ML18270A322

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Attachment 1: Description and Evaluation of Technical Specifications Changes
ML18270A322
Person / Time
Site: Palisades 
Issue date: 09/27/2018
From:
Entergy Nuclear Operations
To:
Office of Nuclear Reactor Regulation
Shared Package
ML18270A320 List:
References
PNP 2018-025
Download: ML18270A322 (107)
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Text

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes

1.0 DESCRIPTION

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation 2.2 Variations

3.0 REGULATORY ANALYSIS

3.1 Applicable Regulatory Requirements 3.2 No Significant Hazards Consideration 3.3 Precedent 3.4 Conclusion 4.0 ENVIRONMENTAL EVALUATION

5.0 REFERENCES

106 Pages Follow

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes

1.0 DESCRIPTION

The proposed amendment would modify the Palisades Nuclear Plant (PNP) Renewed Facility Operating License (RFOL) Technical Specifications (TS) by relocating specific surveillance frequencies to a licensee controlled program with the adoption of Technical Specification Task Force (TSTF)-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control-Risk Informed Technical Specification Task Force (RITSTF) Initiative 5b (Reference 2). Additionally, the change would add a new program, the Surveillance Frequency Control Program (SFCP), to TS Section 5, Administrative Controls.

The changes are consistent with United States Nuclear Regulatory Commission (NRC) approved TSTF Standard TS change TSTF-425, Revision 3. The Federal Register notice published on July 6, 2009 (Reference 3) announced the availability of the TS improvement. This request also incorporates the changes to TSTF-425 Traveler recommended by NRC letter, Notification of Issue with NRC-Approved Technical Specifications Task Force (TSTF) Traveler TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5," issued on April 14, 2010 (Reference 4).

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation Entergy Nuclear Operations, Inc. (ENO) has reviewed the Notice of Availability of Technical Specification Improvement To Relocate Surveillance Frequencies to Licensee Control-Risk-Informed Technical Specification Task Force (RITSTF) Initiative 5b, Technical Specification Task Force-425, Revision 3, dated July 6,2009 (Reference 3). This review included a review of the Applicability and the Proposed Safety Evaluation (SE) within the notice and the requirements specified in NEI 04-10, Revision 1, Risk-Informed Technical Specification Initiative 58, "Risk-Informed Method for Control of Surveillance Frequencies" (Reference 1).

Additionally, ENO reviewed the directed augmented SE clarification language documented in Non-Concurrence Process, NCP-2015-012, Amendment No. 171 to Facility Operating License No. NPF-58 for Perry Nuclear Power Plant, dated January 22, 2016 (Reference 5). includes ENO documentation with regard to PNP probabilistic risk assessment (PRA) technical adequacy, consistent with the requirements of Regulatory Guide 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, Revision 2 (Reference 6), Section 4.2, and describes any PRA models without NRC-endorsed standards, including documentation of the quality characteristics of those models in accordance with Regulatory Guide 1.200.

ENO has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff as augmented by NCP-2015-012 are applicable to PNP and justify this amendment to incorporate the changes into the PNP TS.

2.2 Variations The proposed amendment is consistent with the standard technical specifications (STS) changes described in TSTF-425, Revision 3; however, for some PNP TS, ENO is proposing variations from changes described in TSTF-425, NUREG-1432, Standard Technical Page 1 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes Specifications Combustion Engineering Plants (CEOG STS). The variations are necessary for the following reasons:

PNP TS surveillance requirements (SR)s, in some cases, are worded differently than, or not included in, TSTF-425 listed SRs, however, they do meet the TSTF-425 relocation criteria for periodic frequencies (further justification provided below), and therefore will be relocated to the SFCP. They are listed in Table 1 on page 4 of this attachment.

PNP TS section numbering, in some cases, does not exactly match the TSTF-425 section numbering, however these are considered editorial changes and therefore they will be relocated to the SFCP. They are listed in Table 2 on page 60 of this attachment.

PNP's current TS SR, in some cases, do not include the TSTF-425 listed SRs and therefore these TSTF-425 changes are not applicable to PNP. They will not be adopted by PNP and are listed in Table 3 on page 67 of this attachment.

PNP's design, in some cases, varies from other CEOG STS plants and therefore not all STS sections are applicable to PNP. They will not be adopted by PNP and are listed in Table 4 on page 77 of this attachment.

The definition of STAGGERED TEST BASIS is being retained in the PNP TS definition section 1.0 since the terminology is being maintained in the TS SR in Section 5.5.16, Control Room Envelope Habitability Program, which is not the subject of this amendment request and is not proposed to be changed. This is an administrative variation from TSTF-425 with no impact on the NRC staff's model SE within the notice dated July 6, 2009 (Reference 3).

The PNP TS include plant-specific SRs that are not included in TSTF-425. ENO has determined that the relocation of the frequencies for these PNP-specific surveillances is consistent with TSTF-425, Revision 3, and with the NRC staff's model SE within the Notice of Availability, dated July 6,2009 (Reference 3), including the scope exclusions identified in Section 1.0, Introduction, of the model SE, because the plant-specific surveillance frequencies involve fixed period frequencies. Changes to the frequencies for these plant-specific surveillances would be controlled under the SFCP. As noted above they are listed in Table 1 on page 4 of this attachment.

2.2.1 PNP TS Nomenclature Differences from CEOG STS PNP's current TS nomenclature in some cases differs from CEOG STS. The nomenclature conversion table below provides PNP TS equivalent terms to those used in TSTF-425 and CEOG STS.

NOMENCLATURE CONVERSION TABLE TSTF-425 (CEOG STS)

PNPTS Control Element Assembly (CEA)

Control Rod Reactor Coolant System (RCS)

Primary Coolant System (PCS)

Page 2 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes NOMENCLATURE CONVERSION TABLE TSTF-425 (CEOG STS)

PNPTS Remote Shutdown System Alternate Shutdown System Refueling Water Tank (RWT)

Safety Injection Refueling Water Tank (SIRWT)

Main Feedwater Isolation Valve (MFIV)

Main Feedwater Regulating Valve (MFRV)

Control Room Emergency Air Cleanup Control Room Ventilation (CRV) Filtration System (CREACS)

Control Room Emergency Air Temperature Control Room Ventilation (CRV) Cooling Control System (CREATCS)

Fuel Storage Pool Spent Fuel Pool (SFP)

Some of the TSTF-425 SRs and PNP TS SRs contain notes. These notes are not repeated in the variation tables that follow because they have no significance regarding the relocation of SR frequencies from the PNP TS to a SFCP, which is the purpose of TSTF-425 and this license amendment request (LAR).

2.2.2 PNP Site Specific TS Surveillance Requirements PNP TS SRs, in some cases, are worded differently than, or not included in, TSTF-425 listed SRs, however, they meet the TSTF-425 relocation criteria for periodic frequencies and therefore will be relocated to the SFCP. They are listed in Table 1 below.

Page 3 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

SR 3.1.4.1 FREQUENCY Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fol/owing any CEA movement of> [7 inches}

AND

[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> PNP TS FREQUENCY only includes the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> statement PNPTS SR 3.1.4.1 FREQUENCY 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> PNP proposes to adopt the TSTF-425, however, it will retain the PNP TS SR Frequency wording that excludes the following TSTF-425 words, Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fol/owing any CEA movement of>

[7 inches}

AND This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

TSTF-425 and STS do not include a SR to SR 3.1.4.2 perform a channel check on CEAs.

Perform a CHANNEL CHECK of the control rod position indication channels.

PNP proposes to apply TSTF-425 to this SR by replacing the frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with In accordance with the surveillance frequency control program. This is acceptable because a channel check is another method to ensure control rod position indication remains operable similar to other SRs contained in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 4 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

SR 3.1.4.3 Verify the CEA deviation circuit is OPERABLE.

SR 3.1.4.5 PNPTS SR 3.1.4.4 Verify the rod position deviation alarm is OPERABLE.

PNP proposes to adopt the TSTF-425 change however it will retain the current TSs wording and relocate the current frequency to a SFCP because this SR is a plant specific previously approved variance.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.1.4.5 Perform a CHANNEL FUNCTIONAL TEST Perform a CHANNEL CAL/BRA TION of the of the reed switch position transmitter channel.

SR 3.1.6.1 Verify each regulating CEA group position is within its insertion limits.

control rod position indication channels.

PNP performs a channel calibration in lieu of a channel functional test for both primary control rod position indication (syncros outputs) and secondary indication (reed stack switches). This is considered an equivalent test to verify control rod position indication operability.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.1.6.1 Verify each regulating rod group is within its withdrawal sequence, overlap, and insertion limits.

PNP's TS SR further defines the CEOG STS The CEOG STS requirement is specific to requirement as it applies to PNP.

insertion limits only.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 5 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS TSTF-425 and CEOG STS do not include 3.1.6.3 a SR to verity that the Control Rod Out of Sequence (CROOS) circuit is operable.

Verify GROOS alarm circuit is OPERABLE.

SR 3.1.8.1 Verify THERMAL POWER is equal to or less than the test power plateau.

Verification of the CROOS alarm circuit is an acceptable deviation from TSTF-425 because it provides added assurance that control rod sequencing is maintained when more than one group of controls are being moved, thus ensuring proper control rod group overlap by alerting the operators that a group of control rods are not moving as expected. This is acceptable because verification of control rod group sequencing alarm circuit operability is similar to other control rod position verification SR's contained in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.1.7.1 Verify THERMAL POWER is :s 2% RTP.

PNP TS SR verifies that RTP is within a numerical limit versus verification of the test power plateau. These terms provide an equivalent limit and therefore this deviation is acceptable.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 6 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS TSTF-425 and CEOG STS do not include SR 3.1.7.2 a SR to verify T ave is ? 500°F.

TSTF-425 and CEOG STS do not include a SR to verify? 1 % shutdown reactivity is available for trip insertion.

Verify Tave is.2:. 5000F.

PNP TS SR provides a numerical limit of reactor coolant average temperature during low power physics testing. This limit ensures that Tave remains in an analyzed range during physics tests. The TS basis frequency justification has a similar basis to the RTP SR frequency basis which is included in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.1.7.3 Verify ~ 1 % shutdown reactivity is available for trip insertion.

PNP TS SR provides a numerical limit for shutdown reactivity during low power physics testing. This limit ensures that sufficient shutdown reactivity is available for trip insertion during physics tests. The TS basis frequency justification has a similar basis to the RTP SR frequency basis which is included in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 7 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

TSTF-425 and CEOG STS do not include a SR to verify linear heat rate (LHR) is within the limits specified in the COLR.

SR 3.2.1.2 Verify incore detector local power density alarms satisfy the requirements of the core power distribution map, which shall be updated at least once per 31 days of accumulated operation in MODE 1.

TSTF-425 and CEOG STS do not include a SR to verify THERMAL POWER is less than the allowed power limit (APL) when using excores for monitoring linear heat rate.

PNPTS SR 3.2.1.1 Verify LHR is within the limits specified in the COLR.

PNP TS SR provides an option to use incores for monitoring LHR when excore detectors are not available. This surveillance is similar to incore detector surveillances.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.2.1.2 Adjust incore alarm setpoints based on a measured power distribution.

PNP TS SR frequency applicability is "Prior to operation> 50% RTP after each fuel loading" which is similar to the CEOG STS note 2 and is retained. Adjusting incore alarm setpoints based on measured power distribution is equivalent to satisfying the requirements of the core power distribution map.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.2.1.4 Verify THERMAL POWER is less than the APL.

PNP's TS SR verification that thermal power is less that the allowed power limit (APL) is similar to TSTF-425 and CEOG STS SRs that impose SRs when using excores to monitor LHR.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 8 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS TSTF-425 and CEOG STS do not include SR 3.2.1.5 a SR to verify axial shape index (ASI) is within the target ASI when using excores Verify measured ASI is within 0.05 of target ASI.

for monitoring linear heat rate.

PNP's TS SR verification that ASI is within the target ASI to ensure Excores are acceptable for monitoring LHR is similar to TSTF-425 and CEOG STS SRs that that impose SRs when using Excores to monitor LHR.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

TSTF-425 and CEOG STS do not include SR 3.2.1.6 a SR to verify QUADRANT POWER TILT (Tq) is within limits when using excores for Verify Tq 5'0.03.

monitoring linear heat rate.

SR 3.2.3.1 (Analog)

Verify the value of F/.

PNP's TS SR verification that Tq is within limits to ensure Excores are acceptable for monitoring LHR is similar to TSTF-425 and CEOG STS SRs that impose SRs when using Excores to monitor LHR.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.2.2.1 Verify FRT is within limits specified in the COLR.

PNP TS SR frequency requires the SR be performed prior to > 50% RTP versus the CEOG STS requirement of > 70% and uses the term effective full power days (EFPD) versus 31 days of accumulated operation in MODE 1.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 9 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.2.4.1 (Analog)

Verify Tq is within limits.

SR 3.3.1.1 (Analog)

Perform a CHANNEL CHECK of each RPS instrument channel except Loss of Load.

SR 3.2.3.1 Verify Tq is ~O.05.

PNP TS SR is numbered differently and has the numerical value for Tq listed versus stating within limits.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.3.1.1 Perform a CHANNEL CHECK.

PNP TS SR excludes a channel check for loss of load by not listing SR 3.3.1.1 in Table 3.3.1-1 in the SR column.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

TSTF-425 and CEOG STS do not include SR 3.3.1.2 a SR that verifies control room temperature.

Verify control room temperature is ~90°F.

PNP TS SR includes a control room, temperature limit to support RPS instrumentation operability.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 10 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNPTS SR 3.3.1.4 (Analog)

SR 3.3.1.5 Perform a CHANNEL FUNCTIONAL TEST Perform a CHANNEL FUNCTIONAL TEST and of each RPS channel except Loss of Load verify the Thermal Margin Monitor Constants.

and Power Rate of Change.

SR 3.3.1.5 (Analog)

Perform a CHANNEL CAL/BRA TlON on excore power range channels.

PNP TS SR excludes loss of load channel functional check by not listing the SR 3.3.1.5 in Table 3.3.1-1 for Loss of Load and High Startup Rate Trip (Power Rate of Change). Additionally, PNP adds a requirement to verify the thermal margin monitor constants for each RPS channel which is similar to other RPS functional tests.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.3.1.6 SURVEILLANCE Perform a calibration check of the power range excore channels with a test signal.

PNP TS SR performs a calibration check using an internal test circuit to verify that neither the zero point nor the amplifier gain adjustment have undergone excessive drift. This is performed at the listed frequency in lieu of the TSTF-425 channel calibration. This calibration check is similar to a channel calibration and to other TSTF-425 RPS SRs.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 11 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.3.1.8 (Analog)

Perform a CHANNEL CAL/BRA TlON of each RPS instrument channel, including bypass removal functions.

SR 3.3.3.2 (Analog)

SR 3.3.1.8 Perform a CHANNEL CAL/BRA TION.

PNP TS SR includes the bypass removal functions by listing the SR 3.3.1.8 in Table 3.3.1-1 for those RPS instrument channels that have a function that includes bypass removal. The PNP TS SR wording is equivalent to TSTF-425 SR 3.3.1.8.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.3.2.1 Perform a CHANNEL FUNCTIONAL TEST Perform a CHANNEL FUNCTIONAL TEST on on each RPS Logic channel.

each RPS Matrix Logic channel and each RPS Trip Initiation Logic channel.

PNP TS SR combine the TSTF-425 STS RPS Logic (SR 3.3.3.2) and the RTCB (SR 3.3.3.2) channel functional tests into one PNP TS SR 3.3.2.1 which tests both the RPS Logic (RPS Matrix Logic) and the RTCB (RPS Trip Initiation Logic) channels at a frequency of 92 days. This previously approved SR wording is similar to TSTF-425 CEOG STS SR wording for SR 3.3.3.1 and SR 3.3.3.2.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 12 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.3.4.1 (Analog)

Perform a CHANNEL CHECK of each ESFAS instrument channel.

