Text

Issuance of Amendment Adoption of Technical Specifications Task Force Traveler (TSTF-425) to Relocate Specific Surveillance Frequencies to a Licensee-Controlled Program
	ML120110282
Person / Time
Site:	Duane Arnold
Issue date:	02/24/2012
From:	Beltz T; Plant Licensing Branch III
To:	Wells P; NextEra Energy Duane Arnold
	Feintuch K, NRR/DORL/LPL3-1, 415-3079
References
	TAC ME5744
	Download: ML120110282 (139)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001

'~~ebruary 24, 2012 Mr. Peter Wells Vice President Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324-9785

SUBJECT:

DUANE ARNOLD ENERGY CENTER - ISSUANCE OF AMENDMENT RE:

ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER (TSTF-425) TO RELOCATE SPECIFIC SURVEILLANCE FREQUENCIES TO A LICENSEE-CONTROLLED PROGRAM (TAC NO. ME5744)

Dear Mr. Wells:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 280 to Renewed Facility Operating License No. DPR-49 for the Duane Arnold Energy Center. This amendment consists of changes to the Technical Specifications (TSs) and Renewed Facility Operating License in response to your application letter dated February 23, 2011, as supplemented by letters dated April 20, 2011; August 15, 2011; November 1, 2011; and February 3, 2012.

The amendment revises the TSs by relocating specific surveillance frequencies to a licensee controlled program, the Surveillance Frequency Control Program, based on Nuclear Regulatory Commission-approved TS Task Force (TSTF) TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF [Risk-Informed TSTF] Initiative 5b."

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

Sincerely, Terry A. Beltz, Senior Project Manager Plant licenSing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-331

Enclosures:

1. Amendment No. 280 to License No. DPR-49

2. Safety Evaluation cc wlencls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NEXTERA ENERGY DUANE ARNOLD, LLC DOCKET NO. 50-331 DUANE ARNOLD ENERGY CENTER AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 280 Renewed License No. DPR-49

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that A.

The application for amendment by NextEra Energy Duane Arnold, LLC dated February 23, 2011, as supplemented by letters dated April 20, 2011; August 15, 2011; November 1, 2011; and February 3, 2012, 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 Oi) 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 the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-49 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 280, are hereby incorporated in the license. NextEra Energy Duane Arnold, LLC 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 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Shawn A. Williams, Acting Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Attachments: Changes to the License and Technical Specifications Date of Issuance:

February 24, 2012

ATTACHMENT TO LICENSE AMENDMENT NO. 280 RENEWED FACILITY OPERATING LICENSE NO. DPR-49 DOCKET NO. 50-331 Replace the following page of Renewed Facility Operating License No. DPR-49 with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert 3

3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages as indicated. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert Remove Insert 1.1-6 1.1-6 3.3-23 3.3-23 3.1-10 3.1-10 3.3-25 3.3-25 3.1-17 3.1-17 3.3-26 3.3-26 3.1-19 3.1-19 3.3-28 3.3-28 3.1-21 3.1-21 3.3-29 3.3-29 3.1-22 3.1-22 3.3-31 3.3-31 3.1-26 3.1-26 3.3-39 3.3-39 3.2-1 3.2-1 3.3-40 3.3-40 3.2-2 3.2-2 3.3-48 3.3-48 3.3-3 3.3-3 3.3-55 3.3-55 3.3-4 3.3-4 3.3-56 3.3-56 3.3-5 3.3-5 3.3-64 3.3-64 3.3-6 3.3-6 3.3-67 3.3-67 3.3-12 3.3-12 3.3-68 3.3-68 3.3-13 3.3-13 3.3-71 3.3-71 3.3-17 3.3-17 3.3-74 3.3-74 3.3-18 3.3-18 3.3-77 3.3-77 3.3-19 3.3-19 3.4-3 3.4-3

- 2 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages as indicated. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert Remove Insert 3.4-5 3.4-5 3.6-26 3.6-26 3.4-7 3.4-7 3.6-27 3.6-27 3.4-9 3.4-9 3.6-29 3.6-29 3.4-12 3.4-12 3.6-31 3.6-31 3.4-14 3.4-14 3.6-34 3.6-34 3.4-17 3.4-17 3.6-36 3.6-36 3.4-19 3.4-19 3.6-40 3.6-40 3.4-21 3.4-21 3.6-43 3.6-43 3.4-23 3.4-23 3.7-2 3.7-2 3.4-25 3.4-25 3.7-4 3.7-4 3.5-4 3.5-4 3.7-6 3.7-6 3.5-5 3.5-5 3.7-9 3.7-9 3.5-6 3.5-6 3.7-10 3.7-10 3.5-7 3.5-7 3.7-13 3.7-13 3.5-9 3.5-9 3.7-15 3.7-15 3.5-10 3.5-10 3.7-17 3.7-17 3.5-11 3.5-11 3.7-18 3.7-18 3.5-13 3.5-13 3.7-20 3.7-20 3.5-14 3.5-14 3.8-5 3.8-5 3.6-2 3.6-2 3.8-6 3.8-6 3.6-7 3.6-7 3.8-7 3.8-7 3.6-13 3.6-13 3.8-8 3.8-8 3.6-14 3.6-14 3.8-9 3.8-9 3.6-16 3.6-16 3.8-10 3.8-10 3.6-18 3.6-18 3.8-16 3.8-16 3.6-20 3.6-20 3.8-18 3.8-18 3.6-21 3.6-21 3.8-19 3.8-19 3.6-23 3.6-23 3.8-20 3.8-20

- 3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages as indicated. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert Remove Insert 3.8-25 3.8-25 3.10-5 3.10-5 3.8-29 3.8-29 3.10-8 3.10-8 3.8-31 3.8-31 3.10-11 3.10-11 3.9-2 3.9-2 3.10-12 3.10-12 3.9-3 3.9-3 3.10-14 3.10-14 3.9-4 3.9-4 3.10-15 3.10-15 3.9-5 3.9-5 3.10-17 3.10-17 3.9-8 3.9-8 3.10-22 3.10-22 3.9-9 3.9-9 3.10-23 3.10-23 3.9-12 3.9-12 5.0-18a 5.0-18a 3.9-15 3.9-15 5.8-18b

- 3 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 50.54 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 NextEra Energy Duane Arnold, LLC is authorized to operate the Duane Arnold Energy Center at steady state reactor core power levels not in excess of 1912 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix At as revised through Amendment No. 280, are hereby incorporated in the license. NextEra Energy Duane Arnold, LLC shall operate the facility in accordance with the Technical Specifications.

(a) For Surveillance Requirements (SRs) whose acceptance criteria are modified, either directly or indirectly, by the increase in authorized maximum power level in 2.C.(1) above, in accordance with Amendment No. 243 to Facility Operating License DPR-49, those SRs are not required to be performed until their next scheduled performance, which is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment No. 243.

(b) Deleted.

(3) Fire Protection NextEra Energy Duane Arnold, LLC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the Duane Arnold Energy Center and as approved in the SER dated June 1, 1978. and Supplement dated February 10, 1981, subject to the following provision:

NextEra Energy Duane Arnold, LLC may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(4) The licensee is authorized to operate the Duane Arnold Energy Center following installation of modified safe-ends on the eight primary recirculation system inlet lines which are described in the licensee letter dated July 31,1978. and supplemented by letter dated December 8. 1978.

(5) Physical Protection NextEra Energy Duane Arnold, LLC shall fully implement and maintain in effect all provisions of the Commission-approved phYSical security. training and qualification, Renewed License No. DPR-49 Amendment 280

Definitions 1.1 1.1 Definitions (continued)

SHUTDOWN MARGIN (SDM)

SDM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical assuming that:

a.

The reactor is xenon free;

b.

The moderator temperature is 68°F (20°C); and

'c.

All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn with the core in its most reactive state during the operating cycle.

With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.

(continued)

DAEC 1.1-6 Amendment 280

Control Rod OPERABILITY 3,1,3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1,3.1 Determine the position of each control rod.

In accordance with the Surveillance Frequency Control Program SR 3.1.3.2

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

Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than 20% RTP.

Insert each withdrawn control rod at least one notch.

I n accordance with the Surveillance Frequency Control Program SR 3.1.3.3 Verify each control rod scram time from fully withdrawn to notch position 04 is s 7 seconds.

In accordance with SR 3.1.4.1 and SR 3.1.4.2 SR 3.1.3.4 Verify each withdrawn control rod does not go to the withdrawn overtravel position.

Each time the control rod is withd rawn to "fu II out" position Prior to declaring control rod OPERABLE after work on control rod or CRD System that could affect coupling (continued)

DAEC 3.1-10 Amendment 280

Control Rod Scram Accumulators 3.1.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

One or more control rod scram accumulators inoperable with reactor steam dome pressure

< 900 psig.

C.1 AND C.2 Verify all control rods associated with inoperable accumulators are fully inserted.

Declare the associated control rod inoperable.

Immediately upon qiscovery of charging water header pressure

< 940 psig 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months D.

Required Action and associated Completion Time of Required Action B.1 or C.1 not met.

D. 1

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

Not applicable if all inoperable control rod scram accumulators are associated with fully inserted control rods.

Place the reactor mode switch in the Shutdown position.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify each control rod scram accumulator In accordance with pressure is ~ 940 psig.

Ithe Surveillance Frequency Control Program

DAEC 3.1-17 Amendment 280

Rod Pattern Control 3.1.6 ACTIONS (continued)

CONDITION REQUIRED ACTION I COMPLETION TIME B. Nine or more OPERABLE control rods not in compliance with BPWS.

B.1 B.2

N 0 T E ------------

Rod Worth Minirnizer (RWM) may be bypassed as allowed by LCO 3.3.2.1.

Suspend withdrawal of control rods.

Place the reactor mode switch in the Shutdown position.

Immediately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 Verify all OPERABLE control rods comply with BPWS.

I In accordance with the Surveillance Frequency Control Program DAEC 3.1-19 Amendment 280

SLC System 3.1.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 Verify available volume of sodium pentaborate solution is within the. limits of Figure 3.1.7-1, In accordance with the Surveillance Frequency Control I Program SR 3,1.7,2 Verify temperature of sodium penta borate solution is within the limits of Figure 3,1,7-2.

In accordance with the Surveillance Frequency Control Program SR 3,1.7.3 Verify temperature of pump suction piping is within the limits of Figure 3.1.7-2.

In accordance with the Surveillance Frequency Control Program SR 3.1.7.4 Verify continuity of explosive charge.

In accordance with the Surveillance

. Frequency Control Program SR 3.1.7.5 Verify the concentration of boron in solution is within the limits of Figure 3.1.7-1.

In accordance with the Surveillance Frequency Control Program Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after water or boron is added to solution Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after solution temperature is restored within the limits of Figure 3,1,7-2 (continued)

DAEC 3.1-21 Amendment 280

SLC System 3.1.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.7.6 Verify each pump develops a flow rate lin accordance with

? 26.2 gpm at a discharge pressure? 1150

! the Inservice psig.

ITesting Program SR 3.1.7.7 Verify flow through one SLC subsystem from In accordance with pump into reactor pressure vessel.

the Surveillance Frequency Control Program SR 3.1.7.8 Verify all heat traced piping between storage I n accordance with tank and pump suction is unblocked.

the Surveillance Frequency Control Program AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after solution temperature is restored within the limits of Figure 3 1 7 2 1

DAEC 3.1-22 Amendment 280

3.1.8 SDV Vent and Drain Valves SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.8.1

~()TE-------------------------

~ot required to be met on vent and drain valves closed during the performance of SR 3.1.8.2.

Verify each SDV vent and drain valve is open.

In accordance with the Surveillance Frequency Control Program SR 3.1.8.2 Cycle each SDV vent and drain valve to the fully closed and fully open position.

In accordance with the Inservice Testing Program SR 3.1.8.3 Verify each SDV vent and drain valve:

a.

Closes in s 30 seconds after receipt of an actual or simulated scram signal; and

b.

()pens when the actual or simulated scram signal is reset.

I n accordance with the Surveillance Frequency Control Program DAEC 3.1-26 Amendment 280

3.2.1 APLHGR 3.2 POWER DISTRIBUTION LIMITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

LCO 3.2.1 All APLHGRs shall be less than or equal to the limits specified in the COLR.

APPLICABILITY:

THERMAL POWER c 21.7% RTP.

ACTIONS A.

CONDITION Any APLHGR not within limits.

A.1 REQUIRED ACTION COMPLETION TIME Restore APLHGR(s) to

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

B.

Required Action and associated Completion B.1 Reduce THERMAL POWER to < 21.7%

.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Time not met SURVEILLANCE REQUIREMENTS RTP.

SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify all APLHGRs are less than or equal to the limits specified in the COLR.

Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after

~ 21.7% RTP In accordance with the Surveillance Frequency Control I Program DAEC 3.2-1 Amendment 280

MCPR 3.2.2 3.2 POWER DISTRIBUTION LIMITS 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR)

LCO 3.2.2 All MCPRs shall be greater than or equal to the MCPR operating limits specified in the COLR.

APPLICABILITY:

THERMAL POWER ~ 21.7% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Any MCPR not within limits.

A.1 Restore MCPR(s) to within limits.

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

Required Action and associated Completion Time not met.

B.1 Reduce THERMAL POWER to < 21.7%

RTP.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Verify all MCPRs are greater than or equal to the limits specified in the COLR.

Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after

~ 21.7% RTP AND In accordance with the Surveillance I Frequency Control Program (continued)

DAEC 3.2-2 Amendment 280

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS

N()TE~--------------------------------------------------

1. Refer to Table 3.3.1.1-1 to determine which ~Rs apply for each RPS Function.

2. When a channel is placed in an inoperable status solely for performance of required ~urveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains RPS trip capability.

SURVEILLANCE FREQUENCY SR 3.3.1.1.1 Perform CHANNEL CHECK.

In accordance with the i Surveillance Frequency Control Program SR 3.3.1.1.2

N()TE-----------------------------

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::2:: 21.7% RTP.

Verify the absolute difference between the Average Power Range Monitor (APRM)

In accordance with the Surveillance Frequency channels and the calculated power is

Control Program

2% RTP plus any gain adjustment required by LCO 3.4.1, ~Recirculation Loops Operating," while operating at

: 2:: 21.7% RTP.

SR 3.3.1.1.3 Perform a functional test of each In accordance with the automatic scram contactor.

Surveillance Frequency Control Program SR 3.3.1.1.4

N()TE-----------------------------

Not required to be performed when entering' M()OE 2 from M()OE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering M()OE 2.

Perform CHANNEL FUNCTI()NAL TEST.

in accordance with the Surveillance Frequency lI Control Program (continued)

DAEC 3.3-3 Amendment 280

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.5 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.6 Verify the Source Range Monitor (SRM) and Intermediate Range Monitor (IRM) channels overlap.

Prior to withdrawing SRMs from the fully inserted position SR 3.3.1.1.7

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

Only required to be met during entry into MODE 2 from MODE 1.

Verify the IRM and APRM channels overlap.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.8 Calibrate the local power range monitors.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.9 Perform CHANNEL FUNCTIONAL TEST.

I n accordance with the Surveillance Frequency Control Program SR 3.3.1.1.10 Calibrate the trip units.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.11 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program (continued)

DAEC 3.3-4 Amendment 280

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.3.1.1.12

N()TE:S--------------------------

1.

Neutron detectors are excluded.

2.

For Function 2.a, not required to be performed when entering M()OE 2 from M()OE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering M()OE 2.

Perform CHANNEL CALIBRATI()N.

FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.13 Perform CHANNEL FUNCTI()NAL TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.14

N ()-rE S-------------------------

1.

Neutron detectors are excluded.

2.

For Function 1, not required to be performed when entering M()OE 2 from M()OE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering M()OE 2.

Perform CHANNEL CALIBRATI()N.

SR 3.3.1.1.15 Perform L()GIC SYSTE:M FUNCTI()NAL TEST.

SR 3.3.1.1.16 Verify Turbine Stop Valve-Closure and Turbine Control Valve Fast Closure, Trip ()il Pressure - Low Functions are not bypassed when THERMAL P()WER is

> 26% RTP.

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency I Control Program in accordance with the Surveillance Frequency Control Program (continued)

OAEC 3.3-5 Amendment 280

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.17 Adjust the channel to conform to a calibrated In accordance with the flow signal.

Surveillance Frequency I Control Program SR 3.3.1.1.18 Verify the RPS RESPONSE TIME is within limits.

SR 3.3.1.1.19 Verify the RPS logic system response time is within limits.

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program DAEC 3.3-6 Amendment 280

SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS

N()lrE-------------------------------------------------------

Refer to Table 3.3.1.2-1 to determine which SRs apply for each applicable M()DE or other specified conditions.

SURVEILLANCE FREQUENCY SR 3.3.1.2.1 Perform CHANNEL CHECK.

In accordance with

the Surveillance Frequency Control Program SR 3.3.1.2.2

N()TES-------------------------

1.

()nly required to be met during C()RE AL lrERATI()NS.

2.

()ne SRM may be used to satisfy more than one of the following.

Verify an ()PERABLE SRM detector is located in :

a.

The fueled region;

b.

The core quadrant where C()RE ALTERATI()NS are being performed, when the associated SRM is included in the fueled region; and

c.

A core quadrant adjacent to where CORE ALTERATIONS are being performed, when the associated SRM is included in the fueled region.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.2.3 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program (continued)

DAEC 3.3-12 Amendment 280

SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY S R 3.3. 1.2.4

NOTE -----------------------.;----

Not required to be met with less than or equal to four fuel assemblies adjacent to the SRM and no other fuel assemblies in the associated core quadrant.

In accordance with Verify count rate is ~ 3.0 cps.

the Surveillance Frequency Control Program I n accordance with the Surveillance Frequency Control

. Program SR 3.3.1.2.5 Perform CHANNEL FUNCTIONAL TEST.

S R 3.3. 1.2.6

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after IRMs on Range 2 or below.

In accordance with the Surveillance Frequency Control Program Perform CHANNEL FUNCTIONAL TEST.

S R 3.3. 1.2.7

NOT E S----------------------------

1. Neutron detectors are excluded.

2. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after IRMs on Range 2 or below.

In accordance with Perform CHANNEL CALIBRATION.

the Surveillance Frequency Control I Program DAEC 3.3-13 Amendment 280

Control Rod Block Instrumentation 3.3.2.1 ACTIONS (continued)

CONDITION REQUIRED ACTION I

COMPLETION TIME E.

One or more Reactor Mode Switch Shutdown Position channels inoperable.

E.1 AND E.2 Suspend control rod withd rawa I.

Immediately Initiate action to fully Immediately insert all insertable control rods in core cells containing one or more fuel assemblies.

SURVEILLANCE REQUIREMENTS

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

i. Refer to Table 3.3.2.1-1 to determine which SRs apply for each Control Rod Block Function.

2. When an RBM channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains control rod block capability.

SURVEILLANCE FREQUENCY SR 3.3.2.1.1 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program

( continued)

DAEC 3.3-17 Amendment 280

Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.1.2

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

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after anycontrol rod is withdrawn at

s; 10% RTP in MODE 2.

Perform CHANNEL FUNCTIONAL TEST.

SR 3.3.2.1.3

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

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after THERMAL POWER is:s; 10 % RTP in MODE 1.

Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control IProgram SR 3.3.2.1.4

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

Neutron detectors are excluded.

Verify the RBM:

a. Low Power Range -- Upscale Function is not bypassed when THERMAL POWER is 2:: 29% and < 64% RTP.

b. Intermediate Power Range -- Upscale Function is not bypassed when THERMAL POWER is 2:: 64% and < 84% RTP.

c. High Power Range -- Upscale Function is not bypassed when THERMAL POWER is 2:: 84% RTP.

In accordance with the Surveillance Frequency Control Program (continued)

DAEC 3.3-18 Amendment 280

Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.1.5

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

Neutron detectors are excluded.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.6

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

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after reactor mode switch is in the shutdown position.

Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control

. Program SR 3.3.2.1.7 Verify control rod sequences input to the RWM Prior to declaring

'are in conformance with BPWS.

RWM OPERABLE following loading of seq uence into RWM DAEC 3.3-19 Amendment 280

PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS

N()TE--------------------------------------------------------

These SRs apply to each Function in Table 3.3.3.1-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.3.1.2 Perform CHANNEL CALIBRATI()N.

In accordance with the Surveillance Frequency Control Program DAEC 3.3-23 Amendment 280

Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 The Remote Shutdown System Functions shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2.

ACTIONS

~--------------------------------------------------~OTE---------------------------------------------------

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION I COMPLETION TIME A.

One or more required Functions inoperable.

A.1 Restore required Function to OPERABLE status.

30 days B.

Required Action and associated Completion Time not met.

8.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.2.1 Verify each required control circuit and transfer switch is capable of performing the intended function.

In accordance with the Surveillance Frequency Control I Program

( continued)

DAEC 3.3-25 Amendment 280

Remote Shutdown System SURVEILLANCE REQUIREMENTS continued)

SURVEILLANCE SR 3.3.3.2.2 Perform CHANNEL CALIBRATION for each required instrumentation channel.

3.3.3.2 FREQUENCY In accordance with the Surveillance Frequency Control*

Program DAEC 3.3-26 Amendment 280

EOC-RPT Instrumentation 3.3.4.1 ACTIONS (continued)

CONDITION REQUIRED ACTION I

COMPLETION TIME B.

One or more Functions with EOC-RPT trip capability not maintained.

B.1 OR Restore EOC-RPT trip capability.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND MCPR limit for inoperable EOC-RPT not made applicable.

B.2 Apply the MCPR limit for inoperable EOC-RPT as specified in the COLR.

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

Required Action and associated Completion Time not met.

C.1 OR C.2 Remove the associated recircluation pump from service.

Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months POWER to < 26%

RTP.

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

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

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains EOC-RPT trip capability.

SURVEILLANCE FREQUENCY SR 3.3.4.1.1 Perform CHANNEL FUNCTIONAL TEST.

In accordance with I the Surveillance

. Frequency Control Program (continued)

DAEC 3.3-28 Amendment 280

EOC-RPT Instrumentation 3.3.4.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.4.1.2 Perform CHANNEL CALIBRATION. The Allowable Values shall be:

TSV - Closure: s 10% closed; and TCV Fast Closure, Trip Oil Pressure - Low:

~ 465 psig.

In accordance with the Surveillance Frequency Control Program SR 3.3.4.1.3 Perform LOGIC SYSTEM FUNCTIONAL TEST including breaker actuation.

In accordance with the Surveillance Frequency Control Program SR 3.3.4.1.4 Verify TSV - Closure and TCV Fast Closure, Trip Oil Pressure - Low Functions are not bypassed when THERMAL POWER is ~ 26 %

RTP.

In accordance with the Surveillance Frequency Control Program SR 3.3.4.1.5 Verify the EOC-RPT SYSTEM RESPONSE TIME.is within limits.

In accordance with the Surveillance Frequency Control Program DAEC 3.3-29 Amendment 280

A TWS-RPT Instrumentation 3.3.4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.4.2.1 SR 3.3.4.2.2 SR 3.3.4.2.3 Perform CHANNEL CHECK on the Reactor Vessel Water Level - Low Low Function.

Perform CHANNEL FUNCTIONAL TEST.

Perform CHANNEL CALIBRATION. The Allowable Values shall be:

a.

Reactor Vessel Water Level-Low Low 2 112.65 inches; and

b.

Reactor Steam Dome Pressure - High:

1154.2 psig.

I n accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program I n accordance with the Surveillance Frequency Control Program SR 3.3.4.2.4 Perform LOGIC SYSTEM FUNCTIONAL I n accordance with TEST including breaker actuation.

the Surveillance Frequency Control

. Program DAEC 3.3-31 Amendment 280

ECCS Instrumentation 3.3.S.1 SURVEILLANCE REQUIREMENTS

N()TES---------------------------------------------------

i. Refer to Table 3.3.S.1-1 to determine which SRs apply for each ECCS Function.

2.

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1.d, 2.f, 3.c, 3.d, 3.e, and 3.f; and (b) for up to 6 hpurs for Functions other than 1.d, 2.f, 3.c, 3.d, 3.e, and 3,f provided the associated Function (or the redundant Function for Functions 4 andS) maintains ECCS initiation or loop selection capability.

SURVEILLANCE FREQUENCY SR 3.3.S.1.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.S.1.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.S.1.3 Perform CHANNEL FUNCTIONAL In accordance with TEST.

the Surveillance Frequency Control Program SR 3.3.S.1.4 Perform CHANNEL CALIBRATION.

SR 3.3.S.1.S Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (contin ued)

DAEC 3.3-39 Amendment 280

ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.5.1.6 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance

! Frequency Control Program SR 3.3.5.1.7 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.8 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.9 Perform LOGIC SYSTEM FUNCTIONAL TEST.

I In accordance with the Surveillance Frequencx Control Program DAEC 3.3-40 Amendment 280

RCIC System Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

~OTES--------------------------------------------------

1.

