ML13109A463

Issuance of Amendments Revise Technical Specifications to Add Residual Heat Removal System Drywell Spray Function Requirements (TAC Nos. ME9445 and ME9446)

ML13109A463
Person / Time
Site:	Peach Bottom
Issue date:	06/18/2013
From:	Richard Ennis Plant Licensing Branch 1
To:	Pacilio M J Exelon Nuclear
Ennis R B
References
TAC ME9445, TAC ME9446
Download: ML13109A463 (26)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 18, 2013 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3-ISSUANCE OF AMENDMENTS RE: REVISE TECHNICAL SPECIFICATIONS TO ADD RESIDUAL HEAT REMOVAL SYSTEM DRYWELL SPRAY FUNCTION REQUIREMENTS (TAC NOS. ME9445 AND ME9446)

Dear Mr. Pacilio:

The Commission has issued the enclosed Amendment Nos. 288 and 291 to Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. These amendments consist of changes to the Technical Specifications (TSs) and Facility Operating Licenses in response to your application dated August 29, 2012, as supplemented by letters dated January 31, 2013, and April 26, 2013. The amendments add TS requirements for the Residual Heat Removal Drywell Spray function.

A copy of the safety evaluation is also enclosed.

Notice of Issuance will be included in the Commission's Biweekly Federal Register Notice. Docket Nos. 50-277 and 50-278

Enclosures:

1. Amendment No. 288 to Renewed DPR-44 2. Amendment No. 291 to Renewed DPR-56 3 Safety Evaluation cc w/encls: Distribution via Listserv Sincerely, Richard B. Ennis, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nucle.ar Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001

• , .. . .: '.-EXELON GENERATION COMPANY, LLC PSEG NUCLEAR LLC DOCKET NO. 50-277 PEACH BOTTOM ATOMIC POWER STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 288 Renewed License No. DPR-44 1.

• The Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Exelon Generation Company, LLC (Exelon Generation Company), and PSEG Nuclear LLC (the licensees), dated August 29, 2012, as supplemented by letters dated January 31, 2013, and April 26, 2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate iri conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied. 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Renewed Facility Operating No. DPR-44 is hereby amended to read as follows: (2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 288, are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

Attachment:

Changes to the Technical Specificatiorc:

.. and Facility Operating License

• Date of Issuance:

Jo.rre 18, 2013 FOR THE NUCLEAR REGULATORY COMMISSION Veronica M.

Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation ATTACHMENT TO LICENSE AMENDMENT NO. 288 RENEWED FACILITY OPERATING LICENSE NO. DPR-44 DOCKET NO. 50-277 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change. Remove 3 Insert 3 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Remove ii Insert ii 3.6-30a 3.6-30b Page 3 (5) Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not to separate, ;such byproduct and special nuclear material as may. be produced by, operation of the facility, and such Class B and Class C low-level waste as may be produced by the operation of Limerick Generating Station, Units 1 and 2. C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54. of Part 50, and Section 70.32 of Part 70; all applicable of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below: (1) Maximum Power Level Exelon Generation Company is authorized to operate the Peach Bottom Atomic Power Station, Unit 2, at steady state reactor core power levels not in excess of 3514 megawatts thermal. (2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 288, are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications.

(3) Physical Protection Exelon Generation Company shall fully implement and maintain in effect all provisions of the physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54{p).

The combined set of plans 1 , submitted by letter dated May 17, 2006, is entitled: "Peach Bottom Atomic Power Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security ::Program, Revision 3." The set contains Safeguards Information protected under 10 CFR 73.21. Exelon Generation Company shall fully i'mplement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The Exelon Generation Company CSP was approved by License Amendment No. 283. (4) Fire Protection The Exelon Generation Company shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report fo'r the facility, and as approved in the NRC Safety Evaluation (SER) dated May 23, 1979, and Supplements dated August 14, September 15, October 10 and November 24, 1980, and in the NRC SERs dated September 16, 1993, and August 24, 1994, subject to the following provision:

1 The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan. Renewed License No. DPR-44 Revised by letter dated October 28, 2004 Revised by letter dated May 29, 2007 Amendment No. 288 TABLE OF CONTENTS (continued) 3.4 3. 4.1 3.4.2 3.4.3 3.4.4 3.4.5 3.4.6 3.4.7 3.4.8 3.4.9 3. 4. 10 3.5 3. 5. 1 3.5.2 3.5.3 3.6 3. 6. 1 . 1 3.6.1 .2 3.6.1 .3 3.6.1 .4 3.6.1 .5 3.6.1 .6 3.6.2.1 3.6.2.2 3.6.2.3 3.6.2.4 3.6.2.5 3.6.3.1 3.6.3.2 3. 6. 4.1 3.6.4.2 3.6.4.3 3.7 3.7. 1 3.7.2 3.7.3 3.7.4 3.7.5 PBAPS UNIT 2 REACTOR COOLANT SYSTEM ( RCS) ............................. 3 . 4-1 Recirculation Loops Operating

........................

