ML12139A304

Pilgrim, Entergy Response to NRC Request for Additional Information Dated March 26, 2012, in Support of Proposed License Amendment: Revision to Condensate Storage Tank (CST) Low Level Trip Setpoint

ML12139A304
Person / Time
Site:	Pilgrim
Issue date:	05/16/2012
From:	Smith R G Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME7545
Download: ML12139A304 (43)

Text

SEntergy Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Robert G. Smith, P.E.Site Vice President May 16, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35

REFERENCES:

Entergy Response to NRC Request for Additional Information dated March 26, 2012, in support of Proposed License Amendment:

Revision to Condensate Storage Tank (CST) Low Level Trip Setpoint (TAC No.ME7545)1. NRC Letter, Request for Additional Information

-Pilgrim Nuclear Power Station RE: Revision to Condensate Storage Tank Low Level Setpoint, dated March 26, 2012 2. Entergy Letter No. 2.11.040, Proposed License Amendment:

Revision to Technical Specification (TS) Table 3.2.B for the Condensate Storage Tank (CST) Low Level Trip Setpoint and Corrections to Typographical Errors Incurred during Prior License Amendment Nos. 223 and 228, dated October 28, 2011 LETTER NUMBER: 2.12.035

Dear Sir or Madam:

The Enclosure to this letter dockets Entergy's response to NRC Request for Additional Information (RAI) forwarded by Reference

1. The Enclosure supports the review of Entergy Proposed License Amendment

-Revision to Condensate Storage Tank (CST) Low Level Trip Setpoint (Reference 2).The Enclosure contains the following attachments:

Attachment 1: Pilgrim Calculation No. IN1-245, "Setpoint Calculation for PS-2390A &B, Condensate Tank Low Level Transfer", Rev. 2, dated October 7, 2009.Attachment 2: Pilgrim Procedure No. 8.M.2-2.5.6, "HPCI Condensate Storage Tank Level", Revision 35.Attachment 3: Revised Technical Specification Page 3/4.2-16 pD)

Entergy Nuclear Operations, Inc Pilgrim Nuclear Power Station Letter Number 2.12.035 Page 2 of 2 The Entergy response to the NRC RAI supports the proposed License Amendment and the No Significant Hazards Consideration determination submitted by Reference 2.This letter contains no new regulatory commitments.

If you have any questions regarding the subject matter, please contact Joseph R. Lynch at (508)830-8403.I declare under penalty of perjury that the foregoing is true and correct. Executed on the 16 day of X L!W ,2012.Sincerely, Robert G. Smith, P.E.Site Vice President

Enclosure:

Entergy/Pilgrim Response to NRC Request for Additional Information Dated March 26, 2012 (67 pages)cc: Mr. Richard Guzman, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North O-8C2 11555 Rockville Pike Rockville, MD 20852 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 NRC Resident Inspector Pilgrim Nuclear Power Station John Giarusso, Jr.Planning and Preparedness Section Chief Mass Emergency Management Agency (MEMA)400 Worcester Road Framingham, MA 01702 Robert Gallaghar, Acting Director, Massachusetts Department of Public Health (MDPH)Radiation Control Program Commonwealth of Massachusetts 529 Main Street, Suite 1 M2A Charlestown, MA 02129-1121 ENCLOSURE TO ENTERGY LETTER NO 2.12.035 Enterqy/Pilirim Response to NRC Request for Additional Information Dated March 26. 2012 (67 pages including Attachments 1, 2 and 3)

ENCLOSURE TO ENTERGY LETTER NO 2.12.035 Enterqv/Pilqrim Response to NRC Request for Additional Information Dated March 26, 2012

References:

1. NRC Letter, Request for Additional Information

-Pilgrim Nuclear Power Station RE: Revision to Condensate Storage Tank Low Level Setpoint, dated March 26, 2012 2. Entergy Letter No. 2.11.040, Proposed License Amendment:

Revision to Technical Specification (TS) Table 3.2.B for the Condensate Storage Tank (CST) Low Level Trip Setpoint and Corrections to Typographical Errors Incurred during Prior License Amendment Nos. 223 and 228, dated October 28, 2011 NRC Request for Additional Information (RAI)Attachment 1 "Setpoint Calculation for PS-2390A&B, Condensate Tank Low Level Transfer' of the submitted license amendment request lists the As-Left Tolerance (ALT) value, but does not provide the basis for ALT determination.

The NRC staff notes that the proposed revised setpoint is one of the Limiting Safety System Settings (LSSS) listed for the NUREG-1433, Boiling Water Reactor/4 Plants in the Technical Specification Task Force (TSTF)-493, Revision 4, which is described in Federal Register Notice, Notice of Availability of the Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-493, Revision 4,"Clarify Application of Setpoint Methodology for LSSS Functions," Vol. 75, No. 90 / Tuesday, May 11,2010 (75 FR 26294).1. Describe whether and how you plan to apply the TSTF-493, Revision 4 for this setpoint.If you do not plan to adopt the TSTF-493, then explain how you will ensure compliance with 10 CFR 50.36 and Regulatory Issue Summary (RIS) 2006-17 by addressing items 2 and 3, below.2. As-Found Setpoint Evaluation:

Describe how surveillance test results and associated TS limits are used to establish operability of the safety system. Show that this evaluation is consistent with the assumptions and results of the setpoint calculation methodology.

Discuss the plant corrective action processes (including plant procedures) for restoring channels to operable status when channels are determined to be"inoperable" or "operable but degraded." If the criteria for determining operability of the instrument being tested are located in a document other than the TS (e.g., plant test procedure) explain how the requirements of 10 CFR 50.36 and RIS 2006-17 are met.3. As-Left Setpoint Control: Describe the controls employed to ensure that the instrument setpoint is, upon completion of surveillance testing, consistent with the assumptions of the associated analyses.

If the controls are located in a document other than the TS (e.g., plant test procedure) explain how the requirements of 10 CFR 50.36 and RIS 2006-17 are met.Page 1 of 3 ENCLOSURE TO ENTERGY LETTER NO 2.12.035 Enterg¥/Pilqrim Response to NRC Request for Additional Information Dated March 26, 2012 Enterq¥ Response: Response to Item 1: In response to the NRC Request for Additional Information, the Pilgrim technical staff held a conference call with the NRC staff on March 22, 2012 and discussed the setpoint methodology employed for Condensate Storage Tank (CST) water level setpoint calculations.

