Text

License Amendment Request – Revise Technical Specification to Change Surveillance Intervals to Accommodate a 24-Month Fuel Cycle
	ML24141A136
Person / Time
Site:	Hope Creek
Issue date:	05/20/2024
From:	Denight R; Public Service Enterprise Group
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	LR-N24-0004, LAR H24-01
	Download: ML24141A136 (1)
	v • d • e

Robert DeNight HCGS Site Vice President, PSEG Nuclear PO Box 236 Hancocks Bridge, New Jersey 08038-0221 856-339-5303 Robert.denightjr@pseg.com 10 CFR 50.90 LR-N24-0004 LAR H24-01 May 20, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

License Amendment Request - Revise Hope Creek Generating Station Technical Specification to Change Surveillance Intervals to Accommodate a 24-Month Fuel Cycle

References:

1.

Letter from NRC to Thomas Joyce, Hope Creek Generating Station

- Issuance of Amendment RE: Relocation of Specific Surveillance Frequencies to a Licensee-Controlled Program Based On Technical Specifications Task Force (TSTF) Change TSTF-425 (TAC No.

ME3545), dated February 25, 2011 [ML103410243]

2.

NRC Generic Letter 91-04, Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle, dated April 2, 1991 In accordance with 10 CFR 50.90, PSEG Nuclear LLC (PSEG) hereby requests an amendment to Renewed Facility Operating License (RFOL) No. NPF-57 for Hope Creek Generating Station (HCGS) to implement a 24 Month Fuel Cycle (24MFC). PSEG requests changes to the HCGS RFOL to revise the Technical Specification (TS) Surveillance Requirement (SR) performance intervals from 18 months to 24 months. License Amendment 187 relocated most TS SR Frequencies to a licensee-controlled program governed by TS 6.8.4.j, Surveillance Frequency Control Program (SFCP) (Reference 1). The proposed change reviews the requested SR performance interval increases in accordance with Nuclear Regulatory Commission (NRC) Generic Letter (GL) 91-04 (Reference 2). Some SR frequencies extended under the SFCP to 36 months are proposed to be extended to 48 months based on the principles of GL 91-04.

The Enclosure to this License Amendment Request provides a description of the TS changes, the basis for the amendment, the No Significant Hazards Consideration evaluation pursuant to 10 CFR 50.91(a)(1), and the Environmental Consideration evaluation pursuant to 10 CFR 51.22. Attachment 1 to the Enclosure provides the proposed changes to the current

LR-N24-0004 Page 2 10 CFR 50.90 HCGS RFOL and TS in marked up format. Attachment 2 provides the associated TS Bases changes (for information only). Attachment 3 provides the evaluation of the 24-month review findings. Attachment 4 provides a list of affected channels for 24-month fuel cycle changes by TS section, including instrument make, model, and range. Attachment 5 provides a summary of the methodology and assumptions used to determine the rate of instrument drift with time, based upon historical plant calibration data.

In accordance with 10 CFR 50.91, PSEG is notifying the State of New Jersey by transmitting a copy of this letter and enclosures to the designated State of New Jersey official.

Approval of this proposed amendment is requested within one year after the NRC's acceptance review. Once approved, the amendment shall be implemented during the Fall 2025 refueling outage.

There are no regulatory commitments contained in this letter.

If there are any questions or if additional information is needed, please contact Mr. Brian Thomas at brian.thomas@pseg.com.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on S /ZC1./ 1. L{

(Date)

Respectfully,

~~

Robert W. DeNight Site Vice President Hope Creek Generating Station

Enclosure:

Description and Evaluation of the Proposed Change : Mark-up of the Current Hope Creek Generating Station Facility Operating License Pages : Technical Specification Bases Changes : Evaluation of GL 91-04 Review Findings List of Affected Instrument Channels Instrument Drift Analysis Design Guide cc:

Administrator, Region I, NRG Mr. J. Kim, NRG Project Manager, Hope Creek NRG Senior Resident Inspector, Hope Creek Ms. Ann Pfaff, Manager NJBNE

LR-N24-0004 LAR H24-01 Page 1 of 29 Enclosure Description and Evaluation of the Proposed Change License Amendment Request Revise Hope Creek Generating Station Technical Specification (TS) to Change Surveillance Intervals to Accommodate a 24-Month Fuel Cycle Table of Contents 1.0

SUMMARY

DESCRIPTION.......................................................................................................... 2

2.0 BACKGROUND

............................................................................................................................ 2 3.0 DETAILED DESCRIPTION.......................................................................................................... 3 3.1 Proposed Changes................................................................................................................ 3 3.2 Reason for the Proposed Change........................................................................................ 19

4.0 TECHNICAL EVALUATION

....................................................................................................... 19 4.1 Generic Letter 91-04 Changes.............................................................................................. 19

5.0 REGULATORY EVALUATION

.................................................................................................. 24 5.1 Applicable Regulatory Requirements/Criteria.................................................................... 24 5.2 Precedents............................................................................................................................. 26 5.3 No Significant Hazards Consideration Analysis................................................................. 26

6.0 ENVIRONMENTAL CONSIDERATION

..................................................................................... 28

7.0 REFERENCES

........................................................................................................................... 28

LR-N24-0004 LAR H24-01 Page 2 of 29 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, PSEG Nuclear LLC (PSEG) hereby requests an amendment to Renewed Facility Operating License (RFOL) No. NPF-57 for Hope Creek Generating Station (HCGS) to implement a 24 Month Fuel Cycle (24MFC). PSEG requests changes to the HCGS RFOL to revise the Technical Specification (TS) Surveillance Requirement (SR) performance intervals from 18 months to 24 months. License Amendment 187 relocated most TS SR Frequencies to a licensee-controlled program governed by TS 6.8.4.j, Surveillance Frequency Control Program (SFCP) (Reference 1). The proposed change reviews the requested SR performance interval increases in accordance with Nuclear Regulatory Commission (NRC) Generic Letter (GL) 91-04 (Reference 2).

The submittal also proposes changes to TS Table 1.1, and SR 4.6.1.2.f, g, and h to increase the current 18-month testing intervals to 24 months, and revises TS 6.16, Control Room Envelope Habitability Program from 36 months on a Staggered Test Basis to 48 months on a Staggered Test Basis.

Finally, certain 18-month SR Frequencies have already been extended to 36 months under the SFCP. This submittal proposes to extend these Frequencies to 48 months based on the principles of GL 91-04.

2.0 BACKGROUND

PSEG plans to transition HCGS from the current 18-month operating cycle to a 24MFC. On March 19, 2010, PSEG requested an amendment to the HCGS TS to implement NRC approved TS Task Force (TSTF) Change Traveler, TSTF-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF [Risk-Informed TSTF] Initiative 5 (Reference 3). By letter dated February 25, 2011, the NRC issued Amendment 187 which approved the requested TS changes (Reference 1). Amendment 187 incorporated TS 6.8.4.j, Surveillance Frequency Control Program into the HCGS TS. The SFCP transferred most SR intervals from the TS to a licensee-controlled program. TSTF-425 was not designed to address the wholesale SR interval changes associated with a transition to 24MFC. PSEG observes that all plants with 24MFC used GL 91-04 as the basis for the 24MFC SR interval changes. GL 91-04, has been, and continues to be the basis for 24MFC SR interval changes. Since 1991, 24MFC license amendment requests included the information requested by GL 91-04. Recent plants using GL 91-04 as the basis for the transition to 24 MFCs include: Prairie Island (2022) (Reference 4) and Fermi 2 (2021) (Reference 5). The GL 91-04 basis for 24MFC SR interval changes is well established, and both the Fermi 2 and Prairie Island precedents transitioned to the 24MFC utilizing the GL 91-04 methodology, though they had previously adopted the SFCP approach for extending SR Frequencies.

An additional detail is that HCGS has already transitioned certain SR Frequencies to 36 months under the SFCP. However, this does not negate the appropriateness of utilizing the principles of the GL 91-04 approach for extending these SR Frequencies to 48 months. The selected 36-month SR Frequency extensions are a small subset of the overall population of 36-month SRs, but are necessary to support the continuance of channelized outages.

LR-N24-0004 LAR H24-01 Page 3 of 29 3.0 DETAILED DESCRIPTION 3.1 Proposed Changes 3.1.1 Changes In SR Performance Intervals For A 24-Month Fuel Cycle To accommodate a 24-month fuel cycle for HCGS, a new License Condition is proposed to the RFOL:

C.(29) 24 Month Fuel Cycle Exception to Surveillance Frequency Control Program The 24 Month Fuel Cycle-related Surveillance Requirement Frequency changes approved by the NRC in License Amendment xxx are not subject to the Surveillance Frequency Control Program (SFCP) requirements on a one-time extension basis. Subsequent extensions are subject to the SFCP requirements specified in the Technical Specifications.

This element of the proposed change will allow application of the GL 91-04 methodology to extend current selected 18 month and 36 month SR performance intervals to 24 months and 48 months, respectively, in lieu of the SFCP process, as described in TS 6.8.4.j.

3.1.1.2 Changes from 18-Months to 24-Months TS Table 1.1, Surveillance Frequency Notation, Notation R is revised from At least once every 18 months (550 days) to At least once every 24 months (731 days).

The following SR performance intervals are being revised from 18 months to 24 months:

TS 3/4.1.3 Control Rods SR 4.1.3.1.4 The scram discharge volume shall be determined OPERABLE by demonstrating:

a. The scram discharge volume vent and drain valves OPERABLE in accordance with the Surveillance Frequency Control Program, by verifying that the drain and vent valves:

1. Close within 30 seconds after receipt of a signal for control rods to scram, and

2. Open when the scram signal is reset.

TS 3/4.1.5 Standby Liquid Control System SR 4.1.5 The standby liquid control system shall be demonstrated OPERABLE:

d. In accordance with the Surveillance Frequency Control Program by:

2. Demonstrating that all heat traced piping between the storage tank and the injection pumps is unblocked and then draining and flushing the piping with demineralized water.

3. Demonstrating that the storage tank heaters are OPERABLE by verifying the expected temperature rise of the sodium pentaborate solution in the storage tank after the heaters are energized.

TS 3/4.3.1 Reactor Protection System Instrumentation SR 4.3.1.1 Each reactor protection system instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION] operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.1.1-1.

LR-N24-0004 LAR H24-01 Page 4 of 29 Functional Unit 1.a, Intermediate Range Monitors, Neutron Flux - High:

CHANNEL CALIBRATION only Functional Unit 7, Drywell Pressure - High: CHANNEL CALIBRATION only Functional Unit 8.a, Scram Discharge Volume Water Level High, Float Switch: CHANNEL CALIBRATION only Functional Unit 8.b, Scram Discharge Volume Water Level High, Level Transmitter/Trip Unit: CHANNEL CALIBRATION only Functional Unit 11, Reactor Mode Switch Shutdown Position: CHANNEL FUNCTIONAL TEST only SR 4.3.1.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed in accordance with the Surveillance Frequency Control Program. Functional Unit 2.a, 2.b, 2.c, 2.d, and 2.f do not require separate LOGIC SYSTEM FUNCTIONAL TESTS. The LOGIC SYSTEM FUNCTIONAL TEST for APRM Function 2.e includes simulating APRM and OPRM trip conditions at the APRM channel inputs to the voter channel to check all combinations of two tripped inputs to the 2-Out-Of 4 voter logic in the voter channels. [Functional Units 1.a and b, 2.e, 7, 8.a and b, and 11]

Functional Unit 1.a, Intermediate Range Monitors, Neutron Flux - High Functional Unit 1.b, Intermediate Range Monitors, Inoperative Functional Unit 2.e, Average Power Range Monitor, 2-Out-OF-4 Voter Functional Unit 7, Drywell Pressure - High Functional Unit 8.a, Scram Discharge Volume Water Level High, Float Switch Functional Unit 8.b, Scram Discharge Volume Water Level High, Level Transmitter/Trip Unit Functional Unit 11, Reactor Mode Switch Shutdown Position SR 4.3.1.3 The REACTOR PROTECTION SYSTEM RESPONSE TIME of each reactor trip functional unit shall be demonstrated to be within its limit in accordance with the Surveillance Frequency Control Program. Neutron detectors are exempt from response time testing. For the Reactor Vessel Steam Dome Pressure - High Functional Unit and the Reactor Vessel Water Level - Low, Level 3 Functional Unit, the sensor is eliminated from response time testing for RPS circuits.

UFSAR Table 7.2-3 Functional Unit 3, Reactor Vessel Steam Dome Pressure

- High UFSAR Table 7.2-3 Functional Unit 4, Reactor Vessel Water Level - Low, Level 3 UFSAR Table 7.2-3 Functional Unit 5, Main Steam Line Isolation Valve -

Closure TS 3/4.3.2 Isolation Actuation Instrumentation SR 4.3.2.1 Each isolation actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION] operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.2.1-1.

