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{{#Wiki_filter:Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348 August 7, 2008 www.exeloncorp.com Nuclear 10 CFR 50.90 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.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  
{{#Wiki_filter:Exelon Nuclear                   www.exeloncorp.com 200 Exelon Way                                                                         Nuclear Kennett Square, PA 19348 10 CFR 50.90 August 7, 2008 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 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:==
==Subject:==
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Pursuant to 10 CFR 50.90, Exelon Generation Company, LLC (EGC)hereby requests proposed changes to incorporate various previously NRC-approved Technical Specification Task Force travelers (TSTFs)and other administrative changes.A listing of the proposed TSTFs and other administrative changes is contained in Attachment 1.The proposed changes have been reviewed by the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.EGC requests approval of the proposed amendment by August 7, 2009.Once approved, the amendment shall be implemented within 60 days.No additional regulatory commitments are contained in this request.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Pursuant to 10 CFR 50.90, Exelon Generation Company, LLC (EGC) hereby requests proposed changes to incorporate various previously NRC-approved Technical Specification Task Force travelers (TSTFs) and other administrative changes. A listing of the proposed TSTFs and other administrative changes is contained in Attachment 1.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes August7,2008 Page 2 In accordance with 10 CFR 50.91, EGC is notifying the State of Pennsylvania of this application for changes to the TS and Operating Licenses by transmitting a copy of this letter and its attachments to the designated state official.Should you have any questions concerning this letter, please contact Tom Loomis at (610)765-5510.I declare under penalty of perjury that the foregoing is true and correct.Executed on the i h of August 2008.Respectfully, Director, Licensing&Regulatory Affairs Exelon Generation Company, LLC Attachments:
The proposed changes have been reviewed by the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.
1)Evaluation of Proposed Changes 2)Markup of Proposed Technical Specifications Page Changes 3)Markup of Proposed Technical Specifications Bases Page Changes cc: S.J.Collins, Administrator, Region I, USNRC F.Bower, USNRC Senior Resident Inspector, PBAPS J.Hughey,ProjectManager, USNRCR.R.Janati, Commonwealth of Pennsylvania S.T.Gray, State of Maryland ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 EVALUATION OF PROPOSED CHANGES ATTACHMENT 1 CONTENTS  
EGC requests approval of the proposed amendment by August 7, 2009. Once approved, the amendment shall be implemented within 60 days.
No additional regulatory commitments are contained in this request.
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes August7,2008 Page 2 In accordance with 10 CFR 50.91, EGC is notifying the State of Pennsylvania of this application for changes to the TS and Operating Licenses by transmitting a copy of this letter and its attachments to the designated state official.
Should you have any questions concerning this letter, please contact Tom Loomis at (610) 765- 5510.
h I declare under penalty of perjury that the foregoing is true and correct. Executed on the i   of August 2008.
Respectfully,
~1lf1 Director, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Evaluation of Proposed Changes
: 2) Markup of Proposed Technical Specifications Page Changes
: 3) Markup of Proposed Technical Specifications Bases Page Changes cc:     S. J. Collins, Administrator, Region I, USNRC F. Bower, USNRC Senior Resident Inspector, PBAPS J. Hughey, Project Manager, USNRC R. R. Janati, Commonwealth of Pennsylvania S. T. Gray, State of Maryland
 
ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 EVALUATION OF PROPOSED CHANGES
 
ATTACHMENT 1 CONTENTS


==Subject:==
==Subject:==
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes 1.0  
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes 1.0  


==SUMMARY==
==SUMMARY==
DESCRIPTION 2.0 DETAILED DESCRIPTION, TECHNICAL EVALUATION, REGULATORY EVALUATION, CONCLUSIONS 2.1 TSTF-363-A, Rev.0-Revise Topical Report references in ITS 5.6.5, COLR 2.2 TSTF-400-A, Revision1-Clarify SR on Bypass of DG Automatic Trips 2.3 TSTF-439-A, Revision2-Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO 2.4 TSTF-485-A, Rev.0-Correct Example 1.4-1 2.5 Administrative Changes-Removal of Obsolete Note for Technical Specification Table 3.3.8.1-1 (PBAPS, Units 2 and 3)and Correction to Table 3.3.3.1-1 (PBAPS, Unit 2)2.6 Clarification of Allowable Value on Technical Specification Table 3.3.1.1-1 3.0 ENVIRONMENTAL CONSIDERATION
DESCRIPTION 2.0   DETAILED DESCRIPTION, TECHNICAL EVALUATION, REGULATORY EVALUATION, CONCLUSIONS 2.1     TSTF-363-A, Rev. 0 - Revise Topical Report references in ITS 5.6.5, COLR 2.2     TSTF-400-A, Revision 1 - Clarify SR on Bypass of DG Automatic Trips 2.3     TSTF-439-A, Revision 2 - Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO 2.4     TSTF-485-A, Rev. 0 - Correct Example 1.4-1 2.5     Administrative Changes - Removal of Obsolete Note for Technical Specification Table 3.3.8.1-1 (PBAPS, Units 2 and 3) and Correction to Table 3.3.3.1-1 (PBAPS, Unit 2) 2.6     Clarification of Allowable Value on Technical Specification Table 3.3.1.1-1
 
==3.0   ENVIRONMENTAL CONSIDERATION==


==4.0 REFERENCES==
==4.0   REFERENCES==


License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes 1.0  
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                         Attachment 1 Technical Specifications Changes                                                     Page 1 of 23 1.0    


==SUMMARY==
==SUMMARY==
DESCRIPTION Attachment 1 Page 1 of 23 This evaluation supports a request to amend Renewed Facility Operating Licenses DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.The proposed changes would revise the Operating Licenses to incorporate certain TSTFs that have been previously reviewed and approved by the NRC and make other administrative revisions.
DESCRIPTION This evaluation supports a request to amend Renewed Facility Operating Licenses DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.
These TSTFs and administrative changes were selected, in part, based on their simplicity of review and ease of implementation.
The proposed changes would revise the Operating Licenses to incorporate certain TSTFs that have been previously reviewed and approved by the NRC and make other administrative revisions. These TSTFs and administrative changes were selected, in part, based on their simplicity of review and ease of implementation.
The TSTFs and administrative changes are grouped into six (6)individual analyses as provided in Sections 2.1 through 2.6 of this submittal.
The TSTFs and administrative changes are grouped into six (6) individual analyses as provided in Sections 2.1 through 2.6 of this submittal. Each analysis provides a detailed description, technical evaluation, regulatory evaluation, and conclusions. Bases pages are also provided in this submittal for your information only.
Each analysis provides a detailed description, technical evaluation, regulatory evaluation, and conclusions.
 
Bases pages are also provided in this submittal for your information only.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                           Attachment 1 Technical Specifications Changes                                                       Page 2 of 23 2.0     DETAILED DESCRIPTION, TECHNICAL EVALUATION, REGULATORY EVALUATION, CONCLUSIONS 2.1     TSTF-363-A, Revision 0 - Revise Topical Report references in ITS 5.6.5, COLR Detailed
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes 2.0 DETAILED DESCRIPTION, TECHNICAL EVALUATION, REGULATORY EVALUATION, CONCLUSIONS Attachment 1 Page 2 of 23 2.1 TSTF-363-A, Revision0-Revise Topical Report references in ITS 5.6.5, COLR Detailed


== Description:==
== Description:==


TSTF-363-A, Revision 0 modifies Improved Technical Specifications (NUREG-1433)
TSTF-363-A, Revision 0 modifies Improved Technical Specifications (NUREG-1433) Section 5.6.5 to remove the requirements to identify Core Operating Limits Report (COLR) Topical Report(s) by number, title, and date. The complete citation is added to the COLR for each Topical Report, including the report number, title, revision, date, and any supplements.
Section 5.6.5 to remove the requirements to identify Core Operating LimitsReport(COLR)
See the markup of pages for PBAPS, Units 2 and 3 included in Attachment 2.
Topical Report(s)by number, title, and date.The complete citation is added to the COLR for each Topical Report, including the report number, title, revision, date, and any supplements.
Unit Applicability List of Affected Pages Unit 2         Unit 3 5.0-21                         X             X 5.0-22                         X             X Technical Evaluation:
See the markup of pages for PBAPS, Units 2 and 3 included in Attachment 2.List of Affected Pages Unit Applicability Unit 2 Unit 3 5.0-21 X X 5.0-22 X X Technical Evaluation:
Exelon Generation Company, LLC (EGC) proposes to revise PBAPS Technical Specification Section 5.6.5 to remove the requirement to maintain COLR Topical Report references by number, title, date, and NRC staff approval document, if currently included. This TSTF will permit referencing the topical report by number and title. The additional details will be controlled within the COLR and will be subject to 10 CFR 50.59 for any changes. The details of the Topical Report references are an unwarranted regulatory burden and are acceptably maintained in the COLR. As discussed in TSTF-363, this method of referencing topical reports would allow licensees to use current topical reports to support limits in the COLR without having to submit an amendment to the facility operating license every time the topical report is revised.
Exelon Generation Company, LLC (EGC)proposes to revise PBAPS Technical Specification Section 5.6.5 to remove the requirement to maintain COLR Topical Report references by number, title, date, and NRC staff approval document, if currently included.This TSTF will permit referencing the topical report by number and title.The additional details will be controlled within the COLR and will be subject to 10 CFR 50.59 for any changes.The details of the Topical Reportreferencesare an unwarranted regulatory burden and are acceptably maintained in the COLR.As discussed in TSTF-363, this method of referencing topical reports would allow licensees to use current topical reports to support limits in the COLR without having to submit an amendment to thefacilityoperating license every time the topical report is revised.The COLR would provide specific information identifying the particular approved topical reports used to determine the core limits for the particular cycle in the COLR report.This would eliminate unnecessary expenditure of NRC and licensee resources and would ease the burden of TS submittal and approval needed to license reload fuel.There are no intended deviations from the TSTF.Regulatory Evaluation:
The COLR would provide specific information identifying the particular approved topical reports used to determine the core limits for the particular cycle in the COLR report. This would eliminate unnecessary expenditure of NRC and licensee resources and would ease the burden of TS submittal and approval needed to license reload fuel.
There are no intended deviations from the TSTF.
Regulatory Evaluation:
Applicable Regulatory Requirements/Criteria:
Applicable Regulatory Requirements/Criteria:
10 CFR 50.36,"Technical specifications"-10 CFR 50.36(d)(2) states,"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." The proposed change continues to meet the requirements of this regulation.
10 CFR 50.36, "Technical specifications" - 10 CFR 50.36(d)(2) states, "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." The proposed change continues to meet the requirements of this regulation.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Precedent:
 
TSTF-363-A, Revision 0, was approved for use as described in: Attachment 1 Page 3 of 23 Letter from L.N.Olshan (U.S.Nuclear Regulatory Commission) to W.R.McCollum, Jr.(Duke Energy Corporation),"Oconee Nuclear Station, Units 1,2, and 3 RE: Issuance of Amendments (TAC NOS.MB3713, MB3714, AND MB3715)," dated July 9, 2002.No Significant Hazards Consideration:
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                             Attachment 1 Technical Specifications Changes                                                         Page 3 of 23 Precedent:
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, IIlssuance of amendment, II as discussed below: 1.Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
TSTF-363-A, Revision 0, was approved for use as described in:
Response: No.This action does not affect the plant or operation of the plant.The change simply removes technical details from the Technical Specifications already included in the COLR.These technical details will still be subject to the regulations in 10 CFR 50.59.Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Letter from L. N. Olshan (U. S. Nuclear Regulatory Commission) to W. R. McCollum, Jr.
2.Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
(Duke Energy Corporation), "Oconee Nuclear Station, Units 1,2, and 3 RE: Issuance of Amendments (TAC NOS. MB3713, MB3714, AND MB3715)," dated July 9, 2002.
Response: No.No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed changes.All systems, structures, and components previously required for the mitigation of a transient remain capable of fulfilling their intended design functions.
No Significant Hazards Consideration:
The proposed change has no adverse effects on any safety-related system or component and does not challenge the performance or integrity of any safety related system.This change is considered as an administrative action.Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
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, IIlssuance of amendment, II as discussed below:
3.Does the proposed amendment involve a significant reduction in a margin of safety?Response: No.This administrative action does not involve any reduction in a margin of safety.The change simply removes technical details from the Technical Specifications already included in the COLR.These technical details will still be subject to the regulations in 10 CFR 50.59.Therefore, the proposed change does not involve a significant reduction in a margin of safety.
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Attachment 1 Page 4 of 23 Based on the above, EGC concludes that the proposed amendment does not involve a 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.
Response: No.
This action does not affect the plant or operation of the plant. The change simply removes technical details from the Technical Specifications already included in the COLR. These technical details will still be subject to the regulations in 10 CFR 50.59.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed changes. All systems, structures, and components previously required for the mitigation of a transient remain capable of fulfilling their intended design functions. The proposed change has no adverse effects on any safety-related system or component and does not challenge the performance or integrity of any safety related system. This change is considered as an administrative action.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
This administrative action does not involve any reduction in a margin of safety. The change simply removes technical details from the Technical Specifications already included in the COLR. These technical details will still be subject to the regulations in 10 CFR 50.59. Therefore, the proposed change does not involve a significant reduction in a margin of safety.
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                         Attachment 1 Technical Specifications Changes                                                     Page 4 of 23 Based on the above, EGC concludes that the proposed amendment does not involve a 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.


==
==
Conclusions:==
Conclusions:==


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.
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.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes 2.2 TSTF-400-A, Revision1-Clarify SR on Bypass of DG Automatic Trips Detailed
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                             Attachment 1 Technical Specifications Changes                                                           Page 5 of 23 2.2     TSTF-400-A, Revision 1 - Clarify SR on Bypass of DG Automatic Trips Detailed


== Description:==
== Description:==


Attachment 1 Page 5 of 23 TSTF-400-A, Revision 1 modifies Improved Technical Specification (NUREG-1433)
TSTF-400-A, Revision 1 modifies Improved Technical Specification (NUREG-1433)
Surveillance Requirement (SR)3.8.1.13 to clarify the intent of the SR.Specifically, the wording is revised to clarify that the intent of the SR is to test non-critical Emergency Diesel Generator (EDG)automatic trips.EGCproposesto revise PBAPS Technical Specification SR 3.8.1.13 to clarify the intent of the SR.Specifically, the wording is revised to clarify that the intent of the SR is to test non-critical EDG automatic trips.The associated Technical Specification Bases are also updated in accordance with the approved TSTF and are provided for your information.
Surveillance Requirement (SR) 3.8.1.13 to clarify the intent of the SR. Specifically, the wording is revised to clarify that the intent of the SR is to test non-critical Emergency Diesel Generator (EDG) automatic trips.
There are no intended deviations from the TSTF.See the markup of pages for PBAPS, Units 2 and 3 included in Attachments 2 and 3.List of Affected Pages Unit Applicability Unit 2 Unit 3 3.8-13 X X B 3.8-30 X X Technical Evaluation:
EGC proposes to revise PBAPS Technical Specification SR 3.8.1.13 to clarify the intent of the SR. Specifically, the wording is revised to clarify that the intent of the SR is to test non-critical EDG automatic trips. The associated Technical Specification Bases are also updated in accordance with the approved TSTF and are provided for your information.
Branch Technical Position ICSB-17,"Diesel Generator Protective Trip Circuit Bypasses, II was replaced in 1981 by Regulatory Guide 1.9, Revision 2 (December 1979), Position C.7.Regulatory Guide 1.9, Rev.3, Position C.1.8, is essentially unchanged from the 1979 position.The Regulatory Guide only requires verification that the noncritical trips are bypassed and does not require verification that the critical trips are not bypassed.Regulatory Guide 1.9, Rev.3, Section 2.2.12 states,"Protective Trip Bypass Test: Demonstrate that all automatic diesel generator trips (except engine overspeed, generator differential, and those retained with coincidental logic)are automatically bypassed on an SIAS." Therefore, this SR was intended to verify that the noncritical trips are bypassed so that a spurious actuation of a noncritical trip does not take a DG out of service during an emergency.
There are no intended deviations from the TSTF.
The Branch Technical Position states that if bypasses of non-critical DG trips are used in the DG design, lithe design of the bypass circuitry should include the capability for testing the status and operability of the bypass circuits.II This requirement is the source of SR 3.8.1.13.However, as the SR and Bases are currently written, it is implied that it is not only necessary to verify that the bypasses are operable, but to verify the other channels are not bypassed.Therefore SR 3.8.1.13 and the associated Bases are revised to clarify the purpose of the SR.Testing to verify that critical DG trips are not bypassed is not required to satisfy the requirements of 10 CFR 50.36(d)(3).400-A, Revision 1, was approved by the U.S.Nuclear Regulatory Commission staff, in a letter dated November 13, 2004.
See the markup of pages for PBAPS, Units 2 and 3 included in Attachments 2 and 3.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Attachment 1 Page 6 of 23 Notwithstanding, EGC will continue to ensure appropriate testing of critical EDG trips.Although the intent of the SR is not to test the critical trips, a statement is being added to the TS Bases to ensure appropriate testing of the critical trips (see"Precedent").
Unit Applicability List of Affected Pages Unit 2           Unit 3 3.8-13                         X               X B 3.8-30                         X               X Technical Evaluation:
Therefore, this change does not result in a change to any testing that is currently performed.
Branch Technical Position ICSB-17, "Diesel Generator Protective Trip Circuit Bypasses, was    II replaced in 1981 by Regulatory Guide 1.9, Revision 2 (December 1979), Position C.7.
There are no deviations in the proposed PBAPS Technical Specifications from the TSTF.An extra sentence is added to the Bases to ensure continued testing of the critical trips.Regulatory Evaluation:
Regulatory Guide 1.9, Rev. 3, Position C.1.8, is essentially unchanged from the 1979 position.
The Regulatory Guide only requires verification that the noncritical trips are bypassed and does not require verification that the critical trips are not bypassed. Regulatory Guide 1.9, Rev. 3, Section 2.2.12 states, "Protective Trip Bypass Test: Demonstrate that all automatic diesel generator trips (except engine overspeed, generator differential, and those retained with coincidental logic) are automatically bypassed on an SIAS." Therefore, this SR was intended to verify that the noncritical trips are bypassed so that a spurious actuation of a noncritical trip does not take a DG out of service during an emergency. The Branch Technical Position states that if bypasses of non-critical DG trips are used in the DG design, lithe design of the bypass circuitry should include the capability for testing the status and operability of the bypass circuits. This requirement is the source of SR 3.8.1.13. However, as the SR and Bases are II currently written, it is implied that it is not only necessary to verify that the bypasses are operable, but to verify the other channels are not bypassed. Therefore SR 3.8.1.13 and the associated Bases are revised to clarify the purpose of the SR. Testing to verify that critical DG trips are not bypassed is not required to satisfy the requirements of 10 CFR 50.36(d)(3). TSTF-400-A, Revision 1, was approved by the U. S. Nuclear Regulatory Commission staff, in a letter dated November 13, 2004.
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                             Attachment 1 Technical Specifications Changes                                                         Page 6 of 23 Notwithstanding, EGC will continue to ensure appropriate testing of critical EDG trips. Although the intent of the SR is not to test the critical trips, a statement is being added to the TS Bases to ensure appropriate testing of the critical trips (see "Precedent"). Therefore, this change does not result in a change to any testing that is currently performed.
There are no deviations in the proposed PBAPS Technical Specifications from the TSTF. An extra sentence is added to the Bases to ensure continued testing of the critical trips.
Regulatory Evaluation:
Applicable Regulatory Requirements/Criteria:
Applicable Regulatory Requirements/Criteria:
10 CFR 50.36,"Technical specifications"-10 CFR 50.36(d)(2) states,"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." The proposed change continues to meet the requirements of this regulation.
10 CFR 50.36, "Technical specifications" - 10 CFR 50.36(d)(2) states, "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." The proposed change continues to meet the requirements of this regulation.
10 CFR 50.65,"Requirements for monitoring the effectiveness of maintenance at nuclear power plants"-The overall objective of this performance-based rule is to ensure that nuclear power plant structures, systems, and components (SSCs)will be maintained so that they will perform their intended functions when required.Precedents:
10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants" - The overall objective of this performance-based rule is to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended functions when required.
TSTF-400-A, Revision 1, was approved for use as described in: Letter from J.Stang (U.S.Nuclear Regulatory Commission) to J.R.Morris (Duke Power Company, LLC),"Catawba NuclearStation,Units 1 and 2, Issuance of Amendments Regarding Emergency Diesel Generator Testing (T AC NOS.MD3217 and MD3218)," dated June 25, 2007.Letter from T.H.Boyce (U.S.Nuclear Regulatory Commission) to Technical Specification Task Force, Staff Safety Evaluation for TSTF-400, Revision 1, dated November 13, 2004.No Significant Hazards Consideration:
Precedents:
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, II as discussed below: 1.Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
TSTF-400-A, Revision 1, was approved for use as described in:
Response: No.This change clarifies the purpose of SR 3.8.1.13, which is to verify that noncritical automatic Diesel Generator (DG)trips are bypassed in an accident.The DG automatic trips and their bypasses are not initiators of any accident previously evaluated.
Letter from J. Stang (U. S. Nuclear Regulatory Commission) to J. R. Morris (Duke Power Company, LLC), "Catawba Nuclear Station, Units 1 and 2, Issuance of Amendments Regarding Emergency Diesel Generator Testing (TAC NOS. MD3217 and MD3218)," dated June 25, 2007.
Therefore, the probability of any accident is not significantly increased.
Letter from T. H. Boyce (U. S. Nuclear Regulatory Commission) to Technical Specification Task Force, Staff Safety Evaluation for TSTF-400, Revision 1, dated November 13, 2004.
The function of the DG in mitigating accidents is not changed.The revised SR continues to ensure the License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Attachment 1 Page 7 of 23 DG will operate as assumed in the accident analysis.Therefore, the consequences of any accident previously evaluated are not affected.Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
No Significant Hazards Consideration:
2.Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
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 discussed below:
Response: No.This change clarifies the purpose of SR 3.8.1.13, which is to verify that noncritical automatic DG trips are bypassed in an accident.The proposed change does not involve a physical alteration oftheplant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.
II
Thus, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
3.Does the proposed amendment involve a significant reduction in a margin of safety?Response: No.This change clarifies the purpose of SR 3.8.1.13, which is to verify that noncritical automatic DG trips are bypassed in an accident.This change clarifies the purpose of the SR, which is to verify that the DG is capable of performing the assumed safety function.The safety function of the DG is unaffected, so the change does not affect the margin of safety.Therefore, the proposed change does not involve a significant reduction in a margin of safety.Based on the above, EGC concludes that the proposed amendment does not involve a 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.
Response: No.
This change clarifies the purpose of SR 3.8.1.13, which is to verify that noncritical automatic Diesel Generator (DG) trips are bypassed in an accident. The DG automatic trips and their bypasses are not initiators of any accident previously evaluated.
Therefore, the probability of any accident is not significantly increased. The function of the DG in mitigating accidents is not changed. The revised SR continues to ensure the
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                           Attachment 1 Technical Specifications Changes                                                         Page 7 of 23 DG will operate as assumed in the accident analysis. Therefore, the consequences of any accident previously evaluated are not affected.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
This change clarifies the purpose of SR 3.8.1.13, which is to verify that noncritical automatic DG trips are bypassed in an accident. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Thus, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
This change clarifies the purpose of SR 3.8.1.13, which is to verify that noncritical automatic DG trips are bypassed in an accident. This change clarifies the purpose of the SR, which is to verify that the DG is capable of performing the assumed safety function. The safety function of the DG is unaffected, so the change does not affect the margin of safety. Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, EGC concludes that the proposed amendment does not involve a 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.


==
==
Conclusions:==
Conclusions:==


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.
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.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Attachment 1 Page 8 of 23 2.3 TSTF-439-A, Revision2-Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO Detailed
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                       Attachment 1 Technical Specifications Changes                                                   Page 8 of 23 2.3     TSTF-439-A, Revision 2 - Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO Detailed


== Description:==
== Description:==


TSTF-439-A, Revision 2 modifies Improved Technical Specification (NUREG-1433)
TSTF-439-A, Revision 2 modifies Improved Technical Specification (NUREG-1433)
Completion Times Example 1.3-3 to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion.
Completion Times Example 1.3-3 to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.1.7 Required Actions A.2 and B.1, Technical Specification 3.8.1 Required Action A.3, and Technical Specification 3.8.7 Required Actions C.1 and 0.1 are being deleted. The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.
The second Completion Time associated with Technical Specification 3.1.7 Required Actions A.2 and B.1, Technical Specification 3.8.1 Required Action A.3, and Technical Specification 3.8.7 Required Actions C.1 and 0.1 are being deleted.The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.It is proposed to revise PBAPS Technical Specification Section 1.3 to conform to the above changes.Other TS Bases pages are revised in accordance with the TSTF to conform to the changes in TS 1.3.There are no intended deviations from the TSTF.See the markup of pages for PBAPS, Units 2 and 3 included in Attachments 2 and 3.List of Affected Pages Unit Applicability Unit 2 Unit 3 1.3-2 X X 1.3-6 X X 1.3-7 X X 3.1-20 X X 3.8-2 X X 3.8-42 X X 3.8-43 X X B 3.1-42 X X B 3.1-43 X X B 3.8-8 X X B 3.8-9 X X B 3.8-89 X X B 3.8-90 X X B 3.8-91 X X Technical Evaluation:
It is proposed to revise PBAPS Technical Specification Section 1.3 to conform to the above changes. Other TS Bases pages are revised in accordance with the TSTF to conform to the changes in TS 1.3.
As discussed in TSTF-439-A, Revision 2, the adoption of a second Completion Time was based on an NRC concern that a plant could continue to operate indefinitely with an LCO governing safety significant systems never being met by alternately meeting the requirements of separate Conditions.
There are no intended deviations from the TSTF.
In 1991, the NRC could not identify any regulatory requirement or program which License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Attachment 1 Page 9 of 23 could prevent this misuse of the Technical Specifications.
See the markup of pages for PBAPS, Units 2 and 3 included in Attachments 2 and 3.
However, that is no longer the case.There are now two programs which would provide a strong disincentive to continued operation with concurrent multiple inoperabilities of the type the second Completion Times were designed to prevent.The Maintenance Rule: 10 CFR 50.65(a)(1), the Maintenance Rule, requires each licensee to monitor the performance or condition of SSCs against licensee-established goals to ensure that the SSCs are capable of fulfilling their intended functions.
Unit Applicability List of Affected Pages Unit 2       Unit 3 1.3-2                     X             X 1.3-6                     X             X 1.3-7                     X             X 3.1-20                     X             X 3.8-2                     X             X 3.8-42                     X             X 3.8-43                     X             X B 3.1-42                     X             X B 3.1-43                     X             X B 3.8-8                     X             X B 3.8-9                     X             X B 3.8-89                     X             X B 3.8-90                     X             X B 3.8-91                     X             X Technical Evaluation:
If the performance or condition of an SSC does not meet established goals, appropriate corrective action is required to be taken.The NRC Resident Inspectors monitor the licensee's Corrective Action process and could take action if the licensee's maintenance program allowed the systems required by a single LCO to become concurrently inoperable multiple times.The performance and condition monitoring activities required by 10 CFR 50.65(a)(1) and (a)(2)would identify if poor maintenance practices resulted in multiple entries into the ACTIONS of the Technical Specifications and unacceptable unavailability of these SSCs.The effectiveness of these performance monitoring activities, and associated corrective actions, is evaluated at least every refueling cycle, not to exceed 24 months per 10 CFR 50.65(a)(3).
As discussed in TSTF-439-A, Revision 2, the adoption of a second Completion Time was based on an NRC concern that a plant could continue to operate indefinitely with an LCO governing safety significant systems never being met by alternately meeting the requirements of separate Conditions. In 1991, the NRC could not identify any regulatory requirement or program which
Under the Technical Specifications the Completion Time for one system is not affected by other inoperable equipment.
 
