Text

Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position
	ML21270A069
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle
Issue date:	09/27/2021
From:	David Gudger; Exelon Generation Co LLC, Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	JAFP-21-0089, NMP2L2781, RS-21-101
	Download: ML21270A069 (176)
	v • d • e

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 RS-21-101 JAFP-21-0089 NMP2L2781 September 27, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. 50-456 and 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. 50-454 and 50-455 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Application to Revise Technical Specifications to ADOPT TSTF-541 Revision 2 September 27, 2021 Page 2 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. DPR-69 NRC Docket No. 50-410 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 R.E. Ginna Nuclear Power Plant Facility Operating License No. DPR-18 NRC Docket No. 50-244

SUBJECT:

Application to Revise Technical Specifications to ADOPT TSTF-541 Revision 2, "Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position"

REFERENCES:

1. TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position. Dated August 28, 2019

2. Final Safety Evaluations of Technical Specifications Task Force Traveler TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position. using the Consolidated Line Item Improvement Process, dated December 10, 2019 (EPID L-2019-PMP-0178)

Pursuant to 10 CFR 50.90, Exelon Generation Company, LLC (EGC) is submitting a request for an amendment to the Technical Specifications (TS) for:

Renewed Facility Operating License (FOL) Nos. NPF-72 and NPF-77 For Braidwood Station (BRW), Units 1 and 2; Renewed FOL Nos. NPF-37 and NPF-66 for Byron Station (BYR), Units 1 and 2; Renewed FOL Nos. DPR-53 and DPR-69 for Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2; FOL No. NPF-62 for Clinton Power Station (CPS), Unit 1; Renewed FOL Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3; Renewed FOL No. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF),

Unit 1; Renewed FOL Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS), Units 1 and 2; Renewed FOL Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS),

Units 1 and 2; Renewed FOL No. NPF-69 for Nine Mile Point Nuclear Station (NMP), Unit 2; Renewed FOL Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3;

Application to Revise Technical Specifications to ADOPT TSTF-541 Revision 2 September 27, 2021 Page 3 Renewed FOL Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2; Renewed FOL No. DPR-18 for R.E. Ginna Nuclear Power Plant (GIN), Unit 1.

Exelon Generation Company, LLC (EGC) requests adoption of TSTF-541 Revision 2, "Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position," which is an approved change to the Standard Technical Specifications (STS), into the Technical Specifications (TS) of the stated Licenses. The proposed amendment modifies certain TS Surveillance Requirements (SRs) by adding exceptions to consider the SR met when automatic valves or dampers are locked, sealed, or otherwise secured in the actuated position, in order to consider the SR met.

Securing the automatic valve or damper in the actuated position may affect the operability of the system or any supported systems. The associated Limiting Condition for Operation (LCO) is met if the subject structure, system or component (SSC) remains operable (i.e., capable of performing its specified safety function).

provides a description and assessment of the proposed changes. provides the existing TS pages marked up to show the proposed changes. provides existing TS Bases pages marked to show the proposed changes for information only.

The proposed changes have been reviewed by each listed sites Plant Operations Review Committee, in accordance with the requirements of the Exelon Quality Assurance Program.

Exelon Generation Company, LLC (EGC) requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested by February 18, 2022. Once approved, the amendment shall be implemented within 90 days.

There are no regulatory commitments made in this submittal.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State Officials.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 27th day of September 2021.

If you should have any questions regarding this submittal, please contact Christian Williams at (610) 765-5729.

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

Application to Revise Technical Specifications to ADOPT TSTF-541 Revision 2 September 27, 2021 Page 4 Attachments:

(1)

Description and Assessment of Technical Specifications Changes (2a)

Proposed Technical Specification Changes (Mark-Up) for Braidwood Station, Units 1 and 2 (2b)

Proposed Technical Specification Changes (Mark-Up) for Byron Station, Units 1 and 2 (2c)

Proposed Technical Specification Changes (Mark-Up) for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (2d)

Proposed Technical Specification Changes (Mark-Up) for Clinton Power Station, Unit 1 (2e)

Proposed Technical Specification Changes (Mark-Up) for Dresden Nuclear Power Station, Units 2 and 3 (2f)

Proposed Technical Specification Changes (Mark-Up) for James A.

FitzPatrick Nuclear Power Plant, Unit 1 (2g)

Proposed Technical Specification Changes (Mark-Up) for LaSalle County Station, Units 1 and 2 (2h)

Proposed Technical Specification Changes (Mark-Up) for Limerick Generating Station, Units 1 and 2 (2i)

Proposed Technical Specification Changes (Mark-Up) for Nine Mile Point Nuclear Station, Unit 2 (2j)

Proposed Technical Specification Changes (Mark-Up) for Peach Bottom Atomic Power Station, Units 2 and 3 (2k)

Proposed Technical Specification Changes (Mark-Up) for Quad Cities Nuclear Power Station, Units 1 and 2 (2l)

Proposed Technical Specification Changes (Mark-Up) for R.E. Ginna Nuclear Power Plant (3a)

Revised Technical Specification Bases Changes (Information Only) for Braidwood Station, Units 1 and 2 (3b) Revised Technical Specification Bases Changes (Information Only) for Byron Station, Units 1 and 2 (3c) Revised Technical Specification Bases Changes (Information Only) for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (3d) Revised Technical Specification Bases Changes (Information Only) for Clinton Power Station, Unit 1 (3e) Revised Technical Specification Bases Changes (Information Only) for Dresden Nuclear Power Station, Units 2 and 3 (3f)

Revised Technical Specification Bases Changes (Information Only) for James A. FitzPatrick Nuclear Power Plant, Unit 1 (3g) Revised Technical Specification Bases Changes (Information Only) for LaSalle County Station, Units 1 and 2 (3h) Revised Technical Specification Bases Changes (Information Only) for Limerick Generating Station, Units 1 and 2 (3i)

Revised Technical Specification Bases Changes (Information Only) for Nine Mile Point Nuclear Station, Unit 2 (3j)

Revised Technical Specification Bases Changes (Information Only) for Peach Bottom Atomic Power Station, Units 2 and 3 (3k) Revised Technical Specification Bases Changes (Information Only) for Quad Cities Nuclear Power Station, Units 1 and 2 (3l)

Revised Technical Specification Bases Changes (Information Only) for R.E.

Ginna Nuclear Power Plant

Application to Revise Technical Specifications to ADOPT TSTF-541 Revision 2 September 27, 2021 Page 5 cc:

NRC Regional Administrator - Region I NRC Regional Administrator - Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - R.E. Ginna Nuclear Power Plant Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection A. L. Peterson, NYSERDA Bridget Frymire, NYSPSC S. Seaman, MD-DNR

Page 1 of 6 ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

Exelon Generation Company, LLC (EGC) requests adoption of TSTF-541 Revision 2, "Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position", which is an approved change to the Standard Technical Specifications (STS), into the Technical Specifications (TS) of the listed Licenses. The proposed amendment modifies the TS Surveillance Requirements (SRs) by adding exceptions to consider the SR met when automatic valves or dampers are locked, sealed, or otherwise secured in the actuated position, in order to consider the SR met. Securing the automatic valve or damper in the actuated position may affect the operability of the system or of any supported systems. The associated Limiting Condition for Operation (LCO) is met if the subject structure, system or component (SSC) remains operable (i.e., capable of performing its specified safety function).

The following TSs are affected by the proposed change.

For Braidwood and Byron Stations (NUREG 1431):

TS 3.7.10: "Control Room Ventilation (VC) Filtration System" TS 3.7.12: "Nonaccessible Area Exhaust Filter Plenum Ventilation System" TS 3.7.13: "Fuel Handling Building Exhaust Filter Plenum (FHB) Ventilation System" For Ginna Station (NUREG 1431)

TS 3.7.9: Control Room Emergency Air Treatment System (CREATS)

For Calvert Cliffs Station (NUREG 1432):

TS 3.6.8: "Iodine Removal System (IRS)"

TS 3.7.8: "Control Room Emergency Ventilation System (CREVS)"

TS 3.7.12: "Penetration Room Exhaust Ventilation System (PREVS)

For Dresden, LaSalle, Quad Cities, FitzPatrick, Limerick, Nine Mile Point Unit 2 and Peach Bottom (NUREG-1433)

TS 3.5.1: "ECCS - Operating" TS 3.5.2 (3.5.4 for PBAPS): RPV Water Inventory Control TS 3.5.3: "RCIC System (Isolation Condensers (IC) for DNPS)

TS 3.6.4.3: "Standby Gas Treatment (SGT) System" TS 3.7.2 (3.7.1 for NMP2): Emergency Service Water and Normal Heat Sink (or similar) (Except DNPS, LSCS, QCNPS)

TS 3.7.4 (3.7.2 for NMP2) Main Control Room Emergency Ventilation (MCREV)

System (or similar) (Except LGS)

For Clinton Station (NUREG 1434)

TS 3.5.1: ECCS - Operating" TS 3.5.2: RPV Water Inventory Control TS 3.5.3: "RCIC System" TS 3.6.1.7: "Residual Heat Removal (RHR) Containment Spray System" TS 3.6.4.3: "Standby Gas Treatment (SGT) System" TS 3.7.1: "Division 1 and 2 Shutdown Service Water (SX) Subsystems and Ultimate Heat Sink (UHS)"

TS 3.7.2: "Division 3 Shutdown Service Water (SX) Subsystem" TS 3.7.3: "Control Room Ventilation System" While the proposed exceptions permit automatic valves and dampers that are locked, sealed, or otherwise secured in the actuated position to be excluded from the SR in order to consider

Page 2 of 6 the SR met, the proposed changes will not permit a system that is made inoperable by locking, sealing, or otherwise securing an automatic valve or damper in the actuated position to be considered operable. As stated in the SR 3.0.1 Bases, "Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the SRs."

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation EGC has reviewed the safety evaluation for TSTF-541 Revision 2 provided to the Technical Specifications Task Force in a letter dated December 10, 2019. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-541 Revision 2. As described herein, EGC has concluded that the justifications presented in TSTF-541 and the safety evaluation prepared by the NRC staff are applicable to Braidwood Station (BRW), Units 1 and 2; Byron Station (BYR), Units 1 and 2; Calvert Cliffs Nuclear Power Plant (CCNPS),

Units 1 and 2; Clinton Power Station (CPS), Unit 1; Dresden Nuclear Power Station (DNPS),

Units 2 and 3; James A. FitzPatrick Nuclear Power Plant (JAF), Unit 1; LaSalle County Station (LSCS), Units 1 and 2; Limerick Generating Station (LGS), Units 1 and 2; Nine Mile Point Nuclear Station (NMP), Unit 2; Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3; Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2; and R.E. Ginna Nuclear Power Plant (GIN), Unit 1, and justify this amendment for the incorporation of the changes to the BRW, BYR, CCNPP, CPS, DNPS, JAF, LSCS, LGS, NMP2, PBAPS, QCNPS, and GIN TS.

EGC acknowledges that under the proposed change, the affected valves and dampers may be excluded from the SR when locked, sealed or otherwise secured in the actuated position.

However, if the safety analysis assumes movement from the actuated position following an event, or the system is rendered inoperable by locking, sealing, or otherwise securing the valve or damper in the actuated position, then the system cannot perform its specified safety function and is inoperable regardless of whether the SR is met.

EGC acknowledges for components for which the SR allowance can be utilized, the SR must be verified to have been met within its required Frequency after removing the valve or damper from the locked, sealed or otherwise secured status. If the SR exception is utilized to not test the actuation of a valve or damper and the specified Frequency of the SR is exceeded without testing the component, the SR must be performed on the component when it is returned to service in order to meet the SR.

2.2 Variations EGC is proposing the following variations from the TS changes described in TSTF-541 Revision 2 or the applicable parts of the NRC staffs safety evaluation:

2.2.1 Some EGC Plant TSs utilize different numbering and / or titles than the STSs on which TSTF-541 Revision 2 was based. Table 1 is provided to illustrate the specific differences between affected plants and the applicable STSs for that plant. These differences are administrative and do not affect the applicability of TSTF-541 Revision 2 to the applicable EGC Plant TS.

Page 3 of 6 Table 1: TS Number and Title Variance Plant Name Applicable NUREG STS TS Number STS System Name Plant Specific TS Number Plant Specific System Name Braidwood /

Byron 1431 3.7.12 ECCS PREACS 3.7.12 Nonaccessible Area Exhaust Filter Plenum Ventilation Ginna 1431 3.7.10 CREFS 3.7.9 CREATS Calvert Cliffs 1432 3.6.10 ICS 3.6.8 IRS 3.7.11 CREACS 3.7.8 CREVS 3.7.15 PREACS 3.7.12 PREVS Clinton 1434 3.7.1 SW and UHS 3.7.1 Div 1 and 2 SX 3.7.2 HPCS SW 3.7.2 Div 3 SX Limerick (Custom TS) 1433 3.5.1 ECCS Op 3/4 5.1 ECCS Op 3.5.3 RCIC 3/4 7.3 RCIC 3.6.4.3 SGT 3/4 6.5.3 SGT 3.7.2 PSW/UHS 3/4 7.1.2 ESW Nine Mile Point Unit 2 1433 3.7.2 PSW/UHS 3.7.1 SW/UHS 3.7.4 MCREC 3.7.2 CREF Peach Bottom 1433 3.5.2 RPV WIC 3.5.4 RPV WIC 2.2.2: The traveler and Safety Evaluation discuss the applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A, General Design Criteria (GDC). Calvert Cliffs, Dresden, FitzPatrick, Peach Bottom, Ginna and Quad Cities were not licensed to the 10 CFR 50, Appendix A GDC.

2.2.2.1: Calvert Cliffs CCNPP's Updated Final Safety Analysis (UFSAR), Section 1C.0, "AEC Proposed General Design Criteria for Nuclear Power Plant", provides an assessment against the draft GDC published in 1967. This difference does not alter the conclusion that the proposed change is applicable to CCNPP.

2.2.2.2: Dresden DNPS was not licensed to the 10 CFR 50, Appendix A, General Design Criteria. Dresden UFSAR, Section 3.1.1 contains an evaluation of the design basis of DNPS with respect to the first draft of the 70 proposed "General Design Criteria for Nuclear Power Plant Construction Permits" issued by the Atomic Energy Commission in July 1967. The design basis of Unit 2, was later evaluated against the final "General Design Criteria for Nuclear Power Plants,"

published as 10 CFR 50, Appendix A in July 1971. This evaluation is presented in Section 3.1.2 of the Dresden UFSAR. This difference does not alter the conclusion that the proposed change is applicable to DNPS.

2.2.2.3: FitzPatrick The JAF equivalents of the referenced GDC are located in section 1.5 of the JAF UFSAR.

This difference does not alter the conclusion that the proposed change is applicable to JAF.

2.2.2.4: Peach Bottom The PBAPS UFSAR, Appendix H, "Conformance to AEC (NRC) Criteria," contains an evaluation of the design bases of PBAPS with respect to the GDC to be proposed to be added to 10 CFR 50 as Appendix A in July 1967. This difference does not alter the conclusion that

Page 4 of 6 the proposed change is applicable to PBAPS.

2.2.2.5: Quad Cities The QCNPS equivalents of the referenced GDC are located in section 3.1 of the QCNPS UFSAR. This difference does not alter the conclusion that the proposed change is applicable to QCNPS.

2.2.2.6: Ginna The GIN equivalents of the referenced GDC are located in section 3.1 of the GIN UFSAR.

This difference does not alter the conclusion that the proposed change is applicable to GIN 2.2.3: Plant Specific Technical Variations:

2.2.3.1: Dresden The DNPS Unit 2 and Unit 3 plant designs include the Isolation Condenser (IC) system as opposed to Reactor Containment Isolation Cooling (RCIC). The justification for this TSTF is also applicable to the DNPS IC system. The applicable SR is included in the proposed markup pages for DNPS.

2.2.3.2: FitzPatrick JAF added a one-time-use note to SR 3.7.2.4 as a result of an emergency Tech Spec amendment. That note is no longer applicable and as this note is listed on one of the pages affected by this change, the note is being removed from that page only. This is an administrative change that does not affect the conclusions in this submittal.

2.2.3.3: Limerick LGS maintains Custom Technical Specifications however TSTF-541 Revision 2 is applicable to the LGS Plant design and as such the variations in naming, numbering and formatting are administrative in nature and do not alter the conclusion that the proposed change is applicable to LGS. The specific differences are listed in Table 1 above. Additionally, LGS has identified that the justification for this TSTF also applies to the Reactor Enclosure Recirculation System (RERS) and the associated SR 4.6.5.4.d.2. This SR is included in the proposed markup pages for LGS.

2.2.4: TSTF-542, RPV WIC All EGC BWR Plants listed have incorporated TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," which had not been incorporated into the standard TS on which TSTF-541 Revision 2 was based. The changes in TSTF-541 Revision 2 are equally applicable to two (2) new ECCS SRs added by TSTF-542, 3.5.2.7 and 3.5.2.8 of the STS.

Therefore, the TSTF-541 Revision 2 allowance is added to those SRs. Specific SR numbers vary from site to site as shown in the TS Markup pages in attachments 2a through 2k.

2.2.5: All EGC Plant TSs contain a Surveillance Frequency Control Program. Therefore, the Frequency for the affected SRs is "In accordance with the Surveillance Frequency Control Program." This has no effect on the applicability of the proposed change.

2.3 Licensee Verifications EGC confirms that existing administrative processes, such as the Corrective Action Program, Operability Determination process, the maintenance, design control, configuration control, and operating procedures, etc., will be used to assess the operability of the system or of any supported systems when utilizing the SR allowances, which includes consideration of whether movement of the affected valves or dampers following an event is assumed in the safety analysis.

Page 5 of 6

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination EGC requests adoption of TSTF-541 Revision 2, "Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position," which is an approved change to the Standard Technical Specifications (STS), into the listed EGC Plants Technical Specifications (TS). The proposed amendment modifies the TS Surveillance Requirements (SRs) by adding exceptions to consider the SR met when automatic valves or dampers are locked, sealed, or otherwise secured in the actuated position, in order to consider the SR met. Securing the automatic valve or damper in the actuated position may affect the operability of the system or of any supported systems. The associated Limiting Condition for Operation (LCO) is met if the subject structure, system or component (SSC) remains operable (i.e., capable of performing its specified safety function).

EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment" as discussed below:

1.

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change revises SRs by adding exceptions excluding from actuation and isolation time testing those valves and dampers that are locked, sealed or otherwise secured in the actuated position. The performance or lack of performance of SRs is not an initiator of any accident previously evaluated. As a result, the proposed change has no effect on the probability of any accident previously evaluated. The proposed change excludes performance of portions of certain SRs, but the SSC must still be capable of performing the safety functions assumed in the accident analysis. Otherwise, the SSC is inoperable, and the associated TS Actions are followed. As a result, the SSCs continue to perform their mitigating functions and the consequences of any accident previously evaluated are not affected.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change revises SRs by adding exceptions excluding from actuation and isolation time testing those valves and dampers that are locked, sealed or otherwise secured in the actuated position. The proposed change will not change the design function or operability requirements of the affected SSCs. The SSC must still be capable of performing the safety functions assumed in the accident analysis or the SSC is inoperable, and the associated TS Actions are followed. The proposed change does not create any credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.

