ML12277A080

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License Amendment Request for Implementing a 24-Month Fuel Cycle, Grand Gulf Nuclear Station, Unit 1
ML12277A080
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 10/02/2012
From: Mike Perito
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
Ml122770130 List:
References
GNRO-2012/00096
Download: ML12277A080 (172)
v • d • e


Text

Entergy Operations, Inc.P.O.Box 756 Port Gibson, MS 39150

SUBJECT:

Michael Perito Vice President, Operations Grand Gulf Nuclear Station Tel.(601)437-6409 GNRO-2012/00096 October 2, 2012 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 License Amendment Request for Implementing a 24-Month Fuel Cycle Grand Gulf Nuclear Station, Unit 1 Docket No.50-416 License No.NPF-29

REFERENCES:

(1)Generic Letter 91-04,"Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991 (2)Regulatory Guide 1.52,"Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered Safety Feature Atmospheric Cleanup Systems in Light-water Cooled Nuclear Power Plants," Revision 2, March 1978

Dear Sir or Madam:

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Entergy Operations, Inc.is submitting a request for an amendment to the Technical Specifications (TS)for Grand Gulf Nuclear Station, Unit 1 (GGNS).The proposed amendment would revise the TS to support operation with 24-month fuel cycles, in accordance with the guidance of Generic Letter 91-04 (Reference 1).*Attachment 1 provides an evaluation of the proposed changes.*Attachment 2 provides the markup pages of existing TS to show the proposed changes.*Attachment 3 provides the markup pages of the existing TS Bases to show the proposed changes.*Attachment 4 provides revised (clean)TS pages.*Attachment 5 provides the GL 91-04 review.*Attachment 6 provides the Instrument Drift Analysis Guide.*Attachment 7 provides the Applicable Instrumentation.

Also consistent with this guidance, a change is proposed to Administrative Controls Sections 5.5.7,"Ventilation Filter Testing Program (VFTP)," to address changes to 18 month frequencies that are specified in Regulatory Guide (RG)1.52,"Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants," (Reference 2).Entergy Operations, Inc.requests approval of the proposed license amendment by October 2 2013 with the amendment being implemented within 60 days.

GNRO-2012/00096 Page 2 of 3 In accordance with 10 CFR 50.91 (a)(1),"Notice for Public Comment," the analysis about the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission in accordance with the distribution requirements in 10 CFR 50.4.In accordance with 10 CFR 50.91 (b)(1),"State Consultation," a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to the designated Mississippi Official.This letter contains no new commitments.

If you have any questions or require additional information, please contact Christina Perino at 601-437-6299.

I declare under penalty of perjury that the foregoing is true and correct.Executed on October 2, 2012.Sincerely,'r2 psig for a period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.TS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)SR 3.6.1.3.7 Verify each automatic PCIV actuates to the isolation position on an actual or simulated isolation signal.TS 3.6.1.6 Low-Low Set (LLS)Valves SR 3.6.1.6.2 Verify the LLS System actuates on an actual or simulated automatic initiation signal.TS 3.6.1.7 Residual Heat Removal (RHR)Containment Spray System SR 3.6.1.7.3 Verify each RHR containment spray subsystem automatic valve in the flow path actuates to its correct position on an actual or simulated automatic initiation signal.TS 3.6.1.9 Main Steam Isolation Valve (MSIV)Leakage Control System (LCS)SR 3.6.1.9.3 Perform a system functional test of each MSIV LCS subsystem.

TS 3.6.2.4 Suppression Pool Makeup (SPMU)System SR 3.6.2.4.5 Verify each SPMU subsystem automatic valve actuates to the correct position on an actual or simulated automatic initiation signal.TS 3.6.3.2 Primary Containment and Drywell Hydrogen Igniters SR 3.6.3.2.3 Verify each required igniter in inaccessible areas develops sufficient current draw for a1700°Fsurface temperature.

SR 3.6.3.2.4 Verify each required igniter in accessible areas develops a surface temperature of1700°F.TS 3.6.3.3 Drywell Purge System SR 3.6.3.3.3 Verify each drywell purge subsystem flow rate is?1 000 cfm.SR 3.6.3.3.4 Verify theopeningpressure differential of each vacuum breaker and isolation valve is S 1.0 psid.

GNRO-2012/00096 Attachment 1 Page 6 of 18 TS 3.6.4.1 Secondary Containment-Operating SR 3.6.4.1.3 Verify the secondary containment can be drawn down to;:: 0.25 inch of vacuum water gauge in S 180 seconds using one standby gas treatment (SGT)subsystem.

SR 3.6.4.1.4 Verify the secondary containment can be maintained;::

0.266 inch of vacuum water gauge for one hour using one SGT subsystem at a flow rate S 4000 cfm.TS 3.6.4.2 Secondary Containment Isolation Valves (SCIVs)SR 3.6.4.2.3 Verify each required automaticSCIVactuates to the isolation position on an actual or simulated automatic isolation signal.TS 3.6.4.3 Standby Gas Treatment (SGT)System SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual or simulated initiation signal.TS 3.6.5.3 Drywell Isolation Valves SR 3.6.5.3.4 Verify each automatic drywell isolation valve actuates to the isolation position on an actual or simulated isolation signal.TS 3.6.5.6 Drywell Vacuum Relief System SR 3.6.5.6.3 Verify theopeningpressure differential of each vacuum breaker and isolation valve is S 1.0 psid.TS 3.7.1 Standby Service Water (SSW)System and Ultimate Heat Sink (UHS)SR 3.7.1.4 Verify each SSW subsystem actuates on an actual or simulated initiation signal.TS 3.7.2 High Pressure Core Spray (HPCS)Service Water System (SWS)SR 3.7.2.2 Verify the HPCS SWS actuates on an actual or simulated initiation signal.TS 3.7.3 Control Room Fresh Air (CRFA)System SR 3.7.3.3 Verify each CRFA subsystem actuates on an actual or simulated initiation signal.TS 3.7.4 Control Room Air Conditioning (AC)System SR 3.7.4.1 Verify each control room AC subsystem has the capability to remove the assumed heat load.TS 3.8.1 AC Sources-Operating SR 3.8.1.8 Verify manual transfer of unit power supply from the normal offsite circuit to required alternate offsite circuit.SR 3.8.1.9 Verify each DG rejects a load greater than or equal to its associated single largest post accident load and engine speed is maintained less than nominal plus 75%of the difference between nominal speed and the overspeed trip setpoint or 15%above nominal, whichever is lower.SR 3.8.1.10 Verify each DG does not trip and voltage is maintained S 5000 V during and following a load rejection of a load;:: 5450 kW and S 5740 kW for DG 11 and DG 12 and;:: 2500 kW and;:: 3300 kW for DG 13.

GNRO-2012/00096 Attachment 1 Page 7 of 18 SR 3.8.1.11 Verify on an actual or simulated loss of offsite power signal: a.De-energization of emergency buses;b.Load shedding from emergency buses for Divisions 1 and 2;and c.DG auto-starts from standby condition and: 1.energizes permanently connected loads in S 10 seconds, 2.energizes auto-connected shutdown loads, 3.maintains steady state voltage3744 V and S 4576 V, 4.maintains steady state frequency58.8 Hz and S 61.2 Hz, and 5.supplies permanently connected and auto-connected shutdown loads for5 minutes.SR 3.8.1.12 Verify on an actual or simulated Emergency Gore Gling System (EGGS)initiation signal each DG auto-starts from standby condition and: a.In S 10 seconds after auto-start and during tests, achieve voltage3744 V and frequency58.8 Hz;b.Achieves steady state voltage3744 V and S 4576 V and frequency58.8 Hz and S 61.2 Hz;c.Operates for5 minutes;and d.Emergency loads are auto-connected to the offsite power system.SR 3.8.1.13 Verify each DG's non-critical automatic trips are bypassed on an actual or simulated EGGS initiation signal except.SR 3.8.1.14 Verify each DG operates for24 hours: a.For DG 11 and DG 12 loaded5450 kW and S 5740 kW;and b.For DG 13: 1.For2 hours loaded3630 kW, and 2.For the remaining hours of the test loaded3300 kW.SR 3.8.1.15 Verify each DG starts and achieves;a.in S 10 seconds, voltage3744 V and frequency58.8 Hz;b.steady state voltage3744 V and S 4576 V and frequency58.8 Hz and S 61.2 Hz.SR 3.8.1.16 Verify each DG: a.Synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power;b.Transfers loads to offsite power source;and c.Returns to ready-to-Ioad operation.

SR 3.8.1.17 Verify, with a DG operating in test mode and connected to its bus, an actual or simulated EGGS initiation signal overrides the test mode by: a.Returning DG to ready-to-Ioad operation; and b.Automatically energizing the emergency loads from offsite power.SR 3.8.1.18 Verify interval between each sequenced load block is within+/-10%of design interval for each automatic load sequencer.

SR 3.8.1.19 Verify, on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated EGGS initiation signal: a.De-energization of emergency buses;b.Load shedding from emergency buses for Divisions 1 and 2;and c.DG auto-starts from standby condition and: 1.energizes permanently connected loads in S 10 seconds, 2.energizes auto-connected emergency loads, 3.achieves steady state voltage3744 V and S 4576 V, 4.achieves steady state frequency58.8 Hz and S 61.2 Hz, and 5.supplies permanently connected and auto-connected emergency loads for5 minutes.

GNRO-2012/00096 Attachment 1 Page 8 of 18 TS 3.8.4 DC Sources-Operating SR 3.8.4.3 Verify battery cells, cell plates, and racks show no visual indication of physical damage or abnormal deterioration that could degrade battery performance.

SR 3.8.4.4 Remove visible corrosion, and verify battery cell to cell and terminal connections are coated with anti-corrosion material.SR 3.8.4.5 Verify battery connection resistance is::;1.5 E-4 ohm for inter-cell connections,::;1.5 E-4 ohm for inter-rack connections,::;1.5 E-4 ohm for inter-tier connections, and::;1.5 E-4 ohm for terminal connections.