The second Completion Times were an attempt to influence the Completion Time for one system based on the condition of another system, if the two systems were required by the same LCO.However 10 CFR 50.65(a)(4) is a much better mechanism to apply this influence as the Maintenance Rule considers all inoperable risk-significant equipment, not just the one or two systems governed by the same LCO.Under 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                           Attachment 1 Technical Specifications Changes                                                       Page 9 of 23 could prevent this misuse of the Technical Specifications. However, that is no longer the case.
The risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide 1.182,"Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01,"Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions.These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed maintenance is acceptable.
There are now two programs which would provide a strong disincentive to continued operation with concurrent multiple inoperabilities of the type the second Completion Times were designed to prevent.
This comprehensive program provides much greater assurance of safe plant operation than the second Completion Times in the Technical Specifications.
The Maintenance Rule: 10 CFR 50.65(a)(1), the Maintenance Rule, requires each licensee to monitor the performance or condition of SSCs against licensee-established goals to ensure that the SSCs are capable of fulfilling their intended functions. If the performance or condition of an SSC does not meet established goals, appropriate corrective action is required to be taken.
The Reactor Oversight Process: NEI 99-02,"Regulatory Assessment Performance Indicator Guideline," describes the tracking and reporting of performance indicators to support the NRC's Reactor Oversight Process (RaP).The NEI document is endorsed by RIS 2001-11,"Voluntary Submission Of Performance Indicator Data." NEI 99-02, Section 2.2, describes the Mitigating Systems Cornerstone.
The NRC Resident Inspectors monitor the licensee's Corrective Action process and could take action if the licensee's maintenance program allowed the systems required by a single LCO to become concurrently inoperable multiple times. The performance and condition monitoring activities required by 10 CFR 50.65(a)(1) and (a)(2) would identify if poor maintenance practices resulted in multiple entries into the ACTIONS of the Technical Specifications and unacceptable unavailability of these SSCs. The effectiveness of these performance monitoring activities, and associated corrective actions, is evaluated at least every refueling cycle, not to exceed 24 months per 10 CFR 50.65(a)(3).
NEI 99-02 specifically addresses emergency AC Sources (which encompasses the AC Sources and Distribution System LCOs).Extended unavailability due to multiple entries into the ACTIONS would affect the NRC's evaluation of the licensee's performance under the Rap.
Under the Technical Specifications the Completion Time for one system is not affected by other inoperable equipment. The second Completion Times were an attempt to influence the Completion Time for one system based on the condition of another system, if the two systems were required by the same LCO. However 10 CFR 50.65(a)(4) is a much better mechanism to apply this influence as the Maintenance Rule considers all inoperable risk-significant equipment, not just the one or two systems governed by the same LCO.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Attachment 1 Page 10 of 23 In addition to these programs, a requirement is added to Section 1.3 of the Technical Specifications to require licensees to have administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO.These administrative controls should consider plant risk and shall limit the maximum contiguous time of failing to meet the LCO.This Technical Specification requirement, when considered with the regulatory processes discussed above, provides an equivalent or superior level of plant safety without the unnecessary complication of the Technical Specifications by second Completion Times on some Specifications.
Under 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance. The risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants."
Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed maintenance is acceptable. This comprehensive program provides much greater assurance of safe plant operation than the second Completion Times in the Technical Specifications.
The Reactor Oversight Process: NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," describes the tracking and reporting of performance indicators to support the NRC's Reactor Oversight Process (RaP). The NEI document is endorsed by RIS 2001-11, "Voluntary Submission Of Performance Indicator Data." NEI 99-02, Section 2.2, describes the Mitigating Systems Cornerstone. NEI 99-02 specifically addresses emergency AC Sources (which encompasses the AC Sources and Distribution System LCOs). Extended unavailability due to multiple entries into the ACTIONS would affect the NRC's evaluation of the licensee's performance under the Rap.
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                           Attachment 1 Technical Specifications Changes                                                     Page 10 of 23 In addition to these programs, a requirement is added to Section 1.3 of the Technical Specifications to require licensees to have administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls should consider plant risk and shall limit the maximum contiguous time of failing to meet the LCO. This Technical Specification requirement, when considered with the regulatory processes discussed above, provides an equivalent or superior level of plant safety without the unnecessary complication of the Technical Specifications by second Completion Times on some Specifications.
Regulatory Evaluation:
Regulatory Evaluation:
Applicable Regulatory Requirements/Criteria:
Applicable Regulatory Requirements/Criteria:
10 CFR 50.36,"Technical specifications"-10 CFR 50.36(c)(2) states,"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." The proposed change continues to meet the requirements of this regulation.
10 CFR 50.36, "Technical specifications" - 10 CFR 50.36(c)(2) states, "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." The proposed change continues to meet the requirements of this regulation.
10 CFR 50.65, IIRequirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants"-The overall objective of this performance-based rule is to ensure that nuclear power plant structures, systems, and components (SSCs)will be maintained so that they will perform their intended function when required.Precedent:
10 CFR 50.65, IIRequirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" - The overall objective of this performance-based rule is to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended function when required.
TSTF-439-A, Revision 2 was approved for use as described in: Letter from B.K.Singal (U.S.Nuclear Regulatory Commission) to M.R.Blevins (Luminant Generation Company LLC),"Comanche Peak Steam Electric Station Units 1 and2-Issuance of Amendments RE: Revision to Technical Specifications (TS)3.7.5, 3.8.1, and3.8.9,and TS Example 1.3-3 (TAC NOS.MD4070 AND MD4071)," dated January 25, 2008.No Significant Hazards Consideration:
Precedent:
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 discussed below: 1.Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
TSTF-439-A, Revision 2 was approved for use as described in:
Response: No.The proposed change eliminates certain Completion Times from the Technical Specifications.
Letter from B. K. Singal (U. S. Nuclear Regulatory Commission) to M. R. Blevins (Luminant Generation Company LLC), "Comanche Peak Steam Electric Station Units 1 and 2 - Issuance of Amendments RE: Revision to Technical Specifications (TS) 3.7.5, 3.8.1, and 3.8.9, and TS Example 1.3-3 (TAC NOS. MD4070 AND MD4071 )," dated January 25, 2008.
Completion Times are not an initiator to any accident previously evaluated.
No Significant Hazards Consideration:
As a result, the probability of an accident previously evaluated is not affected.The consequences of an accident during the revised Completion Time are no different than the consequences of the same accident during the existing Completion Times.As a result, the consequences of an accident previously evaluated are not affected by this change.The proposed change does not alter or prevent the ability of License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Attachment 1 Page 11 of 23 structures, systems, and components (SSCs)from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits.The proposed change does not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated.
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 discussed below:
Further, the proposed change does not increase the types or amounts of radioactive effluent that may be released offsite, nor significantly increase individual or cumulative occupational/public radiation exposures.
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change is consistent with the safety analysis assumptions and resultant consequences.
Response: No.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change eliminates certain Completion Times from the Technical Specifications. Completion Times are not an initiator to any accident previously evaluated. As a result, the probability of an accident previously evaluated is not affected. The consequences of an accident during the revised Completion Time are no different than the consequences of the same accident during the existing Completion Times. As a result, the consequences of an accident previously evaluated are not affected by this change. The proposed change does not alter or prevent the ability of
2.Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
 
Response: No.The proposed change does not involve a physical alteration of the plant (Le., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                             Attachment 1 Technical Specifications Changes                                                         Page 11 of 23 structures, systems, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits.
The proposed change does not alter any assumptions made in the safety analysis.Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed change does not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. Further, the proposed change does not increase the types or amounts of radioactive effluent that may be released offsite, nor significantly increase individual or cumulative occupational/public radiation exposures. The proposed change is consistent with the safety analysis assumptions and resultant consequences. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
3.Does the proposed amendment involve a significant reduction in a margin of safety?Response: No.The proposed change to delete the second Completion Time does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
The safety analysis acceptance criteria are not affected by this change.The proposed change will not result in plant operation in a configuration outside of the design basis.Therefore, the proposed change does not involve a significant reduction in a margin of safety.Based on theabove,EGC concludes that the proposed amendment does not involve a 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.
Response: No.
The proposed change does not involve a physical alteration of the plant (Le., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed change does not alter any assumptions made in the safety analysis. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed change to delete the second Completion Time does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis acceptance criteria are not affected by this change.
The proposed change will not result in plant operation in a configuration outside of the design basis. Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, EGC concludes that the proposed amendment does not involve a 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.


==
==
Conclusions:==
Conclusions:==


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.
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.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes 2.4 TSTF-485-A, Rev.0-Correct Example 1.4-1 Detailed
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                             Attachment 1 Technical Specifications Changes                                                         Page 12 of 23 2.4     TSTF-485-A, Rev. 0 - Correct Example 1.4-1 Detailed


== Description:==
== Description:==


Attachment 1 Page 12 of 23 TSTF-485-A, Revision 0 modifies Section 1.4,"Frequency," Example 1.4-1 to be consistent with the requirements of SR 3.0.4.SR 3.0.4 was revised by TSTF-359, Revision 9, and the current example is not consistent with the Technical Specification requirements.
TSTF-485-A, Revision 0 modifies Section 1.4, "Frequency," Example 1.4-1 to be consistent with the requirements of SR 3.0.4. SR 3.0.4 was revised by TSTF-359, Revision 9, and the current example is not consistent with the Technical Specification requirements.
The second paragraph of Example 1.4-1 currently states: If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the MODE or other specified condition.
The second paragraph of Example 1.4-1 currently states:
Failure to do so would result in a violation of SR 3.0.4.It is being revised to state: If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, then SR 3.0.4 becomes applicable.
If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the MODE or other specified condition. Failure to do so would result in a violation of SR 3.0.4.
The Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified by SR 3.0.3, prior to entry into the MODE or other specified condition or the LCO is considered not met (in accordance with SR 3.0.1), and LCO 3.0.4 becomes applicable.
It is being revised to state:
It is proposed to revise Technical Specification Section 1.4,"Frequency," Example 1.4-1 to conform to the above change.There are no associated TS Bases changes required.There are no intended deviations from the TSTF.See the markup of pages for PBAPS, Units 2 and 3 included in Attachment 2.List of Affected Pages Unit Applicability Unit 2 Unit 3 1.4-3 X X Technical Evaluation:
If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, then SR 3.0.4 becomes applicable. The Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified by SR 3.0.3, prior to entry into the MODE or other specified condition or the LCO is considered not met (in accordance with SR 3.0.1), and LCO 3.0.4 becomes applicable.
Example 1.4-1 states that if the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the MODE or other specified condition.
It is proposed to revise Technical Specification Section 1.4, "Frequency," Example 1.4-1 to conform to the above change. There are no associated TS Bases changes required.
Failure to do so would result in a violation of SR 3.0.4.SR 3.0.4 states that entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCOls Surveillances have been met within their specified Frequency.
There are no intended deviations from the TSTF.
TSTF-359 modified SR 3.0.4 to state that when an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.TSTF-359 modified LCO 3.0.4 to provide conditions under which it is acceptable to enter the Applicability of the LCO with License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications
See the markup of pages for PBAPS, Units 2 and 3 included in Attachment 2.
'Changes Attachment 1 Page 13 of 23 the LCO not met.Therefore, it possible to enter the MODE or other specified condition in the Applicability of an LCO with a Surveillance not performed within the Frequency requirements of SR 3.0.2 and this does not result in a violation of SR 3.0.4.The Example 1.4-1, second paragraph discussion is modified to parallel the discussion in the previous paragraph.
Unit Applicability List of Affected Pages Unit 2       Unit 3 1.4-3                         X             X Technical Evaluation:
The previous paragraph discusses Surveillances that exceed the interval without being performed while in the Applicability.
Example 1.4-1 states that if the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the MODE or other specified condition. Failure to do so would result in a violation of SR 3.0.4. SR 3.0.4 states that entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCOls Surveillances have been met within their specified Frequency. TSTF-359 modified SR 3.0.4 to state that when an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. TSTF-359 modified LCO 3.0.4 to provide conditions under which it is acceptable to enter the Applicability of the LCO with
The second paragraph is modified to make a similar statement regarding Surveillances that exceed the interval while not being in the Applicability.
 
The second sentence of the second paragraph is modified to reference the provisions of SR 3.0.3.This is necessary as TSTF-359 modified SR 3.0.4 to recognize that performance of a missed Surveillance may have been extended and prior to performance of the missed Surveillance, but within the time permitted under SR 3.0.3, a MODE change occurs.The statement that failure to perform a Surveillance prior to entering the Applicability would constitute a violation of SR 3.0.4 is deleted and a statement is inserted to state the LCO would not be met and LCO 3.0.4 becomes applicable.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                           Attachment 1 Technical Specifications 'Changes                                                     Page 13 of 23 the LCO not met. Therefore, it possible to enter the MODE or other specified condition in the Applicability of an LCO with a Surveillance not performed within the Frequency requirements of SR 3.0.2 and this does not result in a violation of SR 3.0.4.
This is consistent with the revised SR 3.0.4.Regulatory Evaluation:
The Example 1.4-1, second paragraph discussion is modified to parallel the discussion in the previous paragraph. The previous paragraph discusses Surveillances that exceed the interval without being performed while in the Applicability. The second paragraph is modified to make a similar statement regarding Surveillances that exceed the interval while not being in the Applicability. The second sentence of the second paragraph is modified to reference the provisions of SR 3.0.3. This is necessary as TSTF-359 modified SR 3.0.4 to recognize that performance of a missed Surveillance may have been extended and prior to performance of the missed Surveillance, but within the time permitted under SR 3.0.3, a MODE change occurs.
The statement that failure to perform a Surveillance prior to entering the Applicability would constitute a violation of SR 3.0.4 is deleted and a statement is inserted to state the LCO would not be met and LCO 3.0.4 becomes applicable. This is consistent with the revised SR 3.0.4.
Regulatory Evaluation:
Applicable Regulatory Requirements/Criteria:
Applicable Regulatory Requirements/Criteria:
This change is administrative and will have no effect on any regulatory requirements or criteria.Precedent:
This change is administrative and will have no effect on any regulatory requirements or criteria.
TSTF-485-A, Revision 0 was approved for use as described in: 1.Letter from C.F.Lyon (U.S.Nuclear Regulatory Commission) to J.V.Parrish (Energy Northwest),"Columbia Generating Station-Issuance of Amendment RE: Miscellaneous Administrative Changes (TAC NO.MD6209)," dated December 13, 2007.2.Letter from B.Vaidya (U.S.Nuclear Regulatory Commission) to J.E.Venable (Entergy Operations, Inc.),"River Bend Station, Unit1-Issuance of Amendment RE: Technical Specifications Change Regarding Mode Change Limitations (TSTF-359)
Precedent:
Using Consolidated Line Item Improvement Process, and Correct Example 1.4-1 (TSTF-485)(TAC NO.MD6016)," dated December 6,2007.No Significant Hazards Consideration:
TSTF-485-A, Revision 0 was approved for use as described in:
EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92,"lssuance of amendment, II as discussed below: 1.Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
: 1. Letter from C. F. Lyon (U. S. Nuclear Regulatory Commission) to J. V. Parrish (Energy Northwest), "Columbia Generating Station - Issuance of Amendment RE:
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Response: No.Attachment 1 Page 14 of 23 The proposed change revises Section 1.4,"Frequency," Example 1.4-1, to be consistent with Surveillance Requirement (SR)3.0.4 and Limiting Condition for Operation (LCO)3.0.4.This change is considered administrative in that it modifies the example to demonstrate the proper application of SR 3.0.4 and LCO 3.0.4.The requirements of SR 3.0.4 and LCO 3.0.4 are clear and are clearly explained in the associated Bases.As a result, modifying the example will not result in a change in usage of the Technical Specifications (TS).The proposed change does not adversely affect accident initiators or precursors, the ability of structures, systems, and components (SSCs)to perform their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated.
Miscellaneous Administrative Changes (TAC NO. MD6209)," dated December 13, 2007.
Therefore, this change is considered administrative and will have no effect on the probability or consequences of any accident previously evaluated.
: 2. Letter from B. Vaidya (U. S. Nuclear Regulatory Commission) to J. E. Venable (Entergy Operations, Inc.), "River Bend Station, Unit 1 - Issuance of Amendment RE: Technical Specifications Change Regarding Mode Change Limitations (TSTF-359) Using Consolidated Line Item Improvement Process, and Correct Example 1.4-1 (TSTF-485)
(TAC NO. MD6016)," dated December 6,2007.
No Significant Hazards Consideration:
EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "lssuance of amendment, as discussed below:
II
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                             Attachment 1 Technical Specifications Changes                                                       Page 14 of 23 Response: No.
The proposed change revises Section 1.4, "Frequency," Example 1.4-1, to be consistent with Surveillance Requirement (SR) 3.0.4 and Limiting Condition for Operation (LCO) 3.0.4. This change is considered administrative in that it modifies the example to demonstrate the proper application of SR 3.0.4 and LCO 3.0.4. The requirements of SR 3.0.4 and LCO 3.0.4 are clear and are clearly explained in the associated Bases. As a result, modifying the example will not result in a change in usage of the Technical Specifications (TS). The proposed change does not adversely affect accident initiators or precursors, the ability of structures, systems, and components (SSCs) to perform their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. Therefore, this change is considered administrative and will have no effect on the probability or consequences of any accident previously evaluated.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.No new or different accidents result from utilizing the proposed change.The change does not involve a physical alteration of the plant (Le., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.
Response: No.
In addition, the change does not impose any new or different requirements or eliminate any existing requirements.
No new or different accidents result from utilizing the proposed change. The change does not involve a physical alteration of the plant (Le., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the change does not impose any new or different requirements or eliminate any existing requirements. The change does not alter assumptions made in the safety analysis. The proposed change is consistent with the safety analysis assumptions and current plant operating practice.
The change does not alter assumptions made in the safety analysis.The proposed change is consistent with the safety analysis assumptions and current plant operating practice.Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.Does the proposed amendment involve a significant reduction in a margin of safety?Response: No.The proposed change is administrative and will have no effect on the application of the Technical Specification requirements.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Therefore, the margin of safety provided by the Technical Specification requirements is unchanged.
Response: No.
There are no changes totheplant safety analyses involved with this change.Therefore, the proposed change does not involve a significant reduction in a margin of safety.Based on the above, EGC concludes that the proposed amendment does not involve a 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.
The proposed change is administrative and will have no effect on the application of the Technical Specification requirements. Therefore, the margin of safety provided by the Technical Specification requirements is unchanged. There are no changes to the plant safety analyses involved with this change. Therefore, the proposed change does not involve a significant reduction in a margin of safety.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes
Based on the above, EGC concludes that the proposed amendment does not involve a 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.
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                         Attachment 1 Technical Specifications Changes                                                   Page 15 of 23


== Conclusions:==
==
Conclusions:==


Attachment 1 Page 15 of 23 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.
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.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Attachment 1 Page 16 of 23 2.5 Administrative Changes-Removal of Obsolete Note for Technical Specification Table 3.3.8.1-1 (PBAPS, Units 2 and 3)and Correction to Table 3.3.3.1-1 (PBAPS, Unit 2)Detailed
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                           Attachment 1 Technical Specifications Changes                                                       Page 16 of 23 2.5     Administrative Changes - Removal of Obsolete Note for Technical Specification Table 3.3.8.1-1 (PBAPS, Units 2 and 3) and Correction to Table 3.3.3.1-1 (PBAPS, Unit 2)
Detailed


== Description:==
== Description:==


Thais change addresses two (2)administrative changes: a)TS Table 3.3.8.1-1 lists the TS functions associated with the Loss of Power (LOP)Instrumentation.
Thais change addresses two (2) administrative changes:
As a result of a modification, the allowable values were revised, but as described in the note, were to expire no later than March 1, 2000.The previous values were retained in note (a)at the bottom of the Table.These values were retained as a note to allow for appropriate transition during the period of time that the modifications were being installed on Units 2 and 3.The modifications are complete and the note is no longer necessary.
a) TS Table 3.3.8.1-1 lists the TS functions associated with the Loss of Power (LOP)
Therefore, it is proposed to eliminate note (a)at the bottom of Table 3.3.8.1-1, as an administrative change to the TS.b)TS Table 3.3.3.1-1 lists the Post Accident Monitoring Instrumentation.
Instrumentation. As a result of a modification, the allowable values were revised, but as described in the note, were to expire no later than March 1, 2000. The previous values were retained in note (a) at the bottom of the Table. These values were retained as a note to allow for appropriate transition during the period of time that the modifications were being installed on Units 2 and 3.
The Reference 1 license amendment request implemented TSTF-295, Revision 0,"Post Accident Monitoring Clarifications," by changing the title from"PCIV Position" to"Penetration Flow Path PCIV Position" for Function 8.However, Function 8 was inadvertently revised on the PBAPS, Unit 2 page to state"Penetration Flaw Path PCIV Position." The correct title should be"Penetration Flow Path PCIV Position." The Unit 3 page correctly provides the title of Function 8 as the"Penetration Flow Path PCIV Position." This is an administrative change that corrects a typographical error on the PBAPS, Unit 2 page.There are no TS Bases changes required for either change.See the markup of pages for PBAPS, Units 2 and 3 included in Attachment 2.List of Affected Pages Unit Applicability Unit 2 Unit 3 3.3-65 X X 3.3-26 X Technical Evaluation:
The modifications are complete and the note is no longer necessary. Therefore, it is proposed to eliminate note (a) at the bottom of Table 3.3.8.1-1, as an administrative change to the TS.
a)TS Table 3.3.8.1-1 lists the TS functions associated with the Loss of Power (LOP)Instrumentation.
b) TS Table 3.3.3.1-1 lists the Post Accident Monitoring Instrumentation. The Reference 1 license amendment request implemented TSTF-295, Revision 0, "Post Accident Monitoring Clarifications," by changing the title from "PCIV Position" to "Penetration Flow Path PCIV Position" for Function 8. However, Function 8 was inadvertently revised on the PBAPS, Unit 2 page to state "Penetration Flaw Path PCIV Position." The correct title should be "Penetration Flow Path PCIV Position." The Unit 3 page correctly provides the title of Function 8 as the "Penetration Flow Path PCIV Position." This is an administrative change that corrects a typographical error on the PBAPS, Unit 2 page.
As a result of a modification, the allowable values were revised.The previous values were retained in note (a)at the bottom of the Table.These values were retained as a note to allow for appropriate transition during the period of time that the modifications were being installed on Units 2 and 3.As a result of the completion of the modifications, it is no longer necessary to retain the note in TS.Therefore, it is proposed to eliminate note (a)at the bottom of Table 3.3.8.1-1 as an administrative change to the TS.The previous TS change was approved as License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Attachment 1 Page 17 of 23 amendments 230/235 to the Units 2 and 3 TS, respectively.
There are no TS Bases changes required for either change.
The changes were the result of modifications required to the TS as requested in the Reference 3 letter, supplemented in the Reference 4 letter, and approved in the Reference 5 letter.Note (a)expired March 1, 2000 and is no longer necessary to retain in TS Table 3.3.8.1-1.
See the markup of pages for PBAPS, Units 2 and 3 included in Attachment 2.
Removing the note (a)will reduce the complexity of the TS and enhance usability of the TS.This change is, therefore, considered administrative.
Unit Applicability List of Affected Pages Unit 2       Unit 3 3.3-65                         X             X 3.3-26                         X Technical Evaluation:
b)TS Table 3.3.3.1-1 lists thepostaccident monitoring instrumentation.
a) TS Table 3.3.8.1-1 lists the TS functions associated with the Loss of Power (LOP)
The Reference 1 license amendment request implemented TSTF-295, Revision 0,"Post Accident Monitoring Clarifications," by changing the title from"PCIV Position" to"Penetration Flow Path PCIV Position" for Function 8.However, Function 8 was inadvertently revised on the PBAPS, Unit 2 page to state"Penetration Flaw Path PCIV Position." The correct title in should be"Penetration Flow Path PCIV Position." This change was approved in the Reference 2 letter.The Unit 3 page correctly provides the title of Function 8 as the"Penetration Flow Path PCIV Position." This is an administrative change that corrects a typographical error on the PBAPS, Unit 2 page.No technical change is occurring as a result of this correction.
Instrumentation. As a result of a modification, the allowable values were revised. The previous values were retained in note (a) at the bottom of the Table. These values were retained as a note to allow for appropriate transition during the period of time that the modifications were being installed on Units 2 and 3.
As a result of the completion of the modifications, it is no longer necessary to retain the note in TS. Therefore, it is proposed to eliminate note (a) at the bottom of Table 3.3.8.1-1 as an administrative change to the TS. The previous TS change was approved as
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                           Attachment 1 Technical Specifications Changes                                                     Page 17 of 23 amendments 230/235 to the Units 2 and 3 TS, respectively. The changes were the result of modifications required to the TS as requested in the Reference 3 letter, supplemented in the Reference 4 letter, and approved in the Reference 5 letter.
Note (a) expired March 1, 2000 and is no longer necessary to retain in TS Table 3.3.8.1-1.
Removing the note (a) will reduce the complexity of the TS and enhance usability of the TS. This change is, therefore, considered administrative.
b)   TS Table 3.3.3.1-1 lists the post accident monitoring instrumentation. The Reference 1 license amendment request implemented TSTF-295, Revision 0, "Post Accident Monitoring Clarifications," by changing the title from "PCIV Position" to "Penetration Flow Path PCIV Position" for Function 8. However, Function 8 was inadvertently revised on the PBAPS, Unit 2 page to state "Penetration Flaw Path PCIV Position." The correct title in should be "Penetration Flow Path PCIV Position." This change was approved in the Reference 2 letter. The Unit 3 page correctly provides the title of Function 8 as the "Penetration Flow Path PCIV Position." This is an administrative change that corrects a typographical error on the PBAPS, Unit 2 page. No technical change is occurring as a result of this correction.
Regulatory Evaluation:
Regulatory Evaluation:
Applicable Regulatory Requirements/Criteria:
Applicable Regulatory Requirements/Criteria:
These proposed changes are administrative and will have no effect on any regulatory requirements or criteria.Precedent:
These proposed changes are administrative and will have no effect on any regulatory requirements or criteria.
Precedent:
N/A No Significant Hazards Consideration:
N/A No Significant Hazards Consideration:
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,"lssuance of amendment, II as discussed below: 1.Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
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, "lssuance of amendment, as discussed below:
Response: No.The proposed changes are administrative in nature and do not impact the operation, physical configuration, or function of plant structures, systems, or components (SSCs).Also, the proposed changes do not impact the initiators or assumptions of analyzed events, nor do the proposed changes impact the mitigation of accidents or transient events.Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
II
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Attachment 1 Page 18 of 23 2.Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.The proposed changes are administrative in nature and do not alter plant configuration, require that new equipment be installed, alter assumptions made about accidents previously evaluated, or impact the operation or function of plant equipment.
Response: No.
The proposed changes are administrative in nature and do not impact the operation, physical configuration, or function of plant structures, systems, or components (SSCs).
Also, the proposed changes do not impact the initiators or assumptions of analyzed events, nor do the proposed changes impact the mitigation of accidents or transient events. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                               Attachment 1 Technical Specifications Changes                                                         Page 18 of 23
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed changes are administrative in nature and do not alter plant configuration, require that new equipment be installed, alter assumptions made about accidents previously evaluated, or impact the operation or function of plant equipment.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
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 amendment involve a significant reduction in a margin of safety?Response: No.The proposed changes are administrative in nature and do not involve any physical changes to plant SSCs, or the manner in which SSCs are operated, maintained, modified, tested, or inspected.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
The proposed changes do not involve a change to any safety limits, limiting safety system settings, limiting conditions of operation, or design parameters for any SSC.The proposed changes do not impact any safety analysis assumptions and do not involve a change in initial conditions, system response times, or other parameters affecting any accident analysis.Therefore, the proposed changes do not involve a significant reduction in a margin of safety.Based on the above, EGC concludes that the proposed amendment does not involve a 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.
Response: No.
The proposed changes are administrative in nature and do not involve any physical changes to plant SSCs, or the manner in which SSCs are operated, maintained, modified, tested, or inspected. The proposed changes do not involve a change to any safety limits, limiting safety system settings, limiting conditions of operation, or design parameters for any SSC. The proposed changes do not impact any safety analysis assumptions and do not involve a change in initial conditions, system response times, or other parameters affecting any accident analysis. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Based on the above, EGC concludes that the proposed amendment does not involve a 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.