Trip Function 1.b, Primary Containment Isolation, Drywell Pressure - High:

CHANNEL CALIBRATION only Trip Function 1.c, Primary Containment Isolation, Reactor Building Exhaust Radiation - High: CHANNEL CALIBRATION only Trip Function 2.b, Secondary Containment Isolation, Drywell Pressure - High:

CHANNEL CALIBRATION only

LR-N24-0004 LAR H24-01 Page 5 of 29 Trip Function 2.c, Refueling Floor Exhaust Radiation - High: CHANNEL CALIBRATION only Trip Function 2.d, Reactor Building Exhaust Radiation - High: CHANNEL CALIBRATION only Trip Function 3.b, Main Steam Line Isolation, Main Steam Line Radiation -

High, High: CHANNEL CALIBRATION only Trip Function 3.e, Main Steam Line Isolation, Condenser Vacuum - Low:

CHANNEL CALIBRATION only Trip Function 3.f, Main Steam Line Isolation, Main Steam Line Tunnel Temperature - High: CHANNEL CALIBRATION only Trip Function 3.g footnote (a), Main Steam Line Isolation, Manual Initiation:

CHANNEL FUNCTIONAL TEST only Trip Function 4.a, Reactor Water Cleanup System Isolation, RWCU Flow -

High: CHANNEL CALIBRATION only Trip Function 4.b, Reactor Water Cleanup System Isolation, RWCU Flow -

High, Timer: CHANNEL CALIBRATION only Trip Function 4.c, Reactor Water Cleanup System Isolation, RWCU Area Temperature - High: CHANNEL CALIBRATION only Trip Function 4.d, Reactor Water Cleanup System Isolation, RWCU Area Ventilation Temperature - High: CHANNEL CALIBRATION only Trip Function 4.g footnote (a), Reactor Water Cleanup System Isolation, Manual Isolation: CHANNEL FUNCTIONAL TEST only Trip Function 5.a, Reactor Core Isolation Cooling Isolation, RCIC Steam Line Pressure (Flow) - High: CHANNEL CALIBRATION only Trip Function 5.b, Reactor Core Isolation Cooling Isolation, RCIC Steam Line Pressure (Flow) - High, Timer: CHANNEL CALIBRATION only Trip Function 5.c, Reactor Core Isolation Cooling Isolation, RCIC Steam Supply Pressure - Low: CHANNEL CALIBRATION only Trip Function 5.d, Reactor Core Isolation Cooling Isolation, RCIC Turbine Exhaust Diaphragm Pressure - High: CHANNEL CALIBRATION only Trip Function 5.e, Reactor Core Isolation Cooling Isolation, RCIC Pump Room Temperature - High: CHANNEL CALIBRATION only Trip Function 5.f, Reactor Core Isolation Cooling Isolation, RCIC Pump Room Ventilation Ducts Temperature - High: CHANNEL CALIBRATION only Trip Function 5.g, Reactor Core Isolation Cooling Isolation, RCIC Pipe Routing Area Temperature - High: CHANNEL CALIBRATION only Trip Function 5.h, Reactor Core Isolation Cooling Isolation, RCIC Torus Compartment Temperature - High: CHANNEL CALIBRATION only Trip Function 5.i, Reactor Core Isolation Cooling Isolation, Drywell Pressure -

High: CHANNEL CALIBRATION only Trip Function 5.j, Reactor Core Isolation Cooling Isolation, Manual Initiation:

CHANNEL FUNCTIONAL TEST only Trip Function 6.a, High Pressure Coolant Injection System Isolation, HPCI Steam Line Pressure (Flow) - High: CHANNEL CALIBRATION only Trip Function 6.b, High Pressure Coolant Injection System Isolation, HPCI Steam Line Pressure (Flow) - High, Timer: CHANNEL CALIBRATION only Trip Function 6.c, High Pressure Coolant Injection System Isolation, HPCI Steam Supply Pressure - Low: CHANNEL CALIBRATION only

LR-N24-0004 LAR H24-01 Page 6 of 29 Trip Function 6.d, High Pressure Coolant Injection System Isolation, HPCI Turbine Exhaust Diaphragm Pressure - High: CHANNEL CALIBRATION only Trip Function 6.e, High Pressure Coolant Injection System Isolation, HPCI Pump Room Temperature - High: CHANNEL CALIBRATION only Trip Function 6.f, High Pressure Coolant Injection System Isolation, HPCI Pump Room Ventilation Ducts Temperature - High: CHANNEL CALIBRATION only Trip Function 6.g, High Pressure Coolant Injection System Isolation, HPCI Pipe Routing Area Temperature - High: CHANNEL CALIBRATION only Trip Function 6.h, High Pressure Coolant Injection System Isolation, HPCI Torus Compartment Temperature - High: CHANNEL CALIBRATION only Trip Function 6.i, High Pressure Coolant Injection System Isolation, Drywell Pressure - High: CHANNEL CALIBRATION only Trip Function 6.j, High Pressure Coolant Injection System Isolation, Manual Initiation: CHANNEL FUNCTIONAL TEST only Trip Function 7.c footnote (a), RHR System Shutdown Cooling Mode Isolation, Manual Initiation: CHANNEL FUNCTIONAL TEST only SR 4.3.2.3 The ISOLATION SYSTEM RESPONSE TIME of each isolation trip function shall be demonstrated to be within its limit in accordance with the Surveillance Frequency Control Program. Radiation detectors are exempt from response time testing. The sensor is eliminated from response time testing for MSIV isolation logic circuits of the following trip functions: Reactor Vessel Water Level - Low Low Low, Level 1; Main Steam Line Pressure - Low; Main Steam Line Flow -

High.

UFSAR Table 7.3-16 Trip Function 2.c, Secondary Containment Isolation, Refueling Floor Exhaust Radiation - High UFSAR Table 7.3-16 Trip Function 2.d, Secondary Containment Isolation, Reactor Building Exhaust Radiation - High TS 3/4.3.3 Emergency Core Cooling System Actuation Instrumentation SR 4.3.3.1 Each ECCS actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION] operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.3.1-1.

Trip Function 1.b, Core Spray, Drywell Pressure - High: CHANNEL CALIBRATION only Trip Function 1.d, Core Spray, Core Spray Pump Discharge Flow - Low (Bypass): CHANNEL CALIBRATION only Trip Function 2.b, Low Pressure Coolant Injection Mode of RHR System, Drywell Pressure - High: CHANNEL CALIBRATION only Trip Function 2.c, Low Pressure Coolant Injection Mode of RHR System, Reactor Vessel Pressure - Low (Permissive): CHANNEL CALIBRATION only Trip Function 2.d, Low Pressure Coolant Injection Mode of RHR System, LPCI Pump Discharge Flow - Low (Bypass): CHANNEL CALIBRATION only Trip Function 3.b, High Pressure Coolant Injection System, Drywell Pressure

- High: CHANNEL CALIBRATION only Trip Function 3.c, High Pressure Coolant Injection System, Condensate Storage Tank Level - Low: CHANNEL CALIBRATION only

LR-N24-0004 LAR H24-01 Page 7 of 29 Trip Function 3.f, High Pressure Coolant Injection System, HPCI Pump Discharge Flow - Low (Bypass): CHANNEL CALIBRATION only Trip Function 3.g, High Pressure Coolant Injection System, Manual Initiation:

CHANNEL FUNCTIONAL TEST only Trip Function 4.b, Automatic Depressurization System, Drywell Pressure -

High: CHANNEL CALIBRATION only Trip Function 4.d, Automatic Depressurization System, Core Spray Pump Discharge Pressure - High: CHANNEL CALIBRATION only Trip Function 4.e, Automatic Depressurization System, RHR LPCI Mode Pump Discharge Pressure - High: CHANNEL CALIBRATION only Trip Function 4.h, Automatic Depressurization System, ADS Manual Inhibit Switch: CHANNEL FUNCTIONAL TEST only Trip Function 4.i, Automatic Depressurization System, Manual Initiation:

CHANNEL FUNCTIONAL TEST only SR 4.3.3.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed in accordance with the Surveillance Frequency Control Program.

Trip Functions 1.b, Core Spray, Drywell Pressure - High Trip Function 1.d, Core Spray, Core Spray Pump Discharge Flow - Low (Bypass)

Trip Function 2.b, Low Pressure Coolant Injection Mode of RHR System, Drywell Pressure - High Trip Function 2.c, Low Pressure Coolant Injection Mode of RHR System, Reactor Vessel Pressure - Low (Permissive)

Trip Function 2.d, Low Pressure Coolant Injection Mode of RHR System, LPCI Pump Discharge Flow - Low (Bypass)

Trip Function 3.b, High Pressure Coolant Injection System, Drywell Pressure

- High Trip Function 3.c, High Pressure Coolant Injection System, Condensate Storage Tank Level - Low Trip Function 3.f, High Pressure Coolant Injection System, HPCI Pump Discharge Flow - Low (Bypass)

Trip Function 4.b, Automatic Depressurization System, Drywell Pressure -

High Trip Function 4.c, Automatic Depressurization System, ADS Timer Trip Function 4.d, Automatic Depressurization System, Core Spray Pump Discharge Pressure - High Trip Function 4.e, Automatic Depressurization System, RHR LPCI Mode Pump Discharge Pressure - High Trip Function 4.g, Automatic Depressurization System, ADS Drywell Pressure Bypass Timer Trip Function 4.h, Automatic Depressurization System, ADS Manual Inhibit Switch Trip Function 4.i, Automatic Depressurization System, Manual Initiation TS 3/4.3.5 Reactor Core Isolation Cooling System Actuation Instrumentation SR 4.3.5.1 Each RCIC system actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL FUNCTIONAL TEST and

LR-N24-0004 LAR H24-01 Page 8 of 29 CHANNEL CALIBRATION] operations at the frequencies shown in Table 4.3.5.1-1.

Functional Unit c, Condensate Storage Tank Level - Low: CHANNEL CALIBRATION only Functional Unit d Footnote (a), Manual Initiation: CHANNEL FUNCTIONAL TEST only SR 4.3.5.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed in accordance with the Surveillance Frequency Control Program.

Functional Unit c, Condensate Storage Tank Level - Low Functional Unit d, Manual Initiation TS 3/4.3.6 Control Rod Block Instrumentation SR 4.3.6 Each of the above required control rod block trip systems and instrumentation channels shall be demonstrated OPERABLE by the performance ofthe

[CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION] operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.6-1. The provisions of Specification 4.0.4 arenot applicable for entry into OPERATIONAL CONDITION 2 from OPERATIONAL CONDITION 1 for the Source Range Monitors or the Intermediate Range Monitors.

Trip Function 1.a, Rod Block Monitor, Upscale: CHANNEL CALIBRATION only Trip Function 1.c, Rod Block Monitor, Downscale: CHANNEL CALIBRATION only Trip Function 3.b, Source Range Monitors, Upscale: CHANNEL CALIBRATION only Trip Function 3.d, Source Range Monitors, Downscale: CHANNEL CALIBRATION only Trip Function 4.b, Intermediate Range Monitor, Upscale: CHANNEL CALIBRATION only Trip Function 4.d, Intermediate Range Monitor, Downscale: CHANNEL CALIBRATION only Trip Function 5.a, Scram Discharge Volume, Water Level - High (Float Switch): CHANNEL CALIBRATION only Trip Function 7, Reactor Mode Switch Shutdown Position: CHANNEL FUNCTIONAL TEST only TS 3/4.3.7 Monitoring Instrumentation SR 4.3.7.1 Each of the above required radiation monitoring instrumentation channels shall be demonstrated OPERABLE by the performance of the [CHANNEL CALIBRATION] operations for the conditions and at the frequencies in accordance with the Surveillance Frequency Control Program.

Instrumentation 1, Control Room Ventilation Radiation Monitor Instrumentation 2.a.1, Area Monitors, Criticality Monitors, New Fuel Storage Vault Instrumentation 2.a.2, Area Monitors, Criticality Monitors, Spent Fuel Storage Pool Instrumentation 2.b, Area Monitors, Control Room Direct Radiation Monitor Instrumentation 3, Reactor Auxiliaries Cooling Radiation Monitor

LR-N24-0004 LAR H24-01 Page 9 of 29 Instrumentation 4, Safety Auxiliaries Cooling Radiation Monitor Instrumentation 5, Offgas Pre-treatment Radiation Monitor SR 4.3.7.4.3 Each required instrumentation channel shall be demonstrated OPERABLE by performance of a CHANNEL CALIBRATION at the frequency specified in the Surveillance Frequency Control Program.

Instrument 4, Suppression Chamber Water Level Instrument 5, Suppression Chamber Water Temperature Instrument 6, RHR System Flow Instrument 7, Safety Auxiliaries Cooling System Flow Instrument 8, Safety Auxiliaries Cooling System Temperature Instrument 9, RCIC System Flow Instrument 10, RCIC Turbine Speed Instrument 11, RCIC Turbine Bearing Oil Pressure Low Indication Instrument 12, RCIC High Pressure/Low Pressure Turbine Bearing Temperature High Indication Instrument 13, Condensate Storage Tank Level Low-Low Indication SR 4.3.7.5 Each of the above required accident monitoring instrumentation channels shall be demonstrated OPERABLE by performance of the [CHANNEL CALIBRATION]

operations at the frequencies shown in Table 4.3.7.5-1.

Instrument 3, Suppression Chamber Water Level Instrument 4, Suppression Chamber Water Temperature Instrument 7, Drywell Air Temperature Instrument 11, North Plant Vent Radiation Monitor Instrument 12, South Plant Vent Radiation Monitor Instrument 13, FRVS Vent Radiation Monitor Instrument 14, Primary Containment Isolation Valve Position Indication SR 4.3.7.6 Each of the above required source range monitor channels shall be demonstrated OPERABLE by:

a. Performance of a:

2. CHANNEL CALIBRATION in accordance with the Surveillance Frequency Control Program.

TS 3/4.3.9 Feedwater/Main Turbine Trip System Actuation Instrumentation SR 4.3.9.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed in accordance with the Surveillance Frequency Control Program.

Functional Unit 1, Reactor Vessel Water Level - High, Level 8 TS 3/4.3.10 Mechanical Vacuum Pump Trip Instrumentation SR 4.3.10 Each channel of the Main Steam Line Radiation - High, High function for the mechanical vacuum pump trip shall be demonstrated OPERABLE by:

c. Performance of a CHANNEL CALIBRATION in accordance with the Surveillance Frequency Control Program.

d. Performance of a LOGIC SYSTEM FUNCTIONAL TEST, including mechanical vacuum pump trip breaker actuation, in accordance with the Surveillance Frequency Control Program.

LR-N24-0004 LAR H24-01 Page 10 of 29 TS 3/4.4.2 Safety Relief Valves SR 4.4.2.2 At least 1/2 of the safety relief valve pilot stage assemblies shall be removed, set pressure tested and reinstalled or replaced with spares that have been previously set pressure tested and stored in accordance with manufacturer's recommendations in accordance with the Surveillance Frequency Control Program, and they shall be rotated such that all 14 safety relief valve pilot stage assemblies are removed, set pressure tested and reinstalled or replaced with spares that have been previously set pressure tested and stored in accordance with manufacturer's recommendations in accordance with the Surveillance Frequency Control Program. All safety relief valves will be re-certified to meet a +/-1% tolerance prior to returning the valves to service after setpoint testing.

TS 3/4.4.3 Reactor Coolant Leakage System SR 4.4.3.1 The reactor coolant system leakage detection systems shall be demonstrated OPERABLE by:

a. Drywell atmosphere gaseous radioactivity monitoring system-performance of a [CHANNEL CALIBRATION] in accordance with the Surveillance Frequency Control Program.

SR 4.4.3.2.2 Each reactor coolant system pressure isolation valve specified in Table 3.4.3.2-1 shall be demonstrated OPERABLE by leak testing pursuant to the INSERVICE TESTING PROGRAM and verifying the leakage of each valve to be within the specified limit:

a. In accordance with the Surveillance Frequency Control Program.

SR 4.4.3.2.3 The high/low pressure interface valve leakage pressure monitors shall be demonstrated OPERABLE with alarm setpoints per Table 3.4.3.2-2 by performance of a [CHANNEL CALIBRATION] at the frequencies specified in the Surveillance Frequency Control Program.