3.4-1 Jet Pumps ............................................

3. 4-6 Safety Relief Valves (SRVs) and Safety Valves (SVs) .. 3.4-8 RCS Operational LEAKAGE .. ; ............................

3.4-10 RCS Leakage Detection Instrumentation

................

3.4-12 RCS Specific Activity ................................

3.4-14 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown ...............................

3. 4-16 Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown ..............................

3.4-19 RCS Pressure and Temperature (PIT) Limits ............

3.4-21 Reactor Steam Dome Pressure ..........................

3.4-28 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM ..........................

3.5-1 ECCS-Operating

.......................................

3.5-1 ECCS-Shutdown

........................................

3.5-8 RCIC System ..........................................

3. 5-12 CONTAINMENT SYSTEMS ......................................

3.6-1 Primary Containment

..................................

3.6-1 Primary Containment Air Lock .........................

3.6-3 Primary Containment Isolation Valves (PCIVs} .........

3.6-8 Drywell Air Temperature

..............................

3.6-17 Reactor Building-to-Suppression Chamber Vacuum Breakers ..........................................

3.6-18 Suppression Chamber-to-Drywell Vacuum Breakers ....... 3.6-21 Suppression Pool Average Temperature

.................

3.6-23 Suppression Pool Water Level ..........................

3.6-26 Residual Heat Removal (RHR) Suppression Pool Cooling ...........................................

3.6-27 Residual Heat Removal (RHR) Suppression Pool Spray ... 3.6-29 Residual Heat Removal (RHR) Drywell Spray ............

3.6-30a Deleted ..............................................

3.6-31 Primary Containment Oxygen Concentration

.............

3.6-33 Secondary Containment

................................

3.6-34 Secondary Containment Isolation Valves (SCIVs} ....... 3 .. 6-36. Standby Gas Treatment (SGT) System ...................

3.6-40 PLANT SYSTEMS ............................................

3. 7-1 High Pressure Service Water (HPSW) System ............

3.7-1 Emergency Service Water (ESW) System and Normal Heat Sink ........................................

3. 7-3 Emergency Heat Sink ..................................

3. 7-5 Main Control Room Emergency Ventilation (MCREV) System ............................................

3. 7-7 Main Condenser Offgas ................................

3. 7-10 (continued) i i Amendment No. 288

3.6 CONTAINMENT

SYSTEMS 3.6.2.5 Residual Heat Removal (RHR) Drywell Spray RHR Drywell Spray 3.6.2.5 LCO *3 . 6 . 2 . 5 Two RHR drywell spray subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR d rywe 11 spray A. 1 Restore RHR drywell 7 days subsystem inoperable.

spray subsystem to OPERABLE status. B. Two RHR drywell spray B .1 Restore one RHR 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> subsystems inoperable.

drywell spray subsystem to OPERABLE status. C. Required Action and c .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 not met. AND C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> PBAPS UNIT 2 3.6-30a Amendment No. 288 SURVEILLANCE REQUIREMENTS SR 3.6.2.5.1 SR 3.6.2.5.2 PBAPS UNIT 2 SURVEILLANCE Verify each RHR drywall spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.

Verify each drywall spray nozzle is unobstructed.

3.6-30b RHR Drywall Spray 3.6.2.5 FREQUENCY In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. Amendment No. 288 UNITED STATES NUCLEAR REGULATORY COMMISSION

• WASHING:rON, D.C.

EXELON GENERATION COMPANY, LLC PSEG NUCLEAR LLC DOCKET NO. 50-278 PEACH BOTTOM ATOMIC POWER STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 291 Renewed License No. DPR-56 1. The Nuclear Regulatory Commission (the Commission) has found that: A The application for amendment by Exelon Generation Company, LLC (Exelon Generation Company), and PSEG Nuclear LLC (the licensees), dated August 29, 2012, as supplemented by letters dated January 31, 2013, and April 26, 2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied. 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license. amendment, and paragraph 2.C(2) of Renewed Facility Operating License No. DPR-56 is hereby amended to read as follows: (2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 291, are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

Attachment:

