NG-17-0207, Response to Request for Additional Information Regarding License Amendment Request (TSCR-168), Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.

Response to Request for Additional Information Regarding License Amendment Request (TSCR-168), Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.

ML17305A910
Person / Time
Site:	Duane Arnold
Issue date:	11/01/2017
From:	Dean Curtland NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-17-0207
Download: ML17305A910 (17)

Text

NEXTera ENERGY ~

DUANE ARNOLD November 1, 2017 NG-17-0207 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Duane Arnold Energy Center Docket No. 50-331 Renewed Facility Operating License No. DPR-49 Response to Request for Additional Information Regarding License Amendment Request (TSCR-168), Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control"

References:

1. NextEra Energy Duane Arnold, LLC letter NG-17-0093, License Amendment Request (TSCR-168), Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Invento1y Control," June 9, 2017 (ML17164A076)

2. NRC E-Mail: Final Request for Additional Information - Duane Arnold Energy Center (DAEC) -Application to Revise Technical Specifications to Adopt TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" - CAC No. MF9829. From Mahesh Chawla, NRC, October 4, 2017 In Reference 1, NextEra Energy Duane Arnold, LLC (NextEra) submitted a license amendment request for Duane Arnold Energy Center. The proposed change replaces existing Technical Specifications (TS) requirements related to "operations with a potential for draining the reactor vessel" with new requirements on reactor pressure vessel water invento1y control.

In Reference 2, the NRC staff requested additional information to support its review of the LAR.

The Enclosure to this letter provides NextEra's response to the request for additional information (RAI). Attachment 1 to the Enclosure provides marked up TS pages showing the revised proposed changes. These pages supersede the corresponding pages provided in Reference 1. Updated retyped TS pages, which supersede the corresponding pages in Reference 1, are provided in .

This RAI response does not alter the conclusions in Reference 1 that the changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the changes.

No new or revised commitments are included in this letter.

NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Document Control Desk NG-17-0207 Page 2of2 If you have any questions or require additional information, please contact J. Michael Davis, Licensing Manager, at 319-851-7032.

I declare under penalty of perjury that the foregoing is 1:1ue and correct.

Executed on November _ / _, 2017 Dean Curtland Site Director N extEra Energy Duane Arnold, LLC Enclosure cc: Regional Administrator, USNRC, Region III, Project Manager, USNRC, Duane Arnold Energy Center Resident Inspector, USNRC, Duane Arnold Energy Center A. Leek (State of Iowa)

NG 17-0207 Enclosure Page 1of5 Enclosure Response to Additional Information

1. DAEC-RAI-1:

Background:

DAEC TS Section 2.0, "Safety Limits," TS 2.1.1.3 states; "Reactor Vessel Water Level- Reactor vessel water level shall be greater than 15 inches above the top ofactive irradiated fuel"

[emphasis added]. Safety Limit (SL) 2.1.1.3 is maintained through the TS Limited Condition of Operation (LCO), applicability, actions, and notes. The DAEC TSs require certain safety systems to be OPERABLE during "operations with a potential for draining the reactor vessel" (OPDRVs). The proposed changes would replace existing TS requirements associated for OPDRVs with revised TSs providing an alternative requirement for Reactor Pressure Vessel (RPV) Water Inventmy Control (WIC). These alternative requirements are intended to protect Safety Limit 2.1.1.3. The NRC's regulatory requirements related to the content of the TS are contained in Title 10 of tl1e Code if Federal Regtt!atio11s (10 CFR) at 10 CFR 50.36.

DAEC TS Bases 2.1.1.3 states, in part:

The reactor vessel water level SL has been established at 15 inches above the top of tl1e active irradiated fuel to provide a point that can be monitored and to also provide adequate SLs for affective action.

From Page 1 of 7 of the License Amendment Request (LAR):

NextEra Energy Duane Arnold, LLC (NextEra) has reviewed the safety evaluation provided to the Technical Specifications Task Force (fSTF) on December 20, 2016, as well as the information provided in TSTF-542.

NextEra has concluded that the justifications presented in TSTF-542 and the safety evaluation prepared by the NRG staffare applicable to the Duane Arnold Energy Center (DAEC) and justify this amendment for incorporation of the changes to the DAEC TS.

[emphasis added].

From the (LAR), Page 5 of 7.

