ML18179A467

FENOC-Beaver Valley Power Station, Unit No. 1 and 2; Davis-Besse Nuclear Power Station, Unit 1, and Perry Nuclear Power Plant, Unit 1 - Issuance of Amendments Request to Adopt TSTF-529, Clarify Use and Application Rules

ML18179A467
Person / Time
Site:	Beaver Valley, Davis Besse, Perry
Issue date:	07/30/2018
From:	Bhalchandra Vaidya Plant Licensing Branch III
To:	Moul D FirstEnergy Nuclear Operating Co
Vaidya B
References
CAC MG0133, CAC MG0134, CAC MG0135, CAC MG0136, EPID L-2017-LLA-0259
Download: ML18179A467 (45)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 30, 2018 Mr. Don Moul President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company 341 White Pine Drive Akron, OH 44320

SUBJECT:

FENOC FLEET-BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2; DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1; AND PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - ISSUANCE OF AMENDMENTS RE:

Dear Mr. Moul:

REQUEST TO ADOPT TSTF-529, "CLARIFY USE AND APPLICATION RULES" (CAC NOS. MG0133, MG0134, MG0135, AND MG0136, EPID L-2017-LLA-0259)

The U.S. Nuclear Regulatory Commission (NRC or Commission) has issued the enclosed Amendment No. 303 and Amendment No. 192 to Renewed Facility Operating License No.

DPR-66 and NPF-73 for the Beaver Valley Power Station, Unit Nos. 1 and 2, respectively, Amendment No. 297 to Renewed Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station, Unit No. 1; and Amendment No. 182 to Facility Operating License No.

NPF-58 for the Perry Nuclear Power Plant, Unit No. 1. The amendments are in response to your application dated August 11, 2017.

The amendments revised and clarified the technical specification usage rules for completion times, limiting conditions for operation (LCOs), and surveillance requirements based on Technical Specification Task Force (TSTF) Traveler TSTF 529, "Clarify Use and Application Rules," Revision 4.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

~

• ~

Bhalchandra Vaidya, Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334, 50-412, 50-346, and 50-440

Enclosures:

1. Amendment No. 303 to DPR-66

2. Amendment No. 192 to NPF-73

3. Amendment No. 297 to NPF-3

4. Amendment No. 182 to NPF-58

5. Safety Evaluation cc:

Mr. Ernest J. Harkness Site Vice President FirstEnergy Nuclear Operating Company Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097 Mr. Brian D. Boles Site Vice President FirstEnergy Nuclear Operating Company Mail Stop A-DB-3080 5501 North State, Route 2 Oak Harbor, OH 43449-9760 Additional Distribution via Listserv Mr. Richard D. Bologna Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SSB P.O. Box 4, Route 168 Shippingport, PA 15077

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-334 BEAVER VALLEY POWER STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 303 Renewed Facility Operating License No. DPR-66

1.

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

A.

The application for amendment by FirstEnergy Nuclear Operating Company (the licensee) dated August 11, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

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

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

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

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

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-66 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 303, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Ou 9. "/ ____

David J. Wrona, Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance: July 30, 2018

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-412 BEAVER VALLEY POWER STATION, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 192 Renewed Facility Operating License No. NPF-73

1.

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

A.

The application for amendment by FirstEnergy Nuclear Operating Company (the licensee) dated August 11, 2017, 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 1 ;

B.

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

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

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

The issuance of this amendment is in accordance with 1 O CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-73 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 192, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated into the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

-, c:) c_J o, :)/,.___-*

David J. Wront. Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance: July 30, 2018

ATTACHMENT TO LICENSE AMENDMENT NOS. 303 AND 192 BEAVER POWER STATION, UNITS 1 AND 2 RENEWED FACILITY OPERATING LICENSE NOS. DPR-66 AND NPF-73 DOCKET NOS. 50-334 AND 50-412 Replace the following pages of the Facility Operating License and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment numbers and contain marginal lines indicating the areas of change.

