ML15055A506

License Amendment Request - Proposed Changes to the Technical Specifications to Address Administrative Control of Secondary Containment Access Openings

ML15055A506
Person / Time
Site:	Peach Bottom
Issue date:	02/23/2015
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML15055A506 (24)

Text

Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 February 23, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

SUBJECT:

License Amendment Request Proposed Changes to the Technical Specifications to Address Administrative Control of Secondary Containment Access Openings Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon}, proposes changes to the Technical Specifications (TS}, Appendix A of Renewed Facility Operating License Nos.

DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS}, Units 2 and 3, respectively.

The proposed changes revise PBAPS TS Limiting Condition for Operation (LCO) 3.6.4.1, "Secondary Containment," Surveillance Requirement (SR) 3.6.4.1.1 and SR 3.6.4.1.2.

The LCO and SRs are modified to add a Note which allows the secondary containment boundary to be opened intermittently under administrative control. SR 3.6.4.1.2 is also modified to match NUREG-1434, "Standard Technical Specifications General Electric Plants, BWR/6," Revision 4 (Reference 3), to recognize that due to the PBAPS secondary containment design, brief, inadvertent, simultaneous opening of redundant secondary doors are an expected occurrence and do not render secondary containment inoperable.

Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92.

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

This amendment request contains no regulatory commitments. provides the evaluation of the proposed changes. Attachment 2 provides a copy of the marked up TS pages that reflect the proposed changes. Attachment 3 provides a copy of the marked up TS Bases pages that reflect the proposed changes (information only).

U.S. Nuclear Regulatory Commission License Amendment Request Secondary Containment Access Openings Docket Nos. 50-277 and 50-278 February 23, 2015 Page2 Exelon requests approval of the proposed amendment by February 23, 2016. Upon NRC approval, the amendment shall be implemented within 60 days of issuance.

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

paragraph (b), Exelon is notifying the Commonwealth of Pennsylvania of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Stephanie J.

Hanson at 610-765-5143.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd day of February 2015.

Respectfully, James Barstow Director, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes

2. Markup of Proposed Technical Specifications Pages

3. Markup of Proposed Technical Specifications Bases Pages (Information Only) cc: Regional Administrator - NRC Region I w/ attachments NRC Senior Resident Inspector - Peach Bottom Atomic Power Station "

NRC Project Manager, NRA - Peach Bottom Atomic Power Station "

Director, Bureau of Radiation Protection - Pennsylvania Department II of Environmental Protection II S. T. Gray, State of Maryland

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES License Amendment Request Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278

Subject:

Proposed Changes to the Technical Specifications to Address Administrative Control of Secondary Containment Openings 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedence 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

License Amendment Request Attachment 1 Secondary Containment Access Openings Page 1of9 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, respectively.

The proposed changes revise PBAPS TS Limiting Condition for Operation (LCO) 3.6.4.1, "Secondary Containment," Surveillance Requirement (SR) 3.6.4.1.1 and SR 3.6.4.1.2. The LCO and SRs are modified to add a Note which allows the secondary containment boundary to be opened intermittently under administrative control. SR 3.6.4.1.2 is also modified to match NUREG-1434, "Standard Technical Specifications General Electric Plants, BWR/6," Revision 4 (Reference 3), to recognize that due to the PBAPS secondary containment design, brief, inadvertent, simultaneous opening of redundant secondary doors are an expected occurrence and do not render secondary containment inoperable.

2.0 DETAILED DESCRIPTION The proposed changes address issues related to the secondary containment access openings.

The secondary containment is a single system that performs a safety function. There is no redundant train or system that can perform the secondary containment function should the secondary containment become inoperable. The Actions of TS 3.6.4.1 provide a 4-hour Completion Time to restore an inoperable secondary containment to an Operable status. As stated in the PBAPS TS Bases, "The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time provides a period of time to correct the problem that is commensurate with the importance of maintaining secondary containment during MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal."