Page 6 of 6 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change revises SRs by adding exceptions excluding from actuation and isolation time testing those valves and dampers that are locked, sealed or otherwise secured in the actuated position. The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis assumptions and acceptance criteria are not affected by this change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed change presents no 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.

3.2 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 Commissions 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.

ENVIRONMENTAL CONSIDERATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

a Proposed Technical Specification Changes (Mark-Up)

Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 REVISED TECHNICAL SPECIFICATION PAGES 3.7.10-4 3.7.12-2 3.7.13-4

VC Filtration System 3.7.10 SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.10.2 SR 3.7.10.3 SR 3. 7.10.4 SURVEILLANCE Perform required VC Filtration System filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

Verify each VC Filtration System train actuates on an actual or simulated actuation signal.

Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

BRAIDWOOD - UNITS 1 & 2 3.7.10 - 4 FREQUENCY In accordance with the V FTP In accordance with the Surveillance Frequency Control Program In accordance with the Control Room Envelope Habitability Program Amendment 165 INSERT: ", except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position."

Nonaccessible Area Exhaust Filter Plenum Ventilation System 3.7.12 SURVEILLANCE REQUIREMENTS SR 3.7.12.1 SR 3.7.12.2 SR 3.7.12.3 SR 3. 7.12.4 SURV LLANCE Operate each Nonaccessible Area Exhaust Filter Plenum Ventilation System train for z 15 minutes.

Perform required Nonaccessible Area Exhaust Filter Plenum Ventilation System filter testing in accordance with the Ventilation Filter Testing Program CVFTP).

Verify each Nonaccessible Area Exhaust Filter Plenum Ventilation System train actuates on a manual, an actual, or a simulated actuation signal.

Verify two Nonaccessible Area Exhaust Filter Plenum Ventilation System trains can maintain a pressure ~ -0.25 inches water gauge relative to atmospheric pressure during the emergency mode of operation at a flow rate of ~ 73,590 cfm per train.

BRAIDWOOD - UNITS 1 & 2 3.7.12 - 2 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment 165 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

FHB Ventilation System 3.7.13 SURVEILLANCE REQUIREMENTS (continued)

SURV LLANCE SR 3.7.13.2 Perform required FHB Ventilation System filter testing in accordance with the Ventilation Filter Testing Program CVFTP).

SR 3.7.13.3

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

Only required during movement of RECENTLY IRRADIATED FUEL assemblies with the equipment hatch not intact.

Verify one FHB Ventilation System train can maintain a pressure ~ -0.25 inches water gauge relative to atmospheric pressure during the emergency mode of operation.

SR 3.7.13.4 Verify each FHB Ventilation System train actuates on an actual or simulated actuation signal.

SR 3.7.13.5

NOTE----------

Only required during movement of RECENTLY IRRADIATED FUEL assemblies in the fuel handling building with the equipment hatch intact.

Verify one FHB Ventilation System train can maintain a pressure ~ -0.25 inches water gauge relative to atmospheric pressure during the emergency mode of operation at a flow rate ~ 23,100 cfm.

BRAIDWOOD - UNITS 1 & 2 3.7.13 - 4 FREQUENCY In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment 165 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

b Proposed Technical Specification Changes (Mark-Up)

Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 REVISED TECHNICAL SPECIFICATION PAGES 3.7.10-4 3.7.12-2 3.7.13-4

VC Filtration System

3. 7.10 SURVEILLANCE REQUIREMENTS (continued)

SR 3. 7.10.2 SR 3.7.10.3 SR 3.7.10.4 SURVEILLANCE Perform required VC Filtration System filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

Verify each VC Filtration System train actuates on an actual or simulated actuation signal.

Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

BYRON - UNITS 1 & 2 3.7.10 - 4 FREQUENCY In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Control Room Envelope Habitability Program Amendment 198 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

Nonaccessible Area Exhaust Filter Plenum Ventilation System 3.7.12 SURVEILLANCE REQUIREMENTS SR 3.7.12.l SR 3.7.12.2 SR 3.7.12.3 SR 3.7.12.4 SU RV EI LLANCE Operate each Nonaccessible Area Exhaust Filter Plenum Ventilation System train for

~ 15 minutes.

Perform required Nonaccessible Area Exhaust Filter Plenum Ventilation System filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

Verify each Nonaccessible Area Exhaust Filter Plenum Ventilation System train actuates on a manual, an actual, or a simulated actuation signal.

Verify two Nonaccessible Area Exhaust Filter Plenum Ventilation System trains can maintain a pressure ~ -0.25 inches water gauge relative to atmospheric pressure during the emergency mode of operation at a flow rate of~ 68,200 cfm per train.

BYRON - UNITS 1 & 2 3.7.12 - 2 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the V FTP In accordance with the Surveillance Frequency Contra l Program In accordance with the Surveillance Frequency Control Program Amendment 171 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

FHB Ventilation System 3.7.13 SURVEILLANCE REQUIREMENTS (continued)

SU RV EI LLANCE SR 3.7.13.2 Perform required FHB Ventilation System filter testing in accordance with the Ventilation Filter Testing Program CVFTP).

SR 3.7.13.3

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

Only required during movement of RECENTLY IRRADIATED FUEL assemblies with the equipment hatch not intact.

Verify one FHB Ventilation System train can maintain a pressure ~ -0.25 inches water gauge relative to atmospheric pressure during the emergency mode of operation.

SR 3.7.13.4 Verify each FHB Ventilation System train actuates on an actual or simulated actuation signal.

SR 3.7.13.5

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

Only required during movement of RECENTLY IRRADIATED FUEL assemblies in the fuel handling building with the equipment hatch intact.

Verify one FHB Ventilation System train can maintain a pressure ~ -0.25 inches water gauge relative to atmospheric pressure during the emergency mode of operation at a flow rate ~ 23,100 cfm.

BYRON - UNITS 1 & 2 3.7.13 - 4 FREQUENCY In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment 171 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

c Proposed Technical Specification Changes (Mark-Up)

Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 REVISED TECHNICAL SPECIFICATION PAGES 3.6.8-2 3.7.8-5 3.7.12-2

SURVEILLANCE REQUIREMENTS SR 3.6.8.1 SR 3.6.8.2 SR 3.6.8.3 SURVEILLANCE Operate each IRS train for ~ 15 minutes.

Perform required IRS filter testing in accordance with the Ventilation Filter Testing Program.

Verify each IRS train actuates on an actual or simulated actuation signal.

CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 3.6.8-2 IRS 3.6.8 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Ventilation Filter Testing Program In accordance with the Surveillance Frequency Control Program Amendment No. 314 Amendment No. 292 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

SURVEILLANCE REQUIREMENTS SURVEILLANCE CREVS 3.7.8 FREQUENCY SR 3.7.8.1 Operate each required CREVS filter train for In accordance

~ 15 minutes.

with the Surveillance Frequency Control Program SR 3.7.8.2 SR 3.7.8.3 SR 3.7.8.4 Perform required CREVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

Verify each CREVS train actuates on an actual or simulated actuation signal ~

Perform required CRE unfilte ed air inleakage testing in accor nee with the Control Room Envelope Hab* ability Program.

INSERT ", except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position."

CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 3.7.8-5 In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Control Room Envelope Habitabi 1 ity Program Amendment No. 3+/-4 Amendment No. ~

SURVEILLANCE REQUIREMENTS SR 3.7.12.1 SR 3.7.12.2 SR 3.7.12.3 SURVEILLANCE Operate each PREVS train for~ 15 minutes.

Verify required PREVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

Verify each PREVS train actuates on an actual or simulated actuation signal.

CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 3.7.12-2 PRE VS 3.7.12 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program Amendment No. 314 Amendment No. 292 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

d Proposed Technical Specification Changes (Mark-Up)

Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 REVISED TECHNICAL SPECIFICATION PAGES 3.5-6 3.5-11 3.5-14 3.6-25 3.6-53 3.7-2a 3.7-3 3.7-7

ECCS Operating 3.5.1 CLINTON 3.5-6 Amendment No. 238 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.5

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

Vessel injection/spray may be excluded.

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

In accordance with the Surveillance Frequency Control Program SR 3.5.1.6

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

Valve actuation may be excluded.

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

In accordance with the Surveillance Frequency Control Program SR 3.5.1.7

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

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

Verify each ADS valve actuator strokes when manually actuated.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.8

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

ECCS actuation instrumentation is excluded.

Verify the ECCS RESPONSE TIME for each ECCS injection/spray subsystem is within limits.

In accordance with the Surveillance Frequency Control Program INSERT ", except for valves that are locked, sealed, or otherwise secured in the actuated position."

RPV Water Inventory Control 3.5.2 CLINTON 3.5-11 Amendment No. 238 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5

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

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray subsystem for 10 minutes.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.6 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.7

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

In accordance with the Surveillance Frequency Control Program INSERT ", except for valves that are locked, sealed, or otherwise secured in the actuated position."

INSERT ", except for valves that are locked, sealed, or otherwise secured in the actuated position."

RCIC System 3.5.3 CLINTON 3.5-14 Amendment No. 238 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.3.5

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

Vessel injection may be excluded.

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

In accordance with the Surveillance Frequency Control Program INSERT ", except for valves that are locked, sealed, or otherwise secured in the actuated position."

RHR Containment Spray Sys~em 3.6.1.7 SURVEILLANCE REQUIREMENTS SR 3.6.1.7.l SR 3.6.1.7.2 SR 3.6.1.7.3 SR 3.6.1.7.4 SR 3.6.1.7.5 CLINTON SURVEILLANCE

-NOTE- - -

Not required to be met for system vent flow paths opened under administrative control.

Verify each RHR containment spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

Verify each RHR pump develops a flow rate of ~ 3800 gpm on recirculation flow through the associated heat exchanger to the suppression Verify each RHR containment spray subsystem automatic valve in the flow path actuates to its correct position on an actual or simulated automatic initiation signal.

Verify each spray nozzle is unobstructed.

Verify RHR containment spray subsystem locations susceptible to gas accumulation are sufficiently filled with water.

3.6 25 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the IN SERVICE TESTING PROGRA.lll!

In accordance with the Surveillance Frequency Control Program Following activities that could result in nozzle blockage In accordance with the Surveillance Frequency Control Program Amendment No. 215 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

ACTIONS (continued)

CONDITION REQUIRED ACTION SGT System 3.6.4.3 COMPLETION TIME E.

Two SGT subsystems inoperable during movement of recently irradiated fuel assemblies in the primary or secondary containment.

E. l Suspend movement of Immediately recently irradiated fuel assemblies in the primary and secondary containment.

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 SR 3.6.4.3.2 SR 3.6.4.3.3 SR 3.6.4.3.4 CLINTON SURVEILLANCE Operate each SGT subsystem for 2 15 continuous minutes with heaters operating.

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

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

Verify each SGT filter cool bypass damper can be opened and the fan started.

3.6 53 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 216 INSERT, except for dampers that are locked, sealed, or otherwise secured in the actuated position.

INSERT, except for dampers that are locked, sealed, or otherwise secured in the actuated position.

Division 1 and 2 SX Subsystems and UHS 3.7.1 SURVEILLANCE REQUIREMENTS SR 3.7.1.1 SR 3.7.1.2 SR 3.7.1.3 CLINTON SURVi<;ILLANCE Verify UHS water volume is c 593 acre ft.

each required SX subsystem manual, power operated, and automatic valve in the flow path safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Veri each SX subsystem actuates on an actual or simulated initiation 3.7 2a FREQUENCY In accordance with UHS

Erosion, Sediment Monitoring, and Dredging Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 207 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

Division 3 SX Subsystem 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Division 3 Shutdown Service Water (SX) Subsystem LCO 3.7.2 The Division 3 SX subsystem shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION A.

Division 3 SX subsystem inoperable.

A. l Declare High Pressure Core Spray System inoperable.

SURVEILLANCE REQUIREMENTS SR 3.7.2.l SR 3.7.2.2 CLINTON SURVEILLANCE Veri each required Division 3 SX subsystem manual, power operated, and automatic valve in the flow path servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct ion.

Verify the Division 3 SX subsystem actuates on an actual or simulated initiation signal.

3.7-3 COMPLETION TIME Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 192 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

Control Room Ventilation System 3.7.3 SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.3.3 SR 3.7.3.4 SR 3.7.3.5 CLINTON SURVEILLANCE Perform required Control Room Ventilation filter testing in accordance with the Ventilation Filter Program (VFTP).

Veri each Control Room Ventilation subsystem actuates on an actual or simulated initiation signal.

Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

3.7-7 FREQUENCY In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Control Room Envelope Habitability Program Amendment No. 192 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

e Proposed Technical Specification Changes (Mark-Up)

Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 REVISED TECHNICAL SPECIFICATION PAGES 3.5.1-5 3.5.2-5 3.5.3-2 3.6.4.3-3 3.7.4-3

SURVEILLANCE REQUIREMENTS SR

3. 5.1. 6 SR 3.5.1.7 SR 3.5.1.8 SURVEILLANCE

- - ---* --- - -NOTE - - ---- - -- -- - --- - -- - -

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

Verify, with reactor pressure s 1005 and

~ 920 psig, the HPCI pump can develop a flow rate~ 5000 gpm against a system head corresponding to reactor pressure.

***----NOTE---------------- ---

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

Verify, with reactor pressures 180 psig, the HPCI pump can develop a flow rate

~ 5000 gpm against a system head corresponding to reactor pressure.

- - - - - - - - - NOTE - - - - - - - - * * * - - - - - - - - -

Vessel injection/spray may be excluded.

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

ECCS-Operating 3.5.1 FREQUENCY In accordance with the INSERVICE TESTING PROGRAM In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Dresden 2 and 3 3.5.1-5 Amendment No.254/247 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

RPV Water Inventory Control 3.5.2 Dresden 2 and 3 3.5.2-5 Amendment No. 268 / 261 256/249 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.4

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

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray subsystem IRU 10 minutes.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.5 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.6

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

In accordance with the Surveillance Frequency Control Program INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

SURVEILLANCE REQUIREMENTS SR 3.5.3.1 SR 3.5.3.2 SR 3.5.3.3 SR 3.5.3.4 SU RV EI LLANCE Verify the IC System:

a.

Shellside water level;::: 6 feet; and

b.

Shellside water temperature~ 210°F.

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

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

NOTE ----

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after adequate reactor power is achieved to perform the test.

Verify IC System heat removal capability to remove design heat load.

IC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Dresden 2 and 3 3.5.3-2 Amendment No. 237 I 230 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 SR 3.6.4.3.2 SR 3.6.4.3.3 SURVEILLANCE Operate each SGT subsystem for

~ 15 continuous minutes with heaters operating.

Perform required SGT filter testing in accordance with the Ventilation Filter Testing Program CVFTP).

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

SGT System 3.6.4.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program Dresden 2 and 3 3.6.4.3-3 Amendment t~o. 241/234 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

SURVEILLANCE REQUIREMENTS SR 3.7.4.1 SR 3.7.4.2 SR 3.7.4.3 SR 3.7.4.4 SURVEILLANCE Operate the CREV System for ~ 15 continuous minutes with the heaters operating.

Perform required CREV filter testing in accordance with the Ventilation Filter Testing Program CVFTP).

Verify the CREV System actuates on a manual initiation signal.

Perform requ1red CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

CREV System 3.7.4 FREQUENCY Jn accordance with the Surveillance Frequency Control Program In accordance with the VFTP Jn accordance with the Surveillance Frequency Control Program In accordance with the Control Room Envelope Habitability Program Dresden 2 and 3 3.7.4-3 Amendment No. 241/234 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

f Proposed Technical Specification Changes (Mark-Up)

James A. FitzPatrick Nuclear Power Plant, Unit 1 Renewed Facility Operating License No. DPR-59 REVISED TECHNICAL SPECIFICATION PAGES 3.5.1-6 3.5.2-6 3.5.3-3 3.6.4.3-3 3.7.2-4

SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.1.9 SR 3.5.1.10 SR 3.5.1.11 SR 3.5.1.12 JAFNPP SURVEILLANCE

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

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

Verify, with reactor pressure~ 165 psig, the HPCI pump can develop a flow rate 2: 3400 gpm against a system head corresponding to reactor pressure.

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

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

2. Vessel injection/spray may be excluded.

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

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

Valve actuation may be excluded.

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

Verify each LPCI motor operated valve independent power supply inverter capacity is adequate to supply and maintain in OPERABLE status the required emergency loads for the design duty cycle.

3.5.1-6 ECCS - Operating 3.5.1 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment 301 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.6 SR 3.5.2.7 SR 3.5.2.8 JAFNPP SURVELLANCE Operate the required ECCS injection/spray subsystem through the recirculation line for.a 10 minutes Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

3.5.2-6 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment 321 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.5.3.5

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

1.

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

2.

Vessel injection may be excluded.

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

JAFNPP 3.5.3-3 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment 301 I INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 SR 3.6.4.3.2 SR 3.6.4.3.3 SR 3.6.4.3.4 JAFNPP SURVEILLANCE Operate each SGT subsystem for ~ 15 continuous minutes with heaters operating.

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

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

Manually cycle each SGT subsystem filter cooling cross~tie valve.

3.6.4.~3 SGT System 3.6.4.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment 326 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

ESW System and UHS 3.7.2 JAFNPP 3.7.2-4 Amendment 342 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.2.4 Verify each ESW subsystem actuates on an actual or simulated initiation signal.

In accordance with the Surveillance Frequency Control Program*

This Surveillance for ST-9BA and ST-9BB is not required to be performed until following the return of the A RHR pump to OPRABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

g Proposed Technical Specification Changes (Mark-Up)

LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 REVISED TECHNICAL SPECIFICATION PAGES 3.5.1-5 3.5.2-5 3.5.3-3 3.6.4.3-3 3.7.4-4

SURVEILLANCE REQUIREMENTS (continued)

SR

3. 5. 1. 5 SR

3. 5.1. 6 SR 3.5.1.7 SR 3.5.1.8 SURVEILLANCE Verify each ECCS pump develops the specified flow rate against the specified test line pressure.

SYSTEM LPCS LPCI HPCS (Un it 1)

HPCS (Unit 2l FLOW RATE 2 6350 gpm 2 7200 gpm

6250 gpm 2 6200 gpm TEST LINE PRESSURE 2 290 psig 2 130 psig 2 370 psig 2 330 psig

- - - - - - - - - - - - - - - - - -NOTE-*** - - - * - - - * - * - - - * -

Vessel injection/spray may be excluded.

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

--* - --* -- -* * * -* - --NOTE ---------

Valve actuation may be excluded.

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

- - - - - - - - - - - - - - - - * * -N DTE - - * - - - - - - - - - -

Valve actuation may be excluded.

Verify each required ADS valve actuator strokes when manually actuated.

