JAFP-20-0046, License Amendment Request for Adoption of TSTF-478-A, Revision 2, BWR Technical Specification Changes That Implement the Revised Rule for Combustible Gas Control, Using the Consolidated Line Item.

License Amendment Request for Adoption of TSTF-478-A, Revision 2, BWR Technical Specification Changes That Implement the Revised Rule for Combustible Gas Control, Using the Consolidated Line Item.

ML20182A161
Person / Time
Site:	FitzPatrick
Issue date:	06/30/2020
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-20-0046, TSTF-478-A, Rev 2
Download: ML20182A161 (19)

Text

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10CFR50.90 JAFP-20-0046 June 30, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

License Amendment Request for Adoption of TSTF-478-A, Revision 2, BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control, Using the Consolidated Line Item Improvement Process

References:

1) TSTF-478-A, Revision 2, BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control, dated November 21, 2007

2) Federal Register Notice 72FR65610 - Notice of Availability on Model Safety Evaluation; Model No Significant Hazards Determination, and Model Application for Licensees that Wish to Adopt TSTF-478, Revision 2, BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control, dated November 21, 2007 In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC, (Exelon) requests amendments to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No.

DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF).

The proposed amendments would revise the TS for J A F consistent with NRC-approved Industry TS Task Force (TSTF) Change Traveler TSTF-478-A, Revision 2, "BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control" (Reference 1). The availability of this TS improvement was published in the Federal Register on November 21, 2007 (Reference 2) as part of the Consolidated Line Item Improvement Process (CLllP). Exelon reviewed the proposed No Significant Hazards Determination published in Federal Register Notice 72FR65610, dated November 21, 2007 (Reference 2), as part of the CLllP and determined that it is applicable to JAF.

Exelon Generation

U.S. Nuclear Regulatory Commission License Amendment Request Containment Atmospheric Dilution System Elimination From TS Docket No. DPR-59 June 30, 2020 Page 2 The proposed amendments would delete JAF TS 3.6.3.2, "Containment Atmospheric Dilution (CAD) System," requirements and associated Bases consistent with NRC-approved TSTF-478-A, Revision 2. This TSTF also discusses TS and associated Bases changes for the TS section concerning Drywell Cooling System Fans. The JAF TS do not contain this TS section, and therefore, these changes are not applicable.

The NRC has previously approved a similar amendment request as noted in Section 5.2 of Precedent of Attachment 1.

provides an evaluation and assessment of the proposed changes to remove TS requirements consistent with the applicable criteria specified in NRC-approved TSTF-478-A, Revision 2. These proposed changes will result in modifications to containment combustible gas control TS requirements as permitted by 10 CFR 50.44, "Combustible gas control for nuclear power reactors." Attachment 2 contains the TS page mark-ups for the proposed TS changes. Attachment 3 contains the mark-ups for the associated TS Bases pages for information only.

The proposed changes have been reviewed by the Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the Exelon Quality Assurance Program.

Exelon requests review of this amendment request under the Consolidated Line Item Improvement Process (CLIIP). Exelon requests approval of the proposed amendments by June 30, 2021. Once approved, the amendments shall be implemented within 60 days.

There are no new commitments contained in this submittal.

Pursuant to 10 CFR 50.91 (b)(1), a copy of this License Amendment Request is being provided to the designated New York State official.

Should you have any questions concerning this letter, please contact Mr. Enrique Villar at (610) 765-5736.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of June 2020.

Respectfully, David T. Gudger Senior Manager, Licensing Exelon Generation Company, LLC David T. Gudger

U.S. Nuclear Regulatory Commission License Amendment Request Containment Atmospheric Dilution System Elimination From TS Docket No. DPR-59 June 30, 2020 Page 3 Attachments: 1. Evaluation of Proposed Changes

2. Markup of Proposed Technical Specifications Pages

3. Re-typed Technical Specification Pages

4. Markup of Proposed Technical Specifications Bases Pages (For Information Only) cc: Regional Administrator - NRC Region I w/ attachments NRC Senior Resident Inspector - JAF NRC Project Manager, NRR - JAF A. L. Peterson, NYSERDA

ATTACHMENT 1 Evaluation of Proposed Changes James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control Using the Consolidated Line Item Improvement Process 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria 5.2 Precedent 5.3 No Significant Hazards Consideration 5.4 Conclusion

7.0 REFERENCES

ATTACHMENT 1 Evaluation of Proposed Changes Page 1 of 4 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC, (Exelon) requests amendments to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF).

