90 days. This implementation period will provide adequate time for the affected station documents to be revised using the appropriate change control mechanisms.

There are no regulatory commitments contained in this submittal.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), CEG is notifying the Commonwealth of Pennsylvania and the States of Maryland and New York of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Officials.

Should you have any questions concerning this submittal, please contact Ms. Wendi E. Para at (267) 533-5208.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 25th day of October 2022.

Respectfully, David P. Helker Sr. Manager - Licensing Constellation Energy Generation, LLC Attachments: 1. Evaluation of Proposed Changes 2a. Proposed Technical Specifications Changes (Mark-Up) - Calvert Cliffs Nuclear Power Plant, Units 1 and 2 2b. Proposed Technical Specifications Changes (Mark-Up) - Peach Bottom Atomic Power Station, Unit 2 2c. Proposed Technical Specifications Changes (Mark-Up) - Peach Bottom Atomic Power Station, Unit 3 2d. Proposed Technical Specifications Changes (Mark-Up) - R. E. Ginna Nuclear Power Plant 3a. Proposed Technical Specifications Bases Pages (For Information Only) -

Calvert Cliffs Nuclear Power Plant, Units 1 and 2 3b. Proposed Technical Specifications Bases Pages (For Information Only) -

Peach Bottom Atomic Power Station, Unit 2 3c. Proposed Technical Specifications Bases Pages (For Information Only) -

Peach Bottom Atomic Power Station, Unit 3 3d. Proposed Technical Specifications Bases Pages (For Information Only) -

R. E. Ginna Nuclear Power Plant cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, Calvert Cliffs Nuclear Power Plant

License Amendment Request to Adopt TSTF-273-A October 25, 2022 Page 3 USNRC Senior Resident Inspector, Peach Bottom Atomic Power Station USNRC Senior Resident Inspector, R. E. Ginna Nuclear Power Plant USNRC Project Manager, NRR - Calvert Cliffs Nuclear Power Plant USNRC Project Manager, NRR - Peach Bottom Atomic Power Station USNRC Project Manager, NRR - R. E. Ginna Nuclear Power Plant S. Seaman, State of Maryland Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection A.L. Peterson, NYSERDA

ATTACHMENT 1 Evaluation of Proposed Changes

Subject:

License Amendment Request to Adopt TSTF-273-A, [Safety Function Determination Program] SFDP Clarifications, Revision 2 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Optional Changes and Variations

3.0 REGULATORY EVALUATION

3.1 Applicability of Published Safety Evaluation 3.2 No Significant Hazards Consideration 3.3 Conclusions

5.0 REFERENCES

License Amendment Request to Adopt TSTF-273-A Page 1 of 5 1.0

SUMMARY

DESCRIPTION Constellation Energy Generation, LLC (CEG), proposes changes to the Technical Specifications (TS), Appendix A of the following:

Site: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (CCNPS)

License: Renewed Facility Operating License Nos. DPR-53 and DPR-69 Plant Type: Combustion Engineering Pressurized Water Reactor (PWR)

Site: Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 License: Subsequent Renewed Facility Operating License Nos. DPR-44 and DPR-56 Plant Type: General Electric Boiling Water Reactor/4 (BWR/4)

Site: R.E. Ginna Nuclear Power Plant (Ginna)

License: Renewed Facility Operating License No. DPR-18 Plant Type: Westinghouse Engineering PWR The proposed changes incorporate the NRC-approved Technical Specification Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF-273-A, [Safety Function Determination Program] SFDP Clarifications, Revision 2, as amended by Westinghouse Owners Group (WOG) editorial change WOG-ED-23 (Reference 5.1). The proposed changes add explanatory text to the LCO 3.0.6 Bases clarifying the "appropriate LCO for loss of function," and that consideration does not have to be made for a loss of power in determining loss of function. Explanatory text is also added to the programmatic description of the Safety Function Determination Program (SFDP) in TS 5.5.15 (CCNPP), TS 5.5.11 (PBAPS) and TS 5.5.14 (Ginna) to provide clarification of these same issues.