Engineered Safety Features Actuation System (ESFAS)

SR 3.3.4.2 (Analog)

SR 3.3.3.1 Perform a CHANNEL CHECK.

PNP TS SR does not include the TSTF-425 CEOG STS wording "of each ESFAS instrument channel." This is an editorial change and therefore this deviation is acceptable.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.3.3.2 Perform a CHANNEL FUNCTIONAL TEST Perform a CHANNEL FUNCTIONAL TEST.

of each ESFAS instrument channel.

PNP TS SR list each ESFAS instrument channel in Table 3.3.3-1 that SR 3.3.3.2 applies to as stated in the note prior to the SRs. The PNP SR does not include the TSTF-425 CEOG STS wording "of each ESFAS instrument channel."

PNP's TS SR wording is equivalent with TSTF-425 wording.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 13 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.3.4.4 (Analog)

Perform a CHANNEL CALIBRATION of each ESFAS instrument channel, including bypass removal functions.

SR 3.3.3.3 Perform a CHANNEL CALIBRA TION.

PNP TS SR lists each ESFAS instrument channel in Table 3.3.3-1 that SR 3.3.3.3 applies to as stated in the note prior to the SRs and includes each automatic bypass removal

. function. PNP SR 3.3.3.3 does not include the TSTF-425 CEOG STS wording "of each ESFAS instrument channel, including bypass removal functions."

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 14 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.3.5.1 (Analog)

SR 3.3.4.1 Perform a CHANNEL FUNCTIONAL TEST Perform functional test of each SIS actuation channel on each ESFAS logic channel.

normal and standby functions.

SR 3.3.4.2 Perform a CHANNEL FUNCTIONAL TEST of each AFAS actuation logic channel.

SR 3.3.4.3 Perform a CHANNEL FUNCTIONAL TEST.

PNP TS SRs 3.3.4.1,3.3.4.2, and 3.3.4.3 all require channel functional testing of both the ESF actuation logic and manual initiation functions that are listed in Table 3.3.4-1. When combined, these PNP TS SRs are equivalent to the TSTF-425 CEOG STS SRs 3.3.5.1 and 3.3.5.2, which separate logic testing and manual trip testing, respectively.

SR 3.3.4.1, SIS actuation functional testing, was listed as a separate PNP TS SR because the actuation logic is unique when compared to other actuation systems in that it has a normal power supply function and a standby power supply function.

SR 3.3.4.2, auxiliary feedwater actuation signal (AFAS) actuation logic functional testing, was listed as a separate PNP TS SR because the AFAS actuation system has installed test circuits for functional testing which is unique to this system.

SR 3.3.4.3, channel functional testing, applies to the remaining PNP ESF logic and manual initiation functions listed in Table 3.3.4-1.

Therefore PN P TS SRs 3.3.4.1, 3.3.4.2, and 3.3.4.3 combined wording is equivalent to TSTF-425 CEOG STS SR 3.3.5.1 and 3.3.5.2 wording.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 15 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.3.5.2 (Analog)

SR 3.3.4.1 Perform a CHANNEL FUNCTIONAL TEST Perform functional test of each SIS actuation channel on each ESFAS Manual Trip channel.

normal and standby functions.

SR 3.3.4.2 Perform a CHANNEL FUNCTIONAL TEST of each AFAS actuation logic channel.

SR 3.3.4.3 Perform a CHANNEL FUNCTIONAL TEST.

Perform functional test of each SIS actuation channel normal and standby functions.

PNP TS SRs 3.3.4.1, 3.3.4.2, and 3.3.4.3 all require channel functional testing of both the ESF actuation logic and manual initiation functions that are listed in Table 3.3.4-1. When combined, these PNP TS SRs are equivalent to the TSTF-425 CEOG STS SRs 3.3.5.1 and 3.3.5.2, which separate logic testing and manual trip testing, respectively.

SR 3.3.4.1, SIS actuation functional testing, was listed as a separate PNP TS SR because the actuation logic is unique when compared to other actuation systems in that it has a normal power supply function and a standby power supply function.

SR 3.3.4.2, auxiliary feedwater actuation signal AFAS, was listed as a separate PNP TS SR because the AFAS actuation system has installed test circuits for functional testing which is unique to this system.

SR 3.3.4.3, channel functional testing, applies to the remaining PNP ESF logic and manual initiation functions listed in Table 3.3.4-1.

Therefore PNP TS SRs 3.3.4.1, 3.3.4.2, and 3.3.4.3 combined wording is equivalent to TSTF-425 CEOG STS SR 3.3.5.1 and 3.3.5.2 wording.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 16 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.3.6.2 (Analog)

SR 3.3.5.1 Perform CHANNEL FUNCTIONAL TEST.

Perform a CHANNEL FUNCTIONAL TEST on each DG-UV start logic channel.

SR 3.3.6.3 (Analog)

Perform CHANNEL CAL/BRA TION with set point Allowable Values as follows:

a.
b.

Degraded Voltage Function

~ [3180] V and~ [3220] V Time delay: ~ [ ] seconds and

~

[ ] seconds at [ ] V and Loss of Voltage Function ~ [3180] V PNP TS SR includes the additional clarifying wording, "on each DG-UV start logic channel."

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.3.5.2 Perform CHANNEL CAL/BRA TlON on each Loss of Voltage and Degraded Voltage channel with setpoints as follows:

a.

Degraded Voltage Function ~ 2187 Vand

~2264 V Time delay: ~ 0.5 seconds and

~ 0.8 seconds; and and ~ [3220] V

b.

Loss of Voltage Function ~ 1780 Vand

~ 1940 V Time delay: ~ [ ] seconds and ~

[ ] seconds at [ ] V.

Time delay: ~ 5.45 seconds and

~ 8. 15 seconds at 1400 V.

PNP TS SR includes the additional clarifying wording, "on each Loss of Voltage and Degraded Voltage channel," and excludes TSTF-425 CEOG STS wording "Allowable Values."

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 17 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

SR 3.3.8.1 (Analog)

Perform a CHANNEL CHECK on the required control room radiation monitor channel.

SR 3.3.8.3 (Analog)

PNPTS SR 3.3.6.1 Perform a CHANNEL CHECK of each refueling CHR monitor channel.

PNP TS SR is specific to refueling containment high radiation monitor channels that automatically place control room HVAC in emergency mode, close containment isolation valves should a high radiation setpoint be reached on the monitors located in containment during movement of irradiated fuel assemblies. The CHR monitor channel is similar to the TSTF-425 CEOG STS "control room radiation monitor channel."

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.3.6.2 Perform a CHANNEL FUNCTIONAL TEST Perform a CHANNEL FUNCTIONAL TEST of on the required CRIS Actuation Logic channel.

each refueling CHR monitor channel.

PNP TS SR is specific to refueling containment high radiation monitor channels that automatically place control room HVAC in emergency mode, close containment isolation valves should a high radiation setpoint be reached on the monitors located in containment during movement of irradiated fuel assemblies. The CHR monitor channel is similar to the TSTF-425 CEOG STS wording "CRIS Actuation Logic channel."

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.3.8.4 (Analog)

Perform a CHANNEL CAL/BRA TlON on the required CRIS radiation monitor channel.

SR 3.3.8.5 (Analog)

SR 3.3.6.4 Perform a CHANNEL CAL/BRA TION of each refueling CHR monitor channel.

PNP TS SR is specific to refueling containment high radiation monitor channels that automatically place control room HVAC in emergency mode, close containment isolation valves should a high radiation setpoint be reached on the monitors located in containment during movement of irradiated fuel assemblies. The CHR monitor channel wording is similar to the TSTF-425 CEOG STS "CRIS radiation monitor channeL" This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.3.6.3 Perform a CHANNEL FUNCTIONAL TEST Perform a CHANNEL FUNCTIONAL TEST of on the required CRIS Manual Trip channel.

each CHR Manual Initiation channel.

PNP TS SR is specific to refueling containment high radiation monitor channels that automatically place control room HVAC in emergency mode, close containment isolation valves should a high radiation setpoint be reached on the monitors located in containment during movement of irradiated fuel assemblies. The CHR manual initiation channel is similar to the TSTF-425 CEOG STS wording "CRIS Manual Trip channeL" This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS TSTF-425 and CEOG STS do not include SR 3.3.10.1 a SR associated with Engineered Safeguards Room Ventilation (ESRV).

Perform a CHANNEL CHECK.

PNP TS includes SRs associated with ESRV instrumentation which isolates room ventilation upon reaching a high radiation setpoint on an ESRV radiation monitor.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

TSTF-425 and CEOG STS do not include SR 3.3.10.2 a SR associated with Engineered Safeguards Room Ventilation (ESRV).

Perform a CHANNEL FUNCTIONAL TEST.

PNP TS includes SRs associated with ESRV instrumentation which isolates room ventilation upon reaching a high radiation setpoint on an ESRV radiation monitor.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

TSTF-425 and CEOG STS do not include SR 3.3.10.3 a SR associated with Engineered Safeguards Room Ventilation (ESRV).

Perform a CHANNEL CAL/BRA TION.

Very high radiation set point on each ESRV instrumentation radiation monitoring channel is

5. 2.2E+5 cpm.

PNP TS includes SRs associated with ESRV instrumentation which isolates room ventilation upon reaching a high radiation setpoint on an ESRV radiation monitor.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

SR 3.4.1.1 Verify pressurizer pressure ~ [2025] psia and S. [2275] psia.

SR 3.4.1.2 PNPTS SR 3.4.1.1 Verify pressurizer pressure within the limits specified in the COLR.

PNP TS SR does not list pressurizer limits.

Instead it references the COLR where PNP pressurizer limits are now listed.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.4.1.2 Verify RCS cold leg temperature ~ [535fF Verify PCS cold leg temperature within the limit and s..I558fF for < [70]% RTP or ~ [544fF specified in the COLR.

and s..I558fF for ~ [70]% RTP.

SR 3.4.1.4 Verify by precision heat balance that RCS total flow rate within limits specified in the COLR.

PNP TS SR does not list PCS cold leg temperature limits. Instead it references the COLR where PNP cold leg temperature limits are now listed.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.4.1.3 Verify PCS total flow rate within the limit specified in the COLR.

PNP TS SR does not include the TSTF-425 CEOG STS wording "by precision heat balance."

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.4.3.1 Verify Res pressure, ReS temperature, and ReS heatup and cooldown rates within limits specified in the PTLR.

SR 3.4.5.1 Verify one Res loop is in operation.

SR 3.4.5.3 Verify correct breaker alignment and indicated power available to each required pump.

SR 3.4.3.1 Verify pes pressure, pes temperature, and pes heatup and cooldown rates are within the limits of Figure 3.4.3-1 and Figure 3.4.3-2.

PNP TS SR does not include a pressure and temperature limits report (PTLR), instead the limits are on figures included in the TS section.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.4.5.1 Verify required pes loop is in operation.

PNP TS SR uses the word "required" PCS loop versus "one" RCS loop as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.4.5.3 Verify correct breaker alignment and indicated power available to the required primary coolant pump that is not in operation.

PNP TS SR uses the words "each required primary coolant pump that is not in operation,"

versus "each required pump," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.4.6.1 Verify required RCS loop or SOC train is in operation.

SR 3.4.6.3 Verify correct breaker alignment and indicated power available to each required pump.

SR 3.4.6.1 Verify one SOC train is in operation with

? 2810 gpm flow through the reactor core, or one PCS loop is in operation.

The PNP TS SR clarifies the requirements for a shutdown cooling (SOC) train in operation by adding the words "with ~ 2810 gpm flow through the reactor core." This minimum flow requirement ensures operators have sufficient time to terminate a boron dilution under asymmetric flow conditions.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.4.6.3 Verify correct breaker alignment and indicated power available to the required pump that is not in operation.

PNP TS SR uses the words "the required pump that is not in operation," versus "each required pump," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.4.7.1 Verify required SOC train is in operation.

SR 3.4.7.3 Verify correct breaker alignment and indicated power available to each required SOC pump.

SR 3.4.7.1 Verify one SOC train is in operation with

,? 281 0 gpm flow through the reactor core.

The PNP TS SR clarifies the requirements for a SOC train in operation by adding the words "with

~ 2810 gpm flow through the reactor core." This minimum flow requirement ensures operators have sufficient time to terminate a boron dilution under asymmetric flow conditions.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.4.7.3 Verify correct breaker alignment and indicated power available to the required SOC pump that is not in operation.

PNP TS SR uses the words "the required pump that is not in operation," versus "each required pump," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.4.8.1 Verify required SOC train is in operation.

SR 3.4.8.1 Verify one SOC train is in operation with

,?2810 gpm flow through the reactor core.

The PNP TS SR clarifies the requirements for a SOC train in operation by adding the words "with

~ 2810 gpm flow through the reactor core." This minimum flow requirement ensures operators have sufficient time to terminate a boron dilution under asymmetric flow conditions.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

TSTF-425 CEOG STS do not include a SR SR 3.4.8.2 that clarifies required RCS flow when SOC is in operation.

Verify one SOC train is in operation with'? 650 gpm flow through the reactor core.

The PNP TS SR is a second clarification of the requirements for a SOC train in operation by adding the words "with ~ 650 gpm flow through the reactor core." This lower (lower than 2810 gpm in SR 3.4.8.1) minimum flow requirement, is applicable when two of three charging pumps are incapable of reducing boron concentration, which still ensures operators have sufficient time to terminate a boron dilution under asymmetric flow conditions.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS TSTF-425 CEOG STS do not include a SR SR 3.4.8.3 that clarifies required RCS flow when SOC is in operation.

Verify two of three charging pumps are incapable of reducing the boron concentration in the PCS below the minimum value necessary to maintain the required SHUTDOWN MARGIN.

SR 3.4.8.2 Verify correct breaker alignment and indicated power available to each required SOC pump.

This PNP TS SR supports SR 3.4.8.2 above by ensuring two of three charging pumps are incapable of reducing boron concentration in the PCS when flows less than 2810 gpm and

~ 650 gpm are allowed. This verification requirement during lower PCS flow periods ensures operators have sufficient time to terminate a boron dilution under asymmetric flow conditions. This is an additional clarification that does not change the intent of the CEOG STS SR.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.4.8.4 Verify correct breaker alignment and indicated power available to the SOC pump that is not in operation.

PNP TS SR uses the words "to the SOC pump that is not in operation," versus "each required SOC pump," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.4.9.2 Verify capacity of each required group of pressurizer heaters 2: [150J kW.

SR 3.4.9.3 Verify required pressurizer heaters are capable of being powered from an emergency power supply.

SR 3.4.9.2 Verify the capacity of pressurizer heaters from electrical bus 10J and electrical bus 1 E is

?375kW.

PNP TS SR clarifies the required pressurizer heaters by using the words "pressurizer heaters from electrical bus 1 DJ and electrical bus 1 E is

~ 375 kW," versus "each required group of pressurizer heaters 2: [150J kW," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.4.9.3 Verify the required pressurizer heater capacity from electrical bus 1 E is capable of being powered from an emergency power supply.

PNP TS SR clarifies the required pressurizer heaters by using the words "capacity from electrical bus 1 E," versus "required pressurizer heaters," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.4.11.2 Perform a complete cycle of each PORV.

SR 3.4.12.1 Verify a maximum of one HPSI pump is capable of injecting into the RCS.

SR 3.4.11.2 Perform a complete cycle of each PORV with PCS average temperature> 200 of.

PNP TS SR clarifies the required temperature when a complete cycle of each PORV is required which is an addition to the requirements stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.4.12.1 Verify both HPSI pumps are incapable of injecting into the PCS.