The methodology follows the guidance of Regulatory Guide 1.105, Rev 3, and is consistent with Regulatory Issue Summary (RIS) 2006-17 and TSTF-493, Rev 4, recognizing that the CST water level setpoint falls within the scope of Limiting Safety System Settings (LSSS) to comply with 10 CFR 50.36. Pilgrim is not adopting TSTF-493, Rev. 4, but follows the guidance as prescribed through RG 1.105, Revision 3 and RIS 2006-17 for applicable instruments specified in TSTF-493, Rev 4, within the scope of the proposed License Amendment.

Attachment 1 provides Calculation No. IN1-245, "Setpoint Calculation for PS-2390A & B, Condensate Tank Low Level Transfer" dated October 7, 2009. This calculation was previously submitted in our initial License Amendment submittal (Reference 2).Response to Items 2 and 3: Attachment 2, Pilgrim Procedure No. 8.M.2-2.5.6, "HPCI Condensate Storage Tank Level", Revision 35, provides details of setpoint calibration and surveillance in compliance with Technical Specification (TS) 3/4.2.B, Table 3/4.2.B. Surveillance test results and associated TS limits are used to establish operability of the safety system. The as-found and as-left values (no-adjust limits) are based upon limits established in the setpoint calculation INI1-245 (Attachment 1), which are consistent with the assumptions and results of the setpoint calculation methodology.

Thus the calibration and surveillance of instruments are in accordance with values derived through the setpoint methodology and will ensure safety system operability, thereby demonstrating compliance with 10 CFR 50.36.Procedure 8.M.2-2.5.6 controls the setpoints, addresses setpoint drift, as-found and as-left values, and surveillance practices for instruments that are required to protect LSSS safety limits.The Pilgrim staff follows Entergy fleet procedure EN-DC-1 15, "Engineering Change Process" to ensure that calculated setpoints that protect safety limits are translated accurately from design documents and associated analysis into calibration procedures.

The process includes the following elements.1. Instrumentation and Control (I&C) Design Engineering personnel prepare the design documents including calculations to determine the setpoint that will ensure that the protective action occurs at the proper value.2. The set point is implemented via an Engineering Change (EC) process, which complies with the applicable requirements of 10 CFR 50, Appendix A and B requirements, and licensing basis information.

3. I&C Maintenance personnel incorporate the calculated calibration values into the calibration procedure, as part of the EC process. The procedure 8.M.2-2.5.6 makes reference to the Technical Specification Value included in TS Table 3/4.2.B, and provides for the following:

Page 2 of 3 ENCLOSURE TO ENTERGY LETTER NO 2.12.035 Entergy/PilIrim Response to NRC Request for Additional Information Dated March 26, 2012* Acceptance Criteria, based on controlled engineering documents* Corrective Action* Acceptance Verification

• I&C Procedure Feedback Form 4. A condition report (CR) will be written in accordance with Entergy procedure, EN-LI-102,"Corrective Action Process", if the technician finds the as-found value is outside the no adjust limits. Condition Reports (CR) are coded for drift evaluation and trending.

I&C System Engineers are assigned corrective actions to evaluate the drift of critical components to determine if the instrument has been having repeat issues.Pilgrim follows Entergy fleet procedure, EN-LI-102, "Corrective Action Process" to implement the site corrective action program. This process complies with the requirements of 10 CFR 50, Appendix B. Equipment and instrument operability, restoring operability, accepting degraded conditions with compensatory measures, and operability evaluations are developed in accordance with Entergy Fleet procedure, EN-OP-104, "Operability Determination Process." Corrective Actions taken to restore operability follow the process prescribed in EN-LI-102.

Attachment 3 provides revised TS Page 3/4.2-16, which provides foot notes to the Condensate Storage Tank Low level Set point. The proposed footnote follows the guidance of TSTF-493, Revision 4, as requested by the NRC during the discussion on March 22, 2012.Attachment 1: Pilgrim Calculation No. IN1 -245, "Setpoint Calculation for PS-2390A &B, Condensate Tank Low Level Transfer" dated October 7, 2009 ( 27 pages)Attachment 2: Pilgrim Procedure No. 8.M.2-2.5.6, "HPCI Condensate Storage Tank Level", Revision 35 (33 pages).Attachment 3: Revised Technical Specification Page 3/4.2-16 (1 page)Page 3 of 3 ENCLOSURE TO ENTERGY LETTER NO 2.12.035 Entergy/Pilcrim Response to NRC Request for Additional Information Dated March 26, 2012 Attachment 1: Pilgrim Calculation No. IN1-245, "Setpoint Calculation for PS-2390A & B, Condensate Tank Low Level Transfer' dated October 7, 2009 (27 pages)

ENCLOSURE TO ENTERGY LETTER NO 2.12.035 Enteray/Pilarim Response to NRC Request for Additional Information Dated March 26, 2012 Attachment 2: Pilgrim Procedure No. 8.M.2-2.5.6, "HPCI Condensate Storage Tank Level", Revision 35 (33 pages).

RTYPE H6.08 PILGRIM NUCLEAR POWER STATION Procedure No. 8.M.2-2.5.6 HPCI CONDENSATE STORAGE TANK LEVEL Stop Think Act Review CONTINUOUS USE PM DATABASE RELATED 8.M.2-2.5.6 Rev. 35 REVISION LOG REVISION 35 Pages Affected 8,25,29 25,29 REVISION 34 Pages Affected 7 9 12,20 16 REVISION 33 Pages Affected 10,11,19 12,20 24,26 Date Originated 11/11 Description Replace Shift Manager with on-shift SRO.Change "As-Found" trip point criterion from 7.3 to 8.17 psig as criteria for having to notify the SM. (CR-PNP-2011-4830)

Date Originated 4/11 Descri pti on Add 1/2" female Swagelok fitting to Special Tools and Equipment.

Delete reference to no-longer-used LSFT database.Add a step to capture signoff for Prerequisites Step 7.0[2]being met as required by PNPS 1.3.4-1.Separate multiple action step into single action steps.Date Originated 9/09 Descri pti on Update terminology to reflect Asset Suite implementation.

Delete reference to PNPS 1.3.34 regarding Pre-Evolution Brief.Change condensate storage tank low level HPCI suction transfer setpoint from 7.8 to 8.6 psig decreasing and No Adjust Limits from 7.6 to 8.0 to 8.4 to 8.8 psig.(EC12609)8.M.2-2.5.6 Rev. 35 Page 2 of 33 TABLE OF CONTENTS Page 1.0 PURPOSE AND SCOPE ...................................................

4 2 .0 REFERENCES

..........................................................

4 3 .0 DEF IN IT IONS .........................................................

