ML17363A215

Supplemental Information for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2

ML17363A215
Person / Time
Site:	Nine Mile Point
Issue date:	12/27/2017
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP2L2662
Download: ML17363A215 (15)

Text

Exelon Generation NMP2L2662 December 27 , 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington , DC 20555-0001 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRG Docket No. 50-41 O 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90

Subject:

Supplemental Information for Nine Mile Point Nuclear Station, Unit 2 , to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2

References:

1. Letter from J. Barstow (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request -Revise Technical Specifications to Adopt TSTF-542, 'Reactor Pressure Vessel Water Inventory Control,'

Revision 2," dated February 28 , 2017 2. Letter from M. Marshall (Senior Project Manager, U.S Nuclear Regulatory Commission) to Mr. B. Hanson (Exelon Generation Company, LLC), "Nine Mile Point Nuclear Station, Unit 2 -Request for Additional Information Regarding License Amendment Concerning Reactor Pressure Vessel Water Inventory Control (CAC No. MF9357)," dated October 10, 2017 3. Letter from J. Barstow (Exelon Generation Company , LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information by the Office of Nuclear Reactor Regulation to Support Review of Nine Mile Point Nuclear Station, Unit 2, License Amendment Request to Adopt TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control ," dated November 3 , 2017 4. Public Meeting Announcement, " Meeting with Technical Specifications Task Force (TSTF) RE: TSTF-542 , 'Reactor Pressure Vessel Water Inventory Control,'" dated October 27 , 2017 By letter dated February 28, 2017 (Reference 1 ), Exelon Generation Company, LLC (Exelon) requested to change the Nine Mile Point Nuclear Station, Unit 2 (NMP2) Technical Specifications (TS). The proposed amendment request would revise NMP2 TS by replacing the existing specifications related to Operations with a Potential for Draining the Reactor Vessel with revised requirements for Reactor Pressure Vessel Water Inventory Control to protect / Safety Limit 2.1.1.3. A DD ~/J-U.S. Nuclear Regulatory Commission Supplemental Information TSTF-542 , Reactor Pressure Vessel Water Inventory Control Docket No. 50-410 December 27 , 2017 Page 2 with revised requirements for Reactor Pressure Vessel Water Inventory Control to protect Safety Limit 2.1.1.3. On October 10, 2017 , the U.S. Nuclear Regulatory Comm i ssion (NRC) provided a Request for Additional Information (RAI). On November 3, 2017 , Exelon submitted to the NRC the RAI response (Reference 3). On October 27 , 2017 , a public meeting was held by the NRC and the Boiling Water Reactor Owners Group (BWROG) to discuss a proposed TSTF-542 variation affecting BWR/5 and 6 plants. As noted in the NRC Public Meeting Announcement (Reference 4 ), the details of the proposed variation were provided in ADAMS Accession Number ML 17289A902. Attachment 1 to this letter contains the supplemental information to address the proposed variation provided in ADAMS Accession Number ML 17289A902 and Attachment 2 provides the revised TS and Bases markups. This supplement supersedes the RAI response to Question RAl-1 provided on November 3 , 2017 (Reference 3). Also , two additional supplements are provided in Attachment

2. First , an editorial error was noted in TSTF-542 affecting Bases Page B 3.3.5.2-8. The statement, "This Function iso lates the Group 11 valves ," is revised to refer to the Group 5 valves. Second , TS page 3.6.4.3-2 , Condition E , was incompletely revised in the original submittal (Reference 1 ). Condition E contains the phrase , " ... or during OPDRVs ," that is deleted to meet the intent of TSTF-542 , Revision 2. See Attachment 2 for the revised TS and Bases markups. Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference

1. The supplemental information provided in this letter does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration.

Furthermore , the supplemental information provided in this letter does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

With the supplemental informat ion provided in Attachments 1 and 2 to this letter, Exelon requests approval of the proposed amendment by March 1 , 2018. The requested approval date supports the implementation of TSTF-542 prior to the start of the refueling outage. Once approved , the amendment shall be implemented no later than the start of NMP2 2018 refueling outage. There are no commitments contained i n this response.

