Text

Supplement to the Request for Amendment to Technical Specification 3.1.7, Standby Liquid Control (SLC) System
	ML102070161
Person / Time
Site:	Peach Bottom
Issue date:	07/23/2010
From:	Cowan P; Exelon Generation Co, Exelon Nuclear
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML102070161 (22)
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10 CFR 50.90 July23, 2010 U.S. 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:

Supplement to the Request for Amendment to Technical Specification 3.1.7, Standby Liquid Control (SLC) System

References:

1)

Letter from P. B. Cowan (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, Request for Amendment to Technical Specification 3.1.7, Standby Liquid Control (SLC) System dated March 24, 2010 2)

Letter from J. D. Hughey (U.S. Nuclear Regulatory Commission) to M. J.

Pacilio (Exelon Generation Company, LLC), Peach Bottom Atomic Power Station, Units 2 And 3: Nonacceptance Of License Amendment Request Related To Extending Completion Time For Technical Specification 3.1.7, Standby Liquid Control System dated July 12, 2010 By letter to the Nuclear Regulatory Commission (NRC) dated March 24, 2010, Exelon Generation Company, LLC, (Exelon) submitted a request to revise the Technical Specifications (TS) for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The proposed change would revise TS Section 3.1.7, Standby Liquid Control (SLC) System, to extend the completion time for Condition C (i.e., two SLC subsystems inoperable for reasons other than Condition A) from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

By letter to Exelon dated July 12, 2010 (reference 2), the NRC provided the results of the NRC staffs acceptance review of this amendment request. The NRC staff concluded that additional information is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendment request in terms of regulatory requirements and the protection of public health and safety and the environment. The NRC staff requested that Exelon supplement the application to address the information requested by July 28, 2010. to this supplemental letter provides the information requested by the NRC.

In addition, Unit 2 TS page 3.1-21 and Unit 3 TS page 3.1-21 have been revised and are being re submitted as Attachment 2. Attachment 3 contains revised Bases pages which also supersede the Bases pages submitted March 24, 2010, with the initial LAR submittal.

Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348 July 23, 2010 wwwexeloncorp.com Exelon.

Nuclear 10 CFR 50.90 U.S. 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:

Supplement to the Request for Amendment to Technical Specification 3.1.7, "Standby Liquid Control (SLC) System"

References:

1)

Letter from P. B. Cowan (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Request for Amendment to Technical Specification 3.1.7, "Standby Liquid Control (SLC) System"" dated March 24, 2010 2)

Letter from J. D. Hughey (U.S. Nuclear Regulatory Commission) to M. J.

Pacilio (Exelon Generation Company, LLC), "Peach Bottom Atomic Power Station, Units 2 And 3: Nonacceptance Of License Amendment Request Related To Extending Completion Time For Technical Specification 3.1.7, Standby Liquid Control System" dated July 12, 2010 By letter to the Nuclear Regulatory Commission (NRC) dated March 24, 2010, Exelon Generation Company, LLC, (Exelon) submitted a request to revise the Technical Specifications (TS) for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The proposed change would revise TS Section 3.1.7, "Standby Liquid Control (SLC) System," to extend the completion time for Condition C (Le., two SLC subsystems inoperable for reasons other than Condition A) from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

By letter to Exelon dated July 12, 2010 (reference 2), the NRC provided the results of the NRC staff's acceptance review of this amendment request. The NRC staff concluded that additional information is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendment request in terms of regulatory requirements and the protection of public health and safety and the environment. The NRC staff requested that Exelon supplement the application to address the information requested by July 28, 2010. to this supplemental letter provides the information requested by the NRC. In addition, Unit 2 TS page 3.1-21 and Unit 3 TS page 3.1-21 have been revised and are being re-submitted as Attachment 2. Attachment 3 contains revised Bases pages which also supersede the Bases pages submitted March 24, 2010, with the initial LAR submittal.

Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348 July 23, 2010 wwwexeloncorp.com Exelon.

Nuclear 10 CFR 50.90 U.S. 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:

Supplement to the Request for Amendment to Technical Specification 3.1.7, "Standby Liquid Control (SLC) System"

References:

1)

Letter from P. B. Cowan (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Request for Amendment to Technical Specification 3.1.7, "Standby Liquid Control (SLC) System"" dated March 24, 2010 2)

Letter from J. D. Hughey (U.S. Nuclear Regulatory Commission) to M. J.

Pacilio (Exelon Generation Company, LLC), "Peach Bottom Atomic Power Station, Units 2 And 3: Nonacceptance Of License Amendment Request Related To Extending Completion Time For Technical Specification 3.1.7, Standby Liquid Control System" dated July 12, 2010 By letter to the Nuclear Regulatory Commission (NRC) dated March 24, 2010, Exelon Generation Company, LLC, (Exelon) submitted a request to revise the Technical Specifications (TS) for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The proposed change would revise TS Section 3.1.7, "Standby Liquid Control (SLC) System," to extend the completion time for Condition C (Le., two SLC subsystems inoperable for reasons other than Condition A) from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

By letter to Exelon dated July 12, 2010 (reference 2), the NRC provided the results of the NRC staff's acceptance review of this amendment request. The NRC staff concluded that additional information is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendment request in terms of regulatory requirements and the protection of public health and safety and the environment. The NRC staff requested that Exelon supplement the application to address the information requested by July 28, 2010. to this supplemental letter provides the information requested by the NRC. In addition, Unit 2 TS page 3.1-21 and Unit 3 TS page 3.1-21 have been revised and are being re-submitted as Attachment 2. Attachment 3 contains revised Bases pages which also supersede the Bases pages submitted March 24, 2010, with the initial LAR submittal.

Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348 July 23, 2010 wwwexeloncorp.com Exelon.

Nuclear 10 CFR 50.90 U.S. 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:

Supplement to the Request for Amendment to Technical Specification 3.1.7, "Standby Liquid Control (SLC) System"

References:

1)

Letter from P. B. Cowan (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Request for Amendment to Technical Specification 3.1.7, "Standby Liquid Control (SLC) System"" dated March 24, 2010 2)

Letter from J. D. Hughey (U.S. Nuclear Regulatory Commission) to M. J.

Pacilio (Exelon Generation Company, LLC), "Peach Bottom Atomic Power Station, Units 2 And 3: Nonacceptance Of License Amendment Request Related To Extending Completion Time For Technical Specification 3.1.7, Standby Liquid Control System" dated July 12, 2010 By letter to the Nuclear Regulatory Commission (NRC) dated March 24, 2010, Exelon Generation Company, LLC, (Exelon) submitted a request to revise the Technical Specifications (TS) for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The proposed change would revise TS Section 3.1.7, "Standby Liquid Control (SLC) System," to extend the completion time for Condition C (Le., two SLC subsystems inoperable for reasons other than Condition A) from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

By letter to Exelon dated July 12, 2010 (reference 2), the NRC provided the results of the NRC staff's acceptance review of this amendment request. The NRC staff concluded that additional information is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendment request in terms of regulatory requirements and the protection of public health and safety and the environment. The NRC staff requested that Exelon supplement the application to address the information requested by July 28, 2010. to this supplemental letter provides the information requested by the NRC. In addition, Unit 2 TS page 3.1-21 and Unit 3 TS page 3.1-21 have been revised and are being re-submitted as Attachment 2. Attachment 3 contains revised Bases pages which also supersede the Bases pages submitted March 24, 2010, with the initial LAR submittal.

U.S. Nuclear Regulatory Commission July 23, 2010 Page 2 There is no adverse impact to the No Significant Hazards Consideration submitted in the Reference (1) letter. There are no additional commitments contained within this letter.

If you have any questions or require additional information, please contact Mr. Doug Walker at (610) 765-5952.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd day of July 2010.

Respectfully, i

Pamela B. Cowan Director

- Licensing and Regulatory Affairs :

Response to NRC Acceptance Review Questions :

Proposed Markup of PBAPS Technical Specification Pages :

Proposed Markup of PBAPS Technical Specification Bases Pages cc:

USNRC Region I, Regional Administrator USNRC Project Manager, NRR

- Peach Bottom Atomic Power Station USNRC Senior Resident Inspector

- Peach Bottom Atomic Power Station S. T. Gray, State of Maryland R. R. Janati, Bureau of Radiation Protection, Commonwealth of Pennsylvania U.S. Nuclear Regulatory Commission July 23, 2010 Page 2 There is no adverse impact to the No Significant Hazards Consideration submitted in the Reference (1) letter. There are no additional commitments contained within this letter. If you have any questions or require additional information, please contact Mr. Doug Walker at (610) 765-5952.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd day of July 2010.