Remove License DPR-66 Page 3 License NPF-73 Page 4 TSs 1.3-1 1.3-2 1.3-3 3.0-1 3.0-4 3.0-5 License DPR-66 Page 3 License NPF-73 Page 4 TSs 1.3-1 1.3-2 1.3-3 3.0-1 3.0-4 3.0-5 (3)

FENOC, pursuant to the Act and

• 10 CFR Parts 30, 40 and 70, to receive, possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)

FENOC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (5)

FENOC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C.

This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1:

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; and 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 FENOC is authorized to operate the facility at a steady state reactor core power level of 2900 megawatts thermal.

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 303:, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3)

Auxiliary River Water System (Deleted by Amendment No. 8)

Beaver Valley Unit 1 Amendment No. 303 Renewed Operating License DPR-66 C.

This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations set forth in 1 O CFR Chapter 1 and 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 FENOC is authorized to operate the facility at a steady state reactor core power level of 2900 megawatts thermal.

(2)

Technical Specifications Beaver Valley Unit 2 The Technical Specifications contained in Appendix A, as revised through Amendment No. 192, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated in the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Amendment No. 192 Renewed Operating License NPF-73

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE BACKGROUND DESCRIPTION The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time States, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Beaver Valley Units 1 and 2 1.3 - 1 Amendments 303/192

1.3 Completion Times DESCRIPTION (continued)

Completion Times 1.3 Completion Times are tracked for each Condition starting from the

• discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent train, subsystem, component, or variable, expressed in the Condition, is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a.

Must exist concurrent with the first inoperability; and

b.

Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a.

The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or

b.

The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery... "

Beaver Valley Units 1 and 2 1.3 - 2 Amendments 303/192

Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)

EXAMPLES by the phrase "from discovery... " Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and Bin Example 1.3-3 may not be extended.

The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION B.

Required Action B. 1 Be in MODE 3.

and associated Completion AND Time not met.

8.2 Be in MODE 5.

COMPLETION TIME 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition Bis entered.

The Required Actions of Condition B are to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />) is allowed for reaching MODE 5 from the time that Condition B was entered. If MODE 3 is reached within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the time allowed for reaching MODE 5 is the next 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> because the total time allowed for reaching MODE 5 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

If Condition B is entered while in MODE 3, the time allowed for reaching MODE 5 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Beaver Valley Units 1 and 2 1.3 - 3 Amendments 303/192

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCO 3.0.2 LCO 3.0.3 LCO 3.0.4 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8.

Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a.

MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />,

b.

MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and

c.

MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or Beaver Valley Units 1 and 2 3.0 - 1 Amendments 303/192

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SR 3.0.2 SR 3.0.3 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per... "

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

If it is discovered that a Surveillance was not performed within its specified Frequency, then'compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

Beaver Valley Units 1 and 2 3.0-4 Amendments 303/192

3.0 SR Applicability SR 3.0.4 SR Applicability 3.0 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

Beaver Valley Units 1 and 2 3.0 - 5 Amend men ts 303/192

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-346 DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 297 Renewed Facility Operating License No. NPF-3

1.

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

A.

The application for amendment by FirstEnergy Nuclear Operating Company (the licensee) dated August 11, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

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

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

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

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

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-3 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 297, are hereby incorporated in the renewed license. FENOC shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION 1 ~\\)

"1

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l' /~l l1 1

./

7 David J. Wrona, Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Dateoflssuance: July 30, 2018

ATTACHMENT TO LICENSE AMENDMENT NO. 297 DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE NO. NPF-3 DOCKET NO. 50-346 Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment numbers and contain marginal lines indicating the areas of change.

Remove License NPF-3 Page L-5 TSs 1.3-1 1.3-2 1.3-3 1.3-4 3.0-1 3.0-4 License NPF-3 Page L-5 TSs 1.3-1 1.3-2 1.3-3 1.3-4 3.0-1 3.0-4

2.C.