If you should have any questions regarding this submitta l , please contact Ron Reynolds at 610-765-5247.

U.S. Nuclear Regulatory Commission Supplemental Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Docket No. 50-410 December 27 , 2017 Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 27th day of December 2017. Jam+/--.) I. J r--r Director -Licensing

& Regulatory Affa i rs Exelon Generation Company, LLC Attachment 1: Supplemental Information Attachment 2: Revised Technical Specification Pages and Bases Marked-Up Pages cc: USNRC Region I Regional Administrator USNRC Senior Resident Inspector

-NMP USNRC Project Manager, NRR -NMP A. L. Peterson , NYSERDA w/attachments " " "

ATTACHMENT 1 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License NPF-69 Docket No. 50-410 SUPPLEMENTAL INFORMATION

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*--------------------Supplemental Information TSTF-542 , R eactor Pres s ure Ves s el Wate r In vent ory Con trol Docket No. 50-410 Attachment 1 Page 1 of 2 The Nine Mile Point Unit 2 (NMP2) License Amendment Request (LAR) submittal dated February 28 , 2017, for adoption of TSTF-542 , is revised to reflect the changes to the Techn i cal Specifications (TS) and Bases as agreed upon between the Boiling Water Reactor Owners Group (BWROG) and the NRC. These changes were discussed during the Public Meeting held on October 27 , 2017 , with the proposed variation documented in ADAMS Accession Number ML 17289A902. Subsequently , a needed change to Surveillance Requirement (SR) 3.5.2.8 was identified for consistency with the proposed var i ation. See Attachment 2 for revised markups. Section 2.2 , Variations , of the LAR is revised to add the following: Table 3.3.5.2-1 is revised to reflect the NMP2 design. Function 3 , High Pressure Core Spray (HPCS) System , Function 3.a , "Reactor Vessel Water Level -High, Level 8 ," and Function 3.e , "Manual initiation

," that appear in TSTF-542 are not included i n the proposed Technical Specifications. This corrects an error in TSTF-542 that affects the BWR/5 and BWR/6 ECCS instrumentation requirements.

The purpose of the manual init i ation function is to allow manual actuation of the ECCS subsystem required by TS 3.5.2 to mitigate a drain i ng event. The Reacto r Vessel Water Level -High, Level 8 signal prevents overfill i ng of the reactor vessel i nto the ma i n steam lines by closing the HPCS injection valves when the water l evel is above the Level 8 setpoint.

Therefore , if HPCS is the required ECCS subsystem and the water level is above Level 8 , manually actuating Function 3.e will not i nject inventory into the reactor vessel. This is not the desired response. If t he Level 8 function is retained in Table 3.3.5.2-1 , the function would need to be rendered inoperable in order to inject water when above the Level 8 water level. Th i s would not be consistent with including the funct i on i n Table 3.3.5.2-1. NMP2 has the capability to manually start the HPCS pump and to open the HPCS i n j ection valve i f needed , not utilizing Functions 3.a and 3.e. If desired to inject water into the reactor pressure vessel using the HPCS , the reactor operator can follow procedural steps to take manual control of the pump and injection valve to add inventory.

If the water level is above Level 8 , then manua l override of the Level 8 function can be performed to allow the HPCS injection valve to be opened. These act i ons can be performed from the control room and can be accomplished well within the 1-hour m i nimum drain time limit specified in TS 3.5.2 , Condition E. Consequently , the Function 3.a and 3.e instrumentation functions are not needed to actuate the HPCS subsystem components to mitigate a draining event. The ability to override the HPCS Level 8 isolation is already part of the BWR Emergenc y Operating Procedures and is practiced during Operator training.

SR 3.5.2.8 i s revised to assure that the HPCS manual start capability (including the HPCS Level 8 isolation ove r ride feature) i s tested.