==
==
Conclusions:==
Conclusions:==


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.
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.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Attachment 1 Page 19 of 23 2.6 Clarification of Allowable Value on Technical Specification Table 3.3.1.1-1 Detailed
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                           Attachment 1 Technical Specifications Changes                                                       Page 19 of 23 2.6     Clarification of Allowable Value on Technical Specification Table 3.3.1.1-1 Detailed


== Description:==
== Description:==


The administrative change requested by this amendment application is to delete the"NA" from the Allowable Value column for Function 2.1,"OPRM Upscale," in TS Table 3.3.1.1-1,"Reactor Protection System Instrumentation." The reference to footnote"(d)," which states: "See COLR for OPRM period based detection algorithm (PBDA)setpoint limits," will remain in the Allowable Value column for Function 2.f in TS Table 3.3.1.1-1.
The administrative change requested by this amendment application is to delete the "NA" from the Allowable Value column for Function 2.1, "OPRM Upscale," in TS Table 3.3.1.1-1, "Reactor Protection System Instrumentation." The reference to footnote "(d)," which states: "See COLR for OPRM period based detection algorithm (PBDA) setpoint limits," will remain in the Allowable Value column for Function 2.f in TS Table 3.3.1.1-1.
On March 4, 2005, the NRC contacted EGC by telephone to discuss some follow-up questions concerning the changes to the TS that were originally proposed to the NRC in the Reference 6 letter, regarding activation of the OPRM trip function at PBAPS.The NRC identified an issue that was not significant enough to impact NRC issuance of the OPRM trip activation amendments for PBAPS, Units 2 and 3.However, the NRC requested that a change to TS Table 3.3.1.1-1 be proposed in a subsequent"cleanup" license amendment request (LAR).The NRC subsequently issued Amendment Nos.251 and 254 for PBAPS, Units 2 and 3, by letter dated March 21, 2005 (Reference 8).See the markup of pages for PBAPS, Units 2 and 3 included in Attachment 2.List of Affected Pages Unit Applicability Unit 2 Unit 3 3.3-7 X X Technical Evaluation:
On March 4, 2005, the NRC contacted EGC by telephone to discuss some follow-up questions concerning the changes to the TS that were originally proposed to the NRC in the Reference 6 letter, regarding activation of the OPRM trip function at PBAPS. The NRC identified an issue that was not significant enough to impact NRC issuance of the OPRM trip activation amendments for PBAPS, Units 2 and 3. However, the NRC requested that a change to TS Table 3.3.1.1-1 be proposed in a subsequent "cleanup" license amendment request (LAR). The NRC subsequently issued Amendment Nos. 251 and 254 for PBAPS, Units 2 and 3, by letter dated March 21, 2005 (Reference 8).
The change proposed in Reference 6 added new Function 2.f, i.e., the OPRM Upscale trip function, to TS Table 3.3.1.1-1.
See the markup of pages for PBAPS, Units 2 and 3 included in Attachment 2.
The addition of footnote (d)was discussed in the Reference 7 RAI response.The NRC found the"NA" in the Allowable Value column of Table 3.3.1.1-1 confusing since there are trip setpoints maintained in the COLR which satisfy the requirements of 10 CFR 50.36 for limiting safety system settings.Therefore, the NRC requested that, in a future LAR, EGC delete the"NA" from the Allowable Value column for Function 2.1 in TS Table 3.3.1.1-1 and leave only the footnote"(d)" which references the COLR for the location of the trip setpoints.
Unit Applicability List of Affected Pages Unit 2         Unit 3 3.3-7                       X             X Technical Evaluation:
The change to PBAPS TS Table 3.3.1.1-1 requested by the NRC is therefore being proposed by this amendment request.Regulatorv Evaluation:
The change proposed in Reference 6 added new Function 2.f, i.e., the OPRM Upscale trip function, to TS Table 3.3.1.1-1. The addition of footnote (d) was discussed in the Reference 7 RAI response. The NRC found the "NA" in the Allowable Value column of Table 3.3.1.1-1 confusing since there are trip setpoints maintained in the COLR which satisfy the requirements of 10 CFR 50.36 for limiting safety system settings. Therefore, the NRC requested that, in a future LAR, EGC delete the "NA" from the Allowable Value column for Function 2.1 in TS Table 3.3.1.1-1 and leave only the footnote "(d)" which references the COLR for the location of the trip setpoints. The change to PBAPS TS Table 3.3.1.1-1 requested by the NRC is therefore being proposed by this amendment request.
Regulatorv Evaluation:
Applicable Regulatory Requirements/Criteria:
Applicable Regulatory Requirements/Criteria:
This is an administrative change that clarifies the allowable value for Function 2.1.No regulatory requirements are being impacted, nor is the intent of the TS being modified.Precedent:
This is an administrative change that clarifies the allowable value for Function 2.1. No regulatory requirements are being impacted, nor is the intent of the TS being modified.
N/A License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes No Significant Hazards Consideration:
Precedent:
Attachment 1 Page 20 of 23 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,"lssuance of amendment, II as discussed below: 1.Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
N/A
Response: No.The proposed change is administrative in nature and does not impact the operation, physical configuration, or function of plant structures, systems, or components (SSCs).Also, the proposed change does not impact the initiators or assumptions of analyzed events, nor does the proposed change impact the mitigation of accidents or transient events.Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
 
2.Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                               Attachment 1 Technical Specifications Changes                                                         Page 20 of 23 No Significant Hazards Consideration:
Response: No.The proposed change is administrative in nature and does not alter plant configuration, require that new equipment be installed, alter assumptions made about accidents previously evaluated, or impact the operation or function of plant equipment.
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, "lssuance of amendment, as discussed below:
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
II
3.Does the proposed amendment involve a significant reduction in a margin of safety?Response: No.The proposed change is administrative in nature and does not involve any physical changes to plant SSCs, or the manner in which SSCs are operated, maintained, modified, tested, or inspected.
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change does not involve a change to any safety limits, limiting safety system settings, limiting conditions of operation, or design parameters for any SSC.The proposed change does not impact any safety analysis assumptions and does not involve a change in initial conditions, system response times, or other parameters affecting any accident analysis.Therefore, the proposed change does not involve a significant reduction in a margin of safety.Based on the above, EGC concludes that the proposed amendment does not involve a 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.
Response: No.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes
The proposed change is administrative in nature and does not impact the operation, physical configuration, or function of plant structures, systems, or components (SSCs).
Also, the proposed change does not impact the initiators or assumptions of analyzed events, nor does the proposed change impact the mitigation of accidents or transient events. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed change is administrative in nature and does not alter plant configuration, require that new equipment be installed, alter assumptions made about accidents previously evaluated, or impact the operation or function of plant equipment. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed change is administrative in nature and does not involve any physical changes to plant SSCs, or the manner in which SSCs are operated, maintained, modified, tested, or inspected. The proposed change does not involve a change to any safety limits, limiting safety system settings, limiting conditions of operation, or design parameters for any SSC. The proposed change does not impact any safety analysis assumptions and does not involve a change in initial conditions, system response times, or other parameters affecting any accident analysis. Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, EGC concludes that the proposed amendment does not involve a 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.
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                         Attachment 1 Technical Specifications Changes                                                   Page 21 of 23
 
==
Conclusions:==
 
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.
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                              Attachment 1 Technical Specifications Changes                                                        Page 22 of 23
 
==3.0    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 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 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.
 
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative                                      Attachment 1 Technical Specifications Changes                                                Page 23 of 23
 
==4.0    REFERENCES==
: 1. Letter from M. P. Gallagher (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "License Amendment Request Incorporation of Previously NRC-Approved Generic Technical Specification Changes," dated June 24, 2004.
: 2. Letter from R. V. Guzman (U. S. Nuclear Regulatory Commission) to 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," dated May 10, 2006.
: 3. G. D. Edwards (PECO Nuclear) to U. S. Nuclear Regulatory Commission, "Peach Bottom Atomic Power Station, Units 2 and 3 License Change Application ECR 96-01511 ," dated December 24, 1998
: 4. Letter from J. A. Hutton (PECO Nuclear) to U. S. Nuclear Regulatory Commission, "Peach Bottom Atomic Power Station, Units 2 and 3 Revised Technical Specification Pages for License Change Application ECR 96-01511," dated September 27, 1999
: 5. Letter from B. C. Buckley (U. S. Nuclear Regulatory Commission) to J. A. Hutton (PECO Energy Company), "Peach Bottom Atomic Power Station, Unit Nos. 2 and 3
          - Issuance of Amendment RE: Changes Related to Loss of Power Instrumentation Set Points and Limits of Allowable Values for the 4KV Emergency Buses (TAC NOS.
MA4500 and MA4501 )," dated November 16, 1999
: 6. Letter from M. P. Gallagher (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "License Amendment Request Activation of the Trip Outputs of the Oscillation Power Range Monitor Portion of the Neutron Monitoring System ," dated February 27, 2004
: 7. Letter from M. P. Gallagher (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information License Amendment Request Activation of the Trip Outputs of the Oscillation Power Range Monitor Portion of the Power Range Neutron Monitoring System," dated September 13,2004
: 8. Letter from G. F. Wunder (U. S. Nuclear Regulatory Commission) to C. M. Crane (Exelon Generation Company, LLC), "Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendment RE: Activation of Oscillation Power Range Monitor Trip (TAC NOS. MC2219 and MC2220)," dated March 21, 2005
 
Attachment 2 Peach Bottom Atomic Power Station, Units 2 and 3 Markup of Proposed Technical Specifications Page Changes Unit Applicability Section      List of Affected Pages          Unit 2    Unit 3 2.1            5.0-21            X          X 2.1            5.0-22            X          X 2.2            3.8-13            X          X 2.3              1.3-2            X          X 2.3              1.3-6            X          X 2.3              1.3-7            X          X 2.3            3.1-20            X          X 2.3              3.8-2            X          X 2.3            3.8-42            X          X 2.3            3.8-43            X          X 2.4              1.4-3            X          X 2.5            3.3-65            X          X 2.5            3.3-26            X 2.6              3.3-7            X          X
 
Reporting Requirements 5.6 5.6  Reporting Requirements      (continued) 5.6.5        CORE OPERATING LIMITS REPORT (COLR)
: a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:
: 1. The Average Planar Linear Heat Generation Rate for Specification 3.2.1;
: 2. The Minimum Critical Power Ratio for Specifications 3.2.2 and 3.3.2.1;
: 3. The Linear Heat Generation Rate for Specification 3.2.3 ;
: 4. The Control Rod Block Instrumentation for Specification 3.3.2.1; and
: 5. The Oscillation Power Range Monitor (OPRM)
Instrumentation for Specification 3.3.1.1.
: b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:
1.
: 2. NEDC-32162P, "Maximum Extended Load Line Limit and ARTS Improvement Program Analyses for Peach Bottom Atomic.~
Power Station Units 2 and 3~f§?1S,,,.l, ~zrch", :~~
: 3. PECo-FMS-0001-A, "Steady-State Thermal Hydraulic Analysis of Peach Bottom Units 2 and 3 using the FIBWR Computer Code";
: 4. PEC0 - FM S-0002 -A, "Metho d for Cal cu1at i ng Tran s i en t Critical Power Ratios for Boiling Water Reactors (RETRAN-TCPPECo)";
: 5. PECo-FMS-0003-A, "Steady-State Fuel Performance Methods Report";
: 6. PECo-FMS-0004-A, "Methods for Performing BWR Systems Transient Analysis";
(continued)
PBAPS UNIT 2                                                          Amendmert No. 251
 
Reporting Requirements 5.6 5.6  Reporting Requirements 5.6.5        CORE OPERATING LIMITS REPORT (COLR)  (continued)
: 7. PECo-FMS-0005-A, "Methods for Performing BWR Steady-State Reactor Physics Analysis";
: 8. PECo-FMS-0006-A, "Methods for Performing BWR Reload Safety Evaluations"; and
: 9. NEDO-32465-A, "Reactor Stability Detect and Suppress Solutions Licensing Ba~thod0109Y And Reload Application0 (£igif( ~ J
                                        'A
: c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.
: d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.
5.6.6        Post Accident Monitoring (PAM) Instrumentation Report When a report is required by Condition B or F of LCO 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.
iJ 8APS  UNIT 2                          5.0-22                  Arnendll!Gnt No. 251
 
AC Sources--Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE                            FREQUENCY SR 3.8.1.13    ------------------NOTE---------------------
A single test at the specified Frequency will satisfy this Surveillance for both units.
Verify each DG's utomatic trips are          24 months
                ~y~a~se~ on ~n act~~r~~!mulated ECCS
                ~~~xcePt:                  "'--__
: a. Engine overspeed;
: b. Generator differential overcurrent;
{        c. Generator ground neutral overcurrent; and (continued)
PBAPS UNIT 2                        3.8-13                  Amendment No. 210
 
Completion Times 1.3 1.3 Completion Times DESCRIPTION      However, when a subsequent division, subsystem, component, (continued)  or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:
: a. Must exist concurrent with the first inoperability; and
: b. Must remain inoperable or not within limits after the first inoperabi11ty 1s resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
: a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours; or
: b. The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.
(continued)
PBAPS UNIT 2                        1.3-2                  Amendment No. 210
 
Completion Times 1.3 1.3 Completion Times EXAMPLES        EXAMPLE 1.3-3 (continued)
ACTIONS CONDITION        REQUIRED ACTION      COMPLETION TIME A. One          A.l Restore Function X          Function X subsystem          subsystem to inoperable.        OPERABLE status.
B. One          B. 1 Restore            72 hours Function Y          Function Y subsystem          subsystem to inoperable.        OPERABLE status.
: c. One          C.1 Restore              12 hours Function X          Function X subsystem          subsystem to inoperable.        OPERABLE status.
AND          OR One          C.2 Restore            12 hours Function Y          Function Y subsystem          subsystem to inoperable.        OPERABLE status.
(continued)
PBAPS UNIT 2                      1.3-6                    Amendment No. 210
 
Completion Times 1.3 1.3 Completion Times EXAMPLES                      EXAMPLE 1.3-3 (continued)
When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each subsystem, starting from the ti.e each subsystem was declared inoperable and the Condition was entered. A separate Completion Ti.e is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).
If Required Action C.2 is completed within the specified Completion Time, Conditions Band C are exited. If the Completion Time for Required Action A.l has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable
{i.e., initial entry into Condition A}.
J
                                ~~;Ji;il.iikiw.t'" ...." " A ,  ~~~*,;;fo>l>¥",~:I4:"-~~iilI\'",",'¥-~~~~'lfiiib'M4,lW~-",,,,,"'Y,(;j"'IiL;,J
                                                                                                                                            '-"'''~~~~..... tAlJ.w.~~.._~~!~", if."'_W.M,;.rAll**;>t~""",-
comPleti~"Otr:Tim;; of Conditio A and B are modified bi a '~""'"
I, (/ft;;
logical connec or, with a separ e measured fro the t1me 1t was scovered the LCO was n,i 10        day Completion Timt
                      ! met. In thi example, withou the separate Completio . Time, 1      it WOU1~bPossible to a1t nate between Condition ~, B,
                  .'        and C in 'ch a manner tha operation could contin                                                                                                            ."
                  *(        indefin" ely without ever restoring systems to.. t the LCO.
The se ' rate Completion 1me modified by the ph se "from
                  \ disc ery of failure                                      meet the LCO" is desi ed to prevent
                      \ ind inite continued peration while not mee ing the LCO.
                      \ Th" Completion Ti allows for an excepti to the normal
                        \    n me zero" for b inning the comPleti~n*1me "clock".                                                                                                          In
                        ! t is instance, t. e Completion Time "ti zero" is specified                                                                                                                                /
                          " as comencing , the time the LeO was, nitially not met,                                                                                                                                /
                          \\ instead of at he time the associated Condition was entered.//                                                                                                                      I
                            '-----__                                                  --                        -----~*_"'_*-                    ..        ._,_w~._,_.        __ ~ ,_~p,*'"
e'~"-'''''A~"tccmti,n ued )
It is possi~le to .altema~e bem:een Conditions A, B, and C in such a manner that operation                                                                                                      't, co~ld contmue mdefinitely wIthout ever restoring systems to meet the LCO. However domg so would be inconsistent with the basis of the Completion Times. Therefore th~re                                                                                                        "".)
                                                                                                                                                                                                          ~ '\
shall be ~?ministrative c~ntrol~ to limit ~he maximum time allowed for any combi~ation ofCondltl~n~ that. result In a smgle contiguous occurrence of failing to meet the LCO.
These admmlstratlve controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.
                                                                                                                                                                                                            )
PBAPS UNIT 2                                                    1.3-7                                                                      Amendment No. 210
 
SLC System 3.1.7 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC) System LCO 3.1.7        Two SLC subsystems shall be OPERABLE.
APPLICABILITY:    MODES 1 and 2.
ACTIONS CONDITION                  REQUIRED ACTION          COMPLETION TIME A. Concentration of boron  A.I      Verify the            8 hours in solution> 9.82%                concentration and weight.                          temperature of boron in solution and pump suction piping        Once per temperature are        12 hours within the limits of  thereafter Figure 3.1.7-1.
AND A.2      Restore concentration of boron in solution
                                                                                      )
to ~ 9.821 weight.
                                                                                        / ""
J B. One SLC subsystem          B.l    Restore SLC subsystem  7 days inoperable for reasons            to OPERABLE status.
other than                                              ~~,/
Condition A.
10 days fm      "'.\
discoven of          \)
failur to meet        .
the 0          /
(continued)
PBAPS UNIT 2                          3.1-20                  Amendment No. 210
 
AC Sources-Operating 3.8.1 ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOT E - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
LCO 3.0.4.b is not applicable to DGs.
CONDITION                                            REQUIRED ACTION                              COMPLETION TIME A.      One offsite circuit                            A .1            Perform SR 3.8.1.1                          1 hour inoperable.                                                    for OPERABLE offsite circuits.
Once per 8 hours thereafter AND A.2            Declare required                            24 hours from feature(s) with no                          discovery of no offsite power                              offsite power to available inoperable                      one 4 kV when the redundant                        emergency bus required feature(s)                        concurrent with are inoperable.                            inoperability of redundant required feature(s)
A.3            Restore offsite circuit to OPERABLE status.
(continued)
PBAPS UNIT 2                                                          3.8-2                                      Amendment No. 252
 
Distribution Systems--Operating 3.8.7 ACTIONS CONDITION                  REQUIRED ACTION          COMPLETION TIME A. One or more required    -------------NOTE------------
Unit 3 AC electrical  Enter applicable Conditions power distribution    and Required Actions of LCO subsystems inoperable. 3.8.4, "DC Sources--Operating," when Condition A results in a de-energization of a required Unit 3 125 V battery charger.
A.l      Restore required        7 days Unit 3 AC electrical power distribution subsystem(s) to OPERABLE status.
B. One requi red Unit 3 DC B.l      Restore Unit 3 DC      12 hours electrical power                  electrical power distribution subsystem          distribution inoperable.                      subsystem to OPERABLE status.
C. One Unit 2 AC          C.1      Restore Unit 2 AC electrical power                electrical power distribution subsystem          distribution inoperable.                      subsystem to OPERABLE status.
(continued)
PBAPS UNIT 2                        3.8-42                    Amendment No. 210
 
Distribution Systems-Operating 3.8.7 ACTIONS  (continued)
CONDITION                  REQUIRED ACTION          COMPLETION TIME D. One Unit 2 DC              0.1    Restore Unit 2 DC electrical power                  electrical power distribution subsystem            distribution inoperable.                      subsystem to OPERABLE status.
E. Required Action and        E.1    Be in MODE 3.            12 hours associated Completion Time of Condition A, B, C, or 0 not met.
F. Two or more i noperabl e  F.1    Enter LCO 3.0.3.        Immediately electrical power distribution subsystems that result in a loss of function.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                              FREQUENCY SR  3.8.7.1    Verify:                                        7 days
: a. Correct breaker alignments to required AC electrical power distribution subsystems; and
: b. Indicated power availability to required AC and DC electrical power distribution subsystems.
PBAPS UNIT 2                          3.8-43                  Amendment No. 261
 
Frequency 1.4 Sr< ~ L'o.
afpUcub)e, 1.4 Frequency
                                                                      ~~-~
EXAMPLES      EXAMPLE 1.4-1  (co  inued) ~~                ,~~~~.'3)
If the interval s sp~{iied by SR 3.0. is e~ldr~nl1e the unit 1s no inK'MODE or other sp cified condition in the Applicab* it~ f the LCO for whi performance of the SR is required,      Surveillance must, e performed within the      l~
Frequency requirements of SR 3.0. ~ or to entr in              ~. .
        ~..~E or othgr spet:ified concjiUQ!
* a* re        0 S    ould l      ~!is~  ?"  0io~tipn ~~/a;!I . 4.
EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE                      FREQUENCY Verify flow is within limits.              Once within 12 hours after CP: 25% RTP AND 24 hours thereafter Example 1.4-2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector RAND- indicates that both Frequency requirements must be met. Each time reactor power is increased from a power level < 251 RTP to
              ~ 251 RTP, the Surveillance must be performed within 12 hours.
The use of *once R indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by RAND-). This type of Frequency does not qualify for the extension allowed by SR 3.0.2.
(continued)
PBAPS UNIT 2                      1.4-3                    Amendment No. 210
 