Respectfully,

'V'R,7r ~14at1 Pamela B. 'lo~~j Director - Licensing and Regulatory Affairs : : :

Response to NRC Acceptance Review Questions Proposed Markup of PBAPS Technical Specification Pages Proposed Markup of PBAPS Technical Specification Bases Pages cc:

USNRC Region I, Regional Administrator USNRC Project Manager, NRR - Peach Bottom Atomic Power Station USNRC Senior Resident Inspector - Peach Bottom Atomic Power Station S. T. Gray, State of Maryland R. R. Janati, Bureau of Radiation Protection, Commonwealth of Pennsylvania U.S. Nuclear Regulatory Commission July 23, 2010 Page 2 There is no adverse impact to the No Significant Hazards Consideration submitted in the Reference (1) letter. There are no additional commitments contained within this letter. If you have any questions or require additional information, please contact Mr. Doug Walker at (610) 765-5952.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd day of July 2010.

Respectfully,

'V'R,7r ~14at1 Pamela B. 'lo~~j Director - Licensing and Regulatory Affairs : : :

Response to NRC Acceptance Review Questions Proposed Markup of PBAPS Technical Specification Pages Proposed Markup of PBAPS Technical Specification Bases Pages cc:

USNRC Region I, Regional Administrator USNRC Project Manager, NRR - Peach Bottom Atomic Power Station USNRC Senior Resident Inspector - Peach Bottom Atomic Power Station S. T. Gray, State of Maryland R. R. Janati, Bureau of Radiation Protection, Commonwealth of Pennsylvania U.S. Nuclear Regulatory Commission July 23, 2010 Page 2 There is no adverse impact to the No Significant Hazards Consideration submitted in the Reference (1) letter. There are no additional commitments contained within this letter. If you have any questions or require additional information, please contact Mr. Doug Walker at (610) 765-5952.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd day of July 2010.

Respectfully,

'V'R,7r ~14at1 Pamela B. 'lo~~j Director - Licensing and Regulatory Affairs : : :

Response to NRC Acceptance Review Questions Proposed Markup of PBAPS Technical Specification Pages Proposed Markup of PBAPS Technical Specification Bases Pages cc:

USNRC Region I, Regional Administrator USNRC Project Manager, NRR - Peach Bottom Atomic Power Station USNRC Senior Resident Inspector - Peach Bottom Atomic Power Station S. T. Gray, State of Maryland R. R. Janati, Bureau of Radiation Protection, Commonwealth of Pennsylvania

ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 NRC Docket Nos. 50-277 and 50-278 Renewed Facility Operating License Nos.

DPR-44 and DPR-56 Supplement to Request for Amendment to Technical Specification 3.1.7 Standby Liquid Control (SLC) System Response to NRC Acceptance Review Questions ATTACHMENT 1 PEACH SOnOM ATOMIC POWER STATION UNITS 2 AND 3 NRC Docket Nos. 50-277 and 50-278 Renewed Facility Operating License Nos.

DPR-44 and DPR-56 Supplement to Request for Amendment to Technical Specification 3.1.7 "Standby Liquid Control (SLC) System" Response to NRC Acceptance Review Questions ATTACHMENT 1 PEACH SOnOM ATOMIC POWER STATION UNITS 2 AND 3 NRC Docket Nos. 50-277 and 50-278 Renewed Facility Operating License Nos.

DPR-44 and DPR-56 Supplement to Request for Amendment to Technical Specification 3.1.7 "Standby Liquid Control (SLC) System" Response to NRC Acceptance Review Questions

RESPONSE TO NRC ACCEPTANCE REVIEW QUESTIONS ATTACHMENT 1 REQUEST FOR INFORMATION RELATED TO ACCEPTANCE REVIEW REGARDING LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 3.1.7 "STANDBY LIQUID CONTROL SYSTEM" COMPLETION TIME FOR CONDITION C PEACH BOTTOM ATOMIC POWER STATION -UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278 By letter to the Nuclear Regulatory Commission (NRC) dated March 24, 2010, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100840752) Exelon Generation Company, LLC, (Exelon) submitted a request to revise the Technical Specifications (TS) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The proposed change would revise TS Section 3.1.7, "Standby Liquid Control (SLC) System," to extend the completion time for Condition C (i.e., "Two SLC subsystems inoperable for reasons other than Condition A") from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Supplemental Request 01 The NRC staff requests that Exelon clarify the intended reliance on EOP actions as an alternate means of boration and provide evaluations that justify any credited actions related to the requirements of 10 CFR 50.67, as appropriate.

Page 6 of Attachment 1 to the license amendment request (LAR) describes alternative means for boration as additional redundancy in support of defense-in-depth measures to justify the proposed extension of the TS 3.1.7, condition C, completion time. These alternative means of boration consist of actions in the PBAPS Emergency Operating Procedures (EOP). Page 3 of of the LAR states that the alternative means of boration support the station's ability to meet the requirements of Title 10 Code of Federal Regulations Part 50, Section 50.67 (10 CFR 50.67), "Accident source term."

The NRC staff has identified that the proposed alternate means of boration are not currently included in the PBAPS licensing basis. The LAR indicates that the licensee intends to credit the referenced EOP actions as an alternate boration pathway to meet the requirements of 10 CFR 50.67. If so, then additional justification is required to support reliance on these actions as a credited alternate boration pathway. The NRC document "Guidance on the Assessment of a BWR [boiling-water reactor] SLC System for pH Control," dated February 12, 2004 (ADAMS Accession No. ML040640364), provides an approach that is acceptable to the NRC staff for evaluating the alternative controls of the suppression pool pH against appropriate methodologies. If Exelon's intent is not to credit a new alternate boration pathway, then clarification is needed regarding the use of the EOP actions as an alternative means of boration with respect to defense-in-depth as related to 10 CFR 50.67.

Exelon Response The SLC CT Extension LAR stated the following regarding Alternative Source Term:

The SLC System is required to be operable in Modes 1, 2 and 3 to ensure that offsite doses remain within the limits of 10 CFR 50.67, "Accident source term" following LOCA involving significant fission product releases. However, additional redundancy for the control of suppression pool pH control following a LOCA is established by the PBAPS Emergency Operating Procedures (EOPs). The EOPs describe the actions and criteria

Supplement to Request for Amendment to Technical Specification 3.1.7 "Standby Liquid Control (SLC) System Response to NRC Acceptance Review Questions Page 2 of 10 for alternate means of manual addition of boron should the SLC System fail to operate as designed.

Exelon does not intend to credit the referenced EOP actions in the Licensing Basis as an alternate boration pathway to meet the requirements of 10 CFR 50.67. The reference to the existing PBAPS EOP procedures for alternate SLC injection are provided only to illustrate that additional methods currently exist to enhance and support Sodium Pentaborate injection in the event of a Design Basis LOCA which occurs in conjunction with an outage of the entire SLC System. It is understood that the alternate injection methods contained in PBAPS EOPs do not satisfy all of the requirements in the NRCs "Guidance on the Assessment of a BWR SLC System for pH Control," dated February 12, 2004.

However, the PBAPS SLC System continues to comply with the requirements of the NRCs "Guidance on the Assessment of a BWR SLC System for pH Control" as demonstrated and accepted in the PBAPS AST License Amendment. The Safety Evaluation for Issuance of Amendments Re: Application of Alternative Source Term Methodology (September 5, 2008) addresses the SLC System redundancy and states:

To demonstrate that the SLC system was capable of performing its intended safety function during a LOCA following AST implementation, the licensee utilized the guidance provided by the NRC in the review guideline document titled GUIDANCE ON THE ASSESSMENT OF A BWR SLC SYSTEM FOR pH CONTROL The fourth guideline in this document concerns the lack of redundancy of a plants SLC system with respect to its active components. A plant can offset this lack of redundancy by showing acceptable quality and reliability of non-redundant active components and/or compensatory actions in the event of failure of the non-redundant active components by meeting the six criteria outlined in the document The NRC staff has reviewed the calculations and justifications provided by the licensee and, based in this review, finds that the analysis presented in the licensees submittal support the conclusion that the SLC system will operate as required and that the suppression pool pH will stay basic for the period of 30 days after a LOCA.

The criteria stipulated in the Guidance on the Assessment of a BWR SLC System for pH Control do not refer to the licensee's established SLC System TS Completion Time (CT). The acceptability of the SLC System to fulfill the pH injection requirements does not depend on existing CT. The bases for redundancy and defense-in-depth of SLC injection for pH control centers around showing acceptable quality and reliability of non-redundant active components and/or compensatory actions in the event of failure of the non-redundant active components by meeting the six criteria outlined in the document. This has been accepted in the PBAPS AST Safety Evaluation. In extending the CT from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the defense-in-depth and redundancy justification remain. The increase in outage time is assessed through the PRA analysis, which has resulted in an acceptable margin of safety as shown in the LAR.

