Text

Issuance of Amendments to Adopt Technical Specification Task Force (TSTF) 425, Revision 3 for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program
	ML103140657
Person / Time
Site:	North Anna
Issue date:	01/31/2011
From:	V Sreenivas; Plant Licensing Branch II
To:	Heacock D; Virginia Electric & Power Co (VEPCO)
	Sreenivas V.NRR/DORL/LPL2-1 415-2597
References
	TAC ME3689, TAC ME3690
	Download: ML103140657 (138)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 January 31, 2011 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2,ISSUANCE OF AMENDMENTS TO ADOPT TECHNICAL SPECIFICATION TASK FORCE (TSTF)-425, REVISION 3, FOR THE RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO A LICENSEE CONTROLLED PROGRAM (TAC NOS. ME3689 AND ME3690)

Dear Mr. Heacock:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment Nos. 262 and 243 to Renewed Facility Operating License Nos. NPF-4 and NPF-7 for the North Anna Power Station, Unit Nos. 1 and 2. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated March 30, 2010, as supplemented by letters dated August 30, 2010 and January 18, 2011.

The amendments revise the TSs by relocating specific surveillance frequencies to a licensee-controlled program with the implementation of Nuclear Energy Institute 04-10, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies." The changes are consistent with NRC-approved Industry Technical Specification Task Force (TSTF) Standard Technical Specifications change TSTF-425, Revision 3.

D. Heacock

- 2 A copy of our related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

r. V. Sreenivas, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339

Enclosures:

1. Amendment No. 262 to NPF-4

2. Amendment No. 243 to NPF-7

3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 VIRGINIA ELECTRIC AND POWER COMPANY DOCKET NO. 50-338 NORTH ANNA POWER STATION. UNIT NO.1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 262 Renewed License No. NPF-4

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Virginia Electric and Power Company et al.. (the licensee) dated March 30,2010, as supplemented by letters dated August 30,2010 and January 18, 2011, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

- 2

2.

Accordingly, the license is amended by changes to paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-4, as indicated in the attachment to this license amendment, and is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 262, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 180 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Gloria Kulesa, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-4 and the Technical Specifications Date of Issuance: January 31, 2011

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 VIRGINIA ELECTRIC AND POWER COMPANY DOCKET NO. 50-339 NORTH ANNA POWER STATION, UNIT NO.2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 243 Renewed License No. NPF~7

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Virginia Electric and Power Company et al.. (the licensee) dated March 30,2010, as supplemented by letters dated August 30 and January 18. 2010. complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act). and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public. and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

- 2

2.

Accordingly, the license is amended by changes to paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-7, as indicated in the attachment to this license amendment, and is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 243, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 180 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Gloria Kulesa, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-7 and the Technical Specifications Date of Issuance: January 31,2011

ATTACHMENT TO LICENSE AMENDMENT NO. 262 RENEWED FACILITY OPERATING LICENSE NO. NPF-4 DOCKET NO. 50-338 AND TO LICENSE AMENDMENT NO. 243 RENEWED FACILITY OPERATING LICENSE NO. NPF-7 DOCKET NO. 50-339 Replace the following pages of the Licenses and the Appendix "A" Technical Specifications (TSs) with the enclosed pages as indicated. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.

Remove Pages Insert Pages Licenses Licenses License No. NPF-4, page 3 License No. NPF-4, page 3 License No. NPF-7, page 3 License No. NPF-7, page 3 3.1.1-1 3.1.1-1 3,1.2-2 3.1.2-2 3.1.4-3 3.1.4-3 3.1.5-2 3.1.5-2 3.1.6-3 3.1.6-3 3.1,7-3 3.1.7-3 3.1.9-2 3.1.9-2 3.2.1-3 3.2.1-3 3.2.2-2 3.2.2-2 3.2.3-1 3.2.3-1 3.2.4-3 3.2.4-3 3.2.4-4 3.2.4-4 3.3.1-8 3.3.1-8 3.3.1-9 3.3.1-9 3.3.1-10 3.3.1-10 3.3.1-11 3.3.1-11 3.3.1-12 3.3.1-12 3.3.2-5 3.3.2-5 3.3.2-6 3.3.2-6 3.3.2-7 3.3.2-7

3.3.3-2 3.3.4-1 3.3.4-2 3.3.5-2 3.3.6-2 3.4.1-2 3.4.2-1 3.4.3-2 3.4.4-1 3.4.5-2 3.4.6-2 3.4.7-3 3.4.8-2 3.4.9-2 3.4.11-3 3.4.11-4 3.4.12-3 3.4.12-4 3.4.13-2 3.4.14-2 3.4.15-3 3.4.16-2 3.4.17-2 3.4.19-1 3.5.1-2 3.5.2-2 3.5.2-3 3.5.4-2 3.5.5-2 3.5.6-2 3.6.2-5 3.6.3-5 3.6.3-6 3.6.4-1 3.6.5-1 3.6.6-1 3.6.6-2 3.6.7-2 3.6.7-3 3.6.8-1 3.6.8-2 3.7.2-2 3.7.3-2 3.7.4-1 3.7.5-2 3.7.5-3

- 2 3.3.3-2 3.3.4-1 3.3.4-2 3.3.5-2 3.3.5-3 3.3.6-2 3.4.1-2 3.4.2-1 3.4.3-2 3.4.4-1 3.4.5-2 3.4.5-3 3.4.6-2 3.4.7-3 3.4.8-2 3.4.9-2 3.4.11-3 3.4.11-4 3.4.12-3 3.4.12-4 3.4.13-2 3.4.14-2 3.4.15-3 3.4.16-2 3.4.17-2 3.4.19-1 3.5.1-2 3.5.2-2 3.5.2-3 3.5.4-2 3.5.5-2 3.5.6-2 3.6.2-5 3.6.3-5 3.6.3-6 3.6.4-1 3.6.5-1 3.6.6-1 3.6.6-2 3.6.7-2 3.6.7-3 3.6.8-1 3.6.8-2 3.7.2-2 3.7.3-2 3.7.4-1 3.7.4-2 3.7.5-2 3.7.5-3

- 3 3.7.5-4 3.7.6-1 3.7.6-1 3.7.7-1 3.7.7-1 3.7.8-3 3.7.8-3 3.7.8-4 3.7.9-1 3.7.9-1 3.7.10-3 3.7.10-3 3.7.11-2 3.7.11-2 3.7.12-4 3.7.12-4 3.7.12-5 3.7.12-5 3.7.15-1 3.7.15-1 3.7.16-1 3.7.16-1 3.7.17-1 3.7.17-1 3.7.19-2 3.7.19-2 3.8.1-8 3.8.1-8 3.8.1-9 3.8.1-9 3.8.1-10 3.8.1-10 3.8.1-11 3.8.1-11 3.8.1-12 3.8.1-12 3.8.1-13 3.8.1-13 3.8.1-14 3.8.1-14 3.8.1-15 3.8.1-15 3.8.1-16 3.8.1-16 3.8.1-17 3.8.1-17 3.8.1-18 3.8.1-18 3.8.1-19 3.8.3-3 3.8.3-3 3.8.4-2 3.8.4-2 3.8.4-3 3.8.4-3 3.8.4-4 3.8.4-4 3.8.4-5 3.8.6-2 3.8.6-2 3.8.6-3 3.8.6-3 3.8.7-2 3.8.7-2 3.8.8-2 3.8.8-2 3.8.9-3 3.8.9-3 3.8.10-2 3.8.10-2 3.9.1-1 3.9.1-1 3.9.3-2 3.9.3-2 3.9.4-2 3.9.4-2 3.9.5-2 3.9.5-2 3.9.6-3 3.9.6-3 3.9.7-1 3.9.7-1 5.5-17 5.5-17

3*

(2) Pursuant to the Act and 10 CFR Part 70, VEPCa to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report; (3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, VEPCO to receive, possess, and use at any time any byproduct. source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors In amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30.40, and 70, VEPCO to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material, without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or component; and (5) Pursuant to the Act and 10 CFR Parts 30 and 70, VEPCO to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the faCility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections SO.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and Is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level VEPCO is authorized to operate the North Anna Power Station, Unit NO.1, at reactor core power levels not in excess of 2940 megawatts (thermal).

(2) Technical Specifications The Technical Sl'1l"lr.ificatlons contained in Appendix A, as revised through Amendment No.262 ~e hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical SpeCifications.

Renewed License /\\In. NPF*4 NORTH ANNA

UNIT 1 Amendment NOQ 262

-3 (3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70. VEPCa to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, VEPCa to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material, without restriction to chemical or physical form, for sample analysis or Instrument calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30,40. and 70, VEPCa to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility, C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations as set forth in 10 CFR Chapter! and Is subject to all applicable provisions 01 the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level VEPca is authorized to operate the facility at steady state reactor core power levels not in excess of 2940 megawatts (thermal).

(2) Technical Specifications The Technical Sper,ifications contained in Appendix A, as revised through Amendment No.243 are hereby incorporated In the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Additional Conditions The matters speciiied in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following the issuance of the condition or within the operational restrictions indicated. The removal of these conditions shall be made by an amendment to the renewed license supported by a favorable evaluation by the Commission:

a. If VEPCO plans to remove or to make significant changes in the normal operation of equipment that controls the amount of radioactivity in eftluents from the North Anna Power Station. the Renewed License No. NPF*7 NORTH ANNA* UNIT 2 Hla1dre1t ~. 243

SDM 3.1.1 3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 SHUTDOWN MARGIN (SDM)

LCO 3.1.1 SDM shall be within the limits provided in the COLR.

APPLICABILITY:

MODE 2 with keff < 1.0, MODES 3, 4, and 5.

ACTIONS CONDITION REQU IRED ACTI ON COMPLETION TIME A.

SDM not within limit.

A.l Initiate boration to restore SDM to within 1imit.

15 minutes SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify SDM to be within limits.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.1.1-1 Amendments262 and 243

Core Reactivity 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.1. 2.1

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

The predicted reactivity values may be adjusted (normalized) to correspond to the measured core reactivity prior to exceeding a fuel burnup of 60 effective full power days (EFPD) after each fuel loading.

Verify measured core reactivity is within

+/- 1% Ak/k of predicted values.

FREQUENCY Once prior to entering MODE 1 after each refueling AND

NOTE-----

Only required after 60 EFPD In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.1.2-2 Amendments 262 and 243

Rod Group Alignment Limits 3.1.4 ACTIONS CONDITION REQUIRED ACTION D.

More than one rod within alignment 1imit.

not 0.1.1 Verify SDM to be within the limit provided in the COLR.

OR 0.1.2 Initiate boration to restore required SDM to withi n 1imit.

AND D.2 Be in MODE 3.

SURVEILLANCE REQUIREMENTS COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify individual rod positions within alignment limit.

In accordance with the Surveillance Frequency Control Program SR 3.1. 4.2 Verify rod freedom of movement (trippability) by moving each rod not fully inserted in the core ~ 10 steps in either direction.

In accordance with the Survei 11 ance.

Frequency Control Program SR 3.1.4.3 Verify rod drop time of each rod, from the fully withdrawn position, is s 2.7 seconds from the beginning of decay of stationary gripper coil voltage to dashpot entry, with:

a. Tavg 2 500°F; and

b. All reactor coolant pumps operating.

Pri or to reactor criti ca1ity after each removal of the reactor head North Anna Units 1 and 2 3.1.4-3 Amendments 262 and 243

Shutdown Bank Insertion Limits 3.1.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.

One shutdown bank inserted ~ 18 steps below the insertion limit and immovable.

AND Each control and shutdown rod within limits of LCO 3.1.4.

AND Each control bank within the insertion limits of LCO 3.1.6.

B.1 AND B.2 Verify SDM to be within the limits provided in the COLR.

Restore the shutdown bank to within insertion limit.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 72 hours C.

Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.1.5.1 Verify each shutdown bank is within the insertion limits specified in the COLR.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.1. 5-2 Amendments 262 and 243

Control Bank Insertion Limits 3.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.2 Verify each control bank is within the insertion limits specified in the COLR.

In accordance with the Surveillance Frequency Control Program SR 3.1.6.3 Verify each control bank not fully withdrawn from the core is within the sequence and overlap limits specified in the COLR.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.1.6-3 Amendments262 and 243

Rod Position Indication 3.1. 7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D.

One demand position indicator per bank inoperable for one or more banks.

0.1.1 AND D.1.2 OR D.2 Verify by administrative means all RPI s for the affected banks are OPERABLE.

Verify the most withdrawn rod and the least withdrawn rod of the affected banks are s 12 steps apart.

Reduce THERMAL POWER to S 50% RTP.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 8 hours E.

Required Action and associated Completion Time not met.

E,1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 Perform CHANNEL CALIBRATION of each RPI.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.1.7-3 Amendments 262 and 243

PHYSICS TESTS Exceptions-MODE 2 3.1.9 ACTIONS CONDITION REQUIRED ACTION COMPLETI ON TIME D.

Required Action and associated Completion Time of Condition C not met; 0.1 Be in MODE 3.

15 minutes SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.9.1 Perform a CHANNEL OPERATIONAL TEST on power range and intermediate range channels per SR 3.3.1.7. SR 3.3.1.8, and Table 3.3.1-1.

Prior to initiation of PHYSICS TESTS SR 3.1.9.2 Verify the RCS lowest loop average temperature is ~ 531°F.

In accordance with the Surveillance Frequency Control Program SR 3.1. 9.3 Verify THERMAL POWER is ~ 5% RTP.