TS 3/4.5.1 ECCS - Operating SR 4.5.1 The emergency core cooling systems shall be demonstrated OPERABLE by:

c. In accordance with the Surveillance Frequency Control Program:

1. For 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.

2. For the HPCI system, verifying that:

b) The suction is automatically transferred from the condensate storage tank to the suppression chamber on a condensate storage tank water level - low signal and on a suppression chamber - water level high signal.

3. Performing a CHANNEL CALIBRATION of the CSS, and LPCI system discharge line "keep filled" alarm instrumentation.

4. Performing a CHANNEL CALIBRATION of the CSS header P instrumentation and verifying the setpoint to be the allowable value of 4.4 psid.

LR-N24-0004 LAR H24-01 Page 11 of 29

5. Performing a CHANNEL CALIBRATION of the LPCI header P instrumentation and verifying the setpoint to be the allowable value of 1.0 psid.

d. For the ADS:

2. In accordance with the Surveillance Frequency Control Program:

a) Performing a system functional test which includes simulated automatic actuation of the system throughout its emergency operating sequence, but excluding actual valve actuation.

b) Verify that when tested pursuant to the INSERVICE TESTING PROGRAM, that each ADS valve is capable of being opened.

TS 3/4.5.2 RPV Water Inventory Control SR 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.

TS 3/4.6.1 Primary Containment SR 4.6.1.2

f. Main steam line isolation valves shall be leak tested at least once per 18 months.

g. Containment isolation valves which form the boundry for the long-term seal of the feedwater lines shall be hydrostatically tested at 1.10 Pa, 55.7 psig, at least once per 18 months.

h. All containment isolation valves in hydrostatically tested lines which penetrate the primary containment shall be leak tested at least once per 18 months.

TS 3/4.6.2 Depressurization Systems SR 4.6.2.1 The suppression chamber shall be demonstrated OPERABLE:

e. In accordance with the Surveillance Frequency Control Program by a visual inspection of the accessible interior and exterior of the suppression chamber.

f. In accordance with the Surveillance Frequency Control Program by conducting a drywell-to-suppression chamber bypass leak test at an initial differential pressure of 0.80 psi and verifying that the differential pressure does not decrease by more than 0.24 inch of water per minute for a period of 10 minutes. If any drywell-to-suppression chamber bypass leak test fails to meet the specified limit, the test schedule for subsequent tests shall be reviewed and approved by the Commission. If two consecutive tests fail to meet the specified limit, a test shall be performed at least every 9 months until two consecutive tests meet the specified limit, at which time the Surveillance Frequency Control Program schedule may be resumed.

TS 3/4.6.3 Primary Containment Isolation Valves SR 4.6.3.4 In accordance with the Surveillance Frequency Control Program, verify that a representative sample of reactor instrumentation line excess flow check valves actuates to the isolation position on a simulated instrument line break signal.

SR 4.6.3.5 Each traversing in-core probe system explosive isolation valve shall be demonstrated OPERABLE:

b. In accordance with the Surveillance Frequency Control Program by removing the explosive squib from at least one explosive valve, and initiating the explosive squib. The replacement charge for the exploded squib shall be from the same manufactured batch as the one fired or

LR-N24-0004 LAR H24-01 Page 12 of 29 from another batch which has been certified by having at least one of that batch successfully fired. No squib shall remain in use beyond the expiration of its shelf-life or operating life, as applicable.

TS 3/4.6.4 Vacuum Relief SR 4.6.4.1 Each suppression chamber - drywell vacuum breaker shall be:

b. Demonstrated OPERABLE:

2. In accordance with the Surveillance Frequency Control Program by verifying the opening setpoint of each vacuum breaker to be less than or equal to 0.20 psid.

SR 4.6.4.2 Each reactor building - suppression chamber vacuum breaker assembly shall be:

b. Demonstrated OPERABLE:

2. In accordance with the Surveillance Frequency Control Program by:

a) Verifying the opening setpoint of each vacuum breaker assembly valve to be less than or equal to 0.25 psid.

TS 3/4.6.5.3 Filtration, Recirculation and Ventilation System (FRVS) - Ventilation Subsystem SR 4.6.5.3.1 Each of the two ventilation units shall be demonstrated OPERABLE:

c. In accordance with the Surveillance Frequency Control Program or upon determination that the HEPA filters or charcoal adsorbent could have been damaged by structural maintenance or adversely affected by any chemicals, fumes or foreign materials (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the subsystem by:

1. Verifying that the subsystem satisfies the in-place penetration testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rates are 9,000 cfm +/- 10% for each FRVS ventilation unit.

2. Verifying within 31 days after removal from the FRVS ventilation units, that a laboratory test of a sample of the charcoal adsorber, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 5% when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and a relative humidity 95%.

3. Verifying a subsystem flow rate of 9,000 cfm +/- 10% for each FRVS ventilation unit during system operation when tested in accordance with ANSI N510-1980.

e. In accordance with the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 5 inches Water Gauge in the ventilation unit while operating the filter train at a flow rate of 9,000 cfm

+/-10% for each FRVS ventilation unit.

TS 3/4.6.5.3 Filtration, Recirculation and Ventilation System (FRVS) - Recirculation Subsystem SR 4.6.5.3.2 Each of the six FRVS recirculation units shall be demonstrated OPERABLE:

c. In accordance with the Surveillance Frequency Control Program or upon determination that the HEPA filters could have been damaged by structural

LR-N24-0004 LAR H24-01 Page 13 of 29 maintenance or adversely affected by any foreign materials (1) after any structural maintenance on the HEPA filters or housings by:

1. Verifying that the subsystem satisfies the in-place penetration testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a and C.5.c of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rates are 30,000 cfm

+/-10% for each FRVS recirculation unit.

2. Verifying a subsystem flow rate of 30,000 cfm +/- 10% for each FRVS recirculation unit during system operation when tested in accordance with ANSI N510-1980.

e. In accordance with the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the exhaust duct is less than 8 inches Water Gauge in the recirculation filter train while operating the filter train at a flow rate of 30,000 cfm +/- 10% for each FRVS recirculation unit.

TS 3/4.7.1 Service Water Systems SR 4.7.1.2 At least the above required station service water system loops shall be demonstrated OPERABLE:

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

1. Each automatic valve servicing non-safety related equipment actuates to its isolation position on an isolation test signal.

TS 3/4.7.2 Control Room Systems SR 4.7.2.1.1 Each control room emergency filtration subsystem shall be demonstrated OPERABLE:

c. In accordance with the Surveillance Frequency Control Program or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the subsystem filter train by:

1. Verifying that the subsystem satisfies the in-place penetration testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system filter train flow rate is 4000 cfm +/- 10%.

2. Verifying within 31 days after removal, that a laboratory test of a sample of the charcoal adsorber, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 0.5% when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and a relative humidity 70%.

3. Verifying a subsystem filter train flow rate of 4000 cfm +/- 10% during subsystem operation when tested in accordance with ANSI N510-1980.

e. In accordance with the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 7.5 inches Water Gauge while operating the filter train subsystem at a flow rate of 4000 cfm +/- 10%.

4. Verifying that the heaters dissipate 13 +/- 1.3 Kw when tested in accordance with ANSI N510-1980 and verifying humidity is maintained

LR-N24-0004 LAR H24-01 Page 14 of 29 less than or equal to 70% humidity through the carbon adsorbers by performance of a channel calibration of the humidity control instrumentation.

SR 4.7.2.2 Each control room AC subsystem shall be demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program by verifying each subsystem has the capability to remove the assumed heat load.

TS 3/4.7.4 Reactor Core Isolation Cooling System SR 4.7.4 The RCIC system shall be demonstrated OPERABLE:

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.

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.

TS 3/4.7.7 Main Turbine Bypass System SR 4.7.7 The main turbine bypass system shall be demonstrated OPERABLE:

b. In accordance with the Surveillance Frequency Control Program by:

1. Performing a system functional test which includes simulated automatic actuation and verifying that each automatic valve actuates to its correct position.

2. Demonstrating TURBINE BYPASS SYSTEM RESPONSE TIME meets the following requirements when measured from the initial movement of the main turbine stop or control valve:

a) 80% of turbine bypass system capacity shall be established in less than or equal to 0.3 second.

b) Bypass valve opening shall start in less than or equal to 0.1 second.

TS 3/4.8.1 A.C. Sources SR 4.8.1.1.2 Each of the above required diesel generators shall be demonstrated OPERABLE:

k. In accordance with the Surveillance Frequency Control Program by:

1. Verifying the diesel generator operates for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . During the first 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months of this test, the diesel generator shall be loaded to between 4000 and 4400 kW and during the remaining 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of this test, the diesel generator shall be loaded to between 4652 and 4873 kW. The diesel generator shall achieve 3950 volts and 58.8 Hz in 10 seconds following receipt of the start signal and subsequently achieve steady state voltage 3828 and 4580 volts and frequency of 60 +/- 1.2 Hz.

2. Within 5 minutes after completing 4.8.1.1.2.k.1, verify each diesel generator starts and achieves 3950 volts and 58.8 Hz in 10 seconds after receipt of the start signal, and subsequently achieves steady state voltage 3828 and 4580 volts and frequency of 60 +/- 1.2 Hz.

-OR-Operate the diesel generator between 4000 kW and 4400 kW for two hours. Within 5 minutes of shutting down the diesel generator, verify each diesel generator starts and achieves 3950 volts and 58.8 Hz in 10

LR-N24-0004 LAR H24-01 Page 15 of 29 seconds after receipt of the start signal, and subsequently achieves steady state voltage 3828 and 4580 volts and frequency of 60 +/- 1.2 Hz. This test shall continue for at least five minutes.

TS 3/4.8.4 Electrical Equipment Protective Devices SR 4.8.4.1 Each of the primary containment penetration conductor overcurrent protective devices shown in Table 3.8.4.1-1 shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program:

2. By selecting and functionally testing a representative sample of at least 10% of each type of lower voltage circuit breakers. Circuit breakers selected for functional testing shall be selected on a rotating basis.

Testing of these circuit breakers shall consist of injecting a current with a value between 150% and 300% of the pickup of the long time delay trip element and verifying that the circuit breaker operates within the time delay bandwidth for that current specified by the manufacturer. The instantaneous element shall be tested by injecting a current in excess of 120% of the pickup value of the element and verifying that the circuit breaker trips instantaneously with no intentional time delay. Molded case circuit breaker testing shall also follow this procedure except that generally no more than two trip elements, time delay and instantaneous, will be involved. Circuit breakers found inoperable during functional testing shall be restored to OPERABLE status prior to resuming operation. For each circuit breaker found inoperable during these functional tests, an additional representative sample of at least 10% of all the circuit breakers of the inoperable type shall also be functionally tested until no more failures are found or all circuit breakers of that type have been functionally tested.

SR 4.8.4.2.1 The thermal overload protection bypass circuit for each of the above required MOVs shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by the performance of a CHANNEL FUNCTIONAL TEST for:

2. A representative sample of at least 25% of those thermal overload protection devices which are bypassed continuously and temporarily placed in force only when the MOVs are undergoing periodic or maintenance testing.

3. A representative sample of at least 25% of those thermal overload protection devices which are in force during normal manual (momentary push button contact) MOV operation and bypassed during remote manual (push button held depressed) MOV operation.

SR 4.8.4.4 The above specified RPS electric power monitoring channels shall be determined OPERABLE:

b. In accordance with the Surveillance Frequency Control Program by demonstrating the OPERABILITY of over-voltage, under-voltage, and underfrequency protective instrumentation by performance of a CHANNEL CALIBRATION including simulated automatic actuation of the protective relays, tripping logic and output circuit breakers and verifying the following setpoints.

1. Over-voltage 132 VAC, (Bus A), 132 VAC (Bus B)

2. Under-voltage 108 VAC, (Bus A), 108 VAC (Bus B)

LR-N24-0004 LAR H24-01 Page 16 of 29

3. Under-frequency 57 Hz. (Bus A and Bus B)

SR 4.8.4.6 The above specified power range NMS electric power monitoring channels shall be determined OPERABLE:

b. In accordance with the Surveillance Frequency Control Program by demonstrating the OPERABILITY of over-voltage, under-voltage, and underfrequency protective instrumentation by performance of a CHANNEL CALIBRATION including simulated automatic actuation of the protective relays, tripping logic and output circuit breakers and verifying the following setpoints.

1. Over-voltage 132 VAC (BUS A), 132 VAC (BUS B)

2. Under-voltage 108 VAC (BUS A), 108 VAC (BUS B)

3. Under-frequency 57 Hz. -0, +2%

3.1.1.3 Changes from 36-Months to 48-Months The following SR performance intervals are being revised from 36 months to 48 months:

TS 3/4.3.3 Emergency Core Cooling System Actuation Instrumentation SR 4.3.3.1 Each ECCS actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION] operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.3.1-1.

Trip Function 1.g, Core Spray System, Manual Initiation: CHANNEL FUNCTIONAL TEST only Trip Function 2.f, Low Pressure Coolant Injection Mode of RHR System, Manual Initiation: CHANNEL FUNCTIONAL TEST only Trip Function 5.a, Loss of Power, 4.16 kv Emergency Bus Under-voltage (Loss of Voltage): CHANNEL CALIBRATION only SR 4.3.3.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed in accordance with the Surveillance Frequency Control Program.

Trip Function 1.g, Core Spray System, Manual Initiation Trip Function 5.a, Loss of Power, 4.16 kv Emergency Bus Under-voltage (Loss of Voltage)

Trip Function 5.b, Loss of Power, 4.16 kv Emergency Bus Under-voltage (Degraded Voltage)

SR 4.3.3.3 The ECCS RESPONSE TIME of each ECCS trip function shall be demonstrated to be within the limit in accordance with the Surveillance Frequency Control Program. ECCS actuation instrumentation is eliminated from response time testing.

UFSAR Table 7.3-17 Trip Function 1, Core Spray System UFSAR Table 7.3-17 Trip Function 2, Low Pressure Injection mode of RHR System UFSAR Table 7.3-17 Trip Function 4, High Pressure Coolant Injection System

LR-N24-0004 LAR H24-01 Page 17 of 29 TS 3/4.3.4 Recirculation Pump Trip Actuation Instrumentation SR 4.3.4.2.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed in accordance with the Surveillance Frequency Control Program.

TS 3/4.3.7 Monitoring Instrumentation SR 4.3.7.4.3 Each required instrumentation channel shall be demonstrated OPERABLE by performance of a CHANNEL CALIBRATION at the frequency specified in the Surveillance Frequency Control Program.