2.0 DETAILED DESCRIPTION The proposed changes revise TS 5.5.15 (CCNPP), TS 5.5.11 (PBAPS), and TS 5.5.14 (Ginna), Safety Function Determination Program (SFDP) to add a phrase which clarifies the SFDP connection to the "loss of function" (i.e., cross-train) check for electrical power inoperabilities contained within the LCO 3.8.1 Actions. This added text incorporates the revised language from WOG-ED-23. These TS changes remove ambiguity that have resulted in industry misinterpretation of the SFDP TS.

The proposed changes also add a statement to TS 5.5.11, Safety Function Determination Program (SFDP) (PBAPS) to clarify that the Actions for a single support system inoperability are addressed by that support system's Actions, without cascading to the supported system. The proposed changes clarify the SFDP intent to be consistent with LCO 3.0.6. By clarifying the intent of the existing requirements of the SFDP, these changes remove ambiguity that could lead to a misinterpretation of those requirements. This change is only applicable to PBAPS, Units 2 and 3.

Finally, a corresponding change to TS Bases 3.0.6 was made to add discussion that clarifies TS Actions for a single support system inoperability would be addressed by that support system's Actions and would not require cascading to the supported system, even if both trains of the support system were inoperable resulting from a loss of function. Without this clarification, supported systems with a single support system would be declared inoperable when the support system is inoperable under the provisions of LCO 3.0.6 even though the support system Actions were designed to provide the appropriate response.

License Amendment Request to Adopt TSTF-273-A Page 2 of 5 2.1 Optional Changes and Variations PBAPS, Units 2 and 3, and Ginna utilize different numbering than the Standard Technical Specifications on which TSTF-273 was based. Specifically, NUREG 1433 for BWR/4 Plants (Reference 5.8) has TS 5.5.12, "Safety Function Determination Program," which corresponds to TS 5.5.11 for PBAPS, Units 2 and 3. NUREG 1433 for Westinghouse Plants (Reference 5.6) has TS 5.5.15, "Safety Function Determination Program," which corresponds to TS 5.5.14 for Ginna. This difference is administrative in nature and does not affect the applicability of TSTF-273 to PBAPS, Units 2 and 3, or Ginna.

CCNPP, Units 1 and 2, and Ginna implemented TSTF-567, Revision 1 "Add Containment Sump TS to Address GSl-191 Issues" (References 5.3 and 5.4) which changed TS 5.5.15 (CCNPP) and TS 5.5.14 (Ginna) to add wording to clarify that the Actions for a single support system inoperability are addressed by that support system's Actions, without cascading to the supported system. The wording added by TSTF-567 is identical to the wording added by TSTF-273 Insert 2. Therefore, the TS for CCNPP, Units 1 and 2, and Ginna do not require the TSTF-273 Insert 2 change.

3.0 REGULATORY EVALUATION

3.1 Applicability of Published Safety Evaluation TSTF-273-A, Revision 2, was approved by the NRC as documented in a letter from William Beckner (NRC) to James Davis (NEI), dated August 16, 1999 (Reference 5.2) . TSTF-273-A, Revision 2 has been adopted by many plants as part of complete conversion to the Improved Standard Technical Specifications or in combination with other TSTF changes. An example of a plant-specific NRC approval of the changes in TSTF-273-A, Revision 2 is the May 12, 2022 NRC approval of Amendment Nos. 227 for Braidwood Station, Units 1 and 2; Amendment Nos. 229 for Byron Station, Unit Nos. 1 and 2; and Amendment No. 245 for Clinton Power Station, Unit 1 (Reference 5.5).

CEG has concluded that the justifications presented in TSTF-273-A, the associated approval letter prepared by the NRC staff, and the industry examples are applicable to CCNPP, Units 1 and 2, PBAPS, Units 2 and 3, and Ginna and justify the proposed amendments for incorporation into the associated TS.

