RS-09-042, Request for Amendment to Technical Specifications Section 5.5.6, Inservice Testing Program to Incorporate Previously NRC-Approved Generic TS Changes

Request for Amendment to Technical Specifications Section 5.5.6, Inservice Testing Program to Incorporate Previously NRC-Approved Generic TS Changes

ML091130421
Person / Time
Site:	Clinton
Issue date:	04/22/2009
From:	Hansen J Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-09-042
Download: ML091130421 (23)

Text

Exelon Exelon Nuclear www.exeloncorp .com Nuclear 4300 Winfield Road Warrenville, IL 60555 RS-09-042 10 CFR 50.90 April 22, 2009 U. S . Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No . 50-461

Subject:

Request for Amendment to Technical Specifications Section 5.5.6, "Inservice Testing Program" to Incorporate Previously NRC-Approved Generic Technical Specification Changes

References:

1 . TSTF-479-A, Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a," dated December 19, 2005

2. TSTF-497, Revision 0, "Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less," dated July 12, 2006

3. TSTF-279, Revision 0, "Remove 'applicable supports' from Inservice Testing Program," dated May 21, 1998 4 . Letter from T. H. Boyce (U. S. NRC) to members of the Technical Specification Task Force, "Status of TSTF 343, 479, 482, 485," dated December 6, 2005

5. Letter from T. J. Kobetz (U . S. NRC) to members of the Technical Specification Task Force, dated October 4, 2006

6. Letter from W. D. Beckner (U . S. NRC) to J. Davis (Nuclear Energy Institute), dated July 16, 1998 In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC, (EGC), requests the following amendment to Appendix A, Technical Specifications (TS), of Facility Operating License No. NPF-62 for Clinton Power Station (CPS), Unit 1 . Specifically, the proposed changes will incorporate previously NRC-approved Technical Specification Task Force (TSTF) travelers associated with TS 5.5.6, "Inservice Testing Program."

April 22, 2009 U. S. Nuclear Regulatory Commission Page 2 The proposed changes replace references to Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code with a reference to the ASME Code for Operation and Maintenance of Nuclear Power Plants (i.e., OM Code),

and add provisions in TS 5.5 .6, item b, to only apply Surveillance Requirement (SR) 3.0.2 to those Inservice Testing (IST) frequencies of two years or less . In addition, the change removes the words "including applicable supports" from the description of the IST Program.

The proposed changes are based on TSTF Traveler No. 479-A (TSTF-479-A),

Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a," (i .e., Reference 1) as modified by TSTF-497, Revision 0, "Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less" (i.e., Reference 2) and approved by the NRC in References 4 and 5, respectively . Also, the changes are based on TSTF-279, "Remove 'applicable supports' from Inservice Testing Program," Revision 0 (i .e .,

Reference 3) and approved by the NRC in Reference 6.

EGC requests approval of the proposed changes by April 30, 2010 with the amendment being implemented within 30 days of issuance .

The attached amendment request is subdivided as shown below.

Attachment 1 provides an evaluation of the proposed changes.

Attachment 2 includes a marked-up copy of the applicable TS pages with the proposed changes indicated .

Attachment 3 includes the marked-up TS Bases pages with the proposed changes indicated. Note that the TS Bases pages are provided for information only and do not require prior NRC approval .

The proposed changes have been reviewed by the CPS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.

In accordance with 10 CFR 50 .91, "Notice for public comment; State consultation," EGC is notifying the State of Illinois of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated State Official .

There are no regulatory commitments contained in this letter . Should you have any questions concerning this letter, please contact Mr. Timothy A. Byam at (630) 657-2804 .