Changes to the Technical Specifications and Facility Operating License Date *of Issuance:

June 18, , 2013 FOR THE NUCLEAR REGULATORY COMMISSION Veronica M. Rodriguez, Acti Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation ATTACHMENT TO LICENSE AMENDMENT NO. 291 RENEWED FACILITY OPERATING LICENSE NO. DPR-56 DOCKET NO. 50-278 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change. Remove 3 Insert 3 Replace the following pages of the A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Remove ii Insert ii 3.6-30a 3.6-30b (5) Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not to separate,, such byproduct and special nuclear material as may be produced by operation of the facility, and such Class B and Class C low-level radioactive waste as may be produced by the operation of Limerick Generating Station, U_nits 1 and 2. C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1: Part 20, Section 30.34 of Part 30, Section 40.41 of Part40, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below: (1) Maximum Power Level Exelon Generation Company is authorized to operate the Peach Bottom *Atomic Power Station, Unit No. 3, at steady state reactor core power levels not in excess of 3514 megawatts thermal. (2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 291, are hereby incorporated in the license. Exelon Generation Compalily shall operate the facility in accordance with the Technical Specifications.

1 (3) Physical Protection Exelon Generation Company shall fully implement and maintain in effect all provisions of the Commission-approv,ed physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The combined set of plans 2 , submitted by letter dated May 17, 2006, is entitled: "Peach Bottom Atomic Power Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, Revision 3." The set contains Safeguards Information protected under 10 CFR 73.21. Exelon Generation Company shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The Exelon Generation Company CSP was approved by License Amendment No. 283. 1 Licensed power level was revised by Amendment No. 250, dated November 22, 2002, and will be implemented following the 14 1 h refueling outage currently scheduled for Fall 2003. 2 The training and Qualification Plan and Safeguards Contingency Plan and Appendices

-to the Security Plan. Page 3 Renewed No. bPR-56 Revised by letter dated October 28, 2004 Revised by letter dated November 5, 2004 Revised by letter dated May 29, 2007 Amendment No. 291 TABLE OF CONTENTS (continued) 3.4 3. 4.1 3.4.2 '3.4. 3 3.4.4 3.4.5 3.4.6 3.4.7 3.4.8 3.4.9 3. 4. 10 3.5 3.5:1 3.5.2 3.5.3 3.6 3' 6' 1 . 1 3.6.1 .2 3.6.1 .3 3.6.1 .4 3.6.1 .5 3.6.1 .6 3.6.2.1 3.6.2.2 3.6.2.3 3.6.2.4 3.6.2.5 3.6.3.1 3.6.3.2 3. 6. 4.1 3.6.4.2 3.6.4.3 3.7 3. 7.1 3.7.2 3.7.3 3.7.4 3.7.5 PBAPS UNIT 3 REACTOR COOLANT SYSTEM (RCS) .............................

3.4-1 Recirculation Loops Operating

........................

3.4-1 Jet Pumps ............................................

3.4-6 Safety Relief Valves (SRVs) and Safety Valves (SVs) .. 3.4-8 RCS Operational LEAKAGE ..............................

3.4-10 RCS Leakage Detection Instrumentation

................

3. 4-12 RCS Specific Activity ................................

3.4-14 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown ...............................

3. 4-16 Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown ..............................

3.4-19 RCS Pressure and Temperature (P/T) Limits ............

3.4-21 Reactor Steam Dome Pressure ..........................

3.4-28 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING ( RCIC) SYSTEM ..........................

3. 5-1 ECCS-Operating

.......................................

3.5-1 ECCS-Shutdown

........................................

3.5-8 RCIC System ..........................................

3. 5-12 CONTAINMENT SYSTEMS ................................ : ..... 3.6-1 Primary Containment

..................................

3.6-1 Primary Containment Air Lock ..........................

3.6-3 Primary Containment Isolation Valves (PCIVs) .........

3.6-8 Drywell Air Temperature

..............................

3.6-17 Reactor Building-to-Suppression Chamber Vacuum Breakers ..........................

• ................

3. 6-18 Suppression Chamber-to-Drywell Vacuum Breakers ....... 3.6-21 Suppression Pool Average Temperature

.................

3.6-23 Suppression Pool Water Level .........................

3.6-26 Residual Heat Removal (RHR) Suppression Pool Cooling .................................

• ..........

3. 6-27 Residual Heat Removal (RHR) Suppression Pool Spray ... 3.6-29 Residual Heat Removal (RHR) Drywell Spray ............

3.6-30a D.eleted ...... ; ........................................