The proposed amendments would revise the TS for J A F consistent with NRC-approved Industry TS Task Force (TSTF) Change Traveler TSTF-478-A, Revision 2, "BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control" (Reference 1). The availability of this TS improvement was published in the Federal Register on November 21, 2007 (Reference 2) as part of the Consolidated Line Item Improvement Process (CLllP). Exelon reviewed the proposed No Significant Hazards Determination published in Federal Register Notice 72FR65610, dated November 21, 2007 (Reference 2), as part of the CLllP and determined that it is applicable to JAF.

The proposed amendments would delete JAF TS 3.6.3.2, "Containment Atmospheric Dilution (CAD) System," requirements and associated Bases consistent with NRC-approved TSTF-478-A, Revision 2. This TSTF also discusses TS and associated Bases changes for the TS section concerning Drywell Cooling System Fans. The JAF TS do not contain this TS section, and therefore, these changes are not applicable.

Variations from the NRC-approved TSTF-478-A, Revision 2, and the proposed TS changes are delineated in Section 2.0 below.

2.0 DETAILED DESCRIPTION Consistent with the NRC-approved Revision 2 of TSTF-478-A, the proposed TS changes delete TS 3.6.3.1, "Containment Atmospheric Dilution (CAD) System,"

requirements. The proposed revisions to the TS Bases are also included in this submittal. Adoption of the TS Bases associated with TSTF-478-A, Revision 2, is an integral part of implementing the proposed TS amendments. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.

The proposed amendments are being made in accordance with the CLIIP. Exelon is proposing the following minor variations from the TS changes described in TSTF-478-A, Revision 2, and the U.S. Nuclear Regulatory Commissions (NRCs) model Safety Evaluation (SE) published in the Federal Register on November 21, 2007 (i.e.,

72FR65610).

The JAF TS for the CAD System is TS 3.6.3.2 rather than TS 3.6.3.3 as provided in the TSTF mark-ups.

ATTACHMENT 1 Evaluation of Proposed Changes Page 2 of 4 TSTF-478-A, Revision 2, also makes TS and Bases changes for the TS section on Drywell Cooling System Fans. Since the JAF TS do not have this section these changes are not applicable.

3.0 BACKGROUND

The background for this application is stated in the model SE in the NRCs Notice of Availability published in the Federal Register on November 21, 2007 (i.e., 72 FR 65610) and TSTF-478-A, Revision 2. The proposed changes are consistent with the NRC-approved TSTF-478-A, Revision 2, intended to modify containment combustible gas control requirements as permitted by 10 CFR 50.44, Combustible gas control for nuclear power reactors. The deviations from the approved TSTF-478-A, Revision 2, are discussed above in Section 2.0.

4.0 TECHNICAL EVALUATION

Exelon has reviewed the model SE published in the Federal Register dated November 21, 2007 (i.e., 72 FR 65610), as part of the CLIIP Notice of Availability.

Exelon has concluded that the changes presented in the model SE prepared by the NRC are applicable to JAF, and therefore, justify the proposed TS amendments.

Section 5.2.3.8.3 of the JAF, Updated Final Safety Analysis Report (UFSAR) describes the CAD System.

The CAD system will be maintained functional to support the operation of the ADS system. Maintaining the CAD system functional will also allow the system to be potentially used in conjunction with the station emergency operating procedures. [SRMN1]

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements A description of these proposed changes and their relationship to applicable regulatory requirements and guidance was provided in the NRCs Notice of Availability published in the Federal Register dated November 21, 2007 (i.e., 72FR65610).

5.2 Precedent This application is being made in accordance with the CLIIP. Exelon is not proposing significant variations or deviations from the TS changes described in TSTF-478-A, Revision 2 or in the content of the NRCs model SE published in the Federal Register on November 21, 2007 (i.e., 72FR65610).

ATTACHMENT 1 Evaluation of Proposed Changes Page 3 of 4 Similar amendment requests were submitted for Duane Arnold Energy Center on July 17, 2006 (ML062080521), Progress Energys Brunswick Steam Electric Plant, Units 1 and 2 on November 24, 2008 (ML08330316), and Exelons Peach Bottom Power Station on July 30, 2009 (ML092220045). The NRC approved the license amendment request for Duane Arnold on June 28, 2007 (ML071420246), for Brunswick Steam Electric Plant, Units 1 and 2 on April 13, 2009 (ML090550055), and for Peach Bottom Power Station on January 28, 2010 (ML100130814).

5.3 No Significant Hazards Consideration (NSHC)

Exelon has reviewed the proposed no significant hazards consideration determination published in the Federal Register on November 21, 2007 (i.e., 72FR65610), as part of the CLIIP Notice of Availability. Exelon has concluded that the determination presented in the notice is applicable to FitzPatrick, and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

Based on the above, Exelon concludes that the proposed changes do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

5.4 Conclusion In conclusion, based on the considerations discussed above, (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.