This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 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; and 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 FE NOC is authorized to operate the facility at steady state reactor core power levels not in excess of 2817 megawatts (thermal). Prior to attaining the power level, Toledo Edison Company shall comply with the conditions identified in Paragraph (3) (o) below and complete the preoperational tests, startup tests and other items identified in to this license in the sequence specified. Attachment 2 is an integral part of this renewed license.

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 297, are hereby incorporated in the renewed license.

FENOC shall operate the facility in accordance with the Technical Specifications.

(3)

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

(a)

FENOC shall not operate the reactor in operational Modes 1 and 2 with less than three reactor coolant pumps in operation.

(b)

Deleted per Amendment 6 (c)

Deleted per Amendment 5 L-5 Renewed License No. NPF-3 Amendment No. 297

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE BACKGROUND DESCRIPTION Davis-Besse The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the

• Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate 1.3-1 Amendment 297

Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)

Davis-Besse Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent train, subsystem, component, or variable, expressed in the Condition, is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a.

Must exist concurrent with the first inoperability; and

b.

Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a.

The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or

b.

The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery... "

1.3-2 Amendment 297

Completion Times 1.3 1.3 Completion Times EXAMPLES Davis-Besse The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION B. Required Action and associated Completion Time not met.

REQUIRED ACTION COMPLETION TIME B. 1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> B.2 Be in MODE 5.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition Bis entered.

The Required Actions of Condition B are to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />) is allowed for reaching MODE 5 from the time that Condition B was entered. If MODE 3 is reached within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the time allowed for reaching MODE 5 is the next 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> because the total time allowed for reaching MODE 5 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

If Condition Bis entered while in MODE 3, the time allowed for reaching MODE 5 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

1.3-3 Amendment 297

Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

Davis-Besse EXAMPLE 1.3-2 ACTIONS CONDITION A. One pump inoperable.

B. Required Action and associated Completion Time not met.

REQUIRED ACTION COMPLETION TIME A.1 Restore pump to 7 days OPERABLE status.

B.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND B.2 Be in MODE 5.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> When a pump is declared inoperable, Condition A is entered. If the pump is not restored to OPERABLE status within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the inoperable pump is restored to OPERABLE status after Condition Bis entered, Conditions A and Bare exited, and therefore, the Required Actions of Condition B may be terminated.

When a second pump is declared inoperable while the first pump is still inoperable, Condition A is not re-entered for the second pump.

LCO 3.0.3 is entered, since the ACTIONS do not include a Condition for more than one inoperable pump. The Completion Time clock for Condition A does not stop after LCO 3.0.3 is entered, but continues to be tracked from the time Condition A was initially entered.

While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition B. The Completion Time for Condition Bis tracked from the time the Condition A Completion Time expired.

On restoring one of the pumps to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for> 7 days.

1.3-4 Amendment 297

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCO 3.0.2 LCO 3.0.3 LCO 3.0.4 Davis-Besse LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8.

Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a.

MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;.

b.

MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and

c.

MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or 3.0-1 Amendment 297

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SR 3.0.2 SR 3.0.3 SR 3.0.4 Davis-Besse SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per... "

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

3.0-4 Amendment 297

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-440 PERRY NUCLEAR POWER PLANT, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 182 License No. NPF-58

1.

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

A.

The application for amendment by FirstEnergy Nuclear Operating Company (the licensee) dated August 11, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

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

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

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

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

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-58 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 182, are hereby incorporated into the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Uct (j. '" ~

David J. Wrona, Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance: July 30, 2018

A TI ACHMENT TO LICENSE AMENDMENT NO. 182 PERRY NUCLEAR POWER PLANT, UNIT NO. 1 FACILITY OPERATING LICENSE NO. NPF-58 DOCKET NO. 50-440 Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendments number and contain marginal lines indicating the areas of change.