LOP  Instrumentation 3.3.8.1 Table 3.3.8.1-1 (page 1 of 1)
Loss of Power Instrumentation REQUIRED CHANNELS        SURVEILLANCE                  ALLOWABLE FUNCTION                              PER BUS        REQUIREMENTS                    VALUE
: 1. 4 kV Emergency Bus Undervoltage (Loss of Voltage)
: a. Bus Undervoltage                                              SR 3.3.8.1.3        NA SR 3.3.8.1.4
: 2. 4 kV Emergency Bus Undervoltage (Degraded Voltage Low Setting)
: a. Bus Undervoltage                                    2        SR 3.3.8.1.1        ~  2286 V and  ~ 2706 V (1 per      SR 3.3.8.1.2 source)        SR 3.3.8.1.4
: b. Time Delay                                          2        SR 3.3.8.1.1        ~  1.5 seconds and (1 per      SR 3.3.8.1.2        ~  2.1 seconds source)        SR 3.3.8.1.4
: 3. 4 kV Emergency Bus Undervoltage (Degraded Voltage High Setting)
: 8. Bus Undervoltage                                    2        SR 3.3.8.1.1        ~  3409 V and s 3829 V (1 per        SR 3.3.8.1.2 source)        SR 3.3.8.1.4
: b. Time Delay                                          2        SR 3.3.8.1.1        ~  23.0 seconds and (1 per      SR 3.3.8.1.2        ~  37.0 seconds source)      SR 3.3.8.1.4
: 4. 4 kV Emergency Bus Undervoltage (Degraded Voltage LOCA)
: 8. Bus Undervoltage                                    2 (1 per SR 3.3.8.1.1 SR 3.3.8.1.2
                                                                                                ~  3766 V and S 3836 V  ~
source)        SR 3.3.8.1.4
: b. Time Delay                                          2        SR 3.3.8.1.1        ~ 9.2 seconds ~.-J (1 per        SR 3.3.8.1.2        ~ 10.8 seconds' a) source)        SR 3.3.8.1.4
: 5. 4 kV Emergency Bus Undervoltage (Degraded Voltage non-LOCA)
: a. Bus Undervoltage                                    2 (1 per source)
SR 3.3.8.1.1 SR 3.3.8.1.2 SR 3.3.8.1.4
                                                                                                ~  4116 V and S 4186    ve'..AJ
: b. Time Delay                                          2        SR 3.3.8.1.1        ~    57.8  s~s    and ~ 64.2 (1 per        SR 3.3.8.1.2        seCOndS~ ~
~                                                                                    ~A~V5rn~ I~_~
{      :~~owable~ v3~~1esV a;r:: ~ 3713 V with internal                              seconds and    ~  1.1 sec  s,          'I' 4.b      ~ 8.4 seconds and ~ .6 seconds,
                ~ 4065 V and ~ 408 V, with internal I      5.a 5.b      ~ 57.0 seconds a ~ 63.0 seconds.
-~J!pst~~po~ompletion of modification 96-01511, pBA                                  *_~_.n_.~.",~~=
later than Mar:~_1~",~q9~.:---~/
                                                        --_*.- ~:~'6'5---J_' __"__'            ~      Amendment No. 230
                                                                                                                          /'
I
 
PAM Instrumentation 3.3.3.1 Table 3.3.3.1-1 (page 1 of 1)
Post Accident Monitoring Instrumentation CONDITIONS REFERENCED REQUIRED              FROM REQUIRED FUNCTION                                      CHANNELS                ACTION 0.1
: 1. Reactor Pressure                                                      2                        E
: 2. Reactor Vessel Water Level  (Wide Range)                            2                        E
: 3. Reactor Vessel Water Level  (Fuel Zone)                              2                        E
: 4. Suppressfon Chamber Water Level  (Wide Range)                        2                        E
: 5. Drywell Pressure  (Wide Range)                                        2                        E
: 6. Drywell Pressure  (Subatmospheric Range)                              2                        E
: 7. Drywell High Range Radiatfon                                          2                        F
: 8. Penetratfon ~IV Positfon                                  2 per penetration flow path (a)(b)
E 9.
10.
Deleted Deleted
                          ~
: 11. Suppressfon Chamber Water Temperature                              2(c)                      E (a)  Not required for isolation valves whose associated penetration flow path is fsolated by at least one closed and deactfvated automatfc valve, closed manual valve, blind flange, or check valve wfth flow through the valve secured.
(b)  Only one posftion indication channel fs required for penetration flow paths with only one installed control room indication channel.
(c)  Each channel requfres 10 resfstance temperature detectors (RTDs) to be OPERABLE with no two adjacent RTDs inoperable.
PBAPS UNIT 2                                          3.3-26                              Amendment No. 259
 
RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 <page 1 of 3)
Reactor Protection System Instrumentation APPLICABLE                CONDITIONS MODES OR    REQUIRED    REFERENCED OTHER      CHANNElS      FROM SPECIFIED    PER TRIP    REQUIRED          SURVEILLANCE            ALLOWABLE FUNCTION            CONDITIONS      SYSTEM    ACTION D.l        REQUIREMENTS              VALUE
: 1. Wide Range Neutron Moni tors
: a. Peri od - Short            2            3          G          SR 3.3.1.1.1          ~ 13 seconds SR 3.3.1.1.5 SR 3.3.1.1.12 SR 3.3.1.1.17 SR 3.3.1.1. 18 5(a)            3          H          SR  3.3.1.1.1        ~ 13 seconds SR  3.3.1.1.6 SR  3.3.1.1.12 SR  3.3.1.1.17 SR  3.3.1.1.18
: b. Inop                        2            3            G          SR 3.3.1.1.5        NA SR 3.3.1.1.17 5(a)          3            H          SR  3.3.1.1.6      NA SR  3.3.1.1.17
: 2. Average Power Range Monitors
: a. Neutron Flux-High          2                        G        SR 3.3.1.1.1        : ; 15.0% RTP (Setdown)                                                      SR 3.3.1.1.8 SR 3.3.1.1.11 SR 3.3.1.1.12
: b. Simulated Thermal                                    F          SR 3.3.1.1.1        : ; 0.65 W Power-High                                                      SR 3.3.1.1.2        + 63.7S RTP(b) and::;; 118.0%
RTP SR 3.3.1.1.8 SR 3.3.1.1.11 SR 3.3.1.1.12
: c. Neutron Flux-High                                    F          SR 3.3.1.1.1      : ; 119.7% RTP SR 3.3.1.1.2 SR 3.3.1.1.8 SR 3.3.1.1.11 SR 3.3.1.1.12
: d. Inop                      1,2                        G        SR    3.3.1.1.11    NA
: e. 2-0ut-Of-4 Voter            1.2                        G        SR 3.3.1.1.1        NA SR 3.3.1.1.11 SR 3.3.1.1.17 SR 3.3.1.1. 18
: f. OPRM Upscale              ~25%                                  SR 3.3.1.1.1 RTP                                  SR 3.3.1.1.8 SR 3.3.1.1.11 SR 3.3.1.1.12 SR 3.3.1.1.19 (conti nued)
(a)  With any control rod withdrawn from a core cell containing one or more fuel assemblies.
(b)  0.65 (W - AW) + 63.7% RTP when reset for single loop operation per LCO 3.4.1, "Recirculation Loops Operating."
(c)  Each APRM channel provides inputs to both trip systems.
(d)  See COLR for OPRM period based detection algorithm (PBDA) setpoint limits.
PBAPS UNIT 2                                            3.]-7                                Amend~ent        No. 251
 
Reporting Requirements 5.6 5.6  Reporting Requirements                          (continued) 5.6.5        CORE OPERATING LIMITS REPORT <COLR)
: a. Core operating limits shall be established prior to ,each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:
: 1. The Average Planar Linear Heat Generation Rate for Specification 3.2.1;                                                                                I"
: 2. The Minimum Critical Power Ratio for Specifications 3.2.2 and 3.3.2.1;
: 3. The Linear Heat Generation Rate for Specification 3.2.3;
: 4. The Control Rod Block Instrumentation for Specification 3.3.2.1; and
: 5. The Oscillation Power Range Monitor (OPRM)
Instrumentation for Specification 3.3.1.1.
: b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:
: 1. NED E-24011 -P-A, "G~ ryer ~l~l:~t.~ iE? ~~ry9a r;~AP, p,]iSi3 ~,,M.~~
for Reactor Fuel "1'(1' atesl appr~'vers~'l0' '='~rS""specifi ed
                        <!n ~-rOt,~'i"''''''''-''Y''''''''''~'''''~~''''''''''''~~-'w_",--,,~''''''"'''>,-,,"      ,~ _ _''
                          'f""'*:~"*",'l1*'_*#;W\ffl*. ..... . ..
: 2. NEDC-32162P, "MaXimu,m Extended LO,ad Line, Limit, an~d                                          ARTS.
Improvement Program Analyses for Peach ..J4ltt~ Ato, .
Power Stat ion Uni ts 2 and 3<9' ~ ion j, MY:ch, 199 ;
(,                                .
: 3. PECo-FMS-OOOI-A, "Steady-State Thermal Hydraullc Analysis of Peach Bottom Units 2 and 3 using the FIBWR Computer Code";
: 4. PECo-FMS-0002-A, "Method for Calculating Transient Critical Power Ratios for Boiling Water Reactors (RETRAN-TCPPECo)";
: 5. PECo-FMS-0003-A, "Steady-State Fuel Performance Methods Report";
: 6. PECo-FMS-0004-A, "Methods for Performing BWR Systems Transient Analysis";
(continued)
PBAPS UNIT 3                                                      5.0-21                                      Amendment No. 254
 
Reporting Requirements 5.6 5.6  Reporting Requirements 5.6.5        CORE OPERATING LIMITS REPORT (COLR)  (continued)
: 7. PECb-FMS-0005-A, "Methods for Performing BWR Steady-State Reactor Physics Analysis";
: 8. PECo-FMS-0006-A, "Methods for Performing BWR Reload Safety Evaluations"; and
: 9. NEDO-32465-A, "Reactor Stabilit~...:Detect and Suppress Solutions LiCenS~~.M.~~Ol09YAnd Reload APplicationW ~t          y-
: c. The core o~erating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident'analysis limits) of the safety analysis are met.
: d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.                  "
5.6.6        Post Accident Monitoring (PAM) Instrumentation Report When a report is required by Condition B or F of LCO 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.
PBAPS UNIT 3                          5.0-22                    Amendment No. 254
 
AC Sources--Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEI.LLANCE                          FREQUENCY SR 3.8.1.13    ------------------NOTE---------------------
A single test at the specified Frequency will satisfy this Surveillance for both units.
Veri fy each DG's
* utomatic trips are        24 months bypassed on an actual or simulated ECCS initiation Signal'fxcePt:"~-'"
a:    Eng~peed;
: b. Generator differential overcurrent;
: c. Generator ground neutral overcurrent; and Manual cardox initiation.
(continued)
PBAPS UNIT 3                            3.8-13                Amendment No. 214
 
Completion Times 1.3 1.3 Completion Times DESCRIPTION      However, when a subsequent division, subsystem, component, (continued)    or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:
: a. Must exist concurrent with the first inoperability; and
: b. Must remain inoperable or not within limits after the first inoperability is resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
: a. The stated Completion Time, as mea~ured from the initial entry into the Condition, plus an additional 24 hours; or
: b. The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.
The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., .
                "once per 8 hours," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phras
                *from discovery..
* xamp          *    .:a;                    e 0 '\
p etion Time.
for Condition A and    e 10 da e ompl        ~i... tf..... J... )..
                                                                    . oU.. T 1.. ma~~
(continued)
PBAPS UNIT 3                        1.3-2                    Amendment No. 214
 
Completion Times 1.3 1.3 Completion Times EXAMPLES        EXAMPLE 1.3-3 (continued)
ACTIONS CONDITION        REQUIRED ACTION    COMPLETION TIME A. One            A.I Restore            7 days Function X        Function X subsystem          subsystem to inoperable.        OPERABLE status.
B. One            8.1 Restore Function Y          Function Y subsystem          subsystem to inoperable.        OPERABLE status.
C. One            C.I Restore            12 hours Function X          Function X subsystem          subsystem to inoperable.        OPERABLE status.
AND            OR One            C.2 Restore            12 hours Function Y          Function Y subsystem          subsystem to inoperable.        OPERABLE status.
(continued)
PBAPS UNIT 3                        1.3-6                  Amendment No. 214
 
Completion Times 1.3 1.3 Completion Times EXAMPLES                    EXAMPLE 1.3-3 (continued)
When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition 8 are concu applicable. The Completion Times for Condition A and rrently Condition B are tracked separ ately for each subsy starti ng from the time each subsystem was declaredstem, inoperable and the Condition was entered. A separ Completion Time is estab lishe d for Condition C and ate                    tracked from the time the second subsystem was declared inope                                  rable (i.e. , the time the situa tion described in Condition C                                        was discovered).
If Required Action C.2 is completed within the speci fied Completion Time, Conditions 8 and C are exite d. If the li;:1~~:;~~~!!I~~~i~@i!~i1:~:;~:~il~~g;:f;~~he. J i;rtre~"tcomple"iiOn~T'i";;;s of Condition A-;~-B'-are modif                                          b'y-~a\
                      ! logical connector/... with a separ e 10 day Comp ~ tion ied                            Time                      \
I measured        from ~h. time it was scovered the 0 was not met. In this .. ample, withou the separat.e ompletion Ti,me!, \1\
it would be p sible to alt nate between nditio ns A, B,                                                        I and C in su a manner th o'perati on co d cont inue                                                        ,. t indef inite without ev resto ring sy ems to meet The separ te Completi Time modi fie y the phrase the                          Rfr L*. ,
i discove~ of failu r          0 meet the LC        is designed to . event I indefi te continu operation who e not meeting the co.                                                          I This ompletion me allows for                exception to th normal )
Uti zero" for eginning the mpletion Time "cl k". In
* thi instan ce, the Completion ime "time zero" i speci                                        fied
* as commencing at the time the LCD was initi ally not met, instead of at the time the associated Condition was entered~ .
                    . . . ._ _    ---- ---- ---- .~~~
i4J~ ln~~ >~.~ ,-'"            . 'ffl'-'R'4'~:f,~~-.y4~4'''''-.i!iif-r is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO.
However, doing so would be inconsistent with the basis of the Completion Times. Therefo re, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LeO.
These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.
                            '------'------------~                      .-.- ---
PBAPS UNIT 3                                      1.3-7                          Amendment No. 214
 
SLC System 3.1.7 3.1  REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC) System LCO 3.1.7        Two SLC subsystems shall be OPERABLE.
APPLICABILITY:    MODES ,I and 2.
ACTIONS CONDITION                  REQUIRED ACTION        COMPLETION TIME A. Concentrat ion of boron    A.I    Verify the            8 hours in solution> 9.82%                concentration and weight.                          temperature of boron in solution and pump suction piping        Once per temperature are      12 hours within the limits of  thereafter Figure 3.1.7-1.
AND A.2    Restore concentration of boron in solution 72 hours
                                                                          ,~~
                                                                              ~
to ~ 9.82% weight.
B. One SLC subsystem          B.1    Restore SLC subsystem 7 days inoperable for reasons            to OPERABLE status.
other than Condition A.
(continued)
PBAPS UNIT 3                          3.1-20                  Amendment No. 214
 
AC Sources-Operating 3.8.1 ACTIONS
  - - - - - - - - - - - - - - - - - - - - - ~ - - - - - - - - - - - - - - - NOTE - - - - - - - ~ - - - - - - - - - - - - - - - - - -'- - - - - - - - --
LCO 3.0.4.b is not applicable to DGs.
  - - - - -  - - - - -  - - - - - - - - - - - - - - - - - - -  - - - - - - - -  - - - -  - - - - - - - - ~ 1- - - - - - - - - - -  - - - - -  - - - - - - - - - - -  I CONDITION                                              REQUIRED ACTION                                      COMPLETION TIME A.      One offsite circuit                              A.I              Perform SR 3.8.1.1                                1 hour                          1,1 inoperable.                                                        for OPERABLE offsite circui.ts.
Once per 8 hours, thereafter AND I
A.2              Declare required                                    24 hours from feature(s) with no                                  discovery of no offsite power                                      offsite power to available inoperable                                one 4 kV when the redundant                                  emergency bus requiredfeature(s)                                  concurrent with are in~p~rable.                                    inoperability of redundant required feature(s)
A.3              Restore offsite circuit to OPERABLE status.
(continued)
PBAPS UNIT 3                                                                3.8-2                                                Amendment No. 255
 
Distr ibutio n Systems--Operating 3.8.7 A,CTIONS CONDITION                    REQUIRED ACTION              COMPLETION TIME A. ,One or more required      ------ ------ -NOT E---- ------ --
Unit 2 AC elect rical    Enter applicable Conditions power distri butio n    and Required Actions of LCO subsystems inoperable. 3.8.4 , "DC Sources--Operating," when Condition A resul ts in a de-energization of a required Unit 2 125 V batte ry charger.
A.l        Restore required          7 days Unit 2 AC elect rical power distri butio n subsystem(s) to OPERABLE statu s.
B. One Unit 2 DC              B.l        Restore Unit 2 DC          12 hours elect rical power                  elect rical power distri butio n subsystem            distri butio n inoperable.                        subsystem to OPERABLE statu s.
C. One Unit 3 AC              e.l      Restore Unit 3 AC          8 hours elect rical power                  elect rical power distri butio n subsystem            distri butio n inoperable.                        subsystem to OPERABLE statu s.
(continued)
PBAPS UNIT 3                          3.8-42                        Amendment No. 214
 
Distribution Systems-Operating 3.8.7 ACTIONS    (continued)
CONDITION                    REQUIRED ACTION          COMPLETION TIME D. One Unit 3 DC              0.1      Restore Unit 3 DC      2 hours electrical power                    electrical power distribution subsystem            distribution inoperable.                        subsystem to OPERABLE status.
E. Required Action and        E.1    Be in MODE 3.            12 hours associated Completion Time of Condition A, B, C, or 0 not met.
F. Two or more inoperable    F.1      Enter LCO 3.0.3.        Immediately electrical power distribution subsystems that result in a loss of function.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                              FREQUENCY SR  3.8.7.1      Verify:                                        7 days
: a. Correct breaker alignments to required AC electrical power distribution subsystems; and
: b. Indicated power availability to required AC and DC electrical power distribution subsystems.
PBAPS UNIT 3                            3.8-43                    Amendment No. 265
 
Frequency 1.4 1.4 Frequency EXAMPLES          EXAMPLE 1.4-1 EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE                  FREQUENCY Verify flow is within limit s.          Once within 12 hours after
                                                              ~ 25% RTP AND 24 hours there after Example 1.4-2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type    shown in Example 1.4-1. The logical connector "AND" indicates that both Frequency requirements must be met.
reactor power is increased from a power level <Each  time 25% RTP to
                ~ 251 RTP, the Surveillance must be performed within 12 hours.
The use of "once" indicates a single performance satis fy the specified Frequency (assuming no otherwill Frequencies are connected by "AND"l. This type does not qualify for the extension allowed by SR of3.0.2 Frequency
                                                                          .
(continued)
PBAPS UNIT 3                        1.4-3                  Amendment No. 214


== Conclusions:==
lOP Instrumentation 3.3.8 .1 TabLe 3.3.8.1 -1 (page 1 of 1)
Loss of Power Instrumentation REQUIRED CHANNELS        SURVEILLANCE                  ALLO\oJABLE FUNCTION                    PER BUS        REQUIREMENTS                    VALUE
: 1. 4 kV Emergency Bus Undervoltage (Loss of Voltage)
: a. Bus Undervoltage                                  SR 3.3.8.1 .3      NA SR 3.3.8.1 .4
: 2. 4 kV Emergency Bus Undervoltage (Degraded Voltage Low Setting )
: a. Bus Undervoltage                        2        SR 3.3.8.1 .1        ~  2286 V and s 2706 V (1 per        SR 3.3.8.1 .2 source)        SR 3.3.8.1 .4
: b. Time Delay                              2          SR 3.3.8.1 .1      ~  1.5 seconds and (1 per        SR 3.3.8.1 .2      s 2.1 seconds source)        SR 3.3.8.1 .4
: 3. 4 kV Emergency Bus Undervoltage (Degraded VoLtage High Setting )
: a. Bus Undervoltage                        2        SR 3.3.8.1 .1      ~  3409 V and s 3829 V (1  per      SR 3.3.8.1 .2 source)        SR 3.3.8.1 .4
: b. Time Delay                              2          SR 3.3.8.1 .1      ~  23.0 seconds and (1 per        SR 3.3.8.1 .2      S 37.0 seconds source)          SR 3.3.8.1 .4
: 4. 4 kV Emergency Bus Undervoltage (Degraded Voltage LOCA)
: a. Bus Undervoltage                      2          SR 3.3.8.1 .1                                ,e\) '/
                                                                                  ~    3766 V and s 3836    V~
(1  per      SR 3.3.8.1 .2 source)          SR 3.3.8.1 .4
: b. Time Delay                              2        SR 3.3.8.1 .1      ~  9.2 seconds al'ld.., ~
(1  per      SR 3.3.8.1 .2      S    10.8 seCOndS~
source)          SR 3.3.8.1 .4
: 5. 4 kV Emergency Bus UndervoLtage (Degraded Voltage non-LOCAl
: a. Bus Undervoltage (1
source) 2 per SR 3.3.8.1 .1 SR 3.3.8.1 .2 SR 3.3.8.1 .4
                                                                                  ~  4116 V and  ~  4186  vi f
: b.      Time Delay                            2        SR 3.3.8.1 .1      ~  57.8    s~~a nd      s 64.2 (1 per        SR 3.3.8.1 .2      seCOn dS~            -
source)        SR 3.3.8.1 .4 a particu Lar Function 4 or 5 elay, its seconds, no later than March 1 2000.
Amen ment No. 235


Attachment 1 Page 21 of 23 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.
RPS Instrumentation 3.3.1 .1 Table 3.j.1.1- 1 (page 1 of 3)
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes 3.0 ENVIRONMENTAL CONSIDERATION Attachment 1 Page 22 of 23 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.
Reactor Protecti on System Instrum entation APPLICABLE                    CONDITIONS MODES OR      REQUIRED      REFERENCED OTHER      CHANNELS        FROM SPECIFIED      PER TRIP      REQUIRED            SURVEILLANCE FU'NCTION      CONDITIONS                                                                  ALLOWABLE SYSTEM      ACTION D.1            REQUIREMENTS              VALUE
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).
: 1. Wide Range Neutron Monitors
Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
: a.      Period*S hort          2            3                            SR G                  3.3.1.1 .1      ~ 13 seconds SR    3.3.1.1 .5 SR    3.3.1.1 .12 SR    3.3.1.1 .17 SR    3.3.1.1 .18 5(a)            3              H            SR    3.3.1.1 .1    ~  13 seconds SR    3.3.1.1 .6 SR    3.3.1.1 .12 SR    3.3.1.1 .17 SR    3.3.1.1 .18
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes
: b. I nop                  2            3              G            SR    3.3.1.1 .5      NA SR    3.3.1.1 .17 5(a)           3              H            SR 3.3.1.1 .6        NA SR 3.3.1.1 .17
: 2. Average Power Range Monitors
: a. Neutron Flux-High        2 (Setdown)
G            SR    3.3.1.1 .1    s 15.0% RTP SR    3.3.1.1 .8 SR    3.3.1.1. 11 SR    3.3.1.1 .12
: b. Simulated Thermal                                    F            SR Power*High                                                                3.3.1.1 .1      S 0.65 W SR    3.3.1.1 .2      + 63.7% RTP(b) and S  118.0%
RTP SR    3.3.1.1 .8 SR    3.3.1.1. 11 SR    3.3.1.1 .12
: c. Neutron Flux-High                                      F            SR    3.3.1.1 .1    S  119.7% RTP SR      3.3.1.1 .2 SR    3.3.1.1 .8 SR    3.3.1.1. 11 SR    3.3.1.1 .12
: d. In,op                  1,2                                        SR G                  3.3.1.1. 11    NA
: e. 2-0ut-O f*4 Voter      1,2                            G            SR    3.3.1.1 .1      NA SR    3.3.1.1. 11 SR      3.3.1.1. 17 SR      3.3.1.1 .18
: f. OPRM Upsca 1e          ~25%                                        SR      3.3.1.1 .1 RTP                                        SR    3.3.1.1 .8 SR    3.3.1.1. 11 SR    3.3.1.1. 12 SR    3.3.1.1. 19 (continued)
(a) With any control rod withdrawn from a core cell contain ing one or more fuel assemblies.
(b) 0.65 (W . 4Wl + 63.7% RTP when reset for single loop operation per LCO 3.4.1, "Recirculation Loops Operating."
(c) Each APRM channel provides inputs to both trip systems.
(d) See COLR for OPRM period based detectio n algorith m (PBDA) setpoin t limits.
PBAPS UNIT 3                                          3.3-7                                        Amendment No. 254


==4.0 REFERENCES==
Attachment 3 Peach Bottom Atomic Power Station, Units 2 and 3 Markup of Proposed Technical Specifications Bases Page Changes Unit Applicability Section      List of Affected Pages          Unit 2    Unit 3 2.2            B 3.8-30          X          X 2.3            B 3.1-42          X          X 2.3            B 3.1-43          X          X 2.3              B 3.8-8          X          X 2.3              B 3.8-9          X          X 2.3            B 3.8-89          X          X 2.3            B 3.8-90          X          X 2.3            B 3.8-91          X          X