Refer to Table 3.3.5.2-1 to determine which SRs apply for each RelC Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 2 and 3; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 1 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.3 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control

Program SR 3.3.5.2.4 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.5 Perform LOGIC SYSTEM FUNCTIONAL In accordance with TEST.

the Surveillance Frequency Control Program I

DAEC 3.3-48 Amendment 280

Primary Containment Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS

N()TES-----------------------------------------------------

1.

Refer to Table 3.3.6.1-1 to determine which SRs apply for each Primary Containment Isolation Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 5.a; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions other than 5.a provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control

Program SR 3.3.6.1.2 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control

Program SR 3.3.6.1.3 Perform CHANNEL FUNCTI()NAL TEST.

In accordance with the Surveillance.

Frequency Control Program SR 3.3.6.1.4 Perform CHANNEL FUNCTI()NAL TEST.

In accordance with the Surveillance Frequency Control

Pro ram SR 3.3.6.1.5 Perform CHANNEL CALIBRATI()N.

In accordance with the Surveillance Frequency Control Program (continued)

DAEC 3.3-55 Amendment 280

Primary Containment Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.6.1.6 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control

. Program

. SR 3.3.6.1.7 Perform CHANNEL CALIBRATION.

In accordance with.

the Surveillance Frequency Control I Program SR 3.3.6.1.8 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.9 Perform LOGIC SYSTEM FUNCTIONAL In accordance with TEST.

the Surveillance Frequency Control Program DAEC 3.3-56 Amendment 280

Secondary Containment Isolation Instrumentation 3.3.6.2 SURVEILLANCE REQUIREMENTS

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

1.

Refer to Table 3.3.6.2-1 to determine which SRs apply for each Secondary Containment Isolation Function.

2.

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains secondary containment isolation capability.

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

SURVEILLANCE

[FREQUENCY SR 3.3.6.2.1 Perform CHANNEL CHECK.

I In accordance with the Surveillance Frequency Control

Program SR 3.3.6.2.2 Perform CHANNEL CHECK.

In accordance with I the Surveillance Frequency Control Program SR 3.3.6.2.3 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control I Program SR 3.3.6.2.4 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST.

In accordance with the Surveillance I Frequency Control Program DAEC 3.3-64 Amendment 280

LLS Instrumentation 3.3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Required Action and associated Completion Time of Condition A, B, or C not met.

OR Both LLS valves inoperable due to inoperable channels.

D.1 Declare the associated LLS valve(s) inoperable.

I mmed iately SURVEILLANCE REQUIREMENTS

N()TES----------------------------------------------------

1.

Refer to Table 3.3.6.3-1 to determine which SRs apply for each Function.

2.

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains LLS initiation capability.

FREQUENCY' SURVEILLANCE SR 3.3.6.3.1 Perform CHANNEL FUNCTIONAL TEST for In accordance with portion of the channel outside primary the Surveillance containment.

Frequency Control Program SR 3.3.6.3.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program (continued)

DAEC 3.3-67 Amendment 280

LLS Instrumentation 3.3.6.3 SURVEILLANCE REQUIREMENTS continued)

SURVEILLANCE FREQUENCY SR 3.3.6.3.3 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.3.4 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.3.5 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.3.6 Perform LOGIC SYSTEM FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program DAEC 3.3-68 Amendment 280

SFU System Instrumentation 3.3.7.1 SURVEILLANCE REQUIREMENTS

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

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the other channel is OPERABLE.

SR 3.3.7.1.1 Perform CHANNEL CHECK.

In accordance with SURVEILLANCE IFREQUENCY i

the Surveillance Frequency Control Program SR 3.3.7.1.2 Perform CHANNEL FUNCTIONAL TEST In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.3 Perform CHANNEL CALIBRATION. The Allowable Value shall be:::: 5 mR/hr.

In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.4 Perform LOGIC SYSTEM FUNCTIONAL In accordance with TEST.

the Surveillance Frequency Control Program DAEC 3.3-71 Amendment 280

LOP Instrumentation 3.3.8.1 SURVEILLANCE REQUIREMENTS

NOTES------------~----------------------------------------

1.

Refer to Table 3.3.8.1-1 to determine which SRs apply for each LOP Function.

2.

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provided the associated Function maintains DG initiation capability.

SR 3.3.8.1.1 SURVEILLANCE Perform CHANNEL FUNCTIONAL TEST.

FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.3.8.1.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.8.1.3 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.8.1.4 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.8.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program DAEC 3.3-74 Amendment 280

RPS Electric Power Monitoring 3.3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Required Action and associated Completion Time of Condition A or B not met in MODE 3, 4 or 5 with any control rod withdrawn from a core cell containing one or more fuel assembli,es,.

D'.1 Initiate action to fully insert all insertable control rods in core cells containing one or more fuel assemblies.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.8.2.1

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

Only required to be performed prior to entering MODE 2 or 3 from MODE 4, when in MODE 4 for :2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control

, Program SR 3.3.8.2.2 Perform CHANNEL CALIBRATION. The Allowable Values shall be:

a.

Overvoltage s; 132 V.

b.

Undervoltage ;;:: 108 V.

c.

Underfrequency :2 57 Hz.

In accordance with the Surveillance Frequency Control Program SR 3.3.8.2.3 Perform a system functional test.

I n accordance with the Surveillance I Frequency Control Program DAEC 3.3-77 Amendment 280

3.4.1 Recirculation Loops Operating SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1

N()TE--------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after both recirculation loops are in operation.

. Verify recirculation pump speed mismatch with both recirculation pumps at steady state operation is as follows:

a.

The speed of the faster pump shall be ~

135% of the speed of the slower pump when operating at < 69.4 % RTP.

b.

The speed of the faster pump shall be ~

122% of the speed of the slower pump when operating at ~ 69.4 % RTP.

SR 3.4.1.2 Verify core flow as a function of core THERMAL POWER is outside the Exclusion Region shown in the COLR.

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program DAEC 3.4-3 Amendment 280

Jet Pumps 3.4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.2.1

N()TES------------------------------

1.

Not required to be performed until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the associated recirculation loop is in operation.

2.

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after> 21.7% RTP.

3.

Criterion c is only applicable when pump speed is s 60% rated speed.

Verify at least one of the following criteria (a, b or c, as applicable) is satisfied for each operating recirculation loop:

a.

Recirculation pump flow to speed ratio differs by s 5% from established patterns, and jet pump loop flow to recirculation pump speed ratio differs by s 5% from established patterns.

b.

Each jet pump diffuser to lower plenum differential pressure differs by s 20% from established patterns.

c.

. The recirculation pump flow to speed ratio, jet pump loop flow to recirculation pump speed ratio, and jet pump diffuser to lower plenum differential pressure ratios are evaluated as being acceptable.

In accordance with the Surveillance Frequency Control Program DAEC 3.4-5 Amendment 280

SRVs and SVs 3.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 Verify the safety function lift setpoints of the SRVs and SVs are as follows:

Number of Setpoint SRVs (Qsig}

1 1110 +/- 33.0 1

1120 +/- 33.0 2

1130+/-33.0 2

1140 +/- 33.0 Number of Setpoint SVs

{Qsig}

2 1240 +/- 36.0 Following testing, lift settings shall be within +/-

1%.

I n accordance with the Inservice Testing Program SR 3.4.3.2

N()TE--------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify each SRV opens when manually actuated.

In accordance with the Surveillance Frequency Control Program DAEC 3.4-7 Amendment 280

RCS Operational LEAKAGE 3.4.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.

( continued)

B.2 Verify source of unidentified LEAKAGE increase is not service sensitive type 304 or type 316 austenitic stainless steel.

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

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

C.1 Be in MODE3.

AND C.2 Be in MODE4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.4.1 Verify RCS unidentified and total LEAKAGE and unidentified LEAKAGE increase are within limits.

FREQUENCY In accordance with the Surveillance Frequency Control Program DAEC 3.4-9 Amendment 280

3.4.5 RCS Leakage Detection Instrumentation SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Perform a CHANNEL CHECK of required Primary Containment Air Sampling System.

SR 3.4.5.2 Perform a CHANNEL FUNCTIONAL TEST of required Primary Containment Air Sampling System instrumentation, equipment drain sump flow integrator, and floor drain sump flow integrator.

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program SR 3.4.5.3 Perform a CHANNEL FUNCTIONAL TEST of required equipment drain sump flow timer and floor drain sump flow timer.

In accordance with the Surveillance Frequency Control Program SR 3.4.5.4 Perform a CHANNEL CALIBRATION of required Primary Containment Air Sampling System instrumentation, equipment drain sump flow integrator, and floor drain sump flow integrator.

In accordance with the Surveillance Frequency Control Program SR 3.4.5.5 Perform a CHANNEL CALIBRATION of required equipment drain sump flow timer and floor drain sump flow timer.

In accordance with the Surveillance Frequency Control Program DAEC 3.4-12 Amendment 280

RCS Specific Activity 3.4.6 ACTIONS CONDITION REQUIRED ACTION

COMPLETION TIME B.

(continued)

B.2.2.1 B.2.2.2 Be in MODE 3.

AND Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.6.1

N()TE------------------------

Only required to be performed in MODE 1.

Verify reactor coolant D()SE EQUIVALENT 1-131 specific activity is::; 0.2 I-lCilgm.

FREQUENCY I n accordance with the Surveillance Frequency Control Program DAEC 3.4-14 Amendment 280

RHR Shutdown Cooling System -

Hot Shutdown 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1

N()TE--------------------------

Not required to be met until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after reactor steam dome pressure is < the RCIC Steam Supply Line Pressure - Low isolation pressure.

Verify one required RHR shutdown cooling subsystem or recirculation pump is operating.

In accordance with the Surveillance Frequency Control

, Program DAEC 3.4-17 Amendment 280

RHR Shutdown Cooling System -

Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

No RH R shutdown cooling subsystem in operation.

No recirculation pump in operation.

B.1 Verify reactor coolant circulation by an alternate method.

B.2 Monitor reactor coolant temperature.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of no reactor coolant circulation Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter Once per hour SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.8.1 Verify one required RHR shutdown cooling sUbsystem or one recirculation pump is operating.

FREQUENCY In accordance with the Surveillance Frequency Control Program.

DAEC 3.4-19 Amendment 280

RCS PrT Limits 3.4.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

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

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

Requirements of the LCO not met.in other.

than MODES 1, 2, and. 3.

C.1 AND C.2 Initiate action to restore parameter(s) to witrlin limits.

Determine RCS is acceptable for operation.

Immediately Prior to entering MODE 2 or 3.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1

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

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

Verify:

a.

RCS pressure and RCS temperature are within the applicable limits in Figure 3.4.9-1.

b.

ReS heatup and cooldown rates are

~ 20°F in any 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period during inservice leak and hydrostatic testing (Curve A).

c.

RCS heatup and cooldown rates are

~ 100°F in any 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period during non-nuclear heating (Curve 8) and nuclear heating (Curve C).

I n accordance with the Surveillance Frequency Control Program (continued)

DAEC 3.4-21 Amendment 280

3.4.9 RCS PrT Limits SURVEILLANCE REQUIREMENTS (continued)

FREQUENCY SURVEILLANCE SR 3.4.9.5 SR 3.4.9.6 SR 3.4.9.7

N()TE-------------------------

Only required to be performed when tensioning the reactor vessel head bolting studs.

Verify temperatures at the reactor vessel head flange and the shell adjacent to the head flange are ~ 74°F.

N()TE-------------------~-~--

Not required to be performed until 30 minutes after RCS temperature :s; 80°F in M()OE 4.

Verify temperatures at the reactor vessel head flange and the shell adjacent to the head flange are ~ 74°F.

~--------N()TE:-------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after RCS temperature:::; 100°F in M()OE 4.

Verify temperatures at the reactor vessel head flange and the shell adjacent to the head flange are ~ 74°F.

In accordance with the Surveillance Frequency Control Program.

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control I Program OAEC 3.4-23 Amendment 280

Reactor Steam Dome Pressure 3.4.10 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.10 Reactor Steam Dome Pressure LCO 3.4.10 The reactor steam dome pressure shall be :s: 1025 psig.

APPLICABILITY:

MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Reactor steam dome pressure not within limit.

A.1 Restore reactor steam dome pressure to within limit. '.

15 minutes B.

Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR3.4.10.1 Verify reactor steam dome pressure is :s: 1025 In accordance with psig.

the Surveitlance Frequency Control Program DAEC 3.4-25 Amendment 280

3.5.1 ECCS-Operating ACTIONS (continued)

COMPLETION TIME CONDITION REQUIRED ACTION I

Immediately pressure ECCS subsystems inoperable for reasons other than Condition Cor D.

OR HPCI System alJd two or more ADS valves inoperable.

OR HPCI System and two or more low pressure ECCS subsystems inoperable.

OR One ADS valve and two or more low pressure ECCS subsystems inoperable.