3.1 No Significant Hazards Consideration Analysis NextEra Energy Duane Arnold, LLC (NextEra) requests adoption of TSTF-542, "Reactor Pressure Vessel Water Inventoty Control," which is an approved change to the Standard Technical Specifications (STS), into the Duane Arnold Energy Center Technical Specifications (TS). The proposed amendment replaces the existing requirements in the TS related to "operations with a potential for draining the reactor vessel" (OPDRVs) with new requirements on Reactor Pressure Vessel Water Inventory Control (RPV WIC) to protect Safety Limit 2.1.1.3. Safety Limit 2.1.1.3 requires reactor vessel water level to be greater than the top of active irradiated fuel [emphasis added]. NextEra has

NG 17-0207 Enclosure Page 2 of 5 evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below ....... :

DAEC's Safety Limit, "Reactor vessel water level shall be greater than 15 inches above the top of active irradiated fuel," is different than the SL stated in the approved TS Change Traveler, TSTF-542 which assumes the 'Safety Limit is the top of active fuel'. This difference between the DAEC SL and the TSTF-542 SL is not identified as a variation and is considered a significant change. Because of the differing SLs it is not clear how the proposed TS changes in TSTF-542 would protect DAEC's SL.

This has global effects on the LAR including.

1. Regulato1y Analysis, response to questions 1, 2, and 3.

2. Drain time definition, TS 1.1.

3. All places that relates TAF and the Safety Limit since the safety limit is TAF plus 15 inches (for example, but not limited to; TS LCO 3.5.2 and LCO 3.5.2 Required Action D.1).

4. New variation to describe these differences between TAF and the DAEC safety limit.

5. TS Bases Question: Justify the applicability ofTSTF-542 to DAEC given that the DAEC SL 2.1.1.3 is different than TSTF-542.

NextEra Response The reactor vessel water level of 15 inches above the Top of Active Fuel (TAF) used by DAEC as its Safety Limit is a reflection of the limitations of the vessel level instrumentation available to the Operations staff and is not indicative of a difference from, or change to, the analysis presented in TSTF-542. The Safety Limit is a long-standing Technical Specifications value and is not being changed as part of the TSTF-542 - directed revision.

DAEC TS 2.1.1.3 specifies the SL for water level as 15 inches above the TAF. The TAF at DAEC is defined in the UFSAR as 344.5 inches above vessel zero. Since all of the trip settings for instruments that are relied upon for accident or transient mitigation are referenced to vessel zero, the TS 2.1.1.2 SL for vessel level is actually an administrative limit below which certain regulatory requirements are to be met, and is not directly coupled to any actuation setpoint. Note also that the minimum level assumed for a DBA LOCA is below the TAF, and the degree of cladding damage is a function of core uncovery (reflooded) time, and not minimum vessel level. The SL, therefore, does not directly impact reactor safety. Additionally, since the taps for the reference leg instrnments used to monitor vessel level are located at an elevation of 350.0 inches above vessel zero, indicated vessel levels lower than that elevation are not considered reliable (especially considering containment heating effects, vessel depressurization effects and jet pump flow effects.) Therefore, it must be assumed that the vessel level SL is violated any time indicated vessel level goes offscale low. The lowest reliable vessel level indication is in the range of 15 inches above TAF (344.5 + 15 = 359.5 inches above vessel zero), so it must be assumed that the vessel level SL is violated any time the indicated level is below 15 inches above TAF. As explained in the Emergency Operating

NG 17-0207 Enclosure Page 3 of 5 Procedures, current operating practice would be to assume the vessel level SL is violated any time indicated level is below 15 inches above TAF. This will also be reflected in the DRAIN TIME definition, as noted below.

Variation from TSTF-542: To provide clarification, the definition of DRAIN TIME to be inserted in DAEC TS Section 1.1 (Definitions) as per NG-17-0093 has been modified to specify that the level in question is the Reactor Vessel Water Level Safety Limit of TS 2.1.1.3 (and not simply the TAF.) See Attachment 1 for the markup (Insert 1) and final typed pages 1.1-3 and 1.1-4.

2. DAEC-RAI-2:

Background:

Red line strike-out appears to be in error for LAR, Attachment 2, TS page 3.3-46. For 3.3.5.2 (top left of the page), being corrected to 3.3.5.3, there is a~ missing for the 3.3.5.3 title.

Question: Provide a corrected page for 3.3-46.