ECCS-Operating

3. 5.1 FREQUENCY In accordance with the INSERVICE TESTING PROGRAM In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program LaSalle 1 and 2 3.5.1-5 Amendment No. 223/209 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.5 SR 3.5.2.6 SR 3.5.2.7 SR 3.5.2.8 LaSalle 1 and 2 SURVEILLANCE

NOTE-Not required to be met for system vent flow paths opened under administrative control.

Verify, for the required ECCS injection/spray subsystem, each 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.

Operate the required ECCS injection/spray subsystem through the recirculation line for

~ 10 minutes.

Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program 3.5.2 5 Amendment No. 230/216 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

SURVEILLANCE REQUIREMENTS SR 3.5.3.5 LaSalle 1 and 2 SURVEILLANCE NOTE - - -

Vessel injection may be excluded.

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

3.5.3-3 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 200 I 187 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 SR 3.6.4.3.2 SR 3.6.4.3.3 SURVEILLANCE Operate each SGT subsystem for

~ 15 continuous minutes with heaters operating.

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

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

SGT System 3.6.4.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program LaSalle 1 and 2 3.6.4.3 3 Amendment No. 230/216 INSERT, except for dampers that are locked, sealed, or otherwise secured in the actuated position.

SURVEILLANCE REQUIREMENTS SR 3.7.4.2 SR 3.7.4.3 SR 3.7.4.4 SR

3. 7. 4. 5 SURVEILLANCE Manually initiate flow through the CRAF recirculation filters for ~ 15 minutes.

Perform required CRAF filter testing in accordance with the Ventilation Filter Testing Program CVFTP).

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

Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

CRAF System 3.7.4 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Control Room Envelope Habitability Program LaSalle 1 and 2 3.7.4*4 Amendment No. 208/195 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

h Proposed Technical Specification Changes (Mark-Up)

Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 REVISED TECHNICAL SPECIFICATION PAGES 3/4 5-4 3/4 5-7 3/4 6-54 3/4 6-56 3/4 7-4 3/4 7-10

EMERGENCY CORE COOLING SYSTEMS 4.5.1 The emergency core cooling systems shall be demonstrated OPERABLE by:

a.

In accordance with the Surveillance Frequency Control Program:

1.

For the CSS, the LPCI system, and the HPCI system:

a) b)

Verifying locations susceptible to gas accumulation are I sufficiently filled with water.

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct*

position.***

2.

For the LPCI system, verifying that both LPCI system subsystem cross tie valves (HV-51-182 A, B) are closed with power removed from the valve operators.

3.

For the HPCI system, verifying that the HPCI pump flow controller is in the correct position.

4.

For the CSS and LPCI system, performance of a CHANNEL FUNCTIONAL TEST of the injection header ~P instrumentation.

b.

Verifying that, when tested pursuant to Specification 4.0.5:

1.

Each CSS pump in each subsystem develops a flow of at least 3175 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of ~ 105 psid plus head and line losses.

2.

Each LPCI pump in each subsystem develops a flow of at least 10,000 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of

~ 20 psid plus head and line losses.

3.

The HPCI pump develops a flow of at least 5600 gpm against a test line pressure which corresponds to a reactor vessel pressure of 1040 psig plus head and line losses when steam is being supplied to the turbine at 1040, +13, -120 psig.**

c.

In accordance with the Surveillance Frequency Control Program:

1.

For the CSS, the LPCI system, and the HPCI system, performing a system functional test which includes simulated automatic actuation of the system throughout its emergency operating sequence and verifying that each automatic valve in the flow path actuates to its correct position. Actual injection of coolant into the reactor vessel may be excluded from this test.

an c valve capable of automatic return to its ECCS posi on when an ECCS signal is present may be in position for another mode of operation.

The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test.

If OPERABILITY is not successfully demonstrated within the 12-hour period, reduce reactor steam dome pressure to less than 200 psig within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Not required to be met for system vent flow paths opened under administrative control.

LIMERICK - UNIT 1 3/4 5-4 Amendment No. ~.++/-.~

216

- - - Except for valves that are locked, sealed, or otherwise secured in the actuated position.

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2.1 Verify DRAIN TIME is greater than or equal to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months in accordance with the Surveillance Frequency Control Program.*

4.5.2.2 Verify, for a required LPCI subsystem, the suppression chamber water level is greater than or equal to 16 feet 0 inches in accordance with the Surveillance Frequency Control Program.

4.5.2.3 Verify, for a required CSS subsystem, that the suppression chamber water level is greater than or equal to 16 feet 0 inches or the condensate storage tank water level is greater than or equal to 29 feet 0 inches in accordance with the Surveillance Frequency Control Program.

4.5.2.4 Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

4.5.2.5 DELETED 4.5.2.6 Operate the required ECCS injection/spray subsystem for greater than or equal to 10 minutes in accordance with the Surveillance Frequency Control Program.#^

4.5.2.7 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal in accordance with the Surveillance Frequency Control Program.

4.5.2.8 Verify the required ECCS injection/spray subsystem can be manually operated in accordance with the Surveillance Frequency Control Program.

DELETED.

Operation may be through the test return line.

^Credit may be taken for normal system operation to satisfy this surveillance requirement.

LIMERICK - UNIT 1 3/4 5-7 Amendment No. 95, 186, 227, 252

- Except for valves that are locked, sealed, or otherwise secured in the actuated position.

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) v

2.

Verifying that the fan starts and isolation valves necessary to draw a suction from the refueling area or the reactor enclosure recirculation discharge open on each of the following test signals:

a)

Manual initiation from the control room, and b)

Simulated automatic initiation signal.

3.

Verifying that the temperature differential across each heater is ~ l5°F when tested in accordance with ANSI N510-1980.

e.

After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter bank satisfies the inplace penetration and leakage testing acceptance criteria of less than 0.05% in accordance with ANSI NSJ0-1980 while operating the system at a flow rate of 5764 cfm +/- 10%.

f.

After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorber bank satisfies the inplace penetration and leakage testing acceptance criteria of less than 0.05%

in accordance with ANSI NSl0-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 5764 cfm +/- 10%.

g.

After any major system alteration:

1.

Verify that when the SGTS fan is running the subsystem flowrate is 2800 cfm minimum from each reactor enclosure (Zones I and II) and 2200 cfm minimum from the refueling area (Zone III).

2.

Verify that one standby gas treatment subsystem will drawdown reactor enclosure Zone I secondary containment to greater than or equal to 0.25 inch of vacuum water gauge in less than or equal to 916 seconds with the reactor enclosure recirculation system in operation and the adjacent reactor enclosure and refueling area zones are in their isolation modes.

LIMERICK - UNIT l 3/4 6-54

.Amendment No. ~0, 10~,

1 122 FEB 1 1997 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

c.

After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a repre-sentative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows, the methyl iodide penetration of less than 2.5% when tested in accordance with ASTM 03803-1989 at a temperature of 30°C (86°F) and a relative humidity of 70%.

d.

In accordance with the Surveillance Frequency Control Program by:

1.

Verifying that the pressure drop across the combined prefilter, upstream and downstream HEPA filters, and charcoal adsorber banks is less than 6 inches water gauge while operating the filter train at a flow rate of 60,000 cfm +/- 10%, verifying that the prefilter pressure drop is less than 0.8 inch water gauge and that the pressure drop across each HEPA is less than 2 inches water gauge.

2.

Verifying that the filter train starts and the isolation valves which take suction on and return to the reactor enclosure open on each of the following test signals:

a.

Manual initiation from the control room, and

b.

Simulated automatic initiation signal.

e.

After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter bank satisfies the*inplace penetration and leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 while operating the system at a flow rate of 60,000 cfm +/- 10%.

f.

After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorber bank satisfies the inplace penetration and leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a halogenated hydro-carbon refrigerant test gas while operating the system at a flow rate of 60,000 cfm +/- 10%.

LIMERICK - UNIT 1 3/4 6-56 Amendment No. ~. +l-, ~. 186 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position

PLANT SYSTEMS LIMITING CONDITION FOR OPERATION CContinuedl ACTION:

(Continued)

4.

With three ESW pump/diesel generator pairs** inoperable, restore at least one inoperable ESW pump/diesel generator pair** to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

5.

With fou~ ESW pump/diesel generator pairs** inoperable, restore at least one inoperable ESW pump/diesel generator pair** to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

In OPERATIONAL CONDITION 4 or 5:

1.

With only one em~rgency service water pump and its associated flowpath OPERABLE, restore at least two pumps with at least one flow path to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or declare the associated safety related equipment ihoperable and take the ACTION required by Specifications 3.5.2 and 3.8.1.2.

c.

In OPERATIONAL CONDITION *

1.

With only one emergency service water pump and its associated flo~ path OPERABLE, restore at least two pumps with at l~ast one flow path to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or verify

- - - - -- - * - - -* - **- - -** - *adequate-cool i ng-Temains- *avai-1 ab-1 e for-the-di-es el -generators* --- - * - -- - ---

required to be OPERABLE or declare the associated diesel generator(s) ihoperable and take the ACTION required by Specification 3.8.1.2.

The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENT 4.7.1.2 At least the above required emergency service water system loop(s) shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each. valve (manual, power-operated, or automatic) that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.

In accordance with the Surveillance Frequency Control Program by verifying that:

1.

Each automatic valve actuates to its correct position on its appropriate ESW pump start signal.

2.

Each pump starts automaticaily when its associated diesel generator starts.

When handling irradiated fuel in the secondary containment.

- An ESW pump/diesel generator pair consists of an ESW pump and its associated diesel generator.

If either an ESW pump or its associated diesel generator becomes inoperable, then the ESW pump/diesel generator pair is inoperable.

LIMERICK - UNIT 1 3/4 7-4 Amendment No. -&7,4G-,++/-,+@.B-, 192 INSERT ***"

"*** Except for valves that are locked, sealed or otherwise secured in the actuated position."

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS <Continued

c.

In accordance with the Surveillance Frequency Control Program by:

1.

Performing a system functional test which includes simulated automatic actuation and restart and verifying that each automatic valve in the flow path actuates to its correct position. Actual injection of coolant into the reactor vessel may be excluded.

2.

Verifying that the system wi 11 develop a fl ow of g.reater than or equal to 600 gpm in the test flow path when steam is supplied to the turbine at a pressure of 150 + 15, - 0 psig.*

3.

Verifying that the suction ~or the RCIC system is automatically transferred from the condensate storage tank to the suppression pool on a condensate storage tank water level-low signal.

4.

Performing a CHANNEL CALIBRATION of the RCIC system discharge line "keep filled" level alarm instrumentation.

The prov1s1ons of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the tests. If OPERABILITY is not successfully demonstrated within the 12-hour period, reduce reactor steam pressure to less than 150*

psig within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

LIMERICK - UNIT 1 3/4 7-10 Amendment No. 2-9,.7J.,186 INSERT ** Except for valves that are locked, sealed, or otherwise secured in the actuated position INSERT "**"

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.1 The emergency core cooling systems shall be demonstrated OPERABLE by:

a.

In accordance with the Surveillance Frequency Control Program:

1.

For the CSS, the LPCI system, and the HPCI system:

a)

Verifying locations susceptible to gas accumulation are sufficiently filled with water.

b)

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct* position.***

2.

For the LPCI system, verifying that both LPCI system subsystem cross-tie valves (HV-51-282 A, B) are closed with power removed from the valve operators.

3.

For the HPCI system, verifying that the HPCI pump flow controller is in the correct position.

4.

For the CSS and LPCI system, performance of a CHANNEL FUNCTIONAL TEST of the injection header ~P instrumentation.

b.

Verifying that, when tested pursuant to Specification 4.0.5:

1.

Each CSS pump in each subsystem develops a flow of at least 3175 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of = 105 psid plus head and line losses.

2.

Each LPCI pump in each subsystem develops a flow of at least 10,000 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of

~ 20 psid plus head and line losses.

3.

The HPCI pump develops a flow of at least 5600 gpm against a test line pressure which corresponds to a reactor vessel pressure of 1040 psig plus head and line losses when steam is being supplied to the turbine at 1040, +13, -120 psig.**

c.

In accordance with the Surveillance Frequency Control Program:

1.

For the CSS, the LPCI system, and the HPCI system, performing a system functional test which includes simulated automatic actuation of the system throughout its emergency operating sequence and verifying that each automatic valve in the flow path actuates to its correct position.

Actual injection of coolant into the reactor vessel may be excluded from this test.

Except that an automatic valve capable of automatic return to its ECCS position when an ECCS signal is present may be in position for another mode of operation.

The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test.

If OPERABILITY is not successfully demonstrated within the 12-hour period, reduce reactor steam dome pressure to less than 200 psig within the following 72-hours.

Not required to be met for system vent flow paths opened under administrative control.

LIMERICK - UNIT 2 3/4 5-4 Amendment No.

J-4,~,-+/--4+. 178

- - - Except for valves that are locked, sealed, or otherwise secured in the actuated position.

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2.1 Verify DRAIN TIME is greater than or equal to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months in accordance with the Surveillance Frequency Control Program.*

4.5.2.2 Verify, for a required LPCI subsystem, the suppression chamber water level is greater than or equal to 16 feet 0 inches in accordance with the Surveillance Frequency Control Program.

4.5.2.3 Verify, for a required CSS subsystem, that the suppression chamber water level is greater than or equal to 16 feet 0 inches or the condensate storage tank water level is greater than or equal to 29 feet 0 inches in accordance with the Surveillance Frequency Control Program.

4.5.2.4 Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

4.5.2.5 DELETED 4.5.2.6 Operate the required ECCS injection/spray subsystem for greater than or equal to 10 minutes in accordance with the Surveillance Frequency Control Program.#^

4.5.2.7 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal in accordance with the Surveillance Frequency Control Program.

4.5.2.8 Verify the required ECCS injection/spray subsystem can be manually operated in accordance with the Surveillance Frequency Control Program.

DELETED.

Operation may be through the test return line.

^Credit may be taken for normal system operation to satisfy this surveillance requirement.

LIMERICK - UNIT 2 3/4 5-7 Amendment No. 59, 147, 190 214

- Except for valves that are locked, sealed, or otherwise secured in the actuated position.

CONTAINMENT SYSTEMS starts an iso at1on va ves necessary to enclosure

\\...._..;

signals:

e.

f.

g.

a)

Manual initiation from the control room, and b)

Simulated automatic initiation signal.

3. Verifying that the temperature differential across each heater is ~ 15°F when tested in accordance with ANSI N510-1980.

After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter bank satisfies the inplace penetration and leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 while operating the system at a flow rate of 5764 cfm +/- 10%.

After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorber bank satisfies the inplace penetration and leakage testing acceptance criteria of less than 0.05%

in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 5764 cfm +/- 10%.

After any major system alteration:

1. Verify that when the SGTS fan is running the subsystem flowrate is 2800 cfm minimum from each reactor enclosure (Zones I and II) and 2200 cfm minimum from the refueling area (Zone III).

2. Verify that one standby gas treatment subsystem will drawdown reactor enclosure Zone II secondary containment to greater than or equal to 0.25 inch of vacuum water gauge in less than or equal to 916 seconds with the reactor enclosure recirculation system in operation and the adjacent reactor enclosure and refueling area zones are in their isolation modes

LIMERICK - UNIT 2 3/4 6-54

.Amendment No. r:/J/, 86 FEB 1 1 1997 INSERT ", except for valves that are locked, sealed or otherwise secured in the actuated position."

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

c.

After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a repre-sentative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration of less than 2.5% when tested in accordance with ASTM 03803-1989 at a temperature of 30°C (86°F) an a relative humidity of 70%.

d.

In accordance with the Surveillance Frequency Control Program by:

1.

Verifying that the pressure drop across the combined prefilter, upstream and downstream HEPA filters, and charcoal adsorber banks is less than 6 inches water gauge while operating the filter train at a flow rate of 60,000 cfm +/- 10%, verifying that the prefilter pressure drop is less than 0.8 inch water gauge and that the pressure drop across each HEPA is less than 2 inches water gauge.

2.

Verifying that the filter train starts and the isolation valves which take suction on and return to the reactor enclosure open on each of the following test signals:

a.

Manual initiation from the control room, and

b.

Simulated automatic initiation signal.

e.

After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter bank satisfies the inplace penetration and leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 while operating the system at a flow rate of 60,000 cfm +/- 10%.

f.

After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorber bank satisfies the inplace penetration and leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a halogenated hydro-carbon refrigerant test gas while operating the system at a flow rate of 60,000 cfm +/- 10%.

LIMERICK - UNIT 2 314 6-56

. Amendment No. 34, J.Q.G, -147 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position

PLANT SYSTEMS LIMITING CONDITION FOR OPERATION <Continued)

ACTION:

(Continued)

4.

With three ESW pump/diesel generator pairs** inoperable, restore at least one inoperable ESW pump/diesel generator pair** to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

5.

With four ESW pump/diesel generator pairs** inoperable, restore at least one inoperable ESW pump/diesel generator pair** to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

In OPERATIONAL CONDITION 4 or 5:

1.

With only one emergency service water pump and its associated flow path OPERABLE, restore at least two pumps with at least one flow path to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or declare the associated safety related equipment inoperable and take the ACTION required by Specifications 3.5.2 and 3.8.1.2.

c.

In OPERATIONAL CONDITION *

1.

With only one emergency service water pump and its associated flow path OPERABLE, restore at least two pumps with at least one flow path to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or verify adequate cooling remains available for the diesel generators required to be OPERABLE or declare the associated diesel genera-tor(s) inoperable and take the ACTION required by Specifica-tion 3.8.1.2. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENT 4.7.1.2 At least the above required emergency service water system loop(s) shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying

~that each valve (manual, power-operated, or automatic) that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.

In accordance with the Surveillance Frequency Control Program by verifying that:

1.

Each automatic valve actuates to its correct position on its appropriate ESW pump start signal.

2.

Each pump starts automatically when its associated diesel generator starts.

When handling irradiated fuel in the secondary containment.

An ESW pump/diesel generator pair consists of an ESW pump and its associated diesel generator.* If either an ESW pump or its associated diesel generator becomes inoperable, than the ESW pump/diesel generator pair is inoperable.

LIMERICK - UNIT 2 3/4 7-4 Amendment No..J4,.147 INSERT ***"

INSERT "***

Except for valves that are locked, sealed or otherwise secured in the actuated position."

PLANT SYSTEMS

c.

In accordance with the Surveillance Frequency Control Program by:

1.

Performing a system functional test which includes simulated automatic actuation and restart and verifying that each automatic valve in the flow path actuates to its correct position. Actual injection of coolant into the reactor vessel may be excluded.

2.

Verifying that the system will develop a flow of greater than or equal to 600 gpm in the test flow path when steam is supplied to the turbine at a pressure of 150 + 15, - 0 psig.*

3.

Verifying that the suction *for the RCIC system is automatically transferred from the condensate storage tank to the suppression pool on a condensate storage tank water level-low signal.

4.

Performing a CHANNEL CALIBRATION of the RCIC system discharge line "keep filled" level alarm instrumentation.