OR One ADS valve and HPCI System and one low pressure ECCS subsystem inoperable.

N.1 Enter LCO 3.0.3.

N.

Two or more low SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.5.1.1 Verify, for each ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve.

FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

DAEC 3.5-4 Amendment 280

ECCS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.2

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

The low pressure coolant injection (LPCI) system may be considered OPERABLE during alignment and operation for decay heat removal in MODE 3, if capable of being manually realigned and not otherwise inoperable.

Verify each ECCS injection/spray subsystem 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 3.5.. 1.3 Verify a 100 day supply of nitrogen exists for each ADS accumulator.

In accordance with.

the Surveillance Frequency Control Program SR 3.5.1.4 Verify the following ECCS pumps develop the specified flow rate against a system head corresponding to the specified reactor pressure.

SYSTEM HEAD NO.

CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF Core In accordance with the Inservice Testing Program Spray

~ 2718 gpm 1

~ 113 psig LPCI

~ 4320 gpm 1

~

20 psig (continued)

DAEC 3.5-5 Amendment 280

3.5.1 ECCS-Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.5

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure s; 1025 and ~ 940 psig, the HPCI pump can develop a flow rate

~ 2700 gpm against a system head corresponding to reactor pressure.

In accordance with the Inservice Testing Program SR3.5,1.6

N'OT E -----------,----'------------,

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure s; 160 psig, the HPCI pump can develop a flow rate ~ 2700 gpm against a system head corresponding to reactor pressure.

I n accordance with the Surveillance Frequency Control Program SR 3.5,1.7

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

1, Vessel injection Ispray may be excluded,

2.

For the LPCI System, the Surveillance may be met by any series of sequential and/or overlapping steps, such that the LPCI Loop Select function is tested.

Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal.

In accordance with the Surveillance Frequency Control Program (continued)

DAEC 3.5-6 Amendment 280

3.5.1 ECCS-Operating SURVEILLANCE REQUIREMENTS continued)

SURVEILLANCE FREQUENCY SR 3.5.1.8 SR 3.5.1.9

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

Valve actuation may be excluded.

Verify the ADS actuates on an actual or simulated automatic initiation signal.

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

. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify each ADS valve opens when manually actuated.

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program I

I DAEC 3.5-7 Amendment 280

ECCS Shutdown 3.5.2 ACTIONS (continued)

CONDITION D.

Required Action C.2 and associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for each required Low Pressure Coolant Injection (LPCI) subsystem, the suppression pool water level is ;:::: 7.0 ft.

(continued)

DAEC 3.5-9 Amendment 280

ECCS -

Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.5.2.2 Verify, for each required Core Spray (CS) subsystem, the:

a.

Suppression pool water level is ~ 8.0 ft; or

b.

N 0 TE ------------------------

Only one required CS subsystem may take credit for this option during OPDRVs.

Conden~ate storage tank water level in one CST is ~ 11 ft or ~ 7 ft in both CSTs.

FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.5.2.3 Verify, for each required ECCS subsystem, the In accordance with piping is filled with waterfrom the pump the Surveillance discharge valve to the injection valve.

Frequency Control

. Program SR 3.5.2.4

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

One LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal if.

capable of being manually realigned and not otherwise inoperable.

Verify each required ECCS subsystem power operated -and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

I In accordance with the Surveillance Frequency Control Program (continued)

DAEC 3.5-10 Amendment 280

ECCS -

Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5 Verify each required ECCS pump develops the specified flow rate against a system head corresponding to the specified reactor pressure.

SYSTEM HEAD NO.

CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF CS

2718 gpm 1

113 psig LPCI

4320 gpm 1

20 psig In accordance with the Inservice Testing Program SR 3.5.2.6

.,...;.----.;-------------NOTE S-:--------:..----..,-----------,--'--

1.

Vessel injection/spray may be excluded.

2.

Forthe LPCI System, the surveillance may be met by any series of sequential and/or overlapping steps, such that the LPCI Loop Select function is tested.

Verify each required ECCS subsystem actuates on an actual or simulated automatic initiation signal.

In accordance with the Surveillance Frequency Control Program DAEC 3.5-11 Amendment 280

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 Verify the RCIC System piping is filled with water from the pump discharge valve to the injection valve.

I n accordance with the Surveillance Frequency Control Program SR 3.5.3.2 Verify each RCIC System 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 3.5.3.3

---::.------------------------:.. NOTE --------------------------

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

after reactor steam pressure and flow are

adequate to perform the test.

Verify, with reactor pressure s 1025 psig and

2: 940 psig, the RCIC pump can develop a flow rate :2: 400 gpm against a system head corresponding to reactor pressure.

In accordance with the Inservice' Testing Program SR 3.5.3.4

N()lrE----------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure s 160 psig, the RCIC pump can develop a flow rate :2: 400 gpm against a system head corresponding to reactor pressure..

In accordance with the Surveillance Frequency Control Program

( continued)

DAEC 3.5-13 Amendment 280

3.5.3 RCIC System SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.5.3.5

N()TE---------------------------

Vessel injection may be excluded.

Verify the RCIC System actuates on an actual

. or simulated automatic initiation signal.

FREQUENCY In accordance with the Surveillance Frequency Control Program DAEC 3.5-14

. Amendment 280

Primary Containment 3.6.1.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR3.6.1.1.1 Perform required visual examinations and leakage rate testing except for primary containment air lock testing, in accordance with the Primary Containment Leakage Rate Program.

SR 3.6.1.1.2 Verify suppression chamber pressure does not increase at a rate> 0.009 psi per minute tested over a 1 0 minute period at a differential pressure of> 1.0 psid.

In accordance with the Primary Containment Leakage Rate Program.

In accordance with the Surveillance Frequency Control Program DAEC 3.6-2 Amendment 280

Primary Containment Air Lock 3.6.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.1.2.1

N()TES-----------------------

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 3.6.1.1.1.

Perform required primary containment air lock

. leakage rate testing in accordancewith the Primary Containment Leakage Rate Testing Program.

The acceptance criterion for air lock testing is overall air lock leakage rate ~ 0.05 La when tested at;::: Pa.

FREQUENCY In accordance with the Primary Containment Leakage Rate Testing Program.

SR 3.6.1.2.2 Verify only one door in the primary In accordance with containment air lock can be opened at a time.

the Surveillance Frequency Control Program DAEC 3.6-7 Amendment 280

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.1

N()TE----------------------------

Not required to be met when the 18 inch primary containment purge valves are open for inerting, de-inerting, pressure control, ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open.

Verify each 18 inch primary containment purge valve is closed.

In accordance with the Surveillance Frequency Control Program SR 3.6.1.3.2 Verify continuity of the traversing incore In accordance with probe (TIP) shear isolation valve explosive the Surveillance charge.

Frequency Control

. Program SR 3.6.1.3.3 Verify the isolation time of each power operated automatic PCIV, except for MSIVs, is within limits.

In accordance with the Inservice Testing Program SR 3.6.1.3.4 Perform leakage rate testing for each primary containment purge valve with resilient seals.

In accordance with the Surveillance Frequency Control Program AND

()nce within 92 i days after I opening the valve (continued)

DAEC 3.6-13 Amendment 280

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.5 Verify the isolation time of each MSIV is

> 3 seconds and < 5 seconds.

In accordance with the Inservice Testing Program SR 3.6.1.3.6

N()lrE---------------------------

For the MSIVs, this SR may be met by any series of sequential, overlapping, or total system steps, such that proper operation is verified.

Verify each automatic PCIV actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.6.1.3.7 Verify a representative sample of reactor instrumentation line EFCVs actuate on a simulated instrument line break to restrict flow.

In accordance with the Surveillance Frequency Control Program SR 3.6.1.3.8 Remove and test the explosive squib from each shear isolation valve of the TIP System.

In accordance with the Inservice Testing Program (continued)

DAEC 3.6-14 Amendment 280

Drywell Air Temperature 3.6.1.4 3.6 CONTAINMENT SYSTEMS 3.6.1.4 Drywell Air Temperature LCO 3.6.1.4 Drywell average air temperature shall be ::; 135°F.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION I COMPLETION TIME A.

Drywell average air A 1 Restore drywell average 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months temperature not within air temperature to within limit.

limit.

~-----+--------------I------~----

B.

Required Action and B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion

. Time not met.

B.2 Be i.n MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.4.1 Verify drywell average air temperature is within limit.

In accordance with the Surveillance Frequency Control Program DAEC 3.6-16 Amendment 280

LLS Valves 3.6.1.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.1.5.1

N()TE-------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and "flow are adequate to perform the test.

Verify each LLS valve opens when manually actuated.

FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.6.1.5.2

~--~N()TE--------------------------

Valve actuation may be excluded.

.verify the LLS System actuates on an actual or simulated automatic initiation signal.

In accordance with the Surveillance Frequency Control Program DAEC 3.6-18 Amendment 280

Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.6 ACTIONS ~continued)

CONDITION REQUIRED ACTION i COMPLETION TIIVIE I

D.

Two reactor building-to suppression chamber vacuum breaker assemblies with one or two valves inoperable for opening.

0.1 Restore both valves in one vacuum breaker assembly to OPERABLE status.

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

Required Action and Associated Completion Time not met.

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

Be In MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.6.1

NOTES-----------------------~-

1.

Not required to be met for vacuum breaker assembly valves that are open during Surveillances.

2.

Not required to be met for vacuum breaker assembly valves open when performing their intended function.

Verify each vacuum breaker assembly valve is closed.

SR 3.6.1.6.2 Perform a functional test of each vacuum breaker assembly valve.

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program

( continued)

DAEC 3.6-20 Amendment 280

Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.6.3 Verify the opening setpoint of each vacuum breaker assembly valve 1S

s; 0.614 psid.

In accordance with the Surveillance Frequency Control Program DAEC 3.6-21 Amendment 280

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.7.1

N()TE----------------------------

Not required to be met for vacuum breakers that are open during Surveillances.

Verify each vacuum breaker is closed.

In accordance with the Surveillance Frequency Control Program SR 3.6.1.7.2 Perform a functional test of each required vacuum breaker.

In accordan,ce with the Surveillance Frequency Control Program SR 3.6.1.7.3 Verify the opening setting of each required vacuum breaker is s 0.5 psid.

In accordance with the Surveillance Frequency Control Program DAEC 3.6-23 Amendment 280

Suppression Pool Average Temperature 3.6.2.1 ACTIONS continued CONDITION E.

Suppression pool average temperature

> 120°F.

I REQUIRED ACTION COMPLETION TIME E.1 Depressurize the reactor vessel to

< 200 psig.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND E.2 Be in MODE 4.

.36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months I

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1.1 Verify suppression pool average temperature is within the applicable limits.

In accordance with the Surveillance Frequency Control Program 5 minutes when performing testing that adds heat to the suppression pool DAEC 3.6-26 Amendment 280

Suppression Pool Water Level 3.6.2.2 3.6 CONTAINMENT SYSTEMS 3.6.2.2 Suppression Pool Water Level LCO 3.6.2.2 Suppression pool water level shall be;::: 10.11 ft and

10.43 ft.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Suppression pool water level not within limits.

A.1 Restore suppression pool water level to within limits.

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

- SURVEILLANCE SR 3.6.2.2.1 Verify suppression pool water level is within limits.

FREQUENCY In accordance with the Surveillance Frequency Control Program DAEC 3.6-27 Amendment 280

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 SR 3.6.2.3.2 Verify by administrative means each RHR suppression pool cooling subsystem manual, power operated and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.

Verify each RHR pump develops a flow rate

~ 4800 gpm through the associated heat exchanger whiJe operating in the suppression pool cooling mode,.

In accordance with the Surveillance Fre.quency Control Program In accordance with the Inservice Testing Program I

I DAEC 3.6-29 Amendment 280

RHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.2.4.1 Verify by an air test that the suppression pool spray header and nozzles are unobstructed.

FREQUENCY In accordance with the Surveillance Frequency Control Program DAEC 3.6-31 Amendment 280

Primary Containment Oxygen Concentration 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Primary Containment Oxygen Concentration LCO 3.6.3.2 The primary containment oxygen concentration shall be

< 4.0 volume percent.

APPLICABILITY:

MODE 1 during the time period:

a.

From 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 15% RTP following startup, to

b.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing THERMAL POWER to < 15%

RTP prior to reactor shutdown.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Primary containment A.1 Restore oxygen oxygen concentration not

concentration to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months within limit.

B.

Required Action and associated Completion Time not met.

limit.

B.1 Reduce THERMAL 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months POWER to::; 15%

RTP.

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.3.2.1 Verify primary containment oxygen concentration is within limits.

FREQUENCY In accordance with the Surveillance Frequency Control Program DAEC 3.6-34 Amendment 280

Secondary Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify all secondary containment equipment hatches are closed.