PNP TS SR is modified from CEOG STS by requiring both high pressure safety injection (HPSI) pumps to be verified incapable of injecting into the PCS and by a note stating that it is only required to be met when L TOP LCO 3.4.12.a is required to be met. This is in addition to the requirements stated in TSTF-425 and required at PNP to ensure that mass injection transients beyond the capability of the low temperature over pressure (L TOP) overpressure protection system do not occur.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.4.12.4 Verify required ReS vent ~ [1.3J square inches is open.

SR 3.4.14.1 SURVEILLANCE Verify leakage from each ReS PIV is equivalent to S. 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an ReS pressure ~ [2215J psia and S. [2255J psia.

SR 3.4.12.2 Verify required pes vent, capable of relieving

~ 167 gpm at a pes pressure of 315 psia, is open.

PNP TS SR is modified from CEOG STS by requiring a minimum relief capacity in gallons per minute as a specific pressure versus a vent opening minimum area. This is a clarification to the area requirements in TSTF-425 because opening area by itself may not provide the required vent capacity due to piping configuration.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.4.14.1 SURVEILLANCE Verify leakage from each pes PIV is equivalent to S. 5 gpm at a pes pressure of 2060 psia.

PNP TS SR is modified from CEOG STS by specifying PCS pressure at which < 5 gpm leakage is required and the notes further clarify an acceptable leak rate for the PIVs under test conditions. PNP's frequency is also slightly modified by omitting, "in accordance with the Inservice Testing Program," because the test frequency is stated in the SR.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.4.14.2 Verify SOC System autoc/osure interlock prevents the valves from being opened with a simulated or actual RCS pressure signal,::: [425J psig.

SR 3.4.14.2 Verify each SOC suction valve interlock prevents its associated valve from being opened with a simulated or actual PCS pressure signal

,::: 280 psia.

PNP TS SR uses the words "SOC suction valve interlock" versus "SOC System autoclosure interlock," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

TSTF-425 CEOG STS do not include a SR SR 3.4.15.1 to perform a channel check of the required containment sump level indicator.

Perform CHANNEL CHECK of the required containment sump level indicator.

PNP TS SR includes a channel check of the required containment sump level indicators use to monitor for PCS leakage. While not listed in TSTF-425, its frequency requirement of once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is consistent with TSTF-425 listed frequencies that have moved to a SFCP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 30 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

SR 3.4.15.1 Perform CHANNEL CHECK of the required containment atmosphere radioactivity monitor.

TSTF-425 and CEOG STS do not include a SR to perform a channel check of the required containment atmosphere humidity monitor.

PNPTS SR 3.4.15.2 Perform CHANNEL CHECK of the required containment atmosphere gaseous activity monitor.

PNP TS SR uses the words "containment atmosphere gaseous activity monitor," versus "containment atmosphere radioactivity monitor,"

as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.4.15.3 Perform CHANNEL CHECK of the required containment atmosphere humidity monitor.

PNP TS SR includes a channel check of the required containment atmosphere humidity monitor use to detect PCS leakage. While not listed in TSTF-425, its frequency requirement of once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is consistent with TSTF-425 listed frequencies that have moved to a SFCP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 31 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS TSTF-425 and CEOG STS do not include a SR to perform a channel functional test of the required containment air cooler condensate flow rate monitor.

SR 3.4.15.4 Perform CHANNEL FUNCTIONAL TEST of the required containment air cooler condensate level switch.

PNP TS SR includes a channel functional test of the required containment air cooler condensate level switch used to detect PCS leakage. While not listed in TSTF-425, its frequency requirement of once per 18 months is consistent with TSTF-425 listed frequencies that have moved to a SFCP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.4.15.3 SR 3.4.15.5 Perform CHANNEL CAL/BRA TlON of the Perform CHANNEL CAL/BRA TION of the required containment sump monitor.

required containment sump level indicator.

PNP TS SR uses the words "sump level indicator," versus "sump monitor," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 32 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.4.15.4 Perform CHANNEL CAL/BRA T/ON of the required containment atmosphere radioactivity monitor.

SR 3.4.15.6 Perform CHANNEL CAL/BRT/ON of the required containment atmosphere gaseous activity monitor.

PNP TS SR uses the words "containment atmosphere gaseous activity monitor," versus "containment atmosphere radioactivity monitor,"

as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

TSTF-425 CEOG STS do not include a SR SR 3.4.15.7 to perform a channel calibration of the required containment atmosphere humidity Perform CHANNEL CAL/BRA TlON of the monitor.

required containment atmosphere humidity monitor.

PNP TS SR includes a channel check of the required containment atmosphere humidity monitor use to detect PCS leakage. While not listed in TSTF-425, its frequency requirement of once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is consistent with TSTF-425 listed frequencies that have moved to a SFCP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.5.1.3 Verify nitrogen cover pressure in each SIT is.::: [615] psig and S. [655] psig.

SR 3.5.1.5 Verify power is removed from each SIT isolation valve operator when pressurizer pressure is.::: [2000] pSia.

SR 3.5.1.3 SURVEILLANCE Verify nitrogen cover pressure in each SIT is c200 psig.

PNP TS SR only includes a lower nitrogen cover pressure value.

PNP proposes to adopt the TSTF-425 frequency relocation, however, it will retain the PNP TS SR wording that excludes an upper limit on nitrogen cover pressure.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.5.1.5 Verify power is removed from each SIT isolation valve operator.

PNP TS SR excludes the words "when pressurizer pressure is > [2000] psia" because the SR applicability is provided in the TS applicability section.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS TSTF-425 CEOG STS do not include a SR SR 3.5.2.3 associated with a SOC Flow Control Valve position.

Verify CV-3006, "SOC Flow Control Valve, " is open and its air supply is isolated.

SR 3.5.2.10 Verify, by visual inspection, each ECCS train containment sump suction inlet is not restricted by debris and the suction inlet trash racks and screens show no evidence of structural distress or abnormal corrosion.

PNP TS includes a SR associated with shutdown cooling (SOC) flow control valve position because it is a dual function valve, supporting the SOC and the low pressure safety injection (LPSI) system, which is in the flow path of an emergency core cooling system (ECCS). While not listed in TSTF-425, its frequency of once per 31 days is consistent with TSTF-425 listed frequencies that have moved to a SFCP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.5.2.9 Verify, by visual inspection, the containment sump passive strainer assemblies are not restricted by debris, and the containment sump passive strainer assemblies and other containment sump entrance pathways show no evidence of structural distress or abnormal corrosion.

PNP TS SR uses the words" the containment sump passive strainer assemblies are not restricted by debris, and the containment sump passive strainer assemblies and other containment sump entrance pathways," versus "each ECCS train containment sump suction inlet is not restricted by debris and the suction inlet trash racks and screens," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

SR 3.5.4.2 Verify RWT borated water volume is 2: [362,800 gallons, (88%)] [above the EGGS suction connection).

PNPTS SR 3.5.4.2 Verify SIRWT borated water volume is

250, 000 gallons.

PNP TS SR includes a note stating only required to be met in MODES 1,2,3 because PNP TS include an additional SR (3.5.4.3) which has a different SIRWT borated water volume criteria due to less water required if unit is in MODE 4.

Combining PNP TS SRs 3.5.4.2 and SR 3.5.4.3 is equivalent to TSTF-425 SR 3.5.4.2.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

TSTF-425 CEOG STS do not include a SR SR 3.5.4.3 associated with MODE 4 RWT volume.

Verify SIRWT borated water volume is

200, 000 gallons.

PNP TS SR includes a note stating only required to be met in MODE 4 because PNP TS include an additional SR (3.5.4.2) which has a different SIRWT borated water volume criteria due to more SIRWT water is required if unit is in MODE 1,2, and 3. Combining PNP TS SRs 3.5.4.2 and SR 3.5.4.3 is equivalent to TSTF-425 SR 3.5.4.2.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 36 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

SR 3.5.4.3 SR Verify RWT boron concentration is

.2: [1720J ppm and 5. [2500J ppm.

FREQUENCY 7 days SR 3.5.5.1 PNPTS SR 3.5.4.4 SR Verify SIRWT boron concentration is.2: 1720 ppm and 5. 2500 ppm.

FREQUENCY 31 days PNP's TS SR frequency is currently 31 days versus TSTF-425's 7 days. However, this frequency difference is a plant specific previously approved variance and does not invalidate the TSTF-425 basis for relocating this frequency to a SFCP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.5.5.1 Verify the TSP baskets contain.2: [291Jff of Verify the STB baskets contain ~ 8, 1861bs and trisodium phosphate.

510,553 Ibs of equivalent weight sodium tetraborate decahydrate.

Trisodium phosphate (TSP)

PNP TS SR uses the plant specific containment sump additive sodium tetra borate decahydrate (STB) versus the TSTF-425 TSP. PNP's SR also includes an upper limit on STB weight that results in a desired containment sump PH range that supports the accident analysis.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.5.5.2 Verify that a sample from the TSP baskets provides adequate pH adjustment of RWT water.

SR 3.6.3.2 Verify each [8J inch purge valve is closed except when the [8J inch purge valves are open for pressure control, ALARA or air quality considerations for personnel entry, of for Surveillances that require the valves to be open.

SR 3.5.5.2 Verify that a sample from the STB baskets provides adequate pH adjustment of borated water.

PNP TS SR uses the words "STB baskets provides adequate pH adjustment of borated water" versus TSP baskets provides adequate pH adjustment of RWT water," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.6.3.1 Verify each 8 inch purge valve and 12 inch air room supply valve is locked closed.

PNP TS SR includes an additional 12-inch air room supply valve and does not allow for the exception when the purge valves may be open listed in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.6.3.3 Verify each containment isolation manual valve and blind flange that is located outside containment and not locked, sealed, or otherwise secured, and is required to be closed during accident conditions, is closed, except for containment isolation valves that are open under administrative controls.

SR 3.6.3.6 SR Perform leakage rate testing for containment purge valves with resilient seals.

FREQUENCY 184 days AND Within 92 days after opening the valve SR 3.6.3.2 Verify each manual containment isolation valve and blind flange that is located outside containment and not locked, sealed, or otherwise secured in position, and is required to be closed during accident conditions, is closed, except for containment isolation valves that are open under administrative controls.

PNP TS SR adds the words "in position," to the TSTF-425 wording.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.6.3.5 SR Verify each containment 8 inch purge exhaust and 12 inch air room supply valve is closed by performance of a leakage rate test.

FREQUENCY 184 days PNP TS SR provides plant specific valves, an 8-inch purge valve and a 12-inch air room supply valve. The PNP SR frequency excludes 'Within 92 days after opening the valve" because the valves are locked closed and are not allowed to be opened.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

Page 39 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

SR 3.6.6A.2 Operate each containment cooling train fan unit for c 15 minutes.

SR 3.6.6A.3 Verify each containment cooling train cooling water flow rate is ~ [2000J gpm to each fan cooler.

PNPTS SR 3.6.6.2 Operate each Containment Air Cooler Fan Unit for c 15 minutes.

PNP TS SR uses the words "Containment Air Cooler Fan Unit" versus "containment cooling train," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.6.6.4 Verify total service water flow rate, when aligned for accident conditions, is c 4800 gpm to Containment Air Coolers VHX-1, VHX-2, and VHX-3.

PNP TS SR uses the words total service water flow rate, when aligned for accident conditions, is c 4800 gpm to Containment Air Coolers VHX-1, VHX-2, and VHX-3 versus each containment cooling train cooling water flow rate is ~ [2000J gpm to each fan cooler, as stated in TSTF-425.

The PNP TS SR is worded to better reflect PNP design.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.6.6A.8 Verify each containment cooling train starts automatically on an actual or simulated actuation signal.

SR 3.7.2.2 Verify each MSIV actuates to the isolation position on an actual or simulated actuation signal.

Main Steam Isolation Valve (MSIV)

SR 3.6.6.8 Verify each containment cooling fan starts automatically on an actual or simulated actuation signal.

PNP TS SR uses the words "containment cooling fan" versus "containment cooling train," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.7.2.1 Verify closure time of each MSIV is ~ 5 seconds on an actual or simulated actuation signal from each train under no flow conditions.

PNP TS SR uses the words "verify closure time,"

"~ 5 seconds," and from each train under no flow conditions. "TSTF-425 uses the words, "actuates to the isolation position." The closed position is the MSIVs isolation position at PNP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.7.3.2 Verify each MFIV [and [MFIV] bypass valve] actuates to the isolation position on an actual or simulated actuation signal.

SR 3.7.5.1 Verify each AFW manual, power operated, and automatic valve in each water flow path and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Auxiliary Feedwater (AFW)

SR 3.7.3.1 Verify the closure time of each MFRV and MFRV bypass valve is 5{ 22 seconds on an actual or simulated actuation signal.

PNP TS SR uses the words "verify closure time" and ":::; 22 seconds." TSTF-425 uses the words, "actuates to the isolation position." The closed position is the MFRVs isolation position at PNP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.7.5.1 Verify each required AFW manual, power operated, and automatic valve in each water flow path and in the steam supply flow path to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

PNP TS SR uses the words "required" and excludes "both" because PNP only has one steam supply to the steam driven AFW pump.

TSTF-425 uses the words, "both steam supply flow paths."

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

SR 3.7.5.4 Verify each AFW pump starts automatically on an actual or simulated actuation signal when in MODE 1,2, or 3.

SR 3.7.6.1 Verify CST level is ~ [350,000J gal.

Condensate Storage Tank (CST).

SR 3.7.7.3 Verify each CCW pump starts automatically on an actual or simulated actuation signal.

Component Cooling Water (CCW)

PNPTS SR 3.7.5.4 Verify each required AFW pump starts automatically on an actual or simulated actuation signal.

PNP TS SR uses the words "required" and excludes "when in MODE 1, 2, or 3." PNP TS included the SR applicability in a note prior to the SR. TSTF-425 uses similar words contained in the notes preceding the SR.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.7.6.1 Verify condensate usable volume is ~ 100,000 gallons.

PNP TS SR uses the words "condensate usable volume" versus "CST level," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.7.7.3 Verify each CCW pump starts automatically on an actual or simulated actuation signal in the "with standby power available" mode.

PNP TS SR has the additional words in the "with standby poweravailable" mode versus as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.7.8.3 Verify each SWS pump starts automatically on an actual or simulated actuation signal.

Service Water System (SWS)

SR 3.7.8.3 Verify each SWS pump starts automatically on an actual or simulated actuation signal in the "with standby power available" mode.

PNP TS SR has the additional words in the "with standby power available" mode versus as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

TSTF-425 GEOG STS do not include a SR SR 3.7.13.1 associated with Engineered Safeguards Room Ventilation (ESRV) dampers.

Verify each ESRV Damper train closes on an actual or simulated actuation signal.

PNP TS includes a SR associated with verification that ESRV dampers close when given an actuation signal. This is similar to the TSTF-425 (STS) SRs for EGGS pump room exhaust air cleanup system (PREAGS). Because it is similar to TSTF-425 EGGS PREAGS SR 3.7.13:3, its frequency requirement of once per 31 days is consistent with TSTF-425 listed frequencies that have moved to a SFGP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS TSTF-425 CEOG STS do not include a SR SR 3.7.12.2 associated with Fuel Handling Area Ventilation System flow rates.

SR 3.7.16.1 Verify the fuel storage pool water level is

.2: 23 ft above the top of irradiated fuel assemblies seated in the storage racks.

Verify the flow rate of the Fuel Handling Area Ventilation System, when aligned to the emergency filter bank, is ~ 5840 cfm and S 8760 cfm.

PNP TS includes a SR associated with Fuel Handling Area Ventilation which is similar to the TSTF-425 (STS) SRs for Fuel Building Air Cleanup Systems. Because it is similar to TSTF-425 FBACS SR 3.7.14.4, its frequency requirement of once per 18 months is consistent with TSTF-425 listed frequencies that have moved to a SFCP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.7.14.1 Verify the SFP water level is ~ 647 ft elevation.