6.0 ENVIRONMENTAL CONSIDERATION

Exelon has reviewed the environmental evaluation included in the model SE published on November 21, 2007 (i.e., 72 FR 65610), as part of the CLIIP Notice of Availability.

Exelon has concluded that the NRCs findings presented in that evaluation are applicable to JAF, and the evaluation is hereby incorporated by reference for this application.

7.0 REFERENCES

1. Federal Register Notice, Notice of Availability published on November 21, 2007 (72FR65610).

2. TSTF-478-A Revision 2, "BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control."

ATTACHMENT 2 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 Mark-ups of Technical Specifications Pages 3.6.3.2-1 3.6.3.2-2

3.6 CONTAINMENT S¥STeMS 3.6.3.2 Gentainment AtmospheFe Dlh,Jtion (C.b.D} System LCO a.s.a.2 Two GAD s1;1hsystems shall ee OPERABLE.

APPUCABlblTY:

MODES 1 and 2.

ACTIONS GONDITIQN REQ~IRED AC+ION A:

One CAD sub~em A-.1 RestoFe CAD s1.1bsystem lnepeFable.

to OPERABbE stat1;1s.

8:

,-....,e CAD s1;1bsystems 8.-1

¥eFif¥ e~ admiAistFati'tle inopeFable.

means that the t:lyeregeA eontFOI f1.1netlen is maintaiAed.

ANQ 8.2 RestoFe one CAD subsystem to OPERABLE

&tat\\:16.

C.

Re~1:1lred Aetien and G:4 Be in MODE a.

assooia:t:ed Cempletien Time not met.

JAFNPP 3.6.3.2-1 CAD System 3.8.3.2 GOMPbETION TIME ao days 1 t:101;1r

~

Onoe per 1~ t:101:1FS tllereafter 7 days 12 heuFS Amendment 284

SURVEILLANCE REQUIREMENTS SR 3.6.3.2.1 SR 3.6.3.2.2 JAFNPP SURVEILLANCE Verify~ :1:400 gal of liquid nitFogen arn contained in eaoh CAD subsystem.

Verify each GAD subsystem mamml, poweF opOFated, and automatio valve in the flo'I+' path that is not lool~ed, sealed, or otherwise seourod in position is in the ooFreot position or oan be aligned to the. eorreot position.

3.6.3.2-2 GAD System a.e.a.2 FREQUENCY In aoooFdanoe 11.1ith the Surveillanoe Frequenoy GontFOI PFogFam In aoooFdanee with the Surveillance Frequeno-y Control ProgFam Amendment 3G1-I

ATTACHMENT 3 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 Re-typed Technical Specifications Pages 3.6.3.2-1 3.6.3.2-2

JAFNPP 3.6.3.2-1 This Page is left Intentionally Blank

JAFNPP 3.6.3.2-2 This Page is left Intentionally Blank

ATTACHMENT 4 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 Mark-ups of Technical Specifications Bases Pages (For Information Only)

B 3.6.3.2-1 B 3.6.3.2-2 B 3.6.3.2-3 B 3.6.3.2-4 B 3.6.3.2-5

CAD SystelR 8 3.6.3.2 8--3-:-6 CONTAINMENT SYSTEMS 8 3.6.3.2 Containment Atmospt'lere Dilution (CAO) System

~

BiA.C~GROUND TAe CAD Systeffl functions to fflaintain combustible gas eoncentPations witAin the pri!Rary containment at OP below tAe flamfflability limits foll~,iing a postulated loss of eool ant acci <:lent ( LOCA) by <:Ii lt1ti ng Aye Pe gen ans oxygeR ~.-; tt'I nitPogen. To ensuPe tAat a combustible gas mixtupc <:lees not occuP, oxygen concentration is ~ept c 4.9 volume pePcent

(" 'o) i ;

TAc CAD Systeffl is manually i ni ti atccl ans consists of t~**o indcpenscnt. 100% capacity subsysteffls. Each subsysteffl inclucles a liquid nitrogen supply tank, afflbient vaporizer.

el cctri c Aeatcr, anEl connected piping to supply tAe clry,~cl l ancl suppression ehambeP volumes. The CAO subsyste1Rs are utilizes for normal makeup. TAe CAO subsyste1Rs also proviEle tAe pneu1Ratic supply requirements of instru1Rcnts ancl controls insiclc tt'le clr~~ell including the leng term (100 says) pneumatic supply requirements of the Automatic Dcpressurization System (ADS) valves ancl accumulators foll mJi ng a LOCA. In addition, seJ:>arate lines fro111 each liquid nitrogen storage tank with separate a111bient heat excAangers and pressure control valves provides the pneu111atic supply for the CAD subsyste111 pneumatically operated valves. The nitrogen storage tanks eacA contain

~ 1400 gal, wt'lich is aElequate for 3 days of CAD subsyste111 operation. This proviEles sufficient ti111e to replenish tt'le tanks for the long term supply requirements.