Supplemental Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Docket No. 50-410 Attachment 1 Page 2 of 2 TS submittal page 3.3.5.2-5 (Table 3.3.5.2-1 , page 2 of 2) is revised to delete Functions 3.a. and 3.e. The remaining Functions under 3. High Pressure Core Spray (HPCS) System are renumbered accordingly.

See Attachment 2 for revised markups. TS submittal page 3.5.2-5 is revised to re-word SR 3.5.2.8 to say, "Verify the required LPCI or LPCS subsystem actuates on a manual initiation signal or the required HPCS subsystem can be manually operated." See Attachment 2 for revised markups. Bases submittal pages B 3.3.5.2-5 through -8 are revised as follows: Functions 3.a and 3.e are deleted. The remaining Functions under 3. High Pressure Core Spray (HPCS) System are renumbered accordingly.

SR 3.5.2.8 description on Bases submittal page B 3.5.2-6 is revised to assure that the HPCS manual start capability (including the HPCS Level 8 isolation override feature) is tested. See Attachment 2 for revised markups. Also , two additional supplements are provided in this submittal.

First, an editorial error was noted in TSTF-542 affecting Bases Page B 3.3.5.2-8. The statement "This Function isolates the Group 11 valves" is revised to refer to the Group 5 valves. Second , TS page 3.6.4.3-2 was incompletely revised in the original submittal (Reference 1 ). Condition E contains the phrase ," ... or during OPDRVs ," that is deleted to meet the i ntent of TSTF-542 , Revision 2. See Attachment 2 for the revised TS and Bases markups.

ATTACHMENT 2 Nine Mile Point Nuclear Station , Unit 2 Renewed Facility Operating License NPF-69 Docket No. 50-410 PROPOSED TECHNICAL SPECIFICATION and BASES MARKED-UP PAGES TS Pages 3.3.5.2-5 3.5.2-5 3.6.4.3-2 Bases Pages B 3.3.5.2-5 thru -8 B 3.5.2-6

3. FUNCTION HPCS Pump Discharge Pressure-High (Bypass) (d) HPCS System Flow Rate-Low (Bypass) -JI 4 RHR System Isolation

~-a. Reactor Vessel Water Level-Low , Level 3 5. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water Level-Low Low , Level 2 RGIG SysteAeiRPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 2 of 2) RPV Water Inven t ory Control Instrumentat i on APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 4 , 5 4 , 5 (c) (c) CONDITIONS REFERENCED REQUIRED FROM CHANNELS PER REQUIRED FUNCTION ACTION A.1 Delete 1 per pump (a) 1 per pump Sul3system (a) 2 i n one Trip sys t em 2 i n one Trip system F F B B SURVEILLANCE REQUIREMENTS SR 3.3.5.2.2 SR 3.3.5.2.1 SR 3.3.5.2.2 SR 3.3.5.2.1 SR 3.3.5.2.2 SR 3.3.5.2.1 SR 3.3.5.2.2 SR 3.3.5.2.1 SR 3.3.5.2.2 ALLOWABLE VALUE ;,; 220 psig > 580 gpm and s 720 gpm ?: 157.8 inches ?: 101.8 inches (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2 , " Reactor Pressure Vessel Water Inventory Control." (b) When HPCS is OPERABLE for compliance with LCO 3.5.2 , " RPV Water Inventory Control ," and aligned to the condensate storage tank. (c) When automatic isolation of the associated penetration flow path(s) is credited in ca l culating DRAIN TIME. (d) The i njection functions of Drywell Pressure-High aAa MaAual IAitiatiaA are\:not required to be OPERABLE with reactor steam dome pressur ess than 600 ps~ JI is Delete NMP2 3.3.5.2-5 Amendment RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.6 SR 3.5.2.7 SR 3.5.2.8 NMP2 SURVEILLANCE

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N()TE------

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Not required to be met for ECCS pumps aligned for shutdown cooling. ()perate the required ECCS injection/spray subsystem through the recirculation line for 10 minutes. Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal. -----------------------------N()TE--------------