In accordance with the Surveillance.

Frequency Control Program SR 3.6.4.1.2

N()TE---------------------------

Doors in high radiation areas may be verified by administrative means.

Verify that either the outer door(s) or the inner door(s) in each secondary containment access opening are closed.

In accordance with the Surveillance Frequency Control

Program SR 3.6.4.1.3 Verify each SBGT subsystem can maintain

0.25 inch of vacuum water gauge in the secondary containment at a flow rate

s; 4000 cfm.

DAEC 3.6-36 Amend ment 280

SCIV/Ds 3.6.4.2 SURVEILLANCE,REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 Verify the isolation time of each power operated automatic SCIV/D is within limits.

In accordance with the Surveillance Frequency Control Program SR 3.6.4.2.2 Verify each automatic SCIV/D actuates to the isolation position on an actual or simulated actuation signal.

In accordance with the Surveillance Frequency Control Program DAEC 3.6-40 Amendment 280

SBGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SBGT subsystem for 2: 10 In accordance with continuous hours with heaters operating.

the Surveillance Frequency Control Program SR 3.6.4.3.2

No-rE--------------------------

When a SBGT subsystem is placed in an inoperable status solely for the performance of VFTP testing required by this Surveillance on the other subsystem, entry into associated Conditions and Required Actions may be delayed for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Perform required SBGT filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

In accordance with the VFTP SR 3.6.4.3.3 Verify each SBGT subsystem actuates on an actual or simulated initiation signal.

In accordance with the Surveillance Frequency Control Program SR 3.6.4.3.4 Verify each SBGT filter cooler bypass In accordance with damper can be opened and the fan started.

the Surveillance

. Frequency Control IProgram DAEC 3.6-43 Amendment 280

ACTIONS (continued)

CONDITION REQUIRED ACTION D.

Both RHRSW subsystems inoperable for reasons other than Condition B.

I ----------------NOTE---------------

I Enter applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by RHRSW System.

D.1 Restore one RHRSW subsystem to OPERABLE status.

E.

Required Action and associated Completion Time not met.

I E.1

.AND Be in MODE 3.

E.2 Be in MODE 4.

RHRSW System 3.7.1 COMPLETION TIME 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE

.1 FREQUENCY SR3.7.1.1 Verify eachRHRSW subsystem poweroperated In accordance with and automatic valve in the flow path, that is not the Surveillance Frequency Control locked, sealed, or otherwise secured in position, is in the* correct position or can be aligned to the Program correct position.

DAEC 3.7-2 Amendment 280

RWS System and UHS 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Verify the river water level is:::: 725.2 ft mean sea level.

In accordance with the Surveillance Frequency Control Program SR 3.7.2.2 Verify the average river water temperature is

s; 95°F.

In accordance with the Surveillance

Frequency Control

Program SR 3.7.2.3

N()lrE-------------------------

Not required to be performed until river depth

< 2 feet at the intake structure.

Verify the river water depth is ;:: 12 inches.

In accordance with the Su rveillance Frequency Control Program SR 3.7.2.4 VerifY'each RWS subsystem power operated and automatic valve in the flow paths servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.7.2.5 SR 3.7.2.6 Verify the river water depth;:: 12 inches.

Verify each RWS subsystem actuates on an actual or simulated initiation signal.

I n accordance with

the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program DAEC 3.7-4 Amendment 280

ESW System 3.7.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1

N()lrE-------------------------

Isolation of flow to individual components does not render ESW System inoperable.

Verify each ESW subsystem power operated and automatic valve in the flow paths servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.7.3.2 Verify each ESW subsystem actuates on an actual or simulated initiation signal.

In accordance with the Surveillance Frequency Control Program DAEC 3.7-6 Amendment 280

ACTIONS (continued)

CONDITION F.

Both SFU subsystems inoperable during movement of irradiated fuel assembles in the secondary containment, during CORE ALTERATIONS, or during OPDRVs.

OR One or more SFU subsystems inoperable due to an inoperable CBE boundary during movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs.

REQUIRED ACTION

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

LCO 3.0.3 is not applicable.

F.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

AND F.2 Suspend CORE ALTERATIONS.

AND F.3 Initiate action to suspend OPDRVs.

SFU System 3.7.4 COMPLETION TIME Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Operate each SFU subsystem for 2 15 minutes.

SR 3.7.4.2 Perform required SFU filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

In accordance with the Surveillance Frequency Control Program In accordance with the VFTP (continued)

DAEC 3.7-9 Amendment 280

3.7.4 SFU System SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.4.3 Verify each SFU subsystem actuates on an actual or simulated initiation signal.

SR 3.7.4.4 Perform required CBE unfiltered air inleakage testing in accordance with the Control Building Envelope Habitability Program.

In accordance with the Surveillance Frequency Control Program In accordance with the Control Building Envelope Habitability Program DAEC 3.7-10 Amendment

CBC System 3.7.5 ACTIONS (continued)

CONDITION E.

Required Action and associated Completion Time of Condition B not met during movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs.

REQUIRED ACTION COMPLETION TIME

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

LCO 3.0.3 is not applicable.

E.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

E.2 Suspend CORE ALTERATIONS.

E.3 Initiate action to suspend OPDRVs.

Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE

. FREQUENCY SR 3.7.5.1 Verify each CBC subsystem has the In accordance with capability to remove the available heat load.

the Surveillance Frequency Control Program DAEC 3.7-13 Amendment 280

Main Condenser Offgas 3.7.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1

~o-rE--------------------------

Not required to be performed until 31 days after any main steam line not isolated and SJAE in operation.

Verify the gross gamma activity rate of the noble gases is :s, 1.0 Cilsecond after decay of 30 minutes.

In accordance with the Surveillance Frequency Control Program Once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after a

?::: 50% increase in the nominal steady state fission gas release after factoring out increases due to changes in THERMAL I POWER level DAEC Amendment 280

Main Turbine Bypass System 3.7.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY I n accordance with turbine bypass valve.

SR 3.7.7.1 Verify one complete cycle of each main the Surveillance Frequency Control

! Program SR 3.7.7.2 Perform a system functional test.

SR 3.7.7.3 Verify the TURBINE BYPASS SYSTEM RESPONSE TIME is within limits..

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program DAEC 3.7-17 Amendment 280

Spent Fuel Storage Pool Water Level 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Spent Fuel Storage Pool Water Level LCO 3.7.8 The spent fuel storage pool water level shall be ~ 36 ft.

APPLICABILITY: During movement of irradiated fuel assemblies in the spent fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Spent fuel storage pool water level not within limit.

A.1

NOTE---------

LCO 3.0.3 is not applicable.

Suspend movement of irradiated fuel assemblies in the spent fuel storage Immediately pool.

SURVEILLANCE FREQUENCY SURVEILLANCE REQUIREMENTS SR 3.7.8.1 Verify the spent fuel storage pool water In accordance with level is ~ 36 ft.

the Surveillance Frequency Control Program DAEC 3.7-18 Amendment 280

3.7.9 CB/SBGT instrument Air System SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.9.1 Operates each CB/SBGT instrument Air compressor for ~ 20 minutes.

FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.7.9.2 Verify each CB/SBGT Instrument Air subsystem actuates on an actual or simulated initiation signal and maintains air pressure ~ 75 psig in the receiver.

In accordance with the Surveillance Frequency Control Program DAEC 3.7-20 Amendment 280

AC Sources -= Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR3.8.1.1 Verify correct breaker alignment and indicated power availability for each offsite circuii.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.2

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

1.

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

2.

A modified DG start involving idling and gradual acceleration 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.

3.

When a DG is placed in an inoperable status solely for the performance of testing required by Required Actions B.3 or 8A, entry into associated Conditions and Required Actions maybe delayed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Verify each DG starts from standby conditions and achieves steady state voltage;:::: 3744v and s 4576v and frequency;:::: 595Hz and

. s 60.5Hz.

In accordance with the Surveillance Frequency Control Program (continued)

DAEC 3.8-5 Amendment 280

AC Sources -

Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.3 SURVEILLANCE

NOliES---------------------------

1.

DG 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 DG 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.

FREQUENCY SR 3.8.1.4 SR 3.8.1.5 Verify each DG is synchronized and loaded and operates for :2: 60 minutes at a load

2: 2750kw and:;; 2950kw.

Verify each tank contains :2: 220 gal of fuel oil.

Check for the presence of water in the fuel oil in each day tank and remove water as necessary.

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program

( continued)

DAEC 3.8-6 Amendment 280

AC Sources -

Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.6 Verify the fuel oil transfer system operates to transfer fuel oil from storage tank to the day tank.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.7

NOlrE-----------------------------

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

Verify each DG starts from standby condition and achieves:

a. in:::; 10 seconds, voltage;::: 3744V and frequency;::: 59.5Hz; and

b. steady state, voltage;::: 3744V and:::; 4576V and frequency;::: 59.5Hz and:::; 60.5Hz.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.8

N()TE---------------------------

The Surveillance shall not be performed in M()DE 1 or 2. However, credit may be taken for unplanned events that satisfy this SR.

Verify automatic slow transfer of AC power supply from the Startup Transformer to the Standby Transformer.

In accordance with the Surveillance Frequency Control Program

( continued)

DAEC 3.8-7 Amendment 280

AC Sources -

Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.9 SURVEILLANCE

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

This Surveillance shall not be performed in MODE 1 or 2. However, credit may be taken for unplanned events that satisfy this SR.

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

a.

Following load rejection, the frequency is

64.5Hz.

b.

Within 1.3 seconds following load rejection, the voltage is ~ 3744V and

$ 4576V.

c.

Within 3.9 seconds following load rejection. the frequency is ~ 59.5Hz and

$ 60.5Hz.

FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.8.1.10

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

This Surveillance shall not be performed in MODE 1, 2 or 3. However, credit may be taken for unplanned events that satisfy this SR.

Verify each DG's automatic trips are bypassed on an actual or simulated Loss of Offsite Power (LOOP) signal or on an actual or simulated ECCS initiation signal except:

a.

Engine overspeed; and

b.

Generator lockout.

In accordance with the Surveillance Frequency Control Program

( continued)

DAEC 3.8-8 Amendment 280

3.8.1 AC Sources -

Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3,8.1.11

NOllE-------------------------------

This Surveillance shall not be performed in MODE 1, 2 or 3. However, credit may be taken for unplanned events that satisfy this SR.

Verify under manual control each DG:

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

6.

Returns to ready.:.to-Ioad operation.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.12

N()TE----------------------------------

lIhis Surveillance shall not be performed in M()DE 1, 2 or 3. However, credit may be taken for unplanned events that satisfy this SR.

Verify interval between each sequenced load block is ~ 2 seconds.

In accordance with the Surveillance Frequency Control Program (continued)

DAEC 3.8-9 Amendment 280

3.8.1 AC Sources -

Operating SURVEILLANCE REQUIREMENTS continued FREQUENCY

. SR3.8.1.13 In accordance with the Surveillance Frequency Gontrol Program SURVEILLANCE

N()lrES--------------------------

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

2.

This Surveillance shall not be performed in MODE 1, 2, or 3. However, credit may be taken for unplanned events that satisfy this SR.

Verify, on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ECGS initiation signal:

a.

De-energization of essential buses;

b.

Load shedding from essential buses; and

c.

DG auto-start from standby condition and:

1.

energizes permanently connected loads in s 10 seconds,

2.

energizes auto-connected emergency loads in the proper timed

sequence,

3.

achieves steady state voltage

2: 3744V and S 4576V,

4.

achieves steady state frequency

2: 59.5Hz and s 60.5Hz, and

5.

supplies permanently connected and auto-connected emergency loads for

2: 5 minutes.

DAEC 3.8-10 Amendment 280

Diesel Fuel Oil, Lube OH, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify fuel oil storage tank contains

~ 36,317 gal of fuel.

I n accordance with the Surveillance Frequency Control Program SR 3.8.3.2 Verify lube oil inventory is ~ 257 gal for each DG.

In accordance with the Surveillance Frequency Control Program SR 3.8.3.3 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 with the Diesel Fuel Oil Testing Program SR 3.8.3.4 Verify required air start receiver pressure is ~

150 psig.

In accordance with the Surveillance Frequency Control Program SR 3.8.3.5 Check for the presence of water in the fuel oil in the fuel oil storage tank and remove water as necessary.

In accordance with the Surveillance Frequency Control Program DAEC 3.8-16 Amendment 280

DC Sources -

Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is ;::: 126 V on float charge for the 125 VDC battery and

252 V for the 250 VDC battery.

In accordance with the Surveillance Frequency Control Program SR 3.8.4.2 Verify no visible corrosion at battery terminals and connectors.