The prov1s1ons of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure i~

adequate to perform the tests. If OPERABILITY is not successfully demonstrated within the 12-hour period, reduce reactor steam dome pressure to less than 150 psig within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

LIMERICK - UNIT 2 3/4 7-10 Amendment No. 34,147 INSERT **"

INSERT "** Except for valves that locked, sealed, or otherwise secured in the actuated position."

i Proposed Technical Specification Changes (Mark-Up)

Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 REVISED TECHNICAL SPECIFICATION PAGES 3.5.1-5 3.5.2-5 3.5.3-3 3.6.4.3-3 3.7.1-5 3.7.2-3

SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.1.4 SR 3.5.1.5 SR 3.5.1.6 SR 3.5.1.7 NMP2 SURVEILLANCE Verify each ECCS pump develops the specified flow rate with the specified developed head.

SYSTEM LPCS LPCS A, B LPCIC HPCS TOTAL FLOW RATE DEVELOPED HEAD

6350 gpm

7450 gpm

7450 gpm

6350 gpm

284 psid

127 psid

140 psid

327 psid

NOTE---*------------------------

Vessel injection/spray may be excluded.

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

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

Valve actuation may be excluded.

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

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

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

Verify each required ADS valve actuator strokes when manually actuated.

3.5.1-5 ECCS - Operating 3.5.1 FREQUENCY In accordance with the IN SERVICE TESTING PROGRAM In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment 91, 152, 161 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.6 SR 3.5.2.7 SR 3.5.2.8 NMP2 SURVEILLANCE

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

N o t required to be met for ECCS pumps aligned for shutdown cooling.

Operate the required ECCS injection/spray subsystem through the recirculation line for ~ 10 minutes.

Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

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

Vesse I injection/spray may be excluded.

Verify the required LPCI or LPCS subsystem actuates on a manual initiation signal or the required HPCS subsystem can be manually operated.

3.5.2-5 RPV Water Inventory Control 3.5.2 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment 9,..1, 152, 168 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

INSERT ", except for valves that are locked, sealed, or otherwise secured in the actuated position."

SURVEILLANCE REQUIREMENTS continued SR 3.5.3.5 NMP2 SURVEILLANCE

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

Vessel injection may be excluded.

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

3.5.3-3 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment 9-+,152 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.4.3.1 Operate each SGT subsystem for 2'. 15 continuous minutes with heaters operating.

SR 3.6.4.3.2 Perform required SGT filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual or simulated initiation signal.

SR 3.6.4.3.4 Verify each SGT decay heat removal air inlet valve can be opened.

SGT System 3.6.4.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program NMP2 3.6.4.3-3 Amendment 91, 1 Q1, 162, 166, 168 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

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INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

ACTIONS (continued)

F.

CONDITION Two CREF subsystems inoperable with safety function not maintained during movement of recently irradiated fuel assemblies in the secondary containment.

One or more CREF subsystems inoperable due to inoperable CRE boundary during movement of recently irradiated fuel assemblies in the secondary containment.

REQUIRED ACTION

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

L CO 3.0.3 is not applicable.

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

SURVEILLANCE REQUIREMENTS SR 3.7.2.1 SR 3.7.2.2 SR 3.7.2.3 SURVEILLANCE Operate each CREF subsystem for ~ 15 continuous minutes.

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

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

CREF System 3.7.2 COMPLETION TIME Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program (continued)

NMP2 3.7.2-3 Amendment 91, 95, 97, 125, 126, 152, 166, 168 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

j Proposed Technical Specification Changes (Mark-Up)

Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 REVISED TECHNICAL SPECIFICATION PAGES 3.5-6 3.5-18 3.5-14 3.6-42 3.7-4 3.7-9

SURVEILLANCE REQUIREMENTS (continued)

SR

3. 5.1. 8 SR

3. 5.1. 9 SURVEILLANCE

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

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

Verify, with reactor pressure s 1053 and 2 910 psig, the HPCI pump can develop a flow rate 2 5000 gpm against a system head corresponding to reactor pressure.

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

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

Verify, with reactor pressure s 175 psig, the HPCI pump can develop a flow rate 2 5000 gpm against a system head corresponding to reactor pressure.

SR 3.5.1.10

NOTE--

Vessel injection/spray may be excluded.

PBAPS UNIT 2 Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal.

3.5-6 ECCS -Operating 3.5.1 FREQUENCY In accordance with the Surveillance Frequency Control Program.

In accordance with the Surveillance Frequency Control Program.

(continued)

Amendment No. 316 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position

SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.3.5 PBAPS UNIT 2 SURVEILLANCE

- - - - - - NOTE - - -

Vessel injection may be excluded.

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

3.5 14 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Contro 1 Program.

Amendment No.278 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position

RPV Water Inventory Control 3.5.4 SURVEILLANCE RE UIREMENTS continued SR 3.5.4.4 SR 3.5.4.5 SR 3.5.4.6 SR 3.5.4.7 SR 3.5.4.8 PBAPS UNIT 2 SURVEILLANCE Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

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

Not required to be met for system vent flow paths open under administrative control.

Verify for the required ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Operate the required ECCS injection/spray subsystem through the recirculation line for~ 10 minutes.

Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually actuated.

FREQUENCY In accordance with the Surveillance Frequency Control Pro ram.

In accordance with the Surveillance Frequency Control Program.

In accordance with the

Surveillance Frequency Control Program.

In accordance with the Surveillance Frequency Control Program.

3.5-18 Amendment No. 317 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 SR 3.6.4.3.2 SR 3.6.4.3.3 PBAPS UNIT 2 SURVEILLANCE Operate each SGT subsystem for

~ 15 minutes with heaters operating.

Perform uired SGT lter testing in accordance with the Ventilation Filter Testing Program CVFTP).

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

3.6-42 SGT System 3.6.4.3 FREQUENCY In accordance with the Surveillance F

uency Contro-Program.

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

Amendment No.273 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position

ESW Sys tern and Norma 1 Heat Sink 3.7.2 SURVEILLANCE REQUIREMENTS SR

3. 7.2. l SR 3.7.2.2 SR 3.7.2.3 SR 3.7.2.4 PBAPS UN IT 2 SURVEILLANCE Verify the water level in the pump bays of the pump structure is ~ 98.5 ft Conowingo Datum CCDl and s 113 ft CO.

Verify the water temperature of normal heat sink is s 92"F.

******--NOTE-------------- ---

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

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

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

3.7-4 FREQUENCY In accordance with the Surveillance Frequency Control Program.

ln accordance with the Surveillance Frequency Control Program.

Hourly when water temperature of normal heat s i n k i s > 90 ° F.

ln accordance with the Surveillance Frequency Control Program.

In accordance with the Surveillance Frequency Control Program.

Amendment No. 291 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position

ACTIONS CONDITION F.

Two MCREV subs¥stems inoperable during movement of irradiated fuel assemblies in the secondary containment, or during CORE ALTERATIONS.

OR REQUIRED ACTION

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

LCO 3.0.3 is not applicable.

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

One or more MCREV AND subsystems inoperable due to an inoperable F.2 CRE Boundary during movement of irradiated Suspend CORE ALTERATIONS.

fuel assemblies in the secondary containment, or during CORE ALTERATIONS.

SURVEILLANCE RE UIREMENTS SR 3.7.4.1 SR 3.7.4.2 SR 3.7.4.3 SR 3.7.4.4 PBAPS UNIT 2 SURVEILLANCE Operate each MCREV subsystem for

~ 15 minutes.

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

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

Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

3.7-9 MCREV System 3.7.4 COMPLETION TIME Immediately Immediately FREQUENCY In accordance 1 with the Surveillance Frequency Control

. Program.

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

In accordance with the Cont ro 1 Room Envelope

Habitability Program.

Amendment No. 317 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position

SURVEILLANCE REQUIREMENTS (continued)

SR

3. 5.1. 8 SR

3. 5.1. 9 SR

3. 5.1.10 PBAPS UNIT 3 SURVEILLANCE

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

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

Verify, with reactor pressure s 1053 and 2 910 psig, the HPCI pump can develop a flow rate 2 5000 gpm against a system head corresponding to reactor pressure.

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

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

Verify, with reactor pressure s 175 psig, the HPCI pump can develop a flow rate 2 5000 gpm against a system head corresponding to reactor pressure.

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

Vessel injection/spray may be excluded.

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

3.5-6 ECCS Operating 3.5.1 FREQUENCY In accordance with the Surveillance Frequency Control Program.

In accordance with the Survei 11 ance Frequency Control Program.

In accordance with the Surveillance Frequency Control Program.

(continued)

Amendment No. 319 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position

SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.3.5 PBAPS UNIT 3 SU RV EI LLANCE

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

Vessel injection may be excluded.

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

3.5-14 RCIC System 3.5.3 FREQUEl~CY In accordance with the Surveillance Frequency Control Program.

Amendment 1~0281 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position

RPV Water Inventory Control 3.5.4 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.4.4 SR 3.5.4.5 SR 3.5.4.6 SR 3.5.4.7 SR 3.5.4.8 PBAPS UNIT 3 SURVEILLANCE Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

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

Not required to be met for system vent flow paths open under administrative control.

Verify for the required ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Operate the required ECCS injection/spray subsystem through the recirculation line for ~ 10 minutes.

Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually actuated.

3.5-18 FREQUENCY In accordance with the Surveillance Frequency Control Program.

In accordance with the Surveillance Frequency Control Program.

Amendment No. 320 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.l SR 3.6.4.3.2 SR 3.6.4.3.3 PBAPS UN IT 3 SURVEILLANCE Operate each SGT subsystem for

~ 15 minutes with heaters operating.

Perform required filter testing in accordance with the Ventilation Filter Testing Program CVFTP).

Verify each SGT subsystem actuates on an actual or simu ated initiation signal.

3.6 42 FR SGT System 3.6.4.3 ENCY In accordance with the Surveillance Frequency Control Program.

In accordance with the VFTP In accordance with the Survei l ance Frequency Control Program.

Amendment No.281 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position

ESW System and Normal Heat Sink 3.7.2 SURVEILLANCE REQUIREMENTS SR 3.7.2.1 SR 3.7.2.2 SR 3.7.2.3 SR 3.7.2.4 PBAPS UN IT 3 SURVEILLANCE Verify the water level in the pump bays of the pump structure is~ 98.5 ft Conowingo Datum CCD) and $ 113 ft CD.

Verify the water temperature of normal heat sink is $ 92°F.

. -** *****---*- *-NOTE---- ----*-*----*--

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

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

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

3.7-4 FREQUENCY In accordance with the Surveillance Frequency Control Program.

In accordance with the Surveillance Frequency Control Program.

Hourly when water temperature of normal heat sink is > 90°F.

In accordance with the Surveillance Frequency Control Program.

Amendment No. 294 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position

ACTIONS CONDITION F.

Two MCREV subsystems inoperable during movement of irradiated fuel assemblies in the secondary containment, or during CORE ALTERATIONS.

OR REQUIRED ACTION

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

LCO 3.0.3 is not applicable.

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

One or more MCREV ANO subsystems inoperable due to an inoperable F.2 Suspend CORE ALTERATIONS.

CRE boundary during movement of irradiated fuel assemblies in the secondary containment, or during CORE ALTERATIONS.

SURVEILLANCE RE UIREMENTS SR 3.7.4.1 SR 3.7.4.2 SR 3.7.4.3 SR 3.7.4.4 PBAPS UNIT 3 SURVEILLANCE Operate each MCREV subsystem for

~ 15 minutes.

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

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

Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

3.7-9 I

MCREV System 3.7.4 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Survei 11 ance Frequency Control Program.

In accordance with the VFTP In accordance with the Surveillance Frequency Control In accordance with the Control Room Envelope Habitability Program.

Amendment No. 320 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position k

Proposed Technical Specification Changes (Mark-Up)

Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 REVISED TECHNICAL SPECIFICATION PAGES 3.5.1-6 3.5.2-6 3.5.3-3 3.6.4.3-3 3.7.4-3

SURVEILLANCE REQUIREMENTS SR 3.5.1.8 SR 3.5.1.9 SR 3.5.1.10 SR 3.5.1.11 SR 3.5.1.12 SU RV EI LLANCE NOTE Vessel injection/spray may be excluded.

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

-- -NOTE -

Valve actuation may be excluded.

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

Verify each ADS valve actuator strokes when manually actuated.

Verify automatic transfer capability of the LPCI swing bus power supply from the normal source to the backup source.

Verify ADS pneumatic supply header pressure is::::. 80 psig.

ECCS-Operating

3. 5.1 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Quad Cities 1 and 2 3.5.1-6 Amendment No. 248/243 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS SR 3.5.2.5 SR 3.5.2.6 SR 3.5.2.7 SURVEILLANCE Operate the required ECCS injection/spray subsystem through the recirculation line for ~ 10 minutes.

Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

NOTE------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Quad Cities 1 and 2 3.5.2-6 Amendment No. 273/268 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

SURVEILLANCE REQUIREMENTS SR 3.5.3.5 Quad Cities SURVEILLANCE

NOTE-------

Vessel injection may be excluded.

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

and 2 3.5.3-3 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No.

248/_2_43 INSERT, except for valves that are locked, sealed, or otherwise secured in the actuated position.

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.l SR 3.6.4.3.2 SR 3.6.4.3.3 SURVEILLANCE Operate each SGT subsystem for

~ 15 continuous minutes with heaters operating.

Perform required SGT filter testtng in accordance with the Ventilation Filter Testing Program (VFTP).

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

SGT System 3.6.4.3 FREQUENCY In accordance with the Surveillance Frequertcy Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program Quad Cities 1 and 2 3.6.4.3-3 Amendment No.

252/247 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

CREV System 3.7.4 SURVEILLANCE REQUIREMENTS SR 3.7.4.1 SR 3.7.4.2 SR 3.7.4.3 SR 3.7.4.4 SURVE lLLANCE FREQUENCY Operate the CREV System for ~ 15 continuous In accordance minutes with the heaters operating.

with the Surveillance Frequency Control Program Perform required CREV filter testing in accordance with the Venti1at1on Filter Testing Program (VFTP).

Verify the CREV System isolation dampers close on an actual or simulated initiat1on s"!gnal.

Perform required CRE unfiltered afr inleakage testing in accordance with the Control Room Envelope Habitability Program.

In accordance with the VFTP In accordance with the Surveillance Frequency Control Program rn accordance w1th the Cont ro 1 Room Envelope Habitabi 1i ty Program Quad Cities 1 and 2 3.7.4-3 Amendment.

252/247 INSERT, except for dampers that are locked, sealed, or otherwise secured in the actuated position.

l Proposed Technical Specification Changes (Mark-Up)

R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 REVISED TECHNICAL SPECIFICATION PAGES 3.7.9-2

CONDITION REQUIRED ACTION D.

Required Action and 0.1 Place OPERABLE GREATS associated Completion train in emergency mode.

Time of Condition A not met during movement of OR irradiated fuel assemblies.

D.2 Suspend movement of irradiated fuel assemblies.

E.

Two CREA TS trains E.1 Suspend movement of inoperable during irradiated fuel assemblies.

movement of irradiated fuel assemblies.

OR One or more CREA TS trains inoperable due to an inoperable CRE boundary during movement of irradiated fuel assemblies.

F.

Two CREA TS trains F.1 Enter LCO 3.0.3.

inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.9.1 Operate each CREA TS filtration train :2: 15 minutes.

SR 3.7.9.2 SR 3.7.9.3 Perform required CREA TS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

Verify each CREA TS train actuates on an actual or simulated actuation signal.

R.E. Ginna Nuclear Power Plant 3.7.9-2 CREA TS 3.7.9 COMPLETION TIME Immediately Immediately Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program Amendment No. 122 INSERT, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

TS SR BASES Statement Insert:

NOTE A: The SR excludes automatic dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to dampers or valves that are locked, sealed, or otherwise secured in the actuated position since the affected dampers or valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured.

Placing an automatic valve or damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve or damper to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve or damper to the non-actuated position requires verification that the SR has been met within its required Frequency.

Limerick Notes:

NOTE B: "SR 4.5.1.c.1 excludes automatic dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to dampers or valves that are locked, sealed, or otherwise secured in the actuated position since the affected dampers or valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve or damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve or damper to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve or damper to the non-actuated position requires verification that the SR has been met within its required Frequency.

NOTE C: "SR 4.5.2.7 and 4.5.2.8 exclude automatic dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The SRs do not apply to dampers or valves that are locked, sealed, or otherwise secured in the actuated position since the affected dampers or valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve or damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve or damper to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve or damper to the non-actuated position requires verification that the applicable SR has been met within its required Frequency.

NOTE D: "SR 4.6.5.3.d.2 excludes automatic dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to dampers or valves that are locked, sealed, or otherwise secured in the actuated position since the affected dampers or valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve or damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve or damper to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve or damper to the non-actuated position requires verification that the SR has been met within its required Frequency.

NOTE E: "SR 4.6.5.4.d.2 excludes automatic dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to dampers or valves that are locked, sealed, or otherwise secured in the actuated position since the affected dampers or valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve or damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve or damper to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve or damper to the non-actuated position requires verification that the SR has been met within its required Frequency.

NOTE F: "SR 4.7.1.2.b.1 excludes automatic dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to dampers or valves that are locked, sealed, or otherwise secured in the actuated position since the affected dampers or valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve or damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve or damper to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve or damper to the non-actuated position requires verification that the SR has been met within its required Frequency.

NOTE G: "SR 4.7.3.c.1 excludes automatic dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to dampers or valves that are locked, sealed, or otherwise secured in the actuated position since the affected dampers or valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve or damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve or damper to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve or damper to the non-actuated position requires verification that the SR has been met within its required Frequency.

a Revised Technical Specification Bases Changes (Information Only)

Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3.7.10-8 B 3.7.12-8 B 3.7.13-7

VC Filtration System B 3.7.10 BRAIDWOOD UNITS 1 & 2 B 3.7.10 8 Revision 96 BASES ACTIONS (continued)

F.1 If both VC Filtration System trains are inoperable in MODE 1, 2, 3, or 4, for reasons other than an inoperable CRE boundary (i.e., Condition B), the VC Filtration System may not be capable of performing the intended function and the unit is in a condition outside the accident analyses.

Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. The makeup air filter unit includes heaters. Operation with the heaters on for 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that heater failure, blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The recirculation subsystem filters do not contain heaters and need only be operated for 15 minutes to demonstrate the function of the system. For purposes of satisfying this SR, the recirculation subsystem may be run concurrently with the makeup subsystem. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.10.2 This SR verifies that the required VC Filtration System testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VC Filtration System filter tests are in general conformance with Regulatory Guide 1.52 (Ref. 5). The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, system flow rates, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP.

The acceptance criteria stated in the VFTP, ensure that the filter efficiencies assumed in the safety analyses are met.

SR 3.7.10.3 This SR verifies that each VC Filtration System train aligns, starts, and operates on an actual or simulated actuation signal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

INSERT NOTE A

Nonaccessible Area Exhaust Filter Plenum Ventilation System B 3.7.12 BRAIDWOOD UNITS 1 & 2 B 3.7.12 8 Revision 85 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.12.3 This SR verifies that each Nonaccessible Area Exhaust Filter Plenum Ventilation System train aligns, starts, and operates on a manual, an actual, or a simulated actuation signal.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.12.4 This SR verifies the integrity of the ECCS pump room areas.