3.2 No Significant Hazards Consideration Constellation Energy Generation, LLC (CEG), proposes changes to the Technical Specifications (TS) of Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2, Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, and R. E. Ginna Nuclear Power Plant (Ginna). The changes adopt TSTF-273, [Safety Function Determination Program] SFDP Clarifications, Revision 2, as amended by Westinghouse Owners Group (WOG) editorial change WOG-ED-23.

Title 10 of the Code of Federal Regulations (10 CFR), 10 CFR 50.36(c)(2), states:

Limiting conditions for operation [LCO]. (i) Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

License Amendment Request to Adopt TSTF-273-A Page 3 of 5 The SFDP, as described in TS 5.5.15 (CCNPP), TS 5.5.11 (PBAPS) and TS 5.5.14 (Ginna) implements the requirements of LCO 3.0.6, and ensures that loss of safety function is detected and appropriate actions are taken. There will be no changes to the plant design or operation such that compliance with the regulatory requirements and guidance document above would come into question. The plant and its systems will continue to comply with all applicable regulatory requirements. The proposed changes are consistent with the Improved Standard Technical Specification provided in NUREG-1431, NUREG-1432, and NUREG-1433.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

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

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

Response: No.

The proposed TS changes add explanatory text to the programmatic description of the Safety Function Determination Program (SFDP) in TS 5.5.15 (CCNPP), TS 5.5.11 (PBAPS) and TS 5.5.14 (Ginna), to clarify that consideration does not have to be made for a loss of power in determining loss of function. The Bases for Limiting Condition for Operation (LCO) 3.0.6 are revised to provide clarification of the "appropriate LCO for loss of function," and that consideration does not have to be made for a loss of power in determining loss of function. The changes are editorial and administrative in nature, and therefore do not increase the probability of any accident previously evaluated. No physical or operational changes are being made to the plant. The proposed changes do not have any impact on the integrity of any plant system, structure, or component that initiates an analyzed event.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed changes are editorial and administrative in nature and do not result in a change in the manner in which the plant operates. The loss of function of any specific component will continue to be addressed in the applicable TS LCO, and plant configuration will be governed by the required actions of those LCOs. The proposed changes are clarifications that do not degrade the availability or capability of safety related equipment, and therefore do not create the possibility of a new or different kind of accident from any accident previously evaluated. There are no design changes associated with the proposed

License Amendment Request to Adopt TSTF-273-A Page 4 of 5 changes, and the changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed). The changes do not alter assumptions made in the safety analysis, and are consistent with the safety analysis assumptions and current plant operating practice. Due to the administrative nature of the changes, they cannot be an accident initiator.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

The proposed changes to TS 5.5.15 (CCNPP), TS 5.5.11 (PBAPS) and TS 5.5.14 (Ginna), are clarifications and are editorial and administrative in nature. No changes are being made to the LCOs for plant equipment, the time required for the TS Required Actions to be completed, or the out of service time for the components involved.

The proposed changes do not affect the safety analysis acceptance criteria for any analyzed event, nor is there a change to any safety analysis limit. The proposed changes do not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined, nor is there any adverse effect on those plant systems necessary to assure the accomplishment of protection functions. The proposed changes will not result in plant operation in a configuration outside the design basis.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

3.3 Conclusions Based on the above, CEG concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL CONSIDERATION

The proposed changes would revise an administrative control requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.

License Amendment Request to Adopt TSTF-273-A Page 5 of 5

5.0 REFERENCES

5.1 TSTF-273-A, Revision 2, [Safety Function Determination Program] SFDP Clarifications, dated 07/17/99 (ADAMS Accession No. ML040611069) 5.2 Letter from W.D. Beckner (NRC) to J. Davis (NEI), dated 08/16/99 5.3 Calvert Cliffs, Unit 1 and 2 - Issuance of Amendments 340/318 Re: Adoption of Technical Specifications Task Force Traveler TSTF-567, Revision 1, 'Add Containment Sump TS to Address GSI-191 Issues,' dated 12/14/21 (ADAMS Accession No. ML21299A005) 5.4 Braidwood Units 1 and 2 (216/216), Byron Units 1 and 2 (220/220), and Ginna (143) -