The LAR indicates that the extended CT will typically be utilized for emergent failures of the SLC System. Considering the station has consistently demonstrated that SLC System scheduled preventive and corrective maintenance can typically be performed in the existing 8-hour CT for the SLC System, it is not necessary to extend the CT for normal preventative and scheduled maintenance. The LAR is further clarified to limit the entrance into the extended 72-hour CT to

Supplement to Request for Amendment to Technical Specification 3.1.7 "Standby Liquid Control (SLC) System Response to NRC Acceptance Review Questions Page 3 of 10 prescribed conditions. Scheduled preventive and corrective system maintenance will still continue to be limited by the 8-hour CT, whereas emergent unplanned maintenance that satisfies Condition C of TS 3.1.7 will be permitted up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to complete repairs. Emergent failures can be identified through system inspection, routine surveillance or during scheduled maintenance if a newly identified condition requires entry into Condition C of TS 3.1.7. This limits the use of the 72-hour CT to only those occurrences that would currently result in a reactor shutdown and be candidates for a NOED, similar to the NOEDs submitted and approved for Quad Cities and Dresden (reference LAR precedent). Additionally, the compensatory measures committed in the Dresden and Quad Cities NOEDs are included in the TS language.

The revised TS 3.1.7 reads as follows:

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two SLC subsystems inoperable for reasons other than Condition A.

C.1 Restore one SLC subsystem to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months *

A Completion Time (CT) of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months may be invoked for Condition C when an emergent SLC System failure requires entrance into the Condition, provided the following compensatory measures are in place within the first 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of the CT:

1. The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor Protection System are OPERABLE and protected.

2. For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 is increased from once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

3. System maintenance outages and activities that increase plant risk will be prohibited for the duration of the CT.

In summary, the PBAPS SLC System has satisfied the redundancy and defense-in-depth with respect to the SLC injection requirements as indicated in the AST Safety Evaluation. The evaluation performed in response to the NRCs "Guidance on the Assessment of a BWR SLC System for pH Control," demonstrated an acceptable quality and reliability of non-redundant active components and/or compensatory actions in the event of failure of the non-redundant active components. The increase in the CT is significantly restricted to those prescribed times when an emergent failure results in entry into Condition C of TS 3.1.7 (i.e., both SLC trains inoperable).

Supplement to Request for Amendment to Technical Specification 3.1.7 "Standby Liquid Control (SLC) System Response to NRC Acceptance Review Questions Page 4 of 10 Supplemental Request 02 Identify adequate defense-in-depth for mitigation of ATWS events for the extended 72-hour completion time period.

The SLC System mitigates an (anticipated transient without scram) ATWS event by delivering a concentrated borated solution to the reactor pressure vessel to shutdown the reactor. The TS Required Action being modified addresses the condition where both SLC trains are inoperable.

In the event of an ATWS during this condition, there is no system available to inject concentrated borated solution into the reactor pressure vessel in a timely manner to achieve shutdown. The licensee submittal addresses the low probability of an ATWS event due to the reliability and diversity of the control rods, and also discusses the recirculation pump trip feature which reduces reactor power. However, there is no mechanism identified to assure safe shutdown to subcritical conditions as normally ensured by the operation of one of the two SLC trains.

Exelon Response The SLC System is used to shut down the reactor during an anticipated transient without scram (ATWS) event. The safety objective of the standby liquid control system is to provide a backup method, which is redundant to, but independent of, the control rods, to establish and maintain the reactor subcritical as the nuclear system cools. PBAPS UFSAR Section 3.8.4, Safety Evaluation states, The standby liquid control system is a special safety system not required for plant operation and never expected to be needed for plant safety because of the large number of independent control rods available to shut down the reactor.

As demonstrated in the LAR, PBAPS TS LCO 3.1.7 requires the operability of two SLC subsystems when the reactor is in Modes 1, 2, and 3. In Modes 1 and 2, the SLC System satisfies the requirements of Atomic Energy Commission (AEC) Criterion 27, 28, 29 and 30 and CFR 50.62, "Requirements for reduction of risk from anticipated transients without scram (ATWS) events for light-water-cooled nuclear power plants (note: Mode 3 was applied to TS 3.1.7 when AST was implemented at PBAPS under 10 CFR 50.67). 10 CFR 50.62(c) requires (and PBAPS satisfies) the requirements which demonstrate redundancy and defense-in-depth for an Anticipated Transient without Scram (ATWS) condition. The basis for the NRC Rule 10 CFR50.62 lies in the assessment of the failure to scram attributed to common cause failures of the electrical portion of the scram system or the mechanical portion of the scram system.

The elements of the rule provided redundant and diverse methods to cope with each of these failure modes.

For the electrical common cause failure modes(1), the rule implemented Alternate Rod Insertion (ARI) and Recirculating Pump Trip (RPT) as diverse and redundant methods to achieve reactor shutdown despite the common cause electrical failure to scram. Neither ARI nor RPT are affected by the SLC CT extension.

(1) INEL in NUREG/CR-5500 calculated that the probability of an ATWS event with an electrical scram failure is twice as likely as an ATWS due to a mechanical scram failure.

Supplement to Request for Amendment to Technical Specification 3.1.7 "Standby Liquid Control (SLC) System Response to NRC Acceptance Review Questions Page 5 of 10 For the mechanical common cause failure modes, the rule implemented a SLC requirement that was not single failure proof and required successful RPT.

Subsequently, the BWR Owners Group (BWROG) implemented EPG changes that enhance the ability to use the SLC System in an effective manner, and which provide additional defense-in-depth through alternative methods for insertion of negative reactivity. The BWROG addition of these alternative methods are real plant enhancements to safety which are incorporated into the PBAPS Emergency Operating Procedures (EOPs).

The defense-in-depth associated with a mechanical common cause failure of the scram system (in addition to the SLC System) involves:

RPT to significantly reduce power (automatic initiation)

RPV pressure control is satisfied by implementation of RPT. This is not affected by the SLC extended CT.

EOP actions by the crew to provide techniques to deal with the failure to scram Lower RPV water level to further reduce power Use the main condenser as a heat sink Direct all of the reactor heat to the main condenser In parallel with these control room actions, the following also occurs.

The crew takes two actions:

First:

Control Room Operator Action:

Insert individual control rods with the highest reactivity worth rods first, AND Second:

Field Auxiliary Operators Action:

Align alternate Boron injection for reactivity control.

The ability to lower RPV water level coupled with RPT can bring the power level within the turbine bypass capacity of the main condenser allowing hours for the crew to insert additional negative reactivity from individual control rods or alternate Boron injection.

This diverse procedural method significantly extends the time available for the crew to accomplish the addition of negative reactivity via:

Individual Control Rod Insertion OR Alternate Boron Injection Even without the main condenser, the reduced Reactor Pressure Vessel water level can bring the power level within the suppression pool cooling capability (depending on the severity of the ATWS).

The design requirements for reactivity control at PBAPS are satisfied for the current configuration. The existing TS 3.1.7 allows both trains of the SLC System to be out of service

Supplement to Request for Amendment to Technical Specification 3.1.7 "Standby Liquid Control (SLC) System Response to NRC Acceptance Review Questions Page 6 of 10 for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Currently, there are no additional redundancy or defense-in-depth measures stipulated when both trains of the SLC System are taken out of service for the first 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The increase to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months relies on these same existing defense-in-depth measures. The PRA assessment demonstrates that the incremental risk incurred by the increase in the CT is acceptable with acceptable margin.

In the introduction to Regulatory Guide (RG) 1.177, AN APPROACH FOR PLANT-SPECIFIC, RISK-INFORMED DECISIONMAKING: TECHNICAL SPECIFICATIONS, the RG states, The use of PRA technology should be increased in all regulatory matters to the extent supported by the state of the art in PRA methods and data and in a manner that complements the NRC's deterministic approach and supports the NRC's traditional defense-in-depth philosophy. This statement is elaborated on in section 2.2.1, Defense-In-Depth, with the following:

The engineering evaluation conducted should determine whether the impact of the proposed TS change is consistent with the defense-in-depth philosophy. In this regard, the intent of the principle is to ensure that the philosophy of defense-in-depth is maintained, not to prevent changes in the way defense-in-depth is achieved. The existing TS 3.1.7 allows both trains of the SLC system to be out of service for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The increase to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months relies on these same existing defense-in-depth measures.

Defense-in-depth has been and continues to be an effective way to account for uncertainties in equipment and human performance When a comprehensive risk analysis can be performed, it can be used to help determine the appropriate extent of defense-in-depth (e.g., balance among core damage prevention, containment failures, and consequence mitigation) to ensure protection of public health and safety. Thus risk informed information, when the risk increases are quantitatively assessed to be small or very small, can be used to provide an appropriate assessment and balance of defense-in-depth.