The purpose of these proposed changes is two-fold. First, the addition of notes to LCO 3.6.4.1, SR 3.6.4.1.1 and SR 3.6.4.1.2 will allow for the flexibility to open secondary containment for very brief time periods under administrative control. Based on administrative control, the secondary containment breach would be able to be quickly closed in the unlikely event that a design basis event occurs. This is similar to allowances in the TS involving the Main Control Room Emergency Ventilation system and the Primary Containment Isolation Valves. Secondly, this proposed TS change would revise SR 3.6.4.1.2 to provide an allowance for brief, inadvertent, simultaneous openings of redundant secondary containment doors for normal passage. The original licensed design of the Peach Bottom Secondary Containment airlock system consists of inner and outer doors on the access points on each elevation, such that opening of any inner door on any elevation causes a blue light to be illuminated on every outer airlock door on all access point elevations as described in PBAPS Updated Final Safety Analysis Report (UFSAR)

Section 5.3.1.3 (Reference 1). The original approved UFSAR plant design does not prevent simultaneous openings through mechanical or electrical interlocks; therefore, occasional brief, simultaneous door openings are expected to occur and do not constitute a personnel error or equipment failure. Therefore, declaring secondary containment inoperable for these brief occurrences is not warranted. The change to the SR description would resolve this inconsistency.

License Amendment Request Attachment 1 Secondary Containment Access Openings Page 2 of 9 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes The following changes are proposed:

Proposed LCO 3.6.4.1 Note: The LCO requires the secondary containment to be Operable and the LCO Bases state, "For the secondary containment to be considered OPERABLE, it must have adequate leak tightness to ensure that the required vacuum can be established and maintained."

However, there are legitimate reasons to briefly open the secondary containment boundary, such as personnel or equipment access (e.g., scaffolding material). An LCO Note is proposed which allows the secondary containment boundary to be opened intermittently under administrative control. This Note will allow intermittent opening of a secondary containment barrier without declaring the secondary containment inoperable.

Proposed Notes for SR 3.6.4.1.1 and SR 3.6.4.1.2: SR 3.6.4.1.1 requires verification that all secondary containment equipment hatches are closed and sealed, and SR 3.6.4.1.2 requires verification that at least one door is closed in each secondary containment penetration. The intent of these requirements is to not breach secondary containment at any time when secondary containment is required. This is achieved by maintaining the inner or outer portion of the barrier closed at all times. All secondary containment access doors and hatches are normally kept closed, except when the access opening is being used for entry and exit or when maintenance is being performed on an access opening.

Similar to the proposed Note for LCO 3.6.4.1, the SRs are modified by proposed Notes which allow the secondary containment boundary doors and hatches to be opened intermittently under administrative control. These Notes only apply to openings in the secondary containment that can be rapidly restored to the design condition. These controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the opening and to restore the secondary containment boundary to a condition equivalent to the design condition when a need for secondary containment isolation is indicated. The ability to open secondary containment access openings under administrative control, even if it means the secondary containment boundary is temporarily not intact, is acceptable due to the low probability of an event that could pressurize the secondary containment during the short time in which the secondary containment is open and the presence of administrative controls to rapidly close the opening.

Proposed Revision to SR 3.6.4.1.2: The LAA also requests a revision to the wording of SR 3.6.4.1.2 to address brief, unintentional, simultaneous opening of both an inner and outer secondary containment access door. Opening both an inner and outer door in an access opening at the same time would result in a failure to meet PBAPS SR 3.6.4.1.2, which requires one access door in each access opening to be closed. This situation would require declaring the secondary containment inoperable, which involves administrative processing by licensed operators. The BWR/6 ISTS (NUREG-1434) SR 3.6.4.1.3 contains an exception for both doors in an access opening to be open simultaneously for normal entry and exit, but the PBAPS SR does not since it is a BWR/4 ISTS (NUREG-1433) plant (Reference 2). The proposed change adds the BWR/6 exception to the PBAPS SR.

Proposed Bases Revision: The current combined Bases for SR 3.6.4.1.1 and SR 3.6.4.1.2 are separated and the Bases of SR 3.6.4.1.2 are revised to be consistent with the proposed revised SR.

License Amendment Request Attachment 1 Secondary Containment Access Openings Page 3 of 9 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes

3.0 TECHNICAL EVALUATION

The secondary containment is a structure that completely encloses the primary containment and those components that may contain primary system fluid. It is possible for the secondary containment pressure to rise relative to the environmental pressure during design basis events.

To prevent ground level exfiltration of radioactive material while allowing the secondary containment to be designed as a conventional structure, the secondary containment requires support systems to maintain the control volume pressure at less than atmospheric pressure during design basis events. During normal operation, non-accident systems are used to maintain the secondary containment at a negative pressure. SR 3.6.4.1.3 requires verification that the secondary containment can be drawn down to be 2!: 0.25 inch of vacuum water gauge in s 180 seconds using one standby gas treatment (SGT) subsystem. SR 3.6.4.1.4 requires verification that the secondary containment can be maintained 2!: 0.25 inch of vacuum water gauge for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> using one SGT subsystem at a flow rates 10,500 cfm. Following an accident, the SGT System ensures the secondary containment pressure is less than the external atmospheric pressure.