April 22, 2009 U . S . Nuclear Regulatory Commission Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 22nd day of April 2009 .

ansen er - Licensing Exelon Generation Company, LLC  : Evaluation of the Proposed Changes : Mark-up of Proposed Technical Specifications Page Changes : Mark-up of Proposed Technical Specifications Bases Page Changes

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES

Subject:

Request for Amendment to Technical Specifications Section 5.5.6, "Inservice Testing Program" to Incorporate Previously NRC-Approved Generic Technical Specification Changes 1 .0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions 5 .0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

Page 1 of 10

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES 1 .0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50 .90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC, (EGC), requests the following amendment to Appendix A, Technical Specifications (TS), of Facility Operating License No. NPF-62 for Clinton Power Station (CPS), Unit 1 . Specifically, the proposed changes will incorporate previously NRC-approved Technical Specification Task Force (TSTF) travelers associated with TS 5.5.6, "Inservice Testing Program." The proposed changes replace references to Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code with a reference to the ASME Code for Operation and Maintenance of Nuclear Power Plants (i .e ., OM Code), and add provisions in TS 5.5 .6, item b, to only apply Surveillance Requirement (SR) 3.0.2 to those Inservice Testing (IST) frequencies of two years or less. In addition, the change removes the words "including applicable supports" from the description of the IST Program .

The proposed changes are based on TSTF Traveler No. 479-A (i.e., TSTF-479-A),

Revision 0, "Changes to Reflect Revision of 10 CFR 50 .55a," (i .e., Reference 1) as modified by TSTF-497, Revision 0, "Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less" (i .e., Reference 2) and approved by the NRC in References 4 and 5, respectively . Also, the changes are based on TSTF-279, "Remove 'applicable supports' from Inservice Testing Program," Revision 0 (i.e.,

Reference 3) and approved by the NRC in Reference 6 .

2.0 DETAILED DESCRIPTION EGC proposes to revise the existing wording of TS 5.5 .6 to replace references to the ASME Boiler and Pressure Vessel Code Section XI with a reference to the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code). The change also proposes to remove the words "including applicable supports" from the description of the IST Program. The revised TS 5 .5 .6, with additions italicized, will be as follows.

"This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 components . The program shall include the following:

a. Testing frequencies applicable to the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda as follows :

ASME OM Code and applicable Addenda terminology for Required frequencies inservice testing for performing inservice activities testing activities Weekly At least once per 7 days Monthly At least once per 31 days Page 2 of 10

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days

b. The provisions of SR 3.0.2 are applicable to the above required frequencies and to other normal and accelerated frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities ;

c. The provisions of SR 3.0.3 are applicable to inservice testing activities ;

and

d. Nothing in the ASME OM Code shall be construed to supersede the requirements of any Technical Specification."

A copy of the affected TS pages marked-up to show the proposed changes identified above is provided in Attachment 2 .

TS Bases sections will also be revised to replace or delete the references to Section XI of the ASME Boiler and Pressure Vessel Code as applicable. A mark-up reflecting the TS bases changes is provided in Attachment 3. The TS Bases are provided for information only, and do not require NRC approval .

3.0 TECHNICAL EVALUATION

In 1990, the ASME published the initial edition of the ASME OM Code that provided rules for inservice testing of pumps and valves . The ASME OM Code replaced Section XI of the Boiler and Pressure Vessel Code for inservice testing of pumps and valves .

The 1995 edition with the 1996 Addenda of the ASME OM Code (i.e., Reference 8) was incorporated by reference into 10 CFR 50.55a, "Codes and standards," paragraph (b) on September 22, 1999 (i .e., Reference 7) . The 2001 edition with the 2003 Addenda of the ASME OM Code (i.e ., Reference 10) was approved for use by the NRC and was incorporated by reference into 10 CFR 50.55a paragraph (b) on October 1, 2004 (i.e.,

Reference 9). The ASME OM Code, 2004 Edition (i .e., Reference 14), was approved for use by the NRC and was incorporated by reference into 10 CFR 50.55a paragraph (b) on September 10, 2008 (i .e., Reference 15) . The ASME OM Code 2004 Edition (no Addenda) will be the ASME code of record beginning with the upcoming Third 10-Year IST Interval Program for CPS Unit 1 .