PNP TS SR uses the words "~ 647 ft elevation,"

versus "~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks," as stated in TSTF-425. The PNP water level elevation ensures sufficient SFP water is available in the event of a fuel handling or fuel cask drop accident. This is a plant-specific value that incorporates the 23 ft of water between the top of the fuel assemblies and the fuel pool surface.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.8.1.1 Verify correct breaker alignment and indicated power availability for each

[requiredJ off site circuit.

SR 3.8.1.2 Verify each DG starts from standby conditions and achieves steady state voltage ~ [3740J V and:S; [4580J V, and frequency ~ [58.8J Hz and :s; [61.2J Hz.

SR 3.8.1.1 Verify correct breaker alignment and voltage for each off site circuit.

PNP TS SR uses the word "voltage" versus "indicated power availability" in TSTF-425.

Verification of voltage is considered equivalent to verification of indicated power availability.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.8.1.2 Verify each DG starts from standby conditions and achieves:

a. In:s; 10 seconds, ready-to-Ioad status; and
b. Steady state voltage ~ 2280 V and :s; 2520 V, and frequency ~ 59.5 Hz and:s; 61.2 Hz.

PNP TS SR does not include the notes and includes the start timing requirement "In s 10 seconds, ready-to-Ioad status," that TSTF-425 has in SR 3.8.1.7, as stated in note 2, at a frequency of 184 days. PNP does not use the modified DG start as stated in note 2 and therefore the requirements of TSTF-425 SR 3.8.1.7 apply to PNP TS SR 3.8.1.2. In other words, PNP SR 3.8.1.2 essentially combines TSTF-424 SRs 3.8.1.2 and 3.8.1.7.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.8.1.3 Verify each DG is synchronized and loaded, and operates for ~ 60 minutes at a load of~ [4500J kW andS: [5000J kW.

SR 3.8.1.10 Verify each DG does not trip, and voltage is maintained 5. [5000J V during and following a load rejection of 2:. [4500J kW and 5. [5000J kW.

SR 3.8.1.3 Verify each DG is synchronized and loaded, and operates for ~ 60 minutes:

a. For ~ 15 minutes loaded to greater than or equal to peak accident load; and
b. For the remainder of the test at a load

~ 2300 kW and S: 2500 kW.

PNP TS SR does not include note 1 and has modified note 4 by removing "or SR 3.8.1.7,"

because "gradual loading" is not used at PNP.

PNP TS SR also contains a peak loading verification requirement in addition to the requirements that are in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.8.1.6 Verify each DG, operating at a power factor S: 0.9, does not trip, and voltage is maintained S: 4000 V during and following a load rejection of

~ 2300 kW and S: 2500 kW.

PNP TS SR includes the words, "operating at a power factor ~0.9," that are not in TSTF-425.

This adds additional clarification to the SR requirements to reflect that PNP performs the test with the DG synchronized with offsite power.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNPTS SR 3.8.1.14 SR 3.8.1.8 Verify each DG operates for ~ 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

Verify each DG, operating at a power factor

5 0.9, operates for ~ 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:
a. For ~ [2} hours loaded ~ [5250} kW and

< [5500} kW and

a. For ~ 100 minutes loaded ~ its peak accident loading; and
b. For the remaining hours of the test loaded ~ [4500} kW and:5 [5000} kW.
b. For the remaining hours of the test loaded

~ 2300 kW and :5 2500 kW.

PNP TS SR includes the words, "operating at a power factor :5 0.9," that are not in TSTF-425.

This adds additional clarification to the SR requirements to reflect that PNP performs the test with the DG synchronized with offsite power.

PNP also uses the words "peak accident loading" instead of providing specific kW values in the SR.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.8.1.16 SR 3.8.1.9 Verify each DG:

Verify each DG:

a.

Synchronizes with offsite power

a.

Synchronizes with offsite power source while source while loaded with emergency supplying its associated 2400 V bus upon a loads upon a simulated restoration of simulated restoration of offsite power; off site power,

b. Transfers loads to offsite power source; and
b.

Transfers loads to offsite power source, and

c.

Returns to ready-to-Ioad operation.

c.

Returns to ready-to-Ioad operation.

PNP TS SR uses the words "supplying its associated 2400 V bus" versus "loaded with emergency loads" in TSTF-425. The PNP wording clarifies the DG loading.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

SR 3.8.1.18 Verify interval between each sequenced load block is within +/- [10% of design interval] for each emergency [and shutdownJ load sequencer.

SR 3.8.3.1 Verify each fuel oil storage tank contains ~

[33,000J gal of fuel.

PNPTS SR 3.8.1.10 Verify the time of each sequenced load is within

+/- 0.3 seconds of design timing for each automatic load sequencer.

PNP TS SR uses the words "the time of each sequenced load is within +/- 0.3 seconds" versus "interval between each sequenced load block is within +/- [10%," as stated in TSTF-425. The PNP wording clarifies the verification of the sequenced load timing.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.8.3.1 Verify the fuel oil storage subsystem contains ~ a 7 day supply of fuel.

PNP TS SR uses the words "the fuel oil storage subsystem contains ~ a 7 day supply," versus "each fuel oil storage tank contains ~ [33,000]

gal," as stated in TSTF-425. The PNP TS wording more accurately reflects the fuel oil storage requirement.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.8.3.2 Verify lubricating oil inventory is ~ [500]

gal.

SR 3.8.3.5 Check for and remove accumulated water from each fuel oil storage tank.

SR 3.8.3.2 Verify stored lube oil inventory is ~ a 7 day supply.

PNP TS SR uses the words "stored lube oil inventory is ~ a 7 day supply," versus "lubricating oil inventory ~ [500] gal," as stated in TSTF-425.

The PNP TS wording more accurately reflects the lubricating oil inventory requirement.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.8.3.5 Check for and remove excess accumulated water from the fuel oil storage tank.

PNP TS SR uses the words "excess accumulated water from the fuel oil storage tank," versus "accumulated water from each fuel oil storage tank," as stated in TSTF-425. The PNP TS wording clarifies the requirement to remove accumulated water from PNP's fuel oil storage tank.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

SR 3.8.4.1 Verify battery terminal voltage is greater than or equal to the minimum established float voltage.

TSTF-425 does not include a SR associated with verifying no visible corrosion at battery terminals and connectors or verifying battery connection resistance.

PNPTS SR 3.8.4.1 Verify battery terminal voltage is;::: 125 Von float charge.

PNP TS SR uses the words ";::: 125 V on float charge" versus "is greater than or equal to the minimum established float voltage," as stated in TSTF-425. The PNP TS wording clarifies the terminal voltage that is being verified.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.8.4.2 Verify no visible corrosion at battery terminals and connectors.

OR Verify battery connection resistance is

s; 50 j10hm for inter-cell connections, :s; 360 j10hm for inter-rack connections, and:s; 360 j10hm for inter-tier connections.

PNP TS includes a SR associated with verification that verifying no visible corrosion at battery terminals and connectors or verifying battery connection resistance.

The SR frequency of 92 days is consistent with other TSTF-425 listed frequencies that have moved to a SFCP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

TSTF-425 does not include a SR associated with battery physical condition inspections.

TSTF-425 does not include a SR associated with removal of visible terminal corrosion and verification of anti-corrosion material.

PNPTS SR 3.8.4.3 Inspect battery cel/s, cell plates, and racks for visual indication of physical damage or abnormal deterioration that could degrade battery performance.

PNP TS includes a SR associated with inspecting the physical condition of the station batteries for physical damage or deterioration.

The SR frequency of 12 months is consistent with other TSTF-425 listed frequencies that have moved to a SFCP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.8.4.4 Remove visible terminal corrosion and verify battery cell to cell and terminal connections are coated with anti-corrosion material.

PNP TS includes a SR associated with removal of visible terminal corrosion and verification of anti-corrosion material.

The SR frequency of 12 months is consistent with other TSTF-425 listed frequencies that have moved to a SFCP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS TSTF-425 does not include a SR associated with verification of battery connection resistance.

SR 3.8.4.2 Verify each battery charger supplies 2:. [400J amps at greater than or equal to the minimum established float voltage for 2:. [8J hours.

SR 3.8.4.5 Verify battery connection resistance is

~ 50 J.lohm for inter-cell connections, ~ 360 J.lohm for inter-rack connections, and ~ 360 J.lohm for inter-tier connections.

PNP TS includes a SR associated verification of battery connection resistance The SR frequency of 12 months is consistent with other TSTF-425 listed frequencies that have moved to a SFCP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.8.4.6 Verify each required battery charger supplies

~ 180 amps at~ 125 V for;::: 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

PNP TS SR uses the words "at ~ 125 V" versus "at greater than or equal to the minimum established float voltage," as stated in TSTF-425.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.8.6.2 Verify each battery pilot cell voltage is

~[2.07J V.

SR 3.8.6.3 Verify each battery connected cell electrolyte level is greater than or equal to minimum established design limits.

SR 3.8.6.1 Verify battery cell parameters meet Table 3.8.6-1 Category A limits.

PNP TS SR uses the words "battery cell parameters meet Table 3.8.6-1 Category A limits" versus "each battery pilot cell voltage is

~ [2.07] V," as stated in TSTF-425. PNP Table 3.8.6-1 Category A is specific to pilot cells and list limits for electrolyte level, float voltage, and specific gravity. The PNP SR is equivalent to TSTF-425 SR 3.8.6.2 because PNP TS Table 3.8.6-1 includes pilot cell voltage limits.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.8.6.3 Verify battery cell parameters meet Table 3.8.6-1 Category B limits.

PNP TS SR uses the words "battery cell parameters meet Table 3.8.6-1 Category B limits" versus "each battery connected cell electrolyte level is greater than or equal to minimum established design limits," as stated in TSTF-425.

PNP TS Table 3.8.6-1 Category B is specific to connected cells and list limits for electrolyte level, float voltage, and specific gravity. The PNP TS SR is equivalent to TSTF-425 SR 3.8.6.3 because PNP TS Table 3.8.6-1 includes connected cells electrolyte level limits.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.8.6.4 Verify each battery pilot cell temperature is greater than or equal to minimum established design limits.

SR 3.8.6.5 Verify each battery connected cell voltage is ~ [2.07] V.

SR 3.8.6.2 Verify average electrolyte temperature of representative cells is ~ 70 of.

PNP TS SR uses the words "average electrolyte temperature of representative cells is ~ 70° P' versus "each battery pilot cell temperature is greater than or equal to minimum established design limits." The PNP TS SR term "representative cell" is similar to "pilot cell," PNP lists a specific temperature limit, and clarifies cell temperature as "average electrolyte temperature." The terms in PNP TS SR are similar to TSTF-425 and therefore the SRs are equivalent.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.8.6.3 Verify battery cell parameters meet Table 3.8.6-1 Category B limits.

PNP TS SR uses the words "battery cell parameters meet Table 3.8.6-1 Category B limits" versus "each battery connected cell voltage is

~ [2.07] V," as stated in TSTF-425. PNP TS Table 3.8.6-1 Category B is specific to connected cells and list limits for electrolyte level, float voltage, and specific gravity. The PNP TS SR is equivalent to TSTF-425 SR 3.8.6.3 because PNP TS Table 3.8.6-1 includes connected cells float voltage limits.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.8.7.1 Verify correct inverter voltage, [frequency,]

and alignment to required AC vital buses.

SR 3.8.8.1 Verify correct inverter voltage, [frequencY,1 and alignment to required AC vital buses.

SR 3.8.9.1 Verify correct breaker alignments and voltage to [required1 AC, DC, and AC vital bus electrical power distribution subsystems.

SR 3.8.7.1 Verify correct inverter voltage, frequency, and alignment to Preferred AC buses.

PNP TS SR uses the words "Preferred AC buses" versus "required AC vital buses," as stated in TSTF-425. The PNP wording clarifies the terms used to describe the required AC vital buses at PNP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.8.8.1 Verify correct inverter voltage, frequency, and alignment to Preferred AC buses.

PNP TS SR uses the words "Preferred AC buses" versus "required AC vital buses," as stated in TSTF-425. The PNP wording clarifies the terms used to describe the required AC vital buses at PN P.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.8.9.1 Verify correct breaker alignments and voltage to required AC, DC, and Preferred AC bus electrical power distribution subsystems.

PNP TS SR uses the words "Preferred AC bus" versus "AC vital bus," as stated in TSTF-425. The PNP TS wording clarifies the terms used to describe the required AC vital buses at PNP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

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

SR 3.9.1.1 Verify boron concentration is within the limit specified in the COLR.

Core Operating Limits Report (COLR)

SR 3.9.3.1 Verify each required containment penetration is in the required status.

PNPTS SR 3.8.10.1 Verify correct breaker alignments and voltage to required AC, DC, and Preferred AC bus electrical power distribution subsystems.

PNP TS SR uses the words "Preferred AC bus" versus "AC vital bus," as stated in TSTF-425. The PNP TS wording clarifies the terms used to describe the required AC vital buses at PNP.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.9.1.1 Verify boron concentration is at the REFUELING BORON CONCENTRA TlON.

PNP TS SR uses the words "at the REFUELING BORON CONCENTRATION" versus 'within the limit specified in the COLR," as stated in TSTF-425. The PNP TS wording specifically states the boron concentration limit versus referring to the COLR.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.9.3.1 Verify each required to be met containment penetration is in the required status.

PNP TS SR includes the words to be met" in addition to what is stated in TSTF-425. The PNP TS wording clarifies the required containment penetrations.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNP TS SR 3.9.3.2 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal.

SR 3.9.4.1 Verify one SOC loop is in operation and circulating reactor coolant at a flow rate of c [2200] gpm.

Shutdown Cooling (SOC)

SR 3.9.3.2 Verify each required automatic isolation valve closes on an actual or simulated Refueling Containment High Radiation signal.

PNP TS SR includes the words "automatic isolation valve closes on an actual or simulated Refueling Containment High Radiation signal" versus "containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal," that is stated in TSTF-425. The PNP TS wording is more specific to PNP, which clarifies the required automatic isolation valves and the signal that actuates them.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.9.4.1 Verify one SOC train is in operation and circulating primary coolant at a flow rate of c 1000gpm.

PNP TS SR uses the words "SOC train and primary coolant" versus "SOC loop and reactor coolant" used in TSTF-425. The PNP TS wording is a better description of PNP's sot system and is considered a clarification.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 1 PNP SITE SPECIFIC TS SURVEILLANCE REQUIREMENTS TSTF-425 (CEOG STS)

PNPTS SR 3.9.5.1 SR 3.9.5.1 Verify one SOC train is in operation and Verify required SOC loops are OPERABLE circulating primary coolant at a flow rate of and one SOC loop is in operation.

~ 1000 gpm.

SR 3.9.6.1 Verify refueling water level is ~ 23 ft above the top of reactor vessel flange.

PNP TS SR verifies the required number of SOC trains is in operation and circulating primary coolant at the required flow rate. PNP TS SR uses the words "SOC train and primary coolant" versus "SOC loop and reactor coolanf' used in TSTF-425 and because PNP uses SOC trains operability is verified by TS 3.9.5 condition A and B verifies SOC operability. The PNP wording is a better description of PNP's SOC system and is considered a clarification.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

SR 3.9.6.1 Verify refueling cavity water level is ~ 647 ft elevation.

PNP TS SR uses the words "refueling cavity water level is ~ 647 ft elevation" versus "refueling water level is ~ 23 ft above the top of reactor vessel flange" used in TSTF-425. The PNP TS SR verifies, by water level elevation, that the minimum water level which ensures the design basis for the postulated fuel handling accident analysis during refueling operations is met, which is the same basis for CEOG STS SR use of ~ 23 ft above the top of reactor vessel flange. PNP's TS wording is hence considered equivalent to TSTF-425 and CEIOG STS.

This variation is acceptable because it meets the TSTF-425 relocation criteria for periodic frequencies.