The secondary containment boundary is the combination of walls, floor, roof, ducting, doors, hatches, penetrations and equipment that physically form the secondary containment. For penetrations that consist of a hatch, typically one hatch is provided. For penetrations that contain doors, there exists at least one inner and one outer door. In some cases, secondary containment access openings are shared such that there are multiple inner or outer doors. All secondary containment access doors are normally kept closed, except when the access opening is being used for entry and exit of personnel or equipment.

The safety function of the secondary containment is to contain, dilute, and hold up fission products that may leak from primary containment following a Design Basis Accident (OBA) to ensure the control room operator and offsite doses are within the regulatory and NRC-approved limits. In conjunction with operation of the SGT System and closure of certain valves whose lines penetrate the secondary containment, the secondary containment is designed to contain the fission products that bypass or leak from primary containment, or are released from the reactor coolant pressure boundary components located in secondary containment prior to release to the environment. For the secondary containment to be considered Operable, it must have adequate leak tightness to ensure that the required vacuum can be established and maintained by a single SGT subsystem, when that system is in operation.

The secondary containment and the SGT System together ensure radioactive material is processed. As long as a SGT subsystem can draw and maintain the required vacuum on the secondary containment when needed (as demonstrated by SR 3.6.4.1.3 and SR 3.6.4.1.4), the secondary containment can perform its safety function.

In these and similar cases, the secondary containment remains capable of processing fission products that may leak from primary containment following a OBA, which will ensure the control room operator and offsite doses are within the regulatory and NRC-approved limits.

PBAPS has adopted alternative source term (AST) in accordance with 1O CFR 50.67 and using the methodology described in NRC Regulatory Guide 1.183. This resulted in revising the PBAPS SR 3.6.4.1.3 allowing a 180-second draw down time to ensure the secondary containment is ~ 0.25 inches of water vacuum. Because the typical draw down time using

License Amendment Request Attachment 1 Secondary Containment Access Openings Page 4 of 9 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes one SGT subsystem is well under 60 seconds, substantial margin exists to ensure that the secondary containment can be re-established during brief simultaneous opening of secondary containment redundant barriers or can be quickly re-established under administrative control for other planned breaches of secondary containment.

The following changes are proposed which will allow the secondary containment to be Operable during brief, controlled circumstances which currently would require declaring the secondary containment inoperable.

Proposed LCO 3.6.4.1 Note LCO 3.6.4.1 requires the secondary containment to be Operable and the LCO Bases state, "For the secondary containment to be considered OPERABLE, it must have adequate leak tightness to ensure that the required vacuum can be established and maintained." However, there are sometimes reasons to open the secondary containment boundary, such as personnel or equipment access (e.g., scaffolding material). An LCO Note is proposed which allows the secondary containment boundary to be opened intermittently under administrative control.

The allowance to open a barrier under administrative control appears in other locations within the PBAPS TS, such as the control room boundary and primary containment isolation valves. The administrative controls ensure the opening will be promptly closed if required. Consistent with the existing allowances, the acceptable administrative controls are described in the Bases in a manner similar to the control room boundary and primary containment isolation valve administrative control allowances.

The proposed Bases state:

The LCO is modified by a Note which allows the secondary containment boundary to be opened intermittently under administrative control. The secondary containment boundary is the combination of walls, floor, roof, ducting, doors, hatches, penetrations and equipment that physically form the secondary containment. This Note only applies to openings in the secondary containment that can be rapidly restored to the design condition. These controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the opening and to restore the secondary containment boundary to a condition equivalent to the design condition when a need for secondary containment isolation is indicated. The ability to open secondary containment access openings under administrative control, even if it means the secondary containment boundary is temporarily not intact, is acceptable due to the low probability of an event that could require the secondary containment during the short time in which the secondary containment is open and the presence of administrative controls to rapidly close the opening.

The ability to open secondary containment access openings under administrative control, even if it means the secondary containment boundary is temporarily not intact, is acceptable due to the low probability of an event that requires secondary containment during the short time in which the secondary containment is open and the presence of administrative controls to rapidly close the opening. The risk to the public from this allowance is less than the risk associated with the

License Amendment Request Attachment 1 Secondary Containment Access Openings Page 5 of 9 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes current 4-hour Completion Time to restore an inoperable secondary containment, because the LCO Note requires administrative controls to be able to rapidly (i.e. manual action can be performed to ensure access opening can be closed immediately such that SR 3.6.4.1.3 requirements can be met) restore the secondary containment to Operable status.