Remove License NPF-58 Page 4 TSs 1.0-11 1.0-12 1.0-13 3.0-2 3.0-4 License NPF-58 Page 4 TSs 1.0-11 1.0-12 1.0-13 3.0-2 3.0-4 C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and 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 FENOC is authorized to operate the facility at reactor core power levels not in excess of 3758 megawatts thermal (100% power) in accordance with the conditions specified herein.

(2)

Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No.-182, are hereby incorporated into the license. FE NOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3)

Antitrust Conditions

a. FirstEnergy Nuclear Generation, LLC Amendment No. '182

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE BACKGROUND DESCRIPTION PERRY - UNIT 1 The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation.

(e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s). In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate (continued) 1.0-11 Amendment No. 182

Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)

PERRY - UNIT 1 Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a.

Must exist concurrent with the first inoperability; and

b.

Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a.

The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or

b.

The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery... " Example 1.3-3 illustrates one use of (continued) 1.0-12 Amendment No. 182

Completion Times 1.3 1.3 Completion Times DESCRIPTION

( continued)

EXAMPLES PERRY - UNIT 1 this type of Completion Time. The 10 day Completion Time specified for Conditions A and Bin Example 1.3-3 may not be extended.

The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION B. Required Action B.1 Be in MODE 3.

and associated Completion AND Time not met.

B.2 Be in MODE 4.

COMPLETION TIME 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition B are to be in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) is allowed for reaching MODE 4 from the time that Condition B was entered. If MODE 3 is reached within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the time allowed for reaching MODE 4 is the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> because the total time allowed for reaching MODE 4 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

If Condition B is entered while in MODE 3, the time allowed for reaching MODE 4 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

(continued) 1.0-13 Amendment No. 182

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0A (continued)

LCO 3.0.5 LCO 3.0.6 PERRY - UNIT 1

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c.

When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS, or that are part of a shutdown of the unit.

Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.10, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

( continued) 3.0-2 Amendment No. 182

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SR 3.0.2 SR 3.0.3 PERRY - UNIT 1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per... "

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only appiicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and _the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued) 3.0-4 Amendment No. 182

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR PLANT-SPECIFIC ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-529, REVISION 4, "CLARIFY USE AND APPLICATION RULES," FOR COMPLETION TIMES, LIMITING CONDITIONS FOR OPERATION, AND SURVEILLANCE REQUIREMENTS RELATED TO AMENDMENT NO. 303 TO BEAVER VALLEY POWER STATION, UNIT NO. 1 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-66 1 DOCKET NO. 50-334, AMENDMENT NO. 192 TO BEAVER VALLEY POWER STATION, UNIT NO. 2 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-73, DOCKET NO. 50-412, AMENDMENT NO. 297 TO DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-3, DOCKET NO. 50-346 AND AMENDMENT NO. 182 PERRY NUCLEAR POWER PLANT, UNIT NO. 1 TO FACILITY OPERATING LICENSE NO. NPF-58, DOCKET NO. 50-440 FIRSTENERGY NUCLEAR OPERATING COMPANY

1.0 INTRODUCTION

By application dated August 11, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17227A172), FirstEnergy Nuclear Operating Company (FENOC, the licensee) submitted a license amendment request for Beaver Valley Power Station, Unit Nos. 1 and 2 (Beaver Valley); Davis-Besse Nuclear Power Station (Davis-Besse);

and Perry Nuclear Power Plant (Perry) (the facilities). The amendments would revise and clarify the technical specification (TS) usage rules for completion times (CTs), limiting conditions for operation (LCOs), and surveillance requirements (SRs) based on Technical Specification Task Force (TSTF) Traveler TSTF-529, "Clarify Use and Application Rules," Revision 4 (ADAMS Accession No. ML16062A271 ).