In Section 1.1.3, the RG states, AOT requirements for multiple trains out of service should not be longer than that for one of the constituent train. It is clear that this RG allows the use of risk information to justify multiple train (entire system) inoperability as long as the period of inoperability is appropriately short. The LAR submittal provides the comprehensive risk analysis that determines that the risk increases of this TS change is very small.

As stated in the response to Question 1 above, the proposed TS language is being revised to clearly state that the CT beyond the current 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months will only be utilized for emergent failures of the SLC System. SLC System corrective or preventive maintenance will not be scheduled for more than the existing 8-hour CT unless the condition is emergent and results in inoperability of both trains of the SLC System under TS 3.1.7 Condition C. Additionally, the compensatory measures to protect redundant systems and minimize risk will be implemented prior to exceeding the initial 8-hour CT. These compensatory measures include:

1. The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor Protection systems are Operable and protected.

2. For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 is increased from once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Supplement to Request for Amendment to Technical Specification 3.1.7 "Standby Liquid Control (SLC) System Response to NRC Acceptance Review Questions Page 7 of 10

3. System maintenance outages and activities that increase risk will be prohibited for the duration of the CT.

Because the SLC System CT is utilized only for emergent maintenance, no additional planned unavailability time will be incurred. An emergent SLC System outage has the same probability of occurring whether the CT is set at 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

In the case of an emergent system failure, this amendment will reduce the possibility of a required reactor shutdown resulting from SLC System failures. The CT extension to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months could avoid the possibility of an undesirable transient caused by the shutdown of the reactor as a result of compliance with the 8-hour CT currently in TS 3.1.7.C and, thus, minimizes potential safety consequences and operational risks associated with a plant shutdown. Note: the SLC System is not an initiator of any analyzed design basis event and therefore the CT extension does not increase the probability of a plant transient like a reactor shutdown would.

Competing Risk In addition to the very low calculated risk associated with the continued power operation with SLC in an LCO, it has previously been noted by both NRC and industry studies that imposing a shutdown will introduce its own risks. It is therefore a trade-off in the risks of staying at power versus a forced shutdown.

Continued power operation with the SLC System in an LCO contributes to the accumulated risk.

However, the requirement to demand a shutdown when SLC is inoperable can be considered an averted risk if it can be avoided. While this averted risk is not quantified(1) in the PBAPS SLC CT extension request, it is calculated that the risk associated with the forced shutdown is approximately equivalent to the risk of remaining at power.

Defense-in-Depth Assessment Consistency with the defense-in-depth philosophy as noted in RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis" (Section 2.2.1.1) is maintained if:

A reasonable balance is preserved among prevention of core damage, prevention of containment failure, and consequence mitigation.

Over-reliance on programmatic activities to compensate for weaknesses in plant design is avoided.

System redundancy, independence, and diversity are preserved commensurate with the expected frequency, consequences of challenges to the system, and uncertainties (e.g.,

no risk outliers).

Defenses against potential common cause failures are preserved and the potential for the introduction of new common cause failure mechanisms is assessed.

Independence of barriers is not degraded.

Defenses against human errors are preserved.

The intent of the general design criteria in 10 CFR Part 50, Appendix A, is maintained.

(1) The forced shutdown risk is estimated at 9.24E-08 per demand from the at-power PRA. This represents an approximation of the averted risk. Additional PRA analysis was provided in the initial March 24, 2010 LAR submittal.

Supplement to Request for Amendment to Technical Specification 3.1.7 "Standby Liquid Control (SLC) System Response to NRC Acceptance Review Questions Page 8 of 10 A discussion of the proposed changes against the defense-in-depth criteria listed above is provided below.

A reasonable balance is preserved among prevention of core damage, prevention of containment failure, and consequence mitigation.

The proposed change involves extensions of the CT for the SLC System from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for SLC System emergent repairs. Due to the constraints involved by the compensatory measures required to exceed the first 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , only the SLC System is unavailable during this LCO outage. Core damage due to an ATWS will be prevented by the availability of redundant and diverse methods of inserting sufficient negative reactivity to control the fission process and reach a safe, stable state. These systems include the following:

Reactor scram

- The reactor scram system (automatic or manual)

Or

- ARI and RPT And

- The control rods Individual control rod insertion and RPT

- Individual control rod insertion And

- RPT And

- EOP directed water level control Alternate SLC and RPT (used for partial ATWS conditions)

- Alternate SLC alignment And

- RPT And

- EOP directed water level control Prevention of containment failure will be assured based on adequate decay heat removal capability provided by safety systems via Balance of Plant (BOP) systems (i.e., the Main Condenser) or containment vent. Although the proposed AOT changes do impact core damage frequency (CDF) and large early release frequency (LERF), this impact is very low.

Consequence mitigation remains acceptable during the AOT extension. Therefore, a reasonable balance among prevention of core damage, prevention of containment failure, and consequence mitigation is preserved.

Supplement to Request for Amendment to Technical Specification 3.1.7 "Standby Liquid Control (SLC) System Response to NRC Acceptance Review Questions Page 9 of 10 Over-reliance on programmatic activities to compensate for weaknesses in plant design is avoided.

The proposed change involves extension of the AOT for the SLC System from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Due to the constraints involved with the compensatory measures required to exceed the first 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , only the SLC System is unavailable during this LCO outage.

No programmatic activities are necessary to compensate for the SLC unavailability.

System redundancy, independence, and diversity are preserved commensurate with the expected frequency, consequences of challenges to the system, and uncertainties (e.g., no risk outliers).

The safety equipment associated with the operable Reactivity Control Systems will continue to be capable of performing the necessary safety functions consistent with accident analysis assumptions. Therefore, sufficiently redundant, independent, and diverse capabilities will be maintained for performing critical safety functions during the proposed AOT extensions.

The degree of redundancy provided by the available reactivity control systems is commensurate with the expected frequency of the accident challenge and the consequences of the challenge including the uncertainties.

Defenses against potential common cause failures are preserved and the potential for the introduction of new common cause failure mechanisms is assessed.

The scram system, RPT, ARI, and alternate boron injection are established to assure the availability and capability of redundant, independent, and diverse means of accomplishing critical safety functions during the proposed AOT extensions. The proposed plant configuration poses no new common cause failures. Existing station work practices include programmatic controls to minimize the likelihood of human error induced common cause failures. As such, appropriate measures will be taken to preserve defenses against potential common cause failures and no new common cause failure mechanisms will be introduced as a result of SLC System maintenance and restoration.

Independence of barriers is not degraded.

As discussed above, means of achieving and maintaining safe shutdown conditions will be maintained during the proposed AOT extensions. These means are independent, redundant, and diverse and, consequently, they will prevent undue challenges to the fuel cladding, reactor coolant pressure boundary, and containment from occurring. Therefore, the independence of barriers will not be degraded by the proposed AOT extensions.

Defenses against human errors are preserved.

Critical safety functions will be maintained during the proposed AOT extensions. The compensatory measures include operator briefs to assure that the operating staff is fully aware of the plant configuration and actions that may be needed in order to respond to problems that could arise during the proposed AOT extension. Compensatory measures will also be established to prohibit discretionary maintenance on equipment required to be operable: RPS, ARI, RPT, and Alternate Boron Injection. The increased AOT will provide

Supplement to Request for Amendment to Technical Specification 3.1.7 "Standby Liquid Control (SLC) System Response to NRC Acceptance Review Questions Page 10 of 10 the necessary time to implement SLC repairs. This will reduce time pressure during the repairs, which will facilitate improved operator and maintenance personnel performance resulting in reduced errors. These measures will assure that the defenses against human errors will be adequately preserved during the proposed AOT extensions.

The intent of the General Design Criteria in 10 CFR Part 50, Appendix A, is maintained [note

- Atomic Energy Commission (AEC) Criterion 27, 28, 29 and 30 are applicable for PBAPS].

The proposed change involves an extension of the current TS AOT for systems that are impacted by the SLC repairs. The systems that are affected during a particular SLC LCO outage are all associated with the SLC System leaving the primary reactivity control method and the backup scram system fully capable and operable to perform their safety functions.

The proposed changes do not modify the plant design bases or the design criteria that were applied to structures, systems, and components during plant licensing. Consequently, the plant design with respect to the General Design Criteria is not affected by the proposed change.

Conclusion In conclusion and as stated in the original LAR, the control rods are the primary reactivity control system for the reactors at PBAPS. In conjunction with RPS, the control rods provide the means for reliable control of reactivity changes to ensure that fuel design limits are not exceeded. In addition to control rods and RPS, the ARI system provides a separate set of backup scram valves in the event that the normal scram path cannot be initiated by RPS. Defense-in-depth is maintained through these systems and each of these systems are available to shutdown the reactor during an emergent failure of both SLC trains.