Since 10 CFR 50.55a paragraph (f), "Inservice testing requirements," section (4)(ii) requires that inservice testing during successive 120-month intervals comply with the requirements of the latest edition and addenda of the Code incorporated by reference Page 3 of 10

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES into 10 CFR 50 .55a(b) 12 months before the start of the 120-month interval, therefore TS 5.5.6 must be revised to reference the ASME OM Code.

These proposed changes are consistent with TSTF-479-A, Revision 0, (i.e., Reference

1) that was approved by the NRC in Reference 4 and incorporated into NUREG-1434, "Standard Technical Specifications, General Electrical Plants BWR/6," Revision 3.1 .

On February 23, 2006 at a meeting between the TSTF and the NRC, the NRC stated that they did not agree with a portion of TSTF-479 referring to the application of a 25%

IST interval extension for SR 3.0.2 to test frequencies and would not approve plant-specific amendments incorporating that portion of TSTF-479 . Specifically, the NRC expressed a concern that frequency extensions may be applied to frequencies greater than two years and requested that the TSTF be revised to apply the provisions of SR 3.0.2 to frequencies of two years or less only . On July 12, 2006, TSTF-497, Revision 0, (i .e., Reference 2) was submitted to reflect the revised NRC position . These proposed changes for CPS are based on TSTF-479-A, Revision 0, as modified by TSTF-497, Revision 0, which was approved by the NRC on October 4, 2006 (i .e., Reference 5).

TS 5.5.6 currently references the ASME Boiler and Pressure Vessel Code,Section XI, as the standard for testing frequencies and inservice testing of ASME Code Class 1, 2, and 3 components, including applicable supports . A change to the IST Program description in TS was proposed in TSTF-279 (i.e., Reference 3) and was subsequently approved by the NRC on July 16, 1998 (i .e., reference 6). The IST Program provides controls for testing ASME Code Class 1, 2, and 3 components . Pipe and component supports are addressed in the Inservice Inspection (ISI) Program, not the IST Program.

The phrase "including applicable supports" (e .g ., snubbers), is out of place and is being removed based on Reference 3. The ISI Program required by 10 CFR 50.55a contains appropriate guidance and testing concerning snubbers and supports . Accordingly, removing this phrase changes no requirements related to supports .

The code of record beginning with the Third 10-Year IST Interval Program for CPS will be the ASME OM Code 2004 Edition (no Addenda) (i.e ., Reference 14) . The proposed changes to TS 5.5.6 will replace references to Section XI of the ASME Boiler and Pressure Vessel Code with a reference to the ASME OM Code to conform the TS to the updated IST Program to meet the requirements of the Code currently endorsed by reference in 10 CFR 50.55a(f)(4), as amended in Reference 15, beginning with the upcoming CPS Third 10-Year IST Interval .

Page 4 of 10

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES

4.0 REGULATORY ANALYSIS

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.55a defines the requirements for applying industry Codes to a licensed boiling or pressurized water-cooled nuclear power facility . 10 CFR 50.55a(f)(4) requires that throughout the service life of a boiling water-cooled nuclear power facility, pumps and valves which are classified as ASME Code Class 1, Class 2 and Class 3, must meet the inservice test requirements that are incorporated by reference in 10 CFR 50.55a(b) to the extent practical within the limitations of design, geometry and materials of construction of the components. 10 CFR 50.55a(f)(4)(ii) further states that inservice tests to verify operational readiness of pumps and valves, whose function is required for safety, conducted during successive 120-month intervals must comply with the latest edition and addenda of the Code, incorporated by reference in 10 CFR 50.55a(b),

12 months before the start of the 120-month interval .

10 CFR 50.55a(f)(5)(ii) states that if a revised inservice test program for a facility conflicts with the TS for the facility, the licensee shall apply to the NRC for amendment of the TS to conform the TS to the revised program . This application shall be submitted at least six months before the start of the period during which the provisions become applicable .