SR 3.8.4.6 Verify each Division 1 and 2 required battery charger supplies400 amps at125 V for10 hours;and the Division 3 battery charger supplies50 amps at125 V for4 hours.SR 3.8.4.7 Verify battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test.TS 5.5.7 Ventilation Filter Testing Program (VFTP)A change is proposed to Administrative Controls Section 5.5.7,"Ventilation Filter Testing Program (VFTP)," to address changes to 18-month frequencies that are specified in that section.This change revises the following subsections to change"18 months" to"24 months": The VFTP shall establish the required testing of Engineered Safety Feature (ESF)filter ventilation systems.Tests described in Specifications 5.5.7.a, 5.5.7.b, and 5.5.7.c shall be performed once per 18 months for standby service or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation; and, following significant painting, fire, or chemical release concurrent with system operation in any ventilation zone communicating with the system.Tests described in Specifications 5.5.7.d and 5.5.7.e shall be performed once per 18 months.2.2 Need for Changes The shift from an 18-month fuel cycle to a 24-month fuel cycle is a GGNS strategic initiative.

It is expected to increase the GGNS capacity factor throughout the plant's operating life, and reduce cumulative radiological occupational exposure due to less frequent refueling outages.2.3 Technical Specification Bases Changes Revised TS Bases are provided in Attachment 3 for NRC information.

These Bases revisions will be made as an implementing action pursuant to TS 5.5.11, TS Bases Control Program, following issuance of the amendment.

GN RO-20 12/00096 Attachment 1 Page 9 of 18 2.4 Instrument Set Point Legacy Issue During the calculation review for the 24 month fuel cycle submittal, GGNS identified the existence of several legacy issues dealing with GGNS technical specification related set point calculations.

These legacy issues impact some of the Technical Specification Allowable Values, are unrelated to the required consideration of instrument drift and will be addressed in a separate submittal.

3.0 TECHNICAL EVALUATION

3.1 Generic

Letter 91-04 Changes In NRC GL 91-04, the NRC provided generic guidance for evaluating a 24-month surveillance test interval for TS SRs that arecurrentlyperformed at 18-month intervals.

This section defines each step outlined by the NRC in the GL and provides a description of the methodology used by Entergy to complete the evaluation for each specific TS SR frequency being extended from 18 months to 24 months.The methodology utilized in the GGNS drift analysis is similar to the methodology used for previous plant submittals such as River Bend Station, Perry Nuclear Power Plant and Edwin I.Hatch Nuclear Power Plant submittals.

There have been minor revisions incorporated into the GGNS drift design guide based on NRC comments or Requests for Additional Information from previous 24-month fuel cycle extension submittals, such as the addition of the requirement that 30 samples are generally required to produce a statistically significant sample set.The proposed TS changes based on the GL have been divided into two categories.

The categories are: (1)changes to surveillances other than channel calibrations, identified as"Non-Calibration Changes";and (2)changes involving the channel calibration frequency identified as"Channel Calibration Changes." For each component having a surveillance interval extended, historical surveillance test data and associated maintenance records were reviewed in evaluating the effect on safety.In addition, the licensing basis was reviewed for functions associated with each revision to ensure it was not invalidated.

Based on the results of these reviews, it is concluded that there is no adverse effect onplantsafety due to increasing the surveillance test intervals from 18 months to 24 months, with the continued application of SR 3.0.2, which allowsa25%extension (Le., grace period up to 30 months)to SR frequencies.

Additionally, to support the above channel calibration changes to a 24-month frequency, some setpoint analysis revisions were required, but they did not result in TS Allowable Value changes.GNNS setpoint calculations, and affected calibration and functional test procedures, have been revised, or will be revised prior to implementation to reflect the new 30-month drift values.The revised setpoint calculations were developed in accordance with JS-09,:Methodology for the Generation of Instrument Loop Uncertainty

&Setpoint Calculations" (Reference 6.2).These calculations determined the instrument uncertainties and setpoints for the affected function.The setpoints were determined in a manner suitable to establish limits for their application.

As such, the setpoints ensure that sufficient margins are maintained in the applicable safety analyses to confirm theaffectedinstruments are capable of performing their intended design function.

GNRO-2012/00096 Attachment 1 Page 10 of 18 3.1.1 Non-Calibration Changes GL 91-04 identifies three steps to evaluate non-calibration changes: STEP 1: Licensees should evaluate the effect on safety of the change in surveillance intervals to accommodate a 24-month fuel cycle.This evaluation should support a conclusion that the effect on safety is small.EVALUATION Each non-calibration SR frequency being changed has been evaluated with respect to the effect on plant safety.The methodology utilized to justify the conclusion that extending the testing interval has a minimal effect on safety was based on the fact that the function/feature is: (1)Tested on a more frequent basis during the operating cycle by other plant programs;(2)Designed to have redundant counterparts or be single failure proof;or (3)Highly reliable.A summary of the evaluation of the effect on safety for each non-calibration SR frequency being changed is presented in Attachment 5.STEP 2: Licensees should confirm that historical maintenance and surveillance data do not invalidate this conclusion.

EVALUATION The surveillance test history of the affected SRs has been evaluated.

This evaluation consisted of a review of available surveillance test results and associated maintenance records for at least five cycles of operation.

With the extension of the testing frequency to 24 months, there will be a longer periodbetweeneach surveillance performance.

If a failure that results in the loss of the associated safety function should occur during the operating cycle, which would only be detected by the performance of the 18-month TS SR, then the increase in the surveillance testing interval might result in a decrease in the associated function availability.

In addition to evaluating these surveillance failures, potential common failures of similar components tested by different surveillances were also evaluated.

This additional evaluation determined whether there is evidence of repetitive failures among similar plant components.

These common component failures have been further evaluated to determine if there was an impact on plant reliability.

The evaluation determined that current plant programs are adequate to ensure system reliability.

The surveillance failures that are detailed in Attachment 5 exclude failures that: (a)Did not impact a TS safety function or TS operabilitY;(b)Are detectable by required testing performed more frequently than themonth surveillance being extended;or (c)Where the cause can be attributed to an associated event such as a preventative maintenance task, human error, previous modification, or previously existing design deficiency, or that were subsequently re-performed successfully with nointerveningcorrective maintenance (e.g., plant conditions GNRO-2012/00096 Attachment 1 Page 11 of 18 or malfunctioning measurement and test equipment (M&TE)may have caused aborting the test performance).

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

This review of surveillance test history validated the conclusion that the impact, if any, on system availability will be minimal as a result of the change to a 24-month testing frequency.

Specific SR test failures, and justification for this conclusion, are discussed in Attachment 5.STEP 3: Licensees should confirm that-the performance of surveillances at the bounding surveillance interval limit provided to accommodate a 24-month fuel cycle would not invalidate any assumption in the plant licensing basis.EVALUATION As part of the evaluation of each affected SR, the impact of the changes against the assumptions in the GGNS licensing basis was reviewed.In general, testing interval changes have no impact on the plant licensing basis.In some cases, the change to a 24-month fuel cycle may require a change to licensing basis information as described in the Updated Safety Analysis Report (USAR).However, since no changes requiring NRC review and approval have been identified, the USAR changes associated with fuel cycle extension to 24 months will be drafted in accordance with GGNS procedures that implement 10 CFR 50.59,"Changes, tests and experiments," and will be submitted in accordance with 10 CFR 50.71,"Maintenance of records, making of reports," paragraph (e).The performance of surveillances extended for a 24 month fuel cycle will be trended as a part of the Maintenance Rule Program.Degradation in performance will be evaluated to verify that the degradation is not due to the extension of surveillance or maintenance activities.

3.1.2 Calibration

Changes GL 91-04 identifies seven steps for the evaluation of instrumentation calibration changes.STEP 1: Confirm that instrument drift as determined by as-found and as-left calibration data from surveillance and maintenance records has not, except on rare occasions, exceeded acceptable limits for a calibration interval.EVALUATION The effect of longer calibration intervals on the TS instrumentation was evaluated by performing a review of the surveillance test history for the affected instrumentation including, where appropriate, an instrument drift study.In performing the historical evaluation, an effort was made to retrieve recorded channel calibration data for associated instruments for at least five operating cycles.By obtaining this past GNRO-2012/00096 Attachment 1 Page 12 of 18 recorded calibration data, an acceptable basis for drawing conclusions about the expectation of satisfactory performance can be made.The failure history evaluation and drift study found that instrument drift has not exceeded the current TS Allowable Values except for the SR test failures discussed in Attachment 5.The specific evaluation basis supporting this conclusion is also discussed in Attachment 5.STEP 2: Confirm that the values of drift for each instrument type (make, model, and range)and application have been determined with a high probability and a high degree of confidence.

Provide a summary of the methodology and assumptions used to determine the rate of instrument drift with time based upon historical plant calibration data.EVALUATION The effect of longer calibration intervals on the TS instrumentation was evaluated by performing an instrument drift study.In performing the drift study, an effort was made to retrieve recorded/channel calibration data for associated instruments for at least five operating.

By obtaining this past recorded calibration data, a true representation of instrument drift was determined (except in cases where all collected data still resulted in insufficient data for valid statistical analysis).

The methodology used to perform the drift analysis is consistent with the methodology utilized by other utilities requesting transition to a 24-month fuel cycle.The methodology is also based on Electric Power Research Institute (EPRI)103335,"Statistical Analysis of Instrument Calibration Data," and is summarized in Attachment 6.STEP 3: Confirm that the magnitude of instrument drift has been determined with a high probability and a high degree of confidence for a bounding calibration interval of 30 months for each instrument type (make, model number, and range)and application that performs a safety function.Provide a list of the channels by TS section that identifies these instrument applications.

EVALUATION In accordance with the methodology described in Attachment 6, the magnitude of instrument drift has been determined with a high degree of confidence and a high degree of probability (at least 95/95)for a bounding calibration interval of 30 months for each instrument make, model, and range.For instruments not in service long enough to establish a projected drift value, or where an insufficient number of calibrations have been performed to utilize the statistical methods (Le., fewer than 30 calibrations for any given group of instruments), the SR frequency is proposed to be extended to a 24-month interval based on more frequent testing or other justification obtained from analysis as presented in Attachment 6.The list of affected channels by TS section, including make, and model is provided in Attachment 7.STEP 4: Confirm that a comparison of the projected instrument drift errors has been made with the values of drift used in the setpoint analysis.If this GN RO-20 12/00096 Attachment 1 Page 13 of 18 results in revised setpoints to accommodate larger drift errors, provide proposed TS changes to update trip setpoints.