For the control rod scram function to fail when a valid signal is sent, a diverse number of failures would have to occur in order in prevent the scram valves from opening. Also as noted, the ARI system would be available as a separate means for reactor shutdown in the event that the normal scram path cannot be initiated by the RPS. In addition to the ARI system, the ATWS Recirculating Pump Trip (RPT) provides an additional means for rapid power reduction in the event that the normal scram path cannot be initiated by RPS. Manual insertion of control rods is another method to shutdown the reactor. Adequate redundancy and defense-in-depth exists for reactivity control and the proposed change to the SLC System CT does not affect the redundancy, independence, or diversity of the RPS and ARI systems, or the RPT.

Finally, the proposed change to extend the CT is being limited to emergent conditions with the requirement to implement additional compensatory measures. The compensatory measures ensure that redundant systems are available and that the potential for transients is minimized.

ATTACHMENT 2 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 NRC Docket Nos. 50-277 and 50-278 Renewed Facility Operating License Nos.

DPR-44 and DPR-56 Supplement to Request for Amendment to Technical Specification 3.1.7 Standby Liquid Control (SLC) System Proposed Markup of PBAPS Technical Specification Pages Unit 2 Unit 3 3.1-21 3.1-21 ATTACHMENT 2 PEACH BOnOM ATOMIC POWER STATION UNITS 2 AND 3 NRC Docket Nos. 50-277 and 50-278 Renewed Facility Operating License Nos.

DPR-44 and DPR-56 Supplement to Request for Amendment to Technical Specification 3.1.7 "Standby Liquid Control (SLC) System" Proposed Markup of PBAPS Technical Specification Pages Unit 2 3.1-21 Unit 3 3.1-21 ATTACHMENT 2 PEACH BOnOM ATOMIC POWER STATION UNITS 2 AND 3 NRC Docket Nos. 50-277 and 50-278 Renewed Facility Operating License Nos.

DPR-44 and DPR-56 Supplement to Request for Amendment to Technical Specification 3.1.7 "Standby Liquid Control (SLC) System" Proposed Markup of PBAPS Technical Specification Pages Unit 2 3.1-21 Unit 3 3.1-21

SLC System 3.1.!

CONDITION REQUIRED ACTION COMPLETION EIME C

Eo SLC subsytems

C 1

Restore ore SLC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable or reasons subsystem to OPERABLE other than status.

Condition A.

0.

Required Action and 0.1 Be in MODE 3, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

0.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 Verify level of sodium pentaborate solution 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the SLC tank is 46%.

SR 3.1.7.2 Verify temperature of sodium pentaborate 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months solution is 53°F.

SR 3.1.7.3 Verify temperature of pump suction piping 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is 53°F.

SR 3.1.7.4 Verify continuity of explosive charge.

31 days

A Completion Time (CT) of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months may be invoked for Condition C when an emergent SLC system cont 1

)

failure requires entrance into the Condition, provided the following compensating measures are in place

(

within the first 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of entering the CT:

\\

1.

The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor Protection systems are OPERABLE and protected.

(

2.

For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 wilt be increased from once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

3.

System maintenance outages and activities that increase plant risk will be prohibited for the Amendment No.

ACTIONS (continued) nued) 269 SLC System 3.1.7 ACTIONS (continued)

COND IT ION REQUIRED ACTION COMPLETION TIME C.

Two SLC subsystems C.1 Restore one SLC 8 hourV inoperable for reasons subsystem to OPERABLE other than status.

Condition A.

D.

Required Action and D.l Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

Mill 0.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 SR 3.1.7.2 SR 3.1.7.3 SR 3.1.7.4 Verify level of sodium pentaborate solution 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the SLC tank is

~ 46%.

Verify temperature of sodium pentaborate 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months solution is

~ 53°F.

Verify temperature of pump suction piping 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is

~ 53°F.

Verify continuity of explosive charge.

31 days

A Completion Time (CT) of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months may be invoked for Condition C when an emergent SLC system failure requires entrance into the Condition, provided the following compensating measures are in place within the first 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of entering the CT:

1.

The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor

\\

Protection systems are OPERABLE and protected.

2.

For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 will be increased from once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

3.

System maintenance outages and activities that increase plant risk will be prohibited for the

,,<.__~;;~~~CT.

/'~~-

~ ------

3.1-21 Amendment No.

269 SLC System 3.1.7 ACTIONS (continued)

COND IT ION REQUIRED ACTION COMPLETION TIME C.

Two SLC subsystems C.1 Restore one SLC 8 hourV inoperable for reasons subsystem to OPERABLE other than status.

Condition A.

D.

Required Action and D.l Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

Mill 0.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 SR 3.1.7.2 SR 3.1.7.3 SR 3.1.7.4 Verify level of sodium pentaborate solution 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the SLC tank is

~ 46%.

Verify temperature of sodium pentaborate 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months solution is

~ 53°F.

Verify temperature of pump suction piping 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is

~ 53°F.

Verify continuity of explosive charge.

31 days

A Completion Time (CT) of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months may be invoked for Condition C when an emergent SLC system failure requires entrance into the Condition, provided the following compensating measures are in place within the first 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of entering the CT:

1.

The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor

\\

Protection systems are OPERABLE and protected.

2.

For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 will be increased from once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

3.

System maintenance outages and activities that increase plant risk will be prohibited for the

,,<.__~;;~~~CT.

/'~~-

~ ------

3.1-21 Amendment No.

269 SLC System 3.1.7 ACTIONS (continued)

COND IT ION REQUIRED ACTION COMPLETION TIME C.

Two SLC subsystems C.1 Restore one SLC 8 hourV inoperable for reasons subsystem to OPERABLE other than status.

Condition A.

D.

Required Action and D.l Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

Mill 0.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 SR 3.1.7.2 SR 3.1.7.3 SR 3.1.7.4 Verify level of sodium pentaborate solution 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the SLC tank is

~ 46%.

Verify temperature of sodium pentaborate 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months solution is

~ 53°F.

Verify temperature of pump suction piping 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is

~ 53°F.

Verify continuity of explosive charge.

31 days

A Completion Time (CT) of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months may be invoked for Condition C when an emergent SLC system failure requires entrance into the Condition, provided the following compensating measures are in place within the first 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of entering the CT:

1.

The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor

\\

Protection systems are OPERABLE and protected.

2.

For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 will be increased from once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

3.

System maintenance outages and activities that increase plant risk will be prohibited for the

,,<.__~;;~~~CT.

/'~~-

~ ------

3.1-21 Amendment No.

269

SLC System 3.1.7 CONDITION REQUIRED ACTION COMPLETION TIME C.

Two SLC subsystems C.1 Restore one SLC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ,j inoperable for reasons subsystem to OPERABLE other than status.

Condition A.

0.

Required Action and 0.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

A.Ni3 0.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE_REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 Verify level of sodium pentaborate solution 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the SLC tank is 46%.

SR 3.1.7.2 Verify temperature of sodium pentaborate 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months solution is 53°F.

SR 3.1.7.3 Verify temperature of pump suction piping 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is 53°F.

SR 3.1.7.4 Verify continuity of explosive charge.

31 days

41

A Completion Time (CT) of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months may be invoked for Condition C when an emergent SLC system

\\

/

failure requires entrance into the Condition, provided the following compensating measures are in place within the first 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of entering the CT:

)

1 The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor Protection systems are OPERABLE and protected.

2.

For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 will be increased from /

once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

System maintenance outages and activities that increase plant risk will e prohib4ed for the duration of the CT 1

ACTIONS (continued) 3.

PBAPS

NIT SLC System 3.1.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLET ION TIME C.

Two SLC subsystems C.1 Restore one SLC 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months s0 inoperable for reasons subsystem to OPERABLE other than status.

Condition A.

D.

Required Action and 0.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

81ill 0.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 SR 3.1.7.2 SR 3.1.7.3 SR 3.1.7.4 Verify level of sodium pentaborate solution 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the SLC tank is

~ 46%.

Verify temperature of sodium pentaborate 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months solution is

~ 53°F.

Verify temperature of pump suction piping 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is~53°F.

Verify continuity of explosive charge.

31 days

/. A'(;"ompletion Time (CT) of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ~y be invoked for Condition C when an emergent SLC system

/ -

failure requires entrance into the Condition, provided the following compensating measures are in place

)

\\

within the first 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of entering the CT:

1.

The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor

'\\

Protection systems are OPERABLE and protected.

2.

For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 will be increased from

\\

once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

. "'......*.,\\3.