In accordance with the Surveillance Frequency Control Program SR 3.1. 9.4 Verify SDM to be within the limits provided in the COLR.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.1.9-2 Amendments 262 and 243

FQ(Z) 3.2.1 SURVEILLANCE REQUIREMENTS SR 3.2.1.1 SURVEILLANCE

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

If Fg(Z) measurements indicate F~(Z)]

maximum over z [ K(Z) has increased since the previous evaluation of FS(Z):

a. Increase F~(Z) by the appropriate factor and verify Fg(Z) is still within limits; or

b. Repeat SR 3.2.1.1 once per 7 EFPO until two successive flux maps indicate F~(Z)l maximum over z [ K(Z) has not increased.

Verify F~(Z) is within limit.

FREQUENCY Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by

~ 10% RTP. the THERMAL POWER at whi ch F~ (Z) was last verified AND In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.2.1-3 Amendments 262 and 243

N FAH 3.2.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.4

NOTE--------

THERMAL POWER does not have to be reduced to comply with this Required Action.

Perform SR 3.2.2.1.

Prior to THERMAL POWER exceeding 50% RTP AND Pri or to THERMAL POWER exceeding 75% RTP AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER reaching 2 95% RTP B.

Required Action and associated Completion Time not met.

B.1 Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS SURVEI LLANCE SR 3.2.2.1 Verify F1H ;s within limits specified in the COLR.

FREQUENCY Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND In accordance with the Survei 11 ance Frequency Control Program North Anna Units 1 and 2 3.2.2-2 Amendments262 and 243

AFD 3.2.3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 AXIAL FLUX DIFFERENCE (AFD) lCO 3.2.3 The AFD in % flux difference units shall be maintained within the limits specified in the COLR.

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

The AFD shall be considered outside limits when two or more OPERABLE excore channels indicate AFD to be outside limits.

APPLICABILITY:

MODE I with THERMAL POWER ~ 50% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

AFD not within limits.

A.I Reduce THERMAL POWER to < 50% RTP.

30 minutes SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.2.3.1 Verify AFD within limits for each OPERABLE excore channel.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.2.3-1 Amendments 262 and 243

QPTR 3.2.4 ACTIONS CONDITION A.

(continued)

A.6 REQUIRED ACTION

NOTE--------

Perform Required Action A.6 only after Required Action A.5 is completed.

COMPLETION TIME Perform SR 3.2.1.1 and SR 3.2.2.1.

With"j n 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equil i bri urn Conditions at RTP not to exceed 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after increasing THERMAL POWER above the limit of Required Action A.1 B.

Required Action and associated Completion Time not met.

B.1 Reduce THERMAL POWER to ~ 50% RTP.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.2.4.1

NOTES---------------

1. With input from one Power Range Neutron Flux channel inoperable and THERMAL POWER ~ 75% RTP, the remaining three power range channels can be used for calculating QPTR.

2. SR 3.2.4.2 may be performed in lieu of this Surveillance.

Verify QPTR is within limit by calculation.

FREQUENCY In accordance with the Survei 11 ance Frequency Control Program North Anna Units 1 and 2 3.2.4-3 Amendments 262 and 243

QPTR 3.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.2.4.2

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after input from one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER

> 75% RTP.

Verify QPTR is within limit using the movable incore detectors.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.2.4-4 Amendments 262 and 243

3.3.1 RTS Instrumentation ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME R.

One or more inoperable.

channels R.1 OR R.2 Verify interlock ;s in required state for existing unit conditions.

Be in MODE 2.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 7 hours S.

One trip mechanism inoperable for one RTB.

S.l OR S.2 Restore inoperable trip mechanism to OPERABLE status.

Be in MODE 3.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 54 hours SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.1-1 to determine which SRs apply for each RTS Function.

SURVEILLANCE FREQUENCY SR 3.3.1.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.2

NOT£-----------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is

~ 15% RTP.

Compare results of calorimetric heat balance calculation to power range channel output~ Adjust power range output if calorimetric heat balance calculation result exceeds power range channel output by more than +2% RTP.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.3.1-8 Amendments 262 and 243

RTS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.3

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

Not required to be performed until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after THERMAL POWER is 2 15% RTP.

Compare results of the incore detector measurements to Nuclear Instrumentation System (NIS) AFD.

Adjust NIS channel if absolute difference is 2 3%.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.4

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

This Surveillance must be performed on the reactor trip bypass breaker immediately after placing the bypass breaker in service.

Perform TADOT.

In accordance with the Survei1lance Frequency Control Program SR 3.3.1.5 Perform ACTUATION LOGIC TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.6

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

Verification of setpoint is not required.

Perform TADOT.

In accordance with the Survei11ance Frequency Control Program North Anna Units 1 and 2 3.3.1-9 Amendments 262 and 243

RTS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.7

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

Not required to be performed for source range instrumentation prior to entering MODE 3 from MODE 2 until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after entry into MODE 3.

Perform COT.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.8

~------------------NOTE---------------

This Surveillance shall include verification that interlocks P-6 and P-10 are in their required state for existing unit conditions.

Perform COT.

NOTE----

Only required when not performed within the frequency specified in the Surveillance Control Program Prior to reactor startup Four hours after reducing power below P-6 for source range instrumentation Twelve hours after reducing power below P-IO for power and intermediate range instrumentation AND In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.3.1-10 Amendments 262 and 243

RTS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.9

NOTES-------------

1. Adjust NIS channel if absolute difference ~ 3%.

2. Not required to be performed until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after THERMAL POWER is

~ 50% RTP.

Compare results of the excore channels to incore detector measurements.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.10

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

This Surveillance shall include verification that the time constants are adjusted to the prescribed values.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.11

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

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.12 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.3.1-11 Amendments 262 and 243

RTS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.13 Perform COT.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.14

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

Verification of setpoint ;s not required.

Perform TADOT.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.15

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

Verification of setpoint ;s not required.

Perform TADOT.

Prior to exceeding the P-8 interlock whenever the unit has been in MODE 3, i f not performed within the previous 31 days SR 3.3.1.16

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

Neutron detectors are excluded from response time testing.

Verify RTS RESPONSE TIME is within 1im; ts.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.3.1-12 Amendments262 and 243

ESFAS Instrumentation 3.3.2 ACTIONS CONDITION REQUIRED ACTION COMPLETI ON TIME J. One or more channels inoperable.

J.l Verify interlock is in required state for existing unit condition.

OR J.2.1 Be in MODE 3.

AND J.2.2 Be in MODE 4.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 7 hours 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.

SURVEILLANCE FREQUENCY SR 3.3.2.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.2 Perform ACTUATION LOG[C TEST.

In accordance with the Survei 11 ance Frequency Control Program SR 3.3.2.3 Perform MASTER RELAY TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.4 Perform COT In accordance with the Survei 11 ance Frequency Control Program North Anna Units 1 and 2 3.3.2-5 Amendments 262 and 243

ESFAS Instrumentation 3.3.2 SURVEI LLANCE FREQUENCY SR 3.3.2.5

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

Not required to be performed for SLAVE RELAYS if testing would:

1. Result in an inadvertent Reactor Trip System or ESFAS Actuation if accompanied by a single failure in the Safeguard Test Cabinet;

2. Adversely affect two or more components in one or more ESFAS system(s}; or

3. Create a reactivity, thermal, or hydraulic transient condition in the Reactor Coolant System.

Perform SLAVE RELAY TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.6

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

Verification of relay setpoints not required.

Perform TADOT.

In accordance with the Survei 11 ance Frequency Control Program North Anna Units 1 and 2 3.3.2-6 Amendments 262 and 243

ESFAS Instrumentation 3.3.2 SURVEILLANCE FREQUENCY SR 3.3.2.7

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

Verification of setpoint not required for manual initiation or interlock functions.

Perform TADOT.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.8

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

This Surveillance shall include verification that the time constants are adjusted to the prescribed values.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.9

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

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after SG pressure is

~ 1005 psig.

Verify ESFAS RESPONSE TIMES are within limit.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.3.2-7 Amendments 262 and 243

PAM Instrumentation 3.3.3 SURVEILLANCE REQUIREMENTS

- - NOTE SR 3.3.3.1 and SR 3.3.3.3 apply to each PAM instrumentation Function in Table 3.3.3-1 except SR 3.3.3.3 does not apply to Item 10. SR 3.3.3.4 applies only to Item 10.

SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required instrumentation channel that is normally energized.

In. accordance with the Surveillance Frequency Control Program SR 3.3.3.2 Not Used SR 3.3.3.3

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

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.3.4 Perform TADOr.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.3.3-2 Amendments 262 and 243

Remote Shutdown System 3.3.4 3.3 INSTRUMENTATION 3.3.4 Remote Shutdown System LCO 3.3.4 The Remote Shutdown System Functions shall be OPERABLE.

APPLICABILITY:

MODES 1. 2, and 3.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQU I RED ACTI ON COMPLETION TIME A.

One or more required Functions inoperable.

A.I Restore required Function to OPERABLE status.

30 days B.

Required Action and associated Completion Iime not met.

B.1 AND B.2 Be in MODE 3.

Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREQUENCY SR 3.3.4.1 Perform CHANNEL CHECK for each required instrumentation channel that is normally energized.

In accordance with the Surveillance Frequency Control Program SR 3.3.4.2 Verify each required control circuit and transfer switch is capable of performing the intended function.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.3.4-1 Amendments 262 and 243

Remote Shutdown System 3.3.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.3.4.3 Perform CHANNEL CALIBRATION for each required instrumentation channel.

FREQUENCY In accordance with the Surveillance Frequency Control Program Amendments 262 and 243 North Anna Units 1 and 2

LOP EDG Start Instrumentation 3.3.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.

Required Action and associated Completion Time not met.

C.I Enter applicable Condition(s) and Required Action(s) for the associated EDG made inoperable by LOP EDG start instrumentation.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1

-~------------------NOTE-------------

Verification of setpoint is not required.

Perform TADOT for LCO 3.3.5.a and LCO 3.3.5.b Functions.

In accordance with the Surveil 1ance Frequency Control Program SR 3.3.5.2 Perform CHANNEL CALIBRATION wi th Allowable Values as follows:

a. Loss of voltage Allowable Values

~ 2935 V and ~ 3225 Vwith a time delay of 2 +/-I seconds for LCO 3.3.S.a and LCO 3.3.5.b Functions.

b. Degraded voltage Allowable Values

~ 3720 V and ~ 3772 V with:

I. A time delay of 7.5 +/-1.S seconds with a Safety Injection (SI) signal for LCO 3.3.5.a Function; and

2. A time delay of 56 +/-7 seconds without an SI signal for LCO 3.3.5.a and LCO 3.3.S.b Functions.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.3.5-2 Amendments 262 and 243

LOP EOG Start Instrumentation 3.3.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.3.5.3 Verify ESF RESPONSE TIMES are within limit for LCO 3.3.5.a and LCO 3.3.5.b Functions.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.3.5-3 Amendments 262 and 243

MCR/ESGR Envelope Isolation Actuation Instrumentation 3.3.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.3.6.1

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

Verification of setpoint is not required.

Perform TADOT.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.3.6-2 Amendments 262 and 243

Res Pressure~ Temperature, and Flow DNB Limits 3.4.1 SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREQUENCY SR 3.4.1.1 Verify pressurizer pressure is greater than or equal to the limit specified in the COLR.

In accordance with the Survei 11 ance Frequency Control Program SR 3.4.1.2 Verify RCS average temperature is less than or equal to the limit specified in the COLR.

In accordance with the Surveillance Frequency Control Program SR 3.4.1.3 Verify RCS total flow rate is

~ 295,000 gpm and is greater than or equal to the limit specified in the COLR.

In accordance with the Surveillance Frequency Control Program SR 3.4.1.4

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

Not required to be performed until 30 days after ~ 90% RTP.

Verify by precision heat balance that ReS total flow rate is ~ 295,000 gpm and is greater than or equal to the limit specified in the COLR.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.1-2 Amendments 262 and 243

RCS Minimum Temperature for Criticality 3.4.2 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.2 RCS Minimum Temperature for Criticality LCO 3.4.2 Each ReS loop average temperature (Tavg) shall be ~ 541°F.

APPLICABILITY:

MODE 1, MODE 2 with keff ~ 1. O.

ACTIONS CONDITION REQU IRED ACTI ON COMPLETION TIME A.

Tav in one or more RC5 loops not withi n 1imi t.

A.l Be in MODE 2 with keff < 1. O.

30 minutes SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREQUENCY SR 3.4.2.1 Verify RCS Tavg in each loop ~ 541°F.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.2-1 Amendments 262 and 243

RCS PIT Limits 3.4.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.

NOTE--------

Required Action C.2 shall be completed whenever this Condition is entered.

Requirements of LCO not met any time in other than MODE 1, 2, 3, or 4.

C.l AND C.2 Initiate action to restore parameter(s) to within limits.

Determine ReS ;s acceptable for continued operation.

Immediately Prior to entering MODE 4 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.3.1

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

Only required to be performed during RCS heatup and cool down operations and RCS inservice leak and hydrostatic testing.

Verify RCS pressure, ReS temperature, and RCS heatup and cool down rates are within 1imits.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.3-2 Amendments 262 and 243

RCS Loops-MODES 1 and 2 3.4.4 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.4 RCS Loops-MODES 1 and 2 LCO 3.4.4 Three RCS loops shall be OPERABLE and in operation.

APPLICABILITY:

MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Requirements of LCO not met.

A.l Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS SU RV EI LLANCE FREQUENCY SR 3.4.4.1 Verify each RCS loop is in operation.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.4-1 Amendments 262 and 243

RCS Loops-MODE 3 3.4.5 ACTIONS CONDITION REQUIRED ACTION C.

Two required RCS loops inoperable.

OR Required RCS loop not in operation.