2.0

=

Background===

Traveler TSTF-529, Revision 4, was approved by the U.S. Nuclear Regulatory Commission (NRC or Commission) by letter dated April 21, 2016 (ADAMS Package Accession No. ML16060A441 ). TSTF-529, Revision 4, modifies the current standard technical specifications (STS}.1 The STS provide guidance on the format and content of TS for each of the light-water reactor (LWR) nuclear steam supply systems. TSTF-529, Revision 4, makes changes to Section 1.3, "Completion Times," LCO 3.0.4, and SR 3.0.3 in each of the STS.

The LCOs specify minimum requirements for ensuring safe operation of the facility. When an LCO is not met, the licensee must shut down the reactor or follow any remedial actions permitted by the TS until the LCO can be met. The TS typically specify one or more conditions for each LCO, which describe the ways in which the LCO is not met. For each stated condition, the TS specify one or more required actions and associated CTs (i.e., remedial actions).

TSTF-529, Revision 4, changes STS Section 1.3 to revise and clarify how the CTs for required actions are implemented.

In each STS, LCO 3.0.1 through 3.0.9 establish the general requirements applicable to all specifications and apply at all times, unless otherwise stated. The STS LCO 3.0.4 specifies the only three situations where it is permissible to enter a mode or other specified condition when an LCO is not met. TSTF-529, Revision 4, changes STS LCO 3.0.4 to clarify that these three situations are independent of each other.

Similarly, in each STS, SR 3.0.1 through 3.0.4 establish the general requirements for surveillances that are applicable to all specifications and apply at all times, unless otherwise stated. The STS SR 3.0.3 allows a licensee to delay declaring an LCO not met, for a specified time period, when it is discovered that an SR was not performed within its specified frequency.

TSTF-529, Revision 4, changes STS SR 3.0.3 to permit its use when it is discovered that an SR was never performed, and to clarify that the delay period may only be used when there is a reasonable expectation that the SR will be met when performed.

1 NUREG-1430, Revision 4.0, "Standard Technical Specifications: Babcock and Wilcox Plants," Volume 1, April 2012 (ADAMS Accession No. ML12100A177); NUREG-1431, Revision 4.0, "Standard Technical Specifications: Westinghouse Plants," Volume 1, April 2012 (ADAMS Accession No. ML12100A222); NUREG-1432, Revision 4.0, "Standard Technical Specifications: Combustion Engineering Plants," Volume 1, April 2012 (ADAMS Accession No. ML12102A165); NUREG-1433, Revision 4.0, "Standard Technical Specifications: General Electric [Boiling-Water Reactor] BWR/4 Plants," Volume 1, April 2012 (ADAMS Accession No. ML12104A192); and NUREG-1434, Revision 4.0, "Standard Technical Specifications: General Electric BWR/6," Volume 1, April 2012 (ADAMS Accession No. ML12104A195).

2.2 Description of TS Changes The changes that TSTF-529, Revision 4, makes to STS Section 1.3, LCO 3.0.4, and SR 3.0.3 are independent of each other and licensees may choose to adopt them separately. For each facility, the licensee proposed to make changes to the TS based on TSTF-529, Revision 4. The licensee's proposed TS changes are described below.

2.2.1 Proposed Changes to TS Section 1.3, "Completion Times" The licensee proposed to revise the first part of the Description in TS Section 1.3 for all facilities to read as follows (added text shown in bold, and deleted text shown in bold strikeout):

The completion time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s} supported by an inoperable diesel generator, inoperable when the redundant required feature(s} are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition 8 concurrent with inoperability of redundant required feature(s}." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

2.2.2 Proposed Changes to LCO 3.0.4 The licensee proposed to change LCO 3.0.4 for all facilities. For Beaver Valley and Perry, LCO 3.0.4 currently states, in part:

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c.

When an allowance is stated in the individual value, parameter, or other Specification.

The LCO 3.0.4 for Davis-Besse is similar, except LCO 3.0.4.b ends with a semicolon followed by "or instead of a comma followed by "or."