System maintenance outages and activities that increase plant risk will !?~ prohib~d for the

.-.f PBAPS UN I r 3 \\,... ~~ration of,~~~~.......---J:'b,",-;H",-

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

.J~drn~jo:-*Z~

..............."'~............../

SLC System 3.1.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLET ION TIME C.

Two SLC subsystems C.1 Restore one SLC 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months s0 inoperable for reasons subsystem to OPERABLE other than status.

Condition A.

D.

Required Action and 0.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

81ill 0.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 SR 3.1.7.2 SR 3.1.7.3 SR 3.1.7.4 Verify level of sodium pentaborate solution 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the SLC tank is

~ 46%.

Verify temperature of sodium pentaborate 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months solution is

~ 53°F.

Verify temperature of pump suction piping 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is~53°F.

Verify continuity of explosive charge.

31 days

/. A'(;"ompletion Time (CT) of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ~y be invoked for Condition C when an emergent SLC system

/ -

failure requires entrance into the Condition, provided the following compensating measures are in place

)

\\

within the first 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of entering the CT:

1.

The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor

'\\

Protection systems are OPERABLE and protected.

2.

For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 will be increased from

\\

once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

. "'......*.,\\3.

System maintenance outages and activities that increase plant risk will !?~ prohib~d for the

.-.f PBAPS UN I r 3 \\,... ~~ration of,~~~~.......---J:'b,",-;H",-

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

.J~drn~jo:-*Z~

..............."'~............../

SLC System 3.1.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLET ION TIME C.

Two SLC subsystems C.1 Restore one SLC 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months s0 inoperable for reasons subsystem to OPERABLE other than status.

Condition A.

D.

Required Action and 0.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

81ill 0.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 SR 3.1.7.2 SR 3.1.7.3 SR 3.1.7.4 Verify level of sodium pentaborate solution 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the SLC tank is

~ 46%.

Verify temperature of sodium pentaborate 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months solution is

~ 53°F.

Verify temperature of pump suction piping 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is~53°F.

Verify continuity of explosive charge.

31 days

/. A'(;"ompletion Time (CT) of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ~y be invoked for Condition C when an emergent SLC system

/ -

failure requires entrance into the Condition, provided the following compensating measures are in place

)

\\

within the first 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of entering the CT:

1.

The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor

'\\

Protection systems are OPERABLE and protected.

2.

For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 will be increased from

\\

once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

. "'......*.,\\3.

System maintenance outages and activities that increase plant risk will !?~ prohib~d for the

.-.f PBAPS UN I r 3 \\,... ~~ration of,~~~~.......---J:'b,",-;H",-

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

.J~drn~jo:-*Z~

..............."'~............../

ATTACHMENT 3 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 NRC Docket Nos. 50-277 and 50-278 Renewed Facility Operating License Nos.

DPR-44 and DPR-56 Supplement to Request for Amendment to Technical Specification 3.1.7, Standby Liquid Control (SLC) System Proposed Markup of PBAPS Technical Specification Bases Pages Unit 2 Unit 3 B 3.1-43 B 3.1-43 B 3.1-47 B 3.1-47 ATTACHMENT 3 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 NRC Docket Nos. 50-277 and 50-278 Renewed Facility Operating License Nos.

DPR-44 and DPR-56 Supplement to Request for Amendment to Technical Specification 3.1.7, "Standby Liquid Control (SLC) System" Proposed Markup of PBAPS Technical Specification Bases Pages Unit 2 B 3.1-43 B 3.1-47 Unit 3 B 3.1-43 B 3.1-47 ATTACHMENT 3 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 NRC Docket Nos. 50-277 and 50-278 Renewed Facility Operating License Nos.

DPR-44 and DPR-56 Supplement to Request for Amendment to Technical Specification 3.1.7, "Standby Liquid Control (SLC) System" Proposed Markup of PBAPS Technical Specification Bases Pages Unit 2 B 3.1-43 B 3.1-47 Unit 3 B 3.1-43 B 3.1-47

BASES ACTIONS ILi (continued)

SLC Syctem B Li.!

could be indefinitely perable SLC of failing for availability of an OPERABLE subsystem capable of performino the intended SEC System function and the low probability of a

DBA or severe transient occurring concurrent with the failure of the Control Rod Drive (CR0)

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 combination of concen subsystem during any to meet the

[CO.

If instance, concentrati subsequently returned have been not met for lead to a total durat followed by

! days in the

[CO, to restore t could be found out of tration out of limits or mo single contiguous occurrence Condition B is entered while, on is out of limits, and is to within limi up to 3 days.

ion of 10 days Condition B),

he SEC System.

limits again, y

ts, the LCD may already This situation could (3 da s

in Condition A,

since initial failure of Then concentration and the SEC subsystem restored to OPERABLE.

This could continue This Completion Time allows for an exception to the normal time zero for beginning the allowed outage time clock, resulting in establishing the time zero at the time the

[CO was initially not met instead of at the time Condition B

was entered.

The 10 day Completion Time is an acceptable limitation on this potential to fail to meet the

[CO indefinitely.

C.i If both SEC 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 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 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.

ef. 4 0.1 and 0.2 If any Required Action and associated Completion Time is not

met, the plant must be brought to a

MODE in which the

[CO does not apply.

To achieve this status, the plant must be (continued)

PBAPS UNIT 2

B 3.1-43 Revision No.

75 BASES ACTIONS SLC System B 3.1. 7 ILl (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 failure of the Control Rod Drive (CRD) System to shut down the plant.

The second Completion Time for Required Action B.l establishes a limit on the maximum time al lowed for any combination of concentration out of limits or inoperable SLC subsystem during any single contiguous occurrence of failing to meet the LCO.

If Condition B is entered while, for instance, concentration is out of limits. and is subsequently returned to within limits. the LCO may already have been not met for up to 3 days.

This situation could lead to a total duration of 10 days (3 days in Condition A, followed by 7 days in Condition B), since initial failure of the LCO, to restore the SLC System.

Then concentration could be found out of limits again, and the SLC subsystem could be restored to OPERABLE.

This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock,"

resulting in establishing the "time zero" at the time the LCO was initially not met instead of at the time Condition B was entered.

The 10 day Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

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 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The al lowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 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.~

~

0.1 and 0.2 I

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 2 B 3.1-43 Revision No.

75 BASES ACTIONS SLC System B 3.1. 7 ILl (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 failure of the Control Rod Drive (CRD) System to shut down the plant.

The second Completion Time for Required Action B.l establishes a limit on the maximum time al lowed for any combination of concentration out of limits or inoperable SLC subsystem during any single contiguous occurrence of failing to meet the LCO.

If Condition B is entered while, for instance, concentration is out of limits. and is subsequently returned to within limits. the LCO may already have been not met for up to 3 days.

This situation could lead to a total duration of 10 days (3 days in Condition A, followed by 7 days in Condition B), since initial failure of the LCO, to restore the SLC System.

Then concentration could be found out of limits again, and the SLC subsystem could be restored to OPERABLE.

This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock,"

resulting in establishing the "time zero" at the time the LCO was initially not met instead of at the time Condition B was entered.

The 10 day Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

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 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The al lowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 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.~

~

0.1 and 0.2 I

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 2 B 3.1-43 Revision No.

75 BASES ACTIONS SLC System B 3.1. 7 ILl (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 failure of the Control Rod Drive (CRD) System to shut down the plant.

The second Completion Time for Required Action B.l establishes a limit on the maximum time al lowed for any combination of concentration out of limits or inoperable SLC subsystem during any single contiguous occurrence of failing to meet the LCO.

If Condition B is entered while, for instance, concentration is out of limits. and is subsequently returned to within limits. the LCO may already have been not met for up to 3 days.

This situation could lead to a total duration of 10 days (3 days in Condition A, followed by 7 days in Condition B), since initial failure of the LCO, to restore the SLC System.

Then concentration could be found out of limits again, and the SLC subsystem could be restored to OPERABLE.

This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock,"

resulting in establishing the "time zero" at the time the LCO was initially not met instead of at the time Condition B was entered.

The 10 day Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

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 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The al lowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 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.~

~

0.1 and 0.2 I

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 2 B 3.1-43 Revision No.

75

BASES SLC System B 3.1.7 SURVEI LLANCE REQU I REMENTS SR 3.1.7.9 (continued)

Surveillance when performed at the 24 month Frequency; therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.1.7.10 Enriched sodium pentaborate solution is made by mixing granular, enriched sodium pentaborate with water.

In order to ensure the proper B-b atom percentage (in accordance with Table 3.1.7-1) is being used, calculations must be performed to verify the actual B-b enrichment within 8

hours after addition of the solution to the SLC tank.

The calculations may be performed using the results of isotopic tests on the granular sodium pentaborate or vendor certification documents.