The ability of the ECCS pump room areas to maintain a negative pressure, with respect to potentially uncontaminated adjacent areas, is periodically tested to verify proper functioning of the Nonaccessible Area Exhaust Filter Plenum Ventilation System. During the emergency mode of operation, the Nonaccessible Area Exhaust Filter Plenum Ventilation System is designed to maintain a slight negative pressure in the ECCS pump rooms, with respect to adjacent areas, to prevent unfiltered LEAKAGE. The Nonaccessible Area Exhaust Filter Plenum Ventilation System is designed to maintain a -0.25 inches water gauge relative to atmospheric pressure with two trains operating, each at a flow rate 73,590 cubic feet per minute (cfm). This SR should be performed in four-fan operation with two auxiliary building normal supply and two auxiliary building normal exhaust fans in operation. Performance of the SR in this manner produces the least negative pressure in the ECCS pump room areas (i.e., the least margin to -0.25 inches water gauge). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

INSERT NOTE A

FHB Ventilation System B 3.7.13 BRAIDWOOD UNITS 1 & 2 B 3.7.13 7 Revision 85 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.13.3 This SR verifies the integrity of the fuel handling building and containment enclosure. The ability of the fuel handling building and containment to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the FHB Ventilation System and enclosure integrity. During the emergency mode of operation the FHB Ventilation System is designed to maintain a slight negative pressure in the fuel handling building to prevent unfiltered leakage. The FHB Ventilation System is designed to maintain a -0.25 inches water gauge with respect to atmospheric pressure. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that requires this SR only during movement of RECENTLY IRRADIATED FUEL assemblies (in the fuel building or in the containment) when the equipment hatch is not intact.

SR 3.7.13.4 This SR verifies that each FHB Ventilation System train aligns, starts, and operates on an actual or simulated actuation signal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

INSERT NOTE A b

Revised Technical Specification Bases Changes (Information Only)

Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3.7.10-8 B 3.7.12-8 B 3.7.13-7

VC Filtration System B 3.7.10 BYRON UNITS 1 & 2 B 3.7.10 8 Revision 88 BASES ACTIONS (continued)

F.1 If both VC Filtration System trains are inoperable in MODE 1, 2, 3, or 4, for reasons other than an inoperable CRE boundary (i.e., Condition B), the VC Filtration System may not be capable of performing the intended function and the unit is in a condition outside the accident analyses.

Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. Operation with the heaters on for 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that heater failure, blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The recirculation subsystem filters do not contain heaters and need only be operated for 15 minutes to demonstrate the function of the system. For purposes of satisfying this SR, the recirculation subsystem may be run concurrently with the makeup subsystem. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.10.2 This SR verifies that the required VC Filtration System testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VC Filtration System filter tests are in general conformance with Regulatory Guide 1.52 (Ref. 5). The VFTP includes testing the performance of the HEPA filter, charcoal absorber efficiency, system flow rates, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP.

The acceptance criteria stated in the VFTP, ensure that the filter efficiencies assumed in the safety analyses are met.

SR 3.7.10.3 This SR verifies that each VC Filtration System train aligns, starts, and operates on an actual or simulated actuation signal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

INSERT NOTE A

Nonaccessible Area Exhaust Filter Plenum Ventilation System B 3.7.12 BYRON UNITS 1 & 2 B 3.7.12 8 Revision 75 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.12.3 This SR verifies that each Nonaccessible Area Exhaust Filter Plenum Ventilation System train aligns, starts, and operates on a manual, an actual, or a simulated actuation signal.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.12.4 This SR verifies the integrity of the ECCS pump room areas.

The ability of the ECCS pump room areas to maintain a negative pressure, with respect to potentially uncontaminated adjacent areas, is periodically tested to verify proper functioning of the Nonaccessible Area Exhaust Filter Plenum Ventilation System. During the emergency mode of operation, the Nonaccessible Area Exhaust Filter Plenum Ventilation System is designed to maintain a slight negative pressure in the ECCS pump rooms, with respect to adjacent areas, to prevent unfiltered LEAKAGE. The Nonaccessible Area Exhaust Filter Plenum Ventilation System is designed to maintain a -0.25 inches water gauge relative to atmospheric pressure with two trains operating, each at a flow rate 68,200 cubic feet per minute (cfm).

Nonaccessible Area Exhaust Filter Plenum Ventilation System function must be maintained considering the design basis scenarios of an SI signal only on one unit or an SI signal concurrent with a loss of offsite power to a unit. This SR should be performed with the postulated number of VA supply and exhaust fans running considering the SI signal only scenario. Performance of the SR in this manner produces the least negative pressure in the ECCS pump room areas (i.e.,

the least margin to -0.25 inches water gauge). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

INSERT NOTE A

FHB Ventilation System B 3.7.13 BYRON UNITS 1 & 2 B 3.7.13 7 Revision 75 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.13.3 This SR verifies the integrity of the fuel handling building and containment enclosure. The ability of the fuel handling building and containment to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the FHB Ventilation System and enclosure integrity. During the emergency mode of operation the FHB Ventilation System is designed to maintain a slight negative pressure in the fuel handling building to prevent unfiltered leakage. The FHB Ventilation System is designed to maintain a -0.25 inches water gauge with respect to atmospheric pressure. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that requires this SR only during movement of RECENTLY IRRADIATED FUEL assemblies (in the fuel building or in the containment) when the equipment hatch is not intact.

SR 3.7.13.4 This SR verifies that each FHB Ventilation System train aligns, starts, and operates on an actual or simulated actuation signal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

INSERT NOTE A c

Revised Technical Specification Bases Changes (Information Only)

Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3.6.8-4 B 3.7.8-9 B 3.7.12-4

IRS B 3.6.8 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.6.8-4 Revision 55 SURVEILLANCE SR 3.6.8.1 REQUIREMENTS Initiating each IRS train from the Control Room and operating it for 15 minutes ensures that all trains are OPERABLE and that all associated controls are functioning properly. It also ensures that motor failure can be detected for corrective action. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.8.2 This SR verifies that the required IRS filter testing is performed in accordance with the Ventilation Filter Testing Program. The IRS filter tests are in accordance with portions of Reference 3. The Ventilation Filter Testing Program includes testing high efficiency particulate air filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the Ventilation Filter Testing Program.

SR 3.6.8.3 The automatic startup test verifies that both trains of equipment start upon receipt of an actual or simulated test signal (Engineered Safety Feature Actuation System). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1. UFSAR

2. WCAP-16125-NP-A, Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown, Revision 2, August 2010

3. Regulatory Guide 1.52, Revision 2, "Design, Testing, and Maintenance Criteria for Postaccident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants," March 1978 INSERT NOTE A

CREVS B 3.7.8 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.7.8-9 Revision 62 SURVEILLANCE SR 3.7.8.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. Since the environment and normal operating conditions on this system are not severe, testing each required CREVS filter train once every month provides an adequate check on this system.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.8.2 This SR verifies that the required CREVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CREVS filter tests are in accordance with portions of Reference 4. The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test Frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.8.3 This SR verifies each CREVS train starts and operates on an actual or simulated actuation signal (CRRS). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.8.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to the CRE occupants calculated in the licensing basis analysis of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analysis of DBA consequences. When INSERT NOTE A

PREVS B 3.7.12 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.7.12-4 Revision 55 The test is performed by initiating the system from the Control Room, ensuring flow through the HEPA filter and charcoal adsorber train, and verifying this system operates for 15 minutes. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.12.2 This SR verifies the performance of PREVS filter testing in accordance with the VFTP. The PREVS filter tests are in accordance with portions of Reference 5. The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.12.3 This SR verifies that each PREVS train starts and operates on an actual or simulated actuation signal (Containment Isolation Signal). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

UFSAR 2.

Regulatory Guide 1.194, Atmospheric Relative Concentrations for Control Room Radiological Habitability Assessments at Nuclear Power Plants, June 2003 3.

Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, July 2000 4.

WCAP-16125-NP-A, Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown, Revision 2, August 2010 INSERT NOTE A d

Revised Technical Specification Bases Changes (Information Only)

Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3.5-12 B 3.5-26 B 3.5-27 B 3.5-35 B 3.6-43 B 3.6-100 B 3.7-7 B 3.7-10 B 3.7-19

ECCS Operating B 3.5.1 CLINTON B 3.5-12 Revision No. 20-2 BASES SURVEILLANCE SR 3.5.1.5 REQUIREMENTS (continued)

The ECCS subsystems are required to actuate automatically to perform their design functions. This Surveillance test verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCS, LPCS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup, and actuation of all automatic valves to their required positions. This Surveillance also ensures that the HPCS System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the RCIC storage tank to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

SR 3.5.1.6 The ADS designated S/RVs are required to actuate automatically upon receipt of specific initiation signals.

A system functional test is performed to demonstrate that the mechanical portions of the ADS function (i.e.,

solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components. SR 3.5.1.7 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes valve actuation.

This prevents an RPV pressure blowdown.

SR 3.5.1.7 A manual actuation of each required ADS valve (those valves removed and replaced to satisfy SR 3.4.4.1) is performed to verify that the valve is functioning properly. This SR can (continued)

INSERT NOTE A

RPV Water Inventory Control B 3.5.2 CLINTON B 3.5-26 Revision No. 21-2 BASES SURVEILLANCE SR 3.5.2.5 REQUIREMENTS (continued)

Verifying that the required ECCS injection/spray subsystem can be manually started and operate for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. This SR is modified by two Notes. Note 1 acknowledges that testing of the ECCS injection/spray subsystem through the full flow test return line is adequate to confirm the operational readiness of the required ECCS injection/spray subsystem. Note 2 states that credit for meeting this SR may be taken for normal system operation to satisfy this SR. The minimum operating time of 10 minutes was based on engineering judgement.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.6 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

INSERT NOTE A

RPV Water Inventory Control B 3.5.2 CLINTON B 3.5-27 Revision No. 21-2 BASES SURVEILLANCE SR 3.5.2.7 REQUIREMENTS (continued)

The required ECCS subsystem shall be capable of being manually operated from the main control room. This Surveillance verifies that the required LCPI subsystem, LPCS System, or HPCS System (including the associated pump and valve(s)) can be manually operated, including throttling injection valves, as necessary, to provide additional RPV Water Inventory, if needed, without delay.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the full flow test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES

1.

Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup," November 1984.

2.

Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3.

Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f)," August 1992.

4.

NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs,"

May 1993.

5.

Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1,"

July 1994.

6.

General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6," February 1983.

INSERT NOTE A

RCIC System B 3.5.3 CLINTON B 3.5-35 Revision No. 20-2 BASES SURVEILLANCE SR 3.5.3.5 REQUIREMENTS (continued)

The RCIC System is required to actuate automatically to perform its design function. This Surveillance verifies that with a required system initiation signal (actual or simulated) the automatic initiation logic of RCIC will cause the system to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup and actuation of all automatic valves to their required positions. This Surveillance test also ensures that the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the RCIC storage tank to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.3, "Reactor Core Isolation Cooling (RCIC) System Instrumentation," overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES

1.

10 CFR 50, Appendix A, GDC 33.

2.

USAR, Section 5.4.6.

3.

Memorandum from R.L. Baer (NRC) to V. Stello, Jr.

(NRC), "Recommended Interim Revisions to LCO's for ECCS Components," December 1, 1975.

4.

Deleted.

5.

Calculation 01RI15.

INSERT NOTE A

RHR Containment Spray System B 3.6.1.7 CLINTON B 3.6-43 Revision No. 20-9 BASES SURVEILLANCE SR 3.6.1.7.3 REQUIREMENTS (continued)

This SR verifies that each RHR containment spray subsystem automatic valve actuates to its correct position upon receipt of an actual or simulated automatic actuation signal. Actual spray initiation is not required to meet this SR. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.3.5 overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.1.7.4 This Surveillance is performed following activities that could result in nozzle blockage to verify that the spray nozzles are not obstructed and that flow will be provided when required. Such activities may include a loss of foreign material control (of if it cannot be assured),

following a major configuration change, or following an inadvertent actuation of containment spray. This Surveillance is normally performed by an air or smoke flow test. The Frequency is adequate due to the passive nozzle design and its normally dry state and has been shown to be acceptable through operating experience.

SR 3.6.1.7.5 RHR Containment Spray System piping and components have the potential to develop voids and pockets of entrained gases.

Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR containment spray subsystems and may also prevent water hammer and pump cavitation.

Selection of RHR Containment Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Containment Spray System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume (continued)

INSERT NOTE A

SGT System B 3.6.4.3 CLINTON B 3.6-100 Revision No. 20-2 BASES SURVEILLANCE SR 3.6.4.3.3 REQUIREMENTS (continued)

This SR requires verification that each SGT subsystem automatically starts upon receipt of an actual or simulated initiation signal.

The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.2.5 overlaps this SR to provide complete testing of the safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.4.3.4 This SR requires verification that the SGT filter cooling bypass damper can be opened and the fan started. This ensures that the ventilation mode of SGT System operation is available. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

10 CFR 50, Appendix A, GDC 41.

2.

USAR, Section 6.2.3.

3.

USAR, Section 15.6.5.

4.

Regulatory Guide 1.52.

5.

USAR, Section 6.5.1.

6.

USAR, Section 15.6.4.

7.

USAR Appendix A.

8.

ASME/ANSI N510-1980.

9.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002

10.

Calculation IP-0-0086.

11.

Calculation IP-0-0087.

INSERT NOTE A INSERT NOTE A

Division 1 and 2 SX Subsystems and UHS B 3.7.1 CLINTON B 3.7-7 Revision No. 14-2 BASES SURVEILLANCE SR 3.7.1.3 REQUIREMENTS (continued)

This SR verifies that the automatic isolation valves of the Division 1 and 2 SX subsystems will automatically switch to the safety or emergency position to provide cooling water exclusively to the safety related equipment during an accident event. This is demonstrated by use of an actual or simulated initiation signal and is performed with the plant shut down. This SR also verifies the automatic start capability of the SX pump in each subsystem.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

Regulatory Guide 1.27, Revision 2, January 1976.

2.

USAR, Section 9.2.1.2.

3.

USAR, Table 9.2-3.

4.

USAR, Section 6.2.1.1.3.3.

5.

USAR, Chapter 15.

6.

USAR, Section 6.2.2.3.

7.

USAR, Table 6.2-2.

8.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

9.

Calculation IP-0-0095.

INSERT NOTE A

Division 3 SX Subsystem B 3.7.2 CLINTON B 3.7-10 Revision No. 14-2 BASES SURVEILLANCE SR 3.7.2.1 (continued)

REQUIREMENTS Isolation of the Division 3 SX subsystem to components or systems does not necessarily affect the OPERABILITY of the Division 3 SX subsystem. As such, when the Division 3 SX pump, valves, and piping are OPERABLE, but a branch connection off the main header is isolated, the Division 3 SX subsystem needs to be evaluated to determine if it is still OPERABLE. Alternatively, it is acceptable and conservative to declare an SX subsystem inoperable when a branch connection is isolated or a supported ventilation system is inoperable.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.2.2 This SR verifies that the automatic isolation valves of the Division 3 SX subsystem will automatically switch to the safety or emergency position to provide cooling water exclusively to the safety related equipment during an accident event. This is demonstrated by use of an actual or simulated initiation signal and is performed with the plant shut down. This SR also verifies the automatic start capability of the Division 3 SX pump.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

USAR, Section 9.2.1.2.

2.

USAR, Chapter 6.

3.

USAR, Chapter 15.

INSERT NOTE A

Control Room Ventilation System B 3.7.3 CLINTON B 3.7-19 Revision No. 14-2 BASES SURVEILLANCE SR 3.7.3.1 and SR 3.7.3.2 (continued)

REQUIREMENTS With regard to subsystem operation time values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 8, 9).

SR 3.7.3.3 This SR verifies that the required Control Room Ventilation System testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber bypass leakage and efficiency, minimum system flow rate (scfm), combined HEPA filter and charcoal adsorber pressure drop, and heater dissipation in accordance with Regulatory Guide 1.52 (Ref. 10). The Frequencies for performing the Control Room Ventilation System filter tests are also in accordance with Regulatory Guide 1.52 (Ref.10). Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.3.4 This SR verifies that each Control Room Ventilation subsystem starts and operates on an actual or simulated high radiation initiation signal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

INSERT NOTE A e

Revised Technical Specification Bases Changes (Information Only)

Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3.5.1-16 B 3.5.2-12 B 3.5.2-13 B 3.5.3-5 B 3.6.4.3-7 B 3.7.4-8

ECCSOperating B 3.5.1 Dresden 2 and 3 B 3.5.1-16 Revision 61 BASES SURVEILLANCE SR 3.5.1.8 (continued)

REQUIREMENTS positions. This SR also ensures that the HPCI System will automatically restart on an RPV lowlow water level signal received subsequent to an RPV high water level trip and that the HPCI suction is automatically transferred from the CCST to the suppression pool on high suppression pool water level or low CCST water level. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

SR 3.5.1.9 The ADS designated valves are required to actuate automatically upon receipt of specific initiation signals.

A system functional test is performed to demonstrate that the mechanical portions of the ADS function (i.e.,

solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components. SR 3.5.1.10 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes valve actuation since the valves are individually tested in accordance with SR 3.5.1.10.

(continued)

INSERT NOTE A

RPV Water Inventory Control B 3.5.2 Dresden 2 and 3 B 3.5.2-12 Revision 82 BASES SURVEILLANCE SR 3.5.2.4 REQUIREMENTS (continued)

Verifying that the required ECCS injection/spray subsystem can be manually started and operated for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. This SR is modified by two Notes. Note 1 acknowledges that testing of the ECCS injection/spray subsystem through the full flow test return line is necessary to avoid overfilling the refueling cavity and adequate to confirm the operational readiness of the required ECCS injection/spray subsystem. Note 2 states that credit for meeting this SR may be taken for normal system operation to satisfy this SR. The minimum operating time of 10 minutes is based on engineering judgement.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.5 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur. The Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

Operating experience has shown these components usually pass the Surveillance when performed at the selected Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

INSERT NOTE A

RPV Water Inventory Control B 3.5.2 Dresden 2 and 3 B 3.5.2-13 Revision 82 BASES SURVEILLANCE SR 3.5.2.6 REQUIREMENTS (continued)

The required ECCS subsystem shall be capable of being manually operated. This Surveillance verifies that the required CS or LPCI subsystem (including the associated pump and valve(s)) can be manually operated to provide additional RPV Water Inventory, if needed.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable, and full flow can be demonstrated by recirculation through the full flow test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES

1.

Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup," November 1984.

2.

Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3.

Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f), " August 1992.

4.

NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs,"

May 1993.

5.

Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1,"

July 1994.

6.

General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6," February 1983.