Attachment 1 Page 23 of 23 1.Letter from M.P.Gallagher (Exelon Generation Company, LLC)to U.S.Nuclear Regulatory Commission,"License Amendment Request Incorporation of Previously NRC-Approved Generic Technical Specification Changes," dated June 24, 2004.2.Letter from R.V.Guzman (U.S.Nuclear Regulatory Commission) to C.M.Crane (Exelon Generation Company, LLC),"Peach Bottom Atomic Power Station, Units 2 and3-Issuance of Amendments RE: Incorporation of Previously NRC-Approved Generic Technical Specification Changes," dated May 10, 2006.3.G.D.Edwards (PECO Nuclear)to U.S.Nuclear Regulatory Commission,"Peach Bottom Atomic PowerStation,Units 2 and 3 License Change Application ECR01511 ," dated December 24, 1998 4.Letter from J.A.Hutton (PECO Nuclear)to U.S.Nuclear Regulatory Commission,"Peach Bottom Atomic Power Station, Units 2 and 3 Revised Technical Specification Pages for License Change Application ECR 96-01511," dated September 27, 1999 5.Letter from B.C.Buckley (U.S.Nuclear Regulatory Commission) to J.A.Hutton (PECO Energy Company),"Peach Bottom Atomic Power Station, Unit Nos.2 and 3-Issuance of Amendment RE: Changes Related to Loss of Power Instrumentation Set Points and Limits of Allowable Values for the 4KV Emergency Buses (T AC NOS.MA4500 and MA4501)," dated November 16, 1999 6.Letter from M.P.Gallagher (Exelon Generation Company, LLC)to U.S.Nuclear Regulatory Commission,"License Amendment Request Activation of the Trip Outputs of the Oscillation Power Range Monitor Portion of the Neutron Monitoring System ," dated February 27, 2004 7.Letter from M.P.Gallagher (Exelon Generation Company, LLC)to U.S.Nuclear Regulatory Commission,"Response to Request for Additional Information License Amendment Request Activation of the Trip Outputs of the Oscillation Power Range Monitor Portion of the Power Range Neutron Monitoring System," dated September 13,2004 8.Letter from G.F.Wunder (U.S.Nuclear Regulatory Commission) to C.M.Crane (Exelon Generation Company, LLC),"Peach Bottom Atomic Power Station, Units 2 and3-Issuance of Amendment RE: Activation of Oscillation Power Range Monitor Trip (TAC NOS.MC2219 and MC2220)," dated March 21, 2005 Attachment 2 Peach Bottom Atomic Power Station, Units 2 and 3 Markup of Proposed Technical Specifications Page ChangesUnitApplicability Section List of Affected Pages Unit 2 Unit 3 2.1 5.0-21 X X 2.1 5.0-22XX 2.2 3.8-13XX 2.3 1.3-2XX 2.3 1.3-6 X X 2.3 1.3-7XX 2.3 3.1-20 X X 2.3 3.8-2XX 2.3 3.8-42 X X 2.3 3.8-43XX 2.4 1.4-3XX 2.5 3.3-65 X X 2.5 3.3-26 X 2.6 3.3-7XX Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.5 CORE OPERATING LIMITS REPORT (COLR)a.Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:
AC Sources - Operat i ng B 3.8.1 BASES SURVEILLANCE          S8 3.8.1.12 (continued)
1.The Average Planar Linear Heat Generation Rate for Specification 3.2.1;2.The Minimum Critical Power Ratio for Specifications 3.2.2 and 3.3.2.1;3.The Linear Heat Generation Rate for Specification 3.2.3;4.The Control Rod Block Instrumentation for Specification 3.3.2.1;and 5.The Oscillation Power Range Monitor (OPRM)Instrumentation for Specification 3.3.1.1.b.The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:
REQUIREMENTS The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with the expected fuel cycle lengths.
1.2.NEDC-32162P,"Maximum Extended Load Line Limit and ARTS Improvement Program Analyses for Peach Bottom Power Station Units 2 and3.PECo-FMS-0001-A,"Steady-State Thermal Hydraulic Analysis of Peach Bottom Units 2 and 3 using the FIBWR Computer Code";4.PEC0-FMS-0002-A,"M e tho d for Calcu 1 at ingT ransi en t Critical Power Ratios for Boiling Water Reactors (RETRAN-TCPPECo)";
This S8 is modified by a Note. The reason for the Note is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coo1,ant and oil being continuously circulated and temperature maintained cons i stent wi th manufacturerGr,~.elll1lencla,.,t.ioR,.".~'. -,'-,..L-;"'.'~---""'.'.""'.'''----'_, . . . ,
5.PECo-FMS-0003-A,"Steady-State Fuel Performance Methods Report";6.PECo-FMS-0004-A,"Methods for Performing BWR Systems Transient Analysis";(continued)
pv emt7JCvx1J', . Qhv~m{J.AJ~ .
PBAPS UNIT 2 Amendmert No.251 Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 5.6.6 CORE OPERATING LIMITS REPORT (COLR)(continued) 7.PECo-FMS-0005-A,"Methods for Performing BWRState Reactor Physics Analysis";
fA) I 'II be 'k.s:rer)                   r: 6r *J()eJ l \      J
8.PECo-FMS-0006-A,"Methods for Performing BWR Reload Safety Evaluations";
                                                                                                                                                      \
and 9.NEDO-32465-A,"Reactor Stability Detect and Suppress Solutions Licensing And Reload Application0
SR 3.8.1.13                             VIrJ-~;~~(.~~>)
(&#xa3;igif('A c.The core operating limits shall be determined such that all applicable limits (e.g., fuelthermalmechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS)limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits)of the safety analysis are met.d.The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.Post Accident Monitoring (PAM)Instrumentation Report When a report is required by Condition B or F of LCO 3.3.3.1,"Post Accident Monitoring (PAM)Instrumentation," a report shall be submitted within the following 14 days.The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.i J 8APS UNIT 2 5.0-22 Arnendll!Gnt No.251 AC Sources--Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE SR 3.8.1.13------------------NOTE---------------------
Consistent with Regulatory Guide 1.9 {Ref:-3r:----E.. -"'--~---~~\
A single test at the specified Frequency will satisfy this Surveillance for both units.FREQUENCY{PBAPS UNIT 2 Verify each DG's utomatic trips are on ECCS
paragraph C.2.2.12, this Surveillance demonstrates that OG                                                                        \
"'--__a.Engine overspeed; b.Generator differential overcurrent; c.Generator ground neutral overcurrent; and 3.8-13 24 months (continued)
non-c,ritica1 protective ,function,s., (e.g., high jacket waterf) emperature) are by ass~d on an ECCS initiation test sign #
Amendment No.210 Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)
                    ~w~~~ ~~~~~l~~~~~n~ngine overspeed,
However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s)may be extended.To apply this Completion Time extension, two criteria must first be met.The subsequent inoperability:
a.Must exist concurrent with the first inoperability; and b.Must remain inoperable or not within limits after the first inoperabi11ty 1s resolved.The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either: a.The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours;or b.The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) andseparatetracking of Completion Times based on this re-entry.These exceptions are stated in individual Specifications.(continued)
PBAPS UNIT 2 1.3-2 Amendment No.210 1.3 Completion Times Completion Times 1.3 EXAMPLES (continued)
EXAMPLE 1.3-3 ACTIONS CONDITION A.One Function X subsystem inoperable.
REQUIRED ACTION A.l Restore Function X subsystem to OPERABLE status.COMPLETION TIME B.One Function Y subsystem inoperable.
B.1 Restore 72 hours Function Y subsystem to OPERABLE status.c.One C.1 Restore 12 hours Function X Function X subsystem subsystem to inoperable.
OPERABLE status.AND OR One C.2 Restore 12 hours Function Y Function Y subsystem subsystem to inoperable.
OPERABLE status.(continued)
PBAPS UNIT 2 1.3-6 Amendment No.210 Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)
When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable.
The Completion Times for Condition A and Condition B are tracked separately for each subsystem, starting from the ti.e each subsystem was declared inoperable and the Condition was entered.A separate Completion Ti.e is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).
)'t,"".)'\If Required Action C.2 is completed within the specified Completion Time, Conditions Band C are exited.If the Completion Time for Required Action A.l has not expired, operation may continue in accordance with Condition A.The remaining Completion Time in Condition A is measured from J the time the affected subsystem was declared inoperable
{i.e., initial entry into Condition A}.....""A,
.....
.. if."'_W.M,;.rAll
**
(/ft;;
:Tim;;of Conditio A and B are modified bi a I logical connec or, with a separ e 10 day Completion Timt , measured fro the t1me 1t was scovered the LCO was n,i!met.In thi example, withou the separate Completio.Time, (1 it to a1t nate between Condition B,.'and C in'ch a manner tha operation could contin."*indefin" ely without ever restoring systems to..t the LCO.The se'rate Completion 1me modified by the ph se"from\disc ery of failure meet the LCO" is desi ed to prevent\ind inite continued peration while not mee ing the LCO.\Th" Completion Ti allows for an excepti to the normal\n me zero" for b inning the
*1me"clock".In!t is instance, t.e Completion Time"ti zero" is specified/" as comencing , the time the LeO was, nitially not met,/\instead of at he time the associated Condition was entered.//
I\'-----__--
...
__
__
ued)It is to bem:een Conditions A, B, and C in such a manner that operation contmue mdefinitely wIthout ever restoring systems to meet the LCO.However domg so would be inconsistent with the basis of the Completion Times.Therefore shall be to limit maximum time allowed for any that.result In a smgle contiguous occurrence of failing to meet the LCO.These admmlstratlve controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.PBAPS UNIT 2 1.3-7 Amendment No.210 SLC System 3.1.7 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC)System LCO 3.1.7 Two SLC subsystems shall be OPERABLE.APPLICABILITY:
enerator differential overcurren , genera or round neutra
MODES 1 and 2.ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.Concentration of boron A.I in solution>9.82%weight.Verify the concentration and temperature of boron in solution and pump suction piping temperature are within the limits of
              .-.. .~**vercurrent and manual car x in"tiatio                                            i                Gt                            I su s an a l a                    e          un". The non-cri t i a                                                    I url      s an continue to provide an                                                            I alarm on an abnormal engine condition. This alarm provides                                                                    /'
the operator with sufficient time to react appropriately.                                                                  I The DG availability to mitigate the DBA is more critical                                                                  I than protecting the engine against minor problems that are                                                              /
not immediately detrimental to emergency operation of the .///
DG. E,:-"'''        -',.",..".~~__<<"" ,*,_ _ ._~.,,~**~**w ***,..,,... _,_._~_,- - _....~._......._ .... -  ... _-><_..
The 24 month Frequency is based on engineering judgment, takes into consideration plant condition~ required to perform
f
f
..._-----(continued)
                      ~------------....          _-----
PBAPS UNIT 3 B 3.8-90 Revision No.0 Di stri buti on Systems-Operati ng B 3.8.7 BASES n (/
OP,EAABlE. This could continue indefinitely.      ~_-
,.,...,)\T his Comp1eti 0 n"<ti melon tot hen 0 r mal"time zero" for begi'Rtting the ed outage time"clock." This allowance results',,!
                                                                          .-,,,.~
ablishing the"time zero" at/the time LCO 3.8.7.s inlially not met, instead of at the timeD was enterThe 16 hour Completion his potential offa..J..l'rl1 g tomeet the L COlndef 1 n 1 tely.ACTIONS If the inoperable electrical power distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the overall plant risk is minimized.
(continued)
To achieve this status, the plant must be brought to at least MODE 3 within 12 hours.Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref.3)and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.Condition F corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost.When more than one Condition is entered, and this results in the loss of a required function, the plant is in a condition outside the accident analysis.Therefore, no additional time is justified for continued operation.
PBAPS UNIT 3                     B 3.8-90                             Revision No. 0
LCO 3.0.3 must be entered immediately to commence a controlled shutdown.SURVEILLANCE REQUIREMENTS SR 3.8.7.1 This Surveillance verifies that the AC and DC electrical power distribution systems are functioning properly, with the correct circuit breaker alignment (for the AC electrical power distribution system only).The correct AC breaker alignment ensures the appropriate separation and independence of the electrical buses are maintained, and power is available to each required bus.The verification of indicated power availability on the AC and DC buses (continued)
 
PBAPS UNIT 3 8 3.8-91 Revision No.67}}
Di stri buti on Systems -Operati ng B 3.8.7 BASES ACTIONS                          n
(/
                                                                      '--''''''''''N''''=''''-''''_'''_~~____ ,.,..., )
This Com p1et i 0\n"<ti m e l o n tot hen 0 rmal "time zero" for begi'Rtting the                 ed outage time "clock."
                                                                                                            ~
This allowance results',,!             ablishing the "time zero" at                                   /
the time LCO 3.8.7.             s inlially not met, instead of at the time Con~ D was enter .~.                  The 16 hour Completion Ti~e.~,,:>_.a.ff-dcceptable li~itat~o~              his potential of f a..J ..l'rl1 g tom eet the LCOl ndef 1 n1 tel y .
If the inoperable electrical power distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours. Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state. The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
Condition F corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost. When more than one Condition is entered, and this results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.
SURVEILLANCE SR         3.8.7.1 REQUIREMENTS This Surveillance verifies that the AC and DC electrical power distribution systems are functioning properly, with the correct circuit breaker alignment (for the AC electrical power distribution system only). The correct AC breaker alignment ensures the appropriate separation and independence of the electrical buses are maintained, and power is available to each required bus. The verification of indicated power availability on the AC and DC buses (continued)
PBAPS UNIT 3                           8 3.8-91                             Revision No. 67}}

Revision as of 14:06, 14 November 2019

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes
ML082240520
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 08/07/2008
From: Cowan P
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML082240520 (72)


Text

Exelon Nuclear www.exeloncorp.com 200 Exelon Way Nuclear Kennett Square, PA 19348 10 CFR 50.90 August 7, 2008 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 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 to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes Pursuant to 10 CFR 50.90, Exelon Generation Company, LLC (EGC) hereby requests proposed changes to incorporate various previously NRC-approved Technical Specification Task Force travelers (TSTFs) and other administrative changes. A listing of the proposed TSTFs and other administrative changes is contained in Attachment 1.

The proposed changes have been reviewed by the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.

EGC requests approval of the proposed amendment by August 7, 2009. Once approved, the amendment shall be implemented within 60 days.

No additional regulatory commitments are contained in this request.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes August7,2008 Page 2 In accordance with 10 CFR 50.91, EGC is notifying the State of Pennsylvania of this application for changes to the TS and Operating Licenses by transmitting a copy of this letter and its attachments to the designated state official.

Should you have any questions concerning this letter, please contact Tom Loomis at (610) 765- 5510.

h I declare under penalty of perjury that the foregoing is true and correct. Executed on the i of August 2008.

Respectfully,

~1lf1 Director, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Evaluation of Proposed Changes

2) Markup of Proposed Technical Specifications Page Changes
3) Markup of Proposed Technical Specifications Bases Page Changes cc: S. J. Collins, Administrator, Region I, USNRC F. Bower, USNRC Senior Resident Inspector, PBAPS J. Hughey, Project Manager, USNRC R. R. Janati, Commonwealth of Pennsylvania S. T. Gray, State of Maryland

ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 EVALUATION OF PROPOSED CHANGES

ATTACHMENT 1 CONTENTS

Subject:

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION, TECHNICAL EVALUATION, REGULATORY EVALUATION, CONCLUSIONS 2.1 TSTF-363-A, Rev. 0 - Revise Topical Report references in ITS 5.6.5, COLR 2.2 TSTF-400-A, Revision 1 - Clarify SR on Bypass of DG Automatic Trips 2.3 TSTF-439-A, Revision 2 - Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO 2.4 TSTF-485-A, Rev. 0 - Correct Example 1.4-1 2.5 Administrative Changes - Removal of Obsolete Note for Technical Specification Table 3.3.8.1-1 (PBAPS, Units 2 and 3) and Correction to Table 3.3.3.1-1 (PBAPS, Unit 2) 2.6 Clarification of Allowable Value on Technical Specification Table 3.3.1.1-1

3.0 ENVIRONMENTAL CONSIDERATION

4.0 REFERENCES

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 1 of 23 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Renewed Facility Operating Licenses DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.

The proposed changes would revise the Operating Licenses to incorporate certain TSTFs that have been previously reviewed and approved by the NRC and make other administrative revisions. These TSTFs and administrative changes were selected, in part, based on their simplicity of review and ease of implementation.

The TSTFs and administrative changes are grouped into six (6) individual analyses as provided in Sections 2.1 through 2.6 of this submittal. Each analysis provides a detailed description, technical evaluation, regulatory evaluation, and conclusions. Bases pages are also provided in this submittal for your information only.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 2 of 23 2.0 DETAILED DESCRIPTION, TECHNICAL EVALUATION, REGULATORY EVALUATION, CONCLUSIONS 2.1 TSTF-363-A, Revision 0 - Revise Topical Report references in ITS 5.6.5, COLR Detailed

Description:

TSTF-363-A, Revision 0 modifies Improved Technical Specifications (NUREG-1433) Section 5.6.5 to remove the requirements to identify Core Operating Limits Report (COLR) Topical Report(s) by number, title, and date. The complete citation is added to the COLR for each Topical Report, including the report number, title, revision, date, and any supplements.

See the markup of pages for PBAPS, Units 2 and 3 included in Attachment 2.

Unit Applicability List of Affected Pages Unit 2 Unit 3 5.0-21 X X 5.0-22 X X Technical Evaluation:

Exelon Generation Company, LLC (EGC) proposes to revise PBAPS Technical Specification Section 5.6.5 to remove the requirement to maintain COLR Topical Report references by number, title, date, and NRC staff approval document, if currently included. This TSTF will permit referencing the topical report by number and title. The additional details will be controlled within the COLR and will be subject to 10 CFR 50.59 for any changes. The details of the Topical Report references are an unwarranted regulatory burden and are acceptably maintained in the COLR. As discussed in TSTF-363, this method of referencing topical reports would allow licensees to use current topical reports to support limits in the COLR without having to submit an amendment to the facility operating license every time the topical report is revised.

The COLR would provide specific information identifying the particular approved topical reports used to determine the core limits for the particular cycle in the COLR report. This would eliminate unnecessary expenditure of NRC and licensee resources and would ease the burden of TS submittal and approval needed to license reload fuel.

There are no intended deviations from the TSTF.

Regulatory Evaluation:

Applicable Regulatory Requirements/Criteria:

10 CFR 50.36, "Technical specifications" - 10 CFR 50.36(d)(2) states, "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." The proposed change continues to meet the requirements of this regulation.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 3 of 23 Precedent:

TSTF-363-A, Revision 0, was approved for use as described in:

Letter from L. N. Olshan (U. S. Nuclear Regulatory Commission) to W. R. McCollum, Jr.

(Duke Energy Corporation), "Oconee Nuclear Station, Units 1,2, and 3 RE: Issuance of Amendments (TAC NOS. MB3713, MB3714, AND MB3715)," dated July 9, 2002.

No Significant Hazards Consideration:

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, IIlssuance of amendment, II as discussed below:

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

Response: No.

This action does not affect the plant or operation of the plant. The change simply removes technical details from the Technical Specifications already included in the COLR. These technical details will still be subject to the regulations in 10 CFR 50.59.

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

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

Response: No.

No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed changes. All systems, structures, and components previously required for the mitigation of a transient remain capable of fulfilling their intended design functions. The proposed change has no adverse effects on any safety-related system or component and does not challenge the performance or integrity of any safety related system. This change is considered as an administrative action.

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

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

Response: No.

This administrative action does not involve any reduction in a margin of safety. The change simply removes technical details from the Technical Specifications already included in the COLR. These technical details will still be subject to the regulations in 10 CFR 50.59. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 4 of 23 Based on the above, EGC concludes that the proposed amendment does not involve a 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.

==

Conclusions:==

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.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 5 of 23 2.2 TSTF-400-A, Revision 1 - Clarify SR on Bypass of DG Automatic Trips Detailed

Description:

TSTF-400-A, Revision 1 modifies Improved Technical Specification (NUREG-1433)

Surveillance Requirement (SR) 3.8.1.13 to clarify the intent of the SR. Specifically, the wording is revised to clarify that the intent of the SR is to test non-critical Emergency Diesel Generator (EDG) automatic trips.

EGC proposes to revise PBAPS Technical Specification SR 3.8.1.13 to clarify the intent of the SR. Specifically, the wording is revised to clarify that the intent of the SR is to test non-critical EDG automatic trips. The associated Technical Specification Bases are also updated in accordance with the approved TSTF and are provided for your information.

There are no intended deviations from the TSTF.

See the markup of pages for PBAPS, Units 2 and 3 included in Attachments 2 and 3.

Unit Applicability List of Affected Pages Unit 2 Unit 3 3.8-13 X X B 3.8-30 X X Technical Evaluation:

Branch Technical Position ICSB-17, "Diesel Generator Protective Trip Circuit Bypasses, was II replaced in 1981 by Regulatory Guide 1.9, Revision 2 (December 1979), Position C.7.

Regulatory Guide 1.9, Rev. 3, Position C.1.8, is essentially unchanged from the 1979 position.

The Regulatory Guide only requires verification that the noncritical trips are bypassed and does not require verification that the critical trips are not bypassed. Regulatory Guide 1.9, Rev. 3, Section 2.2.12 states, "Protective Trip Bypass Test: Demonstrate that all automatic diesel generator trips (except engine overspeed, generator differential, and those retained with coincidental logic) are automatically bypassed on an SIAS." Therefore, this SR was intended to verify that the noncritical trips are bypassed so that a spurious actuation of a noncritical trip does not take a DG out of service during an emergency. The Branch Technical Position states that if bypasses of non-critical DG trips are used in the DG design, lithe design of the bypass circuitry should include the capability for testing the status and operability of the bypass circuits. This requirement is the source of SR 3.8.1.13. However, as the SR and Bases are II currently written, it is implied that it is not only necessary to verify that the bypasses are operable, but to verify the other channels are not bypassed. Therefore SR 3.8.1.13 and the associated Bases are revised to clarify the purpose of the SR. Testing to verify that critical DG trips are not bypassed is not required to satisfy the requirements of 10 CFR 50.36(d)(3). TSTF-400-A, Revision 1, was approved by the U. S. Nuclear Regulatory Commission staff, in a letter dated November 13, 2004.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 6 of 23 Notwithstanding, EGC will continue to ensure appropriate testing of critical EDG trips. Although the intent of the SR is not to test the critical trips, a statement is being added to the TS Bases to ensure appropriate testing of the critical trips (see "Precedent"). Therefore, this change does not result in a change to any testing that is currently performed.

There are no deviations in the proposed PBAPS Technical Specifications from the TSTF. An extra sentence is added to the Bases to ensure continued testing of the critical trips.

Regulatory Evaluation:

Applicable Regulatory Requirements/Criteria:

10 CFR 50.36, "Technical specifications" - 10 CFR 50.36(d)(2) states, "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." The proposed change continues to meet the requirements of this regulation.

10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants" - The overall objective of this performance-based rule is to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended functions when required.

Precedents:

TSTF-400-A, Revision 1, was approved for use as described in:

Letter from J. Stang (U. S. Nuclear Regulatory Commission) to J. R. Morris (Duke Power Company, LLC), "Catawba Nuclear Station, Units 1 and 2, Issuance of Amendments Regarding Emergency Diesel Generator Testing (TAC NOS. MD3217 and MD3218)," dated June 25, 2007.

Letter from T. H. Boyce (U. S. Nuclear Regulatory Commission) to Technical Specification Task Force, Staff Safety Evaluation for TSTF-400, Revision 1, dated November 13, 2004.

No Significant Hazards Consideration:

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 discussed below:

II

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

Response: No.

This change clarifies the purpose of SR 3.8.1.13, which is to verify that noncritical automatic Diesel Generator (DG) trips are bypassed in an accident. The DG automatic trips and their bypasses are not initiators of any accident previously evaluated.

Therefore, the probability of any accident is not significantly increased. The function of the DG in mitigating accidents is not changed. The revised SR continues to ensure the

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 7 of 23 DG will operate as assumed in the accident analysis. Therefore, the consequences of any accident previously evaluated are not affected.

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

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

Response: No.

This change clarifies the purpose of SR 3.8.1.13, which is to verify that noncritical automatic DG trips are bypassed in an accident. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Thus, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

This change clarifies the purpose of SR 3.8.1.13, which is to verify that noncritical automatic DG trips are bypassed in an accident. This change clarifies the purpose of the SR, which is to verify that the DG is capable of performing the assumed safety function. The safety function of the DG is unaffected, so the change does not affect the margin of safety. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed amendment does not involve a 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.

==

Conclusions:==

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.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 8 of 23 2.3 TSTF-439-A, Revision 2 - Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO Detailed

Description:

TSTF-439-A, Revision 2 modifies Improved Technical Specification (NUREG-1433)

Completion Times Example 1.3-3 to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.1.7 Required Actions A.2 and B.1, Technical Specification 3.8.1 Required Action A.3, and Technical Specification 3.8.7 Required Actions C.1 and 0.1 are being deleted. The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.

It is proposed to revise PBAPS Technical Specification Section 1.3 to conform to the above changes. Other TS Bases pages are revised in accordance with the TSTF to conform to the changes in TS 1.3.

There are no intended deviations from the TSTF.

See the markup of pages for PBAPS, Units 2 and 3 included in Attachments 2 and 3.

Unit Applicability List of Affected Pages Unit 2 Unit 3 1.3-2 X X 1.3-6 X X 1.3-7 X X 3.1-20 X X 3.8-2 X X 3.8-42 X X 3.8-43 X X B 3.1-42 X X B 3.1-43 X X B 3.8-8 X X B 3.8-9 X X B 3.8-89 X X B 3.8-90 X X B 3.8-91 X X Technical Evaluation:

As discussed in TSTF-439-A, Revision 2, the adoption of a second Completion Time was based on an NRC concern that a plant could continue to operate indefinitely with an LCO governing safety significant systems never being met by alternately meeting the requirements of separate Conditions. In 1991, the NRC could not identify any regulatory requirement or program which

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 9 of 23 could prevent this misuse of the Technical Specifications. However, that is no longer the case.

There are now two programs which would provide a strong disincentive to continued operation with concurrent multiple inoperabilities of the type the second Completion Times were designed to prevent.

The Maintenance Rule: 10 CFR 50.65(a)(1), the Maintenance Rule, requires each licensee to monitor the performance or condition of SSCs against licensee-established goals to ensure that the SSCs are capable of fulfilling their intended functions. If the performance or condition of an SSC does not meet established goals, appropriate corrective action is required to be taken.

The NRC Resident Inspectors monitor the licensee's Corrective Action process and could take action if the licensee's maintenance program allowed the systems required by a single LCO to become concurrently inoperable multiple times. The performance and condition monitoring activities required by 10 CFR 50.65(a)(1) and (a)(2) would identify if poor maintenance practices resulted in multiple entries into the ACTIONS of the Technical Specifications and unacceptable unavailability of these SSCs. The effectiveness of these performance monitoring activities, and associated corrective actions, is evaluated at least every refueling cycle, not to exceed 24 months per 10 CFR 50.65(a)(3).

Under the Technical Specifications the Completion Time for one system is not affected by other inoperable equipment. The second Completion Times were an attempt to influence the Completion Time for one system based on the condition of another system, if the two systems were required by the same LCO. However 10 CFR 50.65(a)(4) is a much better mechanism to apply this influence as the Maintenance Rule considers all inoperable risk-significant equipment, not just the one or two systems governed by the same LCO.

Under 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance. The risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants."

Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed maintenance is acceptable. This comprehensive program provides much greater assurance of safe plant operation than the second Completion Times in the Technical Specifications.

The Reactor Oversight Process: NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," describes the tracking and reporting of performance indicators to support the NRC's Reactor Oversight Process (RaP). The NEI document is endorsed by RIS 2001-11, "Voluntary Submission Of Performance Indicator Data." NEI 99-02, Section 2.2, describes the Mitigating Systems Cornerstone. NEI 99-02 specifically addresses emergency AC Sources (which encompasses the AC Sources and Distribution System LCOs). Extended unavailability due to multiple entries into the ACTIONS would affect the NRC's evaluation of the licensee's performance under the Rap.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 10 of 23 In addition to these programs, a requirement is added to Section 1.3 of the Technical Specifications to require licensees to have administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls should consider plant risk and shall limit the maximum contiguous time of failing to meet the LCO. This Technical Specification requirement, when considered with the regulatory processes discussed above, provides an equivalent or superior level of plant safety without the unnecessary complication of the Technical Specifications by second Completion Times on some Specifications.