NextEra Response Attachment 1 contains a corrected markup of page 3.3-46. (The updated and typed page, 3.3-50, is unchanged and has not been included.)

3. DAEC-RAI-3

Background:

LAR, Attachment 1, Page 4 describes variation "i" related to TS 3.3.5.2. This variation states, in part;

..TS 3.3.5.2 does not include a smveillance requirement (SR) for a logic system functional test since the SR applies only to the manual initiation function. Likewise, the changes to TS 3.5.2, RPV Water Invento1y Control, do not include SR 3.5.2.8, which demonstrates ECCS injection/ spray actuation on a manual initiation signal.

Traveler TSTF-542, SR 3.5.2.8 states, in part;

... Verify the required ECCS injection/ spray subsystem actuates on a manual initiation signal.

An alternative SR appears to be missing that tests the capability that the associated ECCS injection/ spray pumps and valves can be manually operated to provide additional RPV invento1y. This SR ensures that the required ECCS injection/ spray subsystem can be manually operated for Modes 4 and 5.

NG 17-0207 Enclosure Page 4 of 5 Question: Provide additional justification that an alternative SR is not needed to test the capability of the pumps/valves as stated above or provide new TS SR 3.5.2.8 markup.

NextEra Response Duane Arnold Energy Center (DAEC) TS Table 3.3.5.1-1, "Emergency Core Cooling System Instrnmentation," does not include functions for manual initiation of CS and LPCI. Since the design of DAEC does not include this feature (e.g. a pushbutton that, when activated, initiates a sequence of pump starts / valve repositioning resulting in ECCS injection into the RPV),

proposed Table 3.3.5.2-1 does not include manual initiation functions for CS and LPCI. In addition, TS 3.3.5.2 does not include a surveillance requirement (SR) for a logic system functional test since the SR applies 011b1 to the manual initiation function. Likewise, the changes to TS 3.5.2, RPV Water Inventory Control, do not include SR 3.5.2.8, which demonstrates ECCS injection/ spray actuation on a manual initiation signal. No attempt has been made to provide a substitute SR 3.5.2.8 because (proposed) SR 3.5.2.6 demonstrates that the required ECCS injection/ spray subsystem can be manually started (via individual component hand switches) and operated to mitigate a draining event. This statement is substantiated by the (proposed) basis of SR 3.5.2.6. Thus, any proposed substitute for SR 3.5.2.8 would be redundant to SR 3.5.2.6.

4. DAEC-RAI-4

Background:

LAR, Attachment 2, TS page 3.5-10 describes the changes to SR 3.5.2.4 (new 3.5.2.5), which states, "Verify for the required ECCS subsystem each power operated and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position." Per the TSTF-542 traveler, the wording should be: "Verify, for the required ECCS subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or othe1wise secured in position, is in the correct position."

Question: Provide justification for the difference between the submittal and the traveler or provide a correction to TS SR 3.5.2.4. Also consider adding a comma between 'Verify and for,'

per the traveler.

NextEra Response The current DAEC SR 3.5.2.4 requirement is to "Verify each required ECCS subsystem power operated and automatic valve in the flow path, that is not locked, sealed, or othenvise secured in position, is in the correct position." The proposed changes to this portion of SR 3.5.2.4 (new 3.5.2.5) on TS page 3.5-10 are editorial. (The updated page number is 3.5-12.)

A comma will be added between "verify" and "for". The term "manual" is not in the current DAEC TS requirement nor the proposed revised statement. It was removed from the (then) proposed SR 3.5.2.4 ITS prior to its adoption by DAEC in 1998 based upon the facility having adequate controls on the manual valves such that monthly checks were not required. Therefore the term "manual" is not being included in the proposed revision.

NG 17-0207 Enclosure Page 5 of 5

5. DAEC-RAI-5

Background:

Attachment 2 to the LAR (I'v1ark-up DAEC TS page 3.5-11) contains proposed SR 3.5.2.6, "Operate the required ECCS injection/ spray subsystem through the recirculation line for 2: 10 minutes." The Frequency is listed as, "In accordance with the Inservice Testing Program." The equivalent in TSTF-542, STS SR 3.5.2.6, states the associated Frequency as "[92 days OR In accordance with the Surveillance Frequency Control Program]."

Question: Provide a technical justification for this variation from TSTF-542.