TS 5.5 .6 for CPS currently references the ASME Boiler and Pressure Vessel Code,Section XI, as the standard for testing frequencies and inservice testing of ASME Code Class 1, 2, and 3 components, including applicable supports . The ASME code of record beginning with the Third 10-Year IST Interval Program for CPS will be the ASME OM Code, 2004 Edition (no Addenda) . The proposed changes to TS 5.5.6 will replace references to Section XI of the ASME Boiler and Pressure Vessel Code with references to the ASME OM Code to conform the TS to the updated IST Program to meet the requirements of the Code currently endorsed by reference in 10 CFR 50.55a(f)(4), as amended in Reference 15, beginning with the upcoming CPS Third 10-Year IST Interval .

The changes also eliminate references to "applicable supports" from the description of the IST program .

4.2 Precedent EGC has implemented these proposed changes at all the stations within the fleet except for CPS. The changes proposed herein are consistent with those approved for LaSalle County Station, Units 1 and 2 (Reference 11). They are also consistent with those approved for Byron Station, Units 1 and 2 ; Braidwood Station, Units 1 and 2; Dresden Nuclear Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Oyster Creek Nuclear Generating Station ;

Peach Bottom Atomic Power Station, Units 2 and 3 ; and Three Mile Island Nuclear Station Unit 1 (References 12 and 13).

Page 5 of 10

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES 4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC, (EGC), requests the following amendment to Appendix A, Technical Specifications (TS), of Facility Operating License No. NPF-62 for Clinton Power Station (CPS), Unit 1 . Specifically, the proposed changes will replace references to Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code with a reference to the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) in TS 5.5 .6, "Inservice Testing Program ." These proposed changes are consistent with the implementation of the CPS, Unit 1 Inservice Testing (IST) Program beginning with Third 10-Year IST Interval in accordance with the requirements of 10 CFR 50.55a, "Codes and standards," paragraph (f), "Inservice testing requirements ." In addition to the replacement of the references, EGC is also adding provisions in TS 5 .5.6, item b, to only apply Surveillance Requirement (SR) 3 .0.2 to those Inservice Testing Frequencies of two years or less. Also, the change includes removing the phrase "including applicable supports" from the description of the IST Program.

These proposed changes are based on Technical Specification Task Force (TSTF)

Traveler No. 479-A (TSTF-479-A), Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a," as modified by TSTF-497, Revision 0, "Limit Inservice Testing Program SR 3 .0.2 Application to Frequencies of 2 Years or Less" . The change to the description of the IST Program is based on TSTF-279, "Remove 'applicable supports' from Inservice Testing Program," Revision 0 .

EGC 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 described below:

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

Response : No The proposed changes revise TS 5 .5.6 for CPS Unit 1 to conform to the requirements of 10 CFR 50.55a, "Codes and standards," paragraph (f) regarding the inservice testing of pumps and valves beginning with the Third 10-Year Interval . The current TS reference the ASME Boiler and Pressure Vessel Code,Section XI, requirements for the inservice testing of ASME Code Class 1, 2, and 3 components, including applicable supports. The proposed changes would reference the ASME OM Code, which is consistent with 10 CFR 50.55a, paragraph (f), "Inservice testing requirements," and approved for use by the NRC . In addition, provisions modifying TS 5 .5 .6, item b, clarify that SR 3 .0.2 is only applied to those inservice testing frequencies of two years or less. The definitions of the frequencies are not changed by this license amendment request. The change removing the phrase "including applicable supports" clarifies the scope of components in the IST Program .

Page 6 of 10

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES The proposed changes do not affect any accident initiators, do not affect the ability of CPS to successfully respond to previously evaluated accidents and do not affect radiological assumptions used in the evaluations . Thus, the radiological consequences of any accident previously evaluated are not increased.