OR Verify battery connection resistance within limits.

In accordance with the Surveillance Frequency Control Program SR 3.8.4.3 Verify 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 SR 3.8.4.4 Remove visible corrosion and verify battery cell to cell and terminal connections are coated with anti-corrosion material.

In accordance with the Surveillance Frequency Control Program SR 3.8.4.5 Verify battery connection resistance within limits.

In accordance with the Surveillance Frequency Control Program

( continued)

DAEC 3.8-18 Amendment 280

DC Sources -

Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.6 SURVEILLANCE

NOllE-------------------------------

llhis Surveillance shall not be performed on the required battery chargers in MODE 1, 2 or 3.

However, credit may be taken for unplanned events that satisfy this SR.

Verify each required battery charger supplies

~ 300 amps at ~ 129 V for the 125 VDC subsystem and ~ 200 amps at ~ 258 V for the 250 VDC subsystem.

FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.8.4.7

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

1.

The modified performance discharge test in SR 3.8.4.8 may be performed in lieu of the service test in SR 3.8.4.7.

2.

This Surveillance shall not be performed in MODE 1, 2, or 3. However, credit may be taken for unplanned events that satisfy this SR.

Verify 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.

In accordance with the Surveillance Frequency Control Program (continued)

DAEC 3.8-19 Amendment 280

3.8.4 DC Sources -

Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.8.4.8

~()TE---------------------------

This Surveillance shall not be performed in MODE 1, 2, or 3. However, credit may be taken for unplanned events that satisfy this SR.

Verify 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 AND 12 months when battery shows degradation or has reached 85%

of expected life with capacity

< 100% of manufacturer's rating 24 months when battery has reached 85% of the expected life with capacity;:: 100%

of manufacturer's rating DAEC 3.8-20 Amendment 280

3.8.6 Battery Cell Parameters SURVEILLANCE REQUIREMENTS SR 3.8.6.1 SURVEILLANCE Verify battery cell parameters meet Table 3.8.6-1 Category A limits.

FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.8.6.2 Verify battery cell parameters meet Table 3.8.6-1 Category B limits.

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

< 110 V for 125 V and < 220 V for 250V SR 3.8.6.3 Verify average electrolyte temperature of representative cells is ~ 65°F for each battery.

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

> 1 50 V for 125 V and> 300 V for 250V In accordance with the Surveillance Frequency Control Program DAEC 3.8-25 Amendment 280

Distribution Systems -

Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct breaker alignments and indicated power availability to required AC and DC electrical power distribution subsystems.

In accordance with the Surveillance Frequency Control Program SR 3.8.7.2 Verify proper coordination of the LPCI Swing Bus circuit breakers..

In accordance with the Surveillance Frequency Control Program DAEC 3.8-29 Amendment 280

Distribution Systems -

Shutdown 3.8.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.2.4 Initiate actions to restore required AC and DC electircal power distribution.

subsytems to OPERABLE status.

AND A.2.5 Declare associated required shutdown cooling subsystem(s) inoperable.

Immed iately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.8.1 Verify correct breaker alignments and indicated power availability to required AC and DC electrical power distribution subsystems.

FREQUENCY In accordance with the Surveillance Frequency Control Program DAEC 3.8-31 Amendment 280

Refueling Equipment Interlocks 3.9.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR3.9.1.1 Perform CHANNEL FUNCTIONAL TEST on each of the following required refueling equipment interlock inputs:

a.

AII-rods-in,

b.

Refuel platform position,

c.

. Refuel platform fuel grapple, fuel loaded,

d.

Refuel platform fuel grapple fully retracted position,

e.

Refuel platform frame mounted hoist, fuel loaded, and

f.

Refuel platform monorail mounted hoist, fuel loaded.

FREQUENCY In accordance with the Surveillance Frequency Control Program DAEC 3.9-2 Amendment 280

Refuel Position One-Rod-Out Interlock 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Refuel Position One-Rod-Out Interlock LCO 3.9.2 The refuel position one-rod-out interlock shall be OPERABLE.

APPLICABILITY: MODE 5 with the reactor mode switch in the Refuel position and any control rod withdrawn.

ACTIONS*

CONDITION REQUIRED ACTION COMPLETION TIME A.

Refuel position one-rod out interlock inoperable.

A.1 Suspend control rod withdrawal.

Immediately A.2.

Initiate action to fully insert all insertable control rods in core cells containing one or more fuel assemblies.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.2.1 Verify reactor mode switch locked in Refuel position.

FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

DAEC 3.9-3 Amendment 280

3.9.2 Refuel Position One-Rod-Out Interlock SURVEILLANCE REQUIREMENTS (continued SURVEILLANCE FREQUENCY SR 3.9.2.2

NOlrE-----------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after any control rod is withdrawn.

Perform CHANNEL FUNCTIONAL lrEST.

In accordance with the Surveillance Frequency Control Program DAEC 3.9-4 Amendment 280

Control Rod Position 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Control Rod Position LCO 3.9.3 All control rods shall be fully inserted.

APPLICABILITY:

ACTIONS When loading fuel assemblies into the core.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more control rods not fully inserted.

A.1 Suspend loading fuel assemblies into the core.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 Verify all control rods are fully inserted.

In accordance with the Surveillance Frequency Control Program DAEC 3.9-5 Amendment 280

Control Rod OPERABILITY -

Refueling 3.9.5 3.9 REFUELING OPERATIONS 3.9.5 Control Rod OPERABILITY -

Refueling LCO 3.9.5 Each withdrawn control rod shall be OPERABLE.

APPLICABILITY:

MODE 5.

ACTIONS CONDITION REQUIRED ACTION I COMPLETION TIME A.

One or more withdrawn A.1 Initiate action to fully Immediately control rods inoperable.

insert inoperable withdrawn control rods.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1

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

Not required to be performed until 7 days after the control rod is withdrawn.

Insert each withdrawn control rod at least one In accordance with notch.

the Surveillance Frequency Control I Program SR 3.9.5.2 Verify each withdrawn control rod scram In accordance with accumulator pressure is;:::: 940 psig.

the Surveillance Frequency Control I Program DAEC 3.9-8 Amendment 280

RPV Water Level 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Reactor Pressure Vessel (RPV) Water Level LCO 3.9.6 RPV water level shall be ~ 23 ft above the top of the irradiated fuel assemblies seated within the RPV.

APPLICABILITY: During movement of irradiated fuel assemblies within theRPV, During movement of new fuel assemblies or handling of control rods within the RPV, when irradiated fuel assemblies are seated within the RPV.

ACTIONS CONDITION REQUIRED ACTION

! COMPLETION TIME A.

RPV water level not within limit.

A. 1 Suspend movement of.

fuel assemblies and handling of control rods within the RPV.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify RPV water level is ~ 23 ft above the top of the irradiated fuel assemblies seated within the RPV.

In accordance with the Surveillance Frequency Control Program DAEC 3.9-9 Amendment 280

RHR-High Water Level 3.9.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

No RH R sh utdown cooling subsystem in operation with reactor coolant temperature 2: 150°F.

C.1 Verify reactor coolant circulation by an alternate method,.

AND C.2 Monitor reactor coolant temperature.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of no I reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

thereafter Once per hour SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.7.1 Verify one RHR shutdown cooling subsystem is operating when reactor coolant temperature is 2: 150 of.

FREQUENCY In accordance with the Surveillance Frequency Control Program DAEC 3.9-12 Amendment 280

3.9.8 RH R-Low Water Level SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.8.1 Verify one RHR shutdown cooling subsystem is operating.

FREQUENCY I n accordance with the Surveillance Frequency Control Program DAEC 3.9-15 Amendment 280

Reactor Mode Switch Interlock Testing 3.10.2 ACTIONS CONDITION REQUIRED ACTION I COMPLETION TIME A (continued)

A.3.1 Place the reactor mode switch in the Shutdown position.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR A. 3.2 ------------N OT E -----------

Only applicable in MODE 5.

Place the reactor mode switch in th~ Refuel position.

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

. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.2.1 Verify all control rods are fully inserted in core cells containing one or more fuel assemblies.

In accordance with the Surveillance Frequency Control Program SR 3.10.2.2 Verify no CORE ALTERATIONS are in progress.

In accordance with the Surveillance Frequency Control Program DAEC 3.10-5 Amendment 280

Single Control Rod Withdrawal -

Hot Shutdown 3.10.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.3.1 Perform the applicable SRs for the required LCOs.

According to the applicable SRs S R 3. 1 0.3.2

NaTE--------------------.,.--------

Not required to be met if SR 3.10.3.1 is satisfied for LCO 3.10.3.d.1 requirements.

Verify all c~ntrol rods, other than the control rod being withdrawn, in a five by five array centered on the control rod being withdrawn, are disarmed~

In accordance with.

the Surveillance Frequency Control Program SR 3.10.3.3 Verify all control rods, other than the control rod being withdrawn, are fully inserted.

In accordance with the Surveillance Frequency Control Program.

DAEC 3.10-8 Amendment 280

Single Control Rod Withdrawal -

Cold Shutdown 3.10.4 ACTIONS (continued)

REQUIRED ACTION

! COMPLETION TIME CONDITION B.

One or more of the above requirements not met with the affected control rod not insertable.

B.1 B.2.1 B.2.2 Suspend withdrawal of the control rod and removal of associated CRD.

Initiate action to fully.

insert a/l control rods.

Initiate action to satisfy the requirements of this LCO.

Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.10.4.1 Perform the applicable SRs for the required LCOs.

According to the applicable SRs SR 3.10.4.2

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

Not required to be met if SR 3.10.4.1 is satisfied for LCO 3.1 0.4.c.1 requirements.

Verify a/l control rods, other than the control rod being withdrawn, in a five by five array centered on the control rod being withdrawn, In accordance with the Surveillance Frequency Control I

are disarmed.

FREQUENCY IProgram

( continued)

DAEC 3.10-11 Amendment 280

Single Control Rod Withdrawal -

Cold Shutdown 3.10.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY In accordance with being withdrawn, are fully inserted.

SR 3.10.4.3 Verify all control rods, other than the control rod the Surveillance Frequency Control Program SR 3.10.4.4

~------------------N()TE------------------------------

Not required to be met if SR 3.10.4.1 is satisfied for Le() 3.1 0.4.b.1 requirements..

Verify a control rod withdrawal block is inserted.

In accordance with the Surveillance Frequency Control Program DAEC 3.10-12 Amendment 280

Single CRD Removal -

Refueling 3.10.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

( continued)

. A.2.1 Initiate action to fully insert all control rods.

Immediately OR A.2.2 Initiate action to satisfy the requirements of this LCO.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE

. FREQUENCY SR 3.10.5.1 Verify all control rods, other than the control rod withdrawn for the removal of the associated CRD, are fully inserted.

In accordance with the Surveillance Frequency Control Program SR 3.10.5.2 Verify all control rods, other than the control rod withdrawn for the removal of the associated CRD, in a five by five array centered on the control rod withdrawn for the removal of the associated CRD, are disarmed.

In accordance with the Surveillance Frequency Control Program SR 3.10.5.3 Verify a control rod withdrawal block is inserted.

In accordance with the Surveillance Frequency Control I Program SR 3.10.5.4 Perform SR 3.1.1.1.

According to SR 3.1.1.1 I

(continued)

DAEC 3.10-14 Amendment 280

Single CRD Removal -

Refueling 3.10.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.10.5.5 Verify no other CORE ALTERATIONS are in progress.

FREQUENCY In accordance with the Surveillance Frequency Control Program DAEC 3.10-15 Amendment 280

Multiple Control Rod Withdrawal -

Refueling 3.10.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.3.1 A.3.2 Initiate action to fully insert all control rods in core cells containing one or more fuel assemblies.

Initiate action to satisfy the requirements of this LCO.

Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.6.1 Verify the four fuel assemblies are removed from core cells associated with each' control rod or CRD removed.

In accordance with the Surveillance Frequency Control

Program In accordance with containing one or more fuel assemblies are SR 3.10.6.2 Verify all other control rods in core cells the Surveillance fully inserted.

Frequency Control Program SR 3.10.6.3

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

Only required to be met during fuel loading.

In accordance with compliance with an approved reload sequence.

Verify fuel assemblies being loaded are in the Surveillance Frequency Control

. Program I

DAEC 3.10-17 Amendment 280

SDM Test -

Refueling 3.10.8 SURVEILLANCE REQUIREMENTS SR 3.10.8.1 SURVEILLANCE Perform the MODE 2 applicable SRs for LCO 3.3.1.1, Functions 2.a and 2.d of Table 3.3.1.1-1.

FREQUENCY According to the applicable SRs SR 3.10.8.2

~OTE--------------------------

Not required to be met if SR 3.10.8.3 satisfied.