5 4 .0 D ISCUSS ION ...............

i ..........................................

6 5.0 SPECIAL TOOLS AND EQUIPMENT

.........................................

7 6.0 PRECAUTIONS AND LIMITATIONS

.........................................

7 7.0 PREREQU IS ITES .......................................................

8 8 .0 PROC EDURE ...........................................................

8 9.0 ACCEPTANCE CRITERIA .................................................

9 10 .0 CORRECTIVE ACTION ...................................................

9 11.0 ACCEPTANCE VERIFICATION AND SIGNOFF .................................

10 12 .0 ATTACHMENTS

.........................................................

10 ATTACHMENT 1 -HPCI CONDENSATE STORAGE TANK LEVEL INSTRUMENT FUNCTIONAL TEST ............................................

11 ATTACHMENT 2 -HPCI CONDENSATE STORAGE TANK LEVEL INSTRUMENT FUNCTIONAL AND CALIBRATION TEST ............................

19 ATTACHMENT 3 -HPCI CONDENSATE STORAGE TANK LEVEL -ASSOCIATED ALARMS AND ACTUATIONS

.............................................

32 ATTACHMENT 4 -I&C PROCEDURE FEEDBACK FORM ................................

33 8.M.2-2.5.6 Rev. 35 Page 3 of 33 1.0 PURPOSE AND SCOPE This Procedure provides Maintenance personnel the instructions for performance of an instrument functional or instrument functional and calibration test as required by the following Technical Specifications surveillance requirements for the equipment listed. This Procedure partially satisfies the LSFT requirements of Technical Specifications Table 4.2.B Item 4, including the SAA Note (4) and Timer Note (6) for the HPCI subsystem.

TECHNICAL SPECIFICATIONS SURVEILLANCE REQUIREMENTS EQUIPMENT 4.2.B PROTECTIVE INSTRUMENTATION

-Core and Containment Cooling Systems -Initiation

& Control Pressure Switches 23-PS-2390A 23-PS-2390B HPCI Suction Tank Levels [Monthly Functional Test Tech Spec Table 4.2.B, Item 14]HPCI Suction Tank Levels [Quarterly Functional and Calibration Test Tech Spec Table 4.2.B, Item 14]

2.0 REFERENCES

2.1 DEVELOPMENTAL

[1] Entergy Quality Assurance Program Manual (QAPM)[2] NRCCC Item PAPR 020 (Pre-Evolution Briefing)[3] Technical Specifications Bases Sections 3.2 and 4.2 2.2 IMPLEMENTING

[1] Calculation E-634-3, "Setpoint Calculation for PS-2390A & B"[2] GE Instrument Data Sheet, 225A5750, Sheet 60[3] PDC87-78C, Improvements to Labels, Nameplates on Main Control Room Panels[4] PNPS 1.3.34, "Operations Administrative Policies and Processes" 8.M.2-2.5.6 Rev. 35 Page 4 of 33

[5] PNPS Elementary Diagrams -HPCI System (a) M1J 14-14 (b) M1J 16-10 (c) M1J 17-12 (d) MIJ 19-9 (e) M1J 20-5[6] PNPS Piping and Instrumentation Diagrams (P&IDs)(a) M209, Cond & Demin Water Storage and Transfer System (b) M243, High Pressure Coolant Injection (HPCI) System (c) M244 Sheet 1, HPCI System (d) M244 Sheet 2, HPCI System[7] PNPS Technical Specifications (a) Section 3.2.B, Table 3.2.B; "Instrumentation that Initiates or Controls the Core and Containment Cooling Systems" (b) Section 4.2.B, Table 4.2.B, Item 14; "Minimum Test and Calibration Frequency for CSCS, HPCI Suction Tank Levels" (c) Section 4.2.B: Table 4.2.B, Item 4: "Minimum Test and Calibration Frequency for CSCS Logic System Functional Test, HPCI Subsystem"[8] Vendor Manual V-0113, Static "0" Ring Pressure Switches 3.0 DEFINITIONS None 8.M.2-2.5.6 Rev. 35 Page 5 of 33

4.0 DISCUSSION

[1] Impact on Operations NOTE Close signal to MO-2301-6 is generated from MO-2301-35 and MO-2301-36 being full open. MO-2301-35 and MO-2301-36 being full open will also generate a close signal to HPCI/RCIC Test Return Valve MO-2301-15 and Full Flow Test Valve MO-2301-10.(a) Surveillance Summary This Procedure tests the Condensate Storage Tank (CST) low level logic by simulating a low level condition which provides an open signal to Torus Suction Valves MO-2301-35 and MO-2301-36 and a close signal to CST Suction Valve MO-2301-6 if an auto-isolation signal is not present.Attachment 1 performs a functional test of pressure switches 23-PS-2390A and 23-PS-2390B.

Attachment 2 performs a functional and calibration of pressure switches 23-PS-2390A and 23-PS-2390B.(b) Impact HPCI will be available during performance of Attachments 1 and 2 as no loss of suction path occurs, but Condensate Storage Tank low level instrumentation will be less than the minimum number of operable channels during calibration.

Therefore, HPCI is inoperable (Technical Specifications Table 3.2.B Note 1).(c) Technical Specifications (1) Section 3.5.C (2) Tables 3.2.B/4.2.B

[2] The pressure switches (23-PS-2390A, 23-PS-2390B) tested by this Procedure monitor the water levels in the Condensate Storage Tank. Upon sensing a low Condensate Storage Tank water level, these switches provide control logic signals which automatically close MO-2301-6 and open MO-2301-35 and MO-2301-36 to supply water to the HPCI pump suction if the HPCI isolation signal is not activated.

The following components are affected by this Procedure: (a) MO-2301-6 (CST SUCT VLV)(b) MO-2301-35 (TORUS SUCT VLV)(c) MO-2301-36 (TORUS SUCT VLV)[3] The instrument functional/calibration test shall be done in accordance with Technical Specifications Sections 3.2.B and 4.2.B.8.M.2-2.5.6 Rev. 35 Page 6 of 33 5.0 SPECIAL TOOLS AND EQUIPMENT[1] Pneumatic calibrator/test gauge accurate to 0.03 psig or better[2] Portable communication equipment[3] Digital multimeter (DMM) or equivalent

[4] Calibrated chart recorder or digital timer (required for relay 23A-K15 calibration only)[5] Torquing screwdriver capable of 11 inch-pounds

[6] 1/2" female Swagelok fitting 6.0 PRECAUTIONS AND LIMITATIONS

6.1 PRECAUTIONS

[1] One pressure switch shall be tested or disabled at a time unless otherwise directed by this Procedure.