If the drift errors result in revised safety analysis to support existing setpoints, provide a summary of the updated analysis conclusions to confirm that safety limits and safety analysis assumptions are not exceeded.EVALUATION The projected drift values were compared to the design allowances as calculated in the associated instrument setpoint analyses.If the projected drift for an instrument fell outside the existing setpoint calculation design allowances, then the analysis of the setpoint, allowable value, and/or analytical limit was reviewed.Setpoint calculations were revised, as necessary, to accommodate appropriate drift values.Since the 30-month projected drift value for an instrument could be accommodated within the existing or revised setpoint analysis, the SR frequency was changed to"24 months" with no change to the TS Allowable Value or licensing basis analytical limit.As necessary, GGNS setpoint calculations, and affected calibration and functional test procedures, have been revised, or will be revised prior to implementation, to reflect the new 30-month drift values.The revised setpoint calculations were developed in accordance with Setpoint Methodology JS-09 Rev.1"Methodology for the Generation of Instrument Loop Uncertainty

&Setpoint Calculations".

These calculations determined the instrument loop uncertainty and setpoints for the affected function.The setpoints were determined in a manner suitable to establish limits for their application.

As such, the setpoints ensure that sufficient margins are maintained in the applicable safety analyses to confirm the affected instruments are capable of performing their intended designfunction.No Safety Analysis revisions were required due to drift incorporation in the setpoint calculations.

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

EVALUATION As discussed in the previous sections, the calculated drift values have been compared to drift allowances in the GGNS design basis.For instrument loops that provide process variable indication only, an evaluation was performed as described in Attachment 5 to verify that the instruments can still be effectively utilized to perform a plant safe shutdown.In no cases were changes to safe shutdown analyses required to support any change to a 24-month frequency.

STEP 6: Confirm that all conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for Channel Checks, Channel Functional Tests, and Channel Calibrations.

GN RO-20 12/00096 Attachment 1 Page 14 of 18 EVALUATION Applicable surveillance test procedures are being reviewed and acceptance criteria updated to incorporate the necessary changes resulting from any revision to setpoint calculations.

Any necessary changes resulting from the reviews will be incorporated into the instrument surveillance procedures prior to the implementation of the 24 month surveillance test frequency.

Existing plant processes ensure that all conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for Channel Checks, Channel Functional Tests, and Channel Calibrations.

STEP 7: Provide a summary description of the program for monitoring and assessing the effects of increased calibration surveillance intervals on instrument drift and its effect on safety.EVALUATION Instruments with TS calibration surveillance frequencies extended to 24 months will be monitored and trended.The as-found and as-left calibration data will be recorded for each 24-month calibration activity for a period of three cycles.This will identify occurrences of instruments found outside of their allowable value and instruments whose performance is not as assumed in the drift or setpoint analysis.Whenfound conditions are outside the allowable value, an evaluation will be performed in accordance with the GGNS corrective action program to determine if the assumptions made to extend the calibration frequency are still valid and to evaluate the effect on plant safety.Evaluations of mechanical components will be completed under the auspices of the Maintenance Rule, 10 CFR 50.65.3.3 Other 24-Month Cycle Considerations 3.3.1 18-Month Surveillances Not Being Changed During the evaluation of 18 month SRs it was determined that certain SRs or SR Functions were not eligible to be extended to 24 months.These SR frequencies will be maintained at 18 months as part of this submittal:

TS 3.3.6.1 Primary Containment and Drywell Isolation Instrumentation SR 3.3.6.1.7, Perform Logic System Functional Test Table 3.3.6.1-1, Function 2.g.Containment and Drywell Ventilation Exhaust Radiation-High.TS 3.3.8.1 Loss of Power Instrumentation SR 3.3.8.1.2, Perform CHANNEL CALIBRATION.

Table 3.3.8.1-1, Function 1.a.Divisions 1 and2-4.16 kV Emergency Bus Undervoltage, Loss of Voltage-4.16 kV basis.Table 3.3.8.1-1, Function 1.c.Divisions 1 and2-4.16 kV Emergency Bus Undervoltage, Degraded Voltage-4.16 kV basis.

GN RO-20 12/00096 Attachment 1 Page 15 of 18 TS 3.6.1.3 Primary Containment Isolation Valves SR 3.6.1.3.5, Perform leakage rate testing for each primary containment purge valve with resilient seals.(Frequency is 36 months with at least 2 pairs of valves tested every 18 months)TS 5.5.2 Primary Containment Sources Outside Containment SR 5.5.2.b, The program shall include the following:

Integrated leak test requirements for each system at refueling cycle intervals or less.4.0 REGULATORY SAFETY ANALYSIS NRC GL 91-04 provides generic guidance for evaluating a 24-month surveillance test interval for TS SRs.This request for license amendment provides the GGNS-specific evaluation of each step outlined by the NRC in GL 91-04 and provides a description of the methodology used by GGNS to complete the evaluation for each specific TS SR being revised.GGNS has determined that the proposed changes do not require any exemptions or relief from regulatory requirements, other than the TS, and do not affect conformance with any draft General Design Criteria differently than described in the GGNS USAR, as described below.4.1 Applicable Regulatory Requirements/Criteria Regulatory requirement 10 CFR 50.36,"Technical Specifications," provides the content required in a licensee's TS.Specifically, 10 CFR 50.36(c)(3) requires that the TS include surveillance requirements.

The proposed SR frequency changes continue to support the requirements of 10 CFR 50.36(c)(3) to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation are met.NRC GL 91-04 provides generic guidance for evaluating a 24 month surveillance test interval for TS SRs.This request for license amendment provides the GGNS specific evaluation of each step outlined by the NRC in GL 91-04 and provides a description of the methodology used by GGNS to complete the evaluation for each specific TS SR being revised.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 Commission's 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.4.2 No Significant Hazards Consideration 10 CFR 50.91 (a)(1)requires that licensee requests for operating license amendments be accompanied by an evaluation of no significant hazard posed by issuance of the amendment.

Entergy has evaluated this proposed amendment with respect to the criteria given in 10 CFR 50.92(c).The following is the evaluation required by 10 CFR 50.91(a)(1).

Entergy is requesting an amendment of the Operating License for the Grand Gulf Nuclear Station (GGNS)to revise Technical Specification surveillance and testing requirements to accommodate a 24-month fuel cycle.

GNRO-2012/00096 Attachment 1 Page 16 of 18 Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92,"Issuance of amendment," as discussed below: 1.Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.The proposed TS changes involve a change in the surveillance testing intervals to facilitate a change in the operating cycle length.The proposed TS changes do not physically impact the plant.The proposed TS changes do not degrade the performance of, or increase the challenges to, any safety systems assumed to function in the accident analysis.The proposed TS changes do not impact the usefulness of the SRs in evaluating the operability of required systems and components, or the way in which the surveillances are performed.

In addition, the frequency of surveillance testing is not considered an initiator of any analyzed accident, nor does a revision to the frequency introduce any accident initiators.

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

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

The proposed change does not affect the performance of any equipment credited to mitigate the radiological consequences of an accident.Evaluation of the proposed TS changes demonstrated that the availability of credited equipment is not significantly affected because of other more frequent testing that is performed, the availability of redundant systems and equipment, and the high reliability of the equipment.

Historical review of surveillance test results and associated maintenance records did not find evidence of failures thatwouldinvalidate the above conclusions.

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

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

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

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

The way surveillance tests are performed remains unchanged.

A historical review of surveillance test results and associated maintenance records indicated there was no evidence of any failures that would invalidate the above conclusions.

GN RO-20 12/00096 Attachment 1 Page 17 of 18 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3.Do the proposed changes involve a significant reduction in a margin of safety?Response: No.The proposed TS changes involve a change in the surveillance testing intervals to facilitate a change in the operating cycle length.The impact of these changes on system availability is not significant, based on other more frequent testing that is performed, the existence of redundant systems and equipment, and overall system reliability.

Evaluations have shown there is no evidence of time dependent failures that would impact the availability of the systems.The proposed changes do not significantly impact the condition or performance of structures, systems, and components relied upon for accident mitigation.

The proposed changes do not result in any hardware changes or in any changes to the analytical limits assumed in accident analyses.Existing operating margin between plant conditions and actual plant setpoints is not significantly reduced due to these changes.The proposed changes do not significantly impact any safety analysis assumptions or results.Therefore, the proposed change does not involve a significant reduction in a margin of safety.Based on the responses to the above questions, GGNS concludes that the proposed amendment with respect to GL 91-04-related changes presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c)and, accordingly, a finding of"no significant hazards consideration" is justified.

4.3 Conclusion

In conclusion, based on the considerations discussed above, (1)there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2)such activities will be conducted in compliance with the Commissions regulations, and (3)the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.5.0 ENVIRONMENTAL CONSIDERATION The proposed change 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, and would change an inspection or surveillance requirement.

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

GNRO-2012/00096 Attachment 1 Page 18 of 18

6.0 REFERENCES

6.1 NRC Generic Letter 91-04,"Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month FuelCycle,"dated April 2, 1991 6.2 JS-09 Rev.1"Methodology for the Generation of Instrument Loop Uncertainty

&Setpoint Calculations".

Attachment 2 GNRO-2012/00096 Proposed Technical Specification Changes (Mark-up)

Attachment 2 GNRO-2012/00096 Page 1 of 68 List of affected Technical Specifications pages: 3.1-23 3.6-8 3.1-27 3.6-17 3.6-21 3.3-5 3.6-23 3.3-5a 3.6-26 3.3-12 3.6-34 3.3-16 3.6-38 3.3-21 3.6-39 3.3-24 3.6-41 3.3-27 3.6-44 3.3-28 3.6-48 3.3-31 3.6-51 3.3-38 3.6-61 3.3-46 3.6-67 3.3-53 3.3-53a 3.7-4 3.3-54 3.7-5 3.3-55 3.7-8 3.3-56 3.7-11 3.3-57 3.3-58 3.8-7 3.3-61 3.8-8 3.3-65 3.8-9 3.3-69 3.8-10 3.3-72 3.8-11 3.3-75 3.8-12 3.3-78 3.8-13 3.3-79 3.8-13a 3.3-82 3.8-14 3.8-15 3.4-6 3.8-28 3.4-7 3.8-29 3.4-11 3.4-18 5.0-12 3.5-5 3.5-9 3.5-11 3.5-12 Attachment 2 GNRO-2012/00096 Page 2 of 68 SLC System 3.1.7 SURVEILLANCE REQUIREMENTS (continued)

SR 3.1.7.6 SR 3.1.7.7 SR 3.1.7.8 SR 3.1.7.9 SR 3.1.7.10 SURVEILLANCE Verify each SLC subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in the correct position, or can be aligned to the correct position.Verify each pump develops a flow rate41.2 gpm at a discharge pressure1340 psig.Verify flow through one SLC subsystem from pump into reactor pressure vessel.Determine Boron-IO enrichment in atom percent (E).Verify plplng between the storage tank and the pump suction is not blocked.FREQUENCY 31 days In accordance with the Inservice Testing Program 24+/--8 months on a STAGGERED TEST BASIS Once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after boron is added to the solution.Once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after solution temperature is restored to>45°F GRAND GULF 3.1-23 Next page is 3.1-26.Amendment No.