3.6-31 Primary Containment Oxygen Concentration

.............

3.6-33 Secondary Containment

................................

3.6-34 Containment Isolation Valves (SCIVs) ....... 3.6-36 Standby Gas Treatment (SGT) System ...................

3.6-40 PLANT SYSTEMS ............................................

3. 7-1 High Pressure Service Water ( HPSW) System ............

3. 7-1 Emergency Service Water (ESW) System and Normal Heat Sink ........................................

3.7-3 Emergency Heat Sink ..................................

3.7-5 Main Control Room Emergency Ventilation (MCREV) System ............................................

3. 7-7 Main Condenser Offgas ................................

3.7-10 (continued) i i Amendment No. 291

3.6 CONTAINMENT

SYSTEMS 3.6.2.5 Residual Heat Removal (RHR) Drywell Spray RHR Drywell Spray 3.6.2.5 LCO 3.6.2.5 Two RHR drywell spray subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR drywell spray A.1 Restore RHR drywell 7 days subsystem inoperable.

spray subsystem to OPERABLE status. B. Two RHR drywell spray B .1 Restore one RHR 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> subsystems inoperable.

drywell spray subsystem to OPERABLE status. C. Required Action and c. 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 not met. AND C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> PBAPS UNIT 3 3.6-30a Amendment No. 291 SURVEILLANCE REQUIREMENTS SR 3 . 6 . 2 . 5 . 1 SR 3.6.2.5.2 SURVEILLANCE Verify each RHR drywall spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.

Verify each drywell spray nozzle is unobstructed.

RHR Drywell Spray 3.6.2.5 FREQUENCY In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program. PBAPS UNIT 3 3.6-30b Amendment No. 291 UNITED. STATES NUCLEAR REGULATORY COMMISSION D.C.

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 288 AND 291 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-44 AND DPR-56 EXELON GENERATION COMPANY, LLC PSEG NUCLEAR LLC PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278

1.0 INTRODUCTION

By application dated August 29, 201-2, as supplemented by letters dated January 31, 2013, and April 26, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML 12243A497, ML 130320657, and ML 13119A101, respectively), Exelon Generation Company, LLC (Exelon; the licensee), requested changes to the Technical Specifications (TSs) and Facility Operating Licenses for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The proposed amendment would add TS requirements for the:Residual Heat Removal (RHR) Drywell Spray function.

This function had previously resided in the TSs for PBAPS, Units 2 and 3, but was relocated to a licensee-controlled document, the Technical Requirements Manual (TRM), as part of the conversion to the improved TSs on August 30, 1995. Based on the requirements in Section. 50.36 of Title 10 of the Code of Federal Regulations (1 0 CFR), the licensee has determined that the RHR Drywell Spray function needs to be re-established in the PBAPS, Units 2 and 3, TSs. The supplements dated January 31, 2013, and April 26, 2013, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the Nuclear Regulatory Commission (NRC or the Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on October 30, 2012 (77 FR 65723). Enclosure

2.0 REGULATORY EVALUATION

2.1 Regulatory

Requirements and Guidance In 10 CFR 50.36, the NRC established its regulatory requirements related to the content of TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories:

(1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls.

The regulation does not specify the particular requirements to be included in a plant's TSs. As discussed in 10 CFR 50.36(c)(2}, LCOs are the lowest functional capability or performance level of equipment required for safe operation of the facility.

When LCOs are not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the LCO can be met. As discussed in 10 CFR 50.36(c)(3}, SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. On July 22, 1993 (58 FR 39132}, the Commission published a "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (Final Policy Statement}, which discussed the criteria to determine the items that are required to be included iri the TSs as LCOs. The criteria were subsequently incorporated into the regulations by an amendment to 10 CFR 50.36 (60 FR 36953). Specifically, 10 CFR 50.36(c)(2)(ii) requires that a TS LCO be established for each item meeting one or more of the following criteria:

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2: A process variable; design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Criterion 3: A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Criterion 4: A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. As discussed in the Federal Register notice for the final rule dated July 19, 1995 (60 FR 36955): LCOs that do not meet any of the criteria, and their associated actions and surveillance requirements, may be proposed for relocation from the technical specifications to licensee-controlled documents, such as the FSAR [Final Safety Analysis Report]. The criteria may be applied to either standard or custom technical specifications.*

In general, there are two classes of changes to TSs: (1) changes needed to reflect contents of the design basis (TSs are derived from the design basis); and (2) voluntary changes to take advantage of the evolution in policy and guidance as to the required content and preferred format of TSs. The pr_oposed amendment deals with the first class of change, namely, a change that is necessary to reflect the contents of the design basis.