Issuance of Amendments RE: Adoption of TSTF-567, Rev. 1, Add Containment Sump Technical Specifications to Address GSI-191 Issues,' dated 09/11/20 (ADAMS Accession No. ML20167A007) 5.5 Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; and Clinton Power Station, Unit 1 - Issuance of Amendments RE: Adoption of Technical Specifications Task Force Traveler (TSTF) 273, Revision 2, Safety Function Determination Program Clarifications, dated 05/12/22 (ADAMS Accession No. ML22095A270) 5.6 NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Volume 1, Revision 5, dated September 2021 5.7 NUREG-1432, Standard Technical Specifications, Combustion Engineering Plants, Volume 1, Revision 5, dated September 2021 5.8 NUREG-1433, Standard Technical Specifications, General Electric BWR/4 Plants, Volume 1, Revision 4, dated September 2021

ATTACHMENT 2a Markup of Technical Specifications Pages Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Revised Technical Specifications Page 5.5-16

Programs and Manuals 5.5 5.5 Programs and Manuals A loss of safety function exists when, assuming no concurrent single failure, a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, no concurrent loss and:

of offsite power or no concurrent loss a. A required system redundant to system(s) supported by the of onsite diesel inoperable support system is also inoperable; or generator(s),

b. A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable; or

c. A required system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.

5.5.16 Containment Leakage Rate Testing Program A program shall be established to implement the leakage testing of the containment as required by 10 CFR 50.54(o) and 10 CFR Part 50, Appendix J, Option B. This program shall be in accordance with the guidelines contained in Nuclear Energy Institute (NEI) 94-01, Industry Guideline for Implementing Performance Based Option of 10 CFR Part 50, Appendix J, Revision 3-A, dated July 2012, and the conditions and limitations specified in NEI 94-01, Revision 2-A dated October 2008.

The peak calculated containment internal pressure for the design basis loss-of-coolant accident, Pa, is 49.7 psig. The containment design pressure is 50 psig.

CALVERT CLIFFS - UNIT 1 5.5-16 Amendment No. 340 CALVERT CLIFFS - UNIT 2 Amendment No. 318

ATTACHMENT 2b Markup of Technical Specifications Pages Peach Bottom Atomic Power Station, Unit 2 Subsequent Renewed Facility Operating License No. DPR-44 NRC Docket No. 50-277 Revised Technical Specifications Page 5.0-16 5.0-17

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.10 Technical Specifications (TS) Bases Control Program (continued)

d. Proposed changes that meet the criteria of b. above shall be reviewed and approved by the NRC prior to implementation.

Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

5.5.11 Safety Function Determination Program (SFDP)

This program ensures loss of safety function is detected and appropriate actions taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other appropriate limitations and remedial or compensatory actions may be identified to be taken as a result of the support system inoperability and corresponding exception to entering supported system Condition and Required Actions. This program implements the requirements of LCO 3.0.6.

a. The SFDP shall contain the following:

1. Provisions for cross division checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected;

2. Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists;

3. Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and

4. Other appropriate limitations and remedial or compensatory actions.

no concurrent loss b. A loss of safety function exists when, assuming no of offsite power or concurrent single failure, a safety function assumed in the no concurrent loss accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a of onsite diesel support system is inoperable, and:

generator(s),

(continued)

PBAPS UNIT 2 5.0-16 Amendment No. 210

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Safety Function Determination Program (SFDP) (continued)

1. A required system redundant to system(s) supported by When a loss of safety the inoperable support system is also inoperable; or function is caused by the inoperability of a 2. A required system redundant to system(s) in turn single Technical supported by the inoperable supported system is also inoperable; or Specification support system, the appropriate 3. A required system redundant to support system(s) for Conditions and the supported systems (b.1) and (b.2) above is also Required Actions to inoperable.

enter are those of the c. The SFDP identifies where a loss of safety function exists.

support system. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

5.5.12 Primary Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions.

This program shall be in accordance with the guidelines contained in NEI 94-01, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, Revision 3-A, dated July 2012, and the conditions and limitations specified in NEI 94-01, Revision 2-A, dated October 2008, as modified by the following exception:

a. Section 10.2: MSIV leakage is excluded from the combined total of 0.6 L a for the Type B and C tests.

