View source for GO2-21-042, License Amendment Request to Adopt TSTF-546, Revise APRM Channel Adjustment Surveillance Requirement

{{Adams
| number = ML21130A573
| issue date = 05/08/2021
| title = License Amendment Request to Adopt TSTF-546, Revise APRM Channel Adjustment Surveillance Requirement
| author name = Dittmer J
| author affiliation = Energy Northwest
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000397
| license number = 
| contact person = 
| case reference number = GO2-21-042
| document type = Letter type:GO, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 17
| project = 
| stage = Request
}}

=Text=
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ENERGY J. Kent Dittmer Vice President, Engineering P.O. Box 968, PE01 NORTHWEST                                                           Richland, WA 99352-0968 Ph. 509.377.4248 l F. 509.377.2354 jkdittmer@energy-northwest.com May 8, 2021 GO2-21-042 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==Subject:==
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 LICENSE AMENDMENT REQUEST TO ADOPT TSTF-546, "REVISE APRM CHANNEL ADJUSTMENT SURVEILLANCE REQUIREMENT"

==Dear Sir or Madam:==

Pursuant to 10 CFR 50.90 Energy Northwest is submitting a request for an amendment to the Technical Specifications (TS) for Columbia Generating Station (Columbia).
The proposed change is consistent with TSTF-546, Revision 0, "Revise APRM Channel Adjustment Surveillance Requirement." The proposed amendment alters Surveillance Requirement (SR) 3.3.1.1.2 of Technical Specification (TS) 3.3.1.1, "Reactor Protection System (RPS) Instrumentation." This proposed change revises the SR to verify that calculated (i.e., calorimetric heat balance) power is no more than 2% greater than the average power range monitor (APRM) channel output. The SR requires the APRM channel to be adjusted such that calibrated power is no more than 2% greater than the APRM indicated power when operating at  25% of Rated Thermal Power (RTP). This change revises the SR to distinguish between APRM indications that are consistent with the accident analyses and those that provide additional margin. This includes a variation to allow for a two-hour period for adjustment of the APRM output gain to restore compliance with the SR limit before entering the associated Conditions and Required Actions.
Enclosure 1 provides a description and assessment of the proposed changes.
Enclosure 2 provides the Proposed Technical Specification Changes (Mark-Up).
Enclosure 3 provides the Proposed Technical Specification Bases Markup Pages for information only.
Enclosure 4 provides the Proposed Technical Specification Changes (Re-Typed).
Approval of the proposed amendment is requested by one year from the date of this letter. Once approved, the amendment shall be implemented within 90 days.
In accordance with 10 CFR 50.91, Energy Northwest is notifying the State of Washington of this amendment request by transmitting a copy of this letter and enclosures to the designated State Official.
This letter and its enclosures contain no regulatory commitments.

           
GO2-21-042 Page 2 of 2 If there are any questions or if additional information is needed, please contact Mr. R.M.
Garcia, Licensing Supervisor, at 509-377-8463.
I declare under penalty of perjury that the foregoing is true and correct.
                             
Executed this ______     day of May 2021.
Respectfully, J. Kent Dittmer Vice President, Engineering

==Enclosures:==
As stated cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C CD Sonoda - BPA/1399 (email)
EFSECutc.wa.gov - EFSEC (email)
E Fordham - WDOH (email)
R Brice - WDOH (email)
L Albin - WDOH (email)