[2] Unless otherwise directed, the pressure switches under test shall be individually isolated in accordance with the applicable Attachment provided for the pressure switch under test.[3] All applicable plant radiological precautions shall be observed during the performance of this Procedure to reduce exposure to radiation and spread of contamination.(a) Use an appropriate catch-container and absorbent material when connecting and removing test equipment.

[4] Use caution while working on energized circuits to protect personnel and prevent damage to plant equipment.

[5] Personnel must be informed of the Halon fire protection system in the Cable Spreading Room. Prior to the release of the Halon, an alarm will sound and personnel must vacate the area immediately.

[6] Use caution when making valve test connections; high pressure may be present.[7] When opening test connections or venting instrumentation, trap water in an appropriate container to prevent spread of contamination.

[8] All procedural steps are to be performed as written and followed to completion unless otherwise directed.[9] Maintenance Supervision shall be consulted prior to annotating "N/P" (for "not performed")

for any step which does not contain conditional steps.8.M.2-2.5.6 Rev. 35 Page 7 of 33

6.2 LIMITATIONS

[1] Refer to operable Technical Specifications Table 3.2.B for the required number of instrument channels.7.0 PREREQUISITES

[1] Except for ALARA reasons or during plant emergencies, this Procedure may be performed during any plant condition.

[2] Contact Radiation Protection (RP) prior to work in process areas.directions.

Obtain a Radiological Work Permit (RWP) if required.Follow RP[3] Obtain approval of the on-shift SRO prior to starting this test.8.0 PROCEDURE[1] IF any abnormal condition is encountered during this test, NOTIFY Maintenance-uSpervision for corrective action AND DOCUMENT under "Discrepancies noted during surveillance performance".

[2] PERFORM the procedural steps for each Attachment in the sequence as written unless otherwise directed.[3] "N/P" (for "not performed")

may be placed by a procedural step where performance of that step has been conditionally stated and the condition(s) is not met.[4] PRIOR to commencing performance of the instrument functional or instrument Tunctional and calibration test, PROVIDE the on-shift SRO with Attachment 3.[5] IF an instrument functional test performance is required, THEN REFER TO AND PERFORM the steps as written in Attachment 1.[6] IF an instrument functional and calibration test performance is required, THEN REFER TO AND PERFORM the steps as written in Attachment 2.8.M.2-2.5.6 Rev. 35 Page 8 of 33 9.0 ACCEPTANCE CRITERIA[1] The Acceptance Criteria for performance of Attachment 1 are as follows: (a) The pressure switch(es) functioned as required, as indicated by activation of associated channel relays, providing a signal to the appropriate annunciator circuitry and the HPCI subsystem auto valve logic. [Tech Spec Table 4.2.B, Item 14](b) The pressure switch(es) returned to service with verification of restoration as indicated by two persons' initials.

[NUREG 0737, I.C.6][2] The Acceptance Criteria for performance of Attachment 2 are as follows: (a) The pressure switch(es) "As-Found" setpoint(s) was within the No Adjust Limits or a calibration was performed and the "As-Left" setpoint(s) is within the No Adjust Limits during simulation of a HPCI Condensate Storage Tank level signal. [Tech Spec Table 4.2.B, Item 14](b) The pressure switch(es) functioned as required, as indicated by activation of associated channel relays, providing a signal to the appropriate annunciator circuitry and the HPCI subsystem valve logic.[Tech Spec Table 4.2.B, Item 13](c) During HPCI Condensate Storage Tank level signal simulation, HPCI subsystem relays, components, and alarms functioned as required partially satisfying the Tech Spec requirements.

[Tech Spec Table 4.2.B, LSFT Item 3, SAA Note (4) & Timer Note (6)](d) The pressure switch(es) returned to service with verification that the system has been returned to pretest configuration.

[NUREG 0737, I.C.6]10.0 CORRECTIVE ACTION[1] If equipment failed to perform its intended function or a discrepancy is encountered during test, discontinue testing and immediately notify the Maintenance Supervisor and the on-shift SRO. The Maintenance Supervisor and the on-shift SRO must determine whether testing should be terminated, continued, or an investigation be performed.

[2] If equipment failed to perform its intended function, the appropriate corrective action document shall be initiated.

The on-shift SRO must be notified of the failure to allow Operations to initiate action deemed necessary in accordance with PNPS Technical Specifications Table 3.2.B.8.M.2-2.5.6 Rev. 35 Page 9 of 33 11.0 ACCEPTANCE VERIFICATION AND SIGNOFF[1] Maintenance Management/Lead is responsible for reviewing this Procedure to ensure all Acceptance Criteria have been satisfied prior to taking credit for test performance in the PM database.[2] Maintenance Management/Lead shall review steps marked as correct component response(s) and proper data gathering."N/P" to verify[3] The on-shift SRO shall verify that all Acceptance Criteria were met and evaluate any discrepancies for acceptability.

12.0 ATTACHMENTS ATTACHMENT 1 -HPCI CONDENSATE STORAGE TANK LEVEL INSTRUMENT FUNCTIONAL TEST ATTACHMENT 2 -HPCI CONDENSATE STORAGE TANK LEVEL INSTRUMENT FUNCTIONAL AND CALIBRATION TEST ATTACHMENT 3 -HPCI CONDENSATE STORAGE TANK LEVEL -ASSOCIATED ALARMS AND ACTUATIONS ATTACHMENT 4 -I&C PROCEDURE FEEDBACK FORM 8.M.2-2.5.6 Rev. 35 Page 10 of 33 ATTACHMENT 1 Sheet 1 of 8 HPCI CONDENSATE STORAGE TANK LEVEL INSTRUMENT FUNCTIONAL TEST[1] PERFORM the steps in the order they are written. For each step with a [ ], SIGNIFY completion with a check mark. For each step with a , ENTER initials or data as appropriate.

For a step followed by a double , that step shall require verification with two individuals' signed initials required to signify completion. "N/P" (for "not performed")

may be placed by a procedural step where performance of that step has been conditionally stated and the condition(s) has not been met.[2] DOCUMENT in the space provided below the reason this test is being performed (CHECK one):[j Routine Surveillance L-ii Postwork Testing for Work Order (WO)#ii Other (specify)[3] Prerequisites (a) Personnel assigned to perform this Attachment have read and understand this Attachment.

All personnel involved must print their name and the date and sign their initials below.Name (print)Name (print)Name (print)Name (print)Date Initials Date Initials Date Initials Date Initials (b) PROVIDE the on-shift SRO with Attachment 3 (HPCI Condensate Storage Tank Level -Associated Alarms and Actuations).