The licensee proposed to clarify LCO 3.0.4.b for all facilities by placing the statement regarding exceptions in parenthesis and replacing the ending comma with a semicolon. Note that Davis-Besse had already replaced the ending comma with a semicolon in an earlier amendment. Thus, with the proposed changes, TS LCO 3.0.4.b for all facilities will state:

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate ( exceptions to this Specification are stated in the individual Specifications); or The purpose of these proposed changes is to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent conditions, such that LCO 3.0.4 can be applied when any one of these conditions is met.

2.2.3 Proposed Changes to SR 3.0.3 The licensee proposed changes to SR 3.0.3 for each facility. Currently, SR 3.0.3 allows the licensee to delay declaring an LCO not met for a specified period of time when it is discovered that an SR was not performed within its specified frequency. Currently, the licensee cannot apply SR 3.0.3 to an SR that has never been performed. For all facilities, the licensee requested approval to apply SR 3.0.3 to SRs which have never been performed, and proposed to revise SR 3.0.3 to clarify that the delay period is only applicable when there is a reasonable expectation that the SR will be met when performed.

The licensee proposes to revise the first part of SR 3.0.3 for all facilities to read as follows (added text shown in bold):

2.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

Regulatory Requirements and Guidance Per Title 10 of the Code of Federal Regulations ( 10 CFR), Section 50.36(b ), each license authorizing operation of a utilization facility will include TS. The TS will be derived from the analyses and evaluations included in the safety analysis report, and amendments thereto, submitted pursuant to 10 CFR 50.34 (describing the technical information to be included in applications for an operating license). Pursuant to 10 CFR 50.36(c), TS are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls. The Commission may include such additional TS as it finds appropriate.

The regulations in 10 CFR 50.36(c)(2) establish the requirements for LCOs. LCOs are the lowest functional capability or performance level of equipment required for the safe operation of the facility. When an LCO is not met, the licensee must shut down the reactor or follow any remedial action permitted by the TS until the LCO can be met.

The regulations in 10 CFR 50.36(c}(3) establish the requirements for SRs. SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.

The NRC staff's guidance for review of the TS is in Chapter 16, "Technical Specifications,"

Revision 3, dated March 2010 (ADAMS Accession No. ML100351425), of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:

LWR Edition." As described therein, as part of the regulatory standardization effort, the staff has prepared improved STS (NUREG-1430 through NUREG-1434) for each of the LWR nuclear steam supply systems and associated balance-of-plant equipment systems. The licensee's proposed amendments are based on TSTF-529, Revision 4, which is an NRC-approved change to the current STS. The staff's review includes consideration of whether the proposed changes are consistent with the current STS, as modified by TSTF-529, Revision 4. Special attention is given to TS provisions that depart from the current STS, as modified by NRC-approved TSTF travelers, to determine whether proposed differences are justified by uniqueness in plant design or other considerations so that 10 CFR 50.36 is met.

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the licensee's application in accordance with the regulatory requirements and guidance discussed in Section 2.3 of this safety evaluation (SE). The staff's evaluation of the proposed changes to TS Section 1.3, LCO 3.0.4, and SR 3.0.3 are discussed separately below.

3.1 Changes to TS Section 1.3, "Completion Times" The licensee proposed changes to Section 1.3 of the TS for all facilities.

3.1.1 Changes to "Time of Discovery" In the STS, the only mention of the term "time of discovery" in relation to completion times (CT) is in STS Section 1.3. Throughout the STS, the term "discovery" is used to describe the point in time that it is recognized that the requirements of an LCO are not met. For example, STS LCO 3.0.2 states, in part: "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6." In addition, the STS Bases for LCO 3.0.2 state, in part: "LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met." TSTF-529, Revision 4, deletes "time of' from statements referring to "time of discovery" in STS Section 1.3.

As indicated in Section 2.2.1 of this SE, the licensee proposed changes to TS Section 1.3, for all facilities, which would delete "time of' from statements which refer to "time of discovery." These proposed changes are consistent with TSTF-529, Revision 4. The NRC staff determined that the proposed change makes TS Section 1.3 consistent with the use of the term "discovery" in relation to CTs throughout the rest of the TS. These changes do not alter the requirements currently in the TS, and they clarify the use of the term "discovery" as it applies to TS CTs.