Regulatory Evaluation:

Applicable Regulatory Requirements/Criteria:

10 CFR 50.36, "Technical specifications" - 10 CFR 50.36(c)(2) states, "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." The proposed change continues to meet the requirements of this regulation.

10 CFR 50.65, IIRequirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" - The overall objective of this performance-based rule is to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended function when required.

Precedent:

TSTF-439-A, Revision 2 was approved for use as described in:

Letter from B. K. Singal (U. S. Nuclear Regulatory Commission) to M. R. Blevins (Luminant Generation Company LLC), "Comanche Peak Steam Electric Station Units 1 and 2 - Issuance of Amendments RE: Revision to Technical Specifications (TS) 3.7.5, 3.8.1, and 3.8.9, and TS Example 1.3-3 (TAC NOS. MD4070 AND MD4071 )," dated January 25, 2008.

No Significant Hazards Consideration:

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 discussed below:

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

Response: No.

The proposed change eliminates certain Completion Times from the Technical Specifications. Completion Times are not an initiator to any accident previously evaluated. As a result, the probability of an accident previously evaluated is not affected. The consequences of an accident during the revised Completion Time are no different than the consequences of the same accident during the existing Completion Times. As a result, the consequences of an accident previously evaluated are not affected by this change. The proposed change does not alter or prevent the ability of

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 11 of 23 structures, systems, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits.

The proposed change does not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. Further, the proposed change does not increase the types or amounts of radioactive effluent that may be released offsite, nor significantly increase individual or cumulative occupational/public radiation exposures. The proposed change is consistent with the safety analysis assumptions and resultant consequences. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change does not involve a physical alteration of the plant (Le., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed change does not alter any assumptions made in the safety analysis. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The proposed change to delete the second Completion Time does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis acceptance criteria are not affected by this change.

The proposed change will not result in plant operation in a configuration outside of the design basis. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed amendment does not involve a 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.

==

Conclusions:==

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.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 12 of 23 2.4 TSTF-485-A, Rev. 0 - Correct Example 1.4-1 Detailed

Description:

TSTF-485-A, Revision 0 modifies Section 1.4, "Frequency," Example 1.4-1 to be consistent with the requirements of SR 3.0.4. SR 3.0.4 was revised by TSTF-359, Revision 9, and the current example is not consistent with the Technical Specification requirements.

The second paragraph of Example 1.4-1 currently states:

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the MODE or other specified condition. Failure to do so would result in a violation of SR 3.0.4.

It is being revised to state:

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, then SR 3.0.4 becomes applicable. The Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified by SR 3.0.3, prior to entry into the MODE or other specified condition or the LCO is considered not met (in accordance with SR 3.0.1), and LCO 3.0.4 becomes applicable.

It is proposed to revise Technical Specification Section 1.4, "Frequency," Example 1.4-1 to conform to the above change. There are no associated TS Bases changes required.

There are no intended deviations from the TSTF.

See the markup of pages for PBAPS, Units 2 and 3 included in Attachment 2.

Unit Applicability List of Affected Pages Unit 2 Unit 3 1.4-3 X X Technical Evaluation:

Example 1.4-1 states that if the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the MODE or other specified condition. Failure to do so would result in a violation of SR 3.0.4. SR 3.0.4 states that entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCOls Surveillances have been met within their specified Frequency. TSTF-359 modified SR 3.0.4 to state that when an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. TSTF-359 modified LCO 3.0.4 to provide conditions under which it is acceptable to enter the Applicability of the LCO with

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications 'Changes Page 13 of 23 the LCO not met. Therefore, it possible to enter the MODE or other specified condition in the Applicability of an LCO with a Surveillance not performed within the Frequency requirements of SR 3.0.2 and this does not result in a violation of SR 3.0.4.

The Example 1.4-1, second paragraph discussion is modified to parallel the discussion in the previous paragraph. The previous paragraph discusses Surveillances that exceed the interval without being performed while in the Applicability. The second paragraph is modified to make a similar statement regarding Surveillances that exceed the interval while not being in the Applicability. The second sentence of the second paragraph is modified to reference the provisions of SR 3.0.3. This is necessary as TSTF-359 modified SR 3.0.4 to recognize that performance of a missed Surveillance may have been extended and prior to performance of the missed Surveillance, but within the time permitted under SR 3.0.3, a MODE change occurs.

The statement that failure to perform a Surveillance prior to entering the Applicability would constitute a violation of SR 3.0.4 is deleted and a statement is inserted to state the LCO would not be met and LCO 3.0.4 becomes applicable. This is consistent with the revised SR 3.0.4.

Regulatory Evaluation:

Applicable Regulatory Requirements/Criteria:

This change is administrative and will have no effect on any regulatory requirements or criteria.

Precedent:

TSTF-485-A, Revision 0 was approved for use as described in:

1. Letter from C. F. Lyon (U. S. Nuclear Regulatory Commission) to J. V. Parrish (Energy Northwest), "Columbia Generating Station - Issuance of Amendment RE:

Miscellaneous Administrative Changes (TAC NO. MD6209)," dated December 13, 2007.

2. Letter from B. Vaidya (U. S. Nuclear Regulatory Commission) to J. E. Venable (Entergy Operations, Inc.), "River Bend Station, Unit 1 - Issuance of Amendment RE: Technical Specifications Change Regarding Mode Change Limitations (TSTF-359) Using Consolidated Line Item Improvement Process, and Correct Example 1.4-1 (TSTF-485)

(TAC NO. MD6016)," dated December 6,2007.

No Significant Hazards Consideration:

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

II

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

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 14 of 23 Response: No.

The proposed change revises Section 1.4, "Frequency," Example 1.4-1, to be consistent with Surveillance Requirement (SR) 3.0.4 and Limiting Condition for Operation (LCO) 3.0.4. This change is considered administrative in that it modifies the example to demonstrate the proper application of SR 3.0.4 and LCO 3.0.4. The requirements of SR 3.0.4 and LCO 3.0.4 are clear and are clearly explained in the associated Bases. As a result, modifying the example will not result in a change in usage of the Technical Specifications (TS). The proposed change does not adversely affect accident initiators or precursors, the ability of structures, systems, and components (SSCs) to perform their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. Therefore, this change is considered administrative and will have no effect on the probability or consequences of any accident previously evaluated.

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

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

Response: No.

No new or different accidents result from utilizing the proposed change. The change does not involve a physical alteration of the plant (Le., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the change does not impose any new or different requirements or eliminate any existing requirements. The change does not alter assumptions made in the safety analysis. The proposed change is consistent with the safety analysis assumptions and current plant operating practice.

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

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

Response: No.

The proposed change is administrative and will have no effect on the application of the Technical Specification requirements. Therefore, the margin of safety provided by the Technical Specification requirements is unchanged. There are no changes to the plant safety analyses involved with this change. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed amendment does not involve a 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.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 15 of 23

==

Conclusions:==

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.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 16 of 23 2.5 Administrative Changes - Removal of Obsolete Note for Technical Specification Table 3.3.8.1-1 (PBAPS, Units 2 and 3) and Correction to Table 3.3.3.1-1 (PBAPS, Unit 2)

Detailed

Description:

Thais change addresses two (2) administrative changes:

a) TS Table 3.3.8.1-1 lists the TS functions associated with the Loss of Power (LOP)

Instrumentation. As a result of a modification, the allowable values were revised, but as described in the note, were to expire no later than March 1, 2000. The previous values were retained in note (a) at the bottom of the Table. These values were retained as a note to allow for appropriate transition during the period of time that the modifications were being installed on Units 2 and 3.

The modifications are complete and the note is no longer necessary. Therefore, it is proposed to eliminate note (a) at the bottom of Table 3.3.8.1-1, as an administrative change to the TS.

b) TS Table 3.3.3.1-1 lists the Post Accident Monitoring Instrumentation. The Reference 1 license amendment request implemented TSTF-295, Revision 0, "Post Accident Monitoring Clarifications," by changing the title from "PCIV Position" to "Penetration Flow Path PCIV Position" for Function 8. However, Function 8 was inadvertently revised on the PBAPS, Unit 2 page to state "Penetration Flaw Path PCIV Position." The correct title should be "Penetration Flow Path PCIV Position." The Unit 3 page correctly provides the title of Function 8 as the "Penetration Flow Path PCIV Position." This is an administrative change that corrects a typographical error on the PBAPS, Unit 2 page.

There are no TS Bases changes required for either change.

See the markup of pages for PBAPS, Units 2 and 3 included in Attachment 2.

Unit Applicability List of Affected Pages Unit 2 Unit 3 3.3-65 X X 3.3-26 X Technical Evaluation:

a) TS Table 3.3.8.1-1 lists the TS functions associated with the Loss of Power (LOP)

Instrumentation. As a result of a modification, the allowable values were revised. The previous values were retained in note (a) at the bottom of the Table. These values were retained as a note to allow for appropriate transition during the period of time that the modifications were being installed on Units 2 and 3.

As a result of the completion of the modifications, it is no longer necessary to retain the note in TS. Therefore, it is proposed to eliminate note (a) at the bottom of Table 3.3.8.1-1 as an administrative change to the TS. The previous TS change was approved as

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 17 of 23 amendments 230/235 to the Units 2 and 3 TS, respectively. The changes were the result of modifications required to the TS as requested in the Reference 3 letter, supplemented in the Reference 4 letter, and approved in the Reference 5 letter.

Note (a) expired March 1, 2000 and is no longer necessary to retain in TS Table 3.3.8.1-1.

Removing the note (a) will reduce the complexity of the TS and enhance usability of the TS. This change is, therefore, considered administrative.

b) TS Table 3.3.3.1-1 lists the post accident monitoring instrumentation. The Reference 1 license amendment request implemented TSTF-295, Revision 0, "Post Accident Monitoring Clarifications," by changing the title from "PCIV Position" to "Penetration Flow Path PCIV Position" for Function 8. However, Function 8 was inadvertently revised on the PBAPS, Unit 2 page to state "Penetration Flaw Path PCIV Position." The correct title in should be "Penetration Flow Path PCIV Position." This change was approved in the Reference 2 letter. The Unit 3 page correctly provides the title of Function 8 as the "Penetration Flow Path PCIV Position." This is an administrative change that corrects a typographical error on the PBAPS, Unit 2 page. No technical change is occurring as a result of this correction.

Regulatory Evaluation:

Applicable Regulatory Requirements/Criteria:

These proposed changes are administrative and will have no effect on any regulatory requirements or criteria.

Precedent:

N/A No Significant Hazards Consideration:

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, "lssuance of amendment, as discussed below:

II

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

Response: No.

The proposed changes are administrative in nature and do not impact the operation, physical configuration, or function of plant structures, systems, or components (SSCs).

Also, the proposed changes do not impact the initiators or assumptions of analyzed events, nor do the proposed changes impact the mitigation of accidents or transient events. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 18 of 23

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

Response: No.

The proposed changes are administrative in nature and do not alter plant configuration, require that new equipment be installed, alter assumptions made about accidents previously evaluated, or impact the operation or function of plant equipment.

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 amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed changes are administrative in nature and do not involve any physical changes to plant SSCs, or the manner in which SSCs are operated, maintained, modified, tested, or inspected. The proposed changes do not involve a change to any safety limits, limiting safety system settings, limiting conditions of operation, or design parameters for any SSC. The proposed changes do not impact any safety analysis assumptions and do not involve a change in initial conditions, system response times, or other parameters affecting any accident analysis. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed amendment does not involve a 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.

==

Conclusions:==

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.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 19 of 23 2.6 Clarification of Allowable Value on Technical Specification Table 3.3.1.1-1 Detailed

Description:

The administrative change requested by this amendment application is to delete the "NA" from the Allowable Value column for Function 2.1, "OPRM Upscale," in TS Table 3.3.1.1-1, "Reactor Protection System Instrumentation." The reference to footnote "(d)," which states: "See COLR for OPRM period based detection algorithm (PBDA) setpoint limits," will remain in the Allowable Value column for Function 2.f in TS Table 3.3.1.1-1.

On March 4, 2005, the NRC contacted EGC by telephone to discuss some follow-up questions concerning the changes to the TS that were originally proposed to the NRC in the Reference 6 letter, regarding activation of the OPRM trip function at PBAPS. The NRC identified an issue that was not significant enough to impact NRC issuance of the OPRM trip activation amendments for PBAPS, Units 2 and 3. However, the NRC requested that a change to TS Table 3.3.1.1-1 be proposed in a subsequent "cleanup" license amendment request (LAR). The NRC subsequently issued Amendment Nos. 251 and 254 for PBAPS, Units 2 and 3, by letter dated March 21, 2005 (Reference 8).

See the markup of pages for PBAPS, Units 2 and 3 included in Attachment 2.

Unit Applicability List of Affected Pages Unit 2 Unit 3 3.3-7 X X Technical Evaluation:

The change proposed in Reference 6 added new Function 2.f, i.e., the OPRM Upscale trip function, to TS Table 3.3.1.1-1. The addition of footnote (d) was discussed in the Reference 7 RAI response. The NRC found the "NA" in the Allowable Value column of Table 3.3.1.1-1 confusing since there are trip setpoints maintained in the COLR which satisfy the requirements of 10 CFR 50.36 for limiting safety system settings. Therefore, the NRC requested that, in a future LAR, EGC delete the "NA" from the Allowable Value column for Function 2.1 in TS Table 3.3.1.1-1 and leave only the footnote "(d)" which references the COLR for the location of the trip setpoints. The change to PBAPS TS Table 3.3.1.1-1 requested by the NRC is therefore being proposed by this amendment request.

Regulatorv Evaluation:

Applicable Regulatory Requirements/Criteria:

This is an administrative change that clarifies the allowable value for Function 2.1. No regulatory requirements are being impacted, nor is the intent of the TS being modified.

Precedent:

N/A

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 20 of 23 No Significant Hazards Consideration:

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, "lssuance of amendment, as discussed below:

II

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

Response: No.

The proposed change is administrative in nature and does not impact the operation, physical configuration, or function of plant structures, systems, or components (SSCs).

Also, the proposed change does not impact the initiators or assumptions of analyzed events, nor does the proposed change impact the mitigation of accidents or transient events. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change is administrative in nature and does not alter plant configuration, require that new equipment be installed, alter assumptions made about accidents previously evaluated, or impact the operation or function of plant equipment. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The proposed change is administrative in nature and does not involve any physical changes to plant SSCs, or the manner in which SSCs are operated, maintained, modified, tested, or inspected. The proposed change does not involve a change to any safety limits, limiting safety system settings, limiting conditions of operation, or design parameters for any SSC. The proposed change does not impact any safety analysis assumptions and does not involve a change in initial conditions, system response times, or other parameters affecting any accident analysis. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed amendment does not involve a 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.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 21 of 23

==

Conclusions:==

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.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 22 of 23

3.0 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 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 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.

License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Attachment 1 Technical Specifications Changes Page 23 of 23

4.0 REFERENCES

1. Letter from M. P. Gallagher (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "License Amendment Request Incorporation of Previously NRC-Approved Generic Technical Specification Changes," dated June 24, 2004.
2. Letter from R. V. Guzman (U. S. Nuclear Regulatory Commission) to 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," dated May 10, 2006.
3. G. D. Edwards (PECO Nuclear) to U. S. Nuclear Regulatory Commission, "Peach Bottom Atomic Power Station, Units 2 and 3 License Change Application ECR 96-01511 ," dated December 24, 1998
4. Letter from J. A. Hutton (PECO Nuclear) to U. S. Nuclear Regulatory Commission, "Peach Bottom Atomic Power Station, Units 2 and 3 Revised Technical Specification Pages for License Change Application ECR 96-01511," dated September 27, 1999
5. Letter from B. C. Buckley (U. S. Nuclear Regulatory Commission) to J. A. Hutton (PECO Energy Company), "Peach Bottom Atomic Power Station, Unit Nos. 2 and 3

- Issuance of Amendment RE: Changes Related to Loss of Power Instrumentation Set Points and Limits of Allowable Values for the 4KV Emergency Buses (TAC NOS.

MA4500 and MA4501 )," dated November 16, 1999

6. Letter from M. P. Gallagher (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "License Amendment Request Activation of the Trip Outputs of the Oscillation Power Range Monitor Portion of the Neutron Monitoring System ," dated February 27, 2004
7. Letter from M. P. Gallagher (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information License Amendment Request Activation of the Trip Outputs of the Oscillation Power Range Monitor Portion of the Power Range Neutron Monitoring System," dated September 13,2004
8. Letter from G. F. Wunder (U. S. Nuclear Regulatory Commission) to C. M. Crane (Exelon Generation Company, LLC), "Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendment RE: Activation of Oscillation Power Range Monitor Trip (TAC NOS. MC2219 and MC2220)," dated March 21, 2005

Attachment 2 Peach Bottom Atomic Power Station, Units 2 and 3 Markup of Proposed Technical Specifications Page Changes Unit Applicability Section List of Affected Pages Unit 2 Unit 3 2.1 5.0-21 X X 2.1 5.0-22 X X 2.2 3.8-13 X X 2.3 1.3-2 X X 2.3 1.3-6 X X 2.3 1.3-7 X X 2.3 3.1-20 X X 2.3 3.8-2 X X 2.3 3.8-42 X X 2.3 3.8-43 X X 2.4 1.4-3 X X 2.5 3.3-65 X X 2.5 3.3-26 X 2.6 3.3-7 X X

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.5 CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:
1. The Average Planar Linear Heat Generation Rate for Specification 3.2.1;
2. The Minimum Critical Power Ratio for Specifications 3.2.2 and 3.3.2.1;
3. The Linear Heat Generation Rate for Specification 3.2.3 ;
4. The Control Rod Block Instrumentation for Specification 3.3.2.1; and
5. The Oscillation Power Range Monitor (OPRM)

Instrumentation for Specification 3.3.1.1.

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

1.

2. NEDC-32162P, "Maximum Extended Load Line Limit and ARTS Improvement Program Analyses for Peach Bottom Atomic.~

Power Station Units 2 and 3~f§?1S,,,.l, ~zrch", :~~

3. PECo-FMS-0001-A, "Steady-State Thermal Hydraulic Analysis of Peach Bottom Units 2 and 3 using the FIBWR Computer Code";
4. PEC0 - FM S-0002 -A, "Metho d for Cal cu1at i ng Tran s i en t Critical Power Ratios for Boiling Water Reactors (RETRAN-TCPPECo)";
5. PECo-FMS-0003-A, "Steady-State Fuel Performance Methods Report";
6. PECo-FMS-0004-A, "Methods for Performing BWR Systems Transient Analysis";

(continued)

PBAPS UNIT 2 Amendmert No. 251

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

7. PECo-FMS-0005-A, "Methods for Performing BWR Steady-State Reactor Physics Analysis";
8. PECo-FMS-0006-A, "Methods for Performing BWR Reload Safety Evaluations"; and
9. NEDO-32465-A, "Reactor Stability Detect and Suppress Solutions Licensing Ba~thod0109Y And Reload Application0 (£igif( ~ J

'A

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.
d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 Post Accident Monitoring (PAM) Instrumentation Report When a report is required by Condition B or F of LCO 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

iJ 8APS UNIT 2 5.0-22 Arnendll!Gnt No. 251

AC Sources--Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.13 ------------------NOTE---------------------

A single test at the specified Frequency will satisfy this Surveillance for both units.