INSERT NOTE A

IC System B 3.5.3 Dresden 2 and 3 B 3.5.3-5 Revision 75 BASES SURVEILLANCE SR 3.5.3.2 REQUIREMENTS (continued)

Verifying the correct alignment for manual, power operated, and automatic valves in the IC flow path provides assurance that the proper flow path will exist for IC operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.3.3 The IC System is required to actuate automatically in order to verify its design function satisfactorily. This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of the IC System will cause the system to operate as designed; that is, actuation of all automatic valves to their required positions. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.3 overlaps this Surveillance to provide complete testing of the assumed design function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

INSERT NOTE A

SGT System B 3.6.4.3 Dresden 2 and 3 B 3.6.4.3-7 Revision 75 BASES SURVEILLANCE SR 3.6.4.3.2 REQUIREMENTS (continued)

This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The SGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 5). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.6.4.3.3 This SR verifies that each SGT subsystem starts on receipt of an actual or simulated initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation," overlaps this SR to provide complete testing of the safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

UFSAR, Section 3.1.2.4.12.

2.

UFSAR, Section 6.5.3.2.

3.

UFSAR, Section 15.6.5.

4.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

5.

Regulatory Guide 1.52, Rev. 2.

INSERT NOTE A

CREV System B 3.7.4 Dresden 2 and 3 B 3.7.4-8 Revision 58 BASES (continued)

SURVEILLANCE SR 3.7.4.1 REQUIREMENTS This SR verifies that the CREV System in a standby mode starts from the control room and continues to operate. This SR includes initiating flow through the HEPA filters and charcoal adsorbers. Standby systems should be checked periodically to ensure that they start and function properly. Operation with the heaters on for > 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that heater failure, blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.4.2 This SR verifies that the required CREV testing is performed in accordance with Specification 5.5.7, "Ventilation Filter Testing Program (VFTP)." The CREV filter tests are in accordance with Regulatory Guide 1.52 (Ref. 4). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test Frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.4.3 This SR verifies that on a manual initiation from the control room, the CREV System filter train starts and the isolation dampers close. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.4.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

(continued)

INSERT NOTE A f

Revised Technical Specification Bases Changes (Information Only)

James A. FitzPatrick Nuclear Power Plant Unit 1 Facility Operating License No. DPR 59 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3.5.1-16 B 3.5.2-9 B 3.5.3-7 B 3.6.4.3-5 B 3.7.2-5

ECCS Operating B 3.5.1 BASES JAFNPP B 3.5.1-16 Revision 38 SURVEILLANCE SR 3.5.1.10 (continued)

REQUIREMENTS transferred from the CSTs to the suppression pool on high suppression pool water level or low CST water level. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by two Notes. Note 1 states that for the HPCI System, the Surveillance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the reactor steam pressure and flow are adequate to perform the test. The 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed for performing the actual or simulated automatic actuation for the HPCI System after the required pressure and flow are reached is sufficient to achieve stable conditions for testing and provides reasonable time to complete the SR. Note 2 excludes vessel injection/spray during the Surveillance.

Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

SR 3.5.1.11 The ADS designated S/RVs are required to actuate automatically upon receipt of specific initiation signals. A system functional test is performed to demonstrate that the mechanical portions of the ADS function (i.e., solenoids) operate as designed when initiated either by (continued)

INSERT NOTE A

RPV Water Inventory Control B 3.5.2 BASES JAFNPP B 3.5.2-9 Revision 38 SR 3.5.2.6 Verifying that the required ECCS injection/spray subsystem can be manually started and operate for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. Testing the ECCS injection/spray subsystem through the recirculation line is necessary to avoid overfilling the refueling cavity. The minimum operating time of 10 minutes was based on engineering judgement.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.7 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.8 The required ECCS injection/spray subsystem shall be capable of being manually operated from the Control Room. This Surveillance verifies that the required CS or LPCI subsystem (including the associated pump and valve(s)) can be manually operated to provide additional RPV water inventory, if needed.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

(continued)

SURVEILLANCE REQUIREMENTS (continued)

INSERT NOTE A INSERT NOTE A

RCIC System B 3.5.3 BASES JAFNPP B 3.5.3-7 Revision 38 SURVEILLANCE SR 3.5.3.5 (continued)

REQUIREMENTS automatic initiation logic of the RCIC System will cause the system to operate as designed, including actuation of the system throughout its emergency operating sequence; that is, automatic pump startup and actuation of all automatic valves to their required positions. This test also ensures the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) signal (Level 8 signal closes RCIC steam inlet valve, and subsequent Level 2 signal will re-open valve) and that the suction is automatically transferred from the CST to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.2 overlaps this Surveillance to provide complete testing of the assumed design function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by Note 1 that says the Surveillance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the reactor steam pressure and flow are adequate to perform the test. The time allowed for this test after required pressure and flow are reached is sufficient to achieve stable conditions for testing and provides a reasonable time to complete the SR. Adequate reactor pressure must be available to perform this test. Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the RCIC System diverts steam flow. Thus, sufficient time is allowed after adequate pressure and flow are achieved to perform this test. Adequate reactor steam pressure is > 150 psig. Adequate steam flow is represented by at least one turbine bypass valve open. Reactor startup is allowed prior to performing this test because the reactor pressure is low and the time allowed to satisfactorily perform the test is short.

This SR is modified by Note 2 that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

(continued)

INSERT NOTE A

SGT System B 3.6.4.3 BASES JAFNPP B 3.6.4.3-5 Revision 41 SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 Operating each SGT subsystem fan for 15 continuous minutes ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.4.3.2 This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.6.4.3.3 This SR verifies that each SGT subsystem starts on receipt of an actual or simulated initiation signal. In addition, the OPERABILITY of each SGT decay heat cooling valve is verified to ensure the valve closes on subsystem initiation (interlocked with the suction valve) and opens when shutdown. This will ensure the mitigation function as well as the decay heat cooling mode of each SGT subsystem is available.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.4.3.4 This SR verifies that the filter cooling cross-tie valves are OPERABLE.

This ensures that the decay heat cooling mode of SGT System operation is available. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 16.6.

2.

UFSAR, Section 5.3.3.4.

3.

UFSAR, Section 14.6.

4.

10 CFR 50.36(c)(2)(ii).

(continued)

INSERT NOTE A

ESW System and UHS B 3.7.2 BASES JAFNPP B 3.7.2-5 Revision 43 SR 3.7.2.3 (continued) the nonaccident position, and yet considered in the correct position, provided it can be automatically realigned to its accident position within the required time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

This SR is modified by a Note indicating that isolation of the ESW System to components or systems may render those components or systems inoperable, but does not necessarily affect the OPERABILITY of the ESW System. As such, when all ESW pumps, valves, and piping are OPERABLE, but a branch connection off the main header is isolated, the ESW System may still be considered OPERABLE.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.2.4 This SR verifies the automatic start capability of the ESW pump in each subsystem. This is demonstrated by the use of an actual or simulated initiation signal associated with each EDG. In addition, the proper positioning of the ESW supply header isolation valves and the ESW minimum flow valves, upon actual or simulated ESW lockout matrix logic actuation, must be demonstrated in this SR. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.7.3 overlaps this Surveillance to provide complete testing of the assumed safety function. ESW will not be supplied to the Reactor Building Closed Loop Cooling System during the performance of this test to avoid contaminating this system with lake water.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 9.7.1.

2.

UFSAR, Chapter 5.

3.

UFSAR, Chapter 14.

4.

10 CFR 50.36(c)(2)(ii).

SURVEILLANCE REQUIREMENTS INSERT NOTE A g

Revised Technical Specification Bases Changes (Information Only)

LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF 11 and NPF 18 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3.5.1-13 B 3.5.2-11 B 3.5.2-12 B 3.5.3-7 B 3.5.6.3-6 B 3.7.4-10

ECCSOperating B 3.5.1 LaSalle 1 and 2 B 3.5.1-13 Revision 70 BASES SURVEILLANCE SR 3.5.1.5 (continued)

REQUIREMENTS flow rates required by the respective analyses. The ECCS pump flow rates ensure that adequate core cooling is provided to satisfy the acceptance criteria of 10 CFR 50.46 (Ref. 10).

The pump flow rates are verified against a test line pressure that was determined during preoperational testing to be equivalent to the RPV pressure expected during a LOCA.

Under these conditions, the total system pump outlet pressure is adequate to overcome the elevation head pressure between the pump suction and the vessel discharge, the piping friction losses, and RPV pressure present during LOCAs. The Frequency for this Surveillance is in accordance with the INSERVICE TESTING PROGRAM requirements.

SR 3.5.1.6 The ECCS subsystems are required to actuate automatically to perform their design functions. This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCS, LPCS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup, and actuation of all automatic valves to their required position. This Surveillance also ensures that the HPCS System injection valve will automatically reopen on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) injection valve closure signal. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

(continued)

INSERT NOTE A

RPV Water Inventory Control B 3.5.2 LaSalle 1 and 2 B 3.5.2-11 Revision 76 BASES SURVEILLANCE SR 3.5.2.5 (continued)

REQUIREMENTS The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

SR 3.5.2.6 Verifying that the required ECCS injection/spray subsystem can be manually started and operate for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. Testing the ECCS injection/spray subsystem through the full flow test recirculation line is adequate to confirm the operational readiness of the required ECCS injection/spray subsystem. The minimum operating time of 10 minutes was based on engineering judgement.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.7 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

INSERT NOTE A

RPV Water Inventory Control B 3.5.2 LaSalle 1 and 2 B 3.5.2-12 Revision 76 BASES SURVEILLANCE SR 3.5.2.8 REQUIREMENTS (continued)

The required ECCS subsystem shall be capable of being manually operated from the main control room. This Surveillance verifies that the required LCPI subsystem, LPCS System, or HPCS System (including the associated pump and valve(s)) can be manually operated, including throttling injection valves, as necessary, to provide additional RPV Water Inventory, if needed, without delay.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the full flow test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES 1.

Information Notice 84-81, "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup," November 1984.

2.

Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3.

Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f)," August 1992.

4.

NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs,"

May 1993.

5.

Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1,"

July 1994.

6.

General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6," February 1983.

INSERT NOTE A

RCIC System B 3.5.3 LaSalle 1 and 2 B 3.5.3-7 Revision 83 BASES SURVEILLANCE SR 3.5.3.3 and SR 3.5.3.4 (continued)

REQUIREMENTS Notes that state the Surveillances are not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the reactor steam pressure and flow are adequate to perform the test. The 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed for the flow tests after the required pressure and flow are reached are sufficient to achieve stable conditions for testing and provides a reasonable time to complete the SRs. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.3.5 The RCIC System is required to actuate automatically to perform its design function. This Surveillance verifies that with a required system initiation signal (actual or simulated) the automatic initiation logic of RCIC will cause the system to operate as designed, i.e., actuation of the system throughout its emergency operating sequence, which includes automatic pump startup and actuation of all automatic valves to their required positions. This Surveillance also ensures that the RCIC System will automatically restart on an actual or simulated RPV low water level (Level 2) signal received subsequent to an actual or simulated RPV high water level (Level 8) shutdown signal, and that the suction is automatically transferred from the CST to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.3 overlaps this Surveillance to provide complete testing of the assumed design function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

(continued)

INSERT NOTE A

SGT System B 3.6.4.3 LaSalle 1 and 2 B 3.6.4.3-6 Revision 76 BASES SURVEILLANCE SR 3.6.4.3.3 REQUIREMENTS (continued)

This SR requires verification that each SGT subsystem starts upon receipt of an actual or simulated initiation signal.

The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation," overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

10 CFR 50, Appendix A, GDC 41.

2.

UFSAR, Section 6.5.1.

3.

UFSAR, Section 15.6.5.

4.

UFSAR, Section 15.7.4 5.

NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants," December 2002.

6.

ANSI/ASME N510-1989.

INSERT NOTE A

CRAF System B 3.7.4 LaSalle 1 and 2 B 3.7.4-10 Revision 51 BASES SURVEILLANCE SR 3.7.4.4 (continued)

REQUIREMENTS signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.4 overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.4.5 This SR verifies the OPERBILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke.

This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rates assumed in the licensing basis analyses of DBA consequences. When the unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3 (Ref.

8), which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 9). These compensatory measures may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 10).

Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

(continued)

INSERT NOTE A h

Revised Technical Specification Bases Changes (Information Only)

Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF 39 and NPF 85 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3/4 5-3 B 3/4 5-3e B 3/4 6-5a B 3/4 6-6 B 3/4 7-1 B 3/4 7-1d

EMERGENCY CORE COOLING SYSTEM BASES ECCS - OPERATING (Continued) subsystem locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g.,

operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

Surveillance 4.5.1.a.1.b is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

Upon failure of the HPCI system to function properly after a small break loss-of-coolant accident, the automatic depressurization system (ADS) automa-tically causes selected safety/relief valves to open, depressurizing the reactor so that flow from the low pressure core cooling systems can enter the core in time to limit fuel cladding temperature to less than 2200°F. ADS is conserva-tively required to be OPERABLE whenever reactor vessel pressure exceeds 100 psig.

This pressure is substantially below that for which the low pressure core cool-ing systems can provide adequate core cooling for events requiring ADS.

ADS automatically controls five selected safety-relief valves. The safety analysis assumes all five are operable. The allowed out-of-service time for one valve for up to fourteen days is determined in a similar manner to other ECCS subsystem out-of-service time allowances. Alternatively, the allowed out-of-service time can be determined in accordance with the Risk Informed Completion Time Program.

Verification that ADS accumulator gas supply header pressure is 90 psig ensures adequate gas pressure for reliable ADS operation. The accumulator on each ADS valve provides pneumatic pressure for valve actuation. The design pneumatic supply pressure requirements for the accumulator are such that, following a failure of the pneumatic supply to the accumulator at least two valve actuations can occur with the drywell at 70% of design pressure. The ECCS safety analysis assumes only one actuation to achieve the depressurization required for operation of the low pressure ECCS. This minimum required pressure of 90 psig is provided by the PCIG supply.

LIMERICK - UNIT 1 B 3/4 5-3 Amendment No. 8/10/94 Ltr,94,152,169,

186, Associated with Amendment No. 216,227,240 INSERT NOTE B

EMERGENCY CORE COOLING SYSTEM BASES RPV WATER INVENTORY CONTROL (WIC) (Continued)

The exclusion of a single penetration flow path, or multiple penetration flow paths susceptible to a common mode failure, from the determination of DRAIN TIME should consider the effects of temporary alterations in support of maintenance (rigging, scaffolding, temporary shielding, piping plugs, freeze seals, etc.). If reasonable controls are implemented to prevent such temporary alterations from causing a draining event from a closed system or between the RPV and the isolation device, the effect of the temporary alterations on DRAIN TIME need not be considered. Reasonable controls include, but are not limited to, controls consistent with the guidance in NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4, NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, or commitments to NUREG-0612, Control of Heavy Loads at Nuclear Power Plants.

TS 4.0.1 requires SRs to be met between performances. Therefore, any changes in plant conditions that would change the DRAIN TIME requires that a new DRAIN TIME be determined.

SRs 4.5.2.2 and 4.5.2.3 - The minimum water level of 16 feet required for the suppression pool is periodically verified to ensure that the suppression pool will provide adequate net positive suction head (NPSH) for the CSS subsystem or LPCI subsystem pumps, recirculation volume, and vortex prevention. With the suppression pool water level less than the required limit, the required ECCS injection/spray subsystem is inoperable unless aligned to an OPERABLE CST.

The required CSS subsystem is OPERABLE if it can take suction from the CST, and the CST water level is sufficient to provide the required NPSH for the CSS pumps.

Therefore, a verification that either the suppression pool water level is greater than or equal to 16 feet 0 inches or that a CSS subsystem is aligned to take suction from the CST and the CST contains greater than or equal to 135,000 available gallons of water, equivalent to a level of 29 feet 0 inches, ensures that the CSS subsystem can supply the required makeup water to the RPV.

SR 4.5.2.4 - The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the required ECCS injection/spray subsystems full of water ensures that the ECCS subsystem will perform properly. This may also prevent a water hammer following an ECCS actuation. One acceptable method of ensuring that the lines are full is to vent at the high points.

SR 4.5.2.5 - DELETED SR 4.5.2.6 - Verifying that the required ECCS injection/spray subsystem can be manually aligned, and the pump started and operate for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. This surveillance requirement is modified by two footnotes. The first states that testing the ECCS injection/spray subsystem may be done through the test return line to avoid overfilling the refueling cavity. The second states that credit for meeting the surveillance requirement may be taken for normal system operation that satisfies the surveillance requirement, such as using the RHR mode of LPCI for greater than or equal to 10 minutes. The minimum operating time of 10 minutes was based on engineering judgement.

SR 4.5.2.7 - Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

LIMERICK - UNIT 1 B 3/4 5-3e Associated with Amendment No. 227, 252 INSERT NOTE C

CONTAINMENT SYSTEMS BASES SECONDARY CONTAINMENT (Continued)

Surveillances 4.6.5.1.1.a and 4.6.5.1.2.a are each modified by a footnote (*)

which states the surveillance is not required to be met for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months if an analysis demonstrates that one standby gas treatment subsystem remains capable of establishing the required secondary containment vacuum. Use of the footnote is expected to be infrequent but may be necessitated by situations in which secondary containment vacuum may be less than the required containment vacuum, such as, but not limited to, wind gusts or failure or change of operating normal ventilation subsystems. These conditions do not indicate any change in the leak tightness of the secondary containment boundary. The analysis should consider the actual conditions (equipment configuration, temperature, atmospheric pressure, wind conditions, measured secondary containment vacuum, etc.) to determine whether, if an accident requiring secondary containment to be OPERABLE were to occur, one train of standby gas treatment could establish the assumed secondary containment vacuum within the time assumed in the accident analysis. If so, the surveillance may be considered met for a period up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 4-hour limit is based on the expected short duration of the situations when the footnote would be applied.

Surveillances 4.6.5.1.1.b.2 and 4.6.5.1.2.b.2 require verifying that one secondary containment personnel access door in each access opening is closed which provides adequate assurance that exfiltration from the secondary containment will not occur. An access opening contains at least one inner and one outer door. The intent is to not breach the secondary containment, which is achieved by maintaining the inner or outer personnel access door closed.

Surveillances 4.6.5.1.1.b.2 and 4.6.5.1.2.b.2 provide an allowance for brief, inadvertent, simultaneous openings of redundant secondary containment personnel access doors for normal entry and exit conditions.

Although the safety analyses assumes that the reactor enclosure secondary containment draw down time will take 930 seconds, these surveillance require-ments specify a draw down time of 916 seconds. This 14 second difference is due to the diesel generator starting and sequence loading delays which is not part of this surveillance requirement.

The reactor enclosure secondary containment draw down time analyses assumes a starting point of 0.25 inch of vacuum water gauge and worst case SGTS dirty filter flow rate of 2800 cfm. The surveillance requirements satisfy this as-sumption by starting the drawdown from ambient conditions and connecting the adjacent reactor enclosure and refueling area to the SGTS to split the exhaust flow between the three zones and verifying a minimum flow rate of 2800 cfm from the test zone. This simulates the worst case flow alignment and verifies ade-quate flow is available to drawdown the test zone within the required time. The Technical Specification Surveillance Requirement 4.6.5.3.b.3 is intended to be a multi-zone air balance verification without isolating any test zone.