C.1 AND C.2 AND C.3 SURVEILLANCE REQUIREMENTS Place the Rod Control System in a condition incapable of rod withdrawal.

Suspend operations that would cause introduction into the ReS. coolant with boron concentration less than required to meet SDM of LCO 3.1.1.

Initiate action to restore one ReS loop to OPERABLE status and operation.

COMPLETION TIME Il1111ediately Il1111ediately Immediately SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify required RCS loops are in operation.

In accordance with the Surveillance Frequency Control Program SR 3.4.5.2 Verify steam generator secondary side water levels are ~ 17% for required RCS loops.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.5-2 Amendments 262 and 243

RCS Loops-MODE 3 3.4.5*

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.5.3

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

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated power are available to the required pump not in operation.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.5-3 Amendments 262 and 243

RCS Loops-MODE 4 3.4.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.

Two required inoperable.

loops OR Required loop not in operation.

B.1 AND B.2 Suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1.

Initiate action to restore one loop to OPERABLE status and operation.

Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify required RHR or RCS loop is in operation.

In accordance with the Surveillance Frequency Control Program SR 3.4.6.2 Verify SG secondary side water levels are

~ 17% for required RCS loops.

In accordance with the Surveillance Frequency Control Program SR 3.4.6.3

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

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated power are available to the required pump not in operation.

In accordance with the Surveillance Frequency Cont ro 1 Program North Anna Units 1 and 2 3.4.6-2 Amendments 262 and 243

RCS loops-MODE 5, loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS SURVEIllANCE FREQUENCY SR 3.4.7.1 Verify required RHR loop is in operation.

In accordance with the Surveillance Frequency Control Program SR 3.4.7.2 Verify SG secondary side water level is

~ 17% in required SG.

In accordance with the Surveillance Frequency Control Program SR 3.4.7.3

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

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated power are available to the required RHR pump not in operation.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.7-3 Amendments 262 and 243

RCS Loops-MODE 5, Loops Not Filled 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.

No required RHR loop OPERABLE.

OR Required RHR loop not in operation.

B.1 B.2 Suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1.

Initiate action to restore one RHR loop to OPERABLE status and*

operation.

Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify required RHR loop is in operation.

In accordance with the Surveillance Frequency Control Program SR 3.4.8.2

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

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not ;n operation.

Verify correct breaker alignment and indicated power are available to the required RHR pump not in operation.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.8-2 Amendments 262 and 243

Pressurizer 3.4.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 Verify pressurizer water level is ~ 93%.

In accordance with the Surveillance Frequency Contro1 Program SR 3.4.9.2 Verify capacity of each required group of pressurizer heaters is ~ 125 kW.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.9-2 Amendments 262 and 243

Pressurizer PORVs 3.4.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME G.

Two block valves inoperable.

G.1

NOTE--------

Required Action G.1 does not apply when block valve is inoperable solely as a result of complying with Required Action C.2.

Restore one block valve to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months H.

Required Action and associated Completion Time of Condition G not met.

H.i AND Be in MOOE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months H.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEI LLANCE SR 3.4.11.1 Verify PORV backup nitrogen supply pressure is within limit.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.11-3 Amendments 262 and 243

Pressurizer PORVs 3.4.11 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.2

NOTES--------------

1. Not requ; red to be performed with block valve closed in accordance with the Required Actions of this LCO.

2. Only required to be performed in MODES 1 and 2.

Perform a complete cycle of each block valve.

In accordance with the Surveillance Frequency Control Program SR 3.4.11.3

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

Only required to be performed in MODES 1 and 2.

Perform a complete cycle of each PORV.

In accordance with the Surveillance Frequency Control Program SR.3.4.11.4 Perform a complete cycle of each solenoid control valve and check valve on the accumulators in PORV control systems.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.11-4 Amendments 262 and 243

\\

LTDP System 3.4.12 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME G.

Two required PORVs inoperable.

Required Action and associated Completion Time of Condition A, B, D, E, or F not met.

OR LTOP System i noperab1e for any reason other than Condition At B.

C, D, E, or F.

G.1 Depressurize RCS and establish RCS vent of

~ 2.07 square inches.

In accordance with the Surveillance Frequency Control Program SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 Verify a maximum of one LHSI pump is capable of injecting into the RCS.

In accordance with the Surveillance Frequency Control Program SR 3.4.12.2 Verify a maximum of one charging pump is capable of injecting into the RCS.

In accordance with the Surveillance Frequency Control Program SR 3.4.12.3

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

Only required to be met if accumulator pressure is greater than PORV lift setting.

Verify each accumulator is isolated and power is removed from the accumulator isolation 'valve operator.

In accordance wi th the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.12-3 Amendments 262 and 243

LTOP System 3.4.12 SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREQUENCY SR 3.4.12.4 Verify required RCS vent 2 2.07 square inches open.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for unlocked open vent valve(s)

AND In accordance with the Surveillance Frequency Control Program SR 3.4.12.5 Verify PORV block valve is open for each required PORV and PORV keyswitch is in AUTO.

I n accordance wi th the Surveillance Frequency Control Program SR 3.4.12.6 Verify required PORV backup nitrogen supply pressure is within limit.

In accordance wi th the Surveillance Frequency Control Program SR 3.4.12.7

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

Not required to be met until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS cold leg temperature to :::;; 280°F.

Perform a COT on each required PORV.

excluding actuation.

I n accordance \\'Ii th the Survei 11 ance Frequency Control Program SR 3.4.12.8 Perform CHANNEL CALIBRATION for each required PORV actuation channel.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.12-4 Amendments 262 and 243

RCS Operational LEAKAGE 3.4.13 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.13.1

NN-------------NOTES------------------

1. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

2. Not applicable to primary to secondary LEAKAGE.

Verify RCS operational L.EAKAGE is within limits by performance of ReS water inventory balance.

SR 3.4.13.2

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

Verify primary to secondary LEAKAGE is

< 150 gallons per day through anyone SG.

FREQUENCY In accordance with the Surveillance Frequency Contro1 Program In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.13-2 Amendments 262 and 243

RCS PIV Leakage 3.4.14 SURVEIL~ANCE REQUIREMENTS SURVEILLANCE SR 3.4.14.1

NOTES-----------------

1. Not required to be performed in MODES 3 and 4.

2. Not required to be performed on any RCS PIVs required to be tested located in the RHR flow path when in the shutdown cooling mode of operation.

3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.

Verify leakage from each ReS PIV required to be tested is equivalent to ~ 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure

~ 2215 psig and ~ 2255 psig.

FREQUENCY In accordance with the Inservice Testing Program. and in accordance with the Surveillance Frequency Control Program AND Prior to entering MODE 2 whenever the unit has been

n MODE 5 for 7 days or more.

if 1eakage testing has not been performed in the previous 9 months Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months fo 11 owi ng valve actuation due to automatic or manual action or flow through the valve North Anna Units 1 and 2 3.4.14-2 Amendments 262 and 243

RCS Leakage Detection Instrumentation 3.4.15 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of the required containment atmosphere radioactivity monitor.

In accordance with the Surveillance Frequency Control Program SR 3.4.15.2 Perform COT of the required containment atmosphere radioactivity monitor.

In accordance with the Surveillance Frequency Control Program SR 3.4.15.3 Perform CHANNEL CALIBRATION of the required containment sump monitor.

In accordance with the Surveillance Frequency Control Program SR 3.4.15.'4 Perform CHANNEL CALIBRATION of the required containment atmosphere radioactivity monitor.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.15-3 Amendments 262 and 243

RCS Specific Activity 3.4.16 SURVEILLANCE REQUIREMENTS SR SR 3.4.16.1 3.4.16.2 SURVEILLANCE Verify reactor coolant DOSE EQUIVALENT XE 133 specific activity ~ 197 ~Ci/gm.

Verify reactor coolant DOSE EQUIVALENT 1-131 specific activity ~ 1.0 ~Ci/gm.

FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a THERMAL POWER change of

~ 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period North Anna Units 1 and 2 3.4.16-2 Amendments 262 and 243

RCS Loop Isolation Valves 3.4.17 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.17.2 Verify power removed from each Res loop isolation valve.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.4.17-2 Amendments 262 and 243

RCS Loops-Test Exceptions 3.4.19 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.19 RCS Loops-Test Exceptions LCO 3.4.19 The requirements of LCO 3.4.4, "RCS Loops-MODES 1 and 2," may be suspended, with THERMAL POWER < P-7.

APPLICABILITY:

MODES 1 and 2 during startup and PHYSICS TESTS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

THERMAL POWER 2 P-7.

A.l Open reactor trip breakers.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.19.1 Verify THERMAL POWER is < P-7.

In accordance with the Surveillance Frequency Control Program SR 3.4.19.2 Perform a COT for each power range neutron flux-low channel, intermediate range neutron flux channel, P-I0, and P-13.

Prior to i niti at; on of startup and PHYSICS TESTS SR 3.4.19.3 Perform an ACTUATION LOGIC TEST on P-7.

Prior to initiation of startup and PHYSICS TESTS North Anna Units 1 and 2 3.4.19-1 Amendments 262 and 243

Accumulators 3.5.1 SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREQUENCY SR 3.5.1.1 Verify each accumulator isolation valve is fully open.

In accordance wi th the Surveillance Frequency Control Program SR 3.5.1.2 Verify borated water volume in each accumulator is ~ 7580 gallons and

~ 7756 ga 11 ons.

In accordance wi th the Surveillance Frequency Control Program SR 3.5.1.3 Verify nitrogen cover pressure in each accumulator is ~ 599 pSig and

~ 667 psig.

In accordance with the Survei 11 ance Frequency Control Program SR 3.5.1.4 Verify boron concentration in each accumulator is ~ 2500 ppm and

<;; 2800 ppm.

In accordance with the Surveillance Frequency Control Program AND

NOTE-----

Only required to be performed for affected accumulators Once within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after each solution volume increase of ~ 50%

of i ndi cated 1 eve1 i that is not the

. result of additi on from the refuel i ng water storage tank SR 3.5.1. 5 Verify power is removed from each accumulator isolation valve operator when ReS pressure is ~ 2000 psig.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.5.1-2 Amendments 262 and 243

ECCS-Operating 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify the following valves are in the listed position with power to the valve operator removed.

Unit 1 Number Position Function 1-SI-MOV-1890A Closed 1-SI-MOV-1890B Closed 1-SI-MOV-1836 Closed 1-SI-MOV-1869A Closed 1-SI~MOV-1869B Closed Unit 2 LHSI to Hot Leg LHSI to Hot Leg HHSI Pump to Cold Leg HHSI Pump to Hot Leg HHSI Pump to Hot Leg Number Position Function 2-SI-MOV-2890A Closed 2-SI-MOV-2890B Closed 2-SI-MOV-2836 Closed 2-SI-MOV-2869A Closed 2-SI-MOV-2869B Closed LHSI to Hot Leg LHSI to Hot Leg HHSI Pump to Cold Leg HHSI Pump to Hot Leg HHSI Pump to Hot Leg In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify each ECCS manual, power operated, and automatic valve in the flow path, that is not locked, sealed. or otherwise secured in position, is in the correct position.

In accordance wi th the Surveillance Frequency Control Program SR 3.5.2.3 Verify ECCS piping is sufficiently full of water.

In accordance wi th the Surveillance Frequency Control Program SR 3.5.2.4 Verify each ECeS pump1s developed head at the test flow point is greater than or equal to the required developed head.

In accordance with the Inservice Testing Program North Anna Units 1 and 2 3.5.2-2 Amendments 262 and 243

ECCS-Operating 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE I

FREQUENCY SR 3.5.2.5 Verify each ECCS automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or' simulated actuation signal.

In accordance with i the Survei 11 ance I Frequency Control

Program SR 3.5.2.6 Verify each ECCS pump capable of starting automatically starts automatically on an actual or simulated actuation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.7 Verify each ECC5 throttle valve listed below is secured in the correct position.

Unit 1 Valve Number Unit 2 Valve Number 1-S1-188 1-51-191 I-S1-193 I-S1-203 I-S1-204 1-51-205 2-S1-89 2-51-97 2-51-103 2-51-116

2-51-111 2-51-123 In accordance with the Surveillance Frequency Control Program SR 3.5.2.8 Verify, by visual inspection, each ECCS train containment sump component ;s not restricted by debris and shows no evidence of structural distr,ess or abnormal corrosion.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.5.2-3 Amendments 262 and 243

RWST 3.5.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.4.1 Verify RWST borated water temperature is

~ 40°F and ~ 50°F.

In accordance with the Surveillance Frequency Control Program SR 3.5.4.2 Verify RWST borated water volume is

~ 466.200 gallons and ~ 487.000 gallons.

In accordance with the Surveillance Frequency Control Program SR 3.5.4.3 Verify RWST boron concentration is

~ 2600 ppm and ~ 2800 ppm.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.5.4-2 Amendments 262 and 243

Seal Injection Flow 3.5.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.5.5.1

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

Not required to be performed until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the Reactor Coolant System pressure stabilizes at ~ 2215 psig and ~ 2255 pSig.

Verify manual seal injection throttle valves are adjusted to give a flow within limit with RCS pressure ~ 2215 psig and

~ 2255 psig and the seal, injection hand control valve full open.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.5.5-2 Amendments 262 and 243

BIT 3.5.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.6.1 Verify BIT borated water temperature is 2 l1SQF.

In accordance with the Surveillance Frequency Control Program SR 3.5.6.2 Verify BIT borated water volume ;s 2 900 gallons.

In accordance with the Surveillance Frequency Control Program SR 3.5.6.3 Verify BIT boron concentration is 2 12.950 ppm and ~ 15,750 ppm.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.5.6-2 Amendments 262 and 243

Containment Air Locks 3.6.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.2.1

NOTES------------------

1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

2. Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.