Initials 8.M.2-2.5.6 Rev. 35 Page 11 of 33 ATTACHMENT 1 Sheet 2 of 8 (c) IF required, a Pre-Evolution Brief has been completed and attached to this surveillance.

[NRCCC Item PAPR 020](d) COORDINATE action to be taken with Operations personnel AND OBTAIN the on-shift SRO's signature as permission to begin test.Initials On-Shift SRO signature Date Ti me (e) Radiation Protection (RP) notified for performance of the HPCI Condensate Storage Tank Level functional test.(1) IF required, OBTAIN an RWP.[4] ENSURE personnel in the Cable Spreading Room informed of the Halon fire protection system alarm trip.[5] ESTABLISH communication between the following locations: (a) Control Room (b) Cable Spreading Room (c) Reactor Building Aux Bay, east wall, El. 8'Initials Initials[ ][ ][ ][ ]8.M.2-2.5.6 Rev. 35 Page 12 of 33 ATTACHMENT 1 Sheet 3 of 8 NOTE If Reactor is shutdown with no steam pressure available for the HPCI turbine, then leads on terminals EE-5 at Panel C939 and EE-5 at Panel C941 will be lifted to clear the HPCI Low Steam Line Pressure signal.[6] IF Reactor is shutdown OR IF Reactor is operating with less than 100 psig steam pressure being supplied to the HPCI turbine with relays 23A-K52A and 23A-K52B being energized, THEN PERFORM the following (OTHERWISE, ENTER "N/P" for Step [6](a) AND PROCEED TO Step [7]): II ~CAUTION I Use caution when working on energized circuits:

125V DC is present.(a) At Cable Spreading Room, PERFORM the following:

(1) LIFT AND APPROPRIATELY TAG field side lead on EE-5 at Panel C939 (lead lifted to clear HPCI Low Steam Line Pressure signal).Initials Verifier (2) LIFT AND APPROPRIATELY TAG field side lead on EE-5 at Panel C941 (lead lifted to clear HPCI Low Steam Line Pressure signal).Initials Verifier (3) HAVE Operations push in the following Auto-Isolation Reset push buttons to clear the seal-in function of the auto-isolation relays. [ ]Reset Description Location 23A-S26 PCIS Grp 4 Isol C903 Channel A 23A-S18 PCIS Grp 4 Isol C903 Channel B 8.M.2-2.5.6 Rev. 35 Page 13 of 33 ATTACHMENT 1 Sheet 4 of 8 (4) VERIFY the following:

a. White light (C903) PCIS GRP 4 ISOLATION CHANNEL A is OFF.b. White light (C903) PCIS GRP 4 ISOLATION CHANNEL B is OFF.[7] CHECK the identification marker to ensure you are working on the intended instrument 23-PS-2390A (located at Aux Bay, east wall, El. 8').[8] VERIFY the following alarms are CLEAR: ALARM WINDOW (a) "TORUS LEVEL HI" C903C-G3 (b) "HPCI TURBINE TEST" C903C-G5 (c) "CST LEVEL LO" C903C-G2[9] CLOSE isolation valve to 23-PS-2390A.

[10] REQUEST Operations to position/verify the following valves as indicated.

VERIFY the valves are positioned correctly.

[ ][ ][ ]Initials Initials Initials[ ](a) MO-2301-35 (TORUS SUCT VLV) is CLOSED.(b) MO-2301-36 (TORUS SUCT VLV) is CLOSED.(c) MO-2301-6 (CST SUCT VLV) is OPEN.Initials Initials Initials 8.M.2-2.5.6 Rev. 35 Page 14 of 33 ATTACHMENT 1 Sheet 5 of 8[11] DECREASE the test pressure to 23-PS-2390A by loosening plug on test connection AND VERIFY alarm"CST LEVEL LO" (C903C-G2) is ON.Initials (a) At Panel C939, VERIFY nominal DC voltage is NOT present between terminals Li and L2 of relay 23A-K15.Initials[12] VERIFY the following valve positions: (a) MO-2301-35 (TORUS SUCT VLV) is OPEN.Initials (b) MO-2301-36 (TORUS SUCT VLV) is OPEN.Initials (c) MO-2301-6 (CST SUCT VLV) is CLOSED.Initials[13] PERFORM the following: (a) TIGHTEN plug at test connection.

Initials Verifier (b) INCREASE the pressure to 23-PS-2390A by slowly opening isolation valve.Initials Verifier (c) At Panel C939, VERIFY nominal DC voltage is present between terminals Li and L2 of relay 23A-K15.Initials[14] VERIFY alarm "CST LEVEL LO" (C903C-G2) is CLEAR.Initials[15] CHECK the identification marker to ensure you are working on the intended instrument 23-PS-2390B (located at Aux Bay, east wall, El. 8'). [ ]8.M.2-2.5.6 Rev. 35 Page 15 of 33 ATTACMENTJ

[16] CLOSE the isolation valve to 23-PS-2390B.

[17] DECREASE the test pressure to 23-PS-2390B by loosening plug on test connection.

[18] VERIFY alarm "CST LEVEL LO" (C903C-G2) is ON.[19] At Panel C939, VERIFY nominal DC voltage is NOT present between terminals Li and L2 of relay 23A-K15.[20] TIGHTEN plug on test connection.

[21] PERFORM the following: (a) INCREASE the pressure to 23-PS-2390B by slowly opening isolation valve.(b) At Panel C939, VERIFY nominal DC voltage is present between terminals Li and L2 of relay 23A-K15.[22] VERIFY alarm "CST LEVEL LO" (C903C-G2) is CLEAR.[23] VERIFY Operations has placed the following valves in the indicated positions or as specified by Watch Supervisor:

[ ]Initials Initials Initials Initials Verifier Initials Verifier Initials Initials (a) MO-2301-35 (TORUS SUCT VLV) is CLOSED.(b) MO-2301-36 (TORUS SUCT VLV) is CLOSED.(c) MO-2301-6 (CST SUCT VLV) is OPEN.Initials Initials Initials 8.M.2-2.5.6 Rev. 35 Page 16 of 33 ATTACHMENT 1 1 Sheet 7 of 8[241 IF leads were removed, THEN REMOVE tape, RELAND leads, AND TORQUE to 20 (18 to 22) in.-lb at the following terminals. (IF MO-2301-35 and MO-2301-36 are OPEN prior to relanding leads at Panels C939 and C941, they will automatically close when low pressure signal is restored.)