LIMERICK - UNIT 1 B 3/4 6-5a Amendment No. 6,40,71,106,122, 185,186, ECR LG 09-00052, Associated with Amendment 220, 229 INSERT NOTE D

CONTAINMENT SYSTEMS BASES 3/4.6.5 SECONDARY CONTAINMENT (Continued)

The field tests for bypass leakage across the SGTS charcoal adsorber and HEPA filter banks are performed at a flow rate of 5764 +/- 10% cfm. The laboratory analysis performed on the SGTS carbon samples will be tested at a velocity of 66 fpm based on the system residence time.

The SGTS filter train pressure drop is a function of air flow rate and filter conditions. Surveillance testing is performed using either the SGTS or drywell purge fans to provide operating convenience.

Each reactor enclosure secondary containment zone and refueling area secondary containment zone is tested independently to verify the design leak tightness. A design leak tightness of 2500 cfm or less for each reactor enclosure and 764 cfm or less for the refueling area at a 0.25 inch of vacuum water gage will ensure that containment integrity is maintained at an acceptable level if all zones are connected to the SGTS at the same time.

The Reactor Enclosure Secondary Containment Automatic Isolation Valves and Refueling Area Secondary Containment Automatic Isolation Valves can be found in the UFSAR.

The post-LOCA offsite dose analysis assumes a reactor enclosure secondary containment post-draw down leakage rate of 2500 cfm and certain post-accident X/Q values. While the post-accident X/Q values represent a statistical inter-pretation of historical meteorological data, the highest ground level wind speed which can be associated with these values is 7 mph (Pasquill-Gifford stability Class G for a ground level release). Therefore, the surveillance requirement assures that the reactor enclosure secondary containment is verified under meteorological conditions consistent with the assumptions utilized in the design basis analysis. Reactor Enclosure Secondary Containment leakage tests that are successfully performed at wind speeds in excess of 7 mph would also satisfy the leak rate surveillance requirements, since it shows compliance with more conservative test conditions.

3/4.6.6 PRIMARY CONTAINMENT ATMOSPHERE CONTROL The primary containment atmospheric mixing system is provided to ensure adequate mixing of the containment atmosphere to prevent localized accumulations of hydrogen and oxygen from exceeding the lower flammability limit during post-LOCA conditions.

All nuclear reactors must be designed to withstand events that generate hydrogen either due to the zirconium metal water reaction in the core or due to radiolysis. The primary method to control hydrogen is to inert the primary containment. With the primary containment inert, that is, oxygen concentration 4.0 volume percent (v/o), a combustible mixture cannot be present in the primary containment for any hydrogen concentration. The capability to inert the primary containment and maintain oxygen 4.0 v/o works together with Drywell Hydrogen Mixing System to provide redundant and diverse methods to mitigate events that produce hydrogen.

LIMERICK - UNIT 1 B 3/4 6-6 Amendment No. 8, 105, 122, ECR 00-00132, 173 INSERT NOTE E

3/4.7 PLANT SYSTEMS BASES 3/4.7.1 SERVICE WATER SYSTEMS - COMMON SYSTEMS The OPERABILITY of the service water systems ensures that sufficient cooling capacity is available for continued operation of safety-related equipment during normal and accident conditions. The redundant cooling capacity of these systems, assuming a single failure, is consistent with the assumptions used in the accident conditions within acceptable limits.

The RHR and ESW systems are common to Units 1 and 2 and consist of two independent subsystems each with two pumps. One pump per subsystem (loop) is powered from a Unit 1 safeguard bus and the other pump is powered from a Unit 2 safeguard bus. In order to ensure adequate onsite power sources to the systems during a loss of offsite power event, the inoperability of these supplies are restricted in system ACTION statements.

RHRSW is a manually operated system used for core and containment heat removal. Each of two RHRSW subsystems has one heat exchanger per unit. Each RHRSW pump provides adequate cooling for one RHR heat exchanger. By limiting operation with less than three OPERABLE RHRSW pumps with OPERABLE Diesel Generators, each unit is ensured adequate heat removal capability for the design scenario of LOCA/LOOP on one unit and simultaneous safe shutdown of the other unit.

Each ESW pump provides adequate flow to the cooling loads in its associated loop. With only two divisions of power required for LOCA mitigation of one unit and one division of power required for safe shutdown of the other unit, one ESW pump provides sufficient capacity to fulfill design requirements. ESW pumps are automatically started upon start of the associated Diesel Generators. Therefore, the allowable out of service times for OPERABLE ESW pumps and their associated Diesel Generators is limited to ensure adequate cooling during a loss of offsite power event. Alternatively, the allowable out-of-service times can be determined in accordance with the Risk Informed Completion Time Program.

LIMERICK - UNIT 1 B 3/4 7-1 Amendment No. 27, Associated with Amendment 240 INSERT NOTE F

PLANT SYSTEMS BASES 3/4.7.3 REACTOR CORE ISOLATION COOLING SYSTEM (Continued)

The RCIC System flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required RCIC System and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RCIC System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RCIC System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RCIC System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

Surveillance 4.7.3.a.2 is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

LIMERICK - UNIT 1 B 3/4 7-1d Associated with Amendment 216 INSERT NOTE G

EMERGENCY CORE COOLING SYSTEM BASES ECCS - OPERATING (Continued)

ECCS injection/spray subsystem locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

Surveillance 4.5.1.a.1.b is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

Upon failure of the HPCI system to function properly after a small break loss-of-coolant accident, the automatic depressurization system (ADS) automa-tically causes selected safety/relief valves to open, depressurizing the reactor so that flow from the low pressure core cooling systems can enter the core in time to limit fuel cladding temperature to less than 2200°F. ADS is conserva-tively required to be OPERABLE whenever reactor vessel pressure exceeds 100 psig.

This pressure is substantially below that for which the low pressure core cool-ing systems can provide adequate core cooling for events requiring ADS.

ADS automatically controls five selected safety-relief valves. The safety analysis assumes all five are operable. The allowed out-of-service time for one valve for up to fourteen days is determined in a similar manner to other ECCS subsystem out-of-service time allowances. Alternatively, the allowed out-of-service time can be determined in accordance with the Risk Informed Completion Time Program.

Verification that ADS accumulator gas supply header pressure is 90 psig ensures adequate gas pressure for reliable ADS operation. The accumulator on each ADS valve provides pneumatic pressure for valve actuation. The design pneumatic supply pressure requirements for the accumulator are such that, following a failure of the pneumatic supply to the accumulator at least two valve actuations can occur with the drywell at 70% of design pressure. The ECCS safety analysis assumes only one actuation to achieve the depressurization required for operation of the low pressure ECCS. This minimum required pressure of 90 psig is provided by the PCIG supply.

LIMERICK - UNIT 2 B 3/4 5-3 Amendment No. 8/10/94 Ltr, 58, 116, 132, 147, Associated with Amendment No. 178,190,203 INSERT NOTE B

EMERGENCY CORE COOLING SYSTEM BASES RPV WATER INVENTORY CONTROL (WIC) (Continued)

The exclusion of a single penetration flow path, or multiple penetration flow paths susceptible to a common mode failure, from the determination of DRAIN TIME should consider the effects of temporary alterations in support of maintenance (rigging, scaffolding, temporary shielding, piping plugs, freeze seals, etc.). If reasonable controls are implemented to prevent such temporary alterations from causing a draining event from a closed system or between the RPV and the isolation device, the effect of the temporary alterations on DRAIN TIME need not be considered. Reasonable controls include, but are not limited to, controls consistent with the guidance in NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4, NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, or commitments to NUREG-0612, Control of Heavy Loads at Nuclear Power Plants.

TS 4.0.1 requires SRs to be met between performances. Therefore, any changes in plant conditions that would change the DRAIN TIME requires that a new DRAIN TIME be determined.

SRs 4.5.2.2 and 4.5.2.3 - The minimum water level of 16 feet required for the suppression pool is periodically verified to ensure that the suppression pool will provide adequate net positive suction head (NPSH) for the CSS subsystem or LPCI subsystem pumps, recirculation volume, and vortex prevention. With the suppression pool water level less than the required limit, the required ECCS injection/spray subsystem is inoperable unless aligned to an OPERABLE CST.

The required CSS subsystem is OPERABLE if it can take suction from the CST, and the CST water level is sufficient to provide the required NPSH for the CSS pumps. Therefore, a verification that either the suppression pool water level is greater than or equal to 16 feet 0 inches or that a CSS subsystem is aligned to take suction from the CST and the CST contains greater than or equal to 135,000 available gallons of water, equivalent to a level of 29 feet 0 inches, ensures that the CSS subsystem can supply the required makeup water to the RPV.

SR 4.5.2.4 - The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the required ECCS injection/spray subsystems full of water ensures that the ECCS subsystem will perform properly. This may also prevent a water hammer following an ECCS actuation.

One acceptable method of ensuring that the lines are full is to vent at the high points.

SR 4.5.2.5 - DELETED SR 4.5.2.6 - Verifying that the required ECCS injection/spray subsystem can be manually aligned, and the pump started and operated for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. This surveillance requirement is modified by two footnotes. The first states that testing the ECCS injection/spray subsystem may be done through the test return line to avoid overfilling the refueling cavity. The second states that credit for meeting the surveillance requirement may be taken for normal system operation that satisfies the surveillance requirement, such as using the RHR mode of LPCI for greater than or equal to 10 minutes. The minimum operating time of 10 minutes was based on engineering judgement.

SR 4.5.2.7 - Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

LIMERICK - UNIT 2 B 3/4 5-3e Associated with Amendment No. 190, 214 INSERT NOTE C

CONTAINMENT SYSTEMS BASES SECONDARY CONTAINMENT (Continued)

Surveillances 4.6.5.1.1.a and 4.6.5.1.2.a are each modified by a footnote (*)

which states the surveillance is not required to be met for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months if an analysis demonstrates that one standby gas treatment subsystem remains capable of establishing the required secondary containment vacuum. Use of the footnote is expected to be infrequent but may be necessitated by situations in which secondary containment vacuum may be less than the required containment vacuum, such as, but not limited to, wind gusts or failure or change of operating normal ventilation subsystems. These conditions do not indicate any change in the leak tightness of the secondary containment boundary. The analysis should consider the actual conditions (equipment configuration, temperature, atmospheric pressure, wind conditions, measured secondary containment vacuum, etc.) to determine whether, if an accident requiring secondary containment to be OPERABLE were to occur, one train of standby gas treatment could establish the assumed secondary containment vacuum within the time assumed in the accident analysis. If so, the surveillance may be considered met for a period up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 4-hour limit is based on the expected short duration of the situations when the footnote would be applied.

Surveillances 4.6.5.1.1.b.2 and 4.6.5.1.2.b.2 require verifying that one secondary containment personnel access door in each access opening is closed which provides adequate assurance that exfiltration from the secondary containment will not occur. An access opening contains at least one inner and one outer door. The intent is to not breach the secondary containment, which is achieved by maintaining the inner or outer personnel access door closed. Surveillances 4.6.5.1.1.b.2 and 4.6.5.1.2.b.2 provide an allowance for brief, inadvertent, simultaneous openings of redundant secondary containment personnel access doors for normal entry and exit conditions.

Although the safety analyses assumes that the reactor enclosure secondary containment draw down time will take 930 seconds, these surveillance require-ments specify a draw down time of 916 seconds. This 14 second difference is due to the diesel generator starting and sequence loading delays which is not part of this surveillance requirement.

The reactor enclosure secondary containment draw down time analyses assumes a starting point of 0.25 inch of vacuum water gauge and worst case SGTS dirty filter flow rate of 2800 cfm. The surveillance requirements satisfy this as-sumption by starting the drawdown from ambient conditions and connecting the adjacent reactor enclosure and refueling area to the SGTS to split the exhaust flow between the three zones and verifying a minimum flow rate of 2800 cfm from the test zone. This simulates the worst case flow alignment and verifies ade-quate flow is available to drawdown the test zone within the required time.

The Technical Specification Surveillance Requirement 4.6.5.3.b.3 is intended to be a multi-zone air balance verification without isolating any test zone.

The SGTS is common to Unit 1 and 2 and consists of two independent subsystems. The power supplies for the common portions of the subsystems are from Unit 1 safeguard busses, therefore the inoperability of these Unit 1 supplies are addressed in the SGTS ACTION statements in order to ensure adequate onsite power sources to SGTS for its Unit 2 function during a loss of offsite power event. The allowable out of service times are consistent with those in the Unit 1 Technical Specifications for SGTS and AC electrical power supply out of service condition combinations.

LIMERICK - UNIT 2 B 3/4 6-5a Amendment No. 34,51,86,146,147, ECR LG 09-00052, Associated with Amendment 182, 192 INSERT NOTE D

CONTAINMENT SYSTEMS BASES SECONDARY CONTAINMENT (Continued)

The SGTS fans are sized for three zones and therefore, when aligned to a single zone or two zones, will have excess capacity to more quickly drawdown the affected zones. There is no maximum flow limit to individual zones or pairs of zones and the air balance and drawdown time are verified when all three zones are connected to the SGTS.

The three zone air balance verification and drawdown test will be done after any major system alteration, which is any modification which will have an effect on the SGTS flowrate such that the ability of the SGTS to drawdown the reactor enclosure to greater than or equal to 0.25 inch of vacuum water gage in less than or equal to 916 seconds could be affected.

The field tests for bypass leakage across the SGTS charcoal adsorber and HEPA filter banks are performed at a flow rate of 5764 +/- 10% cfm. The laboratory analysis performed on the SGTS carbon samples will be tested at a velocity of 66 fpm based on the system residence time.

The SGTS filter train pressure drop is a function of air flow rate and filter conditions. Surveillance testing is performed using either the SGTS or drywell purge fans to provide operating convenience.

Each reactor enclosure secondary containment zone and refueling area secondary containment zone is tested independently to verify the design leak tightness. A design leak tightness of 2500 cfm or less for each reactor enclosure and 764 cfm or less for the refueling area at a 0.25 inch of vacuum water gage will ensure that containment integrity is maintained at an acceptable level if all zones are connected to the SGTS at the same time.

The Reactor Enclosure Secondary Containment Automatic Isolation Valves and Refueling Area Secondary Containment Automatic Isolation Valves can be found in the UFSAR.

The post-LOCA offsite dose analysis assumes a reactor enclosure secondary containment post-draw down leakage rate of 2500 cfm and certain post-accident X/Q values. While the post-accident X/Q values represent a statistical inter-pretation of historical meteorological data, the highest ground level wind speed which can be associated with these values is 7 mph (Pasquill-Gifford stability Class G for a ground level release). Therefore, the surveillance requirement assures that the reactor enclosure secondary containment is verified under meteorological conditions consistent with the assumptions utilized in the design basis analysis. Reactor Enclosure Secondary Containment leakage tests that are successfully performed at wind speeds in excess of 7 mph would also satisfy the leak rate surveillance requirements, since it shows compliance with more conservative test conditions.

LIMERICK - UNIT 2 B 3/4 6-6 Amendment No. 51, 69, 86 INSERT NOTE E

3/4.7 PLANT SYSTEMS BASES 3/4.7.1 SERVICE WATER SYSTEMS - COMMON SYSTEMS The OPERABILITY of the service water systems ensures that sufficient cooling capacity is available for continued operation of safety-related equipment during normal and accident conditions. The redundant cooling capacity of these systems, assuming a single failure, is consistent with the assumptions used in the accident conditions within acceptable limits.

The RHRSW and ESW systems are common to Units 1 and 2 and consist of two independent subsystems each with two pumps. One pump per subsystem (loop) is powered from a Unit 1 safeguard bus and the other pump is powered from a Unit 2 safeguard bus. In order to ensure adequate onsite power sources to the systems during a loss of offsite power event, the inoperability of these supplies are restricted in system ACTION statements.

RHRSW is a manually operated system used for core and containment heat removal. Each of two RHRSW subsystems has one heat exchanger per unit. Each RHRSW pump provides adequate cooling for one RHR heat exchanger. By limiting operation with less than three OPERABLE RHRSW pumps with OPERABLE Diesel Generators, each unit is ensured adequate heat removal capability for the design scenario of LOCA/LOOP on one unit and simultaneous safe shutdown of the other unit.

Each ESW pump provides adequate flow to the cooling loads in its associated loop. With only two divisions of power required for LOCA mitigation of one unit and one division of power required for safe shutdown of the other unit, one ESW pump provides sufficient capacity to fulfill design requirements. ESW pumps are automatically started upon start of the associated Diesel Generators.

Therefore, the allowable out of service times for OPERABLE ESW pumps and their associated Diesel Generators is limited to ensure adequate cooling during a loss of offsite power event. Alternatively, the allowable out-of-service times can be determined in accordance with the Risk Informed Completion Time Program.

3/4.7.2 CONTROL ROOM EMERGENCY FRESH AIR SUPPLY SYSTEM - COMMON SYSTEM The OPERABILITY of the control room emergency fresh air supply system ensures that the control room will remain habitable for occupants during and following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

Constant purge of the system at 1 cfm is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters. The OPERABILITY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 rem or less Total Effective Dose Equivalent. This limitation is consistent with the requirements of 10 CFR Part 50.67, Accident Source Term.

Since the Control Room Emergency Fresh Air Supply System is not credited for filtration in OPERATIONAL CONDITIONS 4 and 5, applicability to 4 and 5 is only required to support the Chlorine and Toxic Gas design basis isolation requirements.

The CREFAS is common to Units 1 and 2 and consists of two independent subsystems. The power supplies for the system are from Unit 1 Safeguard busses, therefore, the inoperability of these Unit 1 supplies are addressed in the CREFAS ACTION statements in order to ensure adequate onsite power sources to CREFAS during a loss of offsite power event. The allowable out of service LIMERICK - UNIT 2 B 3/4 7-1 Amendment No. 146,149, Associated with Amendment 203 INSERT NOTE F

PLANT SYSTEMS BASES 3/4.7.3 REACTOR CORE ISOLATION COOLING SYSTEM (Continued)

The RCIC System flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required RCIC System and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RCIC System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RCIC System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RCIC System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

Surveillance 4.7.3.a.2 is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

LIMERICK - UNIT 2 B 3/4 7-1d Associated with Amendment No. 178 INSERT NOTE G i

Revised Technical Specification Bases Changes (Information Only)

Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3.5.1-13 B 3.5.2-9 B 3.5.3-7 B 3.6.4.3-5 B 3.7.1-11 B 3.7.2-8

ECCS - Operating B 3.5.1 NMP2 B 3.5.1-13 Revision 0, 43 (A150), 44 (A152)

BASES SURVEILLANCE SR 3.5.1.5 (continued)

REQUIREMENTS (continued)

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

SR 3.5.1.6 The ADS designated S/RVs are required to actuate automatically upon receipt of specific initiation signals. A system functional test is performed to demonstrate that the mechanical portions of the ADS function (i.e., solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes valve actuation. This prevents an RPV pressure blowdown.