Perform required air lock leakage rate testing in accordance with the Containment Leakage Rate Testing Program.

FREQUENCY In accordance with the Containment Leakage Rate Testing Program In accordance opened at a time.

SR 3.6.2.2 Verify only one door in the air lock can be with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.6.2-5 Amendments 262 and 243

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREQUENCY SR 3.6.3.1

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

Valves and blind flanges in high radiation areas may be verified by use of administrative controls.

Verify each containment isolation manual valve and blind flange that is located outside containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.

In accordance with the Surveillance Frequency Control Program SR 3.6.3.2

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

Valves and blind flanges in high radiation areas may be verified by use of administrative means.

Verify each containment isolation manual valve and blind flange that is located inside containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions ;s closed, except for containment isolation valves that are open under administrative controls.

Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days SR 3.6.3.3 Verify the isolation time of each automatic power operated containment isolation valve is within limits~

In accordance with the Inservice Testing Program SR 3.6.3.4 Perform leakage rate testing for containment purge valves with resilient seals.

Prior to entering MODE 4 from MODE 5 after containment vacuum has been broken North Anna Units 1 and 2 3.6.3-5 Amendments 262 and 243

Containment Isolation Valves 3.6.3 SURVEI LLANCE REQU IREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.5 Verify each automatic containment isolation valve that is not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

In accordance with the Surveillance Frequency Control Program SR 3.6.3.6 Cycle each weight or spring loaded check valve not testable during operation through one complete cycle of full travel, and verify each check valve remains closed when the differential pressure in the direction of flow is < 1.2 psid and opens when the differential pressure in the direction of flow is ~ 1.2 psid and < 5.0 psid.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.6.3-6 Amendments 262 and 243

Containment Pressure 3.6.4 3.6 CONTAINMENT SYSTEMS 3.6.4 Containment Pressure LCO 3.6.4 Containment air partial pressure shall be within the acceptable operation range shown on Figure 3.6.4-1.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION A.

Containment air partial pressure not within limits.

B.

Required Action and associated Completion Ti me not met.

A.1 B.1 AND B.2 REQUIRED ACTION Restore containment air partial pressure to within limits.

Be in MODE 3.

Be in MODE 5.

COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 6 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.4.1 Verify containment air partial pressure is within limits.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.6.4-1 Amendments 262 and 243

Containment Air Temperature 3.6.5 3.6 CONTAINMENT SYSTEMS 3.6.5 Containment Air Temperature LCO 3.6.5 Containment average air temperature shall be ~ 86°F and

115°F.

APPLICABILITY:

MODES 1, 2. 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Containment average air temperature not within 1imits.

A.1 Restore containment average air temperature to within 1imits.

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

Required Action and associated Completion Time not met.

B.1 AND B.2 Be in MODE 3.

Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.1 Verify containment average air temperature is within limits.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.6.5-1 Amendments 262 and 243

QS System 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Quench Spray (QS) System LCO 3.6.6 Two QS trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS A.

CONDITION One QS train inoperable.

A.1 REQUIRED ACTION Restore QS train to OPERABLE status.

COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B.

Required Action and associated Completion Ti me not met.

B.1 AND B.2 Be in MODE 3.

Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each QS manual, power operated, and automatic valve in the flow path that is not locked. sealed. or otherwise secured in position is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.6.6.2 Verify each QS pump's developed head at the flow test point is greater than or equal to the required developed head.

In accordance with the Inservice Testing Program North Anna Units 1 and 2 3.6.6-1 Amendments 262 and 243

QS System 3.6.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.3 Verify each QS automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

In accordance with the Surveillance Frequency Control Program SR 3.6.6.4 Verify each QS pump starts automatically on an actual or simulated actuation signal.

In accordance with the Surveillance Frequency Control Program SR 3.6.6.5 Verify each spray nozzle is unobstructed.

Fall OWl ng maintenance which could cause nozzle blockage North Anna Units 1 and 2 3.6.6-2 Amendments 262 and 243

RS System 3.6.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME F.

One outside RS subsystem and one inside RS subsystem

, inoperable and not in the same train.

Three or more RS subsystems inoperable.

Two outside RS subsystems inoperable.

F.l Enter LCO 3.0.3.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.7.1 Verify casing cooling tank temperature is

~ 35°F and ~ 50°F.

In accordance with the Surveillance Frequency Control Program SR 3.6.7.2 Verify casing cooling tank contained borated water volume is ~ 116,500 gal.

In accordance with the Surveillance Frequency Control Program SR 3.6.7.3 Verify casing cooling tank boron concentration is ~ 2600 ppm and ~ 2800 ppm.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 Amendments 262 and 243

RS System 3.6.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.7.4 Verify each RS and casing cooling manual.

power operated. and automatic valve in the flow path that is not locked, sealed. or otherwise secured in position is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.6.7.5 Verify each RS and casing cooling pump's developed head at the flow test point is greater than or equal to the required developed head.

In accordance with the Inservice Testing Program SR 3.6.7.6 Verify on an actual or simulated actuation signal (s):

a. Each RS automatic valve in the flow path that is not locked. sealed, or otherwise secured in position, actuates to the correct position;

b. Each RS pump starts automatically; and

c. Each casing cooling pump starts automat; ca11 y.

In accordance with the Surveillance Frequency Control Program SR 3.6.7.7 Verify. by visual inspection, each RS train containment sump component is not restricted by debris and shows no evidence of structural distress or abnormal corrosion.

In accordance with the Surveillance Frequency Control Program SR 3.6.7.8 Verify each spray nozzle is unobstructed.

Foll owing

maintenance which could cause nozzle I blockage North Anna Units 1 and 2 3.6.7-3 Amendments 262 and 243

Chemical Addition System 3.6.8 3.6 CONTAINMENT SYSTEMS 3.6.8 Chemical Addition System LCO 3.6.8 The Chemical Addition System shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Chemical Addition System inoperable.

A.l Restore Chemical Addition System to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B.

Required Action and associated Completion Time not met.

B.l AND B.2 Be in MODE 3.

Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 84 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.8.1 Verify each Chemical Addition System manual. power operated, and automatiC valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.6.8.2 Verify chemical addition tank solution volume is ~ 4800 gal and ~ 5500 gal.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.6.8-1 Amendments 262 and 243

Chemical Addition System 3.6.8 SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREQUENCY SR 3.6.8.3 Verify chemical addition tank NaOH solution concentration is ~ 12% and ~ 13% by wei ght.

In accordance with th'e Surveillance Frequency Contro1 Program SR 3.6.8.4 Verify each Chemical Addition System automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position In accordance with the Surveillance

. Frequency on an actual or simulated actuation signal.

SR 3.6.8.5 Verify Chemical Addition System flow from each solutionis flow path.

Control Program In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.6.8-2 Amendments 262 and 243

MSTVs 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1

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

Only required to be performed in MODES 1 and 2.

Verify isolation time of each MSTV is

5 seconds.

In accordance with the Inservice Testing Program SR 3.7.2.2

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

Only required to be performed in MODES 1 and 2.

Verify each MSTV actuates to the isolation position on an actual or simulated actuation signal.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.7.2-2 Amendments262 and 243

MFIVs, MFPDVs, MFRVs, and MFRBVs 3.7.3 ACTIONS CONDITION D.

One or more MFPDV inoperable.

E.

Two valves in the same flow path inoperable.

F.. Required Action and associated Completion Time not met.

0.1 AND 0.2 E.1 F.1 AND F.2 REQUIRED ACTION Close or isolate MFPDV.

Verify MFPDV is closed or isolated.

Isolate affected flow path.

Be in MODE 3.

Be in MODE 4.

COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

! Once per 7 days 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 6 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.3.1 Verify the isolation time of each MFIV, MFRV, and MFRBV is ~ 6.98 seconds and the isolation time of each MFPDV is

~ 60 seconds.

FREQUENCY In accordance with the Inservice Test; n9 Program i

SR 3.7.3.2 Verify each MFIV, MFPOV, MFRV, and MFRBV actuates to the isolation position on an actual or Simulated actuation signal.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.7.3-2 Amendments 262 and 243

SG PORVs 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Steam Generator Power Operated Relief Valves (SG PORVs)

LCO 3.7.4 Three SG PORV lines shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One required SG PORV 1ine inoperable.

A.1 Restore required SG PORV line to OPERABLE status.

7 days B.

Two or more required SG PORV lines inoperable.

B.1 Restore all but one SG PORV line to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months C.

Required Action and associated Completion Time not met.

C.1 AND C.2 Be in MODE 3.

Be in MODE 4 without reliance upon steam generator for heat removal.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 24 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify PORV.

one complete cycle of each SG In accordance with

, the Surveil 1ance I Frequency Control Program North Anna Units 1 and 2 3.7.4-1 Amendments 262 and 243

SG PORVs 3.7.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.4.2 Verify one complete cycle of each 5G PORV manua1 isolation valve.

FREQUENCY In accordance with the Surveillance Frequency Control Program Amendments 262 and 243 North Anna Units 1 and 2

AFW System 3.7.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.

Required Action and associated Completion Time for Condition A or B not met.

OR Two AFW trains inoperable in MODE 1, 2, or 3.

C.1 AND C.2 Be in MODE 3.

Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 18 hours D.

Three AFW trains inoperable in MODE 2, or 3.

1, 0.1

NOTE-------

LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore one AFW train to OPERABLE status.

Immediately E. Required AFW train inoperable in MODE 4.

E.1 Initiate action to restore AFW train to OPERABLE status.

Immediately SURVEILLANCE REQUIREMENTS FREQUENCY In accordance SR 3.7.5.1 with the Surveillance Frequency Control Program SURVEILLANCE Verify each AFW manual, power operated, and, automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump, that is not locked. sealed, or otherwise secured in position, is in the correct position.

North Anna Units 1 and 2 3.7.5-2 Amendments 262 and 243

AFW System 3.7.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.2

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

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after ~ 1005 psig in the steam generator.

Verify the developed head of each AFW pump at the flow test point is greater than or equal to the required developed head.

In accordance with the Inservice Testing Program SR 3.7.5.3 SR 3.7.5.4

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

Not applicable in MODE 4 when steam generator is relied upon for heat removal.

Verify each AFW automatic valve that is not locked, sealed. or otherwise secured in position. actuates to the correct position on an actual or simulated actuation signal.

NOTES-----------------

1. Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after ~ 1005 psig in the steam generator.

2. Not applicable in MODE 4 when steam generator is relied upon for heat removal.

Verify each AFW pump starts automatically on an actual or simulated actuation signal.

In accordance with the

. Survei 11 ance Frequency Control Program In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.7.5-3 Amendments 262 and 243

AFW System 3.7.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.5 Verify proper a1ignment of the required AFW flow paths by verifying flow from the emergency condensate storage tank to each steam generator.

Prior to enter; ng MODE 3, whenever unit has been in MODE 5, 6, or defueled for a cumulative period> 30 days North Anna Units 1 and 2 3.7.5-4 Amendments 262 and 243

ECST 3.7.6 3.7 PLANT SYSTEMS 3.7.6 Emergency Condensate Storage Tank (ECST)

LCO 3.7.6 The ECST shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

ECST inoperable.

A.l AND A.2 Verify by administrative means OPERABILITY of Condensate Storage Tank.

Restore ECST to OPERABLE status.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 7 days B.

Required Action and associated Completion Time not met.

B.1 AND Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months B.2 Be in MODE 4, without reliance on steam generator for heat removal.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify the ECST contains

.; 110,000 gal.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.7.6-1 Amendments 262 and 243

Secondary Specific Activity 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Secondary Specific Activity LCO 3.7.7 The specific activity of the secondary coolant shall be

~ 0.10 ~Ci/gm DOSE EQUIVALENT 1-131.

APPLICABILITY:

MODES 1. 2, 3. and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. 'Specific activity not withi n 1 imit.

A.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REMENTS SURVEILLANCE SR 3.7.7.1 Verify the specific activity of the secondary coolant is ~ 0.10 ~Ci/gm DOSE EQUIVALENT 1-131.

FREQUENCY In accordance with the Surveillance' Frequency Cont ro1 Program North Anna Units 1 and 2 3.7.7-1 Amendments 262 and 243

SW System 3.7.8 SURVEILLANCE REMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1

ft------NOTE------------------ft-Isolation of SW flow to individual components does not render the SW System inoperable.

Verify each SW System manual, power operated, and automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.7.8.2 Verify each SW System automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.7.8-3 Amendments 262 and 243

S\\~ System 3.7.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.8.3 Verify each SW pump starts automatically on an actual or simulated actuation signal.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.7.8-4 Amendments 262 and 243

UHS 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS)

LCO 3.7.9 The UHS shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

UHS inoperable.

A.I AND A.2 Be in MODE 3.

Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEI LLANC E FREQUENCY SR 3.7.9.1 Verify water level of the Service Water Reservoir is ~ 313 ft mean sea level.

In accordance with the Surveillance Frequency Control Program SR 3.7.9.2 Verify average water temperature of the Service Water Reservoir is ~ 95°F.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.7.9-1 Amendments 262 and 243

MCR/ESGR EVS I 3.7.10 ACTIONS CONDITION E.

(continued)

OR Two required MCR/ESGR EVS trains inoperable during movement of recently irradiated fuel assemblies for reasons other than Condition B.

F.

Two required MCR/ESGR EVS trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

F.l REQUIRED ACTION Enter LCO 3.0.3.

COMPLETION TIME Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each required MCR/ESGR EVS train for ~ 10 continuous hours with the heaters operating.