Instrument 2, Reactor Water Vessel Level SR 4.3.7.5 Each of the above required accident monitoring instrumentation channels shall be demonstrated OPERABLE by performance of the [CHANNEL CALIBRATION]

operations at the frequencies shown in Table 4.3.7.5-1.

Instrument 1, Reactor Vessel Pressure 3/4.3.9 Feedwater/Main Turbine Trip System Actuation Instrumentation SR 4.3.9.1 Each feedwater/main turbine trip system actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL CALIBRATION] operations at the frequencies specified in the Surveillance Frequency Control Program.

Functional Unit 1, Reactor Vessel Water Level - High, Level 8 TS 3/4.5.1 ECCS - Operating SR 4.5.1 The emergency core cooling systems shall be demonstrated OPERABLE by:

c. In accordance with the Surveillance Frequency Control Program:

1. For the [CSS and LPCI systems], 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.

2. For the HPCI system, verifying that:

a) The system develops a flow of at least 5600 gpm against a test line pressure corresponding to a reactor vessel pressure of 200 psig, when steam is being supplied to the turbine at 200 + 15, -0 psig.

TS 3/4.7.1 Service Water Systems SR 4.7.1.1 At least the above required safety auxiliaries cooling system subsystems shall be demonstrated OPERABLE:

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

2) Each pump starts automatically when its associated diesel generator automatically starts.

SR 4.7.1.2 At least the above required station service water system loops shall be demonstrated OPERABLE:

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

2. Each pump starts automatically when its associated diesel generator automatically starts.

LR-N24-0004 LAR H24-01 Page 18 of 29 TS 3/4.7.4 Reactor Core Isolation Cooling System SR 4.7.4 The RCIC system shall be demonstrated OPERABLE:

c. In accordance with the Surveillance Frequency Control Program by:

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.

TS 3/4.8.1 A.C. Sources SR 4.8.1.1.2 Each of the above required diesel generators shall be demonstrated OPERABLE:

h. In accordance with the Surveillance Frequency Control Program, during shutdown, by:

2. Verifying the diesel generator capability to reject a load of greater than or equal to that of the RHR pump motor for each diesel generator while maintaining voltage 3828 and 4580 volts and frequency at 60 +/- 1.2 Hz.

3. Verifying the diesel generator capability to reject a load of 4430 kW without tripping. The generator voltage shall not exceed 4785 volts during and following the load rejection.

4. Simulating a loss of offsite power by itself, and:

b) Verifying the diesel generator starts on the auto-start signal, energizes the emergency busses with permanently connected loads within 10 seconds after receipt of the start signal, energizes the autoconnected shutdown loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady state voltage and frequency of the emergency busses shall be maintained 3828 and 4580 volts and 60 +/- 1.2 Hz during this test.

5. Verifying that on an ECCS actuation test signal, without loss of offsite power, the diesel generator starts on the auto-start signal and operates on standby for greater than or equal to 5 minutes. The diesel generator shall achieve 3950 volts and 58.8 Hz in 10 seconds following receipt of the start signal and subsequently achieve steady state voltage 3828 and 4580 volts and frequency of 60 +/- 1.2 Hz.

6. Simulating a loss of offsite power in conjunction with an ECCS actuation test signal, and:

b) Verifying the diesel generator starts on the auto-start signal, energizes the emergency busses with permanently connected loads within 10 seconds after receipt of the start signal, energizes the autoconnected shutdown loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the emergency loads. After energization, the steady state voltage and frequency of the emergency busses shall be maintained 3828 and 4580 volts and 60 +/- 1.2 Hz during this test.

7. Verifying that all automatic diesel generator trips, except engine overspeed, generator differential current, generator overcurrent, bus differential current and low lube oil pressure are automatically bypassed upon loss of voltage on the emergency bus concurrent with an ECCS actuation signal.

LR-N24-0004 LAR H24-01 Page 19 of 29

9. Verifying that the auto-connected loads to each diesel generator do not exceed the continuous rating of 4430 kW.

10. Verifying the diesel generator's capability to:

a) Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power, b) Transfer its loads to the offsite power source, c) Be restored to its standby status, and d) Diesel generator circuit breaker is open.

11. Verifying that with the diesel generator operating in a test mode and connected to its bus, a simulated ECCS actuation signal overrides the test mode by (1) returning the diesel generator to standby operation, and (2) automatically energizes the emergency loads with offsite power.

3.2 Reason for the Proposed Change The shift from an 18-month fuel cycle to a 24-month fuel cycle is a PSEG strategic initiative. It is expected to increase the HCGS capacity factor throughout the plant's operating life, and reduce cumulative radiological occupational exposure due to less frequent refueling outages.

Hope Creek has extended several 18-month surveillance frequencies to 36-month to promote outage efficiency by implementing channelized alternating outages through the SFCP. PSEG is proposing to extend these SR frequencies from 36 to 48 months consistent with the principles of GL91-04.

4.0 TECHNICAL EVALUATION

4.1 Generic Letter 91-04 Changes In NRC GL 91-04, the NRC provided generic guidance for evaluating a 24-month surveillance test interval for TS SRs that are currently performed at 18-month intervals. This section defines each step outlined by the NRC in the GL and provides a description of the methodology used by HCGS to complete the evaluation for each specific TS SR frequency being extended from 18 months to 24 months (and from 36 months to 48 months for those SRs that have previously been extended under the SFCP). The methodology utilized in the HCGS drift analysis, as summarized in Attachment 5, is similar to the methodology used for previous plant submittals, such as Fermi 2 Amendment 218 (Reference 5).

The proposed TS changes based on the GL have been divided into two categories. The categories are: (1) changes to surveillances other than channel calibrations, identified as Non-Calibration Changes; and (2) changes involving the channel calibration frequency identified as Calibration Changes. For each component having a surveillance interval extended, historical surveillance test data and associated maintenance records were reviewed in evaluating the effect on safety. In addition, the licensing basis was reviewed for functions associated with each revision to ensure it was not invalidated. Based on the results of these reviews, it is concluded that there is no adverse effect on plant safety due to increasing the surveillance test intervals from 18 months to 24 months, and from 36 months to 48 months that have previously been extended under the SFCP, with the continued application of SR 4.0.2, which allows a 25%

extension (i.e., 30 months interval for 24-month SRs and 60 months for 48-month SRs) to SR frequencies.

LR-N24-0004 LAR H24-01 Page 20 of 29 4.1.1 Non-Calibration Changes GL 91-04 identifies three steps to evaluate non-calibration changes.

STEP 1: Licensees should evaluate the effect on safety of the change in surveillance intervals to accommodate a 24-month fuel cycle. This evaluation should support a conclusion that the effect on safety is small.

HCGS EVALUATION Although the preface of the review process refers to surveillances with an 18-month Frequency, this is pretextual rather than prescriptive, and equally applies to extend SRs with a 36-month Frequency. Each non-calibration SR frequency being changed has been evaluated with respect to the effect on plant safety. The methodology utilized to justify the conclusion that extending the testing interval has a minimal effect on safety was based on the fact that the function/feature is:

(1)

Tested on a more frequent basis during the operating cycle by other plant programs; (2)

Designed to have redundant counterparts or be single failure proof; or (3)

Highly reliable.

A summary of the evaluation of the effect on safety for each non-calibration SR Frequency being changed is presented in Attachment 3.

STEP 2: In addition, licensees should confirm that historical plant maintenance and surveillance data do not invalidate this conclusion.

HCGS EVALUATION The surveillance test history of the affected SRs has been evaluated. This evaluation consisted of a review of available surveillance test results and associated maintenance records for at least five cycles of operation for 18-month to 24-month extensions, and two cycles of operation for 36-month to 48-month extensions. The evaluation included extension of current 18-month frequencies for online testing that is not normally needed to be credited. With the extension of the testing frequency to 24 and 48 months, there will be a longer period between each surveillance performance. If a failure that results in the loss of the associated safety function should occur during the operating cycle, and would only be detected by the performance of the 18-month or 36-month TS SR, then the increase in the surveillance testing interval could reduce the associated function availability. In addition to evaluating these surveillance failures, potential common failures of similar components tested by different surveillances were also evaluated.

This additional evaluation determined whether there is evidence of repetitive failures among similar plant components. These common component failures have been further evaluated to determine if there was an impact on plant reliability. The evaluation determined that current plant programs are adequate to ensure system reliability. The surveillance failures exclude failures that:

(a)

Did not impact a TS safety function or TS operability;

LR-N24-0004 LAR H24-01 Page 21 of 29 (b)

Are detectable by required testing performed more frequently than the 18-month (or 36-month) surveillance being extended; or (c)

The cause can be attributed to an associated event such as a preventative maintenance task, human error, previous modification, or previously existing design deficiency; or that were subsequently re-performed successfully with no intervening corrective maintenance (e.g., plant conditions or malfunctioning measurement and test equipment may have caused aborting the test performance).

These categories of failures are not related to potential unavailability due to testing interval extension, and are therefore not listed or further evaluated in this submittal. This review of surveillance test history validated the conclusion that the impact, if any, on system availability will be minimal as a result of the change to a 24-month and 48-month testing frequency. Specific SR test failures, and justification for this conclusion, are discussed in Attachment 3.1 STEP 3: Licensees should confirm that the performance of surveillances at the bounding surveillance interval limit provided to accommodate a 24-month fuel cycle would not invalidate any assumption in the plant licensing basis.

HCGS EVALUATION As part of the evaluation of each affected SR, the impact of the changes against the assumptions in the HCGS licensing basis were reviewed. In general, testing interval changes have no impact on the plant licensing basis. In some cases, the change to a 24-month fuel cycle may require a change to licensing basis information as described in the Updated Final Safety Analysis Report (UFSAR). However, no changes requiring NRC review and approval have been identified. Therefore, the UFSAR changes associated with fuel cycle extension to 24 months will be drafted in accordance with HCGS procedures and will be submitted in accordance with 10 CFR 50.71(e).

If the proposed SR interval changes were to lead to degrading performance, PSEG would address such degradation as a routine part of Maintenance Rule Program evaluations or, in some cases, evaluations conducted under the surveillance frequency control program (SFCP). Systems and functions included in the scope of the Maintenance Rule are monitored under the Maintenance Rule program. Component and/or train level monitoring is required for high risk SSCs associated with surveillance frequencies that have been extended using the SFCP. If component and/or train monitoring is not already performed as part of the Maintenance Rule performance monitoring for SSCs affected by a SFCP surveillance frequency change, additional monitoring is required under the HCGS SFCP.

4.1.2 Calibration Changes GL 91-04 identifies seven steps for the evaluation of instrumentation calibration changes.

STEP 1: Confirm that instrument drift as determined by as-found and as-left calibration data 1 For SR 4.4.2.2, a technical variation is being taken to this step in GL-91-04. This is described in, Section 2.3.

LR-N24-0004 LAR H24-01 Page 22 of 29 from surveillance and maintenance records has not, except on rare occasions, exceeded acceptable limits for a calibration interval.

HCGS EVALUATION The effect of the proposed calibration SR interval changes on the associated TS instrumentation was evaluated by performing a review of the SR test history for the affected instrumentation including where appropriate, an instrument drift study. In performing the historical evaluation, the recorded channel calibration data for associated instruments for at least five operating cycles were retrieved for the 18-month SR extensions. For the 36-month extensions, two operating cycles were retrieved. By obtaining this past recorded calibration data, an acceptable basis for drawing conclusions about the expectation of satisfactory performance can be made.2 The Surveillance Failure Analysis identified no SR failures that would call into question the acceptability of the proposed extension of surveillance intervals. Furthermore, the drift evaluations for the Calibration SRs do not result in any changes to TS Allowable Values (AV).

STEP 2: Confirm that the values of drift for each instrument type (make, model, and range) and application have been determined with a high probability and a high degree of confidence. Provide a summary of the methodology and assumptions used to determine the rate of instrument drift with time based upon historical plant calibration data.

HCGS EVALUATION A listing of the instrument make, model, and range affected by this submittal is provided in Attachment 4 to this Enclosure. The effect of longer calibration intervals on the TS instrumentation was evaluated by performing an instrument drift study. By obtaining past recorded calibration data, analyses were performed to determine a statistically valid representation of instrument drift.

The methodology used to perform the drift analysis is consistent with the methodology utilized by other utilities requesting transition to a 24-month fuel cycle. The methodology is also based on Electric Power Research Institute (EPRI) TR-103335, "Statistical Analysis of Instrument Calibration Data," and is summarized in Attachment 5.

STEP 3: Confirm that the magnitude of instrument drift has been determined with a high probability and a high degree of confidence for a bounding calibration interval of 30 months for each instrument type (make, model number, and range) and application that performs a safety function. Provide a list of the channels by TS section that identifies these instrument applications.

HCGS EVALUATION In accordance with the methodology described in Attachment 5, the magnitude of instrument drift has been determined with a high probability and a high degree of confidence (typically 95/95) for a bounding calibration interval of 30 months for the 2 For SR 4.3.7.5, Instrument 14, a technical variation is being taken to this step in GL-91-04. This is described in Attachment 3, Section 2.3.

LR-N24-0004 LAR H24-01 Page 23 of 29 18-month extensions (and 60-months for the 36-month extensions) for each instrument make, model, and range. For instruments not in service long enough to establish a projected drift value, or where an insufficient number of calibrations have been performed to utilize the statistical methods (i.e., fewer than 30 calibrations for any given group of instruments), the proposed allowance to apply 1.25 grace to SRs with frequency of 24 months is based on justification obtained from analysis using the method presented in Attachment 5. The list of affected channels by TS section, including instrument make, model, and range, is provided in Attachment 4.

STEP 4: Confirm that a comparison of the projected instrument drift errors has been made with the values of drift used in the setpoint analysis. If this results in revised setpoints to accommodate larger drift errors, provide proposed TS changes to update trip setpoints. If the drift errors result in revised safety analysis to support existing setpoints, provide a summary of the updated analysis conclusions to confirm that safety limits and safety analysis assumptions are not exceeded.

HCGS EVALUATION The projected 30-month (and 60-month) drift values were compared to the design allowances as calculated in the associated instrument setpoint analyses. Required changes in drift values were incorporated into the setpoint calculations, and the analysis of the setpoint, Allowable Value, and/or analytical limit was reviewed. No changes to any TS setpoints or Allowable Values were required. No safety analysis revisions were required to support the existing TS setpoints.

STEP 5: Confirm that the projected instrument errors caused by drift are acceptable for control of plant parameters to effect a safe shutdown with the associated instrumentation.