NextEra Response NextEra revised the Frequency for SR 3.5.2.6 to "In accordance with the Smveillance Frequency Control Progratn," consistent with TSTF-542. NextEra will establish an initial frequency of 92 days for SR 3.5.2.6. See Attachment 1. (Revised markup page 3.5-11 and final typed page 3.5-13 are provided.)

DAEC-RAI-6

Background:

Page 3.5-8 of the LAR describes the proposed LCO 3.5.2. The proposed wording is: One low pressure ECCS subsystem shall be OPERABLE.

TSTF-542 wording is: One low pressure ECCS injection/spray subsystem shall be OPERABLE.

In addition, in several places of the LAR "injection/spray" is missing after ECCS.

D LCO 3.5.2 Condition A D LCO 3.5.2 A.1 Required Actions D SR 3.5.2.5 Question: Provide justification for the difference between the submittal and the traveler TSTF-542 or provide a correction to proposed LCO 3.5.2 and SR 3.5.2.5.

NextEra Response The current DAEC TS generally do not use the term "injection/ spray. The term was not incorporated into the LCO 3.5.2 description or the other 3.5.2 requirements noted above when ITS was adopted by DAEC in 1998. This was based upon the standard usage at DAEC. The omission is editorial only.

NG 17-0207 Attachment 1 Attachment 1 Markups of TS Pages 4 Pages Follow

INSERT1 DRAIN TIME The DRAIN TIME is the time It would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the tap of the active f1 *el {TAF) seated in the RPV the Reactor assuming: '\. Vessel Water T.S. 2.1.1.3 Safety Limit i? "\. Level Safet a) ~h~.water ~nventory above the IAE is divided by the limit of r.i.

llm1ting drain rate; 2.1 .1.3 b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, Joss of normal power, single human error), for all penetration flow paths below the

~ -lAE except:

T.S. 2.1.1.3 Safety Limit

1. Penetration flow paths connected to an Intact closed system, or Isolated by manual or automatic valves that are locked, sealed, or otherwise secured In the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being Isolated by valves that will close automatically without offslte power prior to the RPV water level being equal to T.S. 2.1.1.3 Safety Limit - - -7'th"""'e:,.:;;

• IAE when actuated by RPV water level Isolation Instrumentation; or

3. Penetration flow paths with Isolation devices that T.S. 2.1.1.3 Safety Limit can be closed prior to the RPV water level being

\ equal to the ~ by a dedicated operator trained In the task, who Is in continuous communication with the control room, Is stationed at the controls, and Is capable of closing the penetration flow path Isolation device without offslte power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open Instantaneously and are not subsequently Isolated, and no water is assumed to be subsequently added to the RPV water inventory; d) No additional draining events occur; and e) Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used In lieu of a calculated value.

RCIC System Instrumentation 3.3.5 .~~

~

3.3 INSTRUMENTATION 3.3.5. ~ Reactor Core Isolation Cooling (RCIC) System Instrumentation The RCIC System instrumentation for each Function in Table 3.3 .. ~ 1 shall be OPERABLE.

3 APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure> 150 psig .

ACTIONS

---

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced In Table 3.3.5.~ 1 for the channel.

B. As required by eclare RCIC 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery Required Action A.1 System Inoperable. of loss of RCIC and reference I Initiation capability Table 3.3.5.~ .

AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> B.2 Place channel In trip.

(continued)

DAEC 3.3-46 Amendment ~

jRPV Water Inventory Control

~hbltdown 3.5.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY JC"' a SR 3.5.2.~ Verify, for eask required Core Spray (CS) In accordance subsystem, the: with the

~ a. Suppression pool water level is~ 8.0 ft; or Surveillance Frequency Control Program

b. ~JOTE Only one reqblired CS sblbsystem may ta l~e credit for this option during OPDRVs.

Condensate storage tank water level In one CST Is ~ 11 ft or~ 7 ft In both CSTs.

SR 3.5.2.3 Verify, for 0aGA required ECCS Injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

In accordance with the Surveillance 1

Frequency Control Program SR 3.5.2.4 ------------------------NOTE----------------------------

t GRS LPCI subsystem may be considered OPERABLE during alignment and

~ ope-ration for decay heat removal If capable of being manually realigned and not otherwise Inoperable.