In accordance with the Surveillance Frequency Control Program SR 3.7.10.2 Perform required MCR/ESGR EVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

In accordance with VFTP SR 3.7.10.3 Not Used North Anna Units 1 and 2 3.7.10-3 Amendments 262 and 243

MCR/ESGR ACS 3.7.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E.

Less than 100% of the MCR/ESGR ACS cooling equivalent to a single OPERABLE MCR/ESGR ACS subsystem available in MODE 1, 2, 3, or 4.

E.1 Enter LCO 3.0.3.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.11.1 Verify each required MCR/ESGR ACS chiller has the capability to remove the assumed heat load.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.7.11-2 Amendments 262 and 243

Eees PREACS 3.7.12 ACTIONS CONDITION REQUIRED ACTION TION TIME D.

Two ECCS PREACS trains inoperable due to inoperable ECeS pump room boundary affecting filtration capability.

0.1.1 AND 0.1.2 AND D.1.3 OR 0.2 Verify ECCS leakage log is less than the maximum allowable unfiltered leakage.

Verify by field walkdown that ECCS leakage is less than the maximum allowable unfiltered leakage.

Restore ECCS pump room boundary to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 14 days 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months E.

Required Action and associated Completion Time not met.

E.1 AND Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months E.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.12.1 Operate each ECCS PREACS train for

~ 10 continuous hours with the heaters operating.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.7.12-4 Amendments 262 and 243

ECCS PREACS 3.7.12 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.2 Actuate each ECCS PREACS train by aligning Safeguards Area exhaust flow and Auxiliary Building Central exhaust flow through the Auxiliary Building HEPA filter and charcoal adsorber assembly.

In accordance with the Surveillance Frequency Control Program SR 3.7.12.3 Perform required ECCS PREACS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

In accordance with the VFTP SR 3.7.12.4 Verify Safeguards Area exhaust flow is diverted and each Auxiliary Building filter bank is actuated on an actual or simulated actuation signal.

In accordance with the Surveillance Frequency Control Program SR 3.7.12.5 Verify one ECCS PREACS train can maintain a negative pressure relative to adjacent areas during post accident mode of operation.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.7.12-5 Amendments 262 and 243

FBVS 3.7.15 3.7 PLANT SYSTEMS 3.7.15 Fuel Building Ventilation System (FBVS)

LCO 3.7.15 The FBVS shall be OPERABLE and in operation.

NOTE The fuel building boundary may be opened intermittently under administrative control.

APPLICABILITY:

During movement of recently irradiated fuel assemblies in the fuel building.

ACTIONS

- - - - - - - - - - - - - - - - NOTE LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A.

FBVS inoperable.

OR FBVS not in operation.

A.l Suspend movement of recently irradiated fuel assemblies in the fuel building.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.15.1 Verify the FBVS can maintain a pressure

~ -0.125 inches water gauge with respect to atmospheric pressure.

In accordance with the Survei 11 ance Frequency Control Program North Anna Units 1 and 2 3.7.15-1 Amendments 262 and 243

Fuel Storage Pool Water Level 3.7.16 3.7 PLANT SYSTEMS 3.7.16 Fuel Storage Pool Water Level LCO 3.7.16 The fuel storage pool water level shall be ~ 23 ft over the top of irradiated fuel assemb1ies seated in the storage racks.

APPLICABILITY:

During movement of irradiated fuel assemblies in the fuel storage poo1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Fuel storage pool water level not within limit.

A.l

NOTE--------

LCO 3.0.3 is not applicable.

Suspend movement of i rradi ated fuel assemblies in the fuel storage pool.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.16.1 Verify the fuel storage pool water level is

~ 23 ft above the top of the irradiated fuel assemblies seated in the storage racks.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.7.16-1 Amendments262 and 243

Fuel Storage Pool Boron Concentration 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Fuel Storage Pool Boron Concentration LCO 3.7.17 The fuel storage pool boron concentration shall be

2600 ppm.

APPLICABILITY:

When fuel assemblies are stored in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Fuel storage pool boron concentration not within limit.

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

LCO 3.0.3 is not applicable.

A.l Suspend movement of fuel assemblies in the AND A.2 fuel storage pool.

Initiate action to restore fuel storage pool boron concentration to within limit.

Immediately Immediately SURVEILLANCE REMENTS SURVEILLANCE SR 3.7.17.1 Verify the fuel storage pool boron concentration is within limit.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.7.17-1 Amendments 262 and 243

CC System 3.7.19 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.19.1 Verify each CC manual. power operated, and automatic valve in the flow path servicing the residual heat removal system, that is not locked, sealed, or otherwise secured in position, is in the correct position.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.7.19-2 Amendments 262 and 243

AC Sources-Operating 3.B.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power availability for each required offsite circuit.

In accordance with the Survei 11 ance Frequency Control Program SR 3.8.1.2

NOTES--------------

1. All EOG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

2. A modified EOG start involving idling and gradual accelerati on to synchronous speed may be used for this SR as recommended by the manufacturer. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.

Verify each required EOG starts from standby conditions and achieves steady state voltage ~ 3740 V and ~ 4580 V, and frequency ~ 59.5 Hz and ~ 60.5 Hz.

In accordance with the Surveillance Frequency Cont ro1 Program North Anna Units 1 and 2 3.8.1-8 Amendments 262 and 243

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.1.3

NOTES--------------

1. EDG loadings may include gradual loading as recommended by the manufacturer.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one EDG at a time.

4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

Verify each required EDG is synchronized In accordance and loaded and operates for ~ 60 minutes with the at a load ~ 2500 kW and ~ 2600 kW.

Surveillance Frequency Control Program SR 3.8.1.4 Verify each required day tank contains In accordance

~ 450 gal of fuel oil.

with the Surveillance Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water I In accordance from each required day tank.

with the Surveillance Frequency Control Program SR 3.8.1.6 Verify each required fuel oil transfer In accordance pump operates to transfer fuel oil from with the the storage tank to the day tank.

Surveillance Frequency Control Program North Anna Units 1 and 2 3.8.1-9 Amendments 262 and 243

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1. 7

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

All EDG starts may be preceded by an engine prelube period.

Verify each required EDG starts from standby* condition and achieves

a. In ~ 10 seconds. voltage ~ 3960 V and frequency ~ 59.5 Hz; and

b. Steady state voltage ~ 3740 V and

~ 4580 V, and frequency ~ 59.5 Hz and

~ 60.5 Hz.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.8

NOTES-------------

1. This Surveillance is only applicable to Unit 1.

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced.

Verify manual transfer of AC power sources from the normal offsite circuit to the alternate required offsite circuit.

In accordance with the Surveillance Frequency Contra1 Program North Anna Units 1 and 2 3.8.1-10 Amendments 262 and 243

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SR 3.8.1.9 SURVEILLANCE

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

If performed with EDG synchronized with offsite power, it shall be performed at a power factor ~ 0.9. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition, the power factor shall be maintained as close to the limit as practicable.

Verify each required EDG rejects a load greater than or equal to its associated single largest post-accident load, and:

a. Following load rejection, the frequency is ~ 66 Hz;

b. Within 3 seconds following load rejection, the voltage is ~ 3740 V and

~ 4580 V; and

c. Within 3 seconds following load rejection, the frequency is ~ 59.5 Hz and ~ 60.5 Hz.

FREQUENCY In accordance with the Surve'j 11 ance Frequency Control Program North Anna Units 1 and 2 3.8.1-11 Amendments 262 and 243

3.8.1 AC Sources-operating SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.1.10

NOTES--------------

1. All EDG starts may be preceded by an engine prelube period.

2. This Surveillance shall not normally be performed in MODE I, 2, 3, or 4.

However. portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced.

Verify on an actual or simulated loss of offsite power signal:

a. De-energization of emergency buses;

b. Load shedding from emergency buses;

c. Each required EDG auto-starts from standby condition and:

1. energizes permanently connected loads in s 10 seconds,

2. energizes auto-connected shutdown loads through sequencing timing

relays,

3. maintains steady state voltage

~ 3740 V and s 4580 V,

4. maintains steady state frequency

~ 59.5 Hz and ~ 60.5 Hz, and

5. supplies permanently connected and auto-connected shutdown loads for

~ 5 minutes.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2' 3.8.1-12 Amendments 262 and 243

3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.1.11

NOTES--------------

1. All EDG starts may be preceded by prelube period.

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced.

Verify on an actual or simulated Engineered Safety Feature (ESF) actuation signal each LCO 3.8.1.b EDG auto-starts from standby condition and:

a. In ~ 10 seconds after auto-start and during tests, achieves voltage

~ 3960 V and frequency ~ 59.5 Hz;

b. Achieves steady state voltage ~ 3740 V and ~ 4580 V and frequency ~ 59.5 Hz and ~ 60.5 Hz;

c. Operates for ~ 5 minutes;

d. Permanently connected loads remain energized from the offsite power system; and

e. Emergency loads are energized or auto-connected through the sequencing timing relays from the offsite power system.

FREQUENCY In accordance with the Surveillance Frequency Contra1 Program North Anna Units 1 and 2 3.8.1-13 Amendments 262 and 243

3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.1.12

~---------NOTE----------------

This Surveillance shall not normally be performed in MODE 1 or 2. However. this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced.

Verify each required EDG's automatic trips are bypassed on actual or simulated automatic start signals except:

a. Engine overspeed; and

b. Generator differential current.

FREQUENCY In accordance with the Surveillance Frequency Contra1 Program North Anna Units 1 and 2 3.8.1-14 Amendments 262 and 243

3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.B.l.13

NOTES--------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced.

3. If performed with EDG synchronized with offsite power. it shall be performed at a power factor ~ 0.9. However. if grid conditions do not permit. the power factor limit is not required to be met.

Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each required EDG operates for

~ 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months !

a. For ~ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded ~ 2900 kW and S; 3000 kW; and

b. For the remaining hours of the test loaded ~ 2500 kW and s; 2600 kW.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.B.I-15 Amendments 262 and 243

3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.14

NOTES-----------------

1. This Surveillance shall be performed within 5 minutes of shutting down the EDG after the EDG has operated

~ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded ~ 2500 kW and

~ 2600 kW or after operating temperatures have stabilized.

Momentary transients outside of load range do'not invalidate this test.

2. All EDG starts may be preceded by an engine prelube period.

Verify each required EDG starts and achieves

a. In ~ 10 seconds, voltage ~ 3960 V and frequency ~ 59.5 Hz; and

b. Steady state voltage ~ 3740 V, and

~ 4580 V and frequency ~ 59.5 Hz and

~ 60.5 Hz.

In accordance with the Surveillance Frequency Contro1 Program SR 3.8.1.15

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

This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced.

Verify each required EOG:

a. Synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power;

b. Transfers loads to offsite power source; and

c. Returns to ready-to-load.operation.

In accordance with the Surveil 1 ance Frequency Control Program North Anna Units 1 and 2 3.8.1-16 Amendments 262 and 243

3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.1.16 -------------------NOTE------------------

This Surveillance shall not normally be performed in MODE 1. 2. 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced.

Verify each required sequencing timing relay is within the design tolerance.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.8.1-17 Amendments 262 and 243

3.B.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.B.1.17 ------------------NOTES------------------

1. All EDG starts may be preceded by an engine prelube period.

2. This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4.

However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced.

Verify on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ESF actuation signal:

a. De-energization of emergency buses;

b. Load shedding from emergency buses; and

c. Each LeO 3.8.1.b EDG auto-starts from standby condition and:

1. energizes permanently connected loads in ~ 10 seconds,

2. energizes auto-connected emergency loads through load sequencing timing

relays,

3. achieves steady state voltage

~ 3740 V and ~ 4580 V,

4. achieves steady state frequency

~ 59.5 Hz and ~ 60.5 Hz. and

5. supplies permanently connected and auto-connected emergency loads for

~ 5 minutes.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.8.1-18 Amendments 262 and 243

3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS SURVEI LLANCE SR 3.8.1.18

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

All EDG starts may be preceded by an engine prelube period.

~--------------------------

Verify when started simultaneously from standby condition. each LCO 3.B.1.b EDG achieves:

a. in $ 10 seconds, voltage ~ 3960 V and frequency ~ 59.5 Hz; and

b. steady state voltage~ 3740 V and

$ 4580 V, and frequency ~ 59.5 Hz and

$ 60.5 Hz.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.8.1-19 Amendments 262 and 243

Diesel Fuel Oil and Starting Air 3.8.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME F.

Required Action and associated Completion Time not met.

One or more EDGs diesel fuel oil or starting air subsystem not within limits for reasons other than Condition A, B, C, 0, or E.

F.l Declare associated EDG(s) inoperable.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify fuel oil inventory ~ 90,000 gal.

In accordance

wi th the Surveillance Frequency Control Program SR 3.8.3.2 Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.

In accordance wi th the Oi ese1 Fuel Oil Testing Program SR 3.8.3.3 Verify each EOG air start receiver pressure is ~ 175 psig.

In accordance with the Surveillance Frequency Control Program SR 3.8.3.4 Check for and remove accumulated water from each stored fuel oil storage tank.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.8.3-3 Amendments 262 and 243

DC Sources-Operating 3.8.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D.

NOTE---------

Separate Condition entry is allowed for each DC subsystem.

One or more required LCO 3.8.4.c DC electrical power subsystem(s) inoperable.

0.1 Declare associated shared component{s) inoperable.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE I

FREQUENCY SR 3.8.4.1 Verify for each required Station and EOG battery, terminal voltage is ~ 129 V on float charge.

In accordance with the Surveillance Frequency Control Program SR 3.8.4.2 Verify for each required Station and EDG battery, there is no visible corrosion at battery terminals and connectors.