HCGS EVALUATION discusses the evaluation of impact of drift on instrument setpoint and uncertainty calculations associated with increasing the calibration interval from 18 to 24 months (and 36 to 48 months). This evaluation includes instrumentation used for safe shutdown. The revised setpoint and uncertainty calculations change calibration information if needed to accommodate 24-month and 48-month calibration intervals. The changes in calibration information provide assurance that the instrumentation will perform with the required accuracy to effect a safe shutdown. The calibration information is implemented through plant calibration procedures.

STEP 6: Confirm that all conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for channel checks, channel functional tests, and channel calibrations.

HCGS EVALUATION The revised setpoint and uncertainty calculations result in changes to calibration information which are implemented through plant calibration procedures. The affected calibration surveillance procedures will be revised as part of implementation, prior to the first 24-month (or 48-month) cycle of operation. Existing plant processes ensure that the

LR-N24-0004 LAR H24-01 Page 24 of 29 conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for channel checks, channel functional tests and channel calibrations.

STEP 7: Provide a summary description of the program for monitoring and assessing the effects of increased calibration surveillance intervals on instrument drift and its effect on safety.

HCGS EVALUATION Instruments with TS calibration SR intervals extended to 24 months (and 48 months) will be monitored and trended in accordance with station procedures including recording of as-found and as-left calibration data.

As required by plant procedures, out of tolerance conditions are entered into the corrective action program. This approach will identify occurrences of instruments found outside of their Allowable Value and instruments whose performance is not as assumed in the drift or setpoint analysis. When the as found conditions are outside the Allowable Value, an evaluation will be performed in accordance within corrective action program to evaluate the effect, if any, on plant safety.

5.0 REGULATORY EVALUATION

NRC GL 91-04 provides generic guidance for evaluating surveillance test intervals for TS SRs to support a 24 month fuel cycle. This request for a license amendment provides the HCGS specific evaluation of each step outlined by the NRC in GL 91-04 and provides a description of the methodology used by PSEG to complete the evaluation for each specific TS SR being revised. PSEG has determined that the proposed changes do not require any exemptions or relief from regulatory requirements, other than the TS. The proposed changes do not affect conformance with any GDC described in the HCGS UFSAR as discussed below.

5.1 Applicable Regulatory Requirements/Criteria 5.1.1 10 CFR 50.36 10 CFR 50.36, Technical Specifications, defines the content required in licensee TS.

Specifically, 10 CFR 50.36(c)(3) requires that the TS include SRs relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The proposed changes increase SR intervals from 18 to 24 months (and in certain cases 36 months to 48 months). No SRs are eliminated by the proposed changes. The proposed SR interval changes have been evaluated using the guidance provided by GL 91-04. Based on this evaluation, the proposed SR interval changes continue to support compliance with 10 CFR 50.36(c)(3).

LR-N24-0004 LAR H24-01 Page 25 of 29 5.1.2 Applicable 10 CFR 50 Appendix A - General Design Criteria Criterion 18 Inspection and testing of electric power systems. Electric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features, such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components. The systems shall be designed with a capability to test periodically (1) the operability and functional performance of the components of the systems, such as onsite power sources, relays, switches, and buses, and (2) the operability of the systems as a whole and, under conditions as close to design as practical, the full operation sequence that brings the systems into operation, including operation of applicable portions of the protection system, and the transfer of power among the nuclear power unit, the offsite power system, and the onsite power system.

The proposed changes to SR intervals have no impact on the physical configuration, design, function, or capability to test electric power systems. Therefore, HCGS conformance to Criterion 18 is unaffected by the proposed changes.

Criterion 37 Testing of emergency core cooling system. The emergency core cooling system shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and performance of the active components of the system, and (3) the operability of the system as a whole and, under conditions as close to design as practical, the performance of the full operational sequence that brings the system into operation, including operation of applicable portions of the protection system, the transfer between normal and emergency power sources, and the operation of the associated cooling water system.

The proposed changes to SR intervals have no impact on the physical configuration, design, function, or capability to test emergency core cooling systems. Therefore, HCGS conformance to Criterion 37 is unaffected by the proposed changes.

Criterion 40 Testing of containment heat removal system. The containment heat removal system shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leak-tight integrity of its components, (2) the operability and performance of the active components of the system, and (3) the operability of the system as a whole, and under conditions as close to the design as practical the performance of the full operational sequence that brings the system into operation, including operation of applicable portions of the protection system, the transfer between normal and emergency power sources, and the operation of the associated cooling water system.

The proposed changes to SR intervals have no impact on the physical configuration, design, function, or capability to test containment heat removal systems. Therefore, HCGS conformance to Criterion 40 is unaffected by the proposed changes.

LR-N24-0004 LAR H24-01 Page 26 of 29 Criterion 43 Testing of containment atmosphere cleanup systems. The containment atmosphere cleanup systems shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and performance of the active components of the systems such as fans, filters, dampers, pumps, and valves and (3) the operability of the systems as a whole and, under conditions as close to design as practical, the performance of the full operational sequence that brings the systems into operation, including operation of applicable portions of the protection system, the transfer between normal and emergency power sources, and the operation of associated systems.

The proposed changes to intervals have no impact on the physical configuration, design, function, or capability to test containment atmosphere cleanup systems. Therefore, HCGS conformance to Criterion 43 is unaffected by the proposed changes.

Criterion 46 Testing of cooling water system. The cooling water system shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leak-tight integrity of its components, (2) the operability and the performance of the active components of the system, and (3) the operability of the system as a whole and, under conditions as close to design as practical, the performance of the full operational sequence that brings the system into operation for reactor shutdown and for loss-of-coolant accidents, including operation of applicable portions of the protection system and the transfer between normal and emergency power sources.

The proposed changes to SR intervals have no impact on the physical configuration, design, function, or capability to test cooling water systems. Therefore, HCGS conformance to Criterion 46 is unaffected by the proposed changes.

5.2 Precedents NRC GL 91-04 provides generic guidance for evaluating SR interval changes from 18 to 24 months. GL 91-04 identifies specific considerations to be addressed in applications to change SR intervals in support of a 24MFC. The methodology and approach taken by PSEG in addressing the GL 91-04 considerations after adoption of a SFCP is consistent with that used to support previous 24MFC license amendments. Specifically:

1.

Fermi 2, Amendment 218, dated February 24, 2021 (Reference 5)

2.

Prairie Island Nuclear Generating Plant, Units 1 and 2, Amendments 239 and 237, dated July 28, 2022 (Reference 4) 5.3 No Significant Hazards Consideration Analysis PSEG is requesting an amendment of the Operating License for HCGS to revise TS surveillance and testing requirements to accommodate a 24-month fuel cycle. PSEG has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

LR-N24-0004 LAR H24-01 Page 27 of 29

1.

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

Response: No.

The proposed TS changes involve a change in the surveillance testing intervals to facilitate a change in the operating cycle length. The proposed TS changes do not physically impact the plant. The proposed TS changes do not degrade the performance of, or increase the challenges to, any safety systems assumed to function in the accident analysis.

The proposed TS changes do not impact the usefulness of the surveillance and testing requirements in evaluating the operability of required systems and components, or the way in which the surveillances are performed. In addition, the frequency of surveillance testing is not considered initiators of any analyzed accident, nor do revisions to the frequency introduce any accident initiators. Therefore, the proposed change does not involve a significant increase in the probability of an accident previously evaluated.

The consequences of a previously evaluated accident are not significantly increased.

The proposed changes to surveillance frequencies do not affect the performance of any equipment credited to mitigate the radiological consequences of an accident. Evaluation of the proposed TS changes demonstrated that the availability of credited equipment is not significantly affected because of other more frequent testing that is performed, the availability of redundant systems and equipment, and the high reliability of the equipment. Historical review of surveillance test results and associated maintenance records did not find evidence of failures that would invalidate the above conclusions.

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

2.

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

Response: No.

The proposed TS changes involve a change in the surveillance testing intervals to facilitate a change in the operating cycle length. The proposed TS changes do not introduce any failure mechanisms of a different type than those previously evaluated, since there are no physical configuration or design changes being made to the facility.

No new or different equipment is being installed. No installed equipment is being operated in a different manner. As a result, no new failure modes are being introduced.

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

3.

Do the proposed changes involve a significant reduction in a margin of safety?

Response: No.

LR-N24-0004 LAR H24-01 Page 28 of 29 The proposed TS changes involve a change in the surveillance testing intervals to facilitate a change in the operating cycle length. The impact of these changes on system availability is not significant, based on other more frequent testing that is performed, the existence of redundant systems and equipment, and overall system reliability.

The proposed changes do not significantly impact the condition or performance of structures, systems, and components relied upon for accident mitigation. The proposed changes do not result in any hardware changes or in any changes to the analytical limits assumed in accident analyses. Existing operating margin between plant conditions and actual plant setpoints is not significantly reduced due to these changes. The proposed changes do not significantly impact any safety analysis assumptions or results.

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

==

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.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment 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. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment 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 amendment.

7.0 REFERENCES

1. Letter from NRC to Thomas Joyce, Hope Creek Generating Station - Issuance of Amendment RE: Relocation of Specific Surveillance Frequencies to a Licensee-Controlled Program Based On Technical Specifications Task Force (TSTF) Change TSTF-425 (TAC No. ME3545), dated February 25, 2011 [ML103410243]

2. NRC Generic Letter 91-04, Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle, dated April 2, 1991

3. PSEG letter to NRC, "Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program, dated March 19, 2010

[ML100900224]

LR-N24-0004 LAR H24-01 Page 29 of 29

4. Letter from NRC to Christopher Domingos, Prairie Island Nuclear Generating Plant, Units 1 and 2 - Issuance of Amendments 239 and 227 Re: 24-Month Operating Cycle (EPID L-2021-LLA-0146), dated July 28, 2022 [ML22166A389]

5. Letter from NRC to Peter Dietrich, Fermi 2 - Issuance of Amendment No. 218 -

Revision to Technical Specifications to Change Certain Surveillance Intervals to Accommodate a 24-Month Fuel Cycle (EPID L-2019-LLA-0249), dated February 24, 2021 [ML20358A155]

LR-N24-0004 LAR H24-01 Mark-up of the Current Hope Creek Generating Station Facility Operating License Pages The following pages for Renewed Facility Operating License (RFOL) NPF-57 are affected by this change request:

RFOL Page C.(29) 16 TS Table 1.1 1-10 SR 4.6.1.2.f, g & h 3/4 6-4 6.16d 6-27 Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from the alternate seismic approach (referenced above) to a seismic probabilistic risk assessment approach).

D.

The facility requires exemptions from certain requirements of 10 CFR Part 50 and 10 CFR Part 70. An exemption from the criticality alarm requirements of 10 CFR 70.24 was granted in Special Nuclear Material License No. 1953, dated August 21, 1985. This exemption is described in Section 9.1 of Supplement No. 5 to the SER. This previously granted exemption is continued in this renewed operating license. An exemption from certain requirements of Appendix A to 10 CFR Part 50, is described in Supplement No. 5 to the SER.

This exemption is a schedular exemption to the requirements of General Design Criterion 64, permitting delaying functionality of the Turbine Building Circulating Water System-Radiation Monitoring System until 5 percent power for local indication, and until 120 days after fuel load for control room indication (Appendix R of SSER 5). Exemptions from certain requirements of Appendix J to 10 CFR Part 50, are described in Supplement No. 5 to the SER. These include an exemption from the requirement of Appendix J, exempting main steam isolation valve leak-rate testing at 1.10 Pa (Section 6.2.6 of SSER 5); an exemption from Appendix J, exempting Type C testing on traversing incore probe system shear valves (Section 6.2.6 of SSER 5); an exemption from Appendix J, exempting Type C testing for instrument lines and lines containing excess flow check valves (Section 6.2.6 of SSER 5); and an exemption from Appendix J, exempting Type C testing of thermal relief valves (Section 6.2.6 of SSER 5).

These exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. These exemptions are hereby granted. The special circumstances regarding each exemption are identified in the referenced section of the safety evaluation report and the supplements thereto. These exemptions are granted pursuant to 10 CFR 50.12. With these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E.

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, submitted by letter dated May 19, 2006 are entitled: Salem-Hope Creek Nuclear Generating Station Security Training and Qualification Plan, and Salem-Hope Creek Nuclear Generating Station Security Contingency Plan. The plans contain Safeguards Information protected under 10 CFR 73.21.

Renewed License No. NPF-57 Amendment No. 224 (29) 24 Month Fuel Cycle Exception to Surveillance Frequency Control Program The 24 Month Fuel Cycle-related Surveillance Requirement Frequency changes approved by the NRC in License Amendment xxx are not subject to the Surveillance Frequency Control Program (SFCP) requirements on a one-time extension basis. Subsequent extensions are subject to the SFCP requirements specified in the Technical Specifications.

NOTATION s

0 w

M Q

SA A

R SIU p

z N.A.

HOPE CREEK TABLE 1.1 SURVEILLANCE FREQUENCY NOTATION FREQUENCY At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

At least once per 7 days.

At least once per 31 days.

At least once per 92 days.

At least once per 184 days.

At least once per 366 days.

At least once per 18 months (550 days).

Prior to each reactor startup.

Prior to each radioactive release.

Our;ng startup, prior to exceeding 30%

of RATED THERMAL POWER, ff not performed w;thfn the previous 7 days Not applicable.

1*10 Amendment No.

18 AUG 2 9 1988 24 731

CONTAINMENT SYSTEMS

_)

SURVEILLANCE REQUIREMENTS (Continued)

/

d.

DELETED.

e.

DELETED.

f.

Main steam line isolation valves shall be leak tested at least once per 18 months.

g.

Containment isolation valves which form the boundry for the long-term seal of the feedwater lines shall be hydrostatically tested at 1.10 Pa, 55.7 psig, at least once per 18 months.

h.

All containment isolation valves in hydrostatically tested lines which penetrate the primary containment shall be leak tested at least once per 18 months.

i.

DELETED.

j.

DELETED.

HOPE CREEK 3/4 6-4 Amendment No. 174 24

ADMINISTRA.TIVE CONTROLS 6.16 CONTROL ROOM ENVELOPE HABITABILITY PROGR.ZIJ1 (Continued)

d.

Measurement, at designated locations, of the ~RE. pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of ~peration by one train of the Control Room Emeigency Filtration System, operating at the flow rate rcq~ired by Surveillance Requirement 4.7.2.1.c.1, at* a Frequency of 36 months on a STAGGERED TEST BASIS. The results shall be trended und used as part of the*36 month assessment of the CRE boundary.

e.

The quantitative limits on unfiltered air inleakage into the CRE.