---

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

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

~' J each

~erlfy&aOO required ECCS subsystem ...-----' In accordance power operated and automatic valve In the with the flow path, that Is not locked, sealed, or Surveillance otherwise secured In position, is In the Frequency correct position. Control Program (continued)

DAEC 3.5-10 Amendment ~

IRPV Water Inventory Control - - - - ) _ , , . EGGS Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

~T SURVEILLANCE FREQUENCY

/ lJeFily eash Fe~*iFe8 E':GGS ~*m~ Sevele~s the s~esmea In flow rats against a system head corresponding to ths Operate th e required ECCS specified reactor pressure.

subsystem through the recirculation line for~ 10 minutes. WG-:

8¥S+EM ~EAQ CORRESPO~mlNG accordance with the INSERVICE

+ies+IN<;; ~

f PROGRAM GF'. TOA REACTOR S¥STEM P:bO~ll,l R,A,TE P61MPS PRESS61RE OP: Surveillance Frequency GS ~ 27~g gpm 4 ~ 11a psig Control

~ ~ 4a20 gpm 4 ~ 20 psig

/

SR a.e.2.e NOTES 4:- Vssssl injection/spray may bs excluded .

~ P:or ths bPCI System, ths suF¥slllancs n::iay bs mst by any ssriss of SSE!usntial and/or overlapping steps, such that ths bPCI boop Select function Is tsstsd .

Verify each reE!uired EGGS subsystem actuates on an In accordance aotual or simulated autematic initiatien signal. 1

.vith the SuF¥sillancs P:rSE!USncy Control Program SR 3.5.2.7 Verify each valve cred ited for automatically isolating a penetration flow In path actuates to the isolation position on an actual or simulated isolation signal. accordance with the L...-- - -- - - - - - - - - - -- - - - -- -- - - - - -----1Surveillance Frequency Control Program DAEC 3.5-11 Amendment WQ

NG 17-0207 Attachment 2 Attachment 2 Retyped TS Pages 4 Pages Follow

Definitions 1.1 1.1 Definitions (continued)

CORE OPERATING LIMITS The COLR is the unit specific document that provides REPORT (COLR) cycle specific parameter limits for the current reload cycle.

These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT 1-131 shall be that concentration of DOSE EQUIVALENT 1-131 1-131 (microcuries/ml), that alone would produce the same dose as the quantity and isotopic mixture of 1-131, 1-132, 1-133, 1-134, and 1-135 actually present.

The dose conversion factors used for this calculation shall be those listed in Federal Guidance Report (FGR) 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion," 1989 and FGR 12, "External Exposure to Radionuclides in Air, Water, and Soil," 1993.

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the Reactor Vessel Water Level Safety Limit of T.S. 2.1.1.3 assuming:

a) The water inventory above the T.S. 2.1.1.3 Safety Limit is divided by the limiting drain rate; (cont'd)

(continued)

DAEC 1.1-3 Amendment

Definitions 1.1 1.1 Definitions (continued)

DRAIN TIME (cont'd) b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the T.S. 2.1.1.3 Safety Limit except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the T.S. 2.1.1.3 Safety Limit when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the T.S. 2.1.1.3 Safety Limit by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; d) No additional draining events occur; and e) Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

(continued)

DAEC 1.1-4 Amendment

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify, for a required Core Spray (CS) In accordance subsystem, the: with the Surveillance

a. Suppression pool water level is 2 8.0 ft; or Frequency Control Program

b. Condensate storage tank water level in one CST is 2 11 ft or 2 7 ft in both CSTs.

SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance subsystem, locations susceptible to gas with the accumulation are sufficiently filled with water. Surveillance Frequency Control Program SR 3.5.2.5 ---------------------------N()TE----------------------------

A LPCI subsystem may be considered

()PERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

---

N()TE----------------------------

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

Verify, for the required ECCS subsystem, In accordance each power operated and automatic valve in with the the flow path, that is not locked, sealed, or Surveillance otherwise secured in position, is in the Frequency correct position. Control Program (continued)

DAEC 3.5-12 Amendment

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.6 Operate the required ECCS subsystem through the In recirculation line for~ 10 minutes. accordance with the Surveillance Frequency Control Program SR 3.5.2.7 Verify each valve credited for automatically isolating a In accordance penetration flow path actuates to the isolation position on with the an actual or simulated isolation signal. Surveillance Frequency Control Program DAEC 3.5-13 Amendment