RECORD torquing screwdriver information.(a) EE-5 at Panel C939 (b) EE-5 at Panel C941 Torquing screwdriver

1. Initials Verifier Initials Verifier Cal Due Date[25] NOTIFY the on-shift SRO that test is complete.[26] FILL OUT the I&C Procedure Feedback Form (Attachment

4) AND FORWARD to I&C Supervision.

[I Initials 8.M.2-2.5.6 Rev. 35 Page 17 of 33 ATTACHMENT 1 Sheet 8 of 8 Discrepancies noted during surveillance performance:

Notes: Date Completed:

i-l Acceptance Criteria of Step 9.0[1] of the base document were met.Maint Management/Lead Date On-Shift SRO Date Time I-1 Acceptance Criteria of Step 9.0[1] of the base document were not met.Notify the on-shift SRO.Discrepancies:

Action taken: Maint Mgt/Lead Date Time 8.M.2-2.5.6 Rev. 35 Page 18 of 33 ATTACHMENT 2 Sheet 1 of 13 HPCI CONDENSATE STORAGE TANK LEVEL INSTRUMENT FUNCTIONAL AND CALIBRATION TEST[1] PERFORM the steps in the order they are written. For each step with a [ ], SIGNIFY completion with a check mark. For each step with a , ENTER initials or data as appropriate.

For a step followed by a double I that step shall require verification with two individuals' signed initials required to signify completion. "N/P" (for "not performed")

may be placed by a procedural step where performance of that step has been conditionally stated and the condition(s) has not been met.[2] DOCUMENT in the space provided below the reason this test is being performed (CHECK one): Li Routine Surveillance F- Postwork Testing for Work Order (WO)#I]I Other (specify)[3] Prerequisites (a) Personnel assigned to perform this Attachment have read and understand this Attachment.

All personnel involved must print their name and the date and sign their initials below.Name (print)Name (print)Date Date Date Date Initials Initials Initials Initials Name (print)Name (print)(b) PROVIDE the on-shift SRO with Attachment 3 (HPCI Condensate Storage Tank Level -Associated Alarms and Actuations).

Initials 8.M.2-2.5.6 Rev. 35 Page 19 of 33 ATTACHMENT 2 Sheet 2 of 13 (c) IF required, a Pre-Evolution Brief has been completed and attached to this surveillance.

[NRCCC Item PAPR 020](d) COORDINATE action to be taken with Operations personnel AND OBTAIN the on-shift SRO's signature as permission to begin test.Initials On-Shift SRO signature Date Time (e) Radiation Protection (RP) notified for performance of the HPCI Condensate Storage Tank Level functional test.Initials Initials (1) IF required, OBTAIN an RWP.(f) ENSURE personnel in the Cable Spreading Room informed of the Halon fire protection system alarm trip.[4] ESTABLISH communication between the following locations: (a) Control Room (b) Cable Spreading Room (c) Reactor Building Aux Bay, east wall, El. 8'Initials[1][ ][ ]8.M.2-2.5.6 Rev. 35 Page 20 of 33 ATTACHMENT 2 Sheet 3 of 13 NOTE If Reactor is shutdown with no steam pressure available for the HPCI turbine, then leads on terminals EE-5 at Panel C939 and EE-5 at Panel C941 will be lifted to clear the HPCI Low Steam Line Pressure signal.[5] IF Reactor is shutdown OR IF Reactor is operating with less than 100 psig steam pressure being supplied to the HPCI turbine with relays 23A-K52A and 23A-K52B being energized, THEN PERFORM the following (OTHERWISE, ENTER "N/P" for Step [5](a) AND PROCEED TO Step [6]): Use caution when working on energized circuits:

125V DC is present.(a) At Cable Spreading Room, PERFORM the following:

(1) LIFT AND APPROPRIATELY TAG field side lead on EE-5 at Panel C939 (lead lifted to clear HPCI Low Steam Line Pressure signal).Initials Verifier (2) LIFT AND APPROPRIATELY TAG field side lead on EE-5 at Panel C941 (lead lifted to clear HPCI Low Steam Line Pressure signal).Initials Verifier (3) HAVE Operations push in the following Auto-Isolation Reset push buttons to clear the.seal-in function of the auto-isolation relays. [ ]Reset Description Location 23A-$26 PCIS Grp 4 Isol C903 Channel A 23A-$18 PCIS Grp 4 Isol C903 Channel B 8.M.2-2.5.6 Rev. 35 Page 21 of 33 ATTACHMENT 2 Sheet 4 of 13 (4) VERIFY the following:

a. White light (C903) PCIS GRP 4 ISOLATION CHANNEL A is OFF.b. White light (C903) PCIS GRP 4 ISOLATION CHANNEL B is OFF.[1][ ][6] REQUEST Operations to position the following valves as indicated.

VERIFY the valves are positioned correctly.(a) MO-2301-35 (TORUS SUCT VLV) is OPEN.(b) MO-2301-36 (TORUS SUCT VLV) is OPEN.(c) MO-2301-6 (CST SUCT VLV) is CLOSED.Ini ti al s Initials Initials[71] CHECK the identification marker to ensure you are working on the intended instrument 23-PS-2390A (located at Aux Bay, east wall, El. 8').[ ]NOTE For the calibration of PS-2390A, the required M&TE accuracy is less than or equal to +/-0.03 psig. (Ref. Calculation E-634-3)[8] VERIFY the following alarms are CLEAR: ALARM (a) "TORUS LEVEL HI" (b) "HPCI TURBINE TEST" (c) "CST LEVEL LO" WINDOW C903C-G3 C903C-G5 C903C-G2 Initials Initials Initials 8.M.2-2.5.6 Rev. 35 Page 22 of 33 ATTACHMENT 2 1 Sheet 5 of 13[9] CLOSE isolation valve to 23-PS-2390A.

[10] REMOVE the "tee" plug AND CONNECT a pressure source to 23-PS-2390A.(a) VERIFY alarm "CST LEVEL LO" (C903C-G2) is ON.[11] INCREASE the pressure to 23-PS-2390A until the switch resets AND VERIFY alarm "CST LEVEL LO" (C903C-G2) is CLEAR.[12] At Panel C939, VERIFY nominal DC voltage is present between terminals Li and L2 of relay 23A-K15.[131 REQUEST Operations to position the following valves as indicated.

VERIFY the valves are positioned correctly.