The peak calculated containment internal pressure for the design basis loss of coolant accident, P a , is 49.1 psig.

The maximum allowable primary containment leakage rate, L a , at P a ,

shall be 0.7% of primary containment air weight per day.

Leakage Rate acceptance criteria are:

a. Primary Containment leakage rate acceptance criterion is 1.0 L a . During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are 0.60 L a for the Type B and Type C tests and 0.75 L a for Type A tests; (continued)

PBAPS UNIT 2 5.0-17 Amendment No. 302

ATTACHMENT 2c Markup of Technical Specifications Pages Peach Bottom Atomic Power Station, Unit 3 Subsequent Renewed Facility Operating License No. DPR-56 NRC Docket No. 50-278 Revised Technical Specifications Page 5.0-16 5.0-17

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.10 Technical Specifications (TS) Bases Control Program (continued)

d. Proposed changes that meet the criteria of b. above shall be reviewed and approved by the NRC prior to implementation.

Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

5.5.11 Safety Function Determination Program (SFDP)

This program ensures loss of safety function is detected and appropriate actions taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other appropriate limitations and remedial or compensatory actions may be identified to be taken as a result of the support system inoperability and corresponding exception to entering supported system Condition and Required Actions. This program implements the requirements of LCO 3.0.6.

a. The SFDP shall contain the following:

1. Provisions for cross division checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected;

2. Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists;

3. Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and

4. Other appropriate limitations and remedial or no concurrent loss compensatory actions.

of offsite power or b. A loss of safety function exists when, assuming no no concurrent loss concurrent single failure, a safety function assumed in the of onsite diesel accident analysis cannot be performed. For the purpose of generator(s), this program, a loss of safety function may exist when a support system is inoperable, and:

(continued)

PBAPS UNIT 3 5.0-16 Amendment No. 214

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Safety Function Determination Program (SFDP) (continued)

1. A required system redundant to system(s) supported by the inoperable support system is also inoperable; or When a loss of safety function is caused by 2. A required system redundant to system(s) in turn the inoperability of a supported by the inoperable supported system is also single Technical inoperable; or Specification support

3. A required system redundant to support system(s) for system, the appropriate the supported systems (b.1) and (b.2) above is also Conditions and inoperable.

Required Actions to enter are those of the c. The SFDP identifies where a loss of safety function exists.

support system. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

5.5.12 Primary Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions.

This program shall be in accordance with the guidelines contained in NEI 94-01, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, Revision 3-A dated July 2012, and the conditions and limitations specified in NEI 94-01, Revision 2-A, dated October 2008, as modified by the following exception:

a. Section 10.2: MSIV leakage is excluded from the combined total of 0.6 L a for the Type B and C tests.

The peak calculated containment internal pressure for the design basis loss of coolant accident, P a , is 49.1 psig.

The maximum allowable primary containment leakage rate, L a , at P a ,

shall be 0.7% of primary containment air weight per day.

Leakage Rate acceptance criteria are:

a. Primary Containment leakage rate acceptance criterion is 1.0 L a . During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are 0.60 L a for the Type B and Type C tests and 0.75 L a for Type A tests; (continued)

PBAPS UNIT 3 5.0-17 Amendment No. 306

ATTACHMENT 2d Markup of Technical Specifications Pages R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244 Revised Technical Specifications Page 5.5-10

Programs and Manuals 5.5

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

1. A change in the TS incorporated in the license; or

2. A change to the UFSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the UFSAR.

d. Proposed changes that meet the criteria of Specification 5.5.13.b.1 or Specification 5.5.13.b.2 shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71e.