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

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

Response : No The proposed changes revise TS 5 .5 .6 for CPS Unit 1 to conform to the requirements of 10 CFR 50.55a(f) regarding the inservice testing of pumps and valves beginning with the Third 10-Year Interval . The current TS reference the ASME Boiler and Pressure Vessel Code,Section XI, requirements for the inservice testing of ASME Code Class 1, 2, and 3 components, including applicable supports . The proposed changes would reference the ASME OM Code, which is consistent with the 10 CFR 50.55a(f) and approved for use by the NRC. In addition provisions modifying TS 5 .5.6, item b, clarify that SR 3.0.2 is only applied to those inservice testing frequencies of two years or less. The definitions of the frequencies are not changed by this license amendment request. The change removing the phrase "including applicable supports" clarifies the scope of components in the IST Program .

The proposed changes to TS Section 5 .5 .6 do not affect the performance of any CPS structure, system, or component credited with mitigating any accident previously evaluated and do not introduce any new modes of system operation or failure mechanisms . In addition, the proposed changes do not revise the frequency or method of testing the components covered by the IST program .

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

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

Response: No The proposed changes revise TS 5 .5.6 for CPS to conform to the requirements of 10 CFR 50.55a(f) regarding the inservice testing of pumps and valves beginning with the Third 10-Year Interval . The current TS reference the ASME Boiler and Pressure Vessel Code,Section XI, requirements for the inservice testing of ASME Code Class 1, 2, and 3 components, including applicable supports . The proposed changes would reference the ASME OM Code, which is consistent with the 10 CFR 50.55a(f) and approved for use by the NRC . In addition provisions modifying TS 5 .5 .6, item b, clarify that SR 3.0.2 is only Page 7 of 10

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES applied to those inservice testing frequencies of two years or less . The definitions of the frequencies are not changed by this license amendment request. The change removing the phrase "including applicable supports" clarifies the scope of components in the IST Program.

The proposed changes do not modify the safety limits or setpoints at which protective actions are initiated and do not change the requirements governing operation or availability of safety equipment assumed to operate to preserve the margin of safety .

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

Based on the above information, EGC concludes that the proposed amendment presents 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.

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

5.0 ENVIRONMENTAL EVALUATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure . Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22(c)(9) . Therefore, pursuant to 10 CFR 51 .22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6 .0 REFERENCES 1 . TSTF-479-A, Revision 0, "Changes to Reflect Revision of 10 CFR 50 .55a," dated December 19, 2005 Page 8 of 10

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES 2 . TSTF-497, Revision 0, "Limit Inservice Testing Program SR 3.0 .2 Application to Frequencies of 2 Years or Less," dated July 12, 2006

3. TSTF-279, Revision 0, "Remove 'applicable supports' from Inservice Testing Program," dated May 21, 1998

4. Letter from T. H. Boyce (U . S . NRC) to members of the Technical Specification Task Force, "Status of TSTF 343, 479, 482, 485," dated December 6, 2005

5. Letter from T. J . Kobetz (U. S. NRC) to members of the Technical Specification Task Force, dated October 4, 2006 6 . Letter from W.D . Beckner (U .S . NRC) to J. Davis (Nuclear Energy Institute),

dated July 16, 1998

7. Federal Register, Volume 64, Number 183, "10 CFR Part 50 -Industry Codes and Standards; Amended Requirements," dated September 22, 1999

8. American Society of Mechanical Engineers (ASME), "Operation and Maintenance of Nuclear Power Plants (OM Code)," 1995 Edition through the 1996 Addenda

9. Federal Register, Volume 69, Number 190, "10 CFR Part 50 -Industry Codes and Standards; Amended Requirements," dated October 1, 2004

10. American Society of Mechanical Engineers (ASME), "Operation and Maintenance of Nuclear Power Plants (OM Code)," 2001 Edition through the 2003 Addenda 11 . Letter from S. P . Sands (U . S. NRC) to Mr. C. M. Crane (Exelon Generation Company, LLC), "LaSalle County Station, Units 1 and 2, Issuance of Amendments Re: Amendment to Technical Specification Section 5 .5 .7, "Inservice Testing Program," (TAC Nos. MD3604 and MD36 .5)," dated October 12, 2007 12 . Letter from Mr. C. Gratton (U . S . NRC) to Mr. C. G . Pardee (Exelon Generation Company, LLC), "Braidwood Station, Units 1 and 2; Byron Station, Unit Nos . 1 and 2 ; Dresden Nuclear Power Station, Units 2 and 3; Limerick Generating Station, Units 1 and 2; Oyster Creek Nuclear Generating Station; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; and Three Mile Island Nuclear Station, Unit 1 -Issuance of Amendments That Adopt Technical Specification Task Force (TSTF) Change Traveler TSTF-479 and TSTF-497 (TAC Nos . MD6530 THRU MD6543)," dated August 28, 2008