Therefore, the NRC staff finds the proposed changes acceptable.

3.1.2 Addition of Beginning of CT Discussion Traveler TSTF-529, Revision 4, adds the following text to the first paragraph of the Description in STS Section 1.3:

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered.

The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

For all facilities, the licensee has proposed to add text to TS Section 1.3 that is identical to the text above from TSTF-529, Revision 4.

The operating shift crew is responsible for overall control of facility operation. As part of that responsibility, the operating shift crew must be aware of the status of the plant and condition of structures, systems and components, including any degraded or nonconforming conditions that may affect plant operation. Therefore, the proposed change simply augments the NRC staff's expectation that a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and enters the appropriate Condition. The phrase "and an ACTIONS Condition is entered" in the proposed text is necessary to accommodate circumstances in which LCO 3.0.6 allows an LCO to not be met without entry into a Condition. In those circumstances, a CT does not begin. In addition, the example included in the proposed text helps explain the concept presented.

The NRC staff finds the proposed addition of text to the first paragraph of TS Section 1.3 acceptable because it clarifies senior reactor operators' responsibilities, as they relate to Required Actions and associated CTs, and it is consistent with the allowances of LCO 3.0.6.

3.1.3 Addition of "Unless Otherwise Specified" The phrase "unless otherwise specified" in STS Section 1.3, refers to those instances in which TS LCOs define the start of the CT different from "discovery." For example, in the current STS, LCO 3.8.1, Required Action 8.2, calls for declaring required feature(s) supported by an inoperable diesel generator inoperable when the redundant required feature(s) are inoperable.

The CT states: "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case, the CT does not begin until the conditions are satisfied.

As indicated in Section 3.1.2 of this SE, TSTF-529, Revision 4, includes the phrase "unless otherwise specified" in the additional text added to the first paragraph of STS Section 1.3. The added text further discusses the "otherwise specified" exceptions. TSTF-529, Revision 4, also adds the phrase "unless otherwise specified" to the following two sentences in STS Section 1.3 (emphasis added):

1. "When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified."

2. "The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified."

As indicated it Section 2.2.1 of this SE, the licensee proposes to add the phrase "unless otherwise specified" to Section 1.3 of the TS for all facilities. These changes are consistent with TSTF-529, Revision 4.

The addition of the phrase "unless otherwise specified" acknowledges that there are instances, as indicated in the individual TS, when the CT does not start at discovery. These exceptions are varied, such as when a Required Action Note or SR Note provides an alternative time to perform specific tasks, such as testing, without starting the CT. While using the Note, should a Condition be applicable for any reason not addressed by the Note, the CT begins. Should the time allowance in the Note be exceeded, the CT begins at that point.

The NRC staff finds the proposed change acceptable because it clarifies that there are exceptions regarding entry into TS Required Actions and the start of the associated CTs.

3.1.4 Technical Conclusion Regarding Changes to TS Section 1.3 As discussed above, the amendments for all facilities would revise and clarify the TS usage rules for CTs associated with required actions for conditions where an LCO is not met. The NRC staff concludes that the licensee will continue to meet 10 CFR 50.36(c)(2) with the proposed changes because the TS for each of these facilities will continue to specify appropriate remedial actions for the licensee to follow until the LCO can be met.

3.2 Changes to LCO 3.0.4 The STS LCO 3.0.4 specifies the only three situations (LCOs 3.0.4.a, b, and c) where it is permissible to enter a mode or other specified condition when an LCO is not met. In the STS, LCO 3.0.4.a ends with a semicolon and LCO 3.0.4.b ends with a comma followed by "or." The STS LCO 3.0.4.b states:

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or Operators could misapply this statement by believing the "or" applies to the clause regarding exceptions and that LCO 3.0.4.a, b, and c apply concurrently. TSTF-529, Revision 4, clarified this statement in the STS by placing the clause regarding exceptions in parenthesis and replacing the ending comma with a semicolon. The revised STS LCO 3.0.4.b states:

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate ( exceptions to this Specification are stated in the individual Specifications); or The licensee proposed to revise TS LCO 3.0.4.b for all facilities, so that LCO 3.0.4.b for these plants will read the same as above for TSTF-529, Revision 4.