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ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes 2.2.3 PNP TS Section Number Differences PNP TS section numbering, in some cases, does not exactly match the TSTF-425 section numbering, however these are considered editorial changes and therefore they will be relocated to the SFCP. They are listed in Table 2 below.

TABLE 2 PNP TS SECTION NUMBER DIFFERENCES TSTF-425 (CEOG STS) SURVEILLANCE PNP TS SURVEILLANCE SR 3.1.4.4 SR 3.1.4.3 Verify CEA freedom of movement Verify control rod freedom of movement by (trippability) by moving each individual CEA moving each individual full-length control rod that is not fully inserted into the reactor core that is not fully inserted into the reactor core 2

[5 inchesJ in either direction.

6 inches in either direction.

SR 3.1.6.3 SR 3.1.6.2 Verify POlL alarm circuit is OPERABLE.

Verify POlL alarm circuit is OPERABLE.

SR 3.2.5.1 (Analog)

SR 3.2.4.1 (Analog)

Verify ASI is within limits specified in the Verify ASI is within limits specified in the COLR.

COLR.

SR 3.3.1.2 (Analog)

SR 3.3.1.3 Perform calibration (heat balance only) and Perform calibration (heat balance only) and adjust the excore power range and L1 T power adjust the power range excore and L1 T power channels to agree with calorimetric channels to agree with calorimetric calculation calculation if the absolute difference is if the absolute difference is ~ 1.5%.

2[1.5J%.

SR 3.3.1.3 (Analog)

SR 3.3.1.4 Calibrate the power range excore channels Calibrate the power range excore channels using the incore detectors.

using the incore detectors.

SR 3.3.11.1 (Analog)

SR 3.3.7.1 Perform CHANNEL CHECK for each required Perform CHANNEL CHECK for each required instrumentation channel that is normally instrumentation channel that is normally energized.

energized.

Page 60 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 2 PNP TS SECTION NUMBER DIFFERENCES TSTF-425 (CEOG STS) SURVEILLANCE PNP TS SURVEILLANCE SR 3.3.11.2 (Analog)

SR 3.3.7.2 Perform CHANNEL CAL/BRA TlON.

Perform CHANNEL CAL/BRA TlON.

SR 3.3.12.2 (Analog)

SR 3.3.8.2 Verify each required control circuit and Verify each required control circuit and transfer transfer switch is capable of performing the switch is capable of performing the intended intended function.

function.

SR 3.3.12.3 (Analog)

SR 3.3.8.3 Perform CHANNEL CAL/BRA TlON for each Perform CHANNEL CAL/BRA TlON for each required instrumentation channel.

required instrumentation channel.

SR 3.3.13.1 (Analog)

SR 3.3.9.1 Perform CHANNEL CHECK.

Perform CHANNEL CHECK.

SR 3.3.13.3 (Analog)

SR 3.3.9.2 Perform CHANNEL CAL/BRA TION.

Perform CHANNEL CAL/BRA TlON.

SR 3.4.12.5 SR 3.4.12.3 Verify PORV block valve is open for each Verify PORV block valve is open for each required PORV.

required PORV.

SR 3.4.12.6 SR 3.4.12.4 Perform CHANNEL FUNCTIONAL TEST on Perform CHANNEL FUNCTIONAL TEST on each required PORV, excluding actuation.

each required PORV, excluding actuation.

SR 3.4.12.7 SR 3.4.12.5 Perform CHANNEL CAL/BRA TlON on each Perform CHANNEL CAL/BRA TlON on each required PORV actuation channel.

required PORV actuation channel.

Page 61 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 2 PNP TS SECTION NUMBER DIFFERENCES TSTF-425 (CEOG STS) SURVEILLANCE SR 3.5.2.6 Verify each EGGS automatic valve that is not locked, sealed, or otherwise secured in position, in the flow path actuates to the correct position on an actual or simulated actuation signal.

SR 3.5.2.7 Verify each EGGS pump starts automatically on an actual or simulated actuation signal.

SR 3.5.2.8 Verify each LPSI pump stops on an actual or simulated actuation signal.

SR 3.5.2.9

[Verify, for each EGGS throttle valve listed below, each position stop is in the correct position.

Valve Number

[]

[ ]

SR 3.6.3.7 Verify each automatic containment isolation valve that is not locked, sealed, or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

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

SR 3.5.2.6 Verify each EGGS pump starts automatically on an actual or simulated actuation signal.

SR 3.5.2.7 Verify each LPSI pump stops on an actual or simulated actuation signal.

SR 3.5.2.8 Verify, for each EGGS throttle valve listed below, each position stop is in the correct position.

Valve Number Function MO-300B MO-3010 MO-3012 MO-3014 MO-30B2 MO-30B3 SR 3.6.3.6 LPSI to Gold leg 1A LPSI to Gold leg 18 LPSI to Gold leg 2A LPSI to Gold leg 28 HPSI to Hot leg 1 HPSI to Hot leg 1 Verify each automatic containment isolation valve that is not locked, sealed, or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

Page 62 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 2 PNP TS SECTION NUMBER DIFFERENCES TSTF-425 (CEOG STS) SURVEILLANCE PNP TS SURVEILLANCE SR 3.6.6A.4 SR 3.6.6.3

[Verify the containment spray piping is full of Verify the containment spray piping is full of water to the [100] ft level in the containment water to the 735 ft elevation in the containment spray header.

spray header.

SR 3.7.11.1 SR 3.7.10.1 Operate each CREACS train for Operate each CRV Filtration train for

{? 1 0 continuous hours with heaters operating

~ 10 continuous hours with associated heater or (for systems without heaters) ~ 15 (VHX-26A or VHX-268) operating.

minutes].

SR 3.7.11.3 SR 3.7.10.3 Verify each CREACS train actuates on an Verify each CRV Filtration train actuates on an actual or simulated actuation signal.

actual or simulated actuation signal.

SR 3.7.12.1 SR3.7.11.1 Verify each CREA TCS train has the capability Verify each CRV Cooling train has the to remove the assumed heat load.

capability to remove the assumed heat load.

SR 3.7.17.1 SR 3.7.15.1 Verify the fuel storage pool boron Verify the SFP boron concentration is within concentration is within limit.

limit.

SR 3.7.19.1 SR3.7.17.1 Verify the specific activity of the secondary Verify the specific activity of the secondary coolant is within limit.

coolant is within limit.

SR 3.8.1.6 SR 3.8.3.6 Verify the fuel oil transfer system operates to Verify the fuel oil transfer system operates to

[automatically] transfer fuel oil from storage transfer fuel oil from the fuel oil storage tank to tank[s] to the day tank [and engine mounted each DG day tank and engine mounted tank.

tank].

Page 63 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 2 PNP TS SECTION NUMBER DIFFERENCES TSTF-425 (CEOG STS) SURVEILLANCE PNP TS SURVEILLANCE SR 3.8.1.9 SR 3.8.1.5 Verify each DG rejects a load greater than or Verify each DG rejects a load greater than or equal to its associated single largest equal to its associated single largest post-accident load and:

post-accident load, and:

a. Following load rejection, the frequency is
a. Following load rejection, the frequency is

~ [63] Hz,

~ 68 Hz;

b. Within [3] seconds following load
b. Within 3 seconds following load rejection, rejection, the voltage is ~ [3740] V and the voltage is ~ 2280 V and ~ 2640 V; and

~ [4580] V, and

c. Within 3 seconds following load rejection,
c. Within [3] seconds following load the frequency is ~ 59.5 Hz and ~ 61.5 Hz.

rejection, the frequency is ~ [58.8] Hz and

~ [61.2] Hz.

Page 64 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 2 PNP TS SECTION NUMBER DIFFERENCES TSTF-425 (CEOG STS) SURVEILLANCE PNP TS SURVEILLANCE SR 3.8.1.11 SR 3.8.1.7 Verify on an actual or simulated loss of offsite Verify on an actual or simulated loss of offsite power signal:

power signal:

a. De-energization of emergency buses,
a. De-energization of emergency buses;
b. Load shedding from emergency buses,
b. Load shedding from emergency buses;
c. DG auto-starts from standby condition
c.

DG auto-starts from standby condition and:

and:

1. energizes permanently connected
1. Energizes permanently connected loads in :::; 10 seconds, loads in :::; [10] seconds,
2. energizes auto-connected shutdown
2. Energizes auto-connected shutdown loads through automatic load loads through [automatic load sequencer, sequencer],
3. maintains steady state voltage
3. Maintains steady state voltage
?
2280 V and :::; 2520 V,
?
[3740] V and:::; [4580] V,
4. maintains steady state frequency
4. Maintains steady state frequency
?
59.5 Hz and:::; 61.2 Hz, and
?
[58.8] Hz and:::; [61.2] Hz, and
5. supplies permanently connected loads
5. Supplies permanently connected [and for;?: 5 minutes.

auto-connected] shutdown loads for

?
5 minutes.

Page 65 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 2 PNP TS SECTION NUMBER DIFFERENCES TSTF-425 (CEOG STS) SURVEILLANCE SR 3.8.1.19 Verify on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ESF actuation signal:

a. De-energization of emergency buses,
b. Load shedding from emergency buses,
c. DG auto-starts from standby condition and:
1. energizes permanently connected loads in S [10] seconds,
2. energizes auto-connected emergency loads through [load sequencer],
3. achieves steady state voltage

~ [3740] V and S [4580] V,

4. achieves steady state frequency

~ [58.8] Hz and S [61.2] Hz, and

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

~ [5] minutes.

SR 3.8.4.3 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.

PNP TS SURVEILLANCE SR 3.8.1.11 Verify on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated safety injection signal:

a. De-energization of emergency buses;
b. Load shedding from emergency buses;
c.

DG auto-starts from standby condition and:

1. energizes permanently connected loads in S 10 seconds,
2. energizes auto-connected shutdown loads through automatic load sequencer,
3. achieves steady state voltage ~ 2280 V andS 2520 V,
4. achieves steady state frequency

~ 59.5 Hz and S 61.2 Hz, and

5. supplies permanently connected loads for ~ 5 minutes.

SR 3.8.4.7 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.

Page 66 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 2 PNP TS SECTION NUMBER DIFFERENCES TSTF-425 (CEOG STS) SURVEILLANCE PNP TS SURVEILLANCE SR 3.8.6.6 SR 3.8.4.8 Verify battery capacity is ~ [80%] of the Verify battery capacity is ~ 80% of the manufacturer's rating when subjected to a manufacturer's rating when subjected to a performance discharge test or a modified performance discharge test or a modified performance discharge test.

performance discharge test.

Admin 5.5.18 Admin 5.5.17 Surveillance Freguenc~ Control Program Surveillance Freguenc~ Control Program (SFCP)

(SFCP) 2.2.3 TSTF-425 (CEOG STS) Changes Not in PNP TS PNP's current TS SR, in some cases, do not include the TSTF-425 listed SRs and therefore these changes are not applicable to PNP. They will not be adopted by PNP and are listed in Table 3 below.

TABLE 3 TSTF-425 (CEOG STS) CHANGES NOT IN PNP TS TSTF-425 (CEOG STS) SR PNPTS 1.1 Definitions 1.1 Definitions STAGGERED TEST BASIS STAGGERED TEST BASIS Optional Addition Currently contained in PNP TS. Will not be added under this LAR.

SR 3.1.4.2 This SR is not included in PNP's current TS.

Verify the CEA motion inhibit is OPERABLE.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

Page 67 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 3 TSTF-425 (CEOG STS) CHANGES NOT IN PNP TS TSTF-425 (CEOG STS) SR SR 3.1.6.2 Verify the accumulated times during which the regulating CEA groups are inserted beyond the steady state insertion limits but within the transient insertion limits.

SR 3.1.7.1 Verify that the position of each CEA not fully inserted is within the acceptance criteria for available negative reactivity addition.

SR 3.2.1.1 PNPTS This SR is not included in PNP's TS.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

This SR is not included in PNP's TS.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

This SR is not included in PNP's TS.

Verify ASI alarm setpoints are within the limits ENO will not adopt this TSTF-425 SR specific in the COLR.

frequency relocation for PNP.

SR 3.2.1.3 Verify incore detector local power density alarm setpoints are less than or equal to the limits specified in the COLR.

SR 3.2.2.1 Verify the value of FTxy SR 3.3.1.9 (Analog)

Verify RPS RESPONSE TIME is within limits.

SR 3.3.2.1 (Analog)

Perform a CHANNEL CHECK of each wide range power channel.

This SR is not included in PNP's TS.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

This SR is not included in PNP's TS.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

This SR is not included in PNP's TS.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

PNP TS do not include the TSTF-425 STS section for RPS Instrumentation - Shutdown (Analog) 3.3.2. Instead, PNP TS combined the STS sections of RPS Instrumentation -

Operating (Analog) 3.3.1 and RPS Instrumentation - Shutdown (Analog) 3.3.2 by adding an Applicable MODEs column to Table 3.3.1-1 for each RPS function.

Therefore ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

Page 68 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 3 TSTF-425 (CEOG STS) CHANGES NOT IN PNP TS TSTF-425 (CEOG STS) SR PNPTS SR 3.3.2.2 (Analog)

PNP TS do not include the TSFT-425 STS section for RPS Instrumentation - Shutdown Perform a CHANNEL FUNCTIONAL TEST (Analog) 3.3.2. Instead, PNP TS combined on the Power Rate of Change trip function.

the STS sections of RPS Instrumentation-Operating (Analog) 3.3.1 and RPS Instrumentation - Shutdown (Analog) 3.3.2 by adding an Applicable MODEs column to Table 3.3.1-1 for each RPS function.

Therefore ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

SR 3.3.2.3 (Analog)

PNP TS do not include the TSFT-425 STS section for RPS Instrumentation - Shutdown Perform a CHANNEL FUNCITONAL TEST (Analog) 3.3.2. Instead, PNP TS combined on each automatic bypass removal function.

the STS sections of RPS Instrumentation-Operating (Analog) 3.3.1 and RPS Instrumentation - Shutdown (Analog) 3.3.2 by adding an Applicable MODEs column to Table 3.3.1-1 for each RPS function.

Therefore ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

SR 3.3.2.4 (Analog)

PNP TS do not include the TSFT-425 STS section for RPS Instrumentation - Shutdown Perform a CHANNEL CAL/BRA TlON, (Analog) 3.3.2. Instead, PNP TS combined including bypass removal functions with the STS sections of RPS Instrumentation-Allowable Value < [2.6] dpm.

Operating (Analog) 3.3.1 and RPS Instrumentation - Shutdown (Analog) 3.3.2 by adding an Applicable MODEs column to Table 3.3.1-1 for each RPS function.

Therefore ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

SR 3.3.3.1 (Analog)

PNP TS include a similar RPS trip Initiation logic channel surveillance at a 92 day Perform a CHANNEL FUNCTIONAL TEST frequency (SR 3.3.2.1) CHANNEL on each RTCB channel.

FUNCTIONAL TEST. However, since it is not identical to the reactor trip circuit breakers (RCTS) channel, ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

Page 69 of 1 06

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 3 TSTF-425 (CEOG STS) CHANGES NOT IN PNP TS TSTF-425 (CEOG STS) SR SR 3.3.3.4 (Analog)

[Perform a CHANNEL FUNCTIONAL TEST, including separate verification of the undervoltage and shunt trips, on each RTCB channel.

SR 3.3.4.5 (Analog)

Verify ESF RESPONSE TIME is within limits.

SR 3.3.6.1 (Analog)

[Perform CHANNEL CHECK SR 3.3.8.2 (Analog)

Perform a CHANNEL FUNCTIONAL TEST on the required CRIS radiation monitor channel.

Verify CRIS high radiation setpoint is less than or equal to the Allowable Value of [6E4]

cpm above normal background.

SR 3.3.8.6 (Analog)

[Verify response time of required CRIS channel is within limits SR 3.3.12.1 (Analog)

[Perform CHANNEL CHECK for each required instrumentation channel that is normally energized.