13. Letter from Mr. R . V. Guzman (U . S. NRC) to Mr. C. M . Crane (Exelon Generation Company, LLC), "Peach Bottom Atomic Power Station, Units 2 and 3

- Issuance of Amendments re : Incorporation of Previously NRC-Approved Generic Technical Specification Changes (TAC NOS. MC3683, MC3684, Page 9 of 10

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES MD1516, MD1517, MD1518, MD1519, MD1520, MD1521, MD1522, MD1524, MD1525, MD -1526, MD1527, MD1528, MD1529, MD1530, MD1531, MD1532, MD1533, MD1534, MD1535, MD1536, MD1537, MD1538, MD1539, MD1540, and MD1541)," dated May 10, 2006

14. American Society of Mechanical Engineers (ASME), "Operation and Maintenance of Nuclear Power Plants (OM Code)," 2004 Edition, no Addenda 15 . Federal Register, Volume 73, Number 176, "10 CFR Part 50 - Industry Codes and Standards; Amended Requirements," dated September 10, 2008 Page 1 0 of 10

ATTACHMENT 2 CLINTON POWER STATION UNIT 1 Docket No. 50-461 License No . NPF-62 Markup of Proposed Technical Specifications Page Changes REVISED TS PAGE 5.0-11

Programs and Manuals 5 .5 5 .5 Programs and Manuals (continued) 5 .5 .5 Component Cyclic or Transient Limit This program provides controls to track the cyclic and transient occurrences identified on USAR Table 3 .9-1(b) to ensure that the reactor vessel is maintained within the design limits .

5 .5 .6 Inservice Testing Program This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 components  The program shall include the following :

Testin encies an applicable Ad en a as vs~cmc ASME e an app=Llable Addenda terminology for Required frequencies inservice testing for performing inservice C~~v~ 25 o~d activities testing activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days CoJe) Biennially or every 2 years At least once per 731 days ;

3 .0 .2 are applicable to the above or performing inservice testing

c. The provisions of SR 3 .0 .3 are applicable to inservice testing activities ; and CIVIJ Accdek G~.S c t. 2 v5 ~ ~' Ill W

ATTACHMENT 3 CLINTON POWER STATION UNIT 1 Docket No. 50-461 License No . NPF-62 Markup of Proposed Technical Specifications Bases Page Changes (Provided for information only)

REVISED TS BASES PAGES B 3 .4-22 B 3 .4-32 B 3.4-32a B 3.5-10 B 3.5-14a B 3.6-43 B 3.6-59

S/RVs B 3 .4 .4 BASES SURVEILLANCE SR 3 .4 .4 .3 (continued)

REQUIREMENTS

2. The sample population of S/RVs tested to satisfy SR 3 .4 .4 .1 will also be stroked in the relief mode during "as-found" testing to verify proper operation of the S/RV . The successful performance of the test sample of S/RVs provides reasonable assurance that the remaining installed S/RVs will perform in a similar fashion . After the S/RVs are replaced, the relief-mode actuator of the newly-installed S/RVs will be uncoupled from the S/RV stem, and cycled to ensure that no damage has occurred to the S/RV during transportation and installation . Following cycling, the relief-mode actuator is recoupled and the proper positioning of the stem nut is independently verified .

This verifies that each replaced S/RV will properly perform its intended function . If the valve fails to actuate due only to the failure of the solenoid but is capable of opening on overpressure, the safety function of the S/RV is considered OPERABLE .