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Vessel injection/spray may be excluded. Verify the required EGGS il"ljeetiel"IISJ"rey subsystem actuates on a manual initiation signal. \ 1' I FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program I ~LPClorLPCS I or the required HPCS subsystem can be manually operated 3.5.2-5 Amendment 91 , 152 ACTIONS CONDITION C. (continued)

D. Two SGT subsystems inopera bl e in MODE 1 , 2 , or 3. E. Two SG T subsystems inoperable during movem en t of recently irradiated fuel asse m blies in the secondary containment

'!' t;*i s g O P;R¥> t Delete Delete comma and add period NMP2 REQ UIR ED ACTION C.2.1 Suspend movement of recently irradiated f u el assemblies in the secondary containment.

AWQ G.2.2 li;iitia~e aetiei;i te 6~8f38Fl9 Qi;;!i:;;)~~1,8. D.1 Enter LCO 3.0.3. E.1 -----------NOTE-----------

LCO 3.0.3 is not applicable.

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Suspe n d movement of recen tl y irradiate d fuel assem b lies in the sec o ndary conta i nment. AWQ 3.6.4.3-2 SGT System 3.6.4.3 CO M PLETION TI M E Immediately lmmeeiately Immediately Immediately

~99FltiFl~89~

Ame n dment 91, 101 ,

Delete . NMP2 RPV Water Inventory Control Instrumentation B 3.3.5.2 High RPV water le'lel indioates that suffioient oooling water in 1 1entory exists in the reaotor 'lessel suoh that there is no danger to the fuel. Theref.ore , the Le'lel 8 signal is used to olose the HPCS injeotion 1 1alve to pre'lent O'lerflow into the main steam lines (MSLs). Reaotor Vessel Water Le'lel High , Le'lel 8 signals for HPCS are initiated from four differential pressure transmitters from the wide range 1.Yater le'lel measurement instrumentation. One ohannel assooiated with the HPCS System required to be OPeRABLe by LCO 3.5.2 is required to be OPeR/\BLe. The reaotor Vessel V\f.ater Level High , Le'lel 8 Allowable Value is ohosen to isolate flow from the HPCS System prior to water o'lerflowing into the MSLs. Vessel when manually initiated . . Pump Suction Pressure -Low Low pump suction pressure , which is an indication of low level in the CST , indicates the unavailability of an adequate supply of makeup water from this normal source. Normally the suction valves between HPCS and the CST are open and , upon receiving a HPCS initiation signal , water for HPCS injection would be taken from the CST. However , if the pump suction pressure (indicating low water level in the CST) falls below a preselected level for a preselected time , first the suppression pool suction valve automatically opens , and then the CST suction valve automatically closes. This ensures that an adequate supply of makeup water is available to the HPCS pump. To prevent losing suction to the pump , the suction valves are interlocked so that the suppression pool suction valve must be open before the CST suction valve automatically closes. The Functions are implicitly assumed in the accident and transient analyses (which take credit for HPCS) since the analyses assume that the HPCS suction source is the suppression pool. (continued)

B 3.3.5.2-5 Revision O I BASES APPLICABLE SAFETY ANALYSIS , LCO , and APPLICABILITY (continued) 3.b., 3.c. NMP2 RPV Water Inventory Control Instrumentation B 3.3.5.2 Pump Suction Pressure -Low signals are init i ated from two pressure transmitters. The Pump Suction Pressure -Low Function Allowable Value is high enough to ensure adequate pump suction head while water is being taken from the CST. The pressure at which the transfer occurs also ensures sufficient volume of water is used by the HPCS pump before the transfer occurs and i s analytically determined to prevent the effects of vortexing. The Pump Suction Pressure -Timer Function is init i ated by a single time delay relay. While the Pump Suction Pressure -Timer Function is provided to prevent spurious suction source automatic swaps , the Allowable Value is low enough such that the automatic suction swap from the CST to the suppression pool will occur before adequate pump suction head is lost. One channel of the Pump Suction Pressure -Low Function are only required to be OPERABLE when HPCS is required to be OPERABLE to ensure that no s i ngle instrument failure can preclude HPCS swap to suppression pool source. In addition , one channel of the Pump Suction Pressure -Timer Function is only requi r ed to be OPERABLE when HPCS is required to be OPERABLE.