           
GO2-21-042 Enclosure 1 Page 1 of 5 DESCRIPTION AND ASSESSMENT

==1.0      DESCRIPTION==

The proposed amendment alters Surveillance Requirement (SR) 3.3.1.1.2 of Technical Specification (TS) 3.3.1.1, "Reactor Protection System (RPS) Instrumentation." This proposed change revises the SR to compare the calculated (i.e., calorimetric heat balance) power to the average power range monitor (APRM) indications, and to adjust the APRM consistent with the heat balance power if the calculated power is more than 2% greater than the APRM channel output when operating at  25% of Rated Thermal Power (RTP). This change revises the SR to require adjustment only if the APRM indication deviates from the calculated power in the nonconservative direction.
2.0      ASSESSMENT 2.1      Applicability of Safety Evaluation Energy Northwest has reviewed the safety evaluation provided to the Technical Specifications Task Force (TSTF) in a {{letter dated|date=August 31, 2017|text=letter dated August 31, 2017}} by the Nuclear Regulatory Commission (NRC) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17206A431). This included a review of the NRC staffs evaluation, as well as the information provided in TSTF-546, Revision 0. As described herein, Energy Northwest has concluded that the justifications, plant design description, and safety analysis description presented in TSTF-546 and the safety evaluation prepared by the NRC staff are applicable to Columbia and justify this amendment for the incorporation of the changes to Columbias TS.
2.2      Variations Energy Northwest is proposing the following variations from the TS changes described in TSTF-546 or the applicable portions of the NRC safety evaluation for TSTF-546.
2.2.1 Use the following alternate wording for TS SR 3.3.1.1.2 to eliminate the requirement to adjust the APRM when the APRM is conservative with respect to calculated power:
Verify the calculated power does not exceed the average power range monitor (APRM) channels greater than 2% RTP while operating at  25% RTP.
2.2.2 Maintain the gain adjustment separate from the performance of TS SR 3.3.1.1.2.
2.2.3 For TS 3.3.1.1, add a new Action Table note:
When Functions 2b and 2c channels are inoperable due to the calculated power exceeding the average power range monitor (APRM) output by more than 2% rated

           
GO2-21-042 Enclosure 1 Page 2 of 5 thermal power (RTP) while operating at  25% RTP, entry into associated Conditions and Required Actions may be delayed for up to 2 hours.
These variations differ slightly from the specific wording proposed in TSTF-546, but do not affect the intent of the change, the basis for acceptability of the change, or the conclusions of the NRC safety evaluation dated August 31, 2017.
Justification for the two-hour Delay The delay of up to two hours prior to entering the associated Condition and Required Actions allows the performance of the adjustment of APRM gain. TS SR 3.3.1.1.2 is considered met if the channel can be adjusted to within the limit during the two-hour delay period. The two-hour delay period is reasonable since it is consistent with power distribution limit related completion times in TS 3.2.2 and TS 3.2.3. Similarly, multiple Exelon BWR units received approval January 16, 2019 (ADAMS Accession No. ML18304A365) for the same two-hour delay for non-conservative APRM adjustment, citing the power distribution (thermal) limits as well as other completions times in the Boiling Water Reactor (BWR) standard technical specifications (STS) for the restoration of parameters, subsystems, and channels within TS limits. The APRM system for Columbia is similar in functionality to that of the Exelon BWR units. Due to the similarities between the designs and TSs of these boiling water reactors, Energy Northwest concludes that the two-hour time limit is also reasonable for Columbia.
3.0      Impact on Submittals under Review The NRC is presently reviewing Energy Northwests LAR to adopt TSTF-439 (ADAMS Accession No. ML20337A141). There is no impact.
4.0      Precedent Exelon Generation License Amendment Request to revise TS to modify APRM Channel Adjustment Surveillance Requirement for Clinton Power Station Unit 1, Dresden Nuclear Power Station, Units 2 and 3, James A. Fitzpatrick Nuclear Power Plant, LaSalle County Station, Units 1 and 2, Limerick Generating Station, Units 1 and 2, Nine Mile Point Nuclear Power Station, Units 1 and 2, Peach Bottom Atomic Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 (ADAMS Accession No. ML18166A197). Approved by the Nuclear Regulatory Commission January 16, 2019 (ADAMS Accession No. ML18304A365).
This precedent was approved for the same variations for BWR plants similar to Columbia in design.

             
GO2-21-042 Enclosure 1 Page 3 of 5

==5.0      REGULATORY ANALYSIS==

5.1      No Significant Hazards Consideration Analysis Energy Northwest requests adoption of TSTF-546, Revision 0, "Revise APRM Channel Adjustment Surveillance Requirement," which is an approved change to the standard technical specifications (STS), into the Columbia Generating Station (Columbia)
Technical Specifications (TS). The proposed change alters Surveillance Requirement (SR) 3.3.1.1.2 of Technical Specification (TS) 3.3.1.1, "Reactor Protection System (RPS) Instrumentation." This proposed change revises the SR to compare the calculated (i.e., calorimetric heat balance) power to the Average Power Range Monitoring (APRM) indications, and to adjust the APRM consistent with the heat balance power if the calculated power is more than 2% greater than the APRM channel output when operating at  25% of Rated Thermal Power (RTP). This change revises the SR to require adjustment only if the APRM indication deviates from the calculated power in the nonconservative direction. This includes a variation to allow for a two-hour period for adjustment of the APRM output gain to restore compliance with the SR limit before entering the associated Conditions and Required Actions.
The proposed change has been evaluated against the criteria of 10 CFR 50.92(c) to determine if the proposed change results in any significant hazards. The following is the analysis of each of the 10 CFR 50.92(c) criteria:
: 1.       Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The APRM system and the RPS are not initiators of any accidents previously evaluated. As a result, the proposed change does not affect the probability of any accident previously evaluated. The APRM system and the RPS functions act to mitigate the consequences of accidents previously evaluated. The reliability of APRM system and the RPS is not significantly affected by removing the gain adjustment requirement on the APRM channels when the APRMs are calibrated conservatively with respect to the calculated heat balance. This is because the actual core thermal power at which the reactor will automatically trip is lower, thereby increasing the margin to the core thermal limits and the limiting safety system settings assumed in the safety analyses. The consequences of an accident during the adjustment of the APRM instrumentation are no different from those during the existing surveillance testing period or the existing time allowed to restore the instruments to operable status. As a result, the ability of the APRM system and the RPS to mitigate any accident previously evaluated is not significantly affected.
Therefore, the proposed change does not involve a significant increase in the