The 24 month Frequency was developed based on the S/RV tests required by the ASME _-0116* aad Praee4Ne Yeeea3. Code,_

Qe- i- (Ref. ) . Operating experience has shown that these components usually pass the Surveillance . Therefore, the Frequency was concluded to be acceptable from a reliability standpoint .

REFERENCES 1. ASME, Boiler and Pressure Vessel Code,Section III aiad-

2. USAR, Section 5 .2 .2 .

3. USAR, Section 15 .

4. NEDC-32202P, "SRV Setpoint Tolerance and Out-of-Service Analysis for Clinton Power Station, "August 1993 ."

5. Calculation IP-0-0032 .

6 . ASME/ANSI OM-1987, Operation and Maintenance of Nuclear Power Plants, Part 1 .

Ani~_ t\, ~k4lfce.

CLINTON B 3 .4-22 Revision No . 10-7

RCS PIV Leakage B 3 .4 .6 BASES (continued)

SURVEILLANCE SR 3 .4 .6 .1 REQUIREMENTS Performance of leakage testing on each RCS PIV is required to verify that leakage is below the specified limit and to identify each leaking valve . The leakage limit of 0 .5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve . Leakage testing requires a stable pressure condition . For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves . If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement . In this situation, the protection provided by redundant valves would be lost .

The Frequency require r t ervice Testing Program is within the ASME Cod -&,a_wi+ ~ requency requirement and is based on the neeh"t6-perfos surveillance under the conditions that apply during an outage and the potential for an unplanned transient if the surveillance were performed with the reactor at power .

Therefore, this SR is modified by a Note that states the leakage Surveillance is not required to be performed in MODE 3 . Entry into MODE 3 is permitted for leakage testing at high differential pressures with stable conditions not possible in the lower MODES .

With regard to leakage values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref . 9) .

(continued)

CLINTON B 3 .4-32 Revision No . 11-6

RCS PIV Leakage B 3 .4 .6 BASES (continued)

REFERENCES l. 10 CFR 50 .2 .

2 . 10 CFR 50 .55a(c) .

3 . 10 CFR 50, Appendix A, GDC 55 .

5. NUREG-0677, "The Probability of Intersystem LOCA :

Impact Due to Leak Testing and Operational Changes,"

May 1980 .

6. CPS ISI Program Manual .

7. ASME Operations and Maintenance Code, Part 10, Inservice Testing of Valves in Light-Water Reactor Power Plants, 4 .2 .2 .3(b)(4) .

8. NEDC-31339, "BWR Owners Group Assessment of ECCS Pressurization in BWRs," November 1986 .

9 . Calculation IP-0-0034 .

CLINTON B 3 .4-32a Revision No . 4- 6

ECCS --Operating B 3 .5 .1 BASES SURVEILLANCE SR 3 .5 .1 .2 (continued)

REQUIREMENTS LPCI mode and not otherwise inoperable . This allows operation in the RHR shutdown cooling mode during MODE 3 if necessary .

SR 3 .5 .1 .3 Verification every 31 days that ADS accumulator supply pressure is >_ 140 psig assures adequate air pressure for reliable ADS operation . The accumulator on each ADS valve provides pneumatic pressure for valve actuation . The designed pneumatic supply pressure requirements for the accumulator are such that, following a failure of the pneumatic supply to the accumulator, at least two valve actuations can occur with the drywell at 70% of design pressure (Ref . 14) . The ECCS safety analysis assumes only one actuation to achieve the depressurization required for operation of the low pressure ECCS . This minimum required pressure of 140 psig is provided by the Instrument Air System . The 31 day Frequency takes into consideration administrative control over operation of the Instrument Air System and alarms for low air pressure .

With regard to ADS accumulator supply pressure values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is not considered to be a nominal value with respect to instrument uncertainties .

This requires additional margin to be added to the limit to compensate for instrument uncertainties, for implementation in the associated plant procedures (Ref . 16) .