TAe CAD Syste111 operates in conjunction with e111ergeney operating proeeclures tAat are usecl to reduce pri111ary containment pPessure perioElieally Eluring CAD Syste111 operation. This eombinatian results in a feed and blcea approacA to maintaining Aysrogcn and exygen concentrations below combustible levels.

APPLICABLE Ta evaluate tAe potential for Ayclrogen aAcl OXY§Cn SAF'ETY ANALYSES aeeutRul at ion in primary contai n111ent foll e*,d ng a LOCA.

hyElrogen ana o~(ygeA geAerati aA is cal cul ates ( as a ftmeti on of time following the iAitiation of the aeeiaent). fl'te assumptions states in Reference} are usea to maximize the amouAt of hyaregeA and e*ygcn gencratccl. The ealculatioA canfirms tAat wAen the mitigatiAg systems are actuated in accorElanee with emergeAcy a~erating ~roeedures, tAe peak oxygeA coAeeAtration iA primary eontainmeAt is c 4.0 v/o ffief-: &.

(eontiAued)

JAFNPP B 3.6.3.2-1 Revision 0

BA5E5 APPLICABLE SAFETY ANALYSES (centinucEI)

APPLICABILITY JAFNPP I lyElregen anEI e:><ygcl'I may accumulate ~**ithi n primary centaiRmcl'lt fellewing a LOCA as a result of:

CAD System B 3.6.3.2 tr.

A metal water reaeti en bcb~een the zi reoni um fl::fcl reEI claddiRg aRd the reacter ceelant, er tr.

RaElielytic Elcee1111:3esitieR of ~.-ater in the Reactor CeelaRt System.

The CAD System satisfies Criterion 3 of 18 CFR 58.36(c)(2)(ii) (Ref. 3).

ttte CAD subsystems must sc OPERABLE. This ensures operation ef at least enc CAD subsystem iR the eveAt of a werst ease single active cempenent failure. Operation of at least one CAD subsystem is Elesigned ta maintain primary coRtainmcnt post LOCA o:><ygcn ceneentratien ~ 4.8 v/e fer 3 Elays.

In MODES 1 a19EI 2, the CAD Systcffl is requireEI te maiAtaiA the e:><ygc19 ce19centratiefl within primary centainmcnt below the fla111111al'>ility limit of 5.8 *do follmting a LOCA.

Tfl4s cl9surcs that the relative leak tightness of prifflary centainmcnt is aElequatc anEI prevents Elamagc to safety rclateEI equipment anEI instruments lecatcEI within primary containlfteAt.

IR MODE 3, Both the hyElrogcn anEI o:><ygen preEluction rates anEI the total amounts proEltJceEI after a LOCA wotJld Be less thaA these calctJlateEI fer the Desigl9 Basis LOCA. Thus, if the a19alysis were ta Be pcrformcEI startil9g with a LOCA in

~toDE 3, tt:1c tifflc ta reach a fl afflmaBl c ceAceAtrati en would Be e:><tel'IElcd beyo19d the time eenservati*;ely calculated for MODES 1 and 2. The e:><tenElcEI time wetJld allo~ hyElrogen rcmo*;al froffl the primary ceAtai 19meRt atmos1:3here By ether 111ca19s anEI also allo~i repair of al9 inepcraele CAD suesyste111, if CAD were 190t availaBlc. Therefore, the CAD System is Rat rcqui red to BC OPERABLE i 19 ~40DE 3.

119 MODES 4 a19EI 5, the 1:3roeaeility a19EI conscqtJel9ccs of a LOCA arc reduced due te the pressure and temperature limitations of these MODES. Therefore, the CAD System is not required ta BC OPERABLE i fl ~toDES 4 al9d S.

(cent119ued)

B 3.6.3.2-2 Re*o*i Siefl 8

BASES fooRtinued)

ACTIONS JAFNPP CAD System B a.e.a.2 If ORe GAD subsystem is inoper=able, it must be Festoroa to OPERABLE status i.*.iithin 30 days. In this Condition, the romaiRing OPERABLE CAD subsystem is adeqt:Jate to perfoFm the o~en sontFOI ft:Jnstion.