Verify each DG's utomatic trips are 24 months

~y~a~se~ on ~n act~~r~~!mulated ECCS

~~~xcePt: "'--__

a. Engine overspeed;
b. Generator differential overcurrent;

{ c. Generator ground neutral overcurrent; and (continued)

PBAPS UNIT 2 3.8-13 Amendment No. 210

Completion Times 1.3 1.3 Completion Times DESCRIPTION However, when a subsequent division, subsystem, component, (continued) or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and
b. Must remain inoperable or not within limits after the first inoperabi11ty 1s resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

(continued)

PBAPS UNIT 2 1.3-2 Amendment No. 210

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.l Restore Function X Function X subsystem subsystem to inoperable. OPERABLE status.

B. One B. 1 Restore 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function Y Function Y subsystem subsystem to inoperable. OPERABLE status.

c. One C.1 Restore 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Function X Function X subsystem subsystem to inoperable. OPERABLE status.

AND OR One C.2 Restore 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Function Y Function Y subsystem subsystem to inoperable. OPERABLE status.

(continued)

PBAPS UNIT 2 1.3-6 Amendment No. 210

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each subsystem, starting from the ti.e each subsystem was declared inoperable and the Condition was entered. A separate Completion Ti.e is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions Band C are exited. If the Completion Time for Required Action A.l has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable

{i.e., initial entry into Condition A}.

J

~~;Ji;il.iikiw.t'" ...." " A , ~~~*,;;fo>l>¥",~:I4:"-~~iilI\'",",'¥-~~~~'lfiiib'M4,lW~-",,,,,"'Y,(;j"'IiL;,J

'-"~~~~..... tAlJ.w.~~.._~~!~", if."'_W.M,;.rAll**;>t~""",-

comPleti~"Otr:Tim;; of Conditio A and B are modified bi a '~""'"

I, (/ft;;

logical connec or, with a separ e measured fro the t1me 1t was scovered the LCO was n,i 10 day Completion Timt

! met. In thi example, withou the separate Completio . Time, 1 it WOU1~bPossible to a1t nate between Condition ~, B,

.' and C in 'ch a manner tha operation could contin ."

  • ( indefin" ely without ever restoring systems to.. t the LCO.

The se ' rate Completion 1me modified by the ph se "from

\ disc ery of failure meet the LCO" is desi ed to prevent

\ ind inite continued peration while not mee ing the LCO.

\ Th" Completion Ti allows for an excepti to the normal

\ n me zero" for b inning the comPleti~n*1me "clock". In

! t is instance, t. e Completion Time "ti zero" is specified /

" as comencing , the time the LeO was, nitially not met, /

\\ instead of at he time the associated Condition was entered.// I

'-----__ -- -----~*_"'_*- .. ._,_w~._,_. __ ~ ,_~p,*'"

e'~"-A~"tccmti,n ued )

It is possi~le to .altema~e bem:een Conditions A, B, and C in such a manner that operation 't, co~ld contmue mdefinitely wIthout ever restoring systems to meet the LCO. However domg so would be inconsistent with the basis of the Completion Times. Therefore th~re "".)

~ '\

shall be ~?ministrative c~ntrol~ to limit ~he maximum time allowed for any combi~ation ofCondltl~n~ that. result In a smgle contiguous occurrence of failing to meet the LCO.

These admmlstratlve controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

)

PBAPS UNIT 2 1.3-7 Amendment No. 210

SLC System 3.1.7 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC) System LCO 3.1.7 Two SLC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Concentration of boron A.I Verify the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in solution> 9.82% concentration and weight. temperature of boron in solution and pump suction piping Once per temperature are 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> within the limits of thereafter Figure 3.1.7-1.

AND A.2 Restore concentration of boron in solution

)

to ~ 9.821 weight.

/ ""

J B. One SLC subsystem B.l Restore SLC subsystem 7 days inoperable for reasons to OPERABLE status.

other than ~~,/

Condition A.

10 days fm "'.\

discoven of \)

failur to meet .

the 0 /

(continued)

PBAPS UNIT 2 3.1-20 Amendment No. 210

AC Sources-Operating 3.8.1 ACTIONS

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOT E - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One offsite circuit A .1 Perform SR 3.8.1.1 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable. for OPERABLE offsite circuits.

Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND A.2 Declare required 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from feature(s) with no discovery of no offsite power offsite power to available inoperable one 4 kV when the redundant emergency bus required feature(s) concurrent with are inoperable. inoperability of redundant required feature(s)

A.3 Restore offsite circuit to OPERABLE status.

(continued)

PBAPS UNIT 2 3.8-2 Amendment No. 252

Distribution Systems--Operating 3.8.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required -------------NOTE------------

Unit 3 AC electrical Enter applicable Conditions power distribution and Required Actions of LCO subsystems inoperable. 3.8.4, "DC Sources--Operating," when Condition A results in a de-energization of a required Unit 3 125 V battery charger.

A.l Restore required 7 days Unit 3 AC electrical power distribution subsystem(s) to OPERABLE status.

B. One requi red Unit 3 DC B.l Restore Unit 3 DC 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> electrical power electrical power distribution subsystem distribution inoperable. subsystem to OPERABLE status.

C. One Unit 2 AC C.1 Restore Unit 2 AC electrical power electrical power distribution subsystem distribution inoperable. subsystem to OPERABLE status.

(continued)

PBAPS UNIT 2 3.8-42 Amendment No. 210

Distribution Systems-Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One Unit 2 DC 0.1 Restore Unit 2 DC electrical power electrical power distribution subsystem distribution inoperable. subsystem to OPERABLE status.

E. Required Action and E.1 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, B, C, or 0 not met.

F. Two or more i noperabl e F.1 Enter LCO 3.0.3. Immediately electrical power distribution subsystems that result in a loss of function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify: 7 days

a. Correct breaker alignments to required AC electrical power distribution subsystems; and
b. Indicated power availability to required AC and DC electrical power distribution subsystems.

PBAPS UNIT 2 3.8-43 Amendment No. 261

Frequency 1.4 Sr< ~ L'o.

afpUcub)e, 1.4 Frequency

~~-~

EXAMPLES EXAMPLE 1.4-1 (co inued) ~~ ,~~~~.'3)

If the interval s sp~{iied by SR 3.0. is e~ldr~nl1e the unit 1s no inK'MODE or other sp cified condition in the Applicab* it~ f the LCO for whi performance of the SR is required, Surveillance must, e performed within the l~

Frequency requirements of SR 3.0. ~ or to entr in ~. .

~..~E or othgr spet:ified concjiUQ!

  • a* re 0 S ould l ~!is~  ?" 0io~tipn ~~/a;!I . 4.

EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limits. Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after CP: 25% RTP AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter Example 1.4-2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector RAND- indicates that both Frequency requirements must be met. Each time reactor power is increased from a power level < 251 RTP to

~ 251 RTP, the Surveillance must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The use of *once R indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by RAND-). This type of Frequency does not qualify for the extension allowed by SR 3.0.2.

(continued)

PBAPS UNIT 2 1.4-3 Amendment No. 210

LOP Instrumentation 3.3.8.1 Table 3.3.8.1-1 (page 1 of 1)

Loss of Power Instrumentation REQUIRED CHANNELS SURVEILLANCE ALLOWABLE FUNCTION PER BUS REQUIREMENTS VALUE

1. 4 kV Emergency Bus Undervoltage (Loss of Voltage)
a. Bus Undervoltage SR 3.3.8.1.3 NA SR 3.3.8.1.4
2. 4 kV Emergency Bus Undervoltage (Degraded Voltage Low Setting)
a. Bus Undervoltage 2 SR 3.3.8.1.1 ~ 2286 V and ~ 2706 V (1 per SR 3.3.8.1.2 source) SR 3.3.8.1.4
b. Time Delay 2 SR 3.3.8.1.1 ~ 1.5 seconds and (1 per SR 3.3.8.1.2 ~ 2.1 seconds source) SR 3.3.8.1.4
3. 4 kV Emergency Bus Undervoltage (Degraded Voltage High Setting)
8. Bus Undervoltage 2 SR 3.3.8.1.1 ~ 3409 V and s 3829 V (1 per SR 3.3.8.1.2 source) SR 3.3.8.1.4
b. Time Delay 2 SR 3.3.8.1.1 ~ 23.0 seconds and (1 per SR 3.3.8.1.2 ~ 37.0 seconds source) SR 3.3.8.1.4
4. 4 kV Emergency Bus Undervoltage (Degraded Voltage LOCA)
8. Bus Undervoltage 2 (1 per SR 3.3.8.1.1 SR 3.3.8.1.2

~ 3766 V and S 3836 V ~

source) SR 3.3.8.1.4

b. Time Delay 2 SR 3.3.8.1.1 ~ 9.2 seconds ~.-J (1 per SR 3.3.8.1.2 ~ 10.8 seconds' a) source) SR 3.3.8.1.4
5. 4 kV Emergency Bus Undervoltage (Degraded Voltage non-LOCA)
a. Bus Undervoltage 2 (1 per source)

SR 3.3.8.1.1 SR 3.3.8.1.2 SR 3.3.8.1.4

~ 4116 V and S 4186 ve'..AJ

b. Time Delay 2 SR 3.3.8.1.1 ~ 57.8 s~s and ~ 64.2 (1 per SR 3.3.8.1.2 seCOndS~ ~

~ ~A~V5rn~ I~_~

{  :~~owable~ v3~~1esV a;r:: ~ 3713 V with internal seconds and ~ 1.1 sec s, 'I' 4.b ~ 8.4 seconds and ~ .6 seconds,

~ 4065 V and ~ 408 V, with internal I 5.a 5.b ~ 57.0 seconds a ~ 63.0 seconds.

-~J!pst~~po~ompletion of modification 96-01511, pBA *_~_.n_.~.",~~=

later than Mar:~_1~",~q9~.:---~/

--_*.- ~:~'6'5---J_' __"__' ~ Amendment No. 230

/'

I

PAM Instrumentation 3.3.3.1 Table 3.3.3.1-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITIONS REFERENCED REQUIRED FROM REQUIRED FUNCTION CHANNELS ACTION 0.1

1. Reactor Pressure 2 E
2. Reactor Vessel Water Level (Wide Range) 2 E
3. Reactor Vessel Water Level (Fuel Zone) 2 E
4. Suppressfon Chamber Water Level (Wide Range) 2 E
5. Drywell Pressure (Wide Range) 2 E
6. Drywell Pressure (Subatmospheric Range) 2 E
7. Drywell High Range Radiatfon 2 F
8. Penetratfon ~IV Positfon 2 per penetration flow path (a)(b)

E 9.

10.

Deleted Deleted

~

11. Suppressfon Chamber Water Temperature 2(c) E (a) Not required for isolation valves whose associated penetration flow path is fsolated by at least one closed and deactfvated automatfc valve, closed manual valve, blind flange, or check valve wfth flow through the valve secured.

(b) Only one posftion indication channel fs required for penetration flow paths with only one installed control room indication channel.

(c) Each channel requfres 10 resfstance temperature detectors (RTDs) to be OPERABLE with no two adjacent RTDs inoperable.

PBAPS UNIT 2 3.3-26 Amendment No. 259

RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 <page 1 of 3)

Reactor Protection System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNElS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.l REQUIREMENTS VALUE

1. Wide Range Neutron Moni tors
a. Peri od - Short 2 3 G SR 3.3.1.1.1 ~ 13 seconds SR 3.3.1.1.5 SR 3.3.1.1.12 SR 3.3.1.1.17 SR 3.3.1.1. 18 5(a) 3 H SR 3.3.1.1.1 ~ 13 seconds SR 3.3.1.1.6 SR 3.3.1.1.12 SR 3.3.1.1.17 SR 3.3.1.1.18
b. Inop 2 3 G SR 3.3.1.1.5 NA SR 3.3.1.1.17 5(a) 3 H SR 3.3.1.1.6 NA SR 3.3.1.1.17
2. Average Power Range Monitors
a. Neutron Flux-High 2 G SR 3.3.1.1.1  : ; 15.0% RTP (Setdown) SR 3.3.1.1.8 SR 3.3.1.1.11 SR 3.3.1.1.12
b. Simulated Thermal F SR 3.3.1.1.1  : ; 0.65 W Power-High SR 3.3.1.1.2 + 63.7S RTP(b) and::;; 118.0%

RTP SR 3.3.1.1.8 SR 3.3.1.1.11 SR 3.3.1.1.12

c. Neutron Flux-High F SR 3.3.1.1.1  : ; 119.7% RTP SR 3.3.1.1.2 SR 3.3.1.1.8 SR 3.3.1.1.11 SR 3.3.1.1.12
d. Inop 1,2 G SR 3.3.1.1.11 NA
e. 2-0ut-Of-4 Voter 1.2 G SR 3.3.1.1.1 NA SR 3.3.1.1.11 SR 3.3.1.1.17 SR 3.3.1.1. 18
f. OPRM Upscale ~25% SR 3.3.1.1.1 RTP SR 3.3.1.1.8 SR 3.3.1.1.11 SR 3.3.1.1.12 SR 3.3.1.1.19 (conti nued)

(a) With any control rod withdrawn from a core cell containing one or more fuel assemblies.

(b) 0.65 (W - AW) + 63.7% RTP when reset for single loop operation per LCO 3.4.1, "Recirculation Loops Operating."

(c) Each APRM channel provides inputs to both trip systems.

(d) See COLR for OPRM period based detection algorithm (PBDA) setpoint limits.

PBAPS UNIT 2 3.]-7 Amend~ent No. 251

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.5 CORE OPERATING LIMITS REPORT <COLR)

a. Core operating limits shall be established prior to ,each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:
1. The Average Planar Linear Heat Generation Rate for Specification 3.2.1; I"
2. The Minimum Critical Power Ratio for Specifications 3.2.2 and 3.3.2.1;
3. The Linear Heat Generation Rate for Specification 3.2.3;
4. The Control Rod Block Instrumentation for Specification 3.3.2.1; and
5. The Oscillation Power Range Monitor (OPRM)

Instrumentation for Specification 3.3.1.1.

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:
1. NED E-24011 -P-A, "G~ ryer ~l~l:~t.~ iE? ~~ry9a r;~AP, p,]iSi3 ~,,M.~~

for Reactor Fuel "1'(1' atesl appr~'vers~'l0' '='~rS""specifi ed

<!n ~-rOt,~'i"'''-Y'''''~~~'''''''~~-'w_",--,,~'">,-,," ,~ _ _

'f""'*:~"*",'l1*'_*#;W\ffl*. ..... . ..

2. NEDC-32162P, "MaXimu,m Extended LO,ad Line, Limit, an~d ARTS.

Improvement Program Analyses for Peach ..J4ltt~ Ato, .

Power Stat ion Uni ts 2 and 3<9' ~ ion j, MY:ch, 199 ;

(, .

3. PECo-FMS-OOOI-A, "Steady-State Thermal Hydraullc Analysis of Peach Bottom Units 2 and 3 using the FIBWR Computer Code";
4. PECo-FMS-0002-A, "Method for Calculating Transient Critical Power Ratios for Boiling Water Reactors (RETRAN-TCPPECo)";
5. PECo-FMS-0003-A, "Steady-State Fuel Performance Methods Report";
6. PECo-FMS-0004-A, "Methods for Performing BWR Systems Transient Analysis";

(continued)

PBAPS UNIT 3 5.0-21 Amendment No. 254

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

7. PECb-FMS-0005-A, "Methods for Performing BWR Steady-State Reactor Physics Analysis";
8. PECo-FMS-0006-A, "Methods for Performing BWR Reload Safety Evaluations"; and
9. NEDO-32465-A, "Reactor Stabilit~...:Detect and Suppress Solutions LiCenS~~.M.~~Ol09YAnd Reload APplicationW ~t y-
c. The core o~erating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident'analysis limits) of the safety analysis are met.
d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC. "

5.6.6 Post Accident Monitoring (PAM) Instrumentation Report When a report is required by Condition B or F of LCO 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

PBAPS UNIT 3 5.0-22 Amendment No. 254

AC Sources--Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEI.LLANCE FREQUENCY SR 3.8.1.13 ------------------NOTE---------------------

A single test at the specified Frequency will satisfy this Surveillance for both units.

Veri fy each DG's

  • utomatic trips are 24 months bypassed on an actual or simulated ECCS initiation Signal'fxcePt:"~-'"

a: Eng~peed;

b. Generator differential overcurrent;
c. Generator ground neutral overcurrent; and Manual cardox initiation.

(continued)

PBAPS UNIT 3 3.8-13 Amendment No. 214

Completion Times 1.3 1.3 Completion Times DESCRIPTION However, when a subsequent division, subsystem, component, (continued) or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and
b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as mea~ured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., .

"once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phras

  • from discovery..
  • xamp * .:a; e 0 '\

p etion Time.

for Condition A and e 10 da e ompl ~i... tf..... J... )..

. oU.. T 1.. ma~~

(continued)

PBAPS UNIT 3 1.3-2 Amendment No. 214

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.I Restore 7 days Function X Function X subsystem subsystem to inoperable. OPERABLE status.

B. One 8.1 Restore Function Y Function Y subsystem subsystem to inoperable. OPERABLE status.

C. One C.I Restore 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Function X Function X subsystem subsystem to inoperable. OPERABLE status.

AND OR One C.2 Restore 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Function Y Function Y subsystem subsystem to inoperable. OPERABLE status.

(continued)

PBAPS UNIT 3 1.3-6 Amendment No. 214

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition 8 are concu applicable. The Completion Times for Condition A and rrently Condition B are tracked separ ately for each subsy starti ng from the time each subsystem was declaredstem, inoperable and the Condition was entered. A separ Completion Time is estab lishe d for Condition C and ate tracked from the time the second subsystem was declared inope rable (i.e. , the time the situa tion described in Condition C was discovered).

If Required Action C.2 is completed within the speci fied Completion Time, Conditions 8 and C are exite d. If the li;:1~~:;~~~!!I~~~i~@i!~i1:~:;~:~il~~g;:f;~~he. J i;rtre~"tcomple"iiOn~T'i";;;s of Condition A-;~-B'-are modif b'y-~a\

! logical connector/... with a separ e 10 day Comp ~ tion ied Time \

I measured from ~h. time it was scovered the 0 was not met. In this .. ample, withou the separat.e ompletion Ti,me!, \1\

it would be p sible to alt nate between nditio ns A, B, I and C in su a manner th o'perati on co d cont inue ,. t indef inite without ev resto ring sy ems to meet The separ te Completi Time modi fie y the phrase the Rfr L*. ,

i discove~ of failu r 0 meet the LC is designed to . event I indefi te continu operation who e not meeting the co. I This ompletion me allows for exception to th normal )

Uti zero" for eginning the mpletion Time "cl k". In

  • thi instan ce, the Completion ime "time zero" i speci fied
  • as commencing at the time the LCD was initi ally not met, instead of at the time the associated Condition was entered~ .

. . . ._ _ ---- ---- ---- .~~~

i4J~ ln~~ >~.~ ,-'" . 'ffl'-'R'4'~:f,~~-.y4~4-.i!iif-r is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO.

However, doing so would be inconsistent with the basis of the Completion Times. Therefo re, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LeO.

These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

'------'------------~ .-.- ---

PBAPS UNIT 3 1.3-7 Amendment No. 214

SLC System 3.1.7 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC) System LCO 3.1.7 Two SLC subsystems shall be OPERABLE.

APPLICABILITY: MODES ,I and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Concentrat ion of boron A.I Verify the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in solution> 9.82% concentration and weight. temperature of boron in solution and pump suction piping Once per temperature are 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> within the limits of thereafter Figure 3.1.7-1.

AND A.2 Restore concentration of boron in solution 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

,~~

~

to ~ 9.82% weight.

B. One SLC subsystem B.1 Restore SLC subsystem 7 days inoperable for reasons to OPERABLE status.

other than Condition A.

(continued)

PBAPS UNIT 3 3.1-20 Amendment No. 214

AC Sources-Operating 3.8.1 ACTIONS

- - - - - - - - - - - - - - - - - - - - - ~ - - - - - - - - - - - - - - - NOTE - - - - - - - ~ - - - - - - - - - - - - - - - - - -'- - - - - - - - --

LCO 3.0.4.b is not applicable to DGs.

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ 1- - - - - - - - - - - - - - - - - - - - - - - - - - - I CONDITION REQUIRED ACTION COMPLETION TIME A. One offsite circuit A.I Perform SR 3.8.1.1 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 1,1 inoperable. for OPERABLE offsite circui.ts.

Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, thereafter AND I

A.2 Declare required 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from feature(s) with no discovery of no offsite power offsite power to available inoperable one 4 kV when the redundant emergency bus requiredfeature(s) concurrent with are in~p~rable. inoperability of redundant required feature(s)

A.3 Restore offsite circuit to OPERABLE status.

(continued)

PBAPS UNIT 3 3.8-2 Amendment No. 255

Distr ibutio n Systems--Operating 3.8.7 A,CTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ,One or more required ------ ------ -NOT E---- ------ --

Unit 2 AC elect rical Enter applicable Conditions power distri butio n and Required Actions of LCO subsystems inoperable. 3.8.4 , "DC Sources--Operating," when Condition A resul ts in a de-energization of a required Unit 2 125 V batte ry charger.

A.l Restore required 7 days Unit 2 AC elect rical power distri butio n subsystem(s) to OPERABLE statu s.

B. One Unit 2 DC B.l Restore Unit 2 DC 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> elect rical power elect rical power distri butio n subsystem distri butio n inoperable. subsystem to OPERABLE statu s.

C. One Unit 3 AC e.l Restore Unit 3 AC 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> elect rical power elect rical power distri butio n subsystem distri butio n inoperable. subsystem to OPERABLE statu s.

(continued)

PBAPS UNIT 3 3.8-42 Amendment No. 214

Distribution Systems-Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One Unit 3 DC 0.1 Restore Unit 3 DC 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> electrical power electrical power distribution subsystem distribution inoperable. subsystem to OPERABLE status.

E. Required Action and E.1 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, B, C, or 0 not met.

F. Two or more inoperable F.1 Enter LCO 3.0.3. Immediately electrical power distribution subsystems that result in a loss of function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify: 7 days

a. Correct breaker alignments to required AC electrical power distribution subsystems; and
b. Indicated power availability to required AC and DC electrical power distribution subsystems.

PBAPS UNIT 3 3.8-43 Amendment No. 265

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-1 EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limit s. Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after

~ 25% RTP AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> there after Example 1.4-2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector "AND" indicates that both Frequency requirements must be met.

reactor power is increased from a power level <Each time 25% RTP to

~ 251 RTP, the Surveillance must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The use of "once" indicates a single performance satis fy the specified Frequency (assuming no otherwill Frequencies are connected by "AND"l. This type does not qualify for the extension allowed by SR of3.0.2 Frequency

.

(continued)

PBAPS UNIT 3 1.4-3 Amendment No. 214

lOP Instrumentation 3.3.8 .1 TabLe 3.3.8.1 -1 (page 1 of 1)

Loss of Power Instrumentation REQUIRED CHANNELS SURVEILLANCE ALLO\oJABLE FUNCTION PER BUS REQUIREMENTS VALUE

1. 4 kV Emergency Bus Undervoltage (Loss of Voltage)
a. Bus Undervoltage SR 3.3.8.1 .3 NA SR 3.3.8.1 .4
2. 4 kV Emergency Bus Undervoltage (Degraded Voltage Low Setting )
a. Bus Undervoltage 2 SR 3.3.8.1 .1 ~ 2286 V and s 2706 V (1 per SR 3.3.8.1 .2 source) SR 3.3.8.1 .4
b. Time Delay 2 SR 3.3.8.1 .1 ~ 1.5 seconds and (1 per SR 3.3.8.1 .2 s 2.1 seconds source) SR 3.3.8.1 .4
3. 4 kV Emergency Bus Undervoltage (Degraded VoLtage High Setting )
a. Bus Undervoltage 2 SR 3.3.8.1 .1 ~ 3409 V and s 3829 V (1 per SR 3.3.8.1 .2 source) SR 3.3.8.1 .4
b. Time Delay 2 SR 3.3.8.1 .1 ~ 23.0 seconds and (1 per SR 3.3.8.1 .2 S 37.0 seconds source) SR 3.3.8.1 .4
4. 4 kV Emergency Bus Undervoltage (Degraded Voltage LOCA)
a. Bus Undervoltage 2 SR 3.3.8.1 .1 ,e\) '/

~ 3766 V and s 3836 V~

(1 per SR 3.3.8.1 .2 source) SR 3.3.8.1 .4

b. Time Delay 2 SR 3.3.8.1 .1 ~ 9.2 seconds al'ld.., ~

(1 per SR 3.3.8.1 .2 S 10.8 seCOndS~

source) SR 3.3.8.1 .4

5. 4 kV Emergency Bus UndervoLtage (Degraded Voltage non-LOCAl
a. Bus Undervoltage (1

source) 2 per SR 3.3.8.1 .1 SR 3.3.8.1 .2 SR 3.3.8.1 .4

~ 4116 V and ~ 4186 vi f

b. Time Delay 2 SR 3.3.8.1 .1 ~ 57.8 s~~a nd s 64.2 (1 per SR 3.3.8.1 .2 seCOn dS~ -

source) SR 3.3.8.1 .4 a particu Lar Function 4 or 5 elay, its seconds, no later than March 1 2000.

Amen ment No. 235

RPS Instrumentation 3.3.1 .1 Table 3.j.1.1- 1 (page 1 of 3)

Reactor Protecti on System Instrum entation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE FU'NCTION CONDITIONS ALLOWABLE SYSTEM ACTION D.1 REQUIREMENTS VALUE

1. Wide Range Neutron Monitors
a. Period*S hort 2 3 SR G 3.3.1.1 .1 ~ 13 seconds SR 3.3.1.1 .5 SR 3.3.1.1 .12 SR 3.3.1.1 .17 SR 3.3.1.1 .18 5(a) 3 H SR 3.3.1.1 .1 ~ 13 seconds SR 3.3.1.1 .6 SR 3.3.1.1 .12 SR 3.3.1.1 .17 SR 3.3.1.1 .18
b. I nop 2 3 G SR 3.3.1.1 .5 NA SR 3.3.1.1 .17 5(a) 3 H SR 3.3.1.1 .6 NA SR 3.3.1.1 .17
2. Average Power Range Monitors
a. Neutron Flux-High 2 (Setdown)

G SR 3.3.1.1 .1 s 15.0% RTP SR 3.3.1.1 .8 SR 3.3.1.1. 11 SR 3.3.1.1 .12

b. Simulated Thermal F SR Power*High 3.3.1.1 .1 S 0.65 W SR 3.3.1.1 .2 + 63.7% RTP(b) and S 118.0%

RTP SR 3.3.1.1 .8 SR 3.3.1.1. 11 SR 3.3.1.1 .12

c. Neutron Flux-High F SR 3.3.1.1 .1 S 119.7% RTP SR 3.3.1.1 .2 SR 3.3.1.1 .8 SR 3.3.1.1. 11 SR 3.3.1.1 .12
d. In,op 1,2 SR G 3.3.1.1. 11 NA
e. 2-0ut-O f*4 Voter 1,2 G SR 3.3.1.1 .1 NA SR 3.3.1.1. 11 SR 3.3.1.1. 17 SR 3.3.1.1 .18
f. OPRM Upsca 1e ~25% SR 3.3.1.1 .1 RTP SR 3.3.1.1 .8 SR 3.3.1.1. 11 SR 3.3.1.1. 12 SR 3.3.1.1. 19 (continued)

(a) With any control rod withdrawn from a core cell contain ing one or more fuel assemblies.

(b) 0.65 (W . 4Wl + 63.7% RTP when reset for single loop operation per LCO 3.4.1, "Recirculation Loops Operating."

(c) Each APRM channel provides inputs to both trip systems.

(d) See COLR for OPRM period based detectio n algorith m (PBDA) setpoin t limits.

PBAPS UNIT 3 3.3-7 Amendment No. 254

Attachment 3 Peach Bottom Atomic Power Station, Units 2 and 3 Markup of Proposed Technical Specifications Bases Page Changes Unit Applicability Section List of Affected Pages Unit 2 Unit 3 2.2 B 3.8-30 X X 2.3 B 3.1-42 X X 2.3 B 3.1-43 X X 2.3 B 3.8-8 X X 2.3 B 3.8-9 X X 2.3 B 3.8-89 X X 2.3 B 3.8-90 X X 2.3 B 3.8-91 X X

AC Sources - Operat i ng B 3.8.1 BASES SURVEILLANCE S8 3.8.1.12 (continued)

REQUIREMENTS The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with the expected fuel cycle lengths.

This S8 is modified by a Note. The reason for the Note is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coo1,ant and oil being continuously circulated and temperature maintained cons i stent wi th manufacturerGr,~.elll1lencla,.,t.ioR,.".~'. -,'-,..L-;"'.'~---""'.'.""'.----'_, . . . ,

pv emt7JCvx1J', . Qhv~m{J.AJ~ .

fA) I 'II be 'k.s:rer) r: 6r *J()eJ l \ J

\

SR 3.8.1.13 VIrJ-~;~~(.~~>)

Consistent with Regulatory Guide 1.9 {Ref:-3r:----E.. -"'--~---~~\

paragraph C.2.2.12, this Surveillance demonstrates that OG \

non-c,ritica1 protective ,function,s., (e.g., high jacket waterf) emperature) are by ass~d on an ECCS initiation test sign #

~w~~~ ~~~~~l~~~~~n~ngine overspeed,

__

enerator differential overcurren , genera or round neutra

.-.. .~**vercurrent and manual car x in"tiatio i Gt I su s an a l a e un". The non-cri t i a I url s an continue to provide an I alarm on an abnormal engine condition. This alarm provides /'

the operator with sufficient time to react appropriately. I The DG availability to mitigate the DBA is more critical I than protecting the engine against minor problems that are /

not immediately detrimental to emergency operation of the .///

DG. E,:-" -',.",..".~~__<<"" ,*,_ _ ._~.,,~**~**w ***,..,,... _,_._~_,- - _....~._......._ .... - ... _-><_..

The 24 month Frequency is based on engineering judgment, takes into consideration plant condition~ required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

To minimize testing of the DGs, the Note to this SR allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

(continued)

PBAPS UNIT 2 B 3.8-30 Revision No. 1

SLC System B 3.1.7 BASES ACTIONS A.l and A.2 (continued)

Continued operation is only permitted for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before boron solution concentration must be restored to ~ 9.82%

weight. Taking into consideration that the SLC System design capab ility still exist s for vessel injec tion under these conditions and the low proba bility of the tempe rature and concentration limit s of Figure 3.1.7-1 not being met, the allowed Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is acceptable and provides adequate time to resto re concentration to within limit s.

The second Completion Time for Required Action estab lishe s a limit on the maximum time allow Afor any Qmbination of concentration out of limit s inoperable su~~ms during any singl e contiguous ~QfUrrence fail ing~ meet the LCO.

of If Condition.,Kis entered while, for i nstanc~,~ SLC subsystem is i ~9perab1e and that subsystem is sub~~ntly returne~o OPERABLE, the LCO may already have been no~'mat fO~.uto 7 days. This situa tion could lead to a total du~* of 10 days (7 days in Condition B, followed by_~~y ~~condition A), since initia l failu re of the L~~ to res e the SLC System. Then an SLC subsystem could ,he found inoper~~g~Jn, and concentration could restored to within~ts. This could continue ind 1nite1y. ~

This Comp1etio ime allows for an exception to th~ ~a1 "time zero" r beginning the allowed outage time "clock;~,

resul ting On estab lishin g the "time zero" at the time the ,

LCO was nitia11y not met instead of at the time Condition was ered. The 10 day Completion Time is an accep limit ation on this poten tial to fail to meet the LCO table indef initel y.

If one SLC subsystem is inoperable for reasons other Condition A, the inoperable subsystem must be resto redthan OPERABLE statu s within 7 days. In this condition, the to remaining OPERABLE subsystem is adequate to perform shutdown function. However, the overall relia bilit y the is reduced because a singl e failu re in the remaining OPERA BLE subsystem could resul t in the loss of SLC System shutdown capab ility. The 7 day Completion Time is based on the (continued)