SR 3 .5 .1 .4 The performance requirements of the ECCS pumps are determined through application of the 10 CFR 50, Appendix K, criteria (Ref . 8) . This periodic rve

., i~l1^an e is performed (in accordance with the ASME Cod f e. -- Y equirements for the ECCS pumps) to verify tha eECCS pumps will develop the flow rates required by the respective analyses .

The ECCS pump flow rates ensure that adequate core cooling is provided to satisfy the acceptance criteria of 10 CFR 50 .46 (Ref . 10) .

(continued)

CLINTON B 3 .5-10 Revision No . 4-6

ECCS--Operating B 3 .5 .1 BASES REFERENCES 1. USAR, Section 6 .3 .2 .2 .3 .

2. USAR, Section 6 .3 .2 .2 .4 .

3. USAR, Section 6 .3 .2 .2 .1 .

4. USAR, Section 6 .3 .2 .2 .2 .

5. USAR, Section 15 .2 .8 .

6. USAR, Section 15 .6 .4 .

7. USAR, Section 15 .6 .5 .

8. 10 CFR 50, Appendix K .

9. USAR, Section 6 .3 .3 .

10 . 10 CFR 50 .46 .

11 . USAR, Section 6 .3 .3 .3 .

12 . Memorandum from R .L . Baer (NRC) to V . Stello, Jr .

(NRC), "Recommended Interim Revisions to LCO's for ECCS Components," December 1, 1975 .

13 . USAR, Table 6 .3-8 .

14 . USAR, Section 7 .3 .1 .1 .1 .4 .

15 . NEDO-32291-A, "System Analyses for Elimination of Selected Response Time Testing Requirements," January 1994 .

16 . Calculation IP-0-0044 .

17 . Calculations O1HP09/10/11, IP-C-0042 .

18 . Calculations OlLP08/11/14, IP-C-0043 .

19 . Calculations O1RH19/20/23/24, IP-C-0041 .

20 . Calculation IP-0-0024 .

21 . ASME/ANSI OM-1987, Operation and Maintenance of Nuclear Power Plants, Part 1 .

CLINTON B 3 .5-14a Revision No . 7- 2

RHR Containment Spray System B 3 .6 .1 .7 BASES SURVEILLANCE SR 3 .6 .1 .7 .3 (continued)

REQUIREMENTS Therefore, the Frequency was concluded to be acceptable from a reliability standpoint .

SR 3 .6 .1 .7 .4 This Surveillance is performed following activites that could result in nozzle blockage to verify that the spray nozzles are not obstructed and that flow will be provided when required . Such activities may include a loss of foreign material control (of if it cannot be assured),

following a major configuration change, or following an inadvertent actuation of containment spray . This Surveillance is normally performed by an air or smoke flow test . The Frequency is adequate due to the passive nozzle design and its normally dry state and has been shown to be acceptable through operating experience .

REFERENCES 1. USAR, Section 6 .2 .1 .1 .5 .

CLINTON B 3 .6-43 Revision No . 10-7

RHR Suppression Pool Cooling B 3 .6 .2 .3 BASES SURVEILLANCE SR 3 .6 .2 .3 .2 REQUIREMENTS (continued) Verifying each RHR pump develops a flow rate ? 4550 gpm, with flow through the associated heat exchanger to the suppression pool, ensures that pump performance has not degraded during the cycle . Flow is a normal t~ of centrifugal pump performance required by ASME (Ref . 2) . This test confirms one point on thepump curve, and the results are indicative of overall performance . Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance . The Frequency of this SR is in accordance with the Inservice Testing Program .

With regard to RHR pump flow rate values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value with respect to instrument uncertainties . This requires additional margin to be added to the limit to compensate for instrument uncertainties for implementation in the associated plant procedures . (Ref . 4) .

REFERENCES 1. USAR, Section 6 .2 .

2.

3. USAR, Section 5 .4 .7 .

4. Calculations 01RH20/25 and IP-C-0041 .

CLINTON B 3 .6-59 Revision No . 6-4