The Frequency is acceptable considering that boron enrichment is verified during the procurement process and any time boron is added to the SLC tank.

REFERENCES 1.

10 CFR 50.62.

2.

UFSAR, Section 3.8.4.

3.

10 CFR 50.67.

4

4. RM Documentation No. PB-LAR-05, Revision 0, Risk Assessment Input for Peach Bottom Technical Specification Change for Standby Liquid Control System Completion Time from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months November 16, 2009

/

PBAPS UNIT 2

B 3.1-47 Revision No.

75 BASES SURVEILLANCE REQUIREMENTS SLC System B 3.1.7 SR 3.1.7.9 (continued)

Surveillance when performed at the 24 month Frequency; therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.1.7.10 Enriched sodium pentaborate solution is made by mlxlng granular, enriched sodium penta borate with water.

In order to ensure the proper B-10 atom percentage (in accordance with Table 3.1.7-1) is being used, calculations must be performed to verify the actual B-10 enrichment within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after addition of the solution to the SLC tank.

The calculations may be performed using the results of isotopic tests on the granular sodium pentaborate or vendor certification documents.

The Frequency is acceptable considering that boron enrichment is verified during the procurement process and any time boron is added to the SLC tank.

REFERENCES 1.

10 CFR 50.62.

2.

UFSAR, Section 3.8.4.

3.

10 CFR 50.67.

/

4. RM Documentation No. PB-LAR-05, Revision 0, "Risk Assessment Input for Peach Bottom Technical Specification Change for Standby Liquid Control System Completion Time from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months " November 16, 2009 PBAPS UN IT 2 B 3.1-47 Revision No.

75 BASES SURVEILLANCE REQUIREMENTS SLC System B 3.1.7 SR 3.1.7.9 (continued)

Surveillance when performed at the 24 month Frequency; therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.1.7.10 Enriched sodium pentaborate solution is made by mlxlng granular, enriched sodium penta borate with water.

In order to ensure the proper B-10 atom percentage (in accordance with Table 3.1.7-1) is being used, calculations must be performed to verify the actual B-10 enrichment within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after addition of the solution to the SLC tank.

The calculations may be performed using the results of isotopic tests on the granular sodium pentaborate or vendor certification documents.

The Frequency is acceptable considering that boron enrichment is verified during the procurement process and any time boron is added to the SLC tank.

REFERENCES 1.

10 CFR 50.62.

2.

UFSAR, Section 3.8.4.

3.

10 CFR 50.67.

/

4. RM Documentation No. PB-LAR-05, Revision 0, "Risk Assessment Input for Peach Bottom Technical Specification Change for Standby Liquid Control System Completion Time from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months " November 16, 2009 PBAPS UN IT 2 B 3.1-47 Revision No.

75 BASES SURVEILLANCE REQUIREMENTS SLC System B 3.1.7 SR 3.1.7.9 (continued)

Surveillance when performed at the 24 month Frequency; therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.1.7.10 Enriched sodium pentaborate solution is made by mlxlng granular, enriched sodium penta borate with water.

In order to ensure the proper B-10 atom percentage (in accordance with Table 3.1.7-1) is being used, calculations must be performed to verify the actual B-10 enrichment within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after addition of the solution to the SLC tank.

The calculations may be performed using the results of isotopic tests on the granular sodium pentaborate or vendor certification documents.

The Frequency is acceptable considering that boron enrichment is verified during the procurement process and any time boron is added to the SLC tank.

REFERENCES 1.

10 CFR 50.62.

2.

UFSAR, Section 3.8.4.

3.

10 CFR 50.67.

/

4. RM Documentation No. PB-LAR-05, Revision 0, "Risk Assessment Input for Peach Bottom Technical Specification Change for Standby Liquid Control System Completion Time from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months " November 16, 2009 PBAPS UN IT 2 B 3.1-47 Revision No.

75

BASES ACTIONS J

(continued)

SLC System B

3.1.7 combination of concentration out of subsystem during any single contiguo to meet the

[CO.

If Condition B is instance, concentration is out of ii subsequently returned to within limi have been not met for up to 3 days.

lead to a total duration of 10 days followed by 7 days in Condition B),

the

[CO, to restore the S[C System.

could be found out of limits again, could be restored to OPERAB[E.

This indefini tely.

limits or inoperable S[C us occurrence of failing entered while, for

mits, and is ts, the

[CO may already This situation could (3 days in Condition A,

since initial failure of Then concentration and the S[C subsystem could continue This Completion Time allows for an exception to the normal time zero for beginning the allowed outage time clock, resulting in establishing the time zero at the time the

[CO was initially not met instead of at the time Condition was entered.

The 10 day Completion Time is an acceptable limitation on this potential to fail to meet the

[CO indefinitely.

C.1 If both S[C subsystems are inoperable for reasons other than Condition A,

at least one subsystem must be restored to OPERAB[E status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 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.

Insert 1 (Ref. 4) 0.1 and 0.2 If any Required Action and associated Completion Time is not

met, the plant must be brought to a

MODE in which the

[CO does not apply.

To achieve this status, the plant must be (continued) availability of an OPERAB[E subsystem capable of performing the intended S[C System function and the low probability of a

DBA or severe transient occurring concurrent with the 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 B

PBAPS UNIT 3

B 3.1-43 Revision No.

76 BASES ACTIONS SLC System B 3.1.7 li......l (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 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 combination of concentration out of limits or inoperable SLC subsystem during any single contiguous occurrence of failing to meet the LCO.

If Condition B is entered while, for instance, concentration is out of limits, and is subsequently returned to within limits, the LCO may already have been not met for up to 3 days.

This situation could lead to a total duration of 10 days (3 days in Condition A, followed by 7 days in Condition B), since initial failure of the LCO, to restore the SLC System.

Then concentration could be found out of limits again, and the SLC subsystem could be restored to OPERABLE.

This could continue indefinitely.

ThiS Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock,"

resulting in establishing the "time zero" at the time the LCO was initially not met instead of at the time Condition B was entered.

The 10 day Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

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 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 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. ~

. Jf

~

01 dD2

~

I an 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.

76 BASES ACTIONS SLC System B 3.1.7 li......l (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 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 combination of concentration out of limits or inoperable SLC subsystem during any single contiguous occurrence of failing to meet the LCO.

If Condition B is entered while, for instance, concentration is out of limits, and is subsequently returned to within limits, the LCO may already have been not met for up to 3 days.

This situation could lead to a total duration of 10 days (3 days in Condition A, followed by 7 days in Condition B), since initial failure of the LCO, to restore the SLC System.

Then concentration could be found out of limits again, and the SLC subsystem could be restored to OPERABLE.

This could continue indefinitely.

ThiS Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock,"

resulting in establishing the "time zero" at the time the LCO was initially not met instead of at the time Condition B was entered.

The 10 day Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

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 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 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. ~

. Jf

~

01 dD2

~

I an 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.

76 BASES ACTIONS SLC System B 3.1.7 li......l (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 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 combination of concentration out of limits or inoperable SLC subsystem during any single contiguous occurrence of failing to meet the LCO.

If Condition B is entered while, for instance, concentration is out of limits, and is subsequently returned to within limits, the LCO may already have been not met for up to 3 days.

This situation could lead to a total duration of 10 days (3 days in Condition A, followed by 7 days in Condition B), since initial failure of the LCO, to restore the SLC System.

Then concentration could be found out of limits again, and the SLC subsystem could be restored to OPERABLE.

This could continue indefinitely.

ThiS Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock,"

resulting in establishing the "time zero" at the time the LCO was initially not met instead of at the time Condition B was entered.

The 10 day Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

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 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 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. ~

. Jf

~

01 dD2

~

I an 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.

76

SLC System B 3.1.7 BASES SURVEILLANCE SR 3.1.7.9 (continued)

REQUIREMENTS Surveillance when performed at the 24 month Frequency; therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.1.7.10 Enriched sodium pentaborate solution is made by mixing

granular, enriched sodium pentaborate with water.

In order to ensure the proper B-JO atom percentage (in accordance with Table 3.1.7-1) is being used, calculations must be performed to verify the actual B-10 enrichment within 8

hours after addition of the solution to the SLC tank.

The calculations may be performed using the results of isotopic tests on the granular sodium pentaborate or vendor certification documents.

The Frequency is acceptable considering that boron enrichment is verified during the procurement process and any time boron is added to the SLC tank.

REFERENCES 1.

10 CFR 50.62.

2.

UFSAR, Section 3.8.4.

3.

10 CFR 50.67.

4. RM Documentation No. PB-LAR-05, Revision 0, Risk Assessment Input for Peach Bottom Technical Specification Change for Standby Liquid Control System Completion Time from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months November 16, 2009 PBAPS UNIT 3

B 3.1-47 Revision No.