Perform the MODE 2 applicable SRs for LCO 3.3.2.1, Function 2 of Table 3.3.2.1-1.

According to the applicable SRs SR 3.10.8.3

:-:--...----.;.--------,-----~0 T E ------------------------

Not required to be met if SR 3.10.8.2 satisfied.

Verify movement of control rods is in compliance with the approved control rod sequence for the SDM test by a second licens.ed operator or other qualified member of During control rod movement the technical staff.

SR 3.10.8.4 Verify no other CORE ALTERATIONS are in In accordance with progress.

the Surveillance Frequency Control Program I

( continued)

DAEC 3.10-22 Amendment 280

SOM Test -

Refueling 3.10.8 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.10.8.5 Verify each withdrawn control rod does not go to the withdrawn overtravel position.

Each time the control rod is withdrawn to "full out" position Prior to satisfying LCO 3.1 0.8.c requirement after work on control rod or CRD System that could affect coupling SR 3.10.8.6 Verify CRO charging water header pressure

970 psig.

In accordance with the Surveillance Frequency Control Program OAEC 3.10-23 Amendment 280

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Control Building Envelope Habitability Program (continued)

c.

Requirements for (i) determining the unfiltered air inleakage past the CBE boundary into the CBE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CBE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision O.

d.

Measurement, at designated locations, of the CBE pressure*

relative to all external areas adjacent to the CBE boundary during the pressurization mode of operation by one subsystem of the SFU System, operating at the flow rate required by the VFTP, at a Frequency of 24 months on a Staggered Test Basis. The results shall be trended and used as part of the 24 month assessment of the CBE boundary.

I

e.

The quantitative limits on unfiltered air inleakage into the CBE.

These limits shall be stated in 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 DBA consequences. Unfiltered air leakage limits for hazardous chemicals must ensure that the exposure of CBE 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 CBE habitability, determining CBE unfiltered inleakage, and measuring CBE pressure and assessing the CBE boundary as required by paragraphs c and d, respectively.

(continued)

A Staggered Test Basis shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other deSignated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other deSignated components in the associated function.

DAEC 5.0-18a Amendment 280

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which 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, "Risk-Informed Method for Control of Surveillance Frequencies,"

Revision 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.

DAEC 5.0-18b Amendment 280

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 280 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-49 NEXTERA ENERGY DUANE ARNOLD. LLC DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331

1.0 INTRODUCTION

By application letter dated February 23,2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML110550570), as supplemented by letters dated April 20, 2011; August 15, 2011; November 1, 2011; and February 3, 2012 (ADAMS Accession Nos. ML111110507, ML11229A184, ML113050120, and ML12040A016, respectively), NextEra Energy Duane Arnold, LLC (the licensee) proposed changes to the technical specifications (TSs) for the Duane Arnold Energy Center (DAEC). The supplemental letters 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 or the Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register (FR) on May 17, 2011 (76 FR 28474).

The requested change is the adoption of NRC-approved Technical Specifications Task Force (TSTF)-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF

[Risk-Informed TSTF] Initiative 5b" (Reference 1). 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 TSs. All surveillance frequencies can be relocated except:

Frequencies that reference other approved programs for the specific interval (such as the Inservice 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 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 2! 95% RTP [rated thermal power]")

Enclosure

- 2

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 in TS Section 5.5, "Programs and Manuals," as Specification 5.5.14. 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 requirement 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 TSs 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 (Reference 2), as the basis for making any changes to the surveillance frequencies once they are relocated out of the TSs.

The licensee stated in its application (Reference 11) that the definition of "Staggered Test Basis" will be relocated from the DAEC TS Section 1.1, "Definitions," since this terminology will be mentioned in only one place in the TSs following adoption of TSTF-425. The definition will be moved to TS Section 5.5.13, "Control Building Envelope Habitability Program," as a footnote.

Surveillances contained in TS 5.5.13 were not the subject of TSTF-425 and are not proposed to be otherwise changed. The licensee states that this change is an administrative deviation from TSTF-425 with no impact on the NRC staff's model safety evaluation (SE). The NRC staff agrees that these changes are acceptable.

In a letter dated September 19,2007 (Reference 3), the NRC staff approved Revision 1 to NEI 04-10 as acceptable for referencing in licensing actions to the extent specified and under the limitations delineated in NEI 04-10, and in the NRC staff's SE providing the basis for its acceptance of NEI 04-10.

The NRC staff issued a Notice of Availability for TSTF-425, Revision 3, in the Federal Register on July 6, 2009 (74 FR 31996). The notice included a model SE. In its application, the licensee stated that "NextEra Energy Duane Arnold has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to DAEC and justify this amendment to incorporate the changes to the DAEC TS." The NRC staff's SE that follows is based, in large part, on the model SE for TSTF-425.

2.0 REGULATORY EVALUATION

In the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," published in the Federal Register on July 22, 1993 (58 FR 39132), the NRC addressed the use of Probabilistic Safety Analysis (PSA, currently referred to as Probabilistic Risk Assessment (PRA)) in Standard Technical Specifications. In discussing the use of PSA in nuclear power plant TSs, the Commission wrote in part:

The Commission believes that it would be inappropriate at this time to allow

- 3 requirements which meet one or more of the first three criteria [of 10 CFR 50.36]1 to be deleted from Technical Specifications based solely on PSA (Criterion 4).

However, if the results of PSA 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 of confidence to be given these [probabilistic]2 estimates and assumptions. This is a key part of the process of determining the degree of regulatory 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."

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 two years later, the NRC provided additional detail concerning the use of PRA in the "Use of Probabilistic Risk Assessment Methods in Nuclear Regulatory Activities; Final Policy Statement," published in the Federal Register on August 16, 1995 (60 FR 42622). The Commission, in discussing the deterministic and probabilistic approach to regulation and the extension and enhancement of traditional regulation, wrote in part:

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.

The Commission provided its new policy, stating:

Although PRA methods and information have thus far been used successfully in nuclear regulatory activities, there have been concerns that PRA methods are not consistently applied throughout the agency, that sufficient agency PRA/statistics expertise is not available, and that the Commission is not deriving full benefit from the large agency and industry investment in the developed risk assessment methods. Therefore, the Commission believes that an overall policy on the use of PRA 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 1 This clarification is not part of the original policy statement.

2 The Federal Register Notice, 58 FR 39135, (Alteration in Original) explains the brackets.

- 4 the scope of PRA applications in all nuclear regulatory matters to the extent supported by the state-of-the-art in terms of methods and data. Implementation of the policy statement will improve the regulatory process in three areas:

Foremost, through safety decision making enhanced by the use of PRA insights; through more efficient use of agency resources; and through a reduction in unnecessary burdens on licensees.

Therefore, the Commission adopts the following policy statement regarding the expanded NRC use of PRA:

(1) The use of PRA technology should be increased in all regulatory matters to the extent supported by the state-of-the-art in PRA methods and data and in a manner that complements the NRC's deterministic approach and supports the NRC's traditional defense-in-depth philosophy.

(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 conservatism 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 10 CFR 50.109 (8ackfit Rule). Appropriate procedures for including PRA in the process for changing regulatory requirements 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 revised.

(3) PRA evaluations in support of regulatory 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 power plant licensees.

The regulatory requirements related to the content of the TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR) 50.36. Pursuant to 10 CFR 50.36, TSs will include items in the following five specific categories related to station operations: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements (SRs); (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 of systems 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 TSs. The new TS associated with the SFCP provides the necessary administrative controls to require that surveillances relocated to the SFCP are conducted at a frequency to assure that the 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. Changes to surveillance frequencies in the SFCP are made using the methodology contained in NEI 04-10, including qualitative considerations, results of

- 5 risk analyses, sensitivity studies and any bounding analyses, and recommended monitoring of structures, systems, and components (SSCs), and are 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 TSs 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 is intended to ensure that SRs specified in 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 Appendix B to 10 CFR Part 50 require licensee monitoring of surveillance test failures and implementation of 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, are intended to 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.

Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk Informed Decisions on Plant-Specific Changes to the Licensing Basis" (Reference 4), describes a risk-informed approach, acceptable to the NRC, for assessing the nature and impact of proposed licensing-basis changes by considering engineering issues and applying risk insights.

This regulatory guide also provides risk acceptance guidelines for evaluating the results of such evaluations.

RG 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications" (Reference 5), describes an acceptable risk-informed approach specifically for assessing proposed TS changes.

RG 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities" (Reference 6), 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 DAEC provides for administrative relocation of applicable surveillance frequencies, and provides for the addition of the SFCP to the

- 6 Administrative Controls section of the TSs. 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. 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 consistent with the guidance provided in RG 1.174 and in RG 1.177 in support of changes to surveillance test intervals.

3.1 RG 1.177, Five Key Safety Principles RG 1.177 identifies five key safety principles required for risk-informed changes to the TSs.

Each of these principles is addressed by the industry methodology document, NEI 04-10, and is evaluated below in Sections 3.1.1 through 3.1.5 with respect to the proposed amendment.

3.1.1 The Proposed Change Meets Current Regulations Paragraph (c)(3) in 10 CFR 50.36 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." NEI 04-10 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 surveillances themselves would remain in the TSs, as required by 10 CFR 50.36(c)(3).

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.

Based on the above considerations, the NRC staff concludes that the 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.

- 7

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.

TSTF-425 requires the application of NEI 04-10 for any changes to surveillance frequencies within the SFCP. NEI 04-10 uses both the core damage frequency (CD F) 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, Based on the above considerations, the NRC staff concludes that both the quantitative risk analysis and the qualitative considerations assure that a reasonable balance of defense-in depth is maintained, Therefore, the proposed change satisfies 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 in accordance 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 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 the TSs), 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.

Based on the above considerations, the NRC staff concludes that there is reasonable assurance that safety margins will be maintained by the proposed methodology, and satisfies the third key safety principle of RG 1,177.

- 8 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 Safety Goal Policy Statement RG 1.177 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. NEI 04-10 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 DAEC PRA must be 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.

RG 1.200 is NRC's developed regulatory guidance for assessing the technical adequacy of a PRA. Revision 2 to RG 1.200 (Reference 6) endorses (with comments and qualifications) the use of the American Society of Mechanical Engineers (ASME) I American Nuclear Society (ANS) RA-Sa-2009, "Addenda to ASME/ANS RA-S-2008 Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications,"

(Reference 7); NEI 00-02, "Probabilistic Risk Assessment Peer Review Process Guidelines,"

(Reference 8); and NEI 05-04, "Process for Performing Follow-on PRA Peer Reviews Using the ASME PRA Standard" (Reference 9). Revision 1 to RG 1.200 had endorsed the internal events PRA standard ASME RA-Sb-2005, "Addenda to ASME RA-S-2002 Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications" (Reference 10). For the internal events PRA, there are no significant technical differences in the standard requirements and, therefore, assessments using the previously endorsed internal events standard are acceptable.

The licensee has performed an assessment of the PRA models used to support the SFCP using the guidance of RG 1.200, Revisions 1 and 2, 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 the standard is required by NEI 04-10 for the internal events PRA, and any identified deficiencies to those requirements are assessed further to determine any impacts to proposed decreases to surveillance frequencies, including the use of sensitivity studies where appropriate.

The Boiling Water Reactor Owner's Group performed a peer review of the DAEC internal events PRA model in December 2007, using the NEI 05-04 PRA peer review process and the ASME PRA Standard ASME RA-Sb-2005, along with the clarifications provided in Regulatory Guide 1.200, Revision 1. The DAEC PRA peer review was a full-scope review of all the technical elements of the internal events, at-power PRA. Also in December 2007, the licensee completed a gap analysis against the ASME PRA Standard RA-Sb-2005 and RG 1.200, Revision 1, to identify potential gaps to Capability Category II of the Standard. The licensee provided open

- 9 gap items for their Internal Events PRA model, Revision 5C, for NRC staff review, in the license amendment request (LAR) submittal (Reference 11).

Subsequently, on June 30, 2011, the licensee completed a DAEC Internal Events PRA model update to Revision 6, to be used for the TSTF-425 application. To support this model update, a focused peer review was completed in March 2011. The focused peer review utilized the ASME/ANS RA-Sa-2009 standard and RG 1.200, Revision 2. The scope of the review included those open gap items provided in the LAR submittal, as well as the additional gap items from the 2007 full scope peer review. The focused peer review included a review of new methods implemented in the model upgrade.