These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA ~onsequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f.

The provisions of Specification 4.0.2 are applicable.to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d,* respectively.

HOPE CREEK 6-27 Amendment No. 173 48 LR-N24-0004 LAR H24-01 Technical Specification Bases Changes (one total page)

3/4.0 APPLICABILITY BASES (Con't)

Specification 4.0.2 establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not intended that this provision be used repeatedly to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

Specification 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable, or an affected variable outside the specified limits, when a Surveillance has not been performed within the specified frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with TS 4.0.2, and not at the time that the specified frequency was not met.

This delay period provides adequate time to perform Surveillances that have been missed. This delay period permits the performance of a Surveillance before complying with Required Actions or other remedial measures that might preclude performance of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering Mode 1 after each fuel loading, or in accordance with 10CFR50 Appendix J, as modified by approved exemptions, etc.) is discovered not to have been performed when specified, SR 4.0.3 allows the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity. SR 4.0.3 also provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

SR 4.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed. Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 4.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact; the adjacent, physically connected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed. For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

HOPE CREEK B 3/4 0-8 Amendment No. 214 (PSEG Issued)

LR-N24-0004 LAR H24-01 Page 1 of 70 GL 91-04 Evaluation

1.

BACKGROUND Technical Specification (TS) Surveillance Requirement (SR) Frequency changes are required to accommodate a 24-month fuel cycle for Hope Creek Generating Station (HCGS). PSEG Nuclear LLC (PSEG) is proposing changes in this submittal that were evaluated in accordance with the guidance provided in Nuclear Regulatory Commission (NRC) Generic Letter (GL) 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. GL 91-04 provides NRC Staff guidance that identifies the types of information that must be addressed when proposing extensions of TS SR Frequency intervals from 18 months to 24 months.

Historical surveillance test data and associated maintenance records were reviewed in evaluating the effect of these changes on safety. In addition, the licensing basis was reviewed to ensure it was not invalidated. Based on the results of these reviews, it is concluded that there is no adverse effect on plant safety due to increasing the surveillance test intervals from 18 to 24 months with the continued application of the 25% grace period allowed by SR 4.0.2. Similarly, the GL 91-04 process was used to evaluate certain SRs with Frequencies that had already been extended to 36 months under the SFCP, but now seek extension to 48 months. The selected 36-month SR Frequency extensions are a small subset of the overall population of 36-month SRs, but are necessary to support the continuance of channelized outages.

GL 91-04 addressed steam generator inspections, which are not applicable to HCGS, and are therefore not discussed in this submittal. Additionally, the GL addressed interval extensions to leak rate testing pursuant to 10 CFR Part 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors." This is also not discussed in this submittal because PSEG has adopted 10 CFR 50, Appendix J, Option B, as implemented by TS 6.8.4.f, "Primary Containment Leakage Rate Testing Program," which negates the need for 10 CFR 50 Appendix J exemptions.

2.

EVALUATION In GL 91-04, the NRC provided generic guidance for evaluating a 24-month surveillance test interval for TS SRs. The submittal Enclosure defines each step outlined by the NRC in GL 91-04, and provides a description of the methodology used by PSEG to complete the evaluation for each specific TS SR line item. The methodology utilized in the HCGS drift analysis is similar to the methodology used for previous plant submittals such as the Fermi 2 submittal. There have been minor revisions incorporated into the HCGS drift design guide based on NRC comments or Requests for Additional Information from previous 24-month fuel cycle extension submittals; e.g., PSEG added the requirement that 30 samples were generally required to produce a statistically significant sample set.

For the identified surveillances being extended from 18-months to 24-months, at least five operating cycles of SR performances were retrieved. These were generally performed between the Fall 2013 Refueling Outage and the Fall 2022 Refueling Outage.1 It has been concluded, 1 For SR 4.3.7.5, Instrument 14, a technical variation is taken from GL 91-04. Refer to Section 2.3.

LR-N24-0004 LAR H24-01 Page 2 of 70 based on engineering judgment, that three 30-month periods provide adequate performance test history. For each of the identified surveillances being extended from 36-months to 48-months, at least two operating cycles SR performances were retrieved. These were generally performed during the Spring 2021 Refueling Outage and the Spring 2024 Refueling Outage. It has been concluded, based on engineering judgment, that two 36-month periods provide adequate performance test history.

In addition to evaluating the historical drift associated with current 18-month and 36-month calibrations, the failure history of each 18-month and 36-month surveillance was also evaluated.

With the extension of the testing frequency to 24 months, there will be a longer period between each surveillance performance. If a failure that results in the loss of the associated safety function should occur during the operating cycle that would only be detected by the performance of the 18-month TS SR, then the increase in the surveillance testing interval might result in a decrease in the associated function's availability. Furthermore, potential common failures of similar components tested by different surveillances were also evaluated. This additional evaluation determined whether there is evidence of repetitive failures among similar plant components.

The surveillance failures detailed with each SR exclude failures that:

(a) Did not impact a TS safety function or TS operability; (b) Are detectable by required testing performed more frequently than the 18-month surveillance being extended; or (c) The cause can be attributed to an associated event such as a preventative maintenance task, human error, previous modification or previously existing design deficiency, or that were subsequently re-performed successfully with no intervening corrective maintenance (e.g., plant conditions or malfunctioning measurement and test equipment may have caused aborting the test performance).

These categories of failures are not related to potential unavailability due to testing interval extension, and are therefore not listed or further evaluated in this submittal.

The following sections summarize the results of the failure history evaluation. The evaluation confirmed that the impact on system availability, if any, would be small as a result of the change to a 24-month (or 48-month) testing frequency, as applicable.

The proposed TS changes related to GL 91-04 test interval extensions have been divided into two categories. The categories are: (A) changes to surveillances other than channel calibrations, identified as "Non-Calibration Changes," and (B) changes involving the channel calibration frequency, identified as "Calibration Changes."

2.1 Non-Calibration Changes for 18-Month and 36 Month Frequency Extensions For the non-calibration 18-month surveillances (and by extension the 36-month surveillances),

GL 91-04 requires the following information to support conversion to a 24-month frequency:

1) Licensees should evaluate the effect on safety of an increase in 18-month surveillance intervals to accommodate a 24-month fuel cycle. This evaluation should support a conclusion that the effect on safety is small.

LR-N24-0004 LAR H24-01 Page 3 of 70

2) Licensees should confirm that historical plant maintenance and surveillance support this conclusion.

3) Licensees should confirm that the assumptions in the plant licensing basis would not be invalidated on the basis of performing any surveillance at the bounding surveillance interval limit provided to accommodate a 24-month fuel cycle.

In consideration of these confirmations, GL 91-04 provides that licensees need not quantify the effect of the change in surveillance intervals on the availability of individual systems or components.

The following non-calibration TS SRs are proposed for revision to a 24-month frequency. The associated qualitative evaluation is provided for each of these changes, which concludes that the effect on plant safety is small, that the change does not invalidate any assumption in the plant licensing basis, and that the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. These conclusions have been validated by a review of the surveillance test history at HCGS as summarized below for each SR.

2.1.1 Non-Calibration Changes for 18-Month Frequency Extensions The following SR performance intervals are being revised from 18 months to 24 months:

TS 3/4.1.3 Control Rods SR 4.1.3.1.4 The scram discharge volume shall be determined OPERABLE by demonstrating:

a. The scram discharge volume vent and drain valves OPERABLE in accordance with the Surveillance Frequency Control Program, by verifying that the drain and vent valves:

1. Close within 30 seconds after receipt of a signal for control rods to scram, and

2. Open when the scram signal is reset.

SR 4.1.3.1.4.a.1 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had one failure that was identified as a unique failure which is not indicative of a repetitive time-based failure mechanism.

1) After a reactor scram, a Scram Discharge Volume Vent and Drain Functional Test was performed. The valve HV-F181 closure time was greater than 30 seconds. HV-F181 was reworked with a packing adjustment.

As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 4 of 70 SR 4.1.3.1.4.a.2 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had one failure that was identified as a unique failure which is not indicative of a repetitive time-based failure mechanism.

1) Following the scram reset at the beginning of RF23, the SDV vent and drain valves indicated open, however, water is not draining from the volume as it should. At the time this condition was identified, the reactor was shutdown and was post-scram.

The condition was apparent when scram was reset and volume did not drain in the typical amount of time. Found valve F011 actuator and valve stem had become uncoupled with coupling attached to actuator stem. Removed and attached to valve stem and was able to hand wheel valve open. Bolt for coupling is bent and needs to be replaced (3" x 3/8 bolt). Replaced coupling replaced and retested SAT.

As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.1.5 Standby Liquid Control System SR 4.1.5 The standby liquid control system shall be demonstrated OPERABLE:

d. In accordance with the Surveillance Frequency Control Program by:

2. Demonstrating that all heat traced piping between the storage tank and the injection pumps is unblocked and then draining and flushing the piping with demineralized water.

3. Demonstrating that the storage tank heaters are OPERABLE by verifying the expected temperature rise of the sodium pentaborate solution in the storage tank after the heaters are energized.

SR 4.1.5.d.2 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.1.5.d.3 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

LR-N24-0004 LAR H24-01 Page 5 of 70 A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.3.1 Reactor Protection System Instrumentation SR 4.3.1.1 Each reactor protection system instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL FUNCTIONAL TEST]

operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.1.1-1. [Functional Unit 11]

The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.3.1.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed in accordance with the Surveillance Frequency Control Program. Functional Unit 2.a, 2.b, 2.c, 2.d, and 2.f do not require separate LOGIC SYSTEM FUNCTIONAL TESTS. The LOGIC SYSTEM FUNCTIONAL TEST for APRM Function 2.e includes simulating APRM and OPRM trip conditions at the APRM channel inputs to the voter channel to check all combinations of two tripped inputs to the 2-Out-Of 4 voter logic in the voter channels.

Functional Unit 1.a The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Functional Unit 1.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

LR-N24-0004 LAR H24-01 Page 6 of 70 A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Functional Unit 2.e The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Functional Unit 7 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Functional Unit 8.a The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Functional Unit 8.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this LR-N24-0004 LAR H24-01 Page 7 of 70 SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Functional Unit 11 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.3.1.3 The REACTOR PROTECTION SYSTEM RESPONSE TIME of each reactor trip functional unit shall be demonstrated to be within its limit in accordance with the Surveillance Frequency Control Program. Neutron detectors are exempt from response time testing. For the Reactor Vessel Steam Dome Pressure - High Functional Unit and the Reactor Vessel Water Level - Low, Level 3 Functional Unit, the sensor is eliminated from response time testing for RPS circuits.

[UFSAR Table 7.2-3 Functional Units 3, 4, and 5]

Functional Unit 3 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Functional Unit 4 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 8 of 70 Functional Unit 5 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.3.2 Isolation Actuation Instrumentation SR 4.3.2.1 Each isolation actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL FUNCTIONAL TEST]

operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.2.1-1. Trip Functions 3.g footnote (a), 4.g. footnote (a), 5.j, 6.j, and 7.c footnote (a)]

Trip Function 3.g footnote (a)

The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had two failures that were identified as unique failures which are not indicative of a repetitive time-based failure mechanism.

1) Valve AB-HV-F019 indicates dual position. The valve was removed from its installed location, refurbished and reinstalled. The valve will "AUTO-CLOSE" upon receipt of a Group 1 primary containment isolation signal. The valve was unable to be closed from the control room to establish the required alignment to perform Procedure HC.OP-LR, AB-0005. To perform the leak rate test, the MOV must be closed by normal means. The valve is normally OPEN in series with 1ABHV-F016 and 1ABHV-F033 or 1ABHV-F021, to drain the inboard MSIV above the seat drain area until approximately 15% load on reactor startup. Valve 1ABHV-F019 is controlled via an open/close momentary contact push button located on the 10C651 panel in the main control room. It has an active "Safety-Related" function to close to provide outboard containment isolation of the inboard MSIV above seat drain lines.

2) The E Traversing Incore Probe (TIP) failed to retract when "A" manual NSSS initiation signal was given. Replaced K11 relay in "E" Tip Valve Control Monitoring drawer.

No other previous failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 9 of 70 Trip Function 4.g The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

No previous failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 5.j The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 6.j The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 7.c footnote (a)

The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

No previous failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 10 of 70 SR 4.3.2.3 The ISOLATION SYSTEM RESPONSE TIME of each isolation trip function shall be demonstrated to be within its limit in accordance with the Surveillance Frequency Control Program. Radiation detectors are exempt from response time testing. The sensor is eliminated from response time testing for MSIV isolation logic circuits of the following trip functions: Reactor Vessel Water Level - Low Low Low, Level 1; Main Steam Line Pressure - Low; Main Steam Line Flow -

High. [Trip Functions 2.c and d]

Trip Function 2.c The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 2.d The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.3.3 Emergency Core Cooling System Actuation Instrumentation SR 4.3.3.1 Each ECCS actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL FUNCTIONAL TEST]

operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.3.1-1. [Trip Functions 3.g, 4.h and i]

Trip Function 3.g The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 11 of 70 Trip Function 4.h The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 4.i The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.3.3.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed in accordance with the Surveillance Frequency Control Program. [Trip Functions 1.b and d, 2.b, c, and 2.d, 3.b, c, and f, 4.b, c, d, e, g, h and i]

Trip Function 1.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 1.d The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this LR-N24-0004 LAR H24-01 Page 12 of 70 SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 2.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that the instrumentation had no previous failures of the TS function that would have prevented the performance of the required safety function of the equipment. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 2.c The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 2.d The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 3.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

LR-N24-0004 LAR H24-01 Page 13 of 70 A review of the surveillance history identified one failure that was a unique failure which is not indicative of a repetitive time-based failure mechanism.

1) The performance of this procedure could not be completed due to equipment failure.

Troubleshooting found H1FD-10-P-213 failed to start during the performance of HC.IC-FT.BJ- 0007. Failed relay H1BJ-1BJYY-K056-E41A was found by troubleshooting.

Replacement of the relay was performed.

No other previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 3.c The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 3.f The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Functions 4.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that the instrumentation had no previous failures of the TS function that would have prevented the performance of the required safety function of the equipment. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 14 of 70 Trip Functions 4.c The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

No failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Functions 4.d The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period No failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Functions 4.e The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

No failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Functions 4.g The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

No failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 15 of 70 Trip Functions 4.h The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

No failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Functions 4.i The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had one failure that was identified as a unique failure which is not indicative of a repetitive time-based failure mechanism.