Thus , the Functions are required to be OPERABLE in MODES 1 , 2 , and 3. In MODES 4 and 5 , the Functions are required to be OPERABLE only when HPCS is required to be OPERABLE to fulfill the requirements of LCO 3.5.2 , HPCS is aligned to the CST , and the CST water level is not within the limits of SR 3.5.2.2. With CST water level within limits , a sufficient supply of water exists for injection to minimize the consequences of a vessel draindown event. Refer to LCO 3.5.1 and LCO 3.5.2 for HPCS App l icability Bases . . , .. HPCS Pump Discharge Pressure -High (Bypass) and HPCS System Flow Rate -Low {Bypass) The m i nimum flow instruments are provided to protect the HPCS pump from overheating when the pump is operating and the associated injection valve is not fully open. The minimum flow line valve is opened when low flow and high pump discharge pressure are ( continued)

B 3.3.5.2-6 Revision O I BASES APPLICABLE SAFETY ANALYSIS , LCO , and APPLICABILITY (continued)

NMP2 RPV Water Inventory Control Instrumentation B 3.3.5.2 sensed , and the valve is automatically closed when the flow rate is adequate to protect the pump or the discharge pressure is low (indicating the HPCS pump is not operating). The HPCS System Flow Rate -Low (Bypass) and HPCS Pump Discharge Pressure -High (Bypass) Functions are assumed to be OPERABLE and capable of closing the minimum flow valve to ensure that the ECCS flow assumed during the transients and accidents analyzed in References 1 , 2 , and 3 are met. The core cooling function of the ECCS , along with the scram action of the RPS , ensures that the fuel peak cladding temperature remains below the limits of 10 CFR 50.46. One d i fferential pressure transmitter is used to detect the HPCS Systems' flow rate. The logic is arranged such that the transmitter causes the minimum flow valve to open , provided the HPCS pump discharge pressure , sensed by another transmitter , is high enough (indicating the pump is operating). The logic will close the minimum flow valve once the closure setpoint is exceeded. (The valve will also close upon HPCS pump discharge pressure decreasing below the setpoint.)

The HPCS System Flow Rate -Low and HPCS Pump Discharge Pressure -High Allowable Value is high enough to ensure that pump flow rate is sufficient to protect the pump , yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core. The HPCS Pump Discharge Pressure -High Allowable Value is set high enough to ensure that the valve will not be open when the pump is not operating. One channel of each Function associated with one pump is required to be OPERABLE when HPCS is required to be OPERABLE by LCO 3.5.2 in MODES 4 and 5. 3.e. Manual Initiation The Manual Initiation switoh and push button ohannels introduoe a signal into the HPGS logio to pro\*ide manual initiation oapability and is redundant to the automatio proteotive instrumentation.

There is one switoh and push button (with two ohannels) for the HPCS System. One ohannel of the Manual Initiation Funotion is only required to be OPER/\8LE in MODES 4 and 5 when the assooiated EGGS subsystem is required to be OPER/\8LE per LCO 3.5.2. B 3.3.5.2-7 Revision O I BASES APPLICABLE SAFETY ANALYSIS , LCO , and APPLICABILITY ( continued)