The licensee provided the results of the focused peer review to the NRC staff in its letters dated April 20, and August 15, 2011 (References 12 and 13, respectively). As a result of the focused peer review, many of the open gap items identified in the LAR submittal were closed. The focused peer review team found twelve (12) open gap items that were assessed as not meeting Capability Category II per the ASME/ANS RA-Sa-2009 standard, five of which the licensee addressed and closed after the focused peer review. To assess the technical adequacy of the DAEC Internal Events PRA model for TSTF-425 application, the NRC staff reviewed the remaining seven open gap items for the Revision 6 model to ensure the deficiency, in not meeting Capability Category II, may be addressed and dispositioned for each surveillance frequency per the NEI 04-10 methodology.

The following is the NRC staff's evaluation of the seven remaining open gap items identified for the Revision 6 model (Reference 12).

IE-B3-01A: SR IE-B3 provides requirements for grouping of initiating events. The staff's review finds that loss of bus 1A1, 1A2, 1A3, and 1A4 initiators need to be evaluated separately from the turbine trip initiator. This conclusion is based on a sensitivity study and insights obtained in response to requests for additional information (References 12 and 14). The licensee's sensitivity analysis, performed with the Internal Events PRA model, found the loss of these bus initiators to be a very small contributor to core damage frequency. However, uncertainties need to be fully considered in surveillance test interval evaluations in accordance with NEI 04-10. For these loss-of-bus initiators, uncertainties include the potential of fire resulting, for example, from an electrical fault, with possible event complications other than those assumed in the Internal Events PRA model, as well as the potential of human error resulting in a loss-of-bus initiating event during maintenance or testing. These uncertainties can be considered qualitatively or quantitatively. NEI 04-10 guidance can be used to address this open gap item. Therefore, the NRC staff agrees that this deficiency may be addressed and dispositioned for each surveillance frequency evaluation per the NEI 04-10 methodology.

SY -A5-01 A: SR SY -A5 requires including the effects of both normal and alternate system alignments, to the extent needed for core damage frequency and large early release frequency determination. The peer review commented that no credit is taken in the PRA model for containment venting using an alternate alignment. The licensee noted that without this change in the PRA model, the model is conservative. The NRC staff agrees that not crediting an alternate alignment produces conservative results and thus has no negative impact on risk evaluations associated with this application using NEI 04-10 guidance.

~ 10 ~

SY-C2-01A: SR SY-C2 is related to system documentation. The peer review suggested developing a new system notebook for use of fire water as an alternate injection source. The licensee noted that without crediting fire water injection late in the event, the model is conservative. The NRC staff agrees that not crediting an alternate alignment produces conservative results and thus has no negative impact on risk evaluations for this application using NEI 04-10 guidance.

HR-A1-01A: SR HR-A1 requires, in part, a review of procedures and practices. The licensee states that this observation has no impact since all procedures were reviewed, but the review was simply not documented. The NRC staff agrees that this deficiency has no impact of risk evaluations associated with this application.

HR-A2-01A: SR HR-A2 also requires, in part, a review of procedures and practices. The licensee states that this observation has no impact since all procedures were reviewed, but the review was simply not documented. The NRC staff agrees that this deficiency has no impact on risk evaluations associated with this application.

HR-C1-01A: SR HR-C1 is related to defining human failure events in the PRA model at the appropriate level. The peer review noted some pre-initiator events were reflected at a system level but not at the train level. The licensee's evaluation notes that this modeling uncertainty may have a minor impact on some TSTF-425 applications. The NRC staff agrees that this deficiency may be addressed and dispositioned for each surveillance frequency evaluation in accordance with the NEI 04-10 methodology.

QU-D5a-01A: SR QU-D5a, for Capability Category II, includes SSCs and operator actions that contribute to initiating event frequencies and event mitigation. The focused peer review recommended use of fault trees for support system initiating events to meet Capability Category II. The licensee stated that this SR can be addressed for TSTF-425 applications using sensitivity analysis, qualitative analysis, bounding analysis, or explicit modeling in accordance with theNEI 04-10 guidance. The NRC staff agrees that this deficiency may be addressed and dispositioned for each surveillance 'frequency evaluation per the NEI 04-10 methodology.

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 licensee uses a full-scope PRA model for evaluation of at-power internal events, fires, and seismic events. Since a PRA has not been developed for shutdown conditions, the licensee utilizes guidance provided in NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management." The licensee has analyzed high winds, floods, and other external

- 11 hazards events against the 1975 Standard Review Plan criteria, and will use insights from this evaluation to analyze these hazards.

Based on the above, the NRC staff concludes that 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 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 (i.e., staggered testing or sequential testing) consistent 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 NRC staff concludes that the DAEC 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.

3.1.4.4Assumptions for Time-Related Failure Contributions For SSCs that are normally in a standby mode, the on-demand failure probability of SSCs modeled in typical PRAs may include a standby time-related contribution and cyclic demand related contribution. NEI 04-10 criteria adjust 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 do not support distinguishing between the standby time-related failures and cyclic demand failures, then the change to surveillance frequency is assumed to impact the total failure probability of the SSC, including both standby and cyclic demand contributions. The licensee informed the NRC staff (Reference 13) that they do not explicitly include a separate standby time-related contribution.

As such, the licensee will assume that changes to the surveillance frequency impact the total failure probability of the SSC consistent with NEI 04-10 guidance. 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. Selecting the testing strategy, such as staggered testing, is important in providing monitoring and feedback on performance for surveillance testing intervals and, as noted previously, the licensee will perform quantitative evaluations of the impact of the testing strategy as discussed in NEI 04-10. In addition, 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

- 12 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 NEI 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 NEI 04-10 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 the PRA standard. 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

,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-5 per year for change to CDF, and below 1 E-6 per year for change to LERF, and the total CDF and total LERF must be reasonably shown to be less than 1 E-4 per year and 1 E-5 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

- 13 contribution to cumulative risk from individual changes to surveillance frequencies associated with insignificant risk increases (less than 5E-8 CDF and 5E-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 NRC staff concludes that 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.

Based on the above, the NRC staff concludes that the proposed methodology satisfies the fourth key safety principle of RG 1.177 by assuring that any increase in risk is small and consistent with the intent of the Commission's Safety Goal Policy Statement.

3.1.5 The Impact of the Proposed Change Should Be Monitored Using Performance Measurement Strategies The licensee's adoption of TSTF-425 requires application of NEI 04-10 in the SFCP. NE104-10 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 maintenance rule requirements. The performance monitoring and feedback specified in NEI 04-10 is sufficient to reasonably assure acceptable SSC performance and is consistent with Regulatory Position 3.2 of RG 1.177.

Based on the above, the NRC staff concludes that the fifth key safety principle of RG 1.177 is satisfied.

3.2 Addition of Surveillance Frequency Control Program to Administrative Controls The amendment adds the SFCP to the Administrative Controls section of the DAEC TSs.

Specifically, new T8 5.5.14, "Surveillance Frequency Control Program," reads as follows:

This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

- 14

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of the Surveillance Requirements for which 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,

."Risk-Informed Method for Control of Surveillance Frequencies,"

Revision 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.

The NRC staff concludes that the proposed program is consistent with the model application of TSTF-425, and is therefore acceptable.

3.4 Summary and Conclusions 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 5.5.14 reference 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 section of the TSs.

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.

The regulations in 10 CFR 50.36(c)(3) state that "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 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, NextEra Energy Duane Arnold will

- 15 continue to meet the regulatory requirements of 10 CFR 50.36, and specifically 10 CFR 50.36(c)(3), surveillance requirements.

The NRC staff has reviewed the licensee's proposed relocation of some surveillance frequencies to a new licensee-controlled program, the SFCP, and its proposal to control changes to surveillance frequencies in accordance with the new program. Based on the above considerations, the NRC staff concludes that the proposed amendment is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Iowa State Official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves 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 amendment involves no significant hazards consideration, and there has been no public comment on such finding (76 FR 28474). Accordingly, the amendment meets 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 amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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.

7.0 REFERENCES

1. TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," March 18,2009 (ADAMS Accession No. ML090850642).

2. NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies," April 2007 (ADAMS Accession No. ML071360456).

3. Final Safety Evaluation for Nuclear Energy Institute (!\\lEI) Topical Report (TR) 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies," September 19, 2007, (ADAM Accession No. ML072570267).

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4. Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk Informed Decisions on Plant-Specific Changes to the Licensing Basis," Revision 2, May 2011 (ADAMS Accession No. ML100910006).

5. Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications," Revision 1, May 2011 (ADAMS Accession No. ML100910008).

6. Regulatory Guide 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 2, March 2009 (ADAMS Accession No. ML090410014).

7. ASME/ANS PRA Standard RA-Sa-2009, "Addenda to ASME/AI'JS RA-S-2008, Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications" (ADAMS Accession No. ML092870592).

8. NEI 00-02, "Probabilistic Risk Assessment (PRA) Peer Review Process Guidance,"

Revision 1, May 2006 (ADAMS Accession No. ML061510621).

9. NEI 05-04, "Process for Performing Follow-on PRA Peer Reviews Using the ASME PRA Standard (Internal Events)," Revision 1, December 2007 (ADAMS Accession No. ML073551164).

10. ASME PRA Standard ASME RA-Sb-2005, "Addenda to ASME RA-S-2002, Standard for Probabilistic Risk Assessment for Nuclear Power Plant Application" (ADAMS Accession No. ML061180509).

11. Letter from Christopher R. Costanzo to U.S. NRC, "Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425, Rev. 3)," dated February 23, 2011 (ADAMS Accession No. ML110550570).

12. Letter from Christopher R. Costanzo to U.S. NRC, "Clarification of Information Contained in License Amendment Request (TSCR-120): Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425, Rev. 3)," dated April 20,2011 (ADAMS Accession No. ML111110507).

13. Letter from Peter Wells to U.S. NRC, "Response to Request for Additional Information Related to an Amendment to Adopt Technical Specifications Task Force Traveler TSTF-425, Revision 3, to Relocate Specific Surveillance Frequencies to a Licensee Controlled Program," dated August 15,2011 (ADAMS Accession No. ML11229A184).

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14. Letter from Peter Wells to U.S NRC, "Response to Second Request for Additional Information Related to an Amendment to Adopt Technical Specifications Task Force Traveler TSTF-425, Revision 3, to Relocate Specific Surveillance Frequencies to a Licensee Controlled Program," dated November 1,2011 (ADAMS Accession No. ML113050120).

Principal Contributors: D. O'Neal T. Beltz Date:

February 24, 2012

Mr. Peter Wells February 24, 2012 Vice President Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324-9785

SUBJECT:

DUANE ARNOLD ENERGY CENTER - ISSUANCE OF AMENDMENT RE:

ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER (TSTF-425) TO RELOCATE SPECIFIC SURVEILLANCE FREQUENCIES TO A LICENSEE-CONTROLLED PROGRAM (TAC NO. ME5744)

Dear Mr. Wells:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 280 to Renewed Facility Operating License No. DPR-49 for the Duane Arnold Energy Center. This amendment consists of changes to the Technical Specifications (TSs) and Renewed Facility Operating License in response to your application letter dated February 23, 2011, as supplemented by letters dated April 20, 2011; August 15, 2011; November 1, 2011; and February 3, 2012.

The amendment modifies the TSs by relocating specific surveillance frequencies to a licensee controlled program, the Surveillance Frequency Control Program, based on Nuclear Regulatory Commission-approved TS Task Force (TSTF) TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF [Risk-Informed TSTF] Initiative 5b."

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

Sincerely, IRAJ Terry A. Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-331

Enclosures:

1. Amendment No. 280 to License No. DPR-49

2. Safety Evaluation cc w/encls: Distribution via Ustserv DISTRIBUTION:

PUBLIC LPL3-1 r/f RidsNrrDorlDpr Resource RjdsNrrDorlLpl3-1 Resource RidsAcrsAcnw _MaiICTR Resource RidsNrrLABTully Resource RidsOgcRp Resource RidsNrrDssStsb Resource RidsRgn3MailCenter Resource RGrover, NRR RidsNrrDraApla Resource RidsNrrPMDuaneArnold Resource DONeal, NRR ADAMS Accession No.: ML120110282

via memorandum dated 02/06/2012 OFFICE LPL3-11 PM LPL3-11 LA DRAIAPLAlBC DSS/STSB/BC OGC (NLO w/comments)

LPL3-11 BC DHarrison

RElliott CKanatas SWiliiams TBeltz 02/24/12 02/14112 02/06/12 02/14/12 02/22/12 OFFICIAL RECORD COpy

v t e Letter Sequence Approval
TAC:ME5744, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Approved, Closed)
Initiation Request Acceptance Supplement Administration Questions 3 October 2011 4 October 2011 Answers 15 August 2011 Results Approval Other: ML110890824, ML12037A087, ML120740202
MONTHYEAR2011-03-29 [Table View]

ML120110282

Text

SUBJECT:

Dear Mr. Wells:

Enclosures:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

SUBJECT:

Dear Mr. Wells:

Enclosures:

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