• In determining the acceptability ofthe proposed amendment, the NRC staff used plant-specific licensing basis information as well as the accumulation of generically-approved guidance in the improved Standard Technical Specifications (STS), specifically, NUREG-1433, "Standard Technical Specifications, Revision 4, General Electric BWR/4 Plants," April 2012. 2.2 Equipment Description As discussed in Section 5.0 of the PBAPS Updated Final Safety Analysis Report, the PBAPS primary containment is a Mark I design consisting of: (1) a drywell, which is a steel pressure vessel (in the shape of an inverted light bulb) that encloses the reactor vessel; (?) a suppression chamber (also called the wetwell or suppression pool), which is a . steel pressure vessel that is partially filled with a large volume of water and is located below and encircling the drywell; and (3) a vent system connecting the drywell atmosphere to the suppression pool. As discussed in Attachment 3 to the licensee's application dated August 29, 2012, drywell spray is a mode of the RHR system which may be initiated under post-accident conditions to reduce the temperature and pressure of the primary containment atmosphere.

The RHR system has two loops with each loop consisting oftwo motor-driven pumps, two heat exchangers, and associated piping and valves. There are two RHR drywell spray subsystems per RHR loop. The four RHR drywell spray subsystems are manually initiated and independently controlled.

The RHR drywell spray subsystems perform the drywell spray function by circulating water from the suppression pool through the RHR heat exchangers and discharging the cooled suppression pool water into the drywell air space through the drywell spray sparger and spray nozzles. 3.0 TECHNICAL EVALUATION

3.1 Background

The licensee provided the following background information concerning the proposed amendment in Section 3.0 of Attachment 1 to its application dated August 29, 2012: Currently, the guidance and requirements related to the RHR Drywell Spray function are maintained in the TRM. There are no existing TS requirements associated with the RHR Drywell Spray function.

PBAPS, Unit 2 and 3, converted to Improved Technical Specifications (ITS) as documented in NRC Safety Evaluation Report (SER) supporting the issuance of License Amendments 210 and 214, dated August 30, 1995. As part of the conversion to ITS, the RHR Drywell Spray requirements were removed from TS based on the following justification. "The drywe/1 spray is not credited in any DBA [Design Basis Accident] (i.e., it is not needed to function to mitigate the consequence of any design basis accidents) and it is a secondary action in emergency procedures.

Therefore, drywe/1 spray is not risk significant and can be relocated outside of the Technical Specifications.

This change is consistent with NUREG-1433." At that time, it was determined

[by the licensee]

that the requirements for the RHR Drywell Spray function did not satisfy the NRC's TS Policy Statement

[i.e., Final Policy Statement]

screening criteria for remaining in the TS and were relocated to the TRM, which is controlled in accordance with 1 0 CFR 50. 59. The NRC approved the changes in support of the ITS conversion in a letter dated August 30, 1995, which issued Amendment Nos. 210 and 214 for PBAPS, Units 2 and 3, respectively.

The approved amendments (i.e., Nos. 210 and 214) replaced the custom TS and associated Bases with ITS, which was based on the NRC-approved guidance and criteria specified in NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4," dated September 1992. At the time of the ITS conversion, it had not been recognized that a Small Steam Line Break (SSLB) accident may result in higher peak drywell temperatures than that produced by Design Basis Accident (DBA) Loss of Coolant Accident (LOCA) (i.e., Recirculation Suction Line Break (RSLB)). Subsequently, however, an analysis performed in response to General Electric (GE) Service Information Letter (SIL) 636 concluded that an SSLB will result in higher containment temperatures than that of DBA LOCA. Based on, this determination, the earlier justification that .. drywe/1 spray is not credited in any DBA (i.e., it is not needed to function to mitigate the consequence of any design basis accidents)

... ", is not correct. Although evaluated as not being required to mitigate a DBA, RHR Drywell Sprays are the primary success path for mitigating the effects of a SSLB in the drywell. The licensee stated that "since it has been more recently determined that RHR Drywell Spray is needed to mitigate the impact of a SSLB, the requirements of 10 CFR 50.36, Criterion 3, applies." Accordingly, the licensee requested that the requirements for the RHR Drywell Spray function be re-established in the PBAPS, Units 2 and 3, TS. The licensee stated that, during the interim period until the proposed TS change can be reviewed and approved, PBAPS is taking action to operate as if the TS requirements were in effect. 3.2 Licensee's Proposed TS Changes As discussed in Section 2.0 of Attachment 1 to the licensee's application dated August 29, 2012, the requirements for the RHR Drywell Spray function currently reside in PBAPS TRM Section 3.12, which establishes specific guidance and criteria related to the applicability, operation, and testing for the RHR Drywell Spray function.