Proposed Notes for SR 3.6.4.1.1 and SR 3.6.4.1.2 SR 3.6.4.1.1 requires verification that all secondary containment equipment hatches are closed and sealed, and SR 3.6.4.1.2 requires verification that at least one door is closed in each secondary containment penetration. The intent of these requirements is to not breach secondary containment at any time when secondary containment is required. This is achieved by maintaining the inner or outer portion of the barrier closed at all times. All secondary containment access doors and hatches are normally kept closed, except when the access opening is being used for entry and exit or when maintenance is being performed on an access opening.

The ability to open secondary containment access openings under administrative control, even if it means the secondary containment boundary is temporarily not intact, is acceptable due to the low probability of an event that requires secondary containment during the short time in which the secondary containment is open and the presence of administrative controls to rapidly close the opening.

Proposed PBAPS SR 3.6.4.1.2 Revision The PBAPS SR 3.6.4.1.2 is proposed to be revised to be consistent with the similar BWR/6 (NUREG-1434) SR 3.6.4.1.3. The text in italics, below, is added.

Verify one secondary containment access door in each access opening is closed, except when the access opening is being used for entry or exit.

The BWR/6 ISTS (NUREG-1434) SR 3.6.4.1.3 contains an exception for both doors in an access opening being opened simultaneously for normal entry and exit, but the current PBAPS SR does not. This allowance is reasonable because the doors will be promptly closed following entry or exit, restoring the secondary containment boundary.

Personnel are trained in Nuclear General Employee Training (NGET) to not open a secondary containment door if the blue light is illuminated. However, as licensed by the NRC, there is no physical interlock associated with these doors. Proceeding through a door requires an individual to look up at the condition of the blue light, then card in/out (if applicable), re-look at the status of the blue light and then look down again and proceed to open the door. Occasionally, an individual attempts access through the opposite airlock entry point, and an alarm sounds due to a simultaneous door opening by another individual. Well-intended individuals often end up in this simultaneous situation, which cannot be prevented under the original licensed design. From a safety perspective (see UFSAR Table 8.5.1), during a design basis accident (LOCA with simultaneous LOOP), Emergency Diesel Generators start and restore 4 kV Bus power in 13 seconds after the event, followed by 480 V Load Center restoration 3 seconds later, such that SGT start will occur no earlier than 16 seconds after initiation of the event. In addition, no credit is taken for any negative pressure in the building at the time of the event. The AST analysis assumptions are such that no credit is taken for secondary containment for the first 180 seconds

License Amendment Request Attachment 1 Secondary Containment Access Openings Page 6 of 9 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes following a Design Basis LOCA or fuel handling accidents. Based on the original licensed design of the Peach Bottom Secondary Containment and the allowances of AST, it can be concluded that brief simultaneous opening of an inner and outer secondary containment blue light door is expected in the PBAPS secondary design and therefore, a declaration of inoperability is not warranted.

Proposed Bases Revisions The current combined Bases for PBAPS SR 3.6.4.1.1 and SR 3.6.4.1.2 are separated and the Bases of SR 3.6.4.1.2 are revised to be consistent with the proposed revised SR.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The following regulatory requirements have been considered:

• Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, "Technical specifications," in which the Commission established its regulatory requirements related to the contents of the TS. Specifically, 10 CFR 50.36(c)(2) states, in part, "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility." 10 CFR 50.36(c)(3) states, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met."

The proposed changes to the secondary containment LCO and SRs do not affect compliance with these regulations.

The applicable 1O CFR Part 50, Appendix A, General Design Criteria, was considered as follows:

• Criterion 41-Containment atmosphere cleanup. Systems to control fission products, hydrogen, oxygen, and other substances which may be released into the reactor containment shall be provided as necessary to reduce, consistent with the functioning of other associated systems, the concentration and quality of fission products released to the environment following postulated accidents, and to control the concentration of hydrogen or oxygen and other substances in the containment atmosphere following postulated accidents to assure that containment integrity is maintained.

Each system shall have suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) its safety function can be accomplished, assuming a single failure.

License Amendment Request Attachment 1 Secondary Containment Access Openings Page 7 of 9 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes The proposed changes do not alter the design of the secondary containment or its ability to establish an essentially leak-tight barrier against the uncontrolled release of radioactivity.