             
GO2-21-042 Enclosure 1 Page 4 of 5 probability or consequences of an accident previously evaluated.
: 2.       Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?
Response: No The proposed change does not alter the protection system design, create new failure modes, or change any modes of operation. The proposed change does not involve a physical alteration of the plant; no new or different kind of equipment will be installed. Consequently, there are no new initiators that could result in a new or different kind of accident.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
: 3.       Does the proposed change involve a significant reduction in a margin of safety?
Response: No The margin of safety provided by the APRM system and the RPS is to ensure that the reactor is shut down automatically when plant parameters exceed the setpoints for the system. Any reduction in the margin of safety resulting from the adjustment of the APRM channels while continuing operation is considered to be offset by delaying a plant shutdown (i.e., a transient) for a short time with the APRM system, the primary indication of core power and an input to the RPS, not calibrated. Additionally, the short time period required for adjustment is consistent with the time allowed by Technical Specifications to restore the core power distribution parameters to within limits and is acceptable based on the low probability of a transient or design basis accident occurring simultaneously with inaccurate APRM channels.
The proposed change does not alter setpoints or limits established or assumed by the accident analyses. The Technical Specifications continue to require operability of the RPS functions, which provide core protection for postulated reactivity insertion events occurring during power operating conditions consistent with the plant safety analyses.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, Energy Northwest concludes that the proposed amendment presents no significant hazards considerations under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

             
GO2-21-042 Enclosure 1 Page 5 of 5 5.2       Conclusions 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 EVALUATION 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. However, 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 effluents 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==

7.1 TSTF-546-A Traveler, Revise APRM Channel Adjustment Surveillance Requirement, Revision 0, dated August 31, 2017 (ADAMS Accession No, ML17206A431) 7.2 Letter from P.R. Simpson (Manager - Licensing, Exelon Generation Company, LLC) to NRC, Application to Revise Technical Specifications to Modify the APRM Channel Adjustment Surveillance Requirement, dated Jun 15, 2018 (ADAMS Accession No. ML18166A197) 7.3 Letter from B. Purnell (NRC) to B.C. Hanson (President and Chief Nuclear Officer (CNO), Excelon Nuclear), Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; James A. Fitzpatrick Nuclear Power Plant; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Peach Bottom Atomic Power Station, Units 2 and 3; and Quad Cities Nuclear Power Station, Units 1 and 2- Issuance of Amendments to Revise the Average Power Range Monitor Requirements (EPID L-2018-LLA-0167), dated January 16, 2019 (ADAMS Accession No. ML18304A365)

       
GO2-21-042 Enclosure 2 Proposed Technical Specification Changes (Mark-Up)