OR Verify battery connection resistance is

~ 1.5E-4 ohm for inter-cell connections.

~ 1.5E-4 ohm for inter-rack connections.

~ 1.5E-4 ohm for inter-tier connections.

and ~ 1.5E-4 ohm for terminal conn~ctions.

In accordance with the Surveillance Frequency Control Program SR 3.8.4.3 Verify for each required Station and EDG battery, cells, cell plates, and racks show no visual indication of physical damage or abnormal deterioration that could degrade battery performance.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.8.4-2 Amendments 262 and 243

3.8.4 DC Sources-Operating SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREQUENCY SR 3.8.4.4 For. each required Station and EDG battery, remove visible terminal corrosion, verify battery cell to cell and terminal connections are clean and coated with anti-corrosion material.

In accordance with the Surveillance Frequency Control Program SR 3.8.4.5 Verify for each required Station and EDG battery, connection resistance is

~ 1.5E-4 ohm for inter-cell connections,

~ 1.5E-4 ohm for inter-rack connections,

~ 1.5E-4 ohm for inter-tier connections, and ~ 1.5E-4 ohm for terminal connections.

In accordance with the Surveil 1ance Frequency Control Program SR 3.8.4.6 Verify each required Station battery charger supplies ~ 270 amps at ~ 125 V for ~ 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

In accordance with the Surveillance Frequency Control Program SR 3.8.4.7 Verify each required EDG battery charger supplies ~ 10 amps at ~ 125 V for

~ 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

In accordance with the Survei 11 ance Frequency Control Program North Anna Units 1 and 2 3.8.4-3 Amendments 262 and 243

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.4.8

NOTES-------------

1. The modified performance discharge test in SR 3.8.4.9 may be performed in lieu of the service test in SR 3.8.4.8.

2. The performance discharge test in SR 3.8.4.9 may be performed in lieu of the service test in SR 3.8.4.8.

3. This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4.

However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced.

Verify for each required Station battery.

capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.8.4-4 Amendments 262 and 243

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.4.9

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

This Surveillance shall not normally be performed in MODE 1, 2, 3~ or 4 for Station batteries. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced.

Verify for each required Station and EOG battery~ capacity is ~ 80% of the manufacturer's rating when subjected to a performance discharge test or a modified performance discharge test.

FREQUENCY In accordance with the Surveillance Frequency Control Program 18 months when battery shows degradation or has reached 85%

of expected life North Anna Units 1 and 2 3.8.4-5 Amendments 262 and 243

Battery Cell Parameters 3.8.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.3 i

Restore battery cell parameters to Table 3.8.6-1 Category A and B limits.

31 days B.

Required Action and associated Completion Time of Condition A not met.

OR One or more Station batteries with average electrolyte temperature of the representative cells

< 60°F.

OR One or more Station or EDG batteries with one or more battery cell parameters not within Table 3.8.6-1 Category C values.

B.1 Declare associated battery inoperable.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.6.1 Verify for each required Station and EDG battery cell parameters meet Table 3.8.6-1 Category A limits.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.8.6-2 Amendments 262 and 243

Battery Cell Parameters 3.8.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.2 Verify for each required Station and EDG battery cell parameters meet Table 3.8.6-1 Category B limits.

In accordance with the Surveil 1ance Frequency Control Program AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a battery discharge

< 110 V Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a battery overcharge

> 150 V SR 3.8.6.3 Verify average electrolyte temperature of representative cells for each required Station battery ;s ~ 60°F.

I n accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.8.6-3 Amendments 262 and 243

Inverters-Operating 3.8.7 ACTIONS CONDITION B.

One or more inverters required by LCO 3.B.7.b inoperable.

B.1 REQUIRED ACTION

NOTE-------

Enter applicable Conditions and Required Actions of LCO 3.8.9, 1I0istribution Systems-Operating" with any vital bus de-energized.

COMPLETION TIME Declare associated shared components inoperable.

7 days C.

Required Action and associated Completion Time of Condition A not met.

C.l AND C.2 Be in MODE 3.

Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.7.1 Verify correct inverter voltage and alignment to required AC vital buses.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.8.7-2 Amendments 262 and 243

Inverters-Shutdown 3.B.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.8.1 Verify correct inverter voltage and alignments to required AC vital buses.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.8.8-2 Amendments 262 and 243

Distribution Systems-Operating 3.8.9 ACTIONS F.

CONDITION

NOTE---------

Separate Condition entry is allowed for each AC vital subsystem.

One or more required LCO 3.B.9.b AC vital electrical power distribution subsystem{s) inoperable.

'F.!

REQUIRED ACTION Declare associated shared components inoperable.

COMPLETION TIME Immediately G.

Required Action and associated Completion Time for Condition At B, or C not met.

G.!

AND G.2 Be in MODE 3.

Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours H.

Two or more LCO 3.B.g.a electrical power distribution subsystems inoperable that result in a loss of safety function.

H.!

Enter LCO 3.0.3.

Immediately SURVEILLANCE REMENTS SURVEI lLANCE SR 3.B.9.1 Verify correct breaker alignments and voltage to required AC, DC, and AC vital bus electrical power distribution subsystems.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.8.9-3 Amendments 262 and 243

Distribution Systems-Shutdown 3.8.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(conti nued)

A.2.4 Initiate actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

Immediately A.2.5 Declare associated required residual heat removal subsystem(s) inoperable and not in operation.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.10.1 Verify correct breaker alignments and voltage to required AC, DC, and AC vital bus electrical power distribution subsystems.

FREQUENCY In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.8.10-2 Amendments 262 and 243

Boron Concentration 3.9.1 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 Boron concentrations of the Reactor Coolant System (RCS), the refueling canal, and the refueling cavity shall be maintained within the limit specified in the COLR.

APPLICABILITY:

MODE 6.

- - NOTE - - - - - - - -

Only applicable to the refueling canal and refueling cavity when connected to the RCS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Boron concentration not within limit.

A.l Suspend CORE ALTERATIONS.

Immediately AND A.2 Suspend positive reactivity additions.

Immediately AND A.3 Initiate action to restore boron concentration to within limit.

Immediately SURVEILLANCE IREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 Verify boron concentration is within the limit specified in the COLR.

In accordan ce wi th the Surveillance Frequency Control Program North Anna Units 1 and 2 3.9.1-1 Amendments 262 and 243

Nuclear Instrumentation 3.9.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.9.3.2

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

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.9.3-2 Amendments 262 and 243

Containment Penetrations 3.9.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.4.1 Verify each required containment penetration ;s in the required status.

In accordance with the Surveillance Frequency Control Program SR 3.9.4.2

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

Not required to be met for containment purge and exhaust valve(s) in penetrations closed to comp1y with LCO 3.9.4.c.1.

Verify each required containment purge and exhaust valve actuates to the isolation position on manual initiation.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 Amendments 262 and 243

RHR and Coolant Circulation-High Water Level 3.9.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(conti nued)

A.4 AND Close equipment hatch and secure with four bolts.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months A.S Close one door in each installed air lock.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months A.6.1 Close each penetration providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months A.6.2 Verify each penetration is capable of being closed by an OPERABLE Contaoi nment Purge and Exhaust Isolation System.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SURVEI LLANCE IREMENTS SURVEILLANCE SR 3.9.5.1 Verify one RHR loop is in operation and circulating reactor coolant at a flow rate of ;:?! 3000 gpm.

FREQUENCY In accordance with the Survei 11 ance Frequency Control Program North Anna Units 1 and 2 3.9.5-2 Amendments 262 and 243

RHR and Coolant Circulation-Low Water Level 3.9.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.

(continued)

B.5.2 Verify each penetration is capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify one RHR loop is in operation and circulating reactor coolant at a flow rate of:

a. ~ 3000 gpm. or

b. ~ 2000 gpm if RCS temperature S 140°F and time since entry into MODE 3

~ 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months .

In accordance with the Surveil 1ance Frequency Control Program SR 3.9.6.2

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

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required RHR pump is not in operation.

Verify correct breaker alignment and indicated power available to the required RHR pump that is not in operation.

In accordance with the Surveillance Frequency Control Program North Anna Units 1 and 2 3.9.6-3 Amendments 262 and 243

Refueling Cavity Water Level 3.9.7 3.9 REFUELING OPERATIONS 3.9.7 Refueling Cavity Water Level LCO 3.9.7 Refueling cavity water level shall be maintained ~ 23 ft above the top of reactor vessel flange.

APPLICABILITY:

During movement of irradiated fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Refueling cavity water 1evel not within 1imit.

A.l Suspend movement of i rradi ated fuel assemblies within containment.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.7.1 Verify refueling cavity water 1evel is

~ 23 ft above the top of reactor vessel flange.

FREQUENCY In accordance with the Surveillance

Frequency Control Program North Anna Units 1 and 2 3.9.7-1 Amendments 262 and 243

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.16

e. The quantitative limits on unfiltered air inleakage into the MCR/ESGR envelope. These limits shall be stated 1n a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of design basis accident consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of MCR/ESGR envelope occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing MCR/ESGR envelope habitability, determining MCR/ESGR envelope unfiltered inleakage, and measuring MCR/ESGR envelope pressure and assessing the MCR/ESGR envelope boundary as required by paragraphs c and d, respectively.

5.5.17 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specification are performed at interval sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequenci es of those Survei 11 ance Requi rements for whi c,h the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, IIRisk-Informed Method for Control of Surveillance Frequenc1es,1I Rev; s1 on 1.

c. The provisions of Surveillance ReqUirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

North Anna Units 1 and 2 5.5-17 Amendments 262 and 243

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 262 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-4 AND AMENDMENT NO. 243 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION. UNITS 1 AND 2 DOCKET NOS. 50-338 AND 50-339

1.0 INTRODUCTION

By application dated March 30, 2010 (Agencywide Documents Access and Management System (ADAMS), Accession Nos. ML100900162, ML100900163, ML100900167), as supplemented by letters dated August 30, 2010 (ADAMS Accession No. ML102430462) and January 18, 2011 (ADAMS Accession No. ML110200451), Virginia Electric and Power Company (the licensee) submitted a request for changes to the North Anna Power Station, Unit Nos. 1 and 2 (NAPS 1 and 2), Technical Specifications (TSs). The requested change is to relocate specific surveillance frequencies to a licensee-controlled program with the implementation of Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies." The changes are consistent with NRC-approved Industry Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) change TSTF-425, Revision 3. The supplemental letter provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC, the Commission) staff's original proposed no significant hazard consideration determination.

This safety evaluation (SE) documents the NRC staff's review of the impact of the proposed TS changes specifically address when implemented, TSTF-425 relocates most periodic frequencies of TS surveillances to a licensee controlled program, the Surveillance Frequency Control Program (SFCP), and provides requirements for the new program in the Administrative Controls section of the TS. All surveillance frequencies can be relocated except:

Frequencies that reference other approved programs for the specific interval (such as the In-Service Testing Program or the Primary Containment Leakage Rate Testing Program);

Frequencies that are purely event-driven {e.g., "each time the control rod is withdrawn to

- 2 the 'full out' position");

Frequencies that are event-driven, but have a time component for performing the surveillance on a one-time basis once the event occurs (e.g., "within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after thermal power reaching;;:: 95% RTP [rated thermal power]"); and Frequencies that are related to specific conditions (e.g., battery degradation, age and capacity) or conditions for the performance of a surveillance requirement (e.g., "drywell to suppression chamber differential pressure decrease").

A new program is added to the Administrative Controls of TS Section 5 as Specification 5.5.17.

The new program is called the SFCP and describes the requirements for the program to control changes to the relocated surveillance frequencies. The TS Bases for each of the affected surveillance requirements are revised to state that the frequency is set in accordance with the SFCP. Some surveillance requirements Bases do not contain a discussion of the frequency. In these cases, the Bases describing the current frequency were added to maintain consistency with the Bases for similar surveillances. These instances are noted in the markup along with the source of the text. The proposed licensee changes to the Administrative Controls of the TS to incorporate the SFCP include a specific reference to Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specifications Initiative 5B, Risk-Informed Method for Control of Surveillance Frequencies," Revision 1, as the basis for making any changes to the surveillance frequencies once they are relocated out of the TS.

In a letter dated September 19, 2007, the NRC staff approved NEI 04-10, Revision 1 (ADAMS Accession No. ML072570267), as acceptable for referencing in licensing actions to the extent specified and under the limitations delineated in NEI 04-10, and the SE providing the basis for NRC acceptance of NEI 04-10.

2.0 REGULATORY EVALUATION

In the "Final Policy Statement: Technical Specifications for Nuclear Power Plants" published in the Federal Register (FR) (58 FR 39132, published July 22, 1993), the NRC addressed the use of Probabilistic Safety Analysis (PSA), currently referred to as Probabilistic Risk Assessment (PRA) in STS. In this 1993 FR publication, the NRC states, in part:

'The Commission believes that it would be inappropriate at this time to allow requirements which meet one ormore ofthe first three criteria [of 10 CFR 50.36] to be deleted from technical specifications based solely on PSA (Criterion 4).

However, if the results ofPSA indicate that technical specifications can be relaxed or removed, a deterministic review will be performed. "

"The Commission Policy in this regard is consistent with its Policy Statement on

'Safety Goals for the operation of Nuclear Power Plants,' 51 FR 30028, published on August 21, 1986. The Policy Statement on Safety Goals states in part, probabilistic results should also be reasonably balanced and supported through use of deterministic arguments. In this way, judgments can be made about the degree ofconfidence to be given these [probabilistic] estimates and assumptions.