PBAPS UNIT 2 B 3.1-42 Revision No. 0

SLC System B 3.1.7 BASES ACTIONS B.1 (continued) avail abili ty of an OPERABLE subsystem capable of performing the intended SLC System function and the low proba a DBA or severe trans ient occurring concurrent withbility the of failu re of the Control Rod Drive (CRD) System to shut down

/.!!l~h.,I!La~"!,.:_,~_"~. __ ,~__,~ -,-- --- _..-.~

,~ The- second Completion Time for Required Action B.1 ~\

J estab lishes a limit on the maximum time allowed for a n y combination of concentration out of 1 imits or inope~4~le SLC ,~\

subsystem during any single contiguous occurrence to meet th~,LCO. If Condition B is entered whpe,/sfforfailin g l instance, concentration is out of limit s, all~'ls {

subsequently retur.-ned to within limit s, tf"b~,rLCO may already have been not metfQ r up to 3 days. Tb.i's situa tion could lead to a total durattpn of 10 days J! days in Condition followed by 7 days in tbQdition B~since initia l failu re A,of \

the LCO, to resto re the st~y~tem. Then concentration \

cou,ldd bbe found out of limit~f~.gain, and t,he SLC subsystem cou e restored to OPERABLE. This cou d continue f,.

I ind efin itel y../ '#'"  !

I\

I, Th is Comp1eti on Ti,~ lows for an eep tion to the normal 'I "time zero" for",beginning the allowed tage time "clock," ,

\\ resul ting in ~lablishing the "time zero t the time the (),/

LCO was initi ally not met instead of at the

\ was ent~,Fld. The 10 day Completion Time is a imeaccep Condition B limit Jtion on this potential to fail to meet the LCD table "~

I

\'"" ~ ingefinite1y. /",,,-

/

.,~,~, ~~-~-,---"""---,~",,./ '

If both SLC subsystems are inoperable for reasons other than Condition A, at least one subsystem must be resto red to OPERABLE statu s within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The allowed Comp of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is considered acceptable given the low letion Time probability of a DBA or trans ient occurring concurrent with the failu re of the control rods to shut down the react or.

If any Required Action and associated Completion Time is not met, the plant must be brought to a MODE in which does not apply. To achieve this statu s, the plant the LCO must be (continued)

PBAPS UNIT 2 B 3.1-43 Revision No. 0

AC Sources - Operat ing B 3.8.1 BASES ACTIONS A.:.2. (continued)

The remaining OPERABLE offsite circuits and DGs are adequate to supply electrical power to the onsite Class IE Distribution System. Thus, on a component basis, single failure protection may have been lost for the required feature's function; however, function is not lost. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

A.3 The 4 kY emergency bus design and loading is sufficient to allow operation to continue in Condition A for a period not to exceed 7 days. With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the plant safety systems. In this condition, however, the remaining OPERABLE offsite circuits and the four DGs are adequate to supply electrical power to the onsite Class IE Distribution System.

The 7 day Completion Time takes into account the redundancy, capacity, and capability of the remaining AC sources,

~::S~~~~~~i~:~U~~~gr~~~~r~;r~~tthe low probabil ity of a ... } "

J~~~P1;ti'O~-~fiie-fo'rV-"Requi recrAction A.3 ---"'"

(e~tablishes a limit on the maximum time allowed f any cdm~tnation of required AC power sources to b ° operable

\\

\

durin~'a~y single contiguous occurrence of 11ing to meet I

I LCO 3.8.l:'l-",or b. If Condition A is en ed while, for r

instance, a DG-.J.s inoperable, and t OG is subsequently returned OPERABL~the LCO maya ady have been not met for up to 7 days. This~ °tuatio ould lead to a total of 14 days, since in it ia1 ° re to meet LCO 3.8. 1. a or b, to restore the offsite ci i. At this time, a DG could again become inoperable, e circui estored OPERABLE, and an  !

additional 7 da~Y1for a total 0 .. days) allowed prior to f complete rest ~ion of the LCO. T~ 4 day Completion Time I provides a 1mit on the time allowed in specified i Conditi after discovery of failure to mee ~CO 3.8.1.a or b.~._ ~ s limit is considered reasonable for situations in

~h Conditions A and B ar concurrently. The (continued)

PBAPS UNIT 2 B 3.8-8 Revision 5

AC Sourc es - Opera ting B 3.8.1 BASES ACTIONS A3 (

"AND' ).,*ccon nector betwe en the 7 day and 14 day Times m~~n~ that both Comp letion Times apply .

and the more" E~str ictiv e Comp letion Tim

~

As in Requi red AC~ 2, th omple tion Time allow s for excep tion to the norma l e zero" for begin ning the allow ed outag e time " ock." is excep tion resul ts in estab lishin g th ime zero" at t time the LCO was initia lly met, instea d of at the t that Cond ition A red.

B.1 The 33 kV Conow ingo Tie-L ine, using a separ ate 33/13 .8 kV transf orme r, can be used to suppl y the circu it norma lly suppl ied by startu p and emerg ency auxil iary transf orme r no.

2. While not a quali fied circu it, this altern ate sourc e is a direc t tie to the Conow ingo Hydro Statio n that provi des a highl y reliab le sourc e of power becau se: the line and transf ormer s at both ends of the line are dedic ated to the suppo rt of PBAPS; the tie line is not subje ct to damag e from adver se weath er condi tions; and, the tie line can be isola ted from other parts of the grid when neces sary to ensur e its avail abili ty and stabi lity to suppo rt PBAPS . The avail abili ty of this highl y reliab le sourc e of offsi te power permi ts an exten sion of the allow able out of servi ce time for a DG to 14 days from the disco very of failu re to meet LCO 3.8.1 .a or b (per Requi red Actio n B.5). There fore, when a DG is inope rable , it is neces sary to verif y the avail abili ty of the Conow ingo Tie-L ine imme diatel y and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> there after . The Comp letion Time of "Imm ediate ly" refle cts the fact that in order to ensur e that the full 14 day Comp letion Time of Requi red Actio n B.5 is avail able for comp leting prepla nned maint enanc e of a DG, prude nt plant pract ice at PBAPS dicta tes that the avail abili ty of the Conow ingo Tie-L ine be verif ied prior to makin g a DG inope rable for prepla nned maint enanc
e. The Conow ingo Tie-L ine is avail able and satis fies the requir emen ts of Requi red Actio n B.1 if: 1) the Conow ingo line is suppl ying power to the 13.8kV SBO Switc hgear OOA306;
2) all equip ment requi red, per SE-11 , to conne ct power from the Conow ingo Tie-L ine to the emerg ency 4kV buses and to isola te all non-SB O loads from the Conow ingo Tie-L ine is avail able and acces sible ;; and 3) comm unicat ions with the Conow ingo contr ol room indic ate that requi red equip ment at Conow ingo is avail able. If Requi red Actio n B.1 is not met or the (conti nued)

PBAPS UNIT 2 B 3.8-9 Revis ion 38

Distribution Systems--Operating B 3.8.7 BASES ACTIONS ,/ £:...l (conti nued)

The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystem to be inop~ab.le during any single contiguous occur- ence of

, faili to meet LCO 3.8.7.a. If Condition is entered

while, instance, a Unit 2 DC bus is
  • operable and I subsequent)"returned OPERABLE, this L may already have I I been not met fa( up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Th* situation could lead (

\, to a total duratl~n of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, nce initial failure of \

I the LCO, to restor~~he Unit 2 Electrical Power .

\,. Distribution System. 'At thi ime a Unit 2 DC bus could again become inoperable~ Unit 2 AC Electrical Power J Distribution System cou restored OPERABLE. This could \

I continue indefinitely \

\ This Completion 1) allows for a exception to the normal \

\ "time zero" fo~fieginning the allow outage time "clock." \

I This results/in establishing the "ti zero* at the time ) '

J LCO 3.8.7.~"~as initially not met, ins ad of at. the time

( Conditioort was entered. The 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> Co 1etion Time is an .

\. accept~e lillitation on this potential to'{ail to meet the. .

". LCO ~*8. 7.a indefinitely. "'-J

~

~ -------- . - ----~-

-'"'

1W.

With one Unit 2 DC electrical power distribution subsystem inoperable, the remaining DC electrical power distribution subsystem is capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure.

The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the Unit 2 DC electrical power distribution subsystem must be restored to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Condition D represents one Unit 2 electrical power distribution subsystem without adequate DC power, potentially with both the battery(s) significantly degraded and the associated charger(s) nonfunctioning. In this situation the plant is significantly more vulnerable to a complete loss of all Unit 2 DC power. It is, therefore, imperative that the operator's attention focus on (continued)

PBAPS UNIT 2 . B 3.8-89 Revision No. 0

Distribution Systems--Operating B 3.8.7 BASES ACTIONS ~ (continued) stabilizing the plant, minimizing the potential for loss of po~er to the remaining electrical power distribution subsystem, and restoring power to the affected electrical power' distribution subsystem.

This 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is more conservative than Completion Times allowed for the majority of components that would be without power. Taking exception to LCO' 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, is acceptable because of: .

a. The potential for decreased safety when requiring a change in plant conditions (l.e., requiring a shutdown) while not allowing stable operations to continue;
b. The potential for decreased safety when requiring entry into numerous applicable Conditions and Required Actions for components without DC power, while not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected subsystem;
c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time for DC electrical power distribution subsystems is consistent with Regulatory Guide 1.93 (Ref. 2).

'W'w .* ,"" .' ." .. ,.... ....** . .,...... . ,.......*.*. " , ,*** ,.,.,."~,.*.*_w.w**._ **, _ _* .-.,-_"_ _" . . . I Tfi~~~e~~~d**Compl~tio.,. Time'"'for *R~~~i~ed Action D.1,/"'",..:)

i'estaB~shes a 1imit on the maximum time allow fOr any ",\

combinatiQn of required electrical power

  • ribution \,

sUbsystems'~tGlbe inoperable during an 1ng1e contiguous occurrence of , fat ling to meet lC .8.7.a. If Condition 0 is entered while, fb~,instanc a Unit 2 AC bus is inoperable and subsequ~ '. restored OPERABLE, LCO 3.8.7.a may already have been ",00 met.. J or up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Thi s \

situation could lJi~to a totar'dur:ation of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, since \

initial fai1urJVbf LCO 3.8.7.a, to r&~\ore the Unit 2 DC \

Electrica!,c>Power Distribution System. At..,,,this time, a /

pnit~p.,AC bus could again become inoperabl~nd Unit 2 DC .l

~leetrical Power Distribution System could be 'r:estored,f"'/

OPERABLE. This could continue indefinitely. ">>,/.'w'

,.,.~ .,,__--.. . .--'-'-..-- _--...-----*"."w-,***

,"'-"-"'-~----"'------~ (conti nued)

PBAPS UNIT 2 B 3.8-90 Revision No. 0

Distribution Systems-Operating B 3.8.7 BASES ACTIONS ime allows for exception to the normal inning thy lowed outage time "clock."

This allowance res i~tablishing the "time zero" at the time LCO 3.8.7.a . itially not met, instead of at the time Conditigp/r) was ente The 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> Completion Tim e i san ac/cept ab1eli mit at ion t his pot ent i a 1 0 f failin to meet the LCO indefinitely.

If the inoperable electrical power distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state. The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Condition F corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost. When more than one Condition is entered, and this results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the AC and DC electrical power distribution systems are functioning properly, with the correct circuit breaker alignment (for the AC electrical power distribution system only). The correct AC breaker (continued)

PBAPS UNIT 2 B 3.8-91 Revision No. 66

AC Sources - Operat i ng B 3.8 .1 BASES SURVEILLANCE SR 3.8 .1. 12 {continued}

REQUIREMENTS The Frequency of 24 month takes conditions required to persfor m the int o consideration plant intended to be con sis ten t with the Surveillance and is lengths. expected fuel cycle This SR is modified by a Note. The to minimize wear and tea r on the reason for the Note is the purpose of thi s tes tin g, the DGs during tes tin g. For standby conditions, tha t is, with DGs mu st be sta rte d from being continuously cir cul ate d and the eng ine coolant and oil con sis ten t with manufacturer re tem per atu re maintained commend~.

~~

()tr erl)v~(;,t)t1; ~O~"rl1

'tTl,?> ~i) J.. be 1estt:V p~ f' rcJ{uJ./!"ftyJI.f' .,.he sluiwn SR 3 .8. 1.1 3  !

~eo onsistent with Regulatory Guide 1.9 ('led(, Vruf;n I (,:ljltt /X...e.

paragraph C.2 .2. 12 , thi s Surveilla (Re f. 3), . ~~r~~

no n-c riti cal pro tec tiv e functions nce dem onstrates tha t DG

~~ .... ~

,../ NO'nef)"~ . emper A ature) are bypassed on an ECC(e. S g., high jac ket water ini tia tio n tes t signa}~;

( 11'" JIG crOOcl'f prote~!*e func't?1onsjpngi

~Lt:>are generator dif fer en ,a ne overspeed, overcurrent and manual ove rcurr:n~,.ge~er<:).r~~ro

\ O\Al O(('l{1 , v Y=

cardox lnl und neu tra

\ (>. ) \ ~mtdrc I./ er sub an tia l d age to e tla tlo n plJr'"tny~~:{ __

I trl ps are ypasse url un ,. e non-c~l lca

\ 1rr ftiS eXtt{f. s ne on lnu e to pro e an

~ f -

ala rm on an abnormal the operator with sufeng ine condition. This alarm vld provides fic ien t time to rea ct app rop ria tel y.

The DG av ail ab ilit y to mi than pro tec tin g the enginetigaga ate the DBA is more cri tic al not immediately detrimental to ins t minor problems tha t are emergency operation of the DG.

The 24 month Frequency is based on takes int o consideration pla engineering judgment, perform the Surveillance, and is nt con dit ions required to with expected fuel cycle lengths. intend ed to be con sis ten t To minimize tes tin g of the sin gle tes t (in ste ad of two DG s, the Note to thi s SR allows a tes sat isf y the requirements for botts, h one for each un it) to un since the main purpose of the Surve its . This is allowed performing the tes t on eit he r un it. illance can be met by these Su rve illa nce s, the DG should If the DG fai ls one of on both un its , unless the cause of be considered inoperable dir ect ly rel ate d to only one un it. the fai lur e can be (continued)

PBAPS UNIT 3 B 3.8-30 Revision No. 1

'SlC System B 3.1.7 BASES ACTIONS A.I and A.2 (continued)

Continued operation is only permitted for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before boron solution concentration must be restored to ~ 9.82%

weight. Taking into consideration that the SlC System design capab ility still exist s for vessel injec tion under these conditions and the low probability of the tempe rature and concentration limit s of Figure 3.1.7 -1 not being met, the allowed Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is acceptable and provides adequate time to resto re concentration \D within l~l!its ..,.,",. ~,.",~,~_ ~.,_._ . , ~ __.._._",,/-'~'."--"""-.~'-~'----

!The econd Completion Time for Required Acti A.l estab *shes a limit on the maximum time al wed for any combina . n of concentration out of lim' s or inope rable SlC subsystems ~ring any single contiguo occurrence of failin g to me~the LCO. If Condit' n A is entered for instance, an~~ subsystem is noperable and thatwhile, subsystem is subseqUeQt1y retu~ d to OPERABLE, already have been not 1het fo~ P,to 7 days. Thisthesitua LCO may could lead to a total dura ,'on of 10 days (7 days in tion Condition B, followed by da¥s in Condition A), since initia l failu re of the 0, to'~store the SlC an SlC subsystem cou be found 1boperable againSystem , and

. Then concentration coul e restored to~'thin limit s. This could continue i finite ly.

This Completi Time allows for an excep 'on to the normal

-time zero" or beginning the allowed outa time "clock,"

resul tin 1n establishing the "time zero" at e time the lCO was nitia lly not met instead of at the tim Condition was e ered. The 10 day Completion Time is an acceptable A limit ation on this potential to fail to meet the LCO ~

ndefi nitely . -~

~ . . -....-,.. -

B.I If one SlC subsystem is inoperable for reasons other Condition A, the inoperable subsystem must be restoredthan OPERABLE statu s within 1 days. In 'this condition, the to remaining OPERABLE subsystem is adequate to perform the shutdown function. However, the overall relia bility is reduced because a single failu re in the remaining OPERA BLE subsystem could resul t in the loss of SLC System shutdown capab ility. The 7 day Completion Time is based on the (continued)

PBAPS UNIT 3 B 3.1-4 2 Revision No. 0

SLC System B 3.1.7 BASES ACTIONS B.1 (continued) availability of an OPERABLE subsystem capable of performing the intended SLC System function and the low probability of a DBA or severe transient occurring concurrent with the J )

failure of the Control Rod Drive (CRD) System to shut down the plant *

. _--'~----"'-

The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for anY,.4ii' comb; nati on of concentrat 1on out of 11m; ts or i nopera,l>l'f! SLC sUbsystem("'lJ~ring any single contiguous occurrence J~fi"fail ing to meet the'tCQ. If Condition B is entered while;' for

nstance, concehttation 1s out of 1imi ts, ang,,1~

subsequently retur'Etid to within 1imits, . tb.~tco '!lay already have been not met fo p to 3 days. T~lS4 sltuatlon could lead to a total duratio ' of 10 days,,,{,3 days in Condition A, followed by 7 days in Con . ion ~J"" since initial failure of the LCO, to restore the SLC st'em. Then concentration coul d be found out of 1 imit$""i in, and the SLC subsystem could be restored to OPERABLE. *s could continue indefinitely. /i'

/l:;">f/f This Completion lime allows for an exce ion to the normal "time zero" for"beginning the allowed out e time "clock, II resulting il)r4stabl ishing the "time zero" a the time the LCO was i~ilially not met in$tead of at the t e Condition B was e~~ered. The 10 day Completion Time is an ceptable lilljJtation on this potential to fail to meet the 0

",.Jf{CIefinitely.

If both SLC subsystems are inoperable for reasons other than Condition A, at least one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The allowed Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is considered acceptable given the low probability of a DBA or transient occurring concurrent with the failure of the control rods to shut down the reactor.

If any Required Action and associated Completion Time is not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be (continued)

PBAPS UNIT 3 B 3.1-43 Revision No. 0

AC Sources -Operating B 3.8.1 BASES ACTIONS A.2 (continued)

The remaining OPERABLE offsite circuits and DGs are adequate to supply electrical power to the onsite Class IE Distribution System. Thus, on a component basis, single failure protection may have been lost for the required feature's function; however, function is not lost. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

The 4 kV emergency bus design and loading is sufficient to allow operation to continue in Condition A for a period not to exceed 7 days. With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the plant safety systems. In this condition, however, the remaining OPERABLE offsite circuits and the four DGs are adequate to supply electrical power to the onsite Class IE Distribution System.

The 7 day Completion Time takes into account the redundancy, capacity, and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.

"""""",,,,,, , , - - " '" ~ '">'~'~"~%'h Jhe""'sec~ona"'Com~p1etion Time ior"MReqiirred~ Action A.3 ".

/establishes a limit on the maximum time allowed fo~any , ~

/ combtR~~ion of required AC power sources to be Jnoperable 1,\

! duri ng anX si.. n. gl e cont i guous occurrence.e. ofJai1 i ng to meet \

! lCO 3.8.I.aQr b. If Condition A is e~~d while, for ~

I instance, a DG'4~ inoperable, and tl).at DG is subsequently k

! returned OPERABlE,""l.the lCO may al)'e"ady have been not met for I up to 7 days. This S1~ation;~ld lead to a total of 14 days, since initial ff~ ~e to meet lCO 3.8.1.a or b, to

\ restore the offsite Cir:CUlt. t this time, a DG could again become inoperable,~hE{ circuit tored OPERABLE, and an additional 7 days "(for a total of ays) allowed prior to complete restoration of the lCO. The day Completion Time )

providesJ~*rimit on the time allowed in a ecified Condjti6n after discovery of fa i1ure to meett-Q~.8.1. a or b.~This limit is considered reasonable for situations in )

which Conditions A and B are entered concurrently. The ~'

~ - ---",o"*__**~"*-*-"-~-----,_o~--~*_**----"lc*oni*i-nu;d)

PBAPS UNIT 3 B 3.8-8 Revision No. 5

AC Sources -Operating B 3.8.1 BASES ACTIONS

~--~~(cQ.~tinued)

A.3

-~'---------:- - ~~ c#""/

r )

"AND" co~or between the 7 day and~mPletion \"

Times means tftat both completio~~ apply simultaneously, and the more res~ctive C~~ion Time must be met.

As in Required Acti the Completion Time allows for an exception to th ormal "time zero" for beginning the allowed out e time "clock." exception results in establi J..ng the "time zero" at th ime the LCO was

. lly not met, instead of at the . e that Condition A s entered.

B.1 The 33 kV Conowingo Tie-Line, using a separate 33/13.8 kV transformer, can be used to supply the circuit normally supplied by startup and emergency auxiliary transformer no.

2. While not a qualified circuit, this alternate source is a direct tie to the Conowingo Hydro Station that provides a highly reliable source of power because: the line and transformers at both ends of the line are dedicated to the support of PBAPS; the tie line is not subject to damage from adverse weather conditions; and, the tie line can be isolated from other parts of the grid when necessary to ensure its availability and stability to support PBAPS. The availability of this highly reliable source of offsite power permits an extension of the allowable out of service time for a DG to 14 days from the discovery of failure to meet LCO 3.8.1.a or b (per Required Action B.5). Therefore, when a DG is inoperable, it is necessary to verify the availability of the Conowingo Tie-Line immediately and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. The Completion Time of "Immediately" reflects the fact that in order to ensure that the full 14 day Completion Time of Required Action B.5 is available for completing preplanned maintenance of a DG, prudent plant practice at PBAPS dictates that the availability of the Conowingo Tie-Line be verified prior to making a DG inoperable for preplanned maintenance. The Conowingo Tie-Line is available and satisfies the requirements of Required Action B.1 if: 1) the Conowingo line is supplying power to the 13.8kV SBO Switchgear OOA306;
2) all equipment required, per SE-11, to connect power from the Conowingo Tie-Line to the emergency 4kV buses and to isolate all non-SBO loads from the Conowingo Tie-Line is available and accessible; and 3) communications with the Conowingo control room indicate that required equipment at Conowingo is available. If Required Action B.1 is not met or the (continued)

PBAPS UNIT 3 B 3.8-9 Revision No. 39

Distr ibutio n Systems--Operating B 3.8.7 BASES

(~:;=:~:~:~:-::=e~u~red-:-t;:~~-/

ACTIONS j establT~hes a limit on the maximum time allowed I combinatl~ of required distri butio n subsy st r any ~"

to be ,

inoperable ){~ring any singl e contiguous 0 rrence

!i I fail ing to me'e~ LCD 3.8.7 .a. If Condi

  • n C is entered while, for inst~ce, a Unit 3 DC bu s inoperable and of '\

.~

I subsequently retu~ed OPERABLE, (~

s lCO may already have .

been not met for up,+o 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> This situa tion could lead

/ to a total duration Of 10 h s, since initia l failu I the lCO, to resto re the lt 3 AC Elect rical Power re of '\

Distr ibutio n System. is time a Unit 3 DC bus could

) again become inoper. le, an Unit 3 AC Elect rical Power )

I Distr ibutio n Sys m could be estor ed OPERABLE. This could .

' continue inde nitely .

./. I I

.' . j. F i

This Co etion Time allows for an xception to the normal "t.im: ero ll for beginning the allowe outage time Ilclock.11 Th' resul ts in estab lishin g the Ittime ero" at the time o 3.8.7 .a was initia lly not met, inst d of at the time

~ Condition C was enter ed. The 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> Com let ion Time

\ " acceptable limit ation on this poten tial to ail to meetis the an

, lCO 3.8.7 .a indef initel y.

~-

With one Unit 3 DC elect rical power distri butio n subsystem inoperable, the remaining DC elect rical power distri subsystem is capable of supporting the minimum safetbutio y n

functions necessary to shut down the react or and maintain it in a safe shutdown condition, assuming no singl e failu The overall relia bility is reduced, however, because are.

singl e failu re in the remaining DC elect rical power distri butio n subsystem could resul t in the minimum required ESF functions not being supported. Therefore, the Unit 3 DC elect rical power distri butio n subsystem must be resto red to OPERABLE statu s within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Condition D repre sents one Unit 3 elect rical power distri butio n subsystem without adequate DC power, poten tially with both the batte ry(s) signi fican tly degra and the assoc iated charger(s) nonfunctioning. In this ded situa tion the plant is signi fican tly more vulnerable to a complete loss of all Unit 3 DC power. It is, there fore, imperative that the opera tor's atten tion focus on (continued)

PBAPS UNIT 3 B 3.8-89 Revision No. 0

Distribution Systems--Operating B 3.8.7 BASES ACTIONS D.1 (continued) stabilizing the plant, minimizing the potential for los~ of power to the remaining electrical power distribution subsystem, and restoring power to the affected electrical power distribution subsystem.

This 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is more conservative than Completion Times allowed for the majority of components that would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, is acceptable because of:

a. The potential for decreased safety when requiring a change in plant conditions (i.e., requiring a shutdown) while not allowing stable operations to continue;
b. The potential for decreased safety when requiring entry into numerous applicable Conditions and Required Actions for components without DC power, while not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected subsystem;
c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time for DC electrical power distribution subsystems is consistent with Regulatory Guide 1.93 (Ref. 2).

second Completion Time for Required Action D.

ish~a limit on the maximum time allow or any combination~ required electrical power,* ribution subsystems to b~:i,:,operable durin.,1.99,_ aa~, ingle contiguous occurrence of fa i 1 tRg to meet LCO~. 7 . a. If Condit ion D is entered while, for'iostanc~,'i Unit 3 AC bus is inoperable and subsequent ""festored OPERABLE, lCO 3.8. 7* a 1, may already have been p8{~m for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This \

situation COUld.. .,le~o a tota uration of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, since \.

initial failure/Df lCO 3.8.7.a, to store the Unit 3 DC J Electrical Ppwer Distribution System. t this time, a ).

Unit 3 A~r~Us could again become inopera e, and Unit 3 DC '

Elect,r:Jfal Power Distribution System could restored ._--.

f

~------------.... _-----

OP,EAABlE. This could continue indefinitely. ~_-

.-,,,.~

(continued)

PBAPS UNIT 3 B 3.8-90 Revision No. 0

Di stri buti on Systems -Operati ng B 3.8.7 BASES ACTIONS n

(/

'--'''''N''='-'__~~____ ,.,..., )

This Com p1et i 0\n"<ti m e l o n tot hen 0 rmal "time zero" for begi'Rtting the ed outage time "clock."

~

This allowance results',,! ablishing the "time zero" at /

the time LCO 3.8.7. s inlially not met, instead of at the time Con~ D was enter .~. The 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> Completion Ti~e.~,,:>_.a.ff-dcceptable li~itat~o~ his potential of f a..J ..l'rl1 g tom eet the LCOl ndef 1 n1 tel y .

If the inoperable electrical power distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state. The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Condition F corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost. When more than one Condition is entered, and this results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the AC and DC electrical power distribution systems are functioning properly, with the correct circuit breaker alignment (for the AC electrical power distribution system only). The correct AC breaker alignment ensures the appropriate separation and independence of the electrical buses are maintained, and power is available to each required bus. The verification of indicated power availability on the AC and DC buses (continued)

PBAPS UNIT 3 8 3.8-91 Revision No. 67