4.2 Precedence The proposed change to modify SR 3.6.4.1.2 to allow brief, inadvertent, simultaneous opening of redundant secondary containment doors under administrative control is consistent with the improved Standard Technical Specifications endorsed by the NRC in NUREG-1434, Standard Technical Specifications - General Electric BWR/6 Plants, Revision 4 (Reference 3). Additionally, Exelon has submitted a similar LAA for Limerick Generating Station on February 2, 2015.

4.3 No Significant Hazards Consideration Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, respectively.

The proposed changes revise PBAPS TS Limiting Condition for Operation (LCO) 3.6.4.1, "Secondary Containment," Surveillance Requirement (SR) 3.6.4.1.1 and SR 3.6.4.1.2.

The LCO and SRs are modified to add a Note which allows the secondary containment boundary to be opened intermittently under administrative control. SR 3.6.4.1.2 is also modified to match the standard improved TS for BWR/6 plants (NUREG-1434) to recognize that due to the PBAPS secondary containment design, brief, inadvertent, simultaneous opening of redundant secondary containment doors are an expected occurrence and do not render secondary containment inoperable.

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

1. Do the proposed changes involve a significant increase In the probability or consequences of an accident previously evaluated?

Response: No. The proposed changes allow temporary conditions during which the secondary containment LCO and certain SRs are not met. The secondary containment is not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not increased. The consequences of an accident previously evaluated while utilizing the proposed changes are no different than the consequences of an accident while utilizing the existing 4-hour Completion Time for an inoperable secondary containment. As a result, the consequences of an accident previously evaluated are not significantly increased.

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

License Amendment Request Attachment 1 Secondary Containment Access Openings Page 8 of 9 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes

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

Response: No. The proposed changes do not alter the protection system design, create new failure modes, or change any modes of operation. The proposed changes do not involve a physical alteration of the plant; and no new or different kind of equipment will be installed. Consequently, there are no new initiators that could result in a new or different kind of accident.

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

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No. The proposed changes allow temporary conditions during which the secondary containment LCO and certain SRs are not met. Temporary conditions in which the secondary containment is open is acceptable provided the conditions do not affect the ability of the Standby Gas Treatment System to create a lower pressure in the secondary containment than in the outside environment if required. This condition is incorporated in the proposed changes by requiring the condition to be under administrative control such that the conditions equivalent to the design condition can be quickly restored should secondary containment vacuum be required. Therefore, the safety function of the secondary containment is not affected. The allowance for both an inner and outer secondary containment door to be open simultaneously for entry and exit does not affect the safety function of the secondary containment as the doors are promptly closed after entry or exit, thereby restoring the secondary containment boundary. The ability to open secondary containment access openings under administrative control, even if it means the secondary containment boundary is temporarily not intact, is acceptable due to the low probability of an event that requires secondary containment during the short time in which the secondary containment is open and the presence of administrative controls to rapidly close the opening.

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

Based on the above, Exelon 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

License Amendment Request Attachment 1 Secondary Containment Access Openings Page 9 of 9 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 1O CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 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. Peach Bottom Atomic Power Station, Updated Final Safety Analysis Report, Revision 24.

2. NUREG-1433, "Standard Technical Specifications General Electric Plants, BWR/4," Revision 4.

3. NUREG-1434, "Standard Technical Specifications General Electric Plants, BWR/6," Revision 4.

ATTACHMENT2 Markup of Proposed Technical Specifications Pages License Amendment Request Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278 Proposed Changes to the Technical Specifications to Address Administrative Control of Secondary Containment Openings Unit 2 TS Pages 3.6-34 3.6-35 Unit 3 TS Pages 3.6-34 3.6-35

SE:iconcli.1 ry Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 APPLICABILITY:

During movement of RECENTLY IRRADIATED FUEL assemblies in the secondary containment, During operations with a potential for draining the reactor vessel ( OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Secondary containment A.l Restore secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> inoperable in MODE 1, containment to 2, or 3. OPERABLE status.

B. Required Action and B.l Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A not met.

C. Secondary containment C.l - - - - - - - - NOTE - - - - - - - - -

inoperable during LCO 3.0.3 is not movement of RECENTLY applicable.

IRRADIATED FUEL assemblies in the secondary containment Suspend movement of Immediately or during OPDRVs. RECENTLY IRRADIATED FUEL assemblies in the secondary containment.