The licensee is proposing to re-establish the RHR Drywell Spray function requirements in new TS 3.6.2.5, "Residual Heat Removal (RHR) Drywell Spray." Applicable criteria from TRM Section 3.12 will be relocated to TS 3.6.2.5, along with incorporating other information needed to establish the LCO and SRs. The licensee stated that the TRM requirements for the RHR Drywell Spray function will be eliminated once the TS requirements are established.

The LCO forTS 3.6.2.5 would require two RHR drywell spray subsystems to be operable in Modes 1, 2, and 3. The LCO Actions would be as shown in the following table: CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR drywell spray A.1 Restore RHR drywell spray 7 days subsystem inoperable.

subsystem to OPERABLE status. B. Two RHR drywell spray B.1 Restore one RHR drywell 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> subsystems inoperable.

spray subsystem to OPERABLE status. C. Required Action and C.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 not met. AND C.2 Be In MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> The SRs forTS 3.6.2.5 would be as shown in the following table: SURVEILLANCE FREQUENCY SR 3.6.2.5.1 Verify each RHR drywell spray subsystem In accorqance with the manual, power operated, and automatic Surveillance Frequency valve in the flow path that is not locked, Control Program. sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.

SR 3.6.2.5.2 Verify each drywell spray nozzle is In accordance with the unobstructed.

Surveillance Frequency Control Program. The licensee's application dated August 29, 2012, stated that the proposed LCO completion times were established based on the previous requirements that existed in the PBAPS TS prior to converting to ITS in August 1995, as well as the existing LCO 3.6.2.4 regarding the RHR Suppression Pool Spray function.

The licensee's application also stated that the surveillance frequencies would be established in accordance with criteria and guidance in the PBAPS Surveillance Frequency Control Program, as required by TS Section 5.5.14. The proposed amendment would also revise the TS Index to add TS 3.6.2.5. Attachment 3 to the licensee's application dated August 29, 2012, provided revised TS Bases pages to be implemented with the associated TS changes. These pages were provided for information only and would be revised by the licensee in accordance with theTS Bases Control Program. 3.3 NRC Staff Evaluation 3.3.1 SSLB Accident Analysis As discussed above in safety evaluation (SE) Section 3.1, at the time of the ITS conversion, the licensee had not recognized that an SSLB accident may result in higher peak drywell temperatures than that produced by a DBA-LOCA.

Subsequently, an analysis performed in response to GE SIL 636 concluded that an SSLB will result in higher temperatures than that of DBA-lOCA.

As a result of the* analysis,.

the licensee determined that, since the RHR Drywell Spray is needed to mitigate the impact of an SSLB, an LCO was required consistent with the requirements in Criterion 3 of 10 CFR 50.36(c)(2)(ii).

In a request for additional information (RAI) dated December 4, 2012 (ADAMS Accession No. ML 12340A386), the NRC staff requested the licensee to provide the report that documents the detailed results of the GE analysis and the date the analysis was performed in response to GE SIL 636. The staff's RAI also requested that the licensee describe the timeline related to when the licensee determined that the RHR Drywell Spray was required to mitigate the impact of an SSLB. The RAI further stated that: If the licensee's determination was not made soon after the results of the GE analysis was available to the licensee, then explain why the licensee's decision to make the proposed change to revise the TSs to include new TS Section 3.6.2.5 (along with a supporting Bases section) was not made at an earlier date. The licensee provided its response to the RAI in the supplement dated January 31, 2013. The licensee stated that, in 2001, GE issued SIL 636 to inform utilities with GE boiling-water reactors of a change in the GE method for calculating the decay heat values using the ANS 5.1-1979 standard.

In March 2003, GE issued Revision 0 of GE-NE-0000-0011-4483, "Project Task 'Report-Peach Bottom Atomic Power Station Units 2 and 3 SIL 636 Evaluation," documenting the results of an assessment for PBAPS, Units 2 and 3, relative to the design and licensing analyses potentially impacted by the revised decay heat calculation method described in SIL 636. Since PBAPS did not have an SSLB analysis, GE was requested to include an SSLB analysis in the SIL 636 evaluation.

The GE report included the information relative to the SSLB analysis that was performed.

The licensee provided pertinent information from the GE report, related to the SSLB analysis, in the supplement dated January 31, 2013. The GE report concludes that an SSLB will result in more severe containment temperatures than the previously considered DBA-LOCA.

Specifically, on page 2 of Attachment 1 to the supplement dated January 31, 2013, the licensee provided the following table summarizing the expected peak drywell temperatures during the analyzed DBA-LOCA and SSLB accident conditions for PBAPS. Accident Condition Temperature DBA-LOCA Peak Drywell Temperature 307 OF (no credit for Drywell sprays) SSLB Peak Drywell Temperature 337.9 OF (credit for Drywell sprays) Maximum Drywell Temperature Limit 340 °F As shown above, the expected peak drywell temperature calculated for the SSLB accident with credit for drywell sprays is higher than that of the DBA-LOCA.

As discussed on page 5 of Attachment 1 to the application dated August 29, 2012, the licensee provided the following summary of the SSLB analysis contained in the GE report: The steam line breaks are the most limiting events for drywe/1 temperature response, since steam has higher energy content than liquid. These analyses, with primary focus on the drywe./1 temperature response, took credit for containment sprays and structural heat sinks in the drywe/1 and the wetwe/1 airspace.

As discussed above in SE Section 2.1, Criterion 3 of 10 CFR 50.36(c)(2)(ii) requires that a TS LCO be established for a "structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier." Since the peak drywell temperatures are higher for an SSLB than the DBA-LOCA, and the,RHR Drywell Spray function must be credited in the design basis to limit peak drywell temperature following an SSLB inside the drywell, the NRC staff agrees with the licensee's determination that an LCO for the RHR Drywell Spray function is required per the requirements in Criterion 3 of 10 CFR 50.36(c)(2)(ii).

In its response to the staff's RAI, the licensee described the timeline as to when the licensee determined that the RHR Drywell Spray function is needed to mitigate the impact of an SSLB, and explained why the licensee's decision to make the proposed change to revise the TSs to include newTS Section 3.6.2.5 was not made at an earlier date. The licensee stated in Attachment 1 to the supplement dated January 31, 2013, that: The vendor analysis was performed in 2003 and assumed the use of Drywell Spray to mitigate the Small Steam Line Break (SSLB) design event. At that time, Drywell Spray was controlled in the PBAPS, Units 2 and 3, Technical Requirements Manuals (TRMs), which are documents that are similar to the PBAPS TSs. The TRM document generally contains similar limiting conditions and compensatory measures as does the TS and therefore, the impact of Drywell Spray being contained in the TRM instead of the TS was not significant.

The PBAPS staff recognized on June 5,. 2012, that the Drywell Spray function should be transferred from the TRMs to the TSs. Once recognized, the issue was promptly entered into the Corrective Action Program (CAP) (reference Issue Report 1375137) for resolution and is available for review by the site NRC Resident Inspectors.

The causes of the delay in recognizing the need to transfer the Drywell Spray from the TRMs to the TSs were due to inadequate identification of document impacts of the vendor analysis and a non-conservative decision to not include Drywell Spray in the TSs when performing the conversion to Improved Technical Specifications (ITS) in the 1990s. Based on the information provided by the licensee, the application for a license amendment was submitted less than 3 months after the licensee recognized that the RHR Drywell Spray function needed .to be added to the TSs. 3.3.2 Evaluation of Proposed TS Changes As discussed above in SE Section 3.3.1, the RHR Drywell Spray function meets Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Therefore, the PBAPS TSs must contain an LCO for this function.

Furthermore, consistent with the requirements in 10 CFR 50.36(c)(3), the PBAPS TSs must contain SRs to provide the necessary requirements to assure that the LCO will be met. As discussed in 10 CFR 50.36(c)(2), LCOs are the lowest functional capability or performance level of equipment required for safe operation of the facility.

When LCOs are not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the LCO can be met. As discussed in 10 CFR 50.36(c)(3), SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. The NRC staff evaluated the proposed LCO, including its Applicability and Actions with respect to the requirements in 10 CFR 50.36(c)(2).

The staff also reviewed the proposed SRs with respect to the requirements in 10 CFR 50.36(c)(3).

As part of this evaluation, the staff reviewed the proposed TS Bases forTS 3.6.2.5, as well as existing PBAPS TS 3.6.2.4 for the RHR Suppression Pool Spray function.

The staff also used NUREG-1433 as guidance.