                     
RPS Instrumentation 3.3.1.1 3.3 INSTRUMENTATION 3.3.1.1        Reactor Protection System (RPS) Instrumentation LCO 3.3.1.1                   The RPS instrumentation for each Function in Table 3.3.1.1-1 shall be OPERABLE.
APPLICABILITY:                According to Table 3.3.1.1-1 ACTIONS
                 ------------------------------------------------------------NOTES---------------------------------------------------------
: 1. Separate Condition entry is allowed for each channel.
: 2. When Functions 2.b and 2.c channels are inoperable due to the calculated power exceeding the average power range monitor (APRM) output by more than 2% rated thermal power (RTP) while operating at  25% RTP, entry into associated Conditions and Required Actions may be delayed for up to 2 hours.
CONDITION                                REQUIRED ACTION                            COMPLETION TIME A. One or more required                   A.1        Place channel in trip.                   12 hours channels inoperable.
OR
                                                                        -------------NOTE---------------
Not applicable for Functions 2.a, 2.b, 2.c, 2.d, or 2.f.
A.2        Place associated trip                    12 hours system in trip.
                   ---------------NOTE--------------         B.1        Place channel in one trip                6 hours Not applicable for                              system in trip.
Functions 2.a, 2.b, 2.c, 2.d, or 2.f.                         OR B.2        Place one trip system in                 6 hours B. One or more Functions                             trip.
with one or more required channels inoperable in both trip systems.
Columbia Generating Station                               3.3.1.1-1                Amendment No. -       169-- 225
                                                                                                                                  - -226
                                                                                                                                       - -253

               
RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.3.1.1.2        -------------------------------NOTE------------------------------
Not required to be performed until 12 hours after THERMAL POWER  25% RTP.
Verify the absolute difference betweencalculated                       In accordance power does not exceed the average power range                          with the monitor (APRM) channels and the calculated power                       Surveillance by greater than 2% RTP while operating at                            Frequency 25% RTP.                                                             Control Program SR 3.3.1.1.3        -------------------------------NOTE------------------------------
Not required to be performed when entering MODE 2 from MODE 1 until 12 hours after entering MODE 2.
Perform CHANNEL FUNCTIONAL TEST.                                       In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.4        Perform CHANNEL FUNCTIONAL TEST.                                       In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.5        Verify the source range monitor (SRM) and                              Prior to intermediate range monitor (IRM) channels overlap.                     withdrawing SRMs from the fully inserted position SR 3.3.1.1.6        -------------------------------NOTE------------------------------
Only required to be met during entry into MODE 2 from MODE 1.
Verify the IRM and APRM channels overlap.                              In accordance with the Surveillance Frequency Control Program Columbia Generating Station                         3.3.1.1-4              Amendment No. 179 225 226 253

        
GO2-21-042 Enclosure 3 Proposed Technical Specification Bases Markup Pages For information Only

          
RPS Instrumentation B 3.3.1.1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
: 11. Manual Scram The Manual Scram push button channels provide signals, via the manual scram logic channels, to each of the four RPS logic channels that are redundant to the automatic protective instrumentation channels and provide manual reactor trip capability. This Function was not specifically credited in the accident analysis, but it is retained for the overall redundancy and diversity of the RPS as required by the NRC approved licensing basis.
There is one Manual Scram push button channel for each of the four RPS logic channels. In order to cause a scram it is necessary that at least one channel in each trip system be actuated.
There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the push buttons.
Four channels of Manual Scram with two channels in each trip system arranged in a one-out-of-two logic, are available and required to be OPERABLE in MODES 1 and 2, and in MODE 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies, since these are the MODES and other specified conditions when control rods are withdrawn.
ACTIONS              A Note 1 has been provided to modify the ACTIONS related to RPS instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPS instrumentation channels provide appropriate compensatory measures for separate, inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable RPS instrumentation channel.
Note 2 has been provided to modify the ACTIONS for the RPS instrumentation functions of APRM Simulated Thermal Power - High (Function 2.b) and APRM Neutron Flux - High (Function 2.c) when they are inoperable due to failure of SR 3.3.1.1.2 and gain adjustments are necessary. Note 2 allows entry into the associated Conditions and Required Actions to be delayed for up to 2 hours if the APRM is indicating a lower value than the calculated power (i.e. the gain adjustment factor (GAF) is High (non-conservative)). The GAF for any channel is defined as the power value determined by the heat balance divided by the APRM Columbia Generating Station           B 3.3.1.1-19                                       Revision 87

           
RPS Instrumentation B 3.3.1.1 reading for that channel. Upon completion of the gain adjustment, or expiration of the allowed time, the channel must be returned to OPERABLE status or the applicable Condition entered and the Required Actions taken. This Note is based on the time required to perform gain adjustments on multiple channels.
A.1 and A.2 Because of the diversity of sensors available to provide trip signals and the redundancy of the RPS design, an allowable out of service time of 12 hours has been shown to be acceptable (Refs. 11 and 14) to permit restoration of any inoperable channel to OPERABLE status. However, this out of Columbia Generating Station            B 3.3.1.1-20                                   Revision 87