Attachment 2 GNRO-2012/00096 Page 3 of68 SOV Vent and Drain Valves 3.1.8 SURVEILLANCE REQUIREMENTS SR 3.1.8.1 SR 3.1.8.2 SR 3.1.8.3 GRAND GULF SURVEILLANCE

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

Not required to be met on vent and drain valves closed during performance of SR 3.1.8.2.Verify each SOV vent and drain valve is open.Cycle each SOY vent and drain valve to the fully closed and fully open position.Verify each SOY vent and drain valve: a.Closes in s 30 seconds after receipt of an actual or simulated scram signal;and b.Opens when the actual or simulated scram signal is reset.3.1-27 FREQUENCY 31 days 92 days Amendment No.

Attachment 2 GNRO-2012/00096 Page 4 of 68 R?S Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.11 Perform CHANNEL FUNCTIONAL TEST.. SR 3.3.1.1.12

NOTES------------------

1.

detectors are excluded.2.For IRMs, not required to be performed when entering MODE 2 from 1 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering 2.Perform CHANNEL CALIBRATION.months Perform LOGIC SYSTEM FUNCTIONAL TEST.SR 3.3.1.1.13

+-.....--124 imonths S:<'3.3.1.1.14 Verify Turbine Stop Valve Closure, Trip Oil Pressure-Low and Turbine Control Valve Fast Closure Trip Oil Pressure-Low Functions are not bypassed when THERMAL POWER is 2 35.4%RTP.

r-24--'----(continued)

GRAND GULF 3.3-5 Amendment No.+/-4+/-,

Attachment 2 GNRO-2012/00096 Page 50f68 RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.1.15 SR 3.3.1.1.16 SR 3.3.1.1.17 SR 3.3.1.1.18 SR 3.3.1.1.19 SURVEILLANCE

NOTES------------------

1.Neutron detectors are excluded.2.For Functions 3, 4, and 5 in Table 3.3.1.1-1, the channel sensors may be excluded.3.For Function 6,"n" equals 4 channels for the purpose of determining the STAGGERED TEST BASIS Frequency.

Verify the RPS RESPONSE TIME is within limits.Deleted Perform APRM recirculation flow transmitter calibration.

Deleted Perform CHANNEL CHECK.FREQUENCY re-months on a STAGGERED TEST BASIS+/--8 months 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (continued)

GRAND GULF 3.3-5a Amendment No. Hl-8 Attachment 2 GNRO-2012/00096 Page 6 of68 SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.2.4 SR 3.3.1.2*5 SR 3.3.1.2.6 GRAND GULF SURVEILLANCE

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

Not required to be met with less than or equal to four fuel assemblies adjacent to the SRM and no other fuel assemblies in the associated core quadrant.Verify count rate is: a.3.0 cps, or b.0.7 cps with a signal to noise

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

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after IRMs on Range 2 or below.Perform CHANNEL FUNCTIONAL TEST.------------------NOTES------------------

1.Neutron detectors are excluded.2.Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after IRMs on Range 2 or below.Perform CHANNEL CALIBRATION.

3.3-12 FREQUENCY 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during CORE AL TERATIONS AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 31 daysl.a.months Amendment No.

---.--Attachment 2 GNRO-2012/00096 Page 7 of68 Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.1.4 SURVEILLANCE

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

Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after THERMAL POWER is10%RTP in MODE 1.Perform CHANNEL FUNCTIONAL TEST.FREQUENCY 92 days SR 3.3.2.1.5 Calibrate the low power setpoint trip 92 days units.The Allowable Value shall be10%RTP and35%RTP.SR 3.3.2.1.6 Verify the RWL high power Function is not 92 days bypassed when THERMAL POWER is>70%RTP._.SR 3.3.2.1.7 SR 3.3.2.1.8 GRAND GULF Perform CHANNEL CALIBRATION.

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

Not reqUired to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after reactor mode switch is in the shutdown position.Perform CHANNEL FUNCTIONAL TEST.3.3-16 184 days l&months (continued)

Amendment No.

Attachment 2 GNRO-2012/00096 Page 8 of 68 PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS-----------------------------------

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

These SRs apply to each Function in Table 3.3.3.1-1.

SR 3.3.3.1.1 SR 3.3.3.1.2 SR 3.3.3.1.3 SURVEILLANCE Perform CHANNEL CHECK.Deleted------------------

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

Neutron detectors are excluded.Perform CHANNEL CALIBRATION.

FREQUENCY 31 days+8 months GRAND GULF 3.3-21 Amendment No.+&6 Attachment 2 GNRO-2012/00096 Page 90f68 Remote Shutdown System 3.3.3.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.3.2.2 SR 3.3.3.2.3 GRANO GULF SURVEILLANCE Verify each required control circuit and transfer switch is capable of performing the intended functions.

Perform CHANNEL CALIBRATION for each required instrumentation channel.3.3-24 FREQUENCY li-months1-8-monthsAmendment No.

Atlachmenl2 GNRO-2012/00096 Page 10 of 68 EOC-RPT Instrumentation 3.3.4.1 SURVEILLANCS REQUIREMENTS

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

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, provided the associated Function maintains EOC-RPT trip capability.

SR 3.3.4.1.1 SR 3.3.4.1.2 SR 3.3.4.1.3 SR 3.3.4.1.4 SR3.3.4.1.5 SURVEILLANCE Perform CHANNEL FUNCTIONAL TEST.Calibrate the trip units.Perform CHANNEL CALIBRATION.

The Allowable Values shall be: a.TSV Closure, Trip Oil Pressure-Low:

?37 psig.b.TCV Fast Closure, Trip Oil Pressure-Low:
?42 psig.Perform LOGIC SYSTEM FUNCTIONAL TEST, including breaker actuation.

Verify TSV Closure, Trip Oil Pressure-Low and TCV Fast Closure, Trip Oi 1 Pressure-Low Functions are not bypassed when THERMAL POWER is35.4%RTP.?REQUENCY 92 days 92 days(continued)

GRAND GULF 3.3-27 Amendment No. r9+/-

Attachment 2 GNRO-2012/00096 Page 11 of 68 EOC-RPT Instrumentation 3.3.4.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.4.1.6 SR 3.3.4.1.7 GRANO GULF SURVEI llANCE------------------NOTE-------------------

Breaker interruption time may be assumed from the most recent performance of SR 3.3.4.1.7.Verify the EOC-RPT SYSTEM RESPONSE TIME is within limits.Determine RPT breaker interruption time.3.3-28 FREQUENCY 7 1-&months on a STAGGERED TEST BASIS 60 months Amendment No.

Attachment 2 GNRO-2012/00096 Page 12 of 68 ATWS-RPT Instrumentation 3.3.4.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.4.2.2 SR 3.3.4.2.3 SR 3.3.4.2.4 SR 3.3.4.2.5 GRAND GULF SURVEILLANCE Perform CHANNEL FUNCTIONAL TEST.Calibrate the trip units.Perform CHANNEL CALIBRATION.

The Allowable Values shall be: a.Reactor Vessel Water Level--Low Low, Level 2:-43.8 inches;and b.Reactor Vessel Pressure--High:1139 psig.Perform LOGIC SYSTEM FUNCTIONAL TEST, including breaker actuation.

3.3-31 FREQUENCY 92 days 92 days 1&months 24 Amendment No.

Attachment 2 GNRO-2012/00096 Page 13 of 68 ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1.Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECeS Function.2.When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a)for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 3.c, 3.f, 3.g, and 3.h;and (b)for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions other than 3.c, 3.f, 3.g, and 3.h, provided the associated Function or the redundant Function maintains ECCS initiation capability.

SURVEIllANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK.12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST.92 days SR 3.3.5.1.3 Calibrate the trip unit.92 days SR 3.3.5.1.4 Perform CHANNEL CALIBRATION.

92 days SR 3.3.5.1.5 Perform CHANNEL CALIBRATION. 24 SR 3.3.5.1.6 Perform lOGIC SYSTEM FUNCTIONAL TEST.J&months'lm--l 24 GRAND GULF 3.3-38 Amendment No.m

-Attachment 2 GNRO-2012/00096 Page 14 of 68 RCIC System Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1.Refer to Table 3.3.5.2-1 to determine which SRs apply for each RCIC Function.2.When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a)for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 2 and 5;and (b)for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 1, 3, and 4 provided the associated Function maintains RCIC initiation capability.

"--SR 3.3.5.2.1 SR 3.3.5.2.2 SR 3.3.5.2.3 SR 3.3.5.2.4 SR 3.3.5.2.5 GRANO GULF SURVEILLANCE Perform CHANNEL CHECK.Perform CHANNEL FUNCTIONAL TEST.Calibrate the trip units.Perform CHANNEL CALIBRATION.

Perform LOGIC SYSTEM FUNCTIONAL TEST.3.3-46 FREQUENCV 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 92 days 92 days II monthsJt months[.J24 I Amendment No.

Attachment 2 GNRO-2012/00096 Page 15 of 68 Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------1.Refer to Table 3.3.6.1-1 to determine which SRs apply for each Function.2.When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK.12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST.92 days SR 3.3.6.1.3 Calibrate the trip unit.92 days SR 3.3.6.1.4 Perform CHANNEL CALIBRATION.

92 days SR 3.3.6.1.5 Perform CHANNEL CALIBRATION.

12 months ILOGIC SYSTEM FUNCTIONAL TEST.h SR 3.3.6.1.6 Perform CHANNEL CALI8RATI8PJ

.18 months..ISR 3.3.6.1.7 Perform+/--8-months/'(continued)

I SR 3.3.6.1.8 Perform LOGIC SYSTEM FUNCTIONAL TEST 24 months GRAND GULF 3.3-53 Amendment No.