PNPTS PNP TS do not include SRs for RTCBs.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

PNP TS do not include SRs for verification of engineered safety features (ESF) response time.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

PNP TS do not include a SR for performing an ESF channel check.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

PNP TS do not include a SR for performing a channel functional test on the CRIS high radiation setpoint.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

PNP TS do not include a SR for performing radiation monitor control room isolation response time verification.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

PNP TS do not include a SR for performing channel check on normally energized remote shutdown system instrumentation channels.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

Page 70 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 3 TSTF-425 (CEOG STS) CHANGES NOT IN PNP TS TSTF-425 (CEOG STS) SR SR 3.3.13.2 (Analog)

Perform CHANNEL FUNCTIONAL TEST.

SR 3.4.1.3 Verify RCS total flow rate ~ [148 E6] Ib/hour.

SR 3.4.11.1 Perform a complete cycle of each PORV.

This SR to perform a complete cycle of each PORV has a different frequency requirement PNP TS.

SR 3.4.11.3 PNPTS PNP TS do not include a SR for performing channel functional testing of neutron flux monitoring channels.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

PNP TS do not include a SR for verifying total ReS flow rates every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

PNP TS SR frequency is conditional as, "Once prior to entering MODE 4 from MODE 5," and therefore meets a TSTF-425 exclusion criteria and TSTF-425 may not be used to justify the change.

END will not adopt this TSTF-425 SR frequency relocation for PNP.

PNP TS do not include this optional SR.

Perform a complete cycle of each solenoid air END will not adopt this TSTF-425 SR control valve and check valve on the air frequency relocation for PNP.

accumulators in PORV control systems.

This SR is optional in STS and is not included in PNP TS.

SR 3.4.11.4 Verify PORVs and block valve(s) are capable of being powered from an emergency power supply.

This SR is optional in STS and is not included in PNP TS.

PNP TS do not include this optional SR.

END will not adopt this TSTF-425 SR frequency relocation for PNP.

Page 71 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 3 TSTF-425 (CEOG STS) CHANGES NOT IN PNP TS TSTF-425 (CEOG STS) SR SR 3.4.12.3 Verify each SIT is isolated.

SR 3.4.15.2 Perform CHANNEL FUNCTIONAL TEST of the required containment atmosphere radioactivity monitor.

SR 3.4.15.5

[Perform CHANNEL CAL/BRA TlON of the required containment air cooler condensate flow rate monitor.

This surveillance requirement is optional in STS and is not included in PNP TS.

SR 3.4.17.1 Verify THERMAL POWER ~ 5% RTP.

SR 3.5.2.3 Verify ECCS piping is full of water.

PNPTS PNP TS do not include a SR for verifying each safety injection tank (SIT) is isolated.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

This SR is not included in PNP's current TS.

PNP performs a channel calibration of the required containment atmosphere gaseous activity monitor every 18 moths per SR 3.4.15.6 ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

PNP TS do not include this optional SR.

Note: PNP has containment air cooler condensate collection pan level switches versus condensate flow rate monitor.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

This SR is not included in PNP's current TS.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

This SR is not included in PNP's current TS.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

Page 72 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 3 TSTF-425 (CEOG STS) CHANGES NOT IN PNP TS TSTF-425 (CEOG STS) SR SR 3.6.3.5 SR Verify the isolation time of each automatic power operated containment isolation valve is within limits.

FREQUENCY

[In accordance with the In service Testing Program or 92 days]

SR 3.6.6A.9 SR Verify each spray nozzle is unobstructed.

FREQUENCY

[At first refueling]

[10 years]

SR 3.7.9.3

[Operate each cooling tower fan for ~ [15]

minutes.

SR3.7.11.4 Verify one CREACS train can maintain a positive pressure of ~ [0. 125] inches water gauge, relative to the adjacent [area] during the emergency radiation state of the emergency mode of operation at an emergency ventilation flow rate of ~ [3000]

cfm.

PNPTS PNP's frequency for its corresponding SR 3.6.3.4 does not include "or 92 days."

ENO will maintain the current frequency of "in accordance with the INSERVICE TESTING PROGRAM."

Therefore ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

PNP's frequency for its corresponding SR 3.6.6.9 states "Following maintenance which could result in nozzle blockage."

ENO will maintain this current frequency.

Therefore ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

This SR is not included in PNP's current TS.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

PNP has adopted a Control Room Habitability Program which requires unfiltered air inleakage testing. Therefore, this SR is not included in PNP's current TS.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

Page 73 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 3 TSTF-425 (CEOG STS) CHANGES NOT IN PNP TS TSTF-425 (CEOG STS) SR SR 3.8.1.5 Check for and remove accumulated water from each day tank [and engine mounted tank].

SR 3.8.1.7 Verify each DG starts from standby conditions and achieves:

a. In:S; [10] seconds, voltage ~ [3740] Vand frequency ~ [58.8] Hz and
b. Steady state voltage;:::: [3740] V and
s; [4580] V, and frequency;:::: [58.8] Hz and
s; [61.2] Hz.

SR 3.8.1.8

[Verify [automatic [and] manual] transfer of AC power sources from the normal offsite circuit to each alternate [required] offsite circuit.

PNPTS This SR is not included in PNP's current TS.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

PNP TS do not include this SR. Instead PNP has included TSTF-425 SR 3.8.1.7 in PNP SR 3.8.1.2 for diesel generator (DG) start testing.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

This SR is not included in PNP's current TS.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

Page 74 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 3 TSTF-425 (CEOG STS) CHANGES NOT IN PN,P TS TSTF-425 (CEOG STS) SR PNPTS SR 3.8.1.12 This SR is not included in PNP's current TS.

Verify on an actual or simulated Engineered ENO will not adopt this TSTF-425 SR Safety Feature (ESF) actuation signal each frequency relocation for PNP.

DG auto-starts from standby condition and:

a. In < [10] seconds after auto-start and during tests, achieves voltage> [3740] V and frequency> [58.8] Hz,
b. Achieves steady state voltage;:: [3740] V and:5 [4580] V, and frequency;:: [58.8] Hz and :5 [61.2] Hz,
c. Operated for ~ 5 minutes,
d. Permanently connected loads remain energized from the offsite power system, and
e. Emergency loads are energized [or auto-connected through the automatic load sequencer] from the off site power system.

SR 3.8.1.13 This SR is not included in PNP's current TS.

Verify each DG's noncritical automatic trips ENO will not adopt this TSTF-425 SR are bypassed on [actual or simulated loss of frequency relocation for PNP.

voltage signal on the emergency bus concurrent with an actual or simulated ESF actuation signal].

SR 3.8.1.15 This SR is not included in PNP's current TS.

Verify each DG starts and achieves:

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

a. In ~ [10] seconds, voltage ~ [3740] V and frequency ~ [58.8] Hz and
b. Steady state voltage;:: [3740] V and
5 [4580] \\I, and frequency;:: [58.8] Hz and
5 [61.2] Hz.

Page 75 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 3 TSTF-425 (CEOG STS) CHANGES NOT IN PNP TS TSTF-425 (CEOG STS) SR PNP TS SR 3.8.1.17 Verify, with a DG operating in test mode and connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by:

a. Returning DG to ready-to-Ioad operation and

[b. Automatically energizing the emergency load from off site power.]

SR 3.8.1.20 Verify, when started simultaneously from standby condition, each DG achieves:

a. In ~ [10] seconds, voltage ~ [3740] Vand frequency ~ [58.8] Hz and
b. Steady state voltage ~ [3740] Vand
[4580] \\I, and frequency ~ [58.8] Hz and
[61.2] Hz.

SR 3.8.6.1 This SR is not included in PNP's current TS.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

This SR is not included in PNP's current TS.

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

This SR is not included in PNP's current TS.

Verify each battery float current is < [2] amps:

ENO will not adopt this TSTF-425 SR frequency relocation for PNP.

5.5.17 ADMINISTRATIVE CONTROLS This SR is not included in PNP's current TS.

Battery Monitoring and Maintenance Program ENO will not adopt this TSTF-425 administrative controls section change for PNP.

2.2.4 TSTF-425 (CEOG STS) Changes Not Applicable due to PNP Design PNP's design, in some cases, varies from other CEOG STS plants and therefore not all STS sections are applicable to PNP. These TSTF-425 changes will not be adopted by PNP and are listed in Table 4 below.

Page 76 of 1 06

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNPTS SR 3.1.1.1 PNP plant specific design is analogue and therefore frequency changes to specifications Verify SDM to be within limits specified in the in TSTF-425 that apply to SDM (Digital) do COLR.

not apply.

Applies to SDM (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.1.2.1 PNP plant specific design is analogue and therefore frequency changes to specifications Verify overall core reactivity balance is within in TSTF-425 that apply to reactivity balance

+1.0% i1k1k of predicted values.

(Digital) do not apply.

Applies to Reactivity Balance (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.1.4.1 PNP plant specific design is analogue and therefore frequency changes to specifications Verify the indicated position of each full and in TSTF-425 that apply to CEA Alignment part length CEA is within [7 inches] of all (Digital) do not apply.

other CEAs in its group.

ENO will not adopt this TSTF-425 change for Applies to CEA Alignment (Digital)

PNP.

SR 3.1.4.2 PNP plant specific design is analogue and therefore frequency changes to specifications Verify that, for each CEA, its OPERABLE in TSTF-425 that apply to CEA Alignment CEA position indicator channels indicate (Digital) do not apply.

within [5 inches] of each other.

ENO will not adopt this TSTF-425 change for Applies to CEA Alignment (Digital)

PNP.

SR 3.1.4.3 PNP plant specific design is analogue and therefore frequency changes to specifications Verify full length CEA freedom of movement in TSTF-425 that apply to CEA Alignment (trippability) by moving each individual full (Digital) do not apply.

length CEA that is not fully inserted in the core at least [5 inches].

ENO will not adopt this TSTF-425 change for PNP.

Applies to CEA Alignment (Digital)

Page 77 of 1 06

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR SR 3.1.4.4 Perform a CHANNEL FUNCTIONAL TEST of each reed switch position transmitter channel.

Applies to CEA Alignment (Digital)

SR 3.1.5.1 Verify each shutdown CEA is withdrawn

'd145] inches.

Applies to Shutdown CEA insertion Limits (Digital)

SR 3.1.6.1 Verify each regulating CEA group position is within its insertion limits.

Applies to Regulating CEA insertion Limits (Digital)

SR 3.1.6.2 Verify the accumulated times during which the regulating CEA groups are inserted beyond the steady state insertion limits but within the transient insertion limits.

Applies to Regulating CEA insertion Limits (Digital)

SR 3.1.6.3 Verify POlL alarm circuit is OPERABLE.

Applies to Regulating CEA insertion Limits (Digital)

PNPTS PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to CEA Alignment (Digital) do not apply.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to Part Length CEA Insertion Limits (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to Part Length CEA Insertion Limits (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to Part Length CEA Insertion Limits (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to Part Length CEA Insertion Limits (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

Page 78 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.1.7.1 Verify part length CEA group position.

Applies to Part Length CEA insertion Limits (Digital)

SR 3.1.8.1 Verify that the position of each CEA not fully inserted is within the acceptance criteria for available negative reactivity addition.

Applies to STE-SDM (Digital)

SR 3.1.9.1 Verify THERMAL POWER equal to or less than the test power plateau.

Applies to STE-MODES 1 and 2 (Digital)

SR 3.2.1.1 (Digital)

Verify LHR, as indicated on each OPERABLE local power density channel, is within its limit.

Applies to LHR (Digital)

SR 3.2.1.2 (Digital)

Verify the COLSS margin alarm actuates at a THERMAL POWER equal to or less than the core power operating limit based on LHR.

Applies to LHR (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to Part Length CEA Insertion Limits (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to STE-SDM (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to STE-MODES 1 and 2 (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to LHR (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to LHR (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

Page 79 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR SR 3.2.2.1 (Digital)

Verify measured FMXY obtained using the incore Detector System is equal to or less than the value of FCxy used in the COLSS and CPCs.

Applies to Fxy (Digital)

SR 3.2.3.1 (Digital)

Calculate Tq and verify it is within the limit.

Applies to Tq (Digital)

SR 3.2.3.2 (Digital)

Verify COLSS azimuthal tilt alarm is actuated at a Tq less than the Tq value used in the CPCs.

Applies to T q (Digital)

SR 3.2.3.3 (Digital)

Independently confirm the validity of the COLSS calculated Tq by use of the incore detectors.

Applies to T q (Digital)

SR 3.2.4.1 (Digital)

Verify DNBR, as indicated on al/ OPERABLE DNBR channels, is within the limit of Figure 3.2.4-1 or 3.2.4-2 of the COLR as applicable.

Applies to departure from nucleic boiling (DNBR) (Digital)

PNPTS PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to Fxy (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to Tq (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to Tq (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to T q (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to DNBR (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

Page 80 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.2.4.2 (Digital)

Verify COLSS margin alarm actuates at a THERMAL POWER level equal to or less than the core power operating limit based on DNBR.

Applies to (DNBR) (Digital)

SR 3.2.5.1 (Digital)

Verify ASI is within limits.

Applies to axial shape index (ASI) (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to DNBR (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to ASI (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.7.1 (Analog)

PNP plant specific design does not include a CPIS system. Therefore frequency changes Perform a CHANNEL CHECK on each to specifications in TSTF-425 that apply to containment radiation monitor channel.

CPIS (Analog) do not apply to PNP.

Applies to containment purge isolation signal ENO will not adopt this TSTF-425 change for (CPIS) (Analog).

PNP.

SR 3.3.7.2 (Analog)

PNP plant specific design does not include a CPIS system. Therefore frequency changes Perform a CHANNEL FUNCTIONAL TEST to specifications in TSTF-425 that apply to on each containment radiation monitor CPIS (Analog) do not apply to PNP.

channel.

ENO will not adopt this TSTF-425 change for Verify CPIS high radiation setpoint is less PNP.

than or equal to the Allowable Value of [220 mR/hr].

Applies to containment purge isolation signal (CPIS) (Analog).

Page 81 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.3.7.3 (Analog)

Perform a CHANNEL FUNCTIONAL TEST on each CPIS Actuation Logic channel.

Applies to containment purge isolation signal (CPIS) (Analog).

SR 3.3.7.4 (Analog)

Perform a CHANNEL CAL/BRA TlON on each containment radiation monitor channel.

Applies to containment purge isolation signal (CPIS) (Analog).

SR 3.3.7.5 (Analog)

Perform a CHANNEL FUNCTIONAL TEST on each CPIS Manual Trip channel.

Applies to containment purge isolation signal (CPIS) (Analog).

SR 3.3.7.6 (Analog)

Verify CPIS response time of each containment radiation channel is within limits.

Applies to containment purge isolation signal (CPIS) (Analog).

SR 3.3.9.1 (Analog)

Perform a CHANNEL CHECK.

Applies to chemical volume control system (CVCS) isolation signal (Analog).

PNP plant specific design does not include a CPIS system. Therefore frequency changes to specifications in TSTF-425 that apply to CPIS (Analog) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design does not include a CPIS system. Therefore frequency changes to specifications in TSTF-425 that apply to CPIS (Analog) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design does not include a CPIS system. Therefore frequency changes to specifications in TSTF-425 that apply to CPIS (Analog) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design does not include a CPIS system. Therefore frequency changes to specifications in TSTF-425 that apply to CPIS (Analog) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design does not include a TS CVCS isolation system. Therefore frequency changes to specifications in TSTF-425 that apply to CVCS Isolation Signal (Analog) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

Page 82 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.3.9.2 (Analog)

Perform a CHANNEL FUNCTIONAL TEST on each CVCS isolation channel with setpoints in accordance with the following Allowable Values:

West Penetration Room Pressure - High Letdown Heat Exchanger

~.5 psig Room Pressure - High S 5 psig Applies to chemical volume control system (eVeS) isolation signal (Analog).