This is a key part of the process for determining the degree ofregulatory conservatism that may be warranted for particular decisions. This

'defense-in-depth' approach is expected to continue to ensure the protection of public health and safety. "

- 3

'The Commission will continue to use PSA, consistent with its policy on Safety Goals, as a tool in evaluating specific line item improvements to Technical Specifications, new requirements, and industry proposals for risk-based Technical Specification changes. "

Approximately 2 years later the NRC provided additional detail concerning the use of PRA in the "Final Policy Statement: Use of Probabilistic Risk Assessment in Nuclear Regulatory Activities" published in the Federal Register (60 FR 42622, August 16,1995). In this FR publication, the NRC states, in part:

"The Commission believes that an overall policy on the use of PRA methods in nuclear regulatory activities should be established so that the many potential applications of PRA can be implemented in a consistent and predictable manner that would promote regulatory stability and efficiency. In addition, the Commission believes that the use of PRA technology in NRC regulatory activities should be increased 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. "

"PRA addresses a broad spectrum of initiating events by assessing the event frequency. Mitigating system reliability is then assessed, including the potential for multiple and common-cause failures. The treatment, therefore, goes beyond the single failure requirements in the deterministic approach. The probabilistic approach to regulation is, therefore, considered an extension and enhancement of traditional regulation by conSidering risk in a more coherent and complete manner. "

'Therefore, the Commission believes that an overall policy on the use ofPRA in nuclear regulatory activities should be established so that the many potential applications of PRA can be implemented in a consistent and predictable manner that promotes regulatory stability and efficiency. This policy statement sets forth the Commission's intention to encourage the use of PRA and to expand the scope of PRA applications in aI/ nuclear regulatory matters to the extent supported by the state-of-the-art in terms ofmethods and data. "

'Therefore, the Commission adopts the fol/owing policy statement regarding the expanded NRC use ofPRA:

(1)

The use of PRA technology should be increased in aI/ 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.

(2)

PRA and associated analyses (e.g., sensitivity studies, uncertainty analyses, and importance measures) should be used in regulatory matters, where practical within the bounds of the state-of-the-art, to reduce unnecessary conseNatism associated with current regulatory requirements, regulatory guides, license commitments, and staff practices. Where appropriate, PRA should be used to support the proposal for additional regulatory requirements in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.109 (Backfit Rule). Appropriate procedures for including PRA in the process should be developed and followed. It is, of course, understood that the intent of this policy is that existing rules and regulations shall be complied with unless these rules and regulations are

-4 revised.

(3)

PRA evaluations in support ofregulatory decisions should be as realistic as practicable and appropriate supporting data should be publicly available for review.

(4)

The Commission's safety goals for nuclear power plants and subsidiary numerical objectives are to be used with appropriate consideration of uncertainties in making regulatory judgments on the need for proposing and backfitting new generic requirements on nuclear powerplant licensees. "

In 10 CFR 50.36, the NRC established its regulatory requirements related to the content of TSs.

Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.

As stated in 10 CFR 50.36(c)(3), "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality ofsystems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." These categories will remain in the TSs. The new TS SFCP provides the necessary administrative controls to require that surveillance frequencies relocated to the SFCP are conducted at a frequency to assure that the necessary quality of systems and components are maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. Changes to surveillance frequencies in the SFCP are made using the methodology contained in NEI 04-10, including qualitative considerations, results of risk analyses, sensitivity studies and any bounding analyses, and recommended monitoring of structures, systems, and components (SSCs), and required to be documented. Furthermore, changes to frequencies are subject to regulatory review and oversight of the SFCP implementation through the rigorous NRC review of safety-related SSC performance provided by the reactor oversight program.

Licensees are required by TS to perform surveillance test, calibration, or inspection on specific safety-related system equipment (e.g., reactivity control, power distribution, electrical, and instrumentation) to verify system operability. Surveillance frequencies, currently identified in TSs, are based primarily upon deterministic methods such as engineering jUdgment, operating experience, and manufacturer's recommendations. The licensee's use of NRC-approved methodologies identified in NEI 04-10 provides a way to establish risk-informed surveillance frequencies that complement the deterministic approach and support the NRC's traditional defense-in-depth philosophy.

The licensee's SFCP ensures that surveillance requirements specified in the TSs are performed at intervals sufficient to assure the above regulatory requirements are met. Existing regulatory requirements, such as 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and 10 CFR 50, Appendix B (corrective action program),

require licensee monitoring of surveillance test failures and implementing corrective actions to address such failures. One of these actions may be to consider increasing the frequency at which a surveillance test is performed. In addition, the SFCP implementation guidance in NEI 04-10 requires monitoring the performance of SSCs for which surveillance frequencies are decreased to assure reduced testing does not adversely impact the SSCs. These requirements, and the monitoring required by NEI 04-10, ensure that surveillance frequencies are sufficient to assure that the requirements of 10 CFR 50.36 are satisfied and that any performance deficiencies will be identified and appropriate corrective actions taken.

- 5 Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," describes a risk-informed approach, acceptable to the NRC, for assessing the nature and impact of proposed permanent licensing-basis changes by considering engineering issues and applying risk insights. This RG also provides risk acceptance guidelines for evaluating the results of such evaluations.

In RG 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," it describes an acceptable risk-informed approach specifically for assessing proposed permanent TS changes.

In RG 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," it describes an acceptable approach for determining whether the quality of the PRA, in total or the parts that are used to support an application, is sufficient to provide confidence in the results, such that the PRA can be used in regulatory decision making for light water-reactors.

3.0 TECHNICAL EVALUATION

The licensee's adoption of TSTF-425 for NAPS provides for administrative relocation of applicable surveillance frequencies, and provides for the addition of the SFCP to the administrative controls of TS. TSTF-425 also requires the application of NEI 04-10 for any changes to surveillance frequencies within the SFCP. The licensee's application for the changes proposed in TSTF--425 included documentation regarding the PRA technical adequacy consistent with the requirements of RG 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 1. In accordance with NEI 04-10 PRA methods are used, in combination with plant performance data and other considerations, to identify and justify modifications to the surveillance frequencies of equipment at nuclear power plants. This is in accordance with guidance provided in RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," and RG 1.177 in support of changes to surveillance test intervals.

3.1 RG 1.177 Five Key Safety Principles In RG 1.177 it identifies five key safety principles required for risk-informed changes to TSs. Each of these principles is addressed by the industry methodology document, NEI 04-10.

3.1.1 The Proposed Change Meets Current Regulations In 10 CFR 50.36(c)(3) it provides that TSs will include surveillances which are "requirements relating to test, calibration, or inspection to assure that necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." In NEI 04-10 it provides guidance for relocating the surveillance frequencies from the TSs to a licensee-controlled program by providing an NRC-approved methodology for control of the surveillance frequencies. The surveillance category remains in the TSs, as required by 10 CFR 50.36(c)(3).

-6 This change is consistent with other NRC-approved TS changes in which the surveillance frequencies are relocated to licensee-controlled documents, such as surveillances performed in accordance with the In-service Testing Program or the Primary Containment Leakage Rate Testing Program. Thus, this proposed change meets the first key safety principle of RG 1.177 by complying with current regulations.

3.1.2 The Proposed Change Is Consistent With the Defense-in-Depth Philosophy Consistency with the defense-in-depth philosophy, the second key safety principle of RG 1.177, 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). Because the scope of the proposed methodology is limited to revision of surveillance frequencies, the redundancy, independence, and diversity of plant systems are not impacted.

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.

In TSTF-425, it requires the application of NEI 04-10 for any changes to surveillance frequencies within the SFCP. In NEI 04-10 it uses both the core damage frequency (CDF) and the large early release frequency (LERF) metrics to evaluate the impact of proposed changes to surveillance frequencies. The guidance of RG 1.174 and RG 1.177 for changes to CDF and LERF is achieved by evaluation using a comprehensive risk analysis, which assesses the impact of proposed changes including contributions from human errors and common cause failures.

Defense-in-depth is also included in the methodology explicitly as a qualitative consideration outside of the risk analysis, as is the potential impact on detection of component degradation that could lead to an increased likelihood of common cause failures. Both the quantitative risk analysis and the qualitative considerations assure a reasonable balance of defense-in-depth is maintained to ensure protection of public health and safety, satisfying the second key safety principle of RG 1.177.

3.1.3 The Proposed Change Maintains Sufficient Safety Margins The engineering evaluation that will be conducted by the licensee under the SFCP when frequencies are revised will assess the impact of the proposed frequency change with the principle that sufficient safety margins are maintained. The guidelines used for making that assessment will include ensuring the proposed surveillance test frequency change is not in conflict with approved industry codes and standards or adversely affects any assumptions or inputs to the safety analysis, or, if such inputs are affected, justification is provided to ensure

- 7 sufficient safety margin will continue to exist.

The design, operation, testing methods, and acceptance criteria for SSCs, specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plant licensing basis (including the Updated Final Safety Analysis Report and bases to TS), since these are not affected by changes to the surveillance frequencies. Similarly, there is no impact to safety analysis acceptance criteria as described in the plant licensing basis.

Thus, safety margins are maintained by the proposed methodology, and the third key safety principle of RG 1.177 is satisfied.

3.1.4 When Proposed Changes Result in an Increase in Core Damage Frequency or Risk, the Increases Should Be Small and Consistent With the Intent of the Commission's Safety Goal Policy Statement In RG 1.177 it provides a framework for evaluating the risk impact of proposed changes to surveillance frequencies. This requires the identification of the risk contribution from impacted surveillances, determination of the risk impact from the change to the proposed surveillance frequency, and performance of sensitivity and uncertainty evaluations. TSTF-425 requires application of NEI 04-10 in the SFCP. In NEI 04-10 it satisfies the intent of RG 1.177 requirements for evaluating the change in risk, and for assuring that such changes are small.

3.1.4.1 Quality of the PRA The quality of the NAPS PRA is compatible with the safety implications of the proposed TS change and the role the PRA plays in justifying the change. That is, the more the potential change in risk or the greater the uncertainty in that risk from the requested TS change, or both, the more rigor that must go into ensuring the quality of the PRA.

The licensee used RG 1.200 to address the technical adequacy of the NAPS PRA. RG 1.200 is NRC's developed regulatory guidance, which endorses with comments and qualifications the use of the American Society of Mechanical Engineers (ASME) RA-Sb-2005, "Addenda to ASME RA-S-002 Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications," NEI 00-02, "PRA Peer Review Process Guidelines," and NEI 05-04, "Process for Performing Follow-On PRA Peer Reviews Using the ASME PRA Standard." The licensee has performed an assessment of the PRA models used to support the SFCP against the requirements of RG 1.200 to assure that the PRA models are capable of determining the change in risk due to changes to surveillance frequencies of SSCs, using plant-specific data and models. Capability category II of ASME RA-Sb-2005 is applied as the standard, and any identified deficiencies to those requirements are assessed further to determine any impacts to proposed decreases to surveillance frequencies, including by the use of sensitivity studies where appropriate.

The NRC staff reviewed the licensee's assessment of the NAPS PRA and the remaining open deficiencies that do not conform to capability category II of the ASME PRA standard (Table 1 of of the license amendment request, as modified by a response to the NRC staffs request for additional information). The NRC staffs assessment of the remaining open "gaps," to assure that they may be addressed and dispositioned for each surveillance frequency evaluation per the NEI 04-10 methodology, is provided below.

Gap #1:

The model for anticipated transient without scram (A TWS) uses a conservative unfavorable exposure time. The licensee identified that this conservative simplification assumes that pressure relief capacity is always insufficient, and that ATWS will be assessed in sensitivity studies when required. The NRC staff

Gap#2:

Gap #3:

Gap #4:

Gap #5:

Gap #6:

Gap #7:

Gap #8:

Gap #9:

Gap #10:

- 8 concurs that assuming a conservative exposure time can be addressed per the methodology of NEI 04-10.

Support system initiating events fault tree include a multiplier which should be replaced with the newer methodology of Electric Power and Research Institute (EPRI) EPRI-TR-1013490, "Support System Initiating Events: Identification and Quantification Guideline." The licensee identified that this gap is important for changes involving the support systems and will be addressed using the EPRI methodology. The NRC staff concurs that this deficiency can be addressed per the methodology of NEI 04-10.

Operator action to restore Emergency Core Cooling System functions for station blackout is not addressed and the documentation does not reflect this required action. The licensee identified the impact as being a small nonconservatism and that a sensitivity analysis would include consideration of this human action. The NRC staff concurs that this deficiency can be addressed per the methodology of NEI04-10.

Consequential loss of reactor coolant pump seal cooling is not included in the model. Since this failure mode would require concurrent failure of two separate systems, the licensee stated that the impact should be comparable or lower than consequential pressurizer power-operated relief valve failures, which are modeled.

Sensitivity analyses will include consideration of this failure mode. The NRC staff concurs that this deficiency can be addressed per the methodology of NEI 04-10 by additional logic models when required.

Electrical bus cross-tie unavailability is not modeled. Additional modeling of this capability will be made to address the gap with sensitivity studies, and therefore the NRC staff concurs that this deficiency can be addressed per the methodology of NEI04-10.

Success criteria involving operator response is not discussed. The licensee identified this as a documentation issue, and therefore the NRC staff concurs that this deficiency can be addressed per the methodology of NEI 04-10.

Inadvertent safety injection actuation is not addressed in the PRA model. The licensee has identified that this deficiency has been addressed subsequent to the submittal to add this initiator and therefore this gap no longer exists. Therefore, the NRC staff finds this action acceptable.

No formal documentation of plant walkdowns and interviews with plant personnel.

The licensee has identified this as a documentation issue and therefore the NRC staff concurs that this deficiency can be addressed per the methodology of NEI04-10.