           
RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.3.1.1.2 To ensure that the APRMs are accurately indicating the true core average power, the APRMs are calibrated adjusted to the reactor power calculated from a heat balance if the heat balance calculated reactor power exceeds the APRM channel output by more than 2% RTP. If the heat balance calculated reactor power exceeds the APRM channel output by more than 2% RTP, the APRM is not declared inoperable, but must be adjusted consistent with the heat balance calculated reactor power. If the APRM cannot be adjusted, the channel is declared inoperable.
This Surveillance does not preclude making APRM channel adjustments, if desired, when the heat balance calculated reactor power is less than the APRM channel output. To provide agreement between the APRM indicated power and to preserve operating margin, the APRM channels are normally adjusted to within +/-2% of the heat balance calculated reactor power. However, this agreement is not required for OPERABILITY when APRM output indicates higher reactor power than the heat balance calculated reactor power.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
A restriction to satisfying this SR when < 25% RTP is provided that requires the SR to be met only at  25% RTP because it is difficult to accurately maintain APRM indication of core THERMAL POWER consistent with a heat balance when < 25% RTP. At low power levels, a high degree of accuracy is unnecessary because of the large inherent margin to thermal limits (MCPR and APLHGR). At  25% RTP, the Surveillance is required to have been satisfactorily performed in accordance with SR 3.0.2. A Note is provided which allows an increase in THERMAL POWER above 25% if the Frequency is not met per SR 3.0.2. In this event, the SR must be performed within 12 hours after reaching or exceeding 25% RTP. Twelve hours is based on operating experience and in consideration of providing a reasonable time in which to complete the SR.
SR 3.3.1.1.3 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
Columbia Generating Station            B 3.3.1.1-26                                  Revision 93

        
GO2-21-042 Enclosure 4 Proposed Technical Specification Changes (Re-Typed)

                     
RPS Instrumentation 3.3.1.1 3.3 INSTRUMENTATION 3.3.1.1        Reactor Protection System (RPS) Instrumentation LCO 3.3.1.1                   The RPS instrumentation for each Function in Table 3.3.1.1-1 shall be OPERABLE.
APPLICABILITY:                According to Table 3.3.1.1-1 ACTIONS
                 ------------------------------------------------------------NOTES--------------------------------------------------------
: 1. Separate Condition entry is allowed for each channel.
: 2. When Functions 2.b and 2.c channels are inoperable due to the calculated power exceeding the average power range monitor (APRM) output by more than 2% rated thermal power (RTP) while operating at  25% RTP, entry into associated Conditions and Required Actions may be delayed for up to 2 hours.
CONDITION                                REQUIRED ACTION                            COMPLETION TIME A. One or more required                   A.1        Place channel in trip.                   12 hours channels inoperable.
OR
                                                                        -------------NOTE---------------
Not applicable for Functions 2.a, 2.b, 2.c, 2.d, or 2.f.
A.2        Place associated trip                    12 hours system in trip.
                   ---------------NOTE--------------         B.1        Place channel in one trip                6 hours Not applicable for                              system in trip.
Functions 2.a, 2.b, 2.c, 2.d, or 2.f.                         OR B.2        Place one trip system in                 6 hours B. One or more Functions                             trip.
with one or more required channels inoperable in both trip systems.
Columbia Generating Station                               3.3.1.1-1                Amendment No. -       169-- 225
                                                                                                                                  - -226
                                                                                                                                       - -253

               
RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.3.1.1.2        -------------------------------NOTE------------------------------
Not required to be performed until 12 hours after THERMAL POWER  25% RTP.
Verify the calculated power does not exceed the                        In accordance average power range monitor (APRM) channels by                         with the greater than 2% RTP while operating at  25% RTP.                      Surveillance Frequency Control Program SR 3.3.1.1.3        -------------------------------NOTE------------------------------
Not required to be performed when entering MODE 2 from MODE 1 until 12 hours after entering MODE 2.
Perform CHANNEL FUNCTIONAL TEST.                                       In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.4        Perform CHANNEL FUNCTIONAL TEST.                                       In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.5        Verify the source range monitor (SRM) and                              Prior to intermediate range monitor (IRM) channels overlap.                     withdrawing SRMs from the fully inserted position SR 3.3.1.1.6        -------------------------------NOTE------------------------------
Only required to be met during entry into MODE 2 from MODE 1.
Verify the IRM and APRM channels overlap.                              In accordance with the Surveillance Frequency Control Program Columbia Generating Station                         3.3.1.1-4              Amendment No. 179 225 226 253}}