NMP2 RPV Water Invento r y Control Instrumentation B 3.3.5.2 RHR System Isolation 4.a -Reactor Vessel Water Level -Low. Level 3 The definition of DRA I N TIME allows crediting the closing of penetration flow paths that are capable of being automatically isolated by RPV water level isolation instrumentation prior to the RPV water level be i ng equal to the TAF. The Reactor Vessel Water Level -Low , Level 3 Function is only required to be OPERABLE when automatic isolation of the associated RHR penetration flow path is credited in calculat i ng DRAIN TIME. Reactor Vessel Water Level -Low , Level 3 signals are initiated from two differential pressure transmitters (two per trip system) that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level -Low , Level 3 Function are available , only two channels (all in the same trip system) are requi r ed to be OPERABLE. The Reactor Vessel Water Level -Low , Level 3 Allowable Value was chosen to be the same as the RPS Reactor Vessel Water Level -Low , Level 3 Allowable Value (LCO 3.3.1.1 ), since the capability to cool the fuel may be threatened. This Function isolates the Group ¥valve--;:

Reactor Water Cleanup (RWCU) System Isolation 5.a -Reactor Vessel Water level -Low Low, Level 2 The definition of DRAIN TIME allows crediting the closing of penetration flow paths that are capable of being automatically isolated by RPV water level isolation instrumentation prior to the RPV water level being equal to the TAF. The Reactor Vessel Water Level -Low Low , Level 2 Function associated with RWCU System isolation may be credited for automatic isolation of penetration flow paths associated with the RWCU System. (continued)

B 3.3.5.2-8 Revision O I BASES SURVEILLANCE REQUIREMENTS RPV Water Inventory Control~ St;iwt*1ewr1 B 3.5.2 SR 3.5.2.4-§ (seRtiRweEil)

Verifying that the required ECCS injection/spray subsystem can be manually started and operate for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. Testing the ECCS injection/spray subsystem through the recirculat i on line is necessary to avoid overfilling the refueling cavity. The minimum operating time of 10 minutes was based on engineering judgment.

~eeewse ef tt;ie lew i,resswre er1*1 lew temi,eretwre eer1*1itier1s iFl MQgl!!s 4 eR*1 §, sw~ieieRt tiFRe will lile eveileele te FReRwelly eli~R er,;ie iRitiete bPCI swlils','steFR ei,eretieR te ~re1w1iEile eere eeeliR~ ~rier te i,estwlet0*1 fwel wr1e0vePf. Tt;iis will er1swr0 e*1e*lwete eere ee0lir1~ if er1 ir1e*1vert0r1t vessel *1reir,;i*10wr1 st;iewl*1 eeewr. Tt;;ie Swr1w1eiller,;iee is FReEilifieEil B',' a ~lets wt;;iiet;;i S'KSFR~ts S','SteFR 1;1er;it flew i,ett;is ei,0r1e*1 wr1*1er e*1mir1istretive e0r1trnl.

Tt;ie e*1mir1istretive eeRtrnl st;iewl*1 ee ~r9eeEilwrelii!!eEil eR*1 iRelwele stetieR a *1e*1ieete*1 iR*1ivi*1wel et tt;ie systeFR ver;it flew i,ett;;i wt;ie is iR eer,;itir,;iwe1s1s eeFRFRWRieetieR witt;;i tt;;ie ei,ereters iR tt;;ie eer;itrel reeFR. Tt;;iis iR*1iviEilwel will l;ieve a metl;ie*1 te rei,ielly elese tl;ie system ver1t flew i,ett;i if Eilireete*1. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.5.2.7 Verifying that each valve credited for automatically isolating a .---------------.

penetration flow path actuates to the isolation position on an Insert A The HPCS System is verified to start manually from a standby configuration , and includes the ability to override the RPV Level 8 injection valve isolation.

actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.5.2.8 The required E CS subsystem is required to actuate on a manual initiaf n signal. This Surveillance verifies that a -------I[pcfl

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manual initi ion signal will cause the required~~

c.....::..:..J NMP2 subsystem , PCS System , or f9pcg gystem to start and operate as designed , including pump startup and actuation of all automatic valves to their required positions. The Surveillance Frequency is controlled under the urveillance Frequency Control Program. Insert A This SR i s modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active B 3.5.2-6 Revision 0 , 43 (A150), 44 (A 152)