(continued)

PBAPS UN IT 2 3.6-34 Amendment No. 269

Secon(1a ry Containment 3.6.4.1 ACTIONS COND[TION kF::OUIRFD ACTION COMPLETION TIME C. (continued) C.2 Initiate action to Immediately suspend OIJDRVs.

SURVEILLANCE REQUIREMENTS SU RV EI L.LANCE FREQUENCY SR 3.6.4.1.1 Verify all secondary containment In accordance equipment hatches are closed and sealed. with the Surveillance Frequency Control Program.

SR 3.6.4.1.2 Verify one secon ary containment access In accordance door in each access opening is clos with the Surveillance Frequency Control Program.

SR 3.6.4.1.3 Verify secondary containment can be drawn In accordance down to ~ 0.25 inch of vacuum water gauge with the in ~ 180 seconds using one standby gas Surveillance treatment (SGT) subsystem. Frequency Control Program.

SR 3.6.4.1.4 Verify the secondary containment can be In accordance maintained ~ 0.25 inch of vacuum water with the gauge for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> using one SGT subsystem Surveillance at a flow rate~ 10,500 cfm. Frequency Control Program.

PBAPS UN IT 2 3.6-35 Amendment No. 278

Secondary Containment 3.6.4.1 3.6 CONfAINMENT SYSTEMS

• \. 6. 4. J Sec on cl a ry Containment LCO 3.6.4.1 AF1 Pl.ICAB I LITY:

During movement of RECENTLY IRRADIATED FUEL assemblies in the secondary containment, During operations with a potential for draining the reactor vessel ( OPDRVs J.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Secondary containment A. 1 Restore secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> inoperable in MODE 1, containment to 2, or 3. OPERABLE status.

B. Required Action and B.l Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A not met.

C. Secondary containment C.l --------NOTE---------

inoperable during LCO 3.0.3 is not movement of RECENTLY applicable.

IRRADIATED FUEL assemblies in the secondary containment Suspend movement of Immediately or during OPDRVs. RECENTLY IRRADIATED FUEL assemblies in the secondary containment.

(continued)

PBAPS UN IT 3 3.6-34 Amendment No. 273

Secondary Containment

3. 6. 4. 1 f\CTTONS CONDI I ION R[ QU11\ ED AC TI 0 N COMPLETION TIME C. (continued) C.2 Initiate action to Immediately suspend OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify all secondary containment In accordance equipment hatches are closed and sealed. with the Surveillance Frequency Control Program.

SR 3.6.4.1.2 Verify one secondary containment access In accordance door in each access opening is closed with the Surveillance Frequency Control Program.

SR 3.6.4.1.3 Verify secondary containment can be drawn In accordance down to ~ 0.25 inch of vacuum water gauge with the in s 180 seconds using one standby gas Surveillance treatment (SGT) subsystem. Frequency Control Program.

SR 3.6.4.1.4 Verify the secondary containment can be In accordance maintained~ 0.25 inch of vacuum water with the gauge for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> using one SGT subsystem Surveillance at a flow rates 10,500 cfm. Frequency Control Program.

PBAPS UN IT 3 3.6-35 Amendment No. 281

ATTACHMENT3 Markup of Proposed Technical S'{)ciflcations Bases Pages (information nly)

License Amendment Request Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278 Proposed Changes to the Technical Specifications to Address Administrative Control of Secondary Containment Openings Unit 2 TS Bases Page B 3.6-74 B 3.6-76 Unit 3 TS Bases Page B 3.6-74 B 3.6-76

Secondary Containment f3 :~.6.4.1 flASES APPUCAl3U: however, its leak tightness is required to ensure that fission SAFETY ANALYSES products entrapped within the secondary containment structure (continued) will be treated by the SGT System prior to discharge to the environment.

Secondary containment satisfies Criterion 3 of the NRC Policy Statement.

LCO An OPFRABlE secondary containment provides a control volume into which fission products that leak from primary containment, or are released from the reactor coolant pressure boundary components located in secondary containment, can be processed prior to release to the environment. For the secondary containment to be considered OPERABLE, it must have adequate leak tightness to ensure that the required vacuum can be established and maintained.

APPLICABILITY In MODES 1, 2, and 3, a LOCA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, secondary containment OPERABILITY is required during the same operating conditions that require primary containment OPERABILITY.