Attachment 2 GNRO-2012/00096 Page 16 of 68 Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS (continued)

SR 303l SR 3.3.6')1 rn SURVEI LLANCE-------------------NOTE-----------------Channel sensors may be excluded.Verify the ISOLATION SYSTEM RESPONSE TIME for the Main Steam Isolation Valves is within 7imits.-------------------NOTE------------------Only required to be performed when Function 5.b is not OPERABLE as allowed by NOTE (h)of Table 3.3.6.1-1.

FREQUENCYmonths on a STAGGERED TEST BASIS Verify the water level in the Upper 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Containment Pool is22 feet, 8 inches above the reactor pressure vesse7 f7ange_GRAND GULF 3.3-53a Amendment No.1£3 t Attachment 2 GNRO-2012/00096 Page 17 of 68 Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 1 of 5)Primary Containment Drywell Isolation Instrumentation FUNCTION 1.Main Steam Line Isolation APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER TRIP SYSTEM CONDITIONS REFERENCED FROM REQUIRED ACTION C.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE a.Reactor Vessel Water Level C Low Low LClw, Level 1 b.Main Steam Line Pressure C Low c.Main Steam Line Flow C High d.Condenser Vacuum C Low e.Main Steam Tunnel Ambient Temperature C High f.Manual Initiation 2.?rimary Containment and Drywe11 Isolation a.Reactor Vessel Water Level C Low Low, Level 2 1,2,3 1 1,2,3 1,2,3 1,2,3 1,2,3 2 2 2 per MSL 2 2 2(b)L D E D D D G H SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR 3.3.6.1.1-152.5 i es 3.3.6.1.3 7 3.3.6.1.r 83.3.6.1'-:2:-.1019 3.3.6.1.1837 7 3.3.6.1.3 3.3.6.1.8 3.3.6.1.'::+3.3.6.3.3.6.1.1255.9 3.3.6.1.2 psid3.3.

7 3.3.6.1.8 3.3.6.1.98.7 3.3.6.1.2 inches 3.3.6.:.3 Hg vacuum 3.3.6.1..::+:

19PF 3.3.6.1.2 3.3.6.1.5 83.3.6.1..::+i!'3.3.6.1..::+NA 3.3.6.1.1-43.8 3.3.6.1.2 inches 3.3.6.1.(c:cntinued)(a)With any turbine stop valve not closed.(b)Also required to initiate the associated drywell isolation function.GRAND GULF 3.3-54 Amendment No.

Attachment 2 GNRQ-2012/00096 Page 18 of 68PrimaryContainment and Drywell Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 2 of 5)Primery Containment and Drywall Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVE ILLANCE ALLOWABLE FUIICTION CONDITIONS SYSTEM ACTION C.1 REQUIREMENTS VALUE 2.Primery ContaiN*\t and Drywell Isolation (continued) b.Drywell Pressure-High 1,2,3 Z(b)H SR 3.3.6.1.1 s 1.43 psig SR SR 3.3.6.1.3 SR 3.3.6.1.k-@]SR c.Reactor Vessel Water 1,2,3 2(b)F SR 3.3.6.1.1 2'152.5 Level-Low Low Low, SR 3.3.6.1.2 inches Level 1 (eCCs SR Divisions 1 end 2)SR SR 3.3.6.1.8 d.Drywell Pressure-High 1,2,3 2 F SR 3.3.6.1.1 s 1.44 psig (ECCS Divisions 1 SR and 2)SR 3.3.6.1.3 SRSR 3.3.6.1.iL 8 e.Reactor Vessel Water 1,2,3 4 F SR 3.3.6.1.1 2*43.8 Level-Low Low, Level SR 3.3.6.1.2 inches 2 (HPCS)SR 3.3.6.1.3SR SR 3.3.6.1.8 f.Drywall Pressure-High 1,2,3 4 F SR 3.3.6.1.1 s 1.44 psig (HPCS)SR SR 3.3.6.1.3 7 SR 3.3.6.1.SR 3.3.6.1.01-g.Containment end Drywell 1,2,3 2(b)F SR 3.3.6.1.1 s 4.0 IllR/hr Venti l.tion Exh_t SR 3.3.6.1.2 Radiation-High SR 3.3.6.1.5SR(c)2 K SR 3.3.6.1.1 s 4.0 IllR/hr SR 3.3.6.1.2 SR 3.3.6.1.5SR h.Manual Initiation 1,2,3 2(b)G SR(c)2 G SR 3.3.6.1.r NA (continued)(b)Also required to initiate the associated drywell isolation function.(c)During movement of recently irradiated fuel assemblies in primary or secondary containment and operations with.potential for draining the reactor vessel.GRAND GULF 3.3-55 Amendment No.

Attachment 2 GNRO-2012/00096 Page 19 of 68 Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 3 of 5)Primary Containment and Drywell Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS PER REQUI RED SURVE I LLANCE ALLOWABLE FUNCTION CONDITIONS TRIP SYSTEM ACTION C.1 REQUIREMENTS VALUE 3.Reactor Core Isolation Cooling (RCIC)System Isolation a.RCIC Steam Line 1.2.3 SR 3.3.6.1.1 S 64 inches Flow-Hi gh SR 3.3.6.1.2 water SR SR 3.3.6.1.SR b.RCIC Steam Line Flow 1,2,3 SR 3.3.6.1.2<: 3 seconds and Time Delay SR 3.3.6.1.4 s 7 seconds SR c.RCIC Steam Supply Line 1,2(dl.3(dl F SR 3.3.6.1.153 psig Pres sure-Low SR SR 3.3.6.1.3 7 SR SR 3.3.6.1.8 d.RCIC Turbine Exhaust 1, 2.3 SR 3.3.6.1.1 S 20 psig Diaphragm SR Pres sure-High SR 3.3.6.1.3 SR SR e.RCIC Equipment Room 1.2.3 F SR 3.3.6.1.1 S 191'F Ambient SR 3.3.6.1.2 Temperature

-High SR SR 3.3.6.1.f.Main Steam Line Tunnel 1,2,3 SR 3.3.6.1.1 S 191'F Ambient SR 3.3.6.1.2 Temperature

-Hi gh SR SR 3.3.6.1.8 g.Main Steam Line Tunnel 1.2.3 F SR 3.3.6.1.2 s 30 minutes Temperature Timer SR SR 3.3.6.1.8 h.RHR Equipment Room 1.2.3 1 per room SR 3.3.6.1.1 S 171'F Ambient SR 3.3.6.1.2 Temperature

-Hi gh SR 3.3.6.1.5SR 3.3.6.1.+-

i.RCIC/RHR Steam Line 1.2.3 F SR 3.3.6.1.1 s 43 inches Flow-High SR 3.3.6.1.2 water SR SR 3.3.6.1.SR(continued)(dl Not required to be OPERABLE in MODE 2 or 3 with reactor steam dome pressure less than 150 psig during reactor startup.GRAND GULF 3.3-56 Amendment No.1D2 Attachment 2 GNRO-2012/00096 Page 20 of 68 Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 4 of 5)Primary containment and Drywell Isolation Instrumentation APPLICABLE CONDITIONS MCOES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS TRIP SYSTEM ACTION C.1 REQU I REMENTS VALUE 3.RCIC System Isolation (continued) j.DrYNell Pressure-High 1,2,3 F SR 3.3.6.1.1 S 1.44 psig SR SR 3.3.6.1.3 SR 3.3.6.1.8 SR 3.3.6.1.k.Manual Initiation 1,2,3 G SR 3.3.6.1.'1-NA 4.Reactor Water Cleanup (RWCU)Syst_Isolation a.Differential Flow-High 1,2,3 F SR 3.3.6.1.1 S 89SR SR 3.3.6.1.6 SR b.Differential 1,2,3 F SR 3.3.6.1.2 S 57 secanda Flow-T illllr SR SR 3.3.6.1.c.RWCU Hilt Exchanger 1,2,3 F SR 3.3.6.1.1 7'0 F EquipllntSR 3.3.6.1.2 Temperature

  • SR 3.3.6.1.2 High SR SR 3.3.6.1.g.Reactor V....l Wat.r 1,2,3 2 F SR 3.3.6.1.1!-43.8 inch..Lev.l-LOll LOll, Level 2 SR SR 3.3.6.1.3 SR SR 3.3.6.1.h.Standby L iqufd Control 1,2 SR Sy.tem Initiation i.Manual Initiation 1,2,3 2 G SR NA (contInued)

GRAND GULF 3.3-57 Amendment No.

Attachment 2 GNRO-2012/00096 Page 21 of 68 Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 5 of 5)Primary Containment and Drywell Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS PER REQUIRED SURVEI LLANCE ALLOWABLE FUNCTION CONDITIONS TRI P SYSTEM ACTI ON C.l REQUIREMENTS VALUE 5.RHR System Isolation a.RHR Equipment Room 1,2,3 1 per room F SR 3.3.6.1.1 S 171°F Ambient SR 3.3.6.1.2.

Temperature

-Hi gh SR SR 3.3.6.1-b.Reactor Vessel Water 1,2,3(f)2 F SR 3.3.6.1.110.8 inches Level-Low, Level 3 SR 3.3.6.1.2 III SR SR3.3.6.1.-6-=SR 3(g),4,S(h) 2(e)J SR 3.3.6.1.110.8 inchesl SR SR SR 3.3.6.1 SRSR 10 c.Reactor Steam Dome 1,2,3 2 F SR 3.3.6.1.1 5 ISO psig Pressure-High SR SR 3.3.6.1.3 7 SR 3.3.6.1SR 3.3.68 d.Drywell Pressure-High 1,2,3 2 F SR 3.3.6.1.1 S 1.43 psig SR SR 3.3.6.1.3 SRSR 8 e.Manual Initiation 1,2,3 2 G SR(e)Only one trip system required in MODES 4 and S with RHR Shutdown Cooling System integrity maintained.(f)With reactor steam dome pressure greater than or equal to the RHR cut-in permissive pressure.(9)With reactor steam dome pressure less than the RHR cut-in permissive pressure.(h)Not and applicable when SR the upper containment reactor cavity and transfer canal gates are removed I met.GRAND GULF 3.3-58 Amendment No.

Attachment 2 GNRO-2012/00096 Page 22 of6B Secondary Containment Isolation Instrumentation 3.3.6.2'-""--SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.6.2.2 Perform CHANNEL FUNCTIONAL TEST.92 days SR 3.3.6.2.3 Calibrate the trip unit.92 days SR 3.3.6.2.4 Perform CHANNEL CALIBRATION.