PNP plant specific design does not include a TS eves isolation system. Therefore frequency changes to specifications in TSTF-425 that apply to eves Isolation Signal (Analog) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.9.3 (Analog)

PNP plant specific design does not include a TS eves isolation system. Therefore Perform a CHANNEL CAL/BRA TlON on each frequency changes to specifications in CVCS isolation pressure indicating channel.

TSTF-425 that apply to eves Isolation Signal (Analog) do not apply to PNP.

Applies to chemical volume control system (eVeS) isolation signal (Analog).

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.10.1 (Analog)

PNP plant specific design does not include a SBFAS isolation system. Therefore frequency Perform a CHANNEL FUNCTIONAL TEST changes to specifications in TSTF-425 that on each SBFAS Automatic actuation channel.

apply to SBFAS (Analog) do not apply to PNP.

Applies to shield building filtration actuation signal (SBFAS) (Analog).

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.10.2 (Analog)

PNP plant specific design does not include a SBFAS isolation system. Therefore frequency Perform a CHANNEL FUNCTIONAL TEST changes to specifications in TSTF-425 that on each SBFAS Manual Trip channel.

apply to SBFAS (Analog) do not apply to PNP.

Applies to shield building filtration actuation signal (SBFAS) (Analog).

ENO will not adopt this TSTF-425 change for PNP.

Page 83 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR SR 3.3.12.4 (Analog)

[Perform CHANNEL FUNCTIONAL TEST of the reactor trip circuit breaker open/closed indication.

Applies to Remote Shutdown System (Analog)

SR 3.3.1.1 (Digital)

Perform a CHANNEL CHECK of each RPS instrument channel except Loss of Load.

Applies to RPS Instrumentation - Operating (Digital)

SR 3.3.1.2 (Digital)

Verify total Reactor Coolant System (RCS) flow rate as indicated by each CPC is less than or equal to the RCS total flow rate.

If necessary, adjust the CPC addressable constant flow coefficients such that each CPC indicated flow is less than or equal to the RCS flow rate.

Applies to RPS Instrumentation - Operating (Digital)

SR 3.3.1.3 (Digital)

Check the CPC auto restart count.

Applies to RPS Instrumentation - Operating (Digital)

PNPTS PNP plant specific design does not include reactor trip circuit breaker open/closed indication. Therefore frequency changes to specifications in TSTF-425 that apply to SBFAS (Analog) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to RPS Instrumentation - Operating (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to RPS Instrumentation - Operating (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to RPS Instrumentation - Operating (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

Page 84 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.3.1.4 (Digital)

Perform calibration (heat balance only) and adjust the linear power level signals and the CPC addressable constant multipliers to make the CPC /:t,. T power and CPC nuclear power calculations agree with the calorimetric, if the absolute difference is ~

[2]%.

Applies to RPS Instrumentation - Operating (Digital)

SR 3.3.1.5 (Digital)

Verify total RCS flow rate indicated by each CPC is less than or equal to the RCS flow determined by calorimetric calculations.

Applies to RPS Instrumentation - Operating (Digital)

SR 3.3.1.6 (Digital)

Verify linear power subchannel gains of the excore detectors are consistent with the values used to establish the shape annealing matrix elements in the CPCs.

Applies to RPS Instrumentation - Operating (Digital)

SR 3.3.1.7 (Digital)

Perform a CHANNEL FUNCTIONAL TEST on each channel except Loss of Load and power range neutron flux.

Applies to RPS Instrumentation - Operating (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to RPS Instrumentation - Operating (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to RPS Instrumentation - Operating (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to RPS Instrumentation - Operating (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to RPS Instrumentation - Operating (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

Page 85 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNPTS SR 3.3.1.8 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL CAL/BRA TION of the in TSTF-425 that apply to RPS power range neutron flux channels.

Instrumentation - Operating (Digital) do not apply to PNP.

Applies to RPS Instrumentation - Operating (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.1.9 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL FUNCTIONAL TEST in TSTF-425 that apply to RPS for Loss of Load Function.

Instrumentation - Operating (Digital) do not apply to PNP.

Applies to RPS Instrumentation - Operating (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.1.10 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL CAL/BRA TlON on each in TSTF-425 that apply to RPS channel, including bypass removal functions.

Instrumentation - Operating (Digital) do not apply to PNP.

Applies to RPS Instrumentation - Operating (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.1.11 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL FUNCTIONAL TEST in TSTF-425 that apply to RPS on each CPC channel.

Instrumentation - Operating (Digital) do not apply to PNP.

Applies to RPS Instrumentation - Operating (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.1.14 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Verify RPS RESPONSE TIME is within limits.

in TSTF-425 that apply to RPS Instrumentation - Operating (Digital) do not Applies to RPS Instrumentation - Operating apply to PNP.

(Digital)

ENO will not adopt this TSTF-425 change for PNP.

Page 86 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNPTS SR 3.3.2.1 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL CHECK of each in TSTF-425 that apply to RPS logarithmic power channel.

Instrumentation - Shutdown (Digital) do not apply to PNP.

Applies to RPS Instrumentation - Shutdown (Digital)

END will not adopt this TSTF-425 change for PNP.

SR 3.3.2.2 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL FUNCTIONAL TEST in TSTF-425 that apply to RPS on each logarithmic power channel.

Instrumentation - Shutdown (Digital) do not apply to PNP.

Applies to RPS Instrumentation - Shutdown (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.2.4 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL CAL/BRA TlON on each in TSTF-425 that apply to RPS logarithmic power channel, including bypass Instrumentation - Shutdown (Digital) do not removal function with Allowable Value for trip apply to PNP.

channels < [93]%.

END will not adopt this TSTF-425 change for Applies to RPS Instrumentation - Shutdown PNP.

(Digital)

SR 3.3.2.5 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Verify RPS RESPONSE TIME is within limits.

in TSTF-425 that apply to RPS Instrumentation - Shutdown (Digital) do not Applies to RPS Instrumentation - Shutdown apply to PNP.

(Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.3.1 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL CHECK.

in TSTF-425 that apply to CEACs (Digital) do not apply to PNP.

Applies to CEACs (Digital)

END will not adopt this TSTF-425 change for PNP.

Page 87 of 1 06

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNPTS SR 3.3.3.2 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Check the CEAC auto restart count.

in TSTF-425 that apply to CEACs (Digital) do not apply to PNP.

Applies to CEACs (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.3.3 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL FUNCTIONAL TEST.

in TSTF-425 that apply to CEACs (Digital) do not apply to PNP.

Applies to CEACs (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.3.4 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL CAL/BRA TION.

in TSTF-425 that apply to CEACs (Digital) do not apply to PNP.

Applies to CEACs (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.3.5 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL FUNCTIONAL TEST.

in TSTF-425 that apply to CEACs (Digital) do not apply to PNP.

Applies to CEACs (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.3.6 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Verify the isolation characteristics of each in TSTF-425 that apply to CEACs (Digital) do CEAC isolation amplifier and each optical not apply to PNP.

isolator for CEA C to CPC data transfer.

ENO will not adopt this TSTF-425 change for Applies to CEACs (Digital)

PNP.

Page 88 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.3.4.1 (Digital)

Perform a CHANNEL FUNCTIONAL TEST on each RTCB channel.

Applies to RPS Logic and Trip Initiation (Digital)

SR 3.3.4.2 (Digital)

Perform a CHANNEL FUNCTIONAL TEST on each RPS Logic channel.

Applies to RPS Logic and Trip Initiation (Digital)

SR 3.3.4.3 (Digital)

Perform a CHANNEL FUNCTIONAL TEST, including separate verification of the undervoltage and shunt trips, on each RTCB.

Applies to RPS Logic and Trip Initiation (Digital)

SR 3.3.5.1 (Digital)

Perform a CHANNEL CHECK of each ESFAS channel.

Applies to ESFAS Instrumentation (Digital)

SR 3.3.5.2 (Digital)

Perform a CHANNEL FUNCTIONAL TEST of each ESFAS channel.

Applies to ESFAS Instrumentation (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to RPS Logic and Trip Initiation (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to RPS Logic and Trip Initiation (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to RPS Logic and Trip Initiation (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to ESFAS Instrumentation (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to ESFAS Instrumentation (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

Page 89 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNPTS SR 3.3.5.3 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL CALIBRA TlON of each in TSTF-425 that apply to ESFAS ESFAS channel, including bypass removal Instrumentation (Digital) do not apply to PNP.

functions.

ENO will not adopt this TSTF-425 change for Applies to ESFAS Instrumentation (Digital)

PNP.

SR 3.3.5.4 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Verify ESF RESPONSE TIME is within limits.

in TSTF-425 that apply to ESFAS Instrumentation (Digital) do not apply to PNP.

Applies to ESFAS Instrumentation (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.6.1 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL FUNCTIONAL TEST in TSTF-425 that apply to ESFAS Logic and on each ESFAS logic channel.

Manual Trip (Digital) do not apply to PNP.

Applies to ESFAS Logic and Manual Trip ENO will not adopt this TSTF-425 change for (Digital)

PNP.

SR 3.3.6.2 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a subgroup relay test of each in TSTF-425 that apply to ESFAS Logic and Actuation Logic channel, which includes the Manual Trip (Digital) do not apply to PNP.

de-energization of each subgroup relay and verification of the OPERABILITY of each ENO will not adopt this TSTF-425 change for subgroup relay..

PNP.

Applies to ESFAS Logic and Manual Trip (Digital)

SR 3.3.6.3 (Digital)

PNP plant specific design is analogue and therefore frequency changes to speCifications Perform a CHANNEL FUNCTIONAL TEST in TSTF-425 that apply to ESFAS Logic and on each ESFAS Manual Trip channel.

Manual Trip (Digital) do not apply to PNP.

Applies to ESFAS Logic and Manual Trip ENO will not adopt this TSTF-425 change for (Digital)

PNP.

Page 90 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.3.7.1 (Digital)

[Perform CHANNEL CHECK.

Applies to DG - LOVS (Digital)

SR 3.3.7.2 (Digital)

Perform CHANNEL FUNCTIONAL TEST.

Applies to DG - LOVS (Digital)

SR 3.3.7.3 (Digital)

Perform CHANNEL CAL/BRA TlON with setpoint Allowable Values as follows:

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to DG - LOVS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to DG - LOVS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to DG - LOVS (Digital) do not apply to PNP.

a.

Degraded Voltage Function;:: [3180] V ENO will not adopt this TSTF-425 change for and:S; [3220] V PNP.

Time delay: ;:: [ ] seconds and

s;

[ ] seconds at [ ] V and

b.

Loss of Voltage Function;:: [3180] V and :s; [3220] V Time delay: ;:: [ ] seconds and :s;

[ ] seconds at [ ] V.

Applies to DG - LOVS (Digital)

SR 3.3.8.1 (Digital)

Perform a CHANNEL CHECK on required containment area and gaseous radiation monitor channel.

Applies to CPIS (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to CPIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

Page 91 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR SR 3.3.8.2 (Digital)

Perform a CHANNEL CHECK on required containment particulate and iodine radiation monitor channel.

Applies to CPIS (Digital)

SR 3.3.8.3 (Digital)

Perform a CHANNEL FUNCTIONAL TEST on each required containment radiation monitor channel. Verify setpoint [Allowable Value] is in accordance with the following:

Containment Gaseous Monitor:

~ [2X background]

Containment Particulate Monitor:

~ [2X background]

Containment Area Gamma Monitor:

~ [325 mRlhr]

Applies to CPIS (Digital)

SR 3.3.8.4 (Digital)

Perform a CHANNEL FUNCTIONAL TEST on required containment radiation monitor channel. Verify setpoint [Allowable Value] is in accordance with the following:

Containment Gaseous Monitor:

~ [2X background]

Containment Particulate Monitor:

~ [2X background]

Containment Iodine Monitor:

~ [2X background]

Containment Area Gamma Monitor:

~ [2X background]

Applies to CPIS (Digital)

PNPTS PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to CPIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to CPIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to CPIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

Page 92 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.3.8.5 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL FUNCTIONAL TEST in TSTF-425 that apply to CPIS (Digital) do on required CIPS Actuation Logic channel.

not apply to PNP.

Applies to CPIS (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.8.6 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL CAL/BRA TlON on in TSTF-425 that apply to CPIS (Digital) do required containment radiation monitor not apply to PNP.

channel.

ENO will not adopt this TSTF-425 change for Applies to CPIS (Digital)

PNP.

SR 3.3.8.7 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Verify that response time of required CPIS in TSTF-425 that apply to CPIS (Digital) do channel is within limits.

not apply to PNP.

Applies to CPIS (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.8.8 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform CHANNEL FUNCTIONAL TEST on in TSTF-425 that apply to CPIS (Digital) do required CPIS Manual Trip channel.

not apply to PNP.

Applies to CPIS (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.9.1 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL CHECK on the required in TSTF-425 that apply to CRIS (Digital) do control room radiation monitor channel.

not apply to PNP.

Applies to CRIS (Digital)

ENO will not adopt this TSTF-425 change for PNP.

Page 93 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.3.9.2 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL FUNCTIONAL TEST in TSTF-425 that apply to CRIS (Digital) do on required CRIS radiation monitor channel.

not apply to PNP.

Verify CRIS high radiation setpoint [Allowable ENO will not adopt this TSTF-425 change for Value] is ~ [6E4] cpm above normal PNP.

background.

Applies to CRIS (Digital)

SR 3.3.9.3 (Digital)

Perform a CHANNEL FUNCTIONAL TEST on required CRIS Actuation Logic channel.

Applies to CRIS (Digital)

SR 3.3.9.4 (Digital)

Perform a CHANNEL CAL/BRA TlON on required CRIS radiation monitor channel.

Applies to CRIS (Digital)

SR 3.3.9.5 (Digital)

Perform a CHANNEL FUNCTIONAL TEST on required CRIS Manual Trip channel.

Applies to CRIS (Digital)

SR 3.3.9.6 (Digital)

[verify that response time of required CRIS channel is within limits.

Applies to CRIS (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to CRIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to CRIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to CRIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to CRIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

Page 94 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.3.10.1 (Digital)

Perform a CHANNEL CHECK on required FHIS radiation monitor channel.

Applies to FHIS (Digital)

SR 3.3.10.2 (Digital)

Perform a CHANNEL FUNCTIONAL TEST on required FHIS radiation monitor channel.

Verify radiation monitor setpoint [Allowable Values};

[Airborne Particulate/ Iodine: is ~ [6E4} cpm above background}

Airborne Gaseous:

~ [6E4} cpm above background Applies to FHIS (Digital)

SR 3.3.10.3 (Digital)

Perform a CHANNEL CHECK on required FHIS Actuation Logic channel.

Applies to FHIS (Digital)

SR 3.3.10.4 (Digital)

Perform a CHANNEL CHECK on required FHIS Manual Trip logic.

Applies to FHIS (Digital)

SR 3.3.10.5 (Digital)

Perform a CHANNEL CAL/BRA TION on required FHIS radiation monitor channel.

Applies to FHIS (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to FHIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to FHIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to FHIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to FHIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to FHIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

Page 95 of 1 06

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.3.10.6 (Digital)

[Verify response time of required FHIS channel is within limits.

Applies to FHIS (Digital)

SR 3.3.11.1 (Digital)

Perform a CHANNEL CHECK on each required instrument channel that is normally energized.

Applies to PAM Instrumentation (Digital)

SR 3.3.11.2 (Digital)

Perform CHANNEL CAL/BRA TlON.

Applies to PAM Instrumentation (Digital)

SR 3.3.12.1 (Digital)

[Perform a CHANNEL CHECK on each required instrument channel that is normally energized.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to FHIS (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to PAM Instrumentation (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to PAM Instrumentation (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to Remote Shutdown System (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for Applies to Remote Shutdown System (Digital)

PNP.