In MODES 4 and 5, the probability and consequences of the LOCA are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining secondary containment OPERABLE is not required in MODE 4 or 5, except for other situations for which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs), or during movement of RECENTLY IRRADIATED FUEL assemblies in the secondary containment. However, outside ground level hatches (hatches H15 through H19 and Torus room access hatch H33) may not be opened during movement of irradiated fuel. This will maintain CR doses acceptable.

ACTIONS If secondary containment is inoperable, it must be restored to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time provides a period of time to correct the problem that is commensurate with the importance of maintaining secondary containment during MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.

continued PBAPS UN IT 2 B 3.6-74 Revision No. 75

')pcondc1 r,y Containment B '.l, 6 . 4. J BASES (continued)

• --*----*---*-------------*-* - - - -

SURVFILLANCF REQUIREMENTS Verifying Lhat secondary containment equipment hatcJ1es ":l'HB are closed ensures that the infiltration of outside air of such a magnitude as to prevent maintaining the desired negative pressure does not adequate assurance that exfi tration from the dary containment will not occur. In this application, the term "sealed" has no connotation of leak tightness.

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SR 3.6.4.1.3 and SR 3.6.4.1.4 The SGT System exhausts the secondary containment atmosphere to the environment through appropriate treatment equipment.

Each SGT subsystem is designed to draw down pressure in the secondary containment to ~ 0.25 inches of vacuum water gauge in ~ 180 seconds and maintain pressure in the secondary containment at ~ 0.25 inches of vacuum water gauge for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at a flow rate~ 10,500 cfm. To ensure that all fission products released to the secondary containment are treated, SR 3.6.4.1.3 and SR 3.6.4.1.4 verify that a pressure in the secondary containment that is less than the lowest postulated pressure external to the secondary containment boundary can rapidly be established and maintained. When the SGT System is operating as designed, the establishment and maintenance of secondary containment pressure cannot be accomplished if the secondary containment boundary is not intact.

Establishment of this pressure is confirmed by SR 3.6.4.1.3 which demonstrates that the secondary containment can be drawn down to ~ 0.25 inches of vacuum water gauge in ~ 180 continued PBAPS UN IT 2 B 3.6-76 Revision No. 86

Secondary Containment B 3.6.4.1 BASES APPLICABLE however, its leak tightness is required to ensure that fission SAFETY ANALYSES products entrapped within the secondary containment structure (continued) will be treated by the SGT System prior to discharge to the environment.

Secondary containment satisfies Criterion 3 of the NRC Policy Statement.

LCO An OPERABLE secondary containment provides a control volume into which fission products that leak from primary containment, or are released from the reactor coolant pressure boundary components located in secondary containment, can be processed prior to release to the environment. For the secondary containment to be considered OPERABLE, it must have adequate leak tightness to ensure Insert Note 1 t._hat the required vacuum can be established and maintained .

.-------;:?'=---

here APPLICABILITY In MODES 1, 2, and 3, a LOCA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, secondary containment OPERABILITY is required during the same operating conditions that require primary containment OPERABILITY.

In MODES 4 and 5, the probability and consequences of the LOCA are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining secondary containment OPERABLE is not required in MODE 4 or 5, except for other situations for which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs), or during movement of RECENTLY IRRADIATED FUEL assemblies in the secondary containment. However, outside ground level hatches (hatches H20 through H24 and Torus room access hatch H34) may not be opened during movement of irradiated fuel. This will maintain CR dose acceptable.

ACTIONS If secondary containment is inoperable, it must be restored to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time provides a period of time to correct the problem that is commensurate with the importance of maintaining secondary containment during MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.

ontinued PBAPS UN IT 3 B 3.6-74 Revision No. 76

Secon<Jary Con ta i nrnent

[~ '.L 6 .4. I BASLS (continued)

SlJ r~ VL I LL_A NC E RL.QLJ J F\EM [NTS Verifying that secondary containment equipment hatches -atffl

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-a-GE-e*s*s--open-ing-.- The Survei 11 ance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.4.1.3 and SR 3.6.4.1.4 The SGT System exhausts the secondary containment atmosphere to the environment through appropriate treatment equipment.

Each SGT subsystem is designed to draw down pressure in the secondary containment to ~ 0.25 inches of vacuum water gauge in ~ 180 seconds and maintain pressure in the secondary containment at~ 0.25 inches of vacuum water gauge for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at a flow rate~ 10,500 cfm. To ensure that all fission products released to the secondary containment are treated, SR 3.6.4.1.3 and SR 3.6.4.1.4 verify that a pressure in the secondary containment this is less than the lowest postulated pressure external to the secondary containment boundary can rapidly be established and maintained. When the SGT System is operating as designed, the establishment and maintenance of secondary containment pressure cannot be accomplished if the secondary containment boundary is not intact.