Ho*Ne'+'-OF, tl=le 0 1.ieFall roliability is Fedt:Jsed besat:Jse a single astii.*e faill:JFC in the OPERABLE subsystem GOUid rosult in rodueed o~n eontFol eapability. The 30 day Completion Time is eased on the 101.'t' pFobability of the ossuFFenee of a LOCA tl=lat would geneFate hydFOgen and o>ejgen in amounts eapable of ~seeding the flammability limit, tl=le amount of time atJSilable afteF the e*.ient foF operatoF aetion to pm*.*ent e*seeding this limit, ans the a'+'ailability of the OPERABLE GAD subsystem ans otheF hydFogen mitigating systems.

B.1and B.2

~Nith two CAD sul:>systems inopeFable, the ability to perfoFFA the hydFOgen sontFol ft:Jnetion *.iia alternate capabilities must be i.*erified by asministFati1.<<e means within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The alternate hydFOgen eontrol capabilities aro PFO¥ided by the Primary Containment lnerting System.

The 1 Rot-Jr Completion Time all01.'fs a reasonable period of time to

¥eri:fy that a loss of hydrogen oontrol fl:lnstion does not e*ist. In addition, the alternate hydFOgen control system eapability mt:Jst be verified once per 12 houFS theroafter to ensure its oontinued a1.<<ailability, Seth the initial verification and all st-.1bsequent i.*erifioations may be performed as an administratii.*e oheok by eMamining logs or other information to determine tl=le a1.iailability of the alternate hydFOgen control system. It does not mean to perform the Surveillances needed to demonstFate OPERABILITY of the alternate h:,<<drogen sontFOI system. If the ability to perform the hydFOgen eontrol fuRotion Is maintained, oontinued opeFation is permitted with t'No CAD sl:lbsystems leontinued)

B-3.6.3.2-3 Re*+'ision 12

ACTIONS SURVEILLANCE REQUIREMENTS JAFNPP 8.1 and B.2 (sontinued)

CAD System B 3.6.3.2 inoperable for up to 7 eays. Sei.1en eays is a reasonable time to allo1,., two GAD subsystems to be inoper:able besause the hydrogen control funGtion is maintained and besause of the low probability of the occurrence of a LOGA that would generate hygrogen in amounts sapable of ex:ceeding the flammability limit.

If any Required.'\\Gtion cannot be met within the associatee Completion Time, the plant must be brought to a MODE in which the LGO eoes not apply. To ashie1.ie this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable, based on operating ex:periense, to reash MODE 3 from full power conditions in an orcterly manner and without challenging plant systems.

SR 3.6.3.2.1 Verifying that there is> 1400 gal of liquid nitrogen supply in each GAD subsystem will ensure at least 3 eays of post LOG.'\\ C.t\\D oper:ation. This minimum 1.iolume of liquid nitrogen allows suffisient time after an accident to replenish the nitrogen supply for long term inerting. The Sur\\leillance Frequency is controlled uneer the Surveillance Frequency Control Program.

SR 3.6.3.2.2 Verifying the correGt alignment for manual, po'>.ier oper:atee, ane automatic 1.ial1.ies in sash of the G,t\\D subsystem flow paths pro1.iides assuranse that the proper flow paths ex:ist for system operation. This SR eoes not apply to 1.ial1Jes that are lockee, sealed, or otherwise secured in position, sinse these 1.ial1.ies were 1.ierified to be in the sorrect position prior to losking, sealing, or securing.

(continued)

B 3.6.3.2-4 Revision 30 I

SURVEILLANCE REQUIREMENTS REFERENCES J~.FNPP SR 3.6.3.2.2 (continue9)

CAD System B 3.6.3.2 A v-ali.ie is also allowe9 te l:le in the nonacci9ent position pro1.ii9e9 it can l:le aligne9 to the acci9ent position within the time assume9 in the acci9ent analysis. This is acceptal:lle l:lecause the CAD System is manually initiate9.

This SR 9oes not apply te i.1ali.1es that cannot l:le ina9vertently misaligne9, such as check *.ial1.ies. This SR 9oes not require any testing or valve manipulation; rather, it imiol1.ies 1.ierification that those 1.ial1.ies capal:lle of l:leing mispositione9 are in the correct position.

The Surveillance Frequency is controlle9 un9er the Surveillance Frequency Control Program.

Safety Gui9e 7, March 10, 1971.

2-.

UFS.'\\R, Section 5.2.3.8.3.

a..

10 CFR 50.36(cH2Hii).

B 3.6.3.2-5 Revision 30