SR 3.3.12.2 (Digital)

Verify each required control circuit and transfer switch is capable of performing the intended function.

PNP plant specific design is analogue and therefore frequency changes to specifications in TSTF-425 that apply to Remote Shutdown System (Digital) do not apply to PNP.

ENO will not adopt this TSTF-425 change for Applies to Remote Shutdown System (Digital)

PNP.

Page 96 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNPTS SR 3.3.12.3 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform CHANNEL CAL/BRA TION for each in TSTF-425 that apply to Remote Shutdown required instrumentation channel.

System (Digital) do not apply to PNP.

Applies to Remote Shutdown System (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.12.4 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications

[Perform CHANNEL FUNCTIONAL TEST of in TSTF-425 that apply to Remote Shutdown the reactor trip circuit breaker open/closed System (Digital) do not apply to PNP.

indication.

ENO will not adopt this TSTF-425 change for Applies to Remote Shutdown System (Digital)

PNP.

SR 3.3.13.1 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform a CHANNEL CHECK.

in TSTF-425 that apply to [Logarithmic]

Power Monitoring Channels (Digital) do not Applies to [Logarithmic] Power Monitoring apply to PNP.

Channels (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.13.2 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform CHANNEL FUNCTIONAL TEST.

in TSTF-425 that apply to [Logarithmic]

Power Monitoring Channels (Digital) do not Applies to [Logarithmic] Power Monitoring apply to PNP.

Channels (Digital)

ENO will not adopt this TSTF-425 change for PNP.

SR 3.3.13.3 (Digital)

PNP plant specific design is analogue and therefore frequency changes to specifications Perform CHANNEL CAL/BRA TION.

in TSTF-425 that apply to [Logarithmic]

Power Monitoring Channels (Digital) do not Applies to [Logarithmic] Power Monitoring apply to PNP.

Channels (Digital)

END will not adopt this TSTF-425 change for PNP.

Page 97 of 1 06

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.4.12.2 Verify a maximum of one charging pump is capable of injecting into the RCS.

SR 3.4.14.3 Verify SOC System autoclosure interlock causes the valves to close automatically with a simulated or actual RCS pressure signal ~

[600J psig.

SR 3.6.3.1

[Verify each [42J inch purge valve is sealed closed except for one purge valve in a penetration flow path while in Condition E of this LCO.

SR 3.6.3.8

[Verify each [ J inch containment purge valve is blocked to restrict the valve from opening >

[50%].

SR 3.6.68.1 Verify each containment spray 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.

SR 3.6.68.2 Operate each containment cooling train fan unit for ;c 15 minutes.

PNP plant specific design sizes any vent path credited for performing the L TOP function to be sized large enough to accommodate flow from all three charging pumps.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design does not include a SDC System autoclosure interlock that automatically isolates SDC so this SR is not included in PNP TS.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design does not include large [42] inch purge valves and therefore this SR in not included in PNP TS.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant specific design does not include containment purge valves that are blocked to restrict opening therefore this SR is not included in PNP TS.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant's containment is a STS type "A" design and therefore SRs for type "8" containments do not apply.

ENO will not adopt this TSTF-425 change for PNP.

PNP plant's containment is a STS type "A" design and therefore SRs for type "8" containments do not apply.

ENO will not adopt this TSTF-425 change for PNP.

Page 98 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR SR 3.6.68.3 Verify each containment cooling train cooling water flow rate is ~ [2000] gpm to each fan cooler.

SR 3.6.68.4

[Verify the containment spray piping is full of water to the [100] ft level in the containment spray header.

SR 3.6.68.6 Verify each automatic containment spray valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to its correct position on an actual or simulated actuation signal.

SR 3.6.68.7 Verify each containment spray pump starts automatically on an actual or simulated actuation signal.

SR 3.6.68.8 Verify each containment cooling train starts automatically on an actual or simulated actuation signal.

SR 3.6.68.9 Verify each spray nozzle is unobstructed.

PNPTS PNP plant's containment is a STS type "A" design and therefore SRs for type "8" containments do not apply.

ENO will not adopt this TSTF-425 change for PNP.

PNP containment is a STS type "A" design and therefore SRs for type "8" containments do not apply.

ENO will not adopt this TSTF-425 change for PNP.

PNP containment is a STS type "A" design and therefore SRs for type "8" containments do not apply.

ENO will not adopt this TSTF-425 change for PNP.

PNP containment is a STS type "N design and therefore SRs for type "8" containments do not apply.

ENO will not adopt this TSTF-425 change for PNP.

PNP containment is a STS type "A" design and therefore SRs for type "8" containments do not apply.

ENO will not adopt this TSTF-425 change for PNP.

PNP containment is a STS type "A" design and therefore SRs for type "8" containments do not apply.

ENO will not adopt this TSTF-425 change for PNP.

Page 99 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.6.7.1 PNP design does not credit a containment spray additive.

Verify each spray additive manual, power operated, and automatic valve in the flow ENO will not adopt this TSTF-425 change for path that is not locked, sealed, or otherwise PNP.

secured in position is in the correct position.

SR 3.6.7.2 PNP design does not credit a containment spray additive.

Verify spray additive tank solution volume is

~ [816] gal [90%] and ~ [896] gal [100%].

ENO will not adopt this TSTF-425 change for PNP.

SR 3.6.7.3 PNP design does not credit a containment spray additive.

Verify spray additive tank [N2H2] solution concentration is ~ [33%] and ~ [35%] by ENO will not adopt this TSTF-425 change for weight.

PNP.

SR 3.6.7.5 PNP design does not credit a containment spray additive.

Verify each spray additive automatic valve in the flow path that is not locked, sealed, or ENO will not adopt this TSTF-425 change for otherwise secured in position, actuates to its PNP.

correct position on an actual or simulated actuation signal.

SR 3.6.7.6 PNP design does not credit a containment spray additive.

[Verify spray additive flow [rate] from each solution's flow path.

ENO will not adopt this TSTF-425 change for PNP.

SR 3.6.8.1 PNP design does not include a SBEACS.

Operate each SBEACS train for [> 10 ENO will not adopt this TSTF-425 change for continuous hours with the heaters operating PNP.

or (for systems without heaters) > 15 minutes).

Shield Building Exhaust Air Cleanup System (SBEACS)

Page 100 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNPTS SR 3.6.8.3 PNP design does not include a SBEACS.

Verify each SBEACS train actuates on an ENO will not adopt this TSTF-425 change for actual or simulated actuation signal.

PNP.

SR 3.6.8.4 PNP design does not include a SBEACS.

[Verify each SBEACS filter bypass damper ENO will not adopt this TSTF-425 change for can be opened.

PNP.

SR 3.6.8.5 PNP plant's design does not include a SBEACS.

Verify each SBEACS train flow rate is ~ []

cfm.

ENO will not adopt this TSTF-425 SR Frequency change for PNP SR 3.6.9.1 PNP design does not include a HMS.

Operate each HMS train for ~ 15 minutes.

ENO will not adopt this TSTF-425 change for PNP.

Hydrogen Mixing System (HMS)

SR 3.6.9.2 PNP design does not include a HMS.

Verify each HMS train flow rate on slow ENO will not adopt this TSTF-425 change for speed is ~ [37,000] cfm.

PNP.

SR 3.6.9.3 PNP design does not include a HMS.

Verify each HMS train starts on an actual or ENO will not adopt this TSTF-425 change for simulated actuation signal.

PNP.

SR 3.6.10.1 PNP design does not include an ICS.

Operate each ICS train for [> 10 continuous ENO will not adopt this TSTF-425 change for hours with heaters operating or (for systems PNP.

without heaters) > 15 minutes).

Iodine Cleanup System (ICS)

Page 101 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.6.10.3 PNP design does not include an ICS.

Verify each ICS train actuates on an actual or END will not adopt this TSTF-425 change for simulated actuation signal.

PNP.

SR 3.6.10.4 PNP design does not include an ICS.

[Verify each ICS filter bypass damper can be END will not adopt this TSTF-425 change for opened.

PNP.

SR 3.6.11.1 PNP design does not include a shield building.

Verify annulus negative pressure is > [5]

inches water gauge.

END will not adopt this TSTF-425 change for PNP.

This is applicable to containments with shield buildings.

SR 3.6.11.2 PNP design does not include a shield building.

Verify one shield building access door in each access opening is closed.

END will not adopt this TSTF-425 change for PNP.

This is applicable to containments with shield buildings.

SR 3.6.11.4 PNP design does not include a shield building.

Verify shield building can be maintained at a pressure equal to or more negative than END will not adopt this TSTF-425 change for

[-0.25] inch water gauge in the annulus by PNP.

one Shield Building exhaust Air Cleanup System train with a final flow rate < [ ] cfm within [1] minute after a start signal.

This is applicable to containments with shield buildings.

SR 3.7.4.2 PNP design does not include ADV block valves.

[Verify one complete cycle of each ADV block valve.

END will not adopt this TSTF-425 change for PNP.

Atmospheric Dump Valves (ADV)

Page 102 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.7.10.1 Verify each EGW 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.

Essential Ghilled Water (EGW)

SR 3.7.10.2 Verify the proper actuation of each EGW System component on an actual or simulated actuation signal.

SR 3.7.13.1 Operate each EGGS PREAGS train for

~ 10 continuous hours with heaters operating or (for systems without heaters) ~ 15 minutes].

Emergency Gore Gooling System (EGGS)

Pump Room Exhaust Air Gleanup System (PREAGS)

SR 3.7.13.3 Verify each EGGS PREAGS train actuates on an actual or simulated actuation signal.

SR 3.7.13.4 Verify one EGGS PREAGS train can maintain a negative pressure of ~ [ ] inches water gauge, relative to atmospheric pressure during the [post accident] mode of operation at a flow rate of ~ [20,000] cfm.

SR 3.7.13.5

[Verify each EGGS PREAGS filter bypass damper can be opened.

PNP design does not include an EGW system.

ENO will not adopt this TSTF-425 change for PNP.

PNP design does not include an EGW system.

ENO will not adopt this TSTF-425 change for PNP.

PNP design does not include an EGGS PREAGS system.

ENO will not adopt this TSTF-425 change for PNP.

PNP design does not include an EGGS PREAGS system.

ENO will not adopt this TSTF-425 change for PNP.

PNP design does not include an EGGS PREAGS system.

ENO will not adopt this TSTF-425 change for PNP.

PNP design does not include an EGGS PREAGS system.

ENO will not adopt this TSTF-425 change for PNP.

Page 103 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNP TS SR 3.7.14.1 PNP design does not include an FBACS system.

Operate each FBACS train for

{?:. 10 continuous hours with heaters operating ENO will not adopt this TSTF-425 change for or (for systems without heaters) 2: 15 PNP.

minutes].

Fuel Building Air Cleanup System (FBACS)

SR 3.7.14.3 PNP design does not include an FBACS system.

[Verify each FBACS train actuates on an actual or simulated actuation signal.

ENO will not adopt this TSTF-425 change for PNP.

SR 3.7.14.4 PNP design does not include an FBACS system.

Verify one FBACS train can maintain a negative pressure of ~ [ ] inches water gauge, ENO will not adopt this TSTF-425 change for with respect to atmospheric pressure during PNP.

the [post accident] mode of operation at a flow rate of ~ [3,000] cfm.

SR 3.7.14.5 PNP design does not include an FBACS system.

[Verify each FBACS filter bypass damper can be opened.

ENO will not adopt this TSTF-425 change for PNP.

SR 3.7.15.1 PNP design does not include an PREACS system.

Operate each PREACS train for

{?:. 10 continuous hours with heater operating ENO will not adopt this TSTF-425 change for or (for systems without heaters) 2: 15 PNP.

minutes].

Penetration Room Exhaust Cleanup System (PREACS)

SR 3.7.15.3

[Verify each PREACS train actuates on an actual or simulated actuation signal.

PNP design does not include an PREACS system.

ENO will not adopt this TSTF-425 change for PNP.

Page 104 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes TABLE 4 TSTF-425 (CEOG STS) CHANGES NOT APPLICABLE DUE TO PNP DESIGN TSTF-425 (CEOG STS) SR PNPTS SR 3.7.15.4 PNP design does not include an PREACS system.

Verify one PREACS train can maintain a negative pressure of 2:. [ ] inches water gauge, ENO will not adopt this TSTF-425 change for with respect to atmospheric pressure during PNP.

the [post accident] mode of operation at a flow rate of 5. [3, 000] cfm.

SR 3.7.15.5 PNP design does not include an PREACS system.

[Verify each PREACS filter bypass damper can be opened.

ENO will not adopt this TSTF-425 change for PNP.

3.0 REGULATORY ANALYSIS

3.1 Applicable Regulatory Requirements A description of the proposed changes and their relationship to applicable regulatory requirements is provided in TSTF-425, Revision 3, and the NRC's model safety evaluation published in the Notice of Availability dated July 6,2009 (Reference 3). ENO has concluded that the relationship of the proposed changes to the applicable regulatory requirements presented in the Federal Register notice is applicable to PNP.

3.2 No Significant Hazards Consideration Entergy Nuclear Operations, Inc. (ENO) has reviewed the proposed no significant hazards consideration determination (NSHC) published in Federal Register 74 FR 32000, dated July 6,2009. ENO has concluded that the proposed NSHC presented in the Federal Register notice is applicable to Palisades Nuclear Plant and is provided as Attachment 6 in this amendment request, which satisfies the requirements of 10 CFR 50.91 (a).

3.3 Precedent Relocation of surveillance frequencies to a licensee controlled program was approved for multiple licensees including:

Cooper Nuclear Station per License Amendment No. 258 issued on March 31, 2017 (NRC ADAMS Accession Number ML17061A050)

D.C. Cook Units 1 and 2 per License Amendment Nos. 334 and 316, respectively, issued on March 31, 2017 (NRC ADAMS Accession Number ML17045A150)

Page 105 of 106

ATTACHMENT 1 PNP 2018-025 Description and Evaluation of Technical Specifications Changes Brunswick Units 1 and 2 per License Amendment Nos. 276 and 304, respectively, issued on May 24, 2017 (NRC ADAMS Accession Number ML17096A129).

3.4 Conclusion Based on the considerations discussed herein, (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.

4.0 ENVIRONMENTAL EVALUATION ENO has reviewed the environmental consideration included in the NRC's model safety evaluation published in the Federal Register on July 6,2009 (74 FR 32006). END has concluded that the NRC's findings presented therein are applicable to Palisades Nuclear Plant, and the determination is hereby incorporated by reference for this application.

5.0 REFERENCES

1. Nuclear Energy Institute (NEI), 04-10, Revision 1, Risk-Informed Technical Specification Initiative Sb, "Risk-Informed Method for Control of Surveillance Frequencies,"dated April 2007 (NRC ADAMS Accession Number ML071360456)
2. Technical Specifications Task Force letter to the NRC, Transmittal of TSTF-42S, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative Sb,"dated March 18,2009 (NRC ADAMS Package Accession Number ML090850642)
3. Federal Register Notice of Availability, 74 FR 31996, Notice of Availability of Technical Specification Improvement to Relocate Surveillance Frequencies to Licensee Control-Risk-Informed Technical Specification Task Force (RITSTF)

Initiative Sb, Technical Specification Task Force-42S, Revision 3, dated July 6,2009

4. NRC letter to Technical Specifications Task Force, Notification of Issue with NRC-Approved Technical Specifications Task Force (TSTF) Traveler TSTF-42S, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative Sb, "

dated April 14, 2010 (NRC ADAMS Accession Number ML100990099)

5. NRC Non-Concurrence, NCP-2015-012, Perry Nuclear Power Plant - Non-Concurrence for Perry Sb LAR (NCP-201S-012) Sections A, B, & C., dated January 22, 2016 (NRC ADAMS Accession Number ML16033A197)
6. Regulatory Guide 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, Revision 2 dated March 2009 (NRC ADAMS Accession Number ML090410014)

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