12 months SR 3.3.6.2.5 Perform CHANNEL CALIBRATION.

l-3,nths ds SR 3.3.6.2.6 Perform lOGIC SYSTEM FUNCTIONAL TEST.months SR 3.3.6.2.7------------------NOTE-------------------

Radiation detectors may be excluded.T-----------------------------------------

Verify the ISOLATION SYSTEM RESPONSE TIME months on a for air operated Secondary Containment STAGGERED TEST isolation dampers is within limits.BASIS GRAND GULF 3.3-61 Amendment No.

'-Attachment 2 GNRO-2012/00096 Page 23 of 68 RHR Containment Spray System Instrumentation 3.3.6.3 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1.Refer to Table 3.3.6.3-1 to determine which SRs apply for each RHR Containment Spray System Function.2.When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, provided the associated Function maintains RHR containment spray initiation capability.

SURVEIllANCE FREQUENCY SR 3.3.6.3.1 Perform CHANNEL CHECK.12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.3.6.3.2 Perform CHANNEL FUNCTIONAL TEST.92 days SR 3.3.6.3.3 Calibrate the trip unit.92 days SR 3.3.6.3.4 Perform CHANNEL CALIBRATION.

92 days SR 3.3.6.3.5 Perform CHANNEL CALIBRATION.months\[1 SR 3.3.6.3.6 Perform LOGIC SYSTEM FUNCTIONAL TEST.1&months GRAND GULF 3.3-65 Amendment No.

Attachment 2 GNRO-2012/00096 Proposed Technical Specification Changes (Mark-up)

_.Attachment 2 GNRO-2012100096 Page 24 of 68 SPMU System Instrumentation 3.3.6.4 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1.Refer to Table 3.3.6.4-1 to determine which SRs apply for each SPMU Function.2.When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, provided the associated Function maintains SPMU initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.4.1 Perform CHANNEL CHECK.12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.3.6.4.2 Perform CHANNEL FUNCTIONAL TEST.92 days SR 3.3.6.4.3 Calibrate the trip unit.92 days SR 3.3.6.4.4 Perform CHANNEL CALIBRATION.

92 days SR 3.3.6.4.5 Perform CHANNEL CALIBRATION.I 24\11 SR 3.3.6.4.6 Perform LOGIC SYSTEM FUNCTIONAL TEST.1&months GRAND GULF 3.3-69 Amendment

--Attachment 2 GNRO-2012/00096 Page 25 of 68 Relief and LLS Instrumentation 3.3.6.5 SURVEILLANCE REQUIREMENTS

NOTE-------------------.-----------------

When a channel is placed in an inQperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, provided the associated Function maintains LLS or relief initiation capability, as applicable.

SR 3.3.6.5.1 SR 3.3.6.5.2 SURVEILLANCE Perform CHANNEL FUNCTIONAL TEST.Calibrate the trip unit.FREQUENCY 92 days 92 days SR 3.3.6.5.3 Perform CHANNEL CALIBRATION.

The 13 months Allowable Values shall be:i.Relief Function--Low: 1103:I: 15 psig Medium: 1113:I: 15 psig High: 1123:I: 15 psig b.LLS Function Low open: 1033:I: 15 psig close: 926:I: 15 psig Medium open: 1073:I: 15 psig close: 936:I: IS psig High open: 1113 t 15 ps1g 24 close: 946 t 15 psig'II SR 3.3.6.5.4 Perform LOGIC SYSTEM FUNCTIONAL TEST.13 months GRAND GULF 3.3-72 Amendment No.u.o.

Attachment 2 GNRO-2012/00096 Page 26 of 68 SURVEILLANCE REQUIREMENTS CRFA System Instrumentation 3.3.7.1-------------------------------------NOTE-------------------------------------When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided CR isolation capability is maintained.

SR 3.3.7.1.1 GRAND GULF SURVEILLANCE Perform LOGIC SYSTEM FUNCTIONAL TEST.3.3-75 FREQUENCYf8 months Amendment No.+/-r&, 145

"-Attachment 2 GNRO-2012/00096 Page 27 of 68 LOP Instrumentation 3.3.8.1 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1.Refer to Table 3.3.8.1-1 to determine which SRs apply for each lOP Function.2.When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated Function maintains DG initiation capability.

SR 3.3.8.1.1 SR 3.3.8.1.2 SURVEILLANCE Perform CHANNEL FUNCTIONAL TEST.Perform CHANNEL CALIBRATION.

FREQUENCY 31 days 18 months-SR Perform LOGIC SYSTEM FUNCTIONAL TEST.13 months SR 3.3.8.1.3 GRAND GULF Perform CHANNEL CALIBRATION 3.3-78 24 months Amendment No.l-2.Q.

Attachment 2 GNRO-2012/00096 Page 28 of 68 Table 3.3.8.1*1 (page 1 of 1>Loss of Powr Instrunentatlon LOP Instrumentation 3.3.8.1 4 SR ,..., ,,'Z, SR 3.3.8.1.SR 2 5R 3.3.8.1.0.4 seconds and!1.0 seconds SR 4 SR 3.3.8.1.13744 V and!3837.6 V SR SR 3.3.8.1.3 2 SR 3.3.8.1.-28.5 seconds and!9.5 seconds SR 4 SR

....,"06 , SR 2 SR 3.3.8.1 seconds and S 2.5 seconds SR 3.3.B.I.4 SR SR V 3763.5 V 3.3.8.1.4 2 SR mlnut..and S 5.5.inut..SR 4 SR t 3.6 seconds and S 4.4 seconds SR FUNCTION 1.Divisions 1 and 2-4.16 kV Emergency Bus Undervoltage I.Loss of Voltage-4.16 kV basis b.LOSs of Vol tage-Time Deley c.Degraded Vol tege-4.16 kV basis d.Degraded Voltage-Time Delay 2.Division3-4.16 kY E_rv-teY Bus undervol tage**Loss of Voltage-4.16 kV basis b.Loss of Voltage-T 1_Delay c.Degraded Vol tage-4.16 kV basis d.Degraded Vol tege-Time Delay, No LOCA e.Degraded Voltage-Time Delay, LOCA REQUIRED CHANNELS PER SURVEI LlAIICE DIVISION REQUIREMENTS ALLOWABLE VALUE GRAND GULF 3.3-79 Amendment No.

Attachment 2 GNRO-2012/00096 Page 29 of 68 RPS Electric Power Monitoring 3.3.8.2 SURVEILLANCE REQUIREMENTS (continued)

'-SR 3.3.8.2.2 SR 3.3.8.2.3 GRAND GULF SURVEILLANCE Perform CHANNEL CALIBRATION.

The Allowable Values shall be: a.Overvoltage Bus A132.9 V Bus B133.0 V b.Undervoltage Bus A115.0 V Bus B115.9 V c.Underfrequency (with time delay set to4 seconds)Bus A57 Hz Bus B57 Hz Perform a system functional test.3.3-82 FREQUENCY l.a.months" r-l24 I\11 l:a months Amendment No.

-Attachment 2 GNRO-2012/00096 Page 30 of 68 FCVs 3.4.2 3.4 REACTOR COOLANT SYSTEM (RCS)3.4.2 Flow Control Valves (FCVs)LCO 3.4.2 A recirculation loop FCV shall be OPERABLE in each operating recirculation loop.APPLICABILITY:

MODES 1 and 2.ACTIONS-------------------------------------NOTE-------------------------------------

Separate Condition entry 1s allowed for each FCV.CONDITION REQUIRED ACTION COMPLETION TIME A.One or two required A.l Lock up the FCV.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> FCVs inoperable.

B.Required Action and B.l Be in MODE 3.12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met.SURVEILLANCE REQUIREMENTS SR 3.4.2.1 GRAND GULF SURVEILLANCE Verify each Fev fails"as is" on loss of hydraulic pressure at the hydraulic unit.3.4-6 FREQUENCY;t months(continued)

Amendment No.m Attachment 2 GNRO-2012100096 Page 31 of68 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FCVs 3.4.2 FREQUENCY'_.SR 3.4.2.2 GRAND GULF Verify average rate of each Fev movement is: a.11%of stroke per second for opening;and b.11%of stroke per second for closing.3.4-7Amendment No.llQ Attachment 2 GNRO-2012/00096 Page 32 of 68 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE S/RVs 3.4.4 FREQUENCY SR 3.4.4.2 SR 3.4.4.3-------------------NOTE--------------------

Valve actuation may be excluded.Verify each required relief function S/RV actuates on an actual or simulated automatic initiation signal.*-------------------NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.Verify each required S/RV relief-mode actuator strokes when manually actuated.f months L@In accordance.

with the Inservice Testing Program on a STAGGERED TEST BASIS for each valve solenoid GRANO GULF 3.4-11 Amendment No.

Attachment 2 GNRO-2012/00096 Page 33 of 68 Res Leakage Detection Instrumentation

3.4.7 ACTIONS

(continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.Required drywell E.1 Restore required drywell 30 days atmospheric monitoring atmospheric monitoring system inoperable.

system to OPERABLE status.AND OR Drywell air cooler E.2 Restore drywell air cooler 30 days condensate flow rate condensate flow rate monitoring system monitoring system to inoperable.

OPERABLE status.F.Required Action and F.1 Be in Mode 3.12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A, B, C, D, or E AND not met.36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> F.2 Be in Mode 4.G.All required leakage G.1 Enter LCO 3.0.3 Immediately detection systems inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 SR 3.4.7.2 SR 3.4.7.3 Perform CHANNEL CHECK of required drywell atmospheric monitoring system.Perform CHANNEL FUNCTIONAL TEST of required leakage detection instrumentation.

Perform CHANNEL CALIBRATION of required leakage detection instrumentation.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 31 daysGRAND GULF 3.4-18 Amendment No.