1) SRV F013A would not de-energize. This documents that the HS-F013A2 switch did not function as intended and was difficult to actuate. This is therefore considered a functional failure (conservatively). Replaced switch assembly with new parts from store room.

No other previous failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.3.5 Reactor Core Isolation Cooling System Actuation Instrumentation SR 4.3.5.1 Each RCIC system actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL FUNCTIONAL TEST]

operations at the frequencies shown in Table 4.3.5.1-1. [Functional Unit d Footnote (a)]

The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 16 of 70 SR 4.3.5.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed in accordance with the Surveillance Frequency Control Program. [Functional Units c and d]

Functional Unit c The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Functional Unit d The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.3.6 Control Rod Block Instrumentation SR 4.3.6 Each of the above required control rod block trip systems and instrumentation channels shall be demonstrated OPERABLE by the performance ofthe

[CHANNEL FUNCTIONAL TEST] operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.6-1. The provisions of Specification 4.0.4 arenot applicable for entry into OPERATIONAL CONDITION 2 from OPERATIONAL CONDITION 1 for the Source Range Monitors or the Intermediate Range Monitors. [Trip Function 7]

The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 17 of 70 TS 3/4.3.9 Feedwater/Main Turbine Trip System Actuation Instrumentation SR 4.3.9.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed in accordance with the Surveillance Frequency Control Program. [Functional Unit 1]

The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.3.10 Mechanical Vacuum Pump Trip Instrumentation SR 4.3.10 Each channel of the Main Steam Line Radiation - High, High function for the mechanical vacuum pump trip shall be demonstrated OPERABLE by:

d. Performance of a LOGIC SYSTEM FUNCTIONAL TEST, including mechanical vacuum pump trip breaker actuation, in accordance with the Surveillance Frequency Control Program.

The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.4.3 Reactor Coolant Leakage System SR 4.4.3.2.2 Each reactor coolant system pressure isolation valve specified in Table 3.4.3.2-1 shall be demonstrated OPERABLE by leak testing pursuant to the INSERVICE TESTING PROGRAM and verifying the leakage of each valve to be within the specified limit:

a. In accordance with the Surveillance Frequency Control Program.

The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 18 of 70 TS 3/4.5.1 ECCS - Operating SR 4.5.1 The emergency core cooling systems shall be demonstrated OPERABLE by:

c. In accordance with the Surveillance Frequency Control Program:

1. For 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.

2. For the HPCI system, verifying that:

b) The suction is automatically transferred from the condensate storage tank to the suppression chamber on a condensate storage tank water level - low signal and on a suppression chamber - water level high signal.

d. For the ADS:

2. In accordance with the Surveillance Frequency Control Program:

a) Performing a system functional test which includes simulated automatic actuation of the system throughout its emergency operating sequence, but excluding actual valve actuation.

b) Verify that when tested pursuant to the INSERVICE TESTING PROGRAM, that each ADS valve is capable of being opened.

SR 4.5.1.c.1 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.5.1.c.2.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 19 of 70 SR 4.5.1.d.2.a The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.5.1.d.2.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had one failure that was identified as a unique failure which is not indicative of a repetitive time-based failure mechanism.

1) SRV F013A would not de-energize. This documents that the HS-F013A2 switch did not function as intended and was difficult to actuate. This is considered a functional failure (conservatively).

No other previous failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.5.2 RPV Water Inventory Control SR 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.

The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 20 of 70 TS 3/4.6.1 Primary Containment SR 4.6.1.2

f. Main steam line isolation valves shall be leak tested at least once per 18 months.

g. Containment isolation valves which form the boundray for the long-term seal of the feedwater lines shall be hydrostatically tested at 1.10 Pa, 55.7 psig, at least once per 18 months.

h. All containment isolation valves in hydrostatically tested lines which penetrate the primary containment shall be leak tested at least once per 18 months.

SR 4.6.1.2.f The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance history identified five (5) failures. These five failures discussed below are considered repetitive failures with respect to the As-Found local leakage rate testing (LLRT) values of the MSIVs; however, not all failures are on the same valve or same penetration or are a result of the same cause of the failure. A review of the surveillance history concluded that these are not indicative of a repetitive time-based failure mechanism and are considered to be unique failures.

1) Containment Leak Rate Test for Penetration P1C reflects a leakage rate of 28,343 sccm with an Admin Limit of 11,000 sccm and an IST (T/S) Limit of 19,050 sccm. A large packing leak was identified on F028C. (October 2016)

2) Containment Leak Rate Test Data Sheet for Penetration P1C (testing only F022C valve) reflects a leakage rate of 31,146 sccm with an Admin Limit of 11,000 sccm and an IST (T/S) Limit of 19,050 sccm. Work Order activities included disassembly of valve for internal inspection and necessary repairs. Replacement of a scored stem addressed this condition. (April 2021)

3) Measured leakage was above the IST Limit. The measured leakage at valve F028A was 28550 sccm at 5.49 psig. The Technical Specification limit is 19050 sccm and the Administrative Limit is 11000 sccm. The valve was demonstrated to close as expected.

Since the valve responded to the isolation signal and was able to move to the correct safety position, the valve was functional and Function 2 was supported. The MSIV outboard actuator/manifold inspections/walkdown revealed 2 leaking pipe solder joints.

(April 2018)

4) During testing of F028A, the test result was 35,900 sccm, exceeding the Admin Limit of 11,000 sccm and the IST (T/S) Limit of 19,050 sccm. This condition was addressed by filing some identified galling on the poppet body and some machining of the valve seat. This limited scope of repairs resulted in a high as left value but within the LLRT/Technical Specification limit. (October 2019)

5) During testing of F028A, the test result was 92,711 sccm. The valve underwent a major overhaul and repair involving the poppet, poppet seat, seat lapping and all new bolts and gaskets. (April 2021)

LR-N24-0004 LAR H24-01 Page 21 of 70 No other previous failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.6.1.2.g The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had one failure that was identified as a unique failure which is not indicative of a repetitive time-based failure mechanism.

1) Injection Header Valves 1AEHV-F032B AND 1BDHV-F013 were unable to achieve test pressure for the test required 55.7 psig. Maximum pressure obtained while pressurizing through the water test rig was approximately 44 psig. The inspection determined the combination of hinge arm wear, hinge pin wear, and a smaller gap between the hinge arm and disc prevented the valve disc from properly seating resulting in the high leak rate and the failed LLRT.

No other previous failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.6.1.2.h The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this system had one failure that was identified as a unique failure which is not indicative of a repetitive time-based failure mechanism.

1) The observed leakage of valve 1FDV-004 was >5 gpm. Upon performance of the test, the line would not maintain full with test rig or demineralized water. Repacked the valve.

Disassembled, removed old worn pieces/parts and replaced with new disc/arm/nut.

Reassembled and cleaned valve and reconditioned seating surfaces.

No other previous failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 22 of 70 TS 3/4.6.2 Depressurization Systems SR 4.6.2.1 The suppression chamber shall be demonstrated OPERABLE:

e. In accordance with the Surveillance Frequency Control Program by a visual inspection of the accessible interior and exterior of the suppression chamber.

f. In accordance with the Surveillance Frequency Control Program by conducting a drywell-to-suppression chamber bypass leak test at an initial differential pressure of 0.80 psi and verifying that the differential pressure does not decrease by more than 0.24 inch of water per minute for a period of 10 minutes. If any drywell-to-suppression chamber bypass leak test fails to meet the specified limit, the test schedule for subsequent tests shall be reviewed and approved by the Commission. If two consecutive tests fail to meet the specified limit, a test shall be performed at least every 9 months until two consecutive tests meet the specified limit, at which time the Surveillance Frequency Control Program schedule may be resumed.

SR 4.6.2.1.e The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.6.2.1.f The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.6.3 Primary Containment Isolation Valves SR 4.6.3.4 In accordance with the Surveillance Frequency Control Program, verify that a representative sample of reactor instrumentation line excess flow check valves actuates to the isolation position on a simulated instrument line break signal.

The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

LR-N24-0004 LAR H24-01 Page 23 of 70 A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.6.3.5 Each traversing in-core probe system explosive isolation valve shall be demonstrated OPERABLE:

b. In accordance with the Surveillance Frequency Control Program by removing the explosive squib from at least one explosive valve, and initiating the explosive squib. The replacement charge for the exploded squib shall be from the same manufactured batch as the one fired or from another batch which has been certified by having at least one of that batch successfully fired. No squib shall remain in use beyond the expiration of its shelf-life or operating life, as applicable.

The surveillance test interval of this SRs is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.6.4 Vacuum Relief SR 4.6.4.1 Each suppression chamber - drywell vacuum breaker shall be:

b. Demonstrated OPERABLE:

2. In accordance with the Surveillance Frequency Control Program by verifying the opening setpoint of each vacuum breaker to be less than or equal to 0.20 psid.

The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.6.4.2 Each reactor building - suppression chamber vacuum breaker assembly shall be:

b. Demonstrated OPERABLE:

2. In accordance with the Surveillance Frequency Control Program by:

a) Verifying the opening setpoint of each vacuum breaker assembly valve to be less than or equal to 0.25 psid.

LR-N24-0004 LAR H24-01 Page 24 of 70 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.6.5.3 Filtration, Recirculation and Ventilation System (FRVS) - Ventilation Subsystem SR 4.6.5.3.1 Each of the two ventilation units shall be demonstrated OPERABLE:

c. In accordance with the Surveillance Frequency Control Program or upon determination that the HEPA filters or charcoal adsorbent could have been damaged by structural maintenance or adversely affected by any chemicals, fumes or foreign materials (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the subsystem by:

1. Verifying that the subsystem satisfies the in-place penetration testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rates are 9,000 cfm +/- 10% for each FRVS ventilation unit.

2. Verifying within 31 days after removal from the FRVS ventilation units, that a laboratory test of a sample of the charcoal adsorber, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 5% when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and a relative humidity 95%.

3. Verifying a subsystem flow rate of 9,000 cfm +/- 10% for each FRVS ventilation unit during system operation when tested in accordance with ANSI N510-1980.

e. In accordance with the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 5 inches Water Gauge in the ventilation unit while operating the filter train at a flow rate of 9,000 cfm

+/-10% for each FRVS ventilation unit.

SR 4.6.5.3.1.c.1 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 25 of 70 SR 4.6.5.3.1.c.2 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.6.5.3.1.c.3 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.6.5.3.1.e.1 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.6.5.3 Filtration, Recirculation and Ventilation System (FRVS) Recirculation -Subsystem SR 4.6.5.3.2 Each of the six FRVS recirculation units shall be demonstrated OPERABLE:

c. In accordance with the Surveillance Frequency Control Program or upon determination that the HEPA filters could have been damaged by structural maintenance or adversely affected by any foreign materials (1) after any structural maintenance on the HEPA filters or housings by:

1. Verifying that the subsystem satisfies the in-place penetration testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a and C.5.c of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rates are 30,000 cfm

+/-10% for each FRVS recirculation unit.

2. Verifying a subsystem flow rate of 30,000 cfm +/- 10% for each FRVS recirculation unit during system operation when tested in accordance with ANSI N510-1980.

LR-N24-0004 LAR H24-01 Page 26 of 70

e. In accordance with the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the exhaust duct is less than 8 inches Water Gauge in the recirculation filter train while operating the filter train at a flow rate of 30,000 cfm +/- 10% for each FRVS recirculation unit.

SR 4.6.5.3.2.c.1 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.6.5.3.2.c.2 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.6.5.3.2.e.1 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.7.1 Service Water Systems SR 4.7.1.2 At least the above required station service water system loops shall be demonstrated OPERABLE:

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

1. Each automatic valve servicing non-safety related equipment actuates to its isolation position on an isolation test signal.

LR-N24-0004 LAR H24-01 Page 27 of 70 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.7.2 Control Room Systems SR 4.7.2.1.1 Each control room emergency filtration subsystem shall be demonstrated OPERABLE:

c. In accordance with the Surveillance Frequency Control Program or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the subsystem filter train by:

1. Verifying that the subsystem satisfies the in-place penetration testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system filter train flow rate is 4000 cfm +/- 10%.

2. Verifying within 31 days after removal, that a laboratory test of a sample of the charcoal adsorber, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 0.5% when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and a relative humidity 70%.

3. Verifying a subsystem filter train flow rate of 4000 cfm +/- 10% during subsystem operation when tested in accordance with ANSI N510-1980.

e. In accordance with the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 7.5 inches Water Gauge while operating the filter train subsystem at a flow rate of 4000 cfm +/- 10%.

4. Verifying that the heaters dissipate 13 +/- 1.3 Kw when tested in accordance with ANSI N510-1980 and verifying humidity is maintained less than or equal to 70% humidity through the carbon adsorbers by performance of a channel calibration of the humidity control instrumentation.

SR 4.7.2.1.1.c.1 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and LR-N24-0004 LAR H24-01 Page 28 of 70 component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.7.2.1.1.c.2 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.7.2.1.1.c.3 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.7.2.1.1.e.1 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.7.2.1.1.e.4 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 29 of 70 SR 4.7.2.2 Each control room AC subsystem shall be demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program by verifying each subsystem has the capability to remove the assumed heat load.

The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.7.4 Reactor Core Isolation Cooling System SR 4.7.4 The RCIC system shall be demonstrated OPERABLE:

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.

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.

SR 4.7.4.c.1 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.7.4.c.3 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 30 of 70 TS 3/4.7.7 Main Turbine Bypass System SR 4.7.7 The main turbine bypass system shall be demonstrated OPERABLE:

b. In accordance with the Surveillance Frequency Control Program by:

1. Performing a system functional test which includes simulated automatic actuation and verifying that each automatic valve actuates to its correct position.

2. Demonstrating TURBINE BYPASS SYSTEM RESPONSE TIME meets the following requirements when measured from the initial movement of the main turbine stop or control valve:

a) 80% of turbine bypass system capacity shall be established in less than or equal to 0.3 second.

b) Bypass valve opening shall start in less than or equal to 0.1 second.

SR 4.7.7.b.1 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.7.7.b.2 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.8.1 A.C. Sources SR 4.8.1.1.2 Each of the above required diesel generators shall be demonstrated OPERABLE:

k. In accordance with the Surveillance Frequency Control Program by:

1. Verifying the diesel generator operates for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . During the first 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months of this test, the diesel generator shall be loaded to between 4000 and 4400 kW and during the remaining 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of this test, the diesel generator shall be loaded to between 4652 and 4873 kW. The diesel generator shall achieve 3950 volts and 58.8 Hz in 10 seconds following receipt of the start signal and subsequently achieve steady state voltage 3828 and 4580 volts and frequency of 60 +/- 1.2 Hz.