76 BASES SURVEILLANCE REQUIREMENTS SLC System B 3.1.7 SR 3.1.7.9 (continued)

Surveillance when performed at the 24 month Frequency; therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.1.7.10 Enriched sodium pentaborate solution is made by mlxlng granular, enriched sodium pentaborate with water.

In order to ensure the proper B-I0 atom percentage (in accordance with Table 3.1.7-1) is being used, calculations must be performed to verify the actual B-10 enrichment within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after addition of the solution to the SLC tank.

The calculations may be performed using the results of isotopic tests on the granular sodium penta borate or vendor certification documents.

The Frequency is acceptable considering that boron enrichment is verified during the procurement process and any time boron is added to the SLC tank.

REFERENCES 1.

10 CFR 50.62.

2.

UFSAR, Section 3.8.4.

3.

10 CFR 50.67.

~

4. RM Documentation No. PB-LAR-05, Revision 0, "Risk Assessment Input for Peach Bottom Technical Specification Change for Standby Liquid Control System Completion Time from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months " November 16, 2009 PBAPS UN IT 3 B 3.1-47 Revision No.

76 BASES SURVEILLANCE REQUIREMENTS SLC System B 3.1.7 SR 3.1.7.9 (continued)

Surveillance when performed at the 24 month Frequency; therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.1.7.10 Enriched sodium pentaborate solution is made by mlxlng granular, enriched sodium pentaborate with water.

In order to ensure the proper B-I0 atom percentage (in accordance with Table 3.1.7-1) is being used, calculations must be performed to verify the actual B-10 enrichment within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after addition of the solution to the SLC tank.

The calculations may be performed using the results of isotopic tests on the granular sodium penta borate or vendor certification documents.

The Frequency is acceptable considering that boron enrichment is verified during the procurement process and any time boron is added to the SLC tank.

REFERENCES 1.

10 CFR 50.62.

2.

UFSAR, Section 3.8.4.

3.

10 CFR 50.67.

~

4. RM Documentation No. PB-LAR-05, Revision 0, "Risk Assessment Input for Peach Bottom Technical Specification Change for Standby Liquid Control System Completion Time from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months " November 16, 2009 PBAPS UN IT 3 B 3.1-47 Revision No.

76 BASES SURVEILLANCE REQUIREMENTS SLC System B 3.1.7 SR 3.1.7.9 (continued)

Surveillance when performed at the 24 month Frequency; therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.1.7.10 Enriched sodium pentaborate solution is made by mlxlng granular, enriched sodium pentaborate with water.

In order to ensure the proper B-I0 atom percentage (in accordance with Table 3.1.7-1) is being used, calculations must be performed to verify the actual B-10 enrichment within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after addition of the solution to the SLC tank.

The calculations may be performed using the results of isotopic tests on the granular sodium penta borate or vendor certification documents.

The Frequency is acceptable considering that boron enrichment is verified during the procurement process and any time boron is added to the SLC tank.

REFERENCES 1.

10 CFR 50.62.

2.

UFSAR, Section 3.8.4.

3.

10 CFR 50.67.

~

4. RM Documentation No. PB-LAR-05, Revision 0, "Risk Assessment Input for Peach Bottom Technical Specification Change for Standby Liquid Control System Completion Time from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months " November 16, 2009 PBAPS UN IT 3 B 3.1-47 Revision No.

76

Bases Insert The Completion Time (CT) can be extended beyond the initial 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for emergent failures that impact both subsystems of the SLC system (Condition C). The additional Allowed Outage Time is permitted for emergent failures only and cannot be utilized for performance of routine scheduled maintenance. Scheduled preventive and corrective system maintenance will still continue to be limited by the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months CT, whereas; emergent maintenance that satisfies Condition C of TS 3.1.7 will be permitted up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to complete repairs. Emergent failures can result from conditions identified during scheduled maintenance if the condition requires entry into Condition C of TS 3.1.7.

Additionally, the compensating measures to protect redundant systems and mitigate the potential for events caused by concurrent maintenance must be implemented prior to exceeding the initial 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months CT. These compensatory measures include:

1.

The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor Protection systems are Operable and protected.

2.

For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 is increased from once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

3.

System maintenance outages and activities that increase risk will be prohibited for the duration of the CT.

As stated in Reference 4, the risk assessment that forms the basis for the 72-hour CT assumes one entry per year into Condition C.1. With both SLC subsystems inoperable, the on-line risk would be depicted as Orange, based on the deterministic assessment portion of the Configuration Risk Management Program. In this condition, station procedures require senior management review and approval to remove equipment from service, as well as implementation of compensatory measures to reduce risk, including contingency plans.

Bases Insert The Completion Time (CT) can be extended beyond the initial 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for emergent failures that impact both subsystems of the SLC system (Condition C). The additional Allowed Outage Time is permitted for emergent failures only and cannot be utilized for performance of routine scheduled maintenance. Scheduled preventive and corrective system maintenance will still continue to be limited by the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months CT, whereas; emergent maintenance that satisfies Condition C of TS 3.1.7 will be permitted up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to complete repairs. Emergent failures can result from conditions identified during scheduled maintenance if the condition requires entry into Condition C of TS 3.1.7.

Additionally, the compensating measures to protect redundant systems and mitigate the potential for events caused by concurrent maintenance must be implemented prior to exceeding the initial 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months CT. These compensatory measures include:

1.

The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor Protection systems are Operable and protected.

2.

For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 is increased from once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

3.

System maintenance outages and activities that increase risk will be prohibited for the duration of the CT.

As stated in Reference 4, the risk assessment that forms the basis for the 72-hour CT assumes one entry per year into Condition C.1. With both SLC subsystems inoperable, the on-line risk would be depicted as "Orange," based on the deterministic assessment portion of the Configuration Risk Management Program. In this condition, station procedures require senior management review and approval to remove equipment from service, as well as implementation of compensatory measures to reduce risk, including contingency plans.

Bases Insert The Completion Time (CT) can be extended beyond the initial 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for emergent failures that impact both subsystems of the SLC system (Condition C). The additional Allowed Outage Time is permitted for emergent failures only and cannot be utilized for performance of routine scheduled maintenance. Scheduled preventive and corrective system maintenance will still continue to be limited by the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months CT, whereas; emergent maintenance that satisfies Condition C of TS 3.1.7 will be permitted up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to complete repairs. Emergent failures can result from conditions identified during scheduled maintenance if the condition requires entry into Condition C of TS 3.1.7.

Additionally, the compensating measures to protect redundant systems and mitigate the potential for events caused by concurrent maintenance must be implemented prior to exceeding the initial 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months CT. These compensatory measures include:

1.

The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor Protection systems are Operable and protected.

2.

For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 is increased from once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

3.

System maintenance outages and activities that increase risk will be prohibited for the duration of the CT.

As stated in Reference 4, the risk assessment that forms the basis for the 72-hour CT assumes one entry per year into Condition C.1. With both SLC subsystems inoperable, the on-line risk would be depicted as "Orange," based on the deterministic assessment portion of the Configuration Risk Management Program. In this condition, station procedures require senior management review and approval to remove equipment from service, as well as implementation of compensatory measures to reduce risk, including contingency plans.

Bases Insert The Completion Time (CT) can be extended beyond the initial 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for emergent failures that impact both subsystems of the SLC system (Condition C). The additional Allowed Outage Time is permitted for emergent failures only and cannot be utilized for performance of routine scheduled maintenance. Scheduled preventive and corrective system maintenance will still continue to be limited by the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months CT, whereas; emergent maintenance that satisfies Condition C of TS 3.1.7 will be permitted up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to complete repairs. Emergent failures can result from conditions identified during scheduled maintenance if the condition requires entry into Condition C of TS 3.1.7.

Additionally, the compensating measures to protect redundant systems and mitigate the potential for events caused by concurrent maintenance must be implemented prior to exceeding the initial 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months CT. These compensatory measures include:

1.

The Alternate Rod Injection system, both ATWS Recirculation Pump Trip Systems and the Reactor Protection systems are Operable and protected.

2.

For conditions where the SLC tank is available, the frequency for SR 3.1.7.1 is increased from once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

3.

System maintenance outages and activities that increase risk will be prohibited for the duration of the CT.

As stated in Reference 4, the risk assessment that forms the basis for the 72-hour CT assumes one entry per year into Condition C.1. With both SLC subsystems inoperable, the on-line risk would be depicted as "Orange," based on the deterministic assessment portion of the Configuration Risk Management Program. In this condition, station procedures require senior management review and approval to remove equipment from service, as well as implementation of compensatory measures to reduce risk, including contingency plans.

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