Attachment 2 GNRO-2012/00096 Page 34 of 68 ECCS-Operlt 1"9 3.5.1 SURVEILLMCE REQUIREMENTS (continued)

SR 3.5.1.5 SR 3.5.1.6 SR 3.5.1.7 SURVEILLAHCE

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

Vissil injection/spray

.., be Ixcluded.-------------------------------------------

Vlrify IIch ECCS 1nject1on/sprl1 subsyst.lctuatls on an actual or s1.ulated autOlat1c initiation signal.-------------------NOTE--------------------

Valvi actuation-.y.be Ixcluded.-------------------------------------------

Vlr1fy thl ADS actuatls on an actual or s1..hted autOlllt1c initiation signal.--*----------------NOTE--------------------

Not rlqu1red to be until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> aftlr relctor stl" prlssurl and flow are adlqultl to thl tlSt.-------------------------------------------

FREQUENCY Vlr1fy Ilch ADS vilvi rll11f-lOdl actuator In accordanci strokls when..nually actuated.with the Insln1cl Tlsting Progr.on I STAGGERED TEST BASIS for lach vilvi solenoid SR 3.5.1.8-------------------NOTE--------------------

ECCS actult10n 1nstru.entat1on is Ixcluded.Vlr1fy thl ECCS RESPONSE TIME for thl HPCS Syst..is within l1.1ts.GRANO GULF 3.5-5 AMndMnt No.no, 130,'1-33 Attachment 2 GNRO-2012/00096 Page 35 of 68 RE IREMENTS continued SURVEILLANCE ECCS-Shutdown 3.5.2 FREQUENCY Verify each required ECCS PUlP develops the specified flow rate with the specified total developed head.SR 3.5.2.5 SYSTEM LPCS lPCJ HPCS FLOW WE7115 gPil7450 gPil TOTAL DEYELOPP HEAD290 plid125 psid445 psid In accordance with the Inse"ice*Testing Prograa SR 3.5.2.6 GRAND GULF-------------------NOTE--------------------

Vessel injection/spray

..y be excluded.-------------------------------------------

Verify each required ECCS injection/spray subsyst..Ictultes on In actull or silUlated autGiatic initiation signal.3.5-9 AMndMnt No.

-Attachment 2 GNRO-2012/00096 Page 36 of68 RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 SR 3.5.3.2 Verify the RCIC System piping is filled 31 days with water from the pump discharge valve to the injection valve.Verify each RCIC System manual, power 31 days operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.--SR 3.5.3.3 SR 3.5.3.4 GRAND GULF-------------------NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.Verify, with RCIC steam supply pressure s 1045 psig and945 psig, the RCIC pump can develop a flow rate800 gpm against a system head corresponding to reactor pressure.-------------------NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.Verify, with RCIC steam supply pressure s 165 psig and150 psig, the RCIC pump can develop a flow rate800 gpmagainsta system head corresponding to reactor pressure.3.5-11 92 dayst.months (continued)

Amendment Attachment 2 GNRO-2012/00096 Page 37 of 68 SURVEILLANCE REQUIREMENTS SURVEILLANCE RCIC System 3.5.3 FREQUENCY SR 3.5.3.5 GRAND GULF-------------------NOTE--------------------

Vessel injection may be excluded.Verify the RCIC System actuates on an actual or simulated automatic initiation signal.3.5-12J months Amendment No.lln Attachment 2 GNRO-2012/00096 Page 38 of 68 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE Primary Containment Air Locks 3.6.1.2 FREQUENCY SR 3.6.1.2.3 SR 3.6.1.2.4 Verify only one door in the primary containment air lock can be opened at a time.Verify, from an initial pressure of 90 psig, the primary containment air lock seal pneumatic system pressure does not decay at a rate equivalent to>2 psig for a period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.24 months24 GRAND GULF 3.6-8 Amendment No.+eG, t4i Attachment 2 GNRO-2012/00096 Page 39 of 68 PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.1.3.6 SR 3.6.1.3.7 SR 3.6.1.3.8 SR 3.6.1.3.9 SURVEILLANCE Verify the isolation time of each MSIV is z 3 seconds and5 seconds.Verify each automatic PCIV actuates to the isolation position on an actual or simulated isolation signal.------------------NOTE-------------------

Only required to be met in MODES 1, 2, and 3.Verify leakage rate through each main steam line is100 scfh when tested at z P a , and the total leakage rate through all four main steam lines is250 sefh when tested at z P a.------------------NOTE-------------------

Only required to be met in MODES 1, 2, and 3.Verify combined leakage rate of 1 gpm times the total number of PCIVs through hydrostatically tested lines that penetrate the primary containment is not exceeded when these isolation valves are tested at z 1.1 P a.FREQUENCY In accordance with the Inservice Testing Program ronthsIn accordance with 10 CFR 50, Appendix J, Testing Program In accordance with 10 CFR 50, Appendix J, Testing Program GRAND GULF 3.6-17 Amendment No.

Attachment 2 GNRO-2012/00096 Page 40 of 68 SURVEILLANCE REQUIREMENTS SURVEILLANCE LLS Valves 3.6.1.6 FREQUENCY SR 3.6.1.6.1 SR 3.6.1.6.2------------------NOTE-------------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.Verify each LLS valve relief-mode actuator strokes when manually actuated.------------------NOTE-------------------

Valve actuation may be excluded.Verify the LLS System actuates on an actual or simulated automatic initiation signal.In accordance with the Inservice Testing Program on a STAGGERED TEST BASIS for each valve solenoidimonths GRAND GULF 3.6-21 Amendment No. l3&

Attachment 2 GNRO-2012/00096 Page 41 of 68 RHR Containment Spray System 3.6.1.7 SURVEILLANCE REQUIREMENTS

-_.SR 3.6.1.7.1 SR 3.6.1.7.2 SR 3.6.1.7.3 GRAND GULF SURVEILLANCE

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

RHR containment spray subsystems may be considered OPERABLE during alignment and operation for decay heat removal when below the RHR cut in permissive pressure in MODE 3 if capable of being manually realigned and not otherwise inoperable.

Verify each RHR containment spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.Verify each RHR pump develops a flow rate of7450 gpm on recirculation flow through the associated heat exchanger to the suppression pool.Verify each RHR containment spray subsystem automatic valve in the flow path actuates to its correct position on an actual or simulated automatic initiation signal.3.6-23 FREQUENCY 31 days In accordance with the Inservice Testing Program it monthsAmendment No.120 Attachment 2 GNRO-2012/00096 Page 42 of68 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE MSIV LCS 3.6.1.9 FREQUENCY SR 3.6.1.9.2 SR3.6.1.9.3 Deleted not applicable Perform a system functional test of each MSIV LCS subsystem.

24 GRAND GULF 3.6-26 Amendment Attachment 2 GNRO-2012/00096 Page 43 of 68 SPMU System 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 SR 3.6.2.4.2 SR 3.6.2.4.3 Verify upper containment pool water level 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is 2 23 ft 3 inches above the pool bottom.Verify upper containment pool water 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> temperature is125°F.Verify each SPMU subsystem manual, power 31 days operated, and automatic valve that is not locked, sealed, or otherwise secured in position is in the correct position.------------------NOTE-------------------The requirements of this SR are not required to be met when all upper containment pool levels are maintained per SR 3.6.2.4.1 and suppression pool water level is maintained 2 18 ft 5 1/12 inches (one inch above LCD 3.6.2.2 Low Water Level).SR 3.6.2.4.4 SR 3.6.2.4.5 Verify all upper containment pool gates are in the stored position or are otherwise removed from the upper containment pool.------------------

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

Actual makeup to the suppression pool may be excluded.Verify each SPMU subsystem automatic valve actuates to the correct position on an actual or simulated automatic initiation signal.31 days 24 onths GRAND GULF 3.6-34 Amendment No.+/-r&

Attachment 2 GNRO-2012/00096 Page 44 of 68 Primary Containment and Drywell Hydrogen Igniters 3.6.3.2 ACTIONS (continued)

CONDITION C.Required Action and C.1 associated Completion Time not met.SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIRED ACTION Be in MODE 3.COMPLETION TIME 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> FREQUENCY SR 3.6.3.2.1 SR 3.6.3.2.2 SR 3.6.3.2.3 GRAND GULF Energize each primary containment and drywell hydrogen igniter division and perform current versus voltage measurements to verify required igniters in service.------------------NOTE-------------------

Not required to be performed until 92 days after discovery of four or more igniters in the division inoperable.

Energize each primary containment and drywell hydrogen igniter division and perform current versus voltage measurements to verify required igniters in service.Verify each required igniter in inaccessible areas develops sufficient current draw for a1700"F surface temperature.

3.6-38 184 days 92 days ,months(continued)

Amendment No.

Attachment 2 GNRO-2012/00096 Page 45 of 68 Primary Containment and Drywell Hydrogen Igniters 3.6.3.2 SURVEILLANCE REQUIREMENTS SURVEIllANCE FREQUENCY SR 3.6.3.2.4 GRAND GULF Verify each required igniter in accessible areas develops a surface temperature ofI700-F.3.6-39 24 Amendment No.

Attachment 2 GNRO-2012/00096 Page 46 of 68 SURVEILLANCE REQUIREMENTS SURVEILLANCE Drywell Purge System 3.6.3.3 FREQUENCY.--.SR 3.6.3.3.1 SR 3.6.3.3.2 SR 3.6.3.3.3 SR 3.6.3.3.4 GRAND GULF Perform a CHANNEL FUNCTIONAL TEST of the isolation valve pressure actuation instrumentation.

Operate each drywell purge subsystem for15 minutes.Verify each drywell purge subsystem flow rate is1000 cfm.Verify the opening pressure differential of each vacuum breaker and isolation valve is1.0 psid.3.6-41 31 days 92 days

,"'1-124 trant,s 24 Amendment No.

Attachment 2 GNRO-2012/00096 Page 47 of 68 SURVEILLANCE REQUIREMENTS (continued)

Secondary Containment 3.6.4.1 SURVEILLANCE FREQUENCY SR 3.6.4.1.3 SR 3.6.4.1.4 Verify the secondary containment can be drawn down to0.25 inch of vacuum water gauge in180 seconds using one standby gas treatment (SGT)subsystem.