[ ][ ]Initials Initials Initials (a) MO-2301-35 (TORUS SUCT VLV) is CLOSED.(b) MO-2301-36 (TORUS SUCT VLV) is CLOSED.(c') MO-2301-6 (CST SUCT VLV) is OPEN.Initials Initials Initials 8.M.2-2.5.6 Rev. 35 Page 23 of 33 ATTACHMENT 2 Sheet 6 of 13 NOTE There is a +6.5 psi water leg included in the following pressures.

[14] SLOWLY DECREASE the test pressure to 23-PS-2390A.

RECORD "As-Found" setpoint data. Setpoint is 8.6 psig decreasing:

No Adjust Limits are 8.4 to 8.8 psig.(a) RECORD "As-Found" trip setpoint.

psig Data (b) At Panel C939, VERIFY nominal DC voltage is NOT present between terminals Li and L2 of relay 23A-K15.Initials (c) VERIFY alarm "CST LEVEL LO" (C903C-G2) is ON.Initials[15] VERIFY the following valve positions: (a) MO-2301-35 (TORUS SUCT VLV) is OPEN.Initials (b) MO-2301-36 (TORUS SUCT VLV) is OPEN.Initials (c) MO-2301-6 (CST SUCT VLV) is CLOSED.Initials[16] SLOWLY INCREASE test pressure to 23-PS-2390A.

RECORD'As-Found" reset data. psig Data 8.M.2-2.5.6 Rev. 35 Page 24 of 33 ATTACHMENT 2 Sheet 7 of 13[17] IF "As-Found" trip point does NOT fall within No Adjust Limits, THEN CALIBRATE AND RECORD "As-Left" data.(a) RECORD "As-Left" trip setpoint.

psig Data (b) SLOWLY INCREASE test pressure.

RECORD "As-Left" reset data. psig Data (c) REPLACE instrument cover AND TORQUE cover screws to 7 in.-lb.Initials Verifier (d) RECORD torquing screwdriver information.

[ ]Torquing screwdriver

1. Cal Due Date[18] DECREASE the test pressure to 23-PS-2390A, REMOVE test equipment, AND REINSTALL "tee" plug.Initials Verifier[19] SLOWLY OPEN isolation valve to 23-PS-2390A.

Initials Verifier[20] At Panel C939, VERIFY nominal DC voltage is present between terminals Li and L2 of relay 23A-K15.Initials[211 VERIFY alarm "CST LEVEL LO" (C903C-G2) is CLEAR.Initials[22] IF "As-Found" trip point was less than 8.17 psig, NOTIFY the on-shift SRO.On-shift SRO notified?

L- Yes I- No[23] CHECK the identification marker to ensure you are working on the intended instrument 23-PS-2390B (located at Aux Bay, east wall, El. 8'). [ I 8.M.2-2.5.6 Rev. 35 Page 25 of 33

[TTACHMNT 2 Sheet 8 of 1 NOTE For the calibration of PS-2390B, the required M&TE accuracy is less than or equal to +/-0.03 psig. (Ref. Calculation E-634-3)[24] CLOSE the isolation valve to 23-PS-2390B.

[25] REMOVE "tee" plug AND CONNECT a pressure source to 23-PS-2390B.(a) VERIFY alarm "CST LEVEL LO" (C903C-G2) is ON.[26] INCREASE the pressure to 23-PS-2390B until the switch resets AND VERIFY alarm "CST LEVEL LO" (C903C-G2) is CLEAR.[27] At Panel C939, VERIFY nominal DC voltage is present between terminals Li and L2 of relay 23A-K15.[ ][1]Initials Initials Initials NOTE There is a +6.5 psi water leg included in the following pressures.

[28] SLOWLY DECREASE the test pressure to 23-PS-2390B.

RECORD "As-Found" setpoint data. Setpoint is 8.6 psig decreasing:

No Adjust Limits are 8.4 to 8.8 psig.(a) RECORD "As-Found" trip setpoint.(b) At Panel C939, VERIFY nominal DC voltage is NOT present between terminals Li and L2 of relay 23A-K15.(c) VERIFY alarm "CST LEVEL LO" (C903C-G2) is ON.psig Data Initials Initials 8.M.2-2.5.6 Rev. 35 Page 26 of 33 ATTACHMENT 2 Sheet 9 of 13[291 SLOWLY INCREASE test pressure to 23-PS-2390B AND RECORD "As-Found" reset. psig Data[30] IF "As-Found" trip point does NOT fall within No Adjust Limits, THEN CALIBRATE AND RECORD "As-Left" data.(a) RECORD "As-Left" trip setpoint.

psig Data (b) APPLY increasing test input. RECORD "As-Left" reset data. psig Data (c) REPLACE instrument cover AND TORQUE cover screws to 7 in.-lb.Initials Verifier (d) RECORD torquing screwdriver information.

[ ]Torquing screwdriver

1. Cal Due Date[31] At Panel C939, VERIFY timing for relay 23A-K15 as follows (relay is an Agastat model 7024 PC TDDO, setpoint is 3.0 seconds): (a) IF using a chart recorder, ENSURE the chart recorder has been calibrated.

IF using a digital timer for this step, ENTER "N/P". [ ](b) IF using a digital timer, POSITION switch settings as follows (IF using chart recorder for this step, ENTER "N/P"): (1) START INPUT: a. LATCH ON [ ]b. AC/DC REMOVED [ ](2) STOP INPUT: a. LATCH ON [ ]b. NC DRY CONTACTS [ ]8.M.2-2.5.6 Rev. 35 Page 27 of 33 ATTACHMENT 2 Sheet 10 of 13 (c) CONNECT a chart recorder or digital timer channel to relay 23A-K15 terminals Li and L2 (monitoring range 0-125V DC).(d) CONNECT one lead of a second chart recorder or digital timer channel to terminal 4 of relay 23A-K15 (spare normally open contact).(e) CONNECT second lead of second chart recorder or digital timer channel to a voltage source.(DO NOT use a voltage source if a digital timer is used in the N.C. contact mode.) E I (f) CONNECT voltage source to relay 23A-K15, terminal 6.(IF a digital timer is used in the N.C. contact mode, CONNECT the second lead of the timer to relay 23A-K15 terminal 6.) [ ](g) IF used, SET recorder chart speed to 50 mm/sec. [ ](h) IF using a digital timer, PRESS the RESET button on the digital timer (indication should show all zeros and not counting).