2. Within 5 minutes after completing 4.8.1.1.2.k.1, verify each diesel generator starts and achieves 3950 volts and 58.8 Hz in 10 seconds LR-N24-0004 LAR H24-01 Page 31 of 70 after receipt of the start signal, and subsequently achieves steady state voltage 3828 and 4580 volts and frequency of 60 +/- 1.2 Hz.

-OR-Operate the diesel generator between 4000 kW and 4400 kW for two hours. Within 5 minutes of shutting down the diesel generator, verify each diesel generator starts and achieves 3950 volts and 58.8 Hz in 10 seconds after receipt of the start signal, and subsequently achieves steady state voltage 3828 and 4580 volts and frequency of 60 +/- 1.2 Hz. This test shall continue for at least five minutes.

4.8.1.1.2.k.1 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had one failure that was identified as a unique failure which is not indicative of a repetitive time-based failure mechanism.

1) The test was aborted. Not all acceptance criteria performed due to aborted test. Due to Jacket Water Leakage > 54 ml/min, Acceptance Criteria that was performed was satisfactory.

No other previous failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

4.8.1.1.2.k.2 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.8.4 Electrical Equipment Protective Devices SR 4.8.4.1 Each of the primary containment penetration conductor overcurrent protective devices shown in Table 3.8.4.1-1 shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program:

2. By selecting and functionally testing a representative sample of at least 10% of each type of lower voltage circuit breakers. Circuit breakers selected for functional testing shall be selected on a rotating basis.

Testing of these circuit breakers shall consist of injecting a current with a LR-N24-0004 LAR H24-01 Page 32 of 70 value between 150% and 300% of the pickup of the long time delay trip element and verifying that the circuit breaker operates within the time delay bandwidth for that current specified by the manufacturer. The instantaneous element shall be tested by injecting a current in excess of 120% of the pickup value of the element and verifying that the circuit breaker trips instantaneously with no intentional time delay. Molded case circuit breaker testing shall also follow this procedure except that generally no more than two trip elements, time delay and instantaneous, will be involved. Circuit breakers found inoperable during functional testing shall be restored to OPERABLE status prior to resuming operation. For each circuit breaker found inoperable during these functional tests, an additional representative sample of at least 10% of all the circuit breakers of the inoperable type shall also be functionally tested until no more failures are found or all circuit breakers of that type have been functionally tested.

The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had two failures that were identified as unique failures which are not indicative of a repetitive time-based failure mechanism.

1) During performance of low voltage molded case circuit breaker overcurrent trip testing breaker 'A' 52-252041 failed overcurrent trip testing. Replacement breaker passed testing.

2) There were (2) failures for this sample population requiring (12) additional samples:

H1B-52-260843 and H1GT 26252. During PM on MCC bucket (H1BB 264083) instantaneous magnetic breaker failed to trip within required limits. Breaker failed to trip before upper limit of trip range was reached. New breakers were ordered, tested satisfactorily, and reinstalled in location.

No other previous failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.8.4.2.1 The thermal overload protection bypass circuit for each of the above required MOVs shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by the performance of a CHANNEL FUNCTIONAL TEST for:

2. A representative sample of at least 25% of those thermal overload protection devices which are bypassed continuously and temporarily placed in force only when the MOVs are undergoing periodic or maintenance testing.

3. A representative sample of at least 25% of those thermal overload protection devices which are in force during normal manual (momentary LR-N24-0004 LAR H24-01 Page 33 of 70 push button contact) MOV operation and bypassed during remote manual (push button held depressed) MOV operation.

SR 4.8.4.2.1.a.2 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the equipment had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.8.4.2.1.a.3 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

2.1.2 Non-Calibration Changes for 36-Month Frequency Extensions The following non-calibration TS SRs are proposed for revision to a 48-month frequency. The associated qualitative evaluation is provided for each of these changes, which concludes that the effect on plant safety is small, that the change does not invalidate any assumption in the plant licensing basis, and that the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. These conclusions have been validated by a review of the surveillance test history at HCGS as summarized below for each SR.

TS 3/4.3.3 Emergency Core Cooling System Actuation Instrumentation SR 4.3.3.1 Each ECCS actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL FUNCTIONAL TEST]

operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.3.1-1. [Trip Functions 1.g and 2.f]

LR-N24-0004 LAR H24-01 Page 34 of 70 Trip Function 1.g The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 2.f The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.3.3.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed in accordance with the Surveillance Frequency Control Program. [Trip Functions 1.g, 5.a and b]

Trip Function 1.g The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 5.a The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 35 of 70 Trip Function 5.b The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.3.3.3 The ECCS RESPONSE TIME of each ECCS trip function shall be demonstrated to be within the limit in accordance with the Surveillance Frequency Control Program. ECCS actuation instrumentation is eliminated from response time testing. [UFSAR Table 7.3-17 Trip Functions 1, 2, and 4]

Trip Function 1 The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 2 The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 4 The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the LR-N24-0004 LAR H24-01 Page 36 of 70 proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.3.4 Recirculation Pump Trip Actuation Instrumentation SR 4.3.4.2.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed in accordance with the Surveillance Frequency Control Program.

The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.5.1 ECCS - Operating SR 4.5.1 The emergency core cooling systems shall be demonstrated OPERABLE by:

c. In accordance with the Surveillance Frequency Control Program:

1. For the [CSS and LPCI systems], 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.

2. For the HPCI system, verifying that:

a) The system develops a flow of at least 5600 gpm against a test line pressure corresponding to a reactor vessel pressure of 200 psig, when steam is being supplied to the turbine at 200 + 15, -0 psig.

SR 4.5.1.c.1 The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.5.1.c.2.a The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

LR-N24-0004 LAR H24-01 Page 37 of 70 A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.7.1 Service Water Systems SR 4.7.1.1 At least the above required safety auxiliaries cooling system subsystems shall be demonstrated OPERABLE:

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

2) Each pump starts automatically when its associated diesel generator automatically starts.

SR 4.7.1.1.b.2 The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.7.1.2 At least the above required station service water system loops shall be demonstrated OPERABLE:

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

2. Each pump starts automatically when its associated diesel generator automatically starts.

The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.7.4 Reactor Core Isolation Cooling System SR 4.7.4 The RCIC system shall be demonstrated OPERABLE:

c. In accordance with the Surveillance Frequency Control Program by:

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.

LR-N24-0004 LAR H24-01 Page 38 of 70 The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.8.1 A.C. Sources SR 4.8.1.1.2 Each of the above required diesel generators shall be demonstrated OPERABLE:

h. In accordance with the Surveillance Frequency Control Program, during shutdown, by:

2. Verifying the diesel generator capability to reject a load of greater than or equal to that of the RHR pump motor for each diesel generator while maintaining voltage 3828 and 4580 volts and frequency at 60 +/- 1.2 Hz.

3. Verifying the diesel generator capability to reject a load of 4430 kW without tripping. The generator voltage shall not exceed 4785 volts during and following the load rejection.

4. Simulating a loss of offsite power by itself, and:

b) Verifying the diesel generator starts on the auto-start signal, energizes the emergency busses with permanently connected loads within 10 seconds after receipt of the start signal, energizes the autoconnected shutdown loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady state voltage and frequency of the emergency busses shall be maintained 3828 and 4580 volts and 60 +/- 1.2 Hz during this test.

5. Verifying that on an ECCS actuation test signal, without loss of offsite power, the diesel generator starts on the auto-start signal and operates on standby for greater than or equal to 5 minutes. The diesel generator shall achieve 3950 volts and 58.8 Hz in 10 seconds following receipt of the start signal and subsequently achieve steady state voltage 3828 and 4580 volts and frequency of 60 +/- 1.2 Hz.

6. Simulating a loss of offsite power in conjunction with an ECCS actuation test signal, and:

b) Verifying the diesel generator starts on the auto-start signal, energizes the emergency busses with permanently connected loads within 10 seconds after receipt of the start signal, energizes the autoconnected shutdown loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the emergency loads. After energization, the steady state voltage and frequency of the emergency busses shall be maintained 3828 and 4580 volts and 60 +/- 1.2 Hz during this test.

7. Verifying that all automatic diesel generator trips, except engine overspeed, generator differential current, generator overcurrent, bus LR-N24-0004 LAR H24-01 Page 39 of 70 differential current and low lube oil pressure are automatically bypassed upon loss of voltage on the emergency bus concurrent with an ECCS actuation signal.

9. Verifying that the auto-connected loads to each diesel generator do not exceed the continuous rating of 4430 kW.

10. Verifying the diesel generator's capability to:

a) Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power, b) Transfer its loads to the offsite power source, c) Be restored to its standby status, and d) Diesel generator circuit breaker is open.

11. Verifying that with the diesel generator operating in a test mode and connected to its bus, a simulated ECCS actuation signal overrides the test mode by (1) returning the diesel generator to standby operation, and (2) automatically energizes the emergency loads with offsite power.

SR 4.8.1.1.2.h.2 The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.8.1.1.2.h.3 The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.8.1.1.2.h.4.b The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and LR-N24-0004 LAR H24-01 Page 40 of 70 component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.8.1.1.2.h.5 The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.8.1.1.2.h.6.b The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.8.1.1.2.h.7 The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.8.1.1.2.h.9 The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 41 of 70 SR 4.8.1.1.2.h.10 The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

SR 4.8.1.1.2.h.11 The surveillance test interval of this SR is being increased from once every 36 months to once every 48 months, for a maximum interval of 60 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this equipment had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 48-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

2.2 Calibration Changes for an 18-Month and 36-Month Extension NRC GL 91-04 requires that licensees address instrument drift when proposing an increase in the surveillance interval for calibrating instruments that perform safety functions including providing the capability for safe shutdown. The effect of the increased calibration interval on instrument errors must be addressed because instrument errors caused by drift were considered when determining safety system setpoints and when performing safety analyses.

NRC GL 91-04 identifies seven steps for the evaluation of instrumentation calibration changes.

These seven steps are discussed in the Enclosure to this submittal. In that discussion, a description of the methodology used by PSEG for each step is summarized. The detailed methodology is provided in the LAR Enclosure.

The following are the calibration-related TS SRs being proposed for revision from 18 months to 24 months (and 36 months to 48 months), for a maximum interval of 30 months or 60 months (considering the 25% grace period allowed by TS SR 4.0.2). The methodology used to perform the drift analysis is consistent with the methodology utilized by other utilities requesting transition to a 24-month fuel cycle. The methodology is also based on Electric Power Research Institute (EPRI) TR-103335, "Statistical Analysis of Instrument Calibration Data" and is summarized in the LAR Enclosure.

The projected 30-month (and 60-month) drift values for many of the instruments analyzed from the historical as-found/as-left evaluation shows sufficient margin between the current plant setpoint and the Allowable Value to compensate for the 30-month (and 60-month) drift. For each instrument function that has a channel calibration proposed frequency change to 24 LR-N24-0004 LAR H24-01 Page 42 of 70 months (or 48 months), the associated setpoint calculation assumes a consistent or conservative drift value appropriate for a 24-month (and 48-month) calibration interval.

No revisions to any TS setpoints were required. A review of the applicable safety analysis concluded that the setpoints and projected 30-month (and 60-month) drift confirmed the safety limits and safety analysis assumptions remain bounding.

2.2.1 Calibration Changes for an 18-Month Extension The following 18-to-24-month calibration extensions SRs are presented:

TS 3/4.3.1 Reactor Protection System Instrumentation SR 4.3.1.1 Each reactor protection system instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL CALIBRATION] operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.1.1-1. [Functional Units 1.a, 7, and 8.a and b]

Functional Unit 1.a The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history identified one failure that was a unique failure that is not indicative of a repetitive time-based failure mechanism.

1) During performance, the Mean Square Analog (MSA) module was found with evidence of overheating (discoloration). All data obtained was high out of specification. The Intermediate Range Monitor (IRM) had been identified to have had a step change in displayed power level from ~1% to ~6% over a 3 - 4 day period with no changes in plant power. IRM 'B' is inoperative without this card. The physical condition of R8, R12, VR1, and VR2 showed discoloration specific to exact placement on circuit board. R8 appeared to have a crack in the middle of it and solder joints appear to be damaged on resistors in question as well.

No other previous failures of the TS function were identified that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Functional Unit 7 The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change LR-N24-0004 LAR H24-01 Page 43 of 70 to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Functional Unit 8.a The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Functional Unit 8.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.3.2 Isolation Actuation Instrumentation SR 4.3.2.1 Each isolation actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL CALIBRATION] operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.2.1-1. [Trip Functions 1.b and c, 2.b, c, and d, 3.b, e, and f, 4.a, b, c, and d, 5.a through i, and 6.a through i]

Trip Function 1.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 44 of 70 Trip Function 1.c The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 2.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 2.c The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 2.d The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 45 of 70 Trip Function 3.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 3.e The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 3.f The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 4.a The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 46 of 70 Trip Function 4.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 4.c The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 4.d The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 5.a The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 47 of 70 Trip Function 5.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 5.c The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history identified two failures that would not have prevented the performance of the required safety function of the equipment. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency.

Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 5.d The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history identified one failure that would not have prevented the performance of the required safety function of the equipment. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency.

Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 5.e The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 48 of 70 Trip Function 5.f The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 5.g The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 5.h The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 5.i The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 49 of 70 Trip Function 6.a The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 6.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 6.c The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history identified one failure that would not have prevented the performance of the required safety function of the equipment. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency.

Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 6.d The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 50 of 70 Trip Function 6.e The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 6.f The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 6.g The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 6.h The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

LR-N24-0004 LAR H24-01 Page 51 of 70 Trip Function 6.i The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of the surveillance history verified that this instrumentation had no previous failures of the TS functions. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

TS 3/4.3.3 Emergency Core Cooling System Actuation Instrumentation SR 4.3.3.1 Each ECCS actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the [CHANNEL CALIBRATION] operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.3.1-1. [Trip Functions 1.b and d, 2.b through d, 3.b, c, and f, and 4.b, d, and e]

Trip Function 1.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 1.d The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

A review of surveillance test history verified that the instrumentation had no previous failures of the TS function that would have been detected solely by the periodic performance of this SR. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the inherent system and component reliability as shown by the failure history, the impact of this change on safety, if any, is small.

Trip Function 2.b The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25% grace period afforded by TS SR 4.0.2.

LR-N24-0004 LAR H24-01 Page 52 of 70 A review of the surveillance history identified two failures that would not have prevented the performance of the required safety function of the equipment. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency.