ML16132A440

Peach Bottom, Units 2 and 3 - Supplement to License Amendment Request, Revise Surveillance Requirement 3.5.1.5 Involving Recirculation Pump Discharge Valves

ML16132A440
Person / Time
Site:	Peach Bottom
Issue date:	05/11/2016
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML16132A440 (14)

Text

Exelon Generation May 11, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 200 Exelon Way Kennett Square. PA 19348 www exeloncorp com 10 CFR 50.90 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:

Supplement to License Amendment Request Revise Surveillance Requirement 3.5.1.5 Involving Recirculation Pump Discharge Valves

Reference:

Letter from Exelon Generation Company (D. P. Helker) to the U.S. NRC regarding "License Amendment Request to Revise Surveillance Requirement 3.5.1.5 Involving Recirculation Pump Discharge Valves" dated March 24, 2016. On March 24, 2016, in accordance with the provisions of 10 CFR 50.90 , "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC), submitted a request for an amendment to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, respectively (Reference).

The proposed amendment requested U.S. Nuclear Regulatory Commission (NRC) approval to revise the Frequency of Surveillance Requirement (SR) 3.5.1.5 from "Once each startup prior to exceeding 23% RTP," as modified by a Note stating, "Not required to be performed if performed within the previous 31 days" to "In accordance with the Surveillance Frequency Control Program." Based on follow-up discussions with the NRC, EGC has decided to revise the Frequency of SR 3.5.1.5 from "Once each startup prior to exceeding 23% RTP," as modified by a Note stating, "Not required to be performed if performed within the previous 31 days" to "In accordance with the lnservice Testing Program." Attachment 1 provides the evaluation of the proposed change. Attachment 2 provides a copy of the marked up TS pages that reflect the proposed change. Attachment 3 provides a copy of the marked up TS Bases pages that reflect the proposed change (information only). EGC has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Attachment 1 of the Reference letter. Although changes have been made to the no significant hazards consideration to reflect this revision, EGC has concluded that the U.S. Nuclear Regulatory Commission License Amendment Request Revise SR 3.5.1.5 Docket Nos. 50-277 and 50-278 May 11, 2016 Page 2 information provided in this supplement does not affect the bases for concluding that the proposed* license amendment does not involve a significant hazards consideration under the standards set forth in 1 O CFR 50.92. In addition, EGC has concluded that the information in this supplement does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no commitments contained within this submittal.

In accordance with 1 O CFR 50.91, "Notice for public comment; State consultation," paragraph (b), EGC is notifying the Commonwealth of Pennsylvania of this supplement by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Stephanie J. Hanson at 610-765-5143.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 11th day of May 2016. Respectfully, James Barstow Director, Licensing

& Regulatory Affairs Exelon Generation Company, LLC Attachments: 1 . Evaluation of Proposed Change 2. Markup of Proposed Technical Specifications Pages 3. Markup of Technical Specifications Bases Page (For Information Only) cc: Regional Administrator

-NRC Region I w/attachments NRC Senior Resident Inspector

-Peach Bottom Atomic Power Station NRC Project Manager, NRR -Peach Bottom Atomic Power Station Director, Bureau of Radiation Protection, Pennsylvania Department of Environmental Protection S. T. Gray, State of Maryland

SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.1.5 SR 3.5.1.6 SR 3.5.1.7 PBAPS UN IT 2 SURVEILLANCE Not required to be performed if w-:i-t-A+A-i;-A-e-p-revious 31 days. Verify each recirculation pump discharge valve cycles through one complete cycle of full travel or is de-energized in the closed position.

Verify automatic transfer of the power supply from the normal source to the alternate source for each LPCI subsystem inboard injection valve and each recirculation pump discharge valve. -------------------

NOTE --------------------

For the core spray pumps, SR 3.5.1.7 may be met using equivalent values for flow rate and test pressure determined using pump curves. Verify the following ECCS pumps develop the specified flow rate against a system head corresponding to the specified reactor pressure.

SYSTEM HEAD NO. CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF Core Spray 3,125 gpm 1 105 psig LPCI 8,600 gpm 1 20 psig 3.5-5 ECCS-Operati ng 3. 5 .1 FREQUENCY In accordance with the lnservice Testing Program. _ __, 0Ree eaeA ,} startup prior -to e><ceeding 23% RTP In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. (continued)

Amendment No. 293 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.1.5 SR 3.5.1.6 SR 3.5.1.7 PBAPS UN IT 3 SURVEILLANCE to be perfo-r-me&-:i f perforf11*-E}

within the previous 31 days. Verify each recirculation pump discharge valve cycles through one complete cycle of full travel or is de-energized in the closed position.

Verify automatic transfer of the power supply from the normal source to the alternate source for each LPCI subsystem inboard injection valve and each recirculation pump discharge valve. -------------------

NOTE --------------------

For the core spray pumps, SR 3.5.1.7 may be met using equivalent values for flow rate and test pressure determined using pump curves. Verify the following ECCS pumps develop the specified flow rate against a system head corresponding to the specified reactor pressure.

SYSTEM HEAD NO. CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF Core Spray 3,125 gpm 1 105 psig LPCI 8,600 gpm 1 20 psig 3.5-5 ECCS-Operating 3.5.l FREQUENCY In accordance with the lnservice Testing Program. J Once each startup prior to exceeding 23% RTP In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. (continued)

Amendment No. 296 ATTACHMENT 3 Markup of Technical Specifications Bases Pages Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Docket Nos. 50-277 and 50-278 License Amendment Request to Revise SR 3.5.1.5 Unit 2 TSB Pages B 3.5-12 Unit 3 TSB Pages B 3.5-12 BASES SURVEILLANCE REQUIREMENTS (continued)

The Frequency of this SR is in accordance with the lnservice Testing Program. PBAPS UN IT 2 SR 3.5.1.5 ECCS-Operating B 3.5.1 Cycling the recirculation pump discharge valves through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will close when required.

Upon initiation of an automatic LPCI subsystem injection signal, these valves are required to be closed to ensure full LPCI subsystem flow injection in the reactor via the recirculation jet pumps. De-energizing the valve in the closed position will also ensure the proper flow path for the LPCI subsystem.

Acceptable methods of de-energizing the valve include de-energizing breaker control power, racking out the breaker or removing the breaker. The specified Frequency is once during reactor startup before THERMAL POWER is> 23% RTP. However, this SR is modified by a Note that states the Surveillance is only required to be performed if the last performance was more than 31 days ago. Verification during reactor startup prior to reaching > 23% RTP is an exception to the normal +nservice Testing Program generic valve cycling Frequency, but is considered acceptable due to the demonstrated feliability of these valves. If the valve is inoperable and in the open position, the associated LPCI subsystem must be declared inoperable.

SR 3.5.1.6 Verification of the automatic transfer between the normal and the alternate power source (4 kV emergency bus) for each LPCI subsystem inboard injection valve and each recirculation pump discharge valve demonstrates that AC electrical power will be available to operate these valves following loss of power to one of the 4 kV emergency buses. The ability to provide power to the inboard injection valve and the recirculation pump discharge valve from either 4 kV emergency bus associated with the LPCI subsystem ensures that the single failure of an DG will not result in the continued B 3.5-12 Revision No. 114 BASES SURVEILLANCE REQUIREMENTS (continued)

The Frequency of this SR is in accordance with the lnservice Testing Program. PBAPS UN IT 3 SR 3.5.1.5 ECCS-Operating B 3.5.l Cycling the recirculation pump discharge valves through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will close when required.

Upon initiation of an automatic LPCI subsystem injection signal, these valves are required to be closed to ensure full LPCI subsystem flow injection in the reactor via the recirculation jet pumps. De-energizing the valve in the closed position will also ensure the proper flow path for the LPCI subsystem.

Acceptable methods of de-energizing the valve include de-energizing breaker control power, racking out the breaker or removing the breaker. -ttTe---5-pecified Frequency is once during reactor startup before THERMAL POWER is> 23% RTP. However, this SR is modified by a Note that states the Surveillance is only required to be performed if the last performance was more than 31 days ago. Verification during reactor startup prior to reaching>

23% RTP is an exception to the normal Inservice Testing Program generic valve cycling Frequency, but is considered acceptable due to the demonstrated reliability of these valves. If the valve is inoperable and in the open position, the associated LPCI subsystem must be declared inoperable.

SR 3.5.1.6 Verification of the automatic transfer between the normal and the alternate power source (4 kV emergency bus) for each LPCI subsystem inboard injection valve and each recirculation pump discharge valve demonstrates that AC electrical power will be available to operate these valves following loss of power to one of the 4 kV emergency buses. The ability to provide power to the inboard injection valve and the recirculation pump discharge valve from either 4 kV emergency bus associated with the LPCI subsystem ensures that the single failure of an DG will not result in the continued B 3.5-12 Revision No. 119 Exelon Generation May 11, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 200 Exelon Way Kennett Square. PA 19348 www exeloncorp com 10 CFR 50.90 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:

Supplement to License Amendment Request Revise Surveillance Requirement 3.5.1.5 Involving Recirculation Pump Discharge Valves

Reference:

Letter from Exelon Generation Company (D. P. Helker) to the U.S. NRC regarding "License Amendment Request to Revise Surveillance Requirement 3.5.1.5 Involving Recirculation Pump Discharge Valves" dated March 24, 2016. On March 24, 2016, in accordance with the provisions of 10 CFR 50.90 , "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC), submitted a request for an amendment to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, respectively (Reference).

The proposed amendment requested U.S. Nuclear Regulatory Commission (NRC) approval to revise the Frequency of Surveillance Requirement (SR) 3.5.1.5 from "Once each startup prior to exceeding 23% RTP," as modified by a Note stating, "Not required to be performed if performed within the previous 31 days" to "In accordance with the Surveillance Frequency Control Program." Based on follow-up discussions with the NRC, EGC has decided to revise the Frequency of SR 3.5.1.5 from "Once each startup prior to exceeding 23% RTP," as modified by a Note stating, "Not required to be performed if performed within the previous 31 days" to "In accordance with the lnservice Testing Program." Attachment 1 provides the evaluation of the proposed change. Attachment 2 provides a copy of the marked up TS pages that reflect the proposed change. Attachment 3 provides a copy of the marked up TS Bases pages that reflect the proposed change (information only). EGC has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Attachment 1 of the Reference letter. Although changes have been made to the no significant hazards consideration to reflect this revision, EGC has concluded that the U.S. Nuclear Regulatory Commission License Amendment Request Revise SR 3.5.1.5 Docket Nos. 50-277 and 50-278 May 11, 2016 Page 2 information provided in this supplement does not affect the bases for concluding that the proposed* license amendment does not involve a significant hazards consideration under the standards set forth in 1 O CFR 50.92. In addition, EGC has concluded that the information in this supplement does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no commitments contained within this submittal.

In accordance with 1 O CFR 50.91, "Notice for public comment; State consultation," paragraph (b), EGC is notifying the Commonwealth of Pennsylvania of this supplement by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Stephanie J. Hanson at 610-765-5143.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 11th day of May 2016. Respectfully, James Barstow Director, Licensing

& Regulatory Affairs Exelon Generation Company, LLC Attachments: 1 . Evaluation of Proposed Change 2. Markup of Proposed Technical Specifications Pages 3. Markup of Technical Specifications Bases Page (For Information Only) cc: Regional Administrator

-NRC Region I w/attachments NRC Senior Resident Inspector

-Peach Bottom Atomic Power Station NRC Project Manager, NRR -Peach Bottom Atomic Power Station Director, Bureau of Radiation Protection, Pennsylvania Department of Environmental Protection S. T. Gray, State of Maryland

SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.1.5 SR 3.5.1.6 SR 3.5.1.7 PBAPS UN IT 2 SURVEILLANCE Not required to be performed if w-:i-t-A+A-i;-A-e-p-revious 31 days. Verify each recirculation pump discharge valve cycles through one complete cycle of full travel or is de-energized in the closed position.

Verify automatic transfer of the power supply from the normal source to the alternate source for each LPCI subsystem inboard injection valve and each recirculation pump discharge valve. -------------------

NOTE --------------------

For the core spray pumps, SR 3.5.1.7 may be met using equivalent values for flow rate and test pressure determined using pump curves. Verify the following ECCS pumps develop the specified flow rate against a system head corresponding to the specified reactor pressure.

SYSTEM HEAD NO. CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF Core Spray 3,125 gpm 1 105 psig LPCI 8,600 gpm 1 20 psig 3.5-5 ECCS-Operati ng 3. 5 .1 FREQUENCY In accordance with the lnservice Testing Program. _ __, 0Ree eaeA ,} startup prior -to e><ceeding 23% RTP In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. (continued)

Amendment No. 293 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.1.5 SR 3.5.1.6 SR 3.5.1.7 PBAPS UN IT 3 SURVEILLANCE to be perfo-r-me&-:i f perforf11*-E}

within the previous 31 days. Verify each recirculation pump discharge valve cycles through one complete cycle of full travel or is de-energized in the closed position.

Verify automatic transfer of the power supply from the normal source to the alternate source for each LPCI subsystem inboard injection valve and each recirculation pump discharge valve. -------------------

NOTE --------------------

For the core spray pumps, SR 3.5.1.7 may be met using equivalent values for flow rate and test pressure determined using pump curves. Verify the following ECCS pumps develop the specified flow rate against a system head corresponding to the specified reactor pressure.

SYSTEM HEAD NO. CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF Core Spray 3,125 gpm 1 105 psig LPCI 8,600 gpm 1 20 psig 3.5-5 ECCS-Operating 3.5.l FREQUENCY In accordance with the lnservice Testing Program. J Once each startup prior to exceeding 23% RTP In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. (continued)

Amendment No. 296 ATTACHMENT 3 Markup of Technical Specifications Bases Pages Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Docket Nos. 50-277 and 50-278 License Amendment Request to Revise SR 3.5.1.5 Unit 2 TSB Pages B 3.5-12 Unit 3 TSB Pages B 3.5-12 BASES SURVEILLANCE REQUIREMENTS (continued)

The Frequency of this SR is in accordance with the lnservice Testing Program. PBAPS UN IT 2 SR 3.5.1.5 ECCS-Operating B 3.5.1 Cycling the recirculation pump discharge valves through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will close when required.

Upon initiation of an automatic LPCI subsystem injection signal, these valves are required to be closed to ensure full LPCI subsystem flow injection in the reactor via the recirculation jet pumps. De-energizing the valve in the closed position will also ensure the proper flow path for the LPCI subsystem.

Acceptable methods of de-energizing the valve include de-energizing breaker control power, racking out the breaker or removing the breaker. The specified Frequency is once during reactor startup before THERMAL POWER is> 23% RTP. However, this SR is modified by a Note that states the Surveillance is only required to be performed if the last performance was more than 31 days ago. Verification during reactor startup prior to reaching > 23% RTP is an exception to the normal +nservice Testing Program generic valve cycling Frequency, but is considered acceptable due to the demonstrated feliability of these valves. If the valve is inoperable and in the open position, the associated LPCI subsystem must be declared inoperable.

SR 3.5.1.6 Verification of the automatic transfer between the normal and the alternate power source (4 kV emergency bus) for each LPCI subsystem inboard injection valve and each recirculation pump discharge valve demonstrates that AC electrical power will be available to operate these valves following loss of power to one of the 4 kV emergency buses. The ability to provide power to the inboard injection valve and the recirculation pump discharge valve from either 4 kV emergency bus associated with the LPCI subsystem ensures that the single failure of an DG will not result in the continued B 3.5-12 Revision No. 114 BASES SURVEILLANCE REQUIREMENTS (continued)

The Frequency of this SR is in accordance with the lnservice Testing Program. PBAPS UN IT 3 SR 3.5.1.5 ECCS-Operating B 3.5.l Cycling the recirculation pump discharge valves through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will close when required.

Upon initiation of an automatic LPCI subsystem injection signal, these valves are required to be closed to ensure full LPCI subsystem flow injection in the reactor via the recirculation jet pumps. De-energizing the valve in the closed position will also ensure the proper flow path for the LPCI subsystem.

Acceptable methods of de-energizing the valve include de-energizing breaker control power, racking out the breaker or removing the breaker. -ttTe---5-pecified Frequency is once during reactor startup before THERMAL POWER is> 23% RTP. However, this SR is modified by a Note that states the Surveillance is only required to be performed if the last performance was more than 31 days ago. Verification during reactor startup prior to reaching>

23% RTP is an exception to the normal Inservice Testing Program generic valve cycling Frequency, but is considered acceptable due to the demonstrated reliability of these valves. If the valve is inoperable and in the open position, the associated LPCI subsystem must be declared inoperable.

SR 3.5.1.6 Verification of the automatic transfer between the normal and the alternate power source (4 kV emergency bus) for each LPCI subsystem inboard injection valve and each recirculation pump discharge valve demonstrates that AC electrical power will be available to operate these valves following loss of power to one of the 4 kV emergency buses. The ability to provide power to the inboard injection valve and the recirculation pump discharge valve from either 4 kV emergency bus associated with the LPCI subsystem ensures that the single failure of an DG will not result in the continued B 3.5-12 Revision No. 119