5.5.14 Safety Function Determination Program (SFDP)

This program ensures loss of safety function is detected and appropriate actions taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other appropriate actions may be taken as a result of the support system inoperability and corresponding exception to entering supported system Condition and Required Actions. This program implements the requirements of LCO 3.0.6. The SFDP shall contain the following:

a. Provisions for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected;

b. Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists;

c. Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and

d. Other appropriate limitations and remedial or compensatory no concurrent loss actions.

of offsite power or no concurrent loss A loss of safety function exists when, assuming no concurrent single failure, a safety function assumed in the accident analysis cannot be of onsite diesel performed. For the purpose of this program, a loss of safety function may generator(s), exist when a support system is inoperable, and:

a. A required system redundant to the supported system(s) is also inoperable; or R.E. Ginna Nuclear Power Plant 5.5-10 Amendment 110

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

Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Revised Technical Specifications Bases Page B 3.0-12

LCO Applicability B 3.0 BASES EXAMPLE 83.0.6-1 If System 2 of Train A is inoperable, and System 5 of Train B is inoperable, a loss of safety function exists in supported Systems 5, 10, and 11.

b. A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable; or EXAMPLE 83.0.6-2 If System 2 of Train A is inoperable, and System 11 of Train B is inoperable, a loss of safety function exists in System 11.

c. A required system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable.

EXAMPLE 83.0.6-3 If System 2 of Train A is inoperable, and System 1 of Train B is inoperable, a loss of safety function exists in Systems 2, 4, 5, 8, 9, 10, and 11.

TRAIN A TRAIN B System 8 System 8 System 4 System 4

[ system 9 [ System 9 System 2 System 2 System System 10 10 System 5 System 5

[ System [ System 11 11 System 1 System 1 System System 12 12 System 6 System 6

[ System [ System 13 13 System 3 System 3 System System 14 14 System 7 System 7

[ System [ System 15 15 If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

Insert 1 CALVERT CLIFFS - UNITS 1 & 2 B 3.0-12 Revision 62

TSTF-273, Rev. 2 Insert 1 This loss of safety function does not require the assumption of additional single failures or loss of offsite power. Since operation is being restricted in accordance with the ACTIONS of the support system, any resulting temporary loss of redundancy or single failure protection is taken into account. Similarly, the ACTIONS for inoperable offsite circuit(s) and inoperable diesel generator(s) provide the necessary restriction for cross train inoperabilities. This explicit cross train verification for inoperable AC electrical power sources also acknowledges that supported system(s) are not declared inoperable solely as a result of inoperability of a normal or emergency electrical power source (refer to the definition of OPERABILITY).

When a loss of safety function is determined to exist, and the SFDP requires entry into the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists, consideration must be given to the specific type of function affected. Where a loss of function is solely due to a single Technical Specification support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level) the appropriate LCO is the LCO for the support system. The ACTIONS for a support system LCO adequately addresses the inoperabilities of that system without reliance on entering its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported system.

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

Peach Bottom Atomic Power Station, Unit 2 Subsequent Renewed Facility Operating License No. DPR-44 NRC Docket No. 50-277 Revised Technical Specifications Bases Pages B 3.0-8

LCO Applicability B 3.0 BASES LCO 3.0.6 systems' LCOs' Conditions and Required Actions are (continued) eliminated by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's Required Actions.

However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system. This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, when a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

Specification 5.5.11, "Safety Function Determination Program (SFDP)," ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross division checks to identify a loss of safety function for those support systems that support safety systems are required. The cross division check verifies that the supported systems of the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained.

If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

Insert 1 LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit.

These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform (continued)

PBAPS UNIT 2 B 3.0-8 Revision No. 0

TSTF-273, Rev. 2 Insert 1 This loss of safety function does not require the assumption of additional single failures or loss of offsite power. Since operation is being restricted in accordance with the ACTIONS of the support system, any resulting temporary loss of redundancy or single failure protection is taken into account. Similarly, the ACTIONS for inoperable offsite circuit(s) and inoperable diesel generator(s) provide the necessary restriction for cross train inoperabilities. This explicit cross train verification for inoperable AC electrical power sources also acknowledges that supported system(s) are not declared inoperable solely as a result of inoperability of a normal or emergency electrical power source (refer to the definition of OPERABILITY).