As discussed in the proposed TS Bases, one RHR drywell spray subsystem is credited in the design-basis analyses to mitigate the rise in drywell temperature and pressure caused by a steam line break inside the drywell, and to maintain the primary containment peak temperature and pressure below design limits. As discussed in SE Section 2.2, the RHR system has two loops with two RHR drywell spray subsystems per RHR loop. The NRC staff finds that the LCO requirement to have two RHR drywell spray subsystems operable provides reasonable assurance that at least one subsystem will be available while assuming the worst case active single failure. The proposed TS Bases state that in Modes 1, 2, 3, a steam line break in the drywell could cause a rise in primary containment temperature and pressure.

The Bases further state that, in Modes 4 and 5, the probability and consequences of steam line breaks are reduced, due to the pressure and temperature limitations in these Modes. The NRC staff finds that maintaining the RHR drywell spray function operable in Modes 1, 2, 3 is consistent with the plant conditions when the system is needed to mitigate the effects of a steam line break. The LCO Actions require that, with one RHR dryweil spray system inoperable, the subsystem must be restored to operable status within 7 days. The LCO Actions also require that with two RHR drywell spray systems inoperable, one subsystem must be restored within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. With either of the Required Actions not met, the plant must be .in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The NRC staff finds that the Actions including the associated Completion Times provide reasonable remedial actions until the LCO can be met. Proposed SR 3.6.2.4.1 requires verification that each RHR drywell spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be alig*ned to the correct position.

Proposed SR 3.6.2.4.2 requires verification that the spray nozzles are not obstructed.

Both SRs would be performed on a frequency controlled by the Surveillance Frequency Control Program, which is described in TS 5.5.14. The NRC staff finds that the proposed SRs provide reasonable assurance that the proper flow path will exist for system operation when required.

The RHR Drywell Spray function performs a similar function and contains similar operational considerations as the RHR Suppression Pool Spray function.

The NRC staff reviewed the format and content of existing PBAPS TS 3.6.2.4 for the RHR Suppression Pool Spray function, as well as STS 3.6.2.4 in NUREG-1433 for the RHR Suppression Pool Spray function.

The NRC staff finds that proposed TS 3.6.2.5 for the RHR Drywell Spray function closely follows PBAPS TS 3.6.2.4 and STS 3.6.2.4 in format and content. Based on the above considerations, the NRC staff concludes that proposed TS 3.6.2.5 is consistent with the requirements in 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3).

3.3.3 Technical

Evaluation Conclusion Based on the evaluation in SE Sections 3.3.1 and 3.3.2, the NRC staff concludes that the proposed amendment is acceptable.

4.0 STATE CONSULTATION

lh accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments.

The State official had no comments.

5.0 ENVIRONMENTAL

CONSIDERATION The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change SRs. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (77 FR 65723). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

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

M. Razzaque M. Hamm R. Ennis Date: June 18, 2013 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 June 18, 2013

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3-ISSUANCE OF AMENDMENTS RE: REVISE TECHNICAL SPECIFICATIONS TO ADD RESIDUAL HEAT REMOVAL SYSTEM DRYWELL SPRAY FUNCTION REQUIREMENTS (TAC NOS. ME9445 AND ME9446)

Dear Mr. Pacilio:

The Commission has issued the enclosed Amendment Nos. 288 and 291 to Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. These amendments consist of changes to the Technical Specifications (TSs) and Facility Operating Licenses in response to your application dated August 29, 2012, as supplemented by letters dated January 31, 2013, and April 26, 2013. The amendments add TS requirements for the Residuai*Heat Removal Drywell Spray function.

A copy of the safety evaluation is also enclosed.

Notice of Issuance will be included in the Commission's Biweekly Federal Register Notice. Sincerely, /RAJ Richard B. Ennis, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-277 and

Enclosures:

1. Amendment No. 288 to Renewed DPR-44 2. Amendment No, 291 to Renewed DPR-56 3. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL 1-2 R/F RidsNrrDoriDpr Resource RidsNrrDorllp11-2 Resource RidsNrrPMPeachBottom Resource RidsNrrLAABaxter Resource ADAMS Accession No* ML 13109A463 RidsAcrsAcnw_MaiiCTR Resource RidsRgn1 MaiiCenter Resource GHiii,OIS RidsNrrDssStsb Resource RidsNrrDssSrxb Resource *via email MHamm, STSB MRazzaque, SRXB OFFICE LPL 1-2/PM LPL 1-2/LA* SRXB/BC STSB/BC OGC INLO LPL 1-2/BC(A)

NAME REnnis A Baxter CJackson REIIiott EHouseman VRodriQuez DATE 06/17/13 05/13/13 06/03/13 05/23/13 06/12/13 06/18/13 OFFICIAL RECORD COPY