SR 3.5.1.7 A manual actuation of each ADS actuator is performed to verify that the valve and solenoids are functioning properly. This can be demonstrated by one of two methods. Each ADS actuator can be tested using either method. The first method is a manual actuation of the ADS valve with verification of the response of the turbine control or bypass valves, by a change in the measured steam flow, or by any other method suitable to verify steam flow (e.g., tailpipe temperature or acoustic monitor).

(continued)

INSERT NOTE A

RPV Water Inventory Control B 3.5.2 NMP2 B 3.5.2-9 Revision 0, 44 (A152), 55 (A168)

BASES SURVEILLANCE SR 3.5.2.6 REQUIREMENTS (continued)

Verifying that the required ECCS injection/spray subsystem can be manually started and operate for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. Testing the ECCS injection/spray subsystem through the recirculation line (full flow test line) is necessary to avoid overfilling the refueling cavity.

The minimum operating time of 10 minutes was based on engineering judgment.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.7 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.8 The required ECCS subsystem is required to actuate on a manual initiation signal. This Surveillance verifies that a manual initiation signal will cause the required LPCI subsystem or LCPS System to start and operate as designed, including pump startup and actuation of all automatic valves to their required positions. The HPCS System is verified to start manually from a standby configuration, and includes the ability to override the RPV Level 8 injection valve isolation. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

INSERT NOTE A INSERT NOTE A

RCIC System B 3.5.3 NMP2 B 3.5.3-7 Revision 43 (A150), 44 (A152)

BASES SURVEILLANCE SR 3.5.3.5 REQUIREMENTS (continued)

The RCIC System is required to actuate automatically to perform its design function. This Surveillance verifies that with a required system initiation signal (actual or simulated) the automatic initiation logic of RCIC will cause the system to operate as designed, i.e., actuation of the system throughout its emergency operating sequence, which includes automatic pump startup and actuation of all automatic valves to their required positions. This Surveillance also ensures that the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool on a CST low water level signal. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.2 overlaps this Surveillance to provide complete testing of the assumed design function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES

1.

10 CFR 50, Appendix A, GDC 33.

2.

USAR, Section 5.4.6.1.

3.

10 CFR 50.36(c)(2)(ii).

4.

Memorandum from R.L. Baer (NRC) to V. Stello, Jr.

(NRC), "Recommended Interim Revisions to LCO's for ECCS Components," December 1, 1975.

INSERT NOTE A

SGT System B 3.6.4.3 NMP2 B 3.6.4.3-5 Revision 0, 44 (A152), 55 (A166)

BASES (continued)

SURVEILLANCE SR 3.6.4.3.1 REQUIREMENTS Operating (from the control room using the manual initiation switch) each SGT subsystem for 15 continuous minutes ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.4.3.2 This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The SGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 6). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specified test frequencies and additional information are discussed in detail in the VFTP.

SR 3.6.4.3.3 This SR requires verification that each SGT subsystem starts upon receipt of an actual or simulated initiation signal.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

INSERT NOTE A

SW System and UHS B 3.7.1 NMP2 B 3.7.1-11 Revision 0, 13 (A113), 44 (A152)

BASES SURVEILLANCE SR 3.7.1.6 (continued)

REQUIREMENTS position and yet considered in the correct position, provided it can be automatically realigned to its accident position within the required time.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

This SR is modified by a Note indicating that isolation of the associated SW subsystem to components or systems may render those components or systems inoperable, but does not affect the OPERABILITY of the SW subsystem. As such, when all SW pumps, valves, and piping are OPERABLE, but a branch connection off the main header is isolated, the SW subsystem is still OPERABLE.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.1.7 This SR verifies that the automatic isolation valves (i.e., SW isolation valves servicing non-safety related equipment, SW supply header cross connect valves, and SW pump discharge valves of non-operating SW pumps) of the SW System will automatically switch to the safety or emergency position to provide cooling water exclusively to the safety related equipment during a transient event (i.e., LOOP). This is demonstrated by use of an actual or simulated initiation signal. This SR also verifies the automatic start capability of the SW pump (and associated pump discharge valve opening capability) in each subsystem.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.1.8 The resistance of each required heater feeder cable and associated heater elements is required to be checked to ensure the required heaters are OPERABLE for each intake deicer heater division. The Surveillance is performed by verifying that the resistance is 28 ohms for each required heater feeder cable and associated heater element.

(continued)

INSERT NOTE A

CREF System B 3.7.2 NMP2 B 3.7.2-8 Revision 0, 1, 2, 27 (A126),

44 (A152), 55 (A166)

BASES ACTIONS If applicable, movement of recently irradiated fuel (continued) assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. If applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

SURVEILLANCE SR 3.7.2.1 REQUIREMENTS Operating (from the control room) each CREF subsystem for 15 continuous minutes ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, filter booster or air conditioning unit fan or motor failure, or excessive vibration can be detected for corrective action. In addition, it is not necessary to operate all components of a single subsystem simultaneously for the 15 minute period. It is acceptable to operate the fan portion of the air conditioning unit(s) of one subsystem with the CROASFT of the other subsystem, such that the CROASFTs and fan portion of the air conditioning units are each operated for 15 continuous minutes. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.2.2 This SR verifies that the required CROASFT testing is performed in accordance with Specification 5.5.7, Ventilation Filter Testing Program (VFTP). The CROASFT filter tests are in accordance with Regulatory Guide 1.52 (Ref. 8). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test Frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.2.3 This SR verifies that each CREF subsystem starts and operates on an actual or simulated initiation signal. This SR also includes ensuring the air conditioning units (fan portion only) start on a low flow signal after the appropriate time delay. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.7.1, Control Room Envelope Filtration (CREF)

System Instrumentation, overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

INSERT NOTE A j

Revised Technical Specification Bases Changes (Information Only)

Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR 44 and DPR 56 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3.5-15 B 3.5-39 B 3.5-29 B 3.6-90 B 3.7-10 B 3.7-20a

ECCS Operating B 3.5.1 BASES SURVEILLANCE SR 3.5.1.10 (continued)

REQUIREMENTS will automatically restart on an RPV low water level (Level

2) signal received subsequent to an RPV high water level (Level 8) trip or, if the initial RPV low water level (Level

2) signal was not manually reset, then the HPCI System will restart when the RPV high water level (Level 8) trip automatically clears, and that the suction is automatically transferred from the CST to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

SR 3.5.1.11 The ADS designated S/RVs are required to actuate automatically upon receipt of specific initiation signals.

A system functional test is performed to demonstrate that the mechanical portions of the ADS function (i.e.,

solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components. SR 3.5.1.12 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

PBAPS UNIT 2 B 3.5-15 Revision No. 86 INSERT NOTE A

RCIC System B 3.5.3 BASES SURVEILLANCE SR 3.5.3.3 and SR 3.5.3.4 (continued)

REQUIREMENTS The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.3.5 The RCIC System is required to actuate automatically in order to verify its design function satisfactorily. This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of the RCIC System will cause the system to operate as designed, including actuation of the system throughout its emergency operating sequence; that is, automatic pump startup and actuation of all automatic valves to their required positions. This test also ensures the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool on low CST level. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.2 overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

(continued)

PBAPS UNIT 2 B 3.5-29 Revision No. 86 INSERT NOTE A

RPV Water Inventory Control B 3.5.4 BASES SURVEILLANCE a penetration flow path actuates to the isolation position on REQUIREMENTS an actual or simulated RPV water level isolation signal is (continued) required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

RHR MO-017 and MO-018

RWCU MO-015 and MO-018 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.4.8 The required ECCS subsystem is required to be manually actuated. This Surveillance verifies that the required CS subsystems or LPCI subsystem (including the associated pump /

valve(s)) can be placed into service.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup," November 1984.

2.Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3.Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(F), " August 1992.

4.NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.

5.Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.

6.General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6," February 1983.

PBAPS UNIT 2 B 3.5-39 Revision No. 145 INSERT NOTE A INSERT NOTE A

SGT System B 3.6.4.3 BASES SURVEILLANCE SR 3.6.4.3.2 REQUIREMENTS (continued)

This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.6.4.3.3 This SR verifies that each SGT subsystem starts on receipt of an actual or simulated initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation," overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 1.5.1.6.

2.

UFSAR, Section 14.9.

3.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

PBAPS UNIT 2 B 3.6-90 Revision No. 86 INSERT NOTE A

ESW System and Normal Heat Sink B 3.7.2 BASES SURVEILLANCE SR 3.7.2.4 REQUIREMENTS (continued)

This SR verifies that the ESW System pumps will automatically start to provide cooling water to the required safety related equipment during an accident event. This is demonstrated by the use of an actual or simulated initiation signal.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Chapter 14.

2.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

PBAPS UNIT 2 B 3.7-10 Revision No. 86 INSERT NOTE A

MCREV System B 3.7.4 BASES SURVEILLANCE SR 3.7.4.3 REQUIREMENTS (continued)

This SR verifies that on an actual or simulated initiation signal, each MCREV subsystem starts and operates. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.4 overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.4.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem whole body dose or its equivalent to any part of the body and the CRE occupants are protected from hazardous chemicals and smoke that have been licensed to occur. This SR verifies that the unfiltered air inleakage into the CRE through the radiological and chemical boundaries is no greater than the flow rates assumed in the licensing basis analyses of DBA consequences and control room habitability evaluations for hazardous chemicals. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident.

Mitigating actions are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 6) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 7). These mitigating actions may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 9). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence or chemical habitability analyses, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

(continued)

PBAPS UNIT 2 B 3.7-20a Revision No. 116 INSERT NOTE A

ECCS Operating B 3.5.1 BASES SURVEILLANCE SR 3.5.1.10 (continued)

REQUIREMENTS will automatically restart on an RPV low water level (Level

2) signal received subsequent to an RPV high water level (Level 8) trip or, if the initial RPV low water level (Level

2) signal was not manually reset, then the HPCI System will restart when the RPV high water level (Level 8) trip automatically clears, and that the suction is automatically transferred from the CST to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

SR 3.5.1.11 The ADS designated S/RVs are required to actuate automatically upon receipt of specific initiation signals.

A system functional test is performed to demonstrate that the mechanical portions of the ADS function (i.e.,

solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components. SR 3.5.1.12 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

PBAPS UNIT 3 B 3.5-15 Revision No. 87 INSERT NOTE A

RCIC System B 3.5.3 BASES SURVEILLANCE SR 3.5.3.3 and SR 3.5.3.4 (continued)

REQUIREMENTS The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.3.5 The RCIC System is required to actuate automatically in order to verify its design function satisfactorily. This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of the RCIC System will cause the system to operate as designed, including actuation of the system throughout its emergency operating sequence; that is, automatic pump startup and actuation of all automatic valves to their required positions. This test also ensures the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool on low CST level. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.2 overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

(continued)

PBAPS UNIT 3 B 3.5-29 Revision No. 87 INSERT NOTE A

RPV Water Inventory Control B 3.5.4 BASES SURVEILLANCE a penetration flow path actuates to the isolation position on REQUIREMENTS an actual or simulated RPV water level isolation signal is (continued) required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

RHR MO-017 and MO-018

RWCU MO-015 and MO-018 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.4.8 The required ECCS subsystem is required to be manually actuated. This Surveillance verifies that the required CS subsystems or LPCI subsystem (including the associated pump /

valve(s)) can be placed into service.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup," November 1984.

2.Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3.Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(F), " August 1992.

4.NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.

5.Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.

6.General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6," February 1983.

PBAPS UNIT 3 B 3.5-39 Revision No. 143 INSERT NOTE A INSERT NOTE A

SGT System B 3.6.4.3 BASES SURVEILLANCE SR 3.6.4.3.2 REQUIREMENTS (continued)

This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.6.4.3.3 This SR verifies that each SGT subsystem starts on receipt of an actual or simulated initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation," overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 1.5.1.6.

2.

UFSAR, Section 14.9.

3.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

PBAPS UNIT 3 B 3.6-90 Revision No. 87 INSERT NOTE A

ESW System and Normal Heat Sink B 3.7.2 BASES SURVEILLANCE SR 3.7.2.4 REQUIREMENTS (continued)

This SR verifies that the ESW System pumps will automatically start to provide cooling water to the required safety related equipment during an accident event. This is demonstrated by the use of an actual or simulated initiation signal.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Chapter 14.

2.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

PBAPS UNIT 3 B 3.7-10 Revision No. 87 INSERT NOTE A

MCREV System B 3.7.4 BASES SURVEILLANCE SR 3.7.4.3 REQUIREMENTS (continued)

This SR verifies that on an actual or simulated initiation signal, each MCREV subsystem starts and operates. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.4 overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.4.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem whole body dose or its equivalent to any part of the body and the CRE occupants are protected from hazardous chemicals and smoke that have been licensed to occur. This SR verifies that the unfiltered air inleakage into the CRE through the radiological and chemical boundaries is no greater than the flow rates assumed in the licensing basis analyses of DBA consequences and control room habitability evaluations for hazardous chemicals. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident.

Mitigating actions are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 6) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 7). These mitigating actions may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 9). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence or chemical habitability analyses, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

(continued)

PBAPS UNIT 3 B 3.7-20a Revision No. 114 INSERT NOTE A k

Revised Technical Specification Bases Changes (Information Only)

Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR 29 and DPR 30 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3.5.1-17 B 3.5.2-12 B 3.5.3-8 B 3.6.4.3-7 B 3.7.4-8

BASES SURVEILLANCE REQUIREMENTS SR 3.5.1.8 (continued)

ECCS-Operating B 3.5.1 LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup and actuation of all automatic valves to their required positions.

This SR also ensures that the HPCI System will automatically restart on an RPV low-low water level signal received subsequent to an RPV high water level trip and that the HPCI suction is automatically transferred from the CCST to the suppression pool on high suppression pool water level or low CCST water level.

The LOGIC SYSTEM FUNCTIONAL TEST performed in LCD 3.3.5.1 overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance.

Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

SR 3.5.1.9 The ADS designated valves are required to actuate automatically upon receipt of specific initiation signals.

A system functional test is performed to demonstrate that the mechanical portions of the ADS function (i.e.,

solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components.

SR 3.5.1.10 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCD 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes valve actuation since the valves are individually tested in accordance with SR 3.5.1.10.

(continued)

Quad Cities 1 and 2 B 3.5.1-17 Revision 50 INSERT NOTE A

RPV Water Inventory Control B 3.5.2 Quad Cities 1 and 2 B 3.5.2-12 Revision 61 BASES SURVEILLANCE SR 3.5.2.5 REQUIREMENTS (continued)

Verifying that the required ECCS injection/spray subsystem can be manually started and operated for at least 10 minutes demonstrates that the subsystem is operationally ready to mitigate a draining event. Testing the ECCS injection/spray subsystem through the full flow test recirculation line is necessary to avoid overfilling the refueling cavity. The minimum operating time of 10 minutes is based on engineering judgement.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.6 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur. The Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

Operating experience has shown these components usually pass the Surveillance when performed at the selected Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.7 The required ECCS subsystem shall be capable of being manually operated. This Surveillance verifies that the required CS or LPCI subsystem (including the associated pump and valve(s)) is capable of being manually operated from the control room, and without delay, to provide additional RPV Water Inventory, if needed.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

INSERT NOTE A INSERT NOTE A

RCIC System B 3.5.3 Quad Cities 1 and 2 B 3.5.3-8 Revision 61 BASES SURVEILLANCE SR 3.5.3.5 (continued)

REQUIREMENTS low-low water level signal received subsequent to an RPV high water level trip and that the suction is automatically transferred from the CCST to the suppression pool on a CCST low water level signal. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.3 overlaps this Surveillance to provide complete testing of the assumed design function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES 1.

UFSAR, Section 5.4.6.

2.

Memorandum from R.L. Baer (NRC) to V. Stello, Jr.

(NRC), "Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.

3.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

INSERT NOTE A

SGT System B 3.6.4.3 Quad Cities 1 and 2 B 3.6.4.3-7 Revision 47 BASES (continued)

SURVEILLANCE SR 3.6.4.3.1 REQUIREMENTS Operating (from the control room using the manual initiation switch) each SGT subsystem for 15 continuous minutes ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.4.3.2 This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The SGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 5). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.6.4.3.3 This SR verifies that each SGT subsystem starts on receipt of an actual or simulated initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation," overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

INSERT NOTE A

CREV System B 3.7.4 Quad Cities 1 and 2 B 3.7.4-8 Revision 47 BASES (continued)

SURVEILLANCE SR 3.7.4.1 REQUIREMENTS This SR verifies that the CREV System in a standby mode starts from the control room and continues to operate. This SR includes initiating flow through the HEPA filters and charcoal adsorbers. Standby systems should be checked periodically to ensure that they start and function properly. Operation with the heaters on for 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that heater failure, blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.4.2 This SR verifies that the required CREV testing is performed in accordance with Specification 5.5.7, "Ventilation Filter Testing Program (VFTP)." The CREV filter tests are in accordance with Regulatory Guide 1.52 (Ref. 4). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.4.3 This SR verifies that on an actual or simulated initiation signal, the CREV System isolation dampers close. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.6 overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

INSERT NOTE A l

Revised Technical Specification Bases Changes (Information Only)

R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3.7.9-6

CREATS B 3.7.9 B 3.7.9-6 Revision 77 R.E. Ginna Nuclear Power Plant a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE REQUIREMENTS SR 3.7.9.1 Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each CREATS filtration train for 15 minutes provides an adequate check of this system. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.9.2 This SR verifies that the required CREATS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, flow rate, and the physical properties of the activated charcoal. The required flowrate through each CREATS filtration train is 6000 cubic feet per minute (+/-10%). Specific test Frequencies and additional information are discussed in detail in the VFTP.

The value of 1.5% methyl iodide penetration was chosen for the laboratory test sample acceptance criteria because, even though the new system contains 4-inch charcoal beds, the design face velocity is 61 fpm.

Regulatory Guide 1.52, Revision 3 (Ref. 9), Table 1, provides testing criteria assuming a 40 fpm face velocity. The value of 1.5% was interpolated between the two values listed because of the higher face velocity of Ginna's system. The face velocity is listed in the specification because it is a non standard number. Testing at 61 fpm or greater satifies the criteria.

SR 3.7.9.3 This SR verifies that each CREATS train starts and operates and that each CREATS automatic damper actuates on an actual or simulated actuation signal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.9.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA The SR excludes automatic dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

The SR does not apply to dampers or valves that are locked, sealed, or otherwise secured in the actuated position since the affected dampers or valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve or damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve or damper to be repositioned to the non-actuated position to support the accident analysis.

Restoration of an automatic valve or damper to the non-actuated position requires verification that the SR has been met within its required Frequency.

v t e Letter Sequence Request
EPID:L-2021-LLA-0169, TSTF-541 (Approved, Closed)
Initiation Request, Request Acceptance Supplement Administration Questions 10 February 2022 Answers 23 February 2022 Results Approval... Other: ML22090A086
MONTHYEAR2022-02-10 [Table View]

JAFP-21-0089, Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position

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JAFP-21-0089, Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position

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1.0 DESCRIPTION

2.0 ASSESSMENT

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