Verify the secondary containment can be maintained0.266 inch of vacuum water gauge for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> using one SGT subsystem at a flow rate4000 cfm.l!months on a STAGGERED TEST BASIS for each SGT subsystem'fg.months on a STAGGERED TEST BASIS for each SGT subsystem GRAND GULF 3.6-44 Amendment No.+/-4&,

Attachment 2 GNRO-2012/00096 Page 48 of 68 SURVEILLANCE REQUIREMENTS SURVEI LLANCE SCIVs 3.6.4.2 FREQUENCY SR 3.6.4.2.1 SR 3.6.4.2.2 SR 3.6.4.2.3--------.---.-----NOTES--------..--.-----1.Valves, dampers, rupture disks, and blind flanges in high radiation areas may be verified by use of administrative means.2.Not required to be met for SCIVs that are open under administrative controls.Verify each secondary containment isolation manual valve, damper, rupture disk, and blind flange that is required to be closed during accident conditions is closed.Verify the isolation time of each power operated, automatic SCIV is within limits.Verify each automatic SCIV actuates to the isolation position on an actual or simulated automatic isolation signal.31 days In accordance with the Inservice Testing Program*monthsGRAND GULF 3.6-48 Amendment No.129, Attachment 2 GNRO-2012/00096 Page 49 of68 SURVEILLANCE REQUIREMENTS SURVEI LLANCE SGT System 3.6.4.3 FREQUENCY SR 3.6.4.3.1 SR 3.6.4.3.2 SR 3.6.4.3.3 GRAND GULF Operate each SGT subsystem for10 continuous hours with heaters operating.

Perform required SGT filter testing in accordance with the Ventilation Filter Testing Program (VFTP).Verify each SGT subsystem actuates on an actual or simulated initiation signal.3.6-51 31 days In accordance with the VFTP 1&monthsAmendment No.

Attachment 2 GNRO-2012/00096 Page 50 of 68 SURVEILLANCE REQUIREMENTS (continued)

Drywell Isolation Valves 3.6.5.3 SURVEILLANCE FREQUENCY SR 3.6.5.3.3 SR 3.6.5.3.4 Verify the isolation time of each power operated, automatic drywell isolation valve is within limits.Verify each automatic drywell isolation valve actuates to the isolation position on an actual or simulated isolation signal.In accordance with the Inservice Testing Program 1 monthsGRAND GULF 3.6-61 Amendment No.128, Attachment 2 GNRO-2012/00096 Page 51 of 68 Drywell Vacuum Relief System 3.6.5.6 SURVEILLANCE REQUIREMENTS SR 3.6.5.6.1 SR 3.6.5.6.2 SR 3.6.5.6.3 GRAND GULF SURVEILLANCE

NOTES-------------------

1.Not required to be met for vacuum breakers or isolation valves open during surveillances.

2.Not required to be met for vacuum breakers or isolation valves open when performing their intended function.Verify each vacuum breaker and its associated isolation valve is closed.Perform a functional test of each vacuum breaker and its associated isolation valve.Verify the opening pressure differential of each vacuum breaker and isolation valve is1.0 psid.3.6-67 FREQUENCY 7 days 31 days 1f monthsAmendment No.

Attachment 2 GNRO-2012/00096 Page 52 of68 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SSW System and UHS 3.7.1 FREQUENCY SR 3.7.1.3 SR 3.7.1.4 Verify each required SSW subsystem manual, 31 days power operated, and automatic valve in the flow path servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.Verify each SSW subsystem actuates on an onths actual or simulated initiation signal.24 GRAND GULF 3.7-4 Amendment No.120 Attachment 2 GNRO-2012/00096 Page 53 of 68 HPCS SWS 3.7.2 3.7 PLANT SYSTEMS 3.7.2 High Pressure Core Spray (HPCS)Service Water System (SWS)LCO 3.7.2 The HPCS SWS shall be OPERABLE.APPLICABILITY:

MODES 1, 2, and 3.ACTIONS CONDITION A.HPCS SWS inoperable.

A.l REQUIRED ACTION Declare HPCS System inoperable.

COMPLETION TIME IlTIIIediately

......SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 SR 3.7.2.2 GRAND GULF Verify each required HPCS SWS manual, power operated, and automatic valve in the flow path servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.Verify the HPCS SWS actuates on an actual or simulated initiation signal.3.7-5 31 days 13 monthsAmendment No.

Attachment 2 GNRO-2012/00096 Page 54 of68 CRFA System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.TwO CRFA subsystems E.l Enter LCO 3.0.3.Immediately inoperable in MODE 1, 2, or 3 for reasons other than condition B.F.Two CRFA subsystems F.l Initiate action to Immediately inoperable during suspend OPDRVS.OPDRVS.OR One or more CRFA subsystems inogerable due to inopera le CRE boundary during OPDRVS.SURVEILLANCE REQUIREMENTS SR 3.7.3.1 SR 3.7.3.2 SR 3.7.3.3 SR 3.7.3.4 SURVEILLANCE operate each CRFA subsystem for10 continuous hours with the heaters operating.

perform required CRFA filter testing in accordance with the Ventilation Filter Testing program (VFTP).verify each CRFA subsystem actuates on an actual or simulated initiation signal*perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.FREQUENCY 31 days In accordance with the VFTP

.In accordance with the Control Room Envelope Habitability program GRAND GULF 3.7-8 Amendment Attachment 2 GNRO-2012/00096 Page 55 of 68 ACTIONS (continued)

CONDITION E.Required Action and E.1 associated Completion Time of Condition B not met during OPDRVs.SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIRED ACTION Initiate action to suspend OPDRVs.Control Room AC System 3.7.4 COMPLETION TIME Immediately FREQUENCY SR 3.7.4.1 Verify each control room AC subsystem has the capability to remove the assumed heat load.trn°nthsGRAND GULF 3.7-11 Amendment No.+/-r&,

Attachment 2 GNRO-2012/00096 Page 56 of 68 SURVEILLANCE REQUIREMENTS (continued)

AC Sources-Operating

3.8.1 SURVEI

LLANCE FREQUENCY SR 3.8.1.8 SR 3.8.1.9-----------------

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

--This Surveillance shall not be performed in MODE 1 and 2.However.credit may be taken for unplanned events that satisfy this SR.Verify manual transfer of unit power supply from the normal offsite circuit to required alternate offsite circuit.-----------------NOTES---------------------

1.Credit may be taken for unplanned events that satisfy this SR.Jmonths 2.If performed with the DG synchronized with offs ite power, it sha 11 be performed at a power factor0.9 for DG 11 and DG 13 and0.89 for DG 12.However.if grid conditions do not permit.the power factor limit is not required to be met.Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG rejects a load greater than or equal to its associated single largest post accident load and engine speed is maintained less than nominal plus 75%of the difference between nominal speed and the overspeed setpoint or 15%above nominal.whichever is lower.months (continued)

GRAND GULF 3.8-7 Amendment No.

Attachment 2 GNRO-2012/00096 Page 57 of 68 SURVEILLANCE REQUIREMENTS (continued)

AC Sources-Operating

3.8.1 SURVEI

LLANCE FREQUENCY SR 3.8.1.10-------------------NOTE--------------------

1.Credit may be taken for unplanned events that satisfy this SR.2.I f performed wi th the DG synchroni zed with offsite power, it shall be performed at a power factor0.9 for DG 11 and DG 130.89 for DG 12.However, if grid conditions do not permit, the power factor limit is not required to be met.Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG does not trip and voltage is maintained5000 V during and following a load rejection of a load5450 kW and5740 kW for DG 11 and DG 12 and3300 kW for DG 13..J months (continued)

GRAND GULF 3.8-8 Amendment No.

Attachment 2 GNRO-2012/00096 Page 58 of 68 AC Sources-Operat i ng 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEI LLANCE FREQUENCY SR 3.8.1.11-------------------

NOTES-------------------

1.All DG starts may be preceded by an engine prelube period.2.This Surveillance shall not be performed in MODE 1, 2, or 3 (Not Applicable to DG 13).However, credit may be taken for unplanned events that satisfy this SR.Verify on an actual or simulated loss of offsite power signal: a.De-energization of emergency buses;b.Load shedding from emergency buses for Divisions 1 and 2;and c.DG auto-starts from standby condition and: 1.energizes permanently connected loads in s 10 seconds, 2.energizes auto-connected shutdown loads, 3.maintains steady state voltage3744 V and S 4576 V, 4.maintains steady state frequency58.8 Hz and s 61.2 Hz, and 5.supplies permanently connected and auto-connected shutdown loads for5 minutes.-*months (continued)

GRAND GULF 3.8-9 Amendment No.

Attachment 2 GNRO-2012/00096 Page 59 of 68 AC Sources-Operat i ng 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.12 SURVEI LLANCE-------------

NOTES-------------------1.All DG sta rts may be preceded by an engine prelube period.2.This Surveillance shall not be performed in MODE l,or 2 (Not Applicable to DG 13).However, credit may be taken for unplanned events that satisfy this SR.Verify on an actual or simulated Emergency Core Cooling System (ECCS)initiation signal each DG auto-starts from standby condition and: a.In10 seconds after auto-start and during tests, achieve voltage 2 3744 V and frequency 2 58.8 Hz;b.Achieves steady state voltage 2 3744 V and4576 V and frequency 2 58.8 Hz and61.2 Hz;c.Operates for 2 5 minutes;and d.Emergency loads are auto-connected to the offsite power system.FREQUENCY l: t8 months (continued)

GRAND GULF 3.8-10 Amendment No.

Attachment 2 GNRO-2012/00096 Page 60 of 68 SURVEILLANCE REQUIREMENTS (continued)

AC Sources-Operating

3.8.1 SURVEI

LLANCE FREQUENCY SR 3.8.1.13------------------

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

Credit may be taken for unplanned events that satisfy this SR.Verify each DG's non-critical automatic trips are bypassed on an actual or simulated ECCS initiation signal.r+&months (continued)

GRAND GULF 3.8-11 Amendment No.

Attachment 2 GNRO-2012/00096 Page 61 of 68 SURVEILLANCE REQUIREMENTS (continued)

AC Sources-Operating

3.8.1 SURVEILLANCE

FREQUENCY SR 3.8.1.14..------.--.-------NOTES-------------------1.Momentary transients outside the load and power factor ranges do not invalidate this test.2.Credit may be taken for unplanned events that satisfy this SR.3.If performed with the DG synchronized with offsite power, it shall be performed at a power factor0.9 for DG 11 and DG 13 and0.89 for DG 12.However, if grid conditions do not permit, the power factor limit is not required to be met.Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG operates for24 hours: a.For DG 11 and DG 12 loaded5450 kW and5740 kW;and b.For DG 13: 1.For2 hours loaded3630 kW, and 2.For the remalnlng hours of the test loaded3300 kW.months (continued)

GRAND GULF 3.8-12 Amendment No.+/-&4, Attachment 2 GNRO-2012/00096 Page 62 of 68 SURVEILLANCE REQUIREMENTS (continued)

AC Sources-Operati ng 3.8.1 