When a loss of safety function is determined to exist, and the SFDP requires entry into the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists, consideration must be given to the specific type of function affected. Where a loss of function is solely due to a single Technical Specification support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level) the appropriate LCO is the LCO for the support system. The ACTIONS for a support system LCO adequately addresses the inoperabilities of that system without reliance on entering its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported system.

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

Peach Bottom Atomic Power Station, Unit 3 Subsequent Renewed Facility Operating License No. DPR-56 NRC Docket No. 50-278 Revised Technical Specifications Bases Pages B 3.0-8

LCO Applicability B 3.0 BASES LCO 3.0.6 systems' LCOs' Conditions and Required Actions are (continued) eliminated by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's Required Actions.

However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system. This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, when a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

Specification 5.5.11, "Safety Function Determination Program (SFDP)," ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross division checks to identify a loss of safety function for those support systems that support safety systems are required. The cross division check verifies that the supported systems of the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained.

If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are Insert 1 required to be entered.

LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit.

These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform (continued)

PBAPS UNIT 3 B 3.0-8 Revision No. 0

TSTF-273, Rev. 2 Insert 1 This loss of safety function does not require the assumption of additional single failures or loss of offsite power. Since operation is being restricted in accordance with the ACTIONS of the support system, any resulting temporary loss of redundancy or single failure protection is taken into account. Similarly, the ACTIONS for inoperable offsite circuit(s) and inoperable diesel generator(s) provide the necessary restriction for cross train inoperabilities. This explicit cross train verification for inoperable AC electrical power sources also acknowledges that supported system(s) are not declared inoperable solely as a result of inoperability of a normal or emergency electrical power source (refer to the definition of OPERABILITY).

When a loss of safety function is determined to exist, and the SFDP requires entry into the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists, consideration must be given to the specific type of function affected. Where a loss of function is solely due to a single Technical Specification support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level) the appropriate LCO is the LCO for the support system. The ACTIONS for a support system LCO adequately addresses the inoperabilities of that system without reliance on entering its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported system.

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

R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244 Revised Technical Specifications Bases Pages B 3.0-9

LCO Applicability B3.0 to ensure the plant is maintained in a safe condition are specified in the support systems' LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions.

When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCO's Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's Required Actions.

However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.

This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, when a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LC03.0.2.

Specification 5.5.14, "Safety Function Determination Program (SFDP),"

ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross train checks to identify a loss of safety function for those support systems that support multiple and redundant safety systems are required.

The cross train check verifies that the supported systems of the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained. If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

Insert 1 LC03.0.7 There are certain special tests and operations required to be performed at various times over the life of the plant. These special tests and operations are necessary to demonstrate select plant performance characteristics, to perform special maintenance activities, and to R.E. Ginna Nuclear Power Plant B3.0-9 Revision82

TSTF-273, Rev. 2 Insert 1 This loss of safety function does not require the assumption of additional single failures or loss of offsite power. Since operation is being restricted in accordance with the ACTIONS of the support system, any resulting temporary loss of redundancy or single failure protection is taken into account. Similarly, the ACTIONS for inoperable offsite circuit(s) and inoperable diesel generator(s) provide the necessary restriction for cross train inoperabilities. This explicit cross train verification for inoperable AC electrical power sources also acknowledges that supported system(s) are not declared inoperable solely as a result of inoperability of a normal or emergency electrical power source (refer to the definition of OPERABILITY).

When a loss of safety function is determined to exist, and the SFDP requires entry into the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists, consideration must be given to the specific type of function affected. Where a loss of function is solely due to a single Technical Specification support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level) the appropriate LCO is the LCO for the support system. The ACTIONS for a support system LCO adequately addresses the inoperabilities of that system without reliance on entering its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported system.