The PRA model does not distinguish between water relief and steam relief for pressurizer power-operated relief valves failure to reclose failure mode. The guidance of EPRI-1 011 047 will be used to develop sensitivity models. Therefore, the NRC staff concurs that this deficiency can be addressed per the methodology of NEI 04-10.

Time windows for successful completion of operator actions need to be updated.

The licensee identified similarities with other PRA models based on plant-specific analyses, and identified that a sensitivity study using a factor of two for the

- 9 probability offailure of the action would be used. Therefore, the NRC staff concurs that this deficiency can be addressed per the methodology of NEI 04-10.

Gap#11:

Required action times are based on similar actions for other PRA models rather than on time measurements from walkthroughs or simulator scenarios. The licensee does not expect any significant changes based on comparisons with other PRA models, and considers this to be a documentation issue. The NRC staff concurs that this deficiency can be addressed per the methodology of NEI 04-10.

Gaps #12, #13, #14, #15, #16: Deficiencies in documentation of human errors, key assumptions and key sources of uncertainty were identified. The NRC staff concurs that these deficiencies in documentation can be addressed per the methodology of NEI04-10.

Gap #17:

A realistic evaluation of secondary side isolation capability for steam generator tube releases is required. The licensee identified that additional steam generator relief valve demands are not considered, and that a more realistic model will be developed to support sensitivity studies. The NRC staff concurs that this deficiency can be addressed per the methodology of NEI 04-10.

Based on the licensee's assessment using the applicable PRA standard and RG 1.200, the level of PRA quality, combined with the proposed evaluation and disposition of gaps, is sufficient to support the evaluation of changes proposed to surveillance frequencies within the SFCP, and is consistent with Regulatory Position 2.3.1 of RG 1.177.

3.1.4.2 Scope of the PRA The licensee is required to evaluate each proposed change to a relocated surveillance frequency using the guidance contained in NEI 04-10 to determine its potential impact on risk, due to impacts from internal events, fires, seismic, other external events, and from shutdown conditions.

Consideration is made of both CDF and LERF metrics. In cases where a PRA of sufficient scope or where quantitative risk models were unavailable, the licensee uses bounding analyses, or other conservative quantitative evaluations. A qualitative screening analysis may be used when the surveillance frequency impact on plant risk is shown to be negligible or zero.

The individual plant examination of external events (IPEEE) fire-induced vulnerability evaluation analysis, and the IPEEE seismic margins analysis, will be used to provide insights for fires and seismic events. Other external hazards were screened during the IPEEE assessment, and will therefore be qualitatively assessed for this application.

The licensee's evaluation methodology is sufficient to ensure the scope of the risk contribution of each surveillance frequency change is properly identified for evaluation, and is consistent with Regulatory Position 2.3.2 of RG 1.177.

3.1.4.3 PRA Modeling The licensee will determine whether the SSCs affected by a proposed change to a surveillance frequency are modeled in the PRA. Where the SSC is directly or implicitly modeled, a quantitative evaluation of the risk impact may be carried out. The methodology adjusts the failure probability of the impacted SSCs, including any impacted common cause failure modes, based on the proposed change to the surveillance frequency. Where the SSC is not modeled in the PRA, bounding analyses are performed to characterize the impact of the proposed change to the

- 10 surveillance frequency. Potential impacts on the risk analyses due to screening criteria and truncation levels are addressed by the requirements for PRA technical adequacy consistent with guidance contained in RG 1.200, and by sensitivity studies identified in NEI 04-10.

The licensee will perform quantitative evaluations of the impact of selected testing strategy (Le.,

staggered testing or sequential testing) consistently with the guidance of NUREG/CR-6141 and NUREG/CR-5497, as discussed in NEI 04-10.

Thus, through the application of NEI 04-10 the NAPS PRA modeling is sufficient to ensure an acceptable evaluation of risk for the proposed changes in surveillance frequency, and is consistent with Regulatory Position 2.3.3 of RG 1.177.

3.1.4.4 Assumptions for Time-Related Failure Contributions The failure probabilities of SSCs modeled in the NAPS PRA include a standby time-related contribution and a cyclic demand-related contribution. The NEI 04-10 criterion adjusts the time-related failure contribution of SSCs affected by the proposed change to surveillance frequency. This is consistent with RG 1.177, Section 2.3.3, which permits separation of the failure rate contributions into demand and standby for evaluation of surveillance requirements. If the available data does not support distinguishing between the time-related failures and demand failures, then the change to surveillance frequency is conservatively assumed to impact the total failure probability of the SSC, including both standby and demand contributions. The SSC failure rate (per unit time) is assumed to be unaffected by the change in test frequency, and will be confirmed by the required monitoring and feedback implemented after the change in surveillance frequency is implemented. The process requires consideration of qualitative sources of information with regards to potential impacts of test frequency on SSC performance, including industry and plant-specific operating experience, vendor recommendations, industry standards, and code-specified test intervals. Thus, the process is not reliant upon risk analyses as the sole basis for the proposed changes.

The potential beneficial risk impacts of reduced surveillance frequency, including reduced downtime, lesser potential for restoration errors, reduction of potential for test caused transients, and reduced test-caused wear of equipment, are identified qualitatively, but are conservatively not required to be quantitatively assessed. Thus, through the application of NEt 04-10, the licensee has employed reasonable assumptions with regard to extensions of surveillance test intervals, and is consistent with Regulatory Position 2.3.4 of RG 1.177.

3.1.4.5 Sensitivity and Uncertainty Analyses In NEI 04-10 it requires sensitivity studies to assess the impact of uncertainties from key assumptions of the PRA, uncertainty in the failure probabilities of the affected SSCs, impact to the frequency of initiating events, and of any identified deviations from capability category II of ASME PRA Standard (ASME RA-Sb-2005). Where the sensitivity analyses identify a potential impact on the proposed change, revised surveillance frequencies are considered, along with any qualitative considerations that may bear on the results of such sensitivity studies. Required monitoring and feedback of SSC performance once the revised surveillance frequencies are implemented will also be performed. Thus, through the application of NEI 04-10, the licensee has appropriately considered the possible impact of PRA model uncertainty and sensitivity to key assumptions and model limitations, and is consistent with regulatory position 2.3.5 of RG 1.177.

3.1.4.6 Acceptance Guidelines The licensee will quantitatively evaluate the change in total risk (including internal and external

~ 11 events contributions) in terms of CDF and LERF for both the individual risk impact of a proposed change in surveillance frequency and the cumulative impact from all individual changes to surveillance frequencies using the guidance contained in NRC-approved NEI 04-10 in accordance with the TS SFCP. Each individual change to surveillance frequency must show a risk impact below 1 E~6 per year for change to CDF, and below 1 E~7 per year for change to LERF.

These are consistent with the limits of RG 1.174 for very small changes in risk. Where the RG 1.174 limits are not met, the process either considers revised surveillance frequencies which are consistent with RG 1.174 or the process terminates without permitting the proposed changes.

Where quantitative results are unavailable to permit comparison to acceptance guidelines, appropriate qualitative analyses are required to demonstrate that the associated risk impact of a proposed change to surveillance frequency is negligible or zero. Otherwise, bounding quantitative analyses are required which demonstrate the risk impact is at least one order of magnitude lower than the RG 1.174 acceptance guidelines for very small changes in risk. In addition to assessing each individual SSC surveillance frequency change, the cumulative impact of all changes must result in a risk impact below 1 E-S per year for change to CDF, and below 1 E-6 per year for change to LERF. The total CDF and total LERF must be reasonably shown to be less than 1 E-4 per year and 1 E~S per year, respectively. These are consistent with the limits of RG 1.174 for acceptable changes in risk, as referenced by RG 1.177 for changes to surveillance frequencies. The NRC staff interprets this assessment of cumulative risk as a requirement to calculate the change in risk from a baseline model utilizing failure probabilities based on the surveillance frequencies prior to implementation of the SFCP, compared to a revised model with failure probabilities based on changed surveillance frequencies. The NRC staff further notes that the licensee includes a provision to exclude the contribution to cumulative risk from individual changes to surveillance frequencies associated with insignificant risk increases (less than SE-8 CDF and SE-9 LERF) once the baseline PRA models are updated to include the effects of the revised surveillance frequencies.

The quantitative acceptance guidance of RG 1.174 is supplemented by qualitative information to evaluate the proposed changes to surveillance frequencies, including industry and plant-specific operating experience, vendor recommendations, industry standards, the results of sensitivity studies, and SSC performance data and test history.

The final acceptability of the proposed change is based on all of these considerations and not solely on the PRA results compared to numerical acceptance guidelines. Post implementation performance monitoring and feedback are also required to assure continued reliability of the components. The licensee's application of NEI 04-10 provides reasonable acceptance guidelines and methods for evaluating the risk increase of proposed changes to surveillance frequencies, consistent with Regulatory Position 2.4 of RG 1.177. Therefore, the proposed methodology satisfies the fourth key safety principle of RG 1.177 by assuring any increase in risk is small consistent with the intent of the Commission's Safety Goal Policy Statement.

3.1.S The Impact of the Proposed Change Should Be Monitored Using Performance Measurement Strategies The licensee's adoption of TSTF-42S requires application of NEI 04-10 in the SFCP. In NEI 04-10 it requires performance monitoring of SSCs whose surveillance frequency has been revised as part of a feedback process to assure that the change in test frequency has not resulted in degradation of equipment performance and operational safety. The monitoring and feedback includes consideration of maintenance rule monitoring of equipment performance. In the event of degradation of SSC performance, the surveillance frequency will be reassessed in accordance with the methodology, in addition to any corrective actions which may apply as part of the

- 12 maintenance rule requirements. The performance monitoring and feedback specified in NE 04-10 is sufficient to reasonably assure acceptable SSC performance and is consistent with regulatory position 3.2 of RG 1.177. Thus, the fifth key safety principle of RG 1.177 is satisfied.

3.2 Addition of Surveillance Frequency Control Program to Administrative Controls The licensee has included the SFCP and specific requirements into the Administrative Controls, TS Section 5.5.17, Surveillance Frequency Control Program, as follows:

This program provides controls for SUNeillance Frequencies. The program shall ensure that SUNeiJIance Requirements specified in the Technical Specifications are performed at inteNals sufficient to assure that the associated Limiting Conditions for Operation are met.

a. The SUNeillance Frequency Control Program shall contain a list ofFrequencies of the SUNeillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the SUNeillance Frequency Control Program shall be made in accordance with NEI04-10, "Risk-Informed Method for Control of SUNeiJIance Frequencies, " Revision 1.

c. The provisions of SUNeillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the SUNeil/ance Frequency Control Program.

The proposed program is consistent with the model application of TSTF-425, and is therefore acceptable.

3.3 Summary The NRC staff has reviewed the licensee's proposed relocation of some surveillance frequencies to a licensee controlled document, and controlling changes to surveillance frequencies in accordance with a new program, the SFCP, identified in the administrative controls of TS. The SFCP and TS Section 5.5.17 references NEI 04-10, which provides a risk-informed methodology using plant-specific risk insights and performance data to revise surveillance frequencies within the SFCP. This methodology supports relocating surveillance frequencies from TS to a licensee-controlled document, provided those frequencies are changed in accordance with NEI 04-10 which is specified in the Administrative Controls of the TS.

The proposed licensee adoption of TSTF-425 and risk-informed methodology of NEI 04-10 as referenced in the Administrative Controls of TS, satisfies the key principles of risk-informed decision making applied to changes to TS as delineated in RG 1.177 and RG 1.174, in that:

The proposed change meets current regulations; The proposed change is consistent with defense-in-depth philosophy; The proposed change maintains sufficient safety margins; Increases in risk resulting from the proposed change are small and consistent with the Commission's Safety Goal Policy Statement; and The impact of the proposed change is monitored with performance measurement strategies.

In 10 CFR 50.36(c)(3) it states "[Technical specifications will include items in the following categories:] Surveillance Requirements. Surveillance Requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is

- 13 maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The NRC staff finds that with the proposed relocation of surveillance frequencies to an owner-controlled document and administratively controlled in accordance with the TS SFCP, the licensee continues to meet the regulatory requirement of 10 CFR 50.36, and, specifically, 10 CFR 50.36(c)(3), surveillance requirements.

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

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Virginia State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of facility components within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards considerations, and there has been no public comment on such finding (75 FR 27833).

Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22{c)(9). Pursuant to 10 CFR 51.22{b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The license amendment request proposes TS changes that will revise the TSs by relocating specific surveillance frequencies to a licensee-controlled program with the implementation of NEI 04-10, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies." The changes are consistent with NRC-approved Industry TSTF Standard Technical Specifications change TSTF-425, Revision 3.

The NRC staff finds that with the proposed relocation of surveillance frequencies to an owner-controlled document and administratively controlled in accordance with the TS SFCP, the licensee continues to meet the regulatory requirement of 10 CFR 50.36, and specifically, 10 CFR 50.36(c)(3), surveillance requirements.

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

Principal Contributors: Andrew Howe, NRRIDRA Date of Issuance: January 31, 2011

ML103140657

SE input by memo dated 9-24-2010 OFFICE LPL2-1/PM LPL2-1/LA DRAlAPLAlBC DIRS/ITSB/BC NAME IVSreenivas MO'Brien DHarrison*

RElliott SRohrer for)

~11/10/10 11/15/10 09/24/2010 11/17/10 OGC LPL2-1/BC LPL2-1/PM DRoth NLO GKulesa

!VSreenivas 11/29/10 1128111 1/31/11

v t e Letter Sequence Approval
TAC:ME3689, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Approved, Closed) TAC:ME3690, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers 30 August 2010 Results Approval Other:
MONTHYEAR2011-01-18 [Table View]

ML103140657

Text

SUBJECT:

Dear Mr. Heacock:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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