IF using a chart recorder for this step, ENTER "N/P".NOTE The starting of the chart recorder or digital timer is to be coordinated with the pressure switch operation.(i) START chart recorder or digital timer AND DECREASE test pressure to 23-PS-2390B.(j) IF used, STOP chart recorder after relay 23A-K15 drops out. [ I (1) RECORD "As-Found" time delay. Setpoint is 3.0 seconds: No Adjust Limits are 2.85 to 3.15 seconds. sec As-Found 8.M.2-2.5.6 Rev. 35 Page 28 of 33 ATTACHMENT 2 Sheet 11 of 13 (k) IF required, ADJUST relay 23A-K15 AND REVERIFY timing by resetting switch and repeating Steps [31](g) through (k) until desired setpoint value is obtained.

[ ](1) RECORD "As-Left" time delay. Setpoint is 3.0 seconds: No Adjust Limits are 2.85 to 3.15 seconds. sec As-Left (1) DISCONNECT recorder or digital timer test leads. [ ][32] DECREASE the test instrument pressure, REMOVE test equipment, AND REINSTALL "tee" plug.Initials Verifier[33] SLOWLY OPEN isolation block valve to 23-PS-2390B.

Initials Verifier[34] At Panel C939, VERIFY nominal DC voltage is present between terminals Li and L2 of relay 23A-K15.Initials[35] VERIFY alarm "CST LEVEL LO" (C903C-G2) is CLEAR.Initials[36] IF "As-Found" trip point was less than 8.17 psig, NOTIFY the on-shift SRO.On-shift SRO notified? -I Yes LI] No[37] VERIFY Operations has placed the following valves in the indicated positions or as specified by the Watch Supervisor.(a) MO-2301-35 (TORUS SUCT VLV) is CLOSED.Initials (b) MO-2301-36 (TORUS SUCT VLV) is CLOSED.Initials (c) MO-2301-6 (CST SUCT VLV) is OPEN.Initials 8.M.2-2.5.6 Rev. 35 Page 29 of 33 ATTACHMENT 2 Sheet 12 of 13[38] IF leads were removed, THEN REMOVE tape, RELAND leads, AND TORQUE to 20 (18 to 22) in.-lb at the following terminals. (IF MO-2301-35 and MO-2301-36 are OPEN prior to relanding leads at Panels C939 and C941, they will automatically close when low pressure signal is restored.)

RECORD torquing screwdriver information.(a) EE-5 at Panel C939 (b) EE-5 at Panel C941 Torquing screwdriver

1. Initials Verifier Initials Verifier Cal Due Date[39] COMPLETE documentation AND UPDATE Maintenance records.[40] NOTIFY the on-shift SRO that test is complete.[41] RECORD test equipment used.M&TE # Cal Due Date M&TE # Cal Due Date M&TE # Cal Due Date[ ][ ]Initials[42] FILL OUT the I&C Procedure Feedback Form (Attachment

4) AND FORWARD to I&C Supervision.

Initials 8.M.2-2.5.6 Rev. 35 Page 30 of 33 ATTACHMENT 2 Sheet 13 of 13 Discrepancies noted during surveillance performance:

Notes: Date Completed:

LI Acceptance Criteria of Step 9.0[2] of the base document were met.Maint Management/Lead Date On-Shift SRO Date Ti me LI-1 Acceptance Criteria of Step 9.0[2] of the base document were not met.Notify the on-shift SRO.Discrepancies:

Action taken: Maint Mgt/Lead Date Ti me 8.M.2-2.5.6 Rev. 35 Page 31 of 33 ATTACHMENT 3 Sheet 1 of 1 HPCI CONDENSATE STORAGE TANK LEVEL -ASSOCIATED ALARMS AND ACTUATIONS NOTE The following alarms and actuations will be activated during the performance of this Procedure (PNPS 8.M.2-2.5.6).

INSTRUMENT 23-PS-2390A 23-PS-2390B 23-PS-2390A 23-PS-2390B 23-PS-2390A 23-PS-2390B LOCATION ALARM/ACTUATION Reactor Bldg Aux Bay, east wall, El. 8'Reactor Bldg Aux Bay, east wall, El. 8'"CST LEVEL LO" (C903C-G2)"CST LEVEL LO" (C903C-G2)

Isolation signals for the following:

MO-2301-6, CST Suct Vlv Opening signals for the following:

MO-2301-35, Torus Suct Vlv MO-2301-36, Torus Suct Vlv 8.M.2-2.5.6 Rev. 35 Page 32 of 33 ATTACHMENT 4 Sheet 1 of 1 I&C PROCEDURE FEEDBACK FORM Date: Name (print):[1] Were there any problems found while performing this Procedure:

YES E1 NO 1i1 (a) If YES, record problem(s) in Step [3] below.[2] Are there any enhancements that need to be made to this Procedure:

YES L]-- NO I-1 (a) If YES, record step(s) to be enhanced and a description of the enhancement(s) in Step [3] below. Include Attachment number if applicable.

[3] Problem/Enhancement:

8.M.2-2.5.6 Rev. 35 Page 33 of 33 ENCLOSURE TO ENTERGY LETTER NO 2.12.035 Entergy/Pilarim Response to NRC Request for Additional Information Dated March 26, 2012 Attachment 3: Revised Technical Specification Page 3/4.2-16 (1 page)

PNPS TABLE 3.2.B (Cont)INSTRUMENTATION THAT INITIATES OR CONTROLS THE CORE AND CONTAINMENT COOLING SYSTEMS Minimum # of Operable Instrument Channels Per Trip System (1)Trip Function Trip Level Settinq Remarks 2 2 1 2 2 2 4 1 2 2 2 Condensate Storage Tank Low Level Suppression Chamber High Level RCIC Turbine Steam Line High Flow RCIC Turbine Compartment Wall RCIC Exhaust Duct Torus Cavity RCIC Valve Station Area Wall RCIC Steam Line Low Pressure HPCI Turbine Steam Line High Flow HPCI Turbine Compartment Exhaust Duct HPCI Exhaust Duct Torus Cavity HPCI/RHR Valve Station Area Exhaust Duct> 46" above tank zero (a)<1'11" below torus zero<300% of rated steam flow< 168°F< 148'F< 198°F 77 > P > 63 psig Provides interlock to HPCI I pump suction valves. I (2)(2)(2)(2)(K ((2 (2)(5)(6)< 296% of rated flow< 168 0 F< 198 0 F< 168 0 F (3)(3)(3)(3)(: C 2 2.,.-((a) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise the channel shall be declared inoperable.

Setpoints more conservative than NTSP are acceptable provide that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedure to confirm channel performance.

The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in the Pilgrim Setpoint calculation for Condensate Tank Low Level Instrumentation, IN1-245.Amendment No. 0--, 1 4 8--, 1 9 8 ,