The NRC staff finds the proposed change acceptable because it reduces the potential for misapplication of LCO 3.0.4 and it does not change the current TS requirements for any of the licensee's facilities. Therefore, with the proposed changes to LCO 3.0.4, the requirements in 10 CFR 50.36( c )(2) will continue to be met for all facilities.

3.3 Changes to SR 3.0.3 TSTF-529, Revision 4, revises the interpretation of STS SR 3.0.3 to allow it to be applied to SRs which have never been performed, and revises STS SR 3.0.3 to read as follows (added text shown in bold):

If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

For each facility, the licensee requested approval to apply SR 3.0.3 to SRs which have never been performed and proposed changes to SR 3.0.3 consistent with TSTF-529, Revision 4.

Currently, SR 3.0.3 allows the licensee to delay declaring an LCO not met for a specified period of time when it is discovered that an SR was not performed within its specified frequency. The licensee is not currently permitted to apply SR 3.0.3 to an SR that has never been performed.

This is because the allowance provided by SR 3.0.3 is currently based on the fact that the SR was satisfactorily met in the past and it will most likely be met when performed.

The NRC staff recognizes that there are instances in which an SR may not have been performed in the past, but there is still a reasonable expectation the SR will be met when performed. For example, suppose that a licensee finds a relay contact has never been tested as required by an SR The licensee can determine that there is a reasonable expectation the SR will be met when performed if the subject relay contact has been tested by another SR or historical operation of the subject relay contact has been successful.

For each facility, the licensee stated in the revised TS Bases pages included with the application, that many factors should be considered when determining if there is a reasonable expectation that the SR will be met when performed. The factors identified include, but are not limited to, the period of time since the SR was last performed, whether the SR (or a portion thereof) has ever been performed, and any other indications, tests, or activities that might support the expectation that the SR will be met when performed. The licensee further states:

It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed. For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

The NRC staff finds that the delay period allowed by SR 3.0.3 offers adequate time to complete SRs that have been missed including those that have never been performed. In addition, the proposed change augments plant safety since it could prevent unnecessary shutdowns by providing adequate time to complete SRs that have never been performed but are likely to be met when performed. The staff finds that the proposed change, which expands the scope of SR 3.0.3 to SRs that have never been performed, is acceptable because the licensee must determine that there is a reasonable expectation the SR will be met when performed.

Therefore, with the proposed change to SR 3.0.3, the staff concludes that 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3) will continue to be met at each of the licensee's facilities.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Pennsylvania and Ohio State officials were notified of the proposed issuance of the amendment on June 28, 2018. The State officials had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted areas as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding, which was published in the Federal Register on November 7, 2017 (82 FR 51651), that the amendments involve no significant hazards consideration, and there has been no public comment on such finding.

Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

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

Principal Contributor: C. Tilton, NRR Dateoflssuance:July 30, 2018

ML18179A467 OFFICE NRR/LPL3/PM NRR/LPL3/LA NAME BVaidya SRohrer DATE 7/30/18 7/30/18 OFFICE NRR/LPL3/BC NRR/LPL3/PM NAME DWrona BVaidya DATE 7/30/18 7/30/18 RidsNrrLASRohrer Resource RidsNrrPMBeaver Valley RidsNrrPMDavisBesse BVaidya, NRR RidsOgcRp Resource RidsRgn1 MailCenter C. Tilton, NRR/STSB via email NRR/DSS/STSB/BC VCusumano 7/10/18 OGC NLO BHarris 7/12/18