Establishment of this pressure is confirmed by SR 3.6.4.1.3 which demonstrates that the secondary containment can be drawn down to~ 0.25 inches of vacuum water gauge in~ 180 continued PBAPS UN IT 3 B 3.6-76 Revision No. 87

License Amendment Request Secondary Containment Access Openings Docket Nos. 50-277 and 50-278 PBAPS Unit 2 and Unit 3 TSB Insertions Note 1.:

The LCO is modified by a Note which allows the secondary containment boundary to be opened intermittently under administrative control. The secondary containment boundary is the combination of walls, floor, root ducting, doors, hatches, penetrations and equipment that physically form the secondary containment. This Note only applies to openings in the secondary containment that can be rapidly (i.e., manual action can be performed to ensure access opening can be closed immediately such that SR 3.6.4.1.3 requirements can be met) restored to the design condition. These controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the opening and to restore the secondary containment boundary to a condition equivalent to the design condition when a need for secondary containment isolation is indicated. The ability to open secondary containment access openings under administrative control, even if it means the secondary containment boundary is temporarily not intact, is acceptable due to the low probability of an event that would require the secondary containment during the short time in which the secondary containment is open and the presence of administrative controls to rapidly close the opening.

Note2:

SR 3.6.4.1.1 Similar to the NOTE for LCO 3.6.4.1, the SR is modified by a Note which allows the secondary containment equipment hatches to be opened intermittently under administrative control. This Note only applies to openings in the secondary containment that can be rapidly (i.e., manual action can be performed to ensure access opening can be closed immediately such that SR 3.6.4.1.3 requirements can be met) restored to the design condition. These controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the opening and to restore the secondary containment boundary to a condition equivalent to the design condition when a need for secondary containment isolation is indicated. The ability to open secondary containment access openings under administrative control, even if it means the secondary containment boundary is temporarily not intact, is acceptable due to the low probability of an event that could require the secondary containment during the short time in which the secondary containment is open and the presence of administrative controls to rapidly close the opening.

Note3:

SR 3.6.4.1.2 Verifying that one secondary containment access door in each access opening is closed provides adequate assurance that exfiltration from the secondary containment will not occur. An access opening

License Amendment Request Secondary Containment Access Openings Docket Nos. 50-277 and 50-278 PBAPS Unit 2 and Unit 3 TSB Insertions contains at least one inner and one outer door. In some coses, secondary containment access openings ore shored such that there ore multiple inner or outer doors. The intent is to not breach the secondary containment, which is achieved by maintaining the inner or outer portion of the barrier closed except when the access opening is being used for entry and exit.

Similar to the NOTE for LCO 3.6.4.1, the SR is modified by a NOTE which allows the secondary containment boundary doors and hatches to be opened intermittently under administrative control. This Note only applies to openings in the secondary containment that con be rapidly (i.e., manual action con be performed to ensure access opening can be closed immediately such that SR 3.6.4.1.3 requirements con be met) restored to the design condition. These controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the opening and to restore the secondary containment boundary to a condition equivalent to the design condition when a need for secondary containment isolation is indicated. The ability to open secondary containment access openings under administrative control, even if it means the secondary containment boundary is temporarily not intact, is acceptable due to the low probability of on event that could require the secondary containment during the short time in which the secondary containment is open and the presence of administrative controls to rapidly close the opening.

Personnel ore trained not to open a secondary containment door if the blue light is illuminated.

Individuals ore instructed to immediately close the door if it alarms. A main control room alarm is provided if the Airlock seal is broken for 10 seconds. From a safety perspective (see UFSAR Table 8.5.1),

during a design basis accident {LOCA with simultaneous LOOP), Emergency Diesel Generators start and restore 4 kV Bus power in 13 seconds after the event, followed by 480 V Load Center restoration 3 seconds later, such that SBGTS start will occur no earlier than 16 seconds after initiation of the event. In addition, no credit is taken for any negative pressure in the building at the time of the event. The Alternate Source Term {AST) analysis assumptions ore such that no credit is taken for secondary containment for the first 180 seconds following a Design Basis LOCA. Therefore, based on the original licensed design of the Peach Bottom Secondary Containment and the allowances of Alternate Source Term, it can be concluded that brief simultaneous opening of an inner and outer secondary containment blue light door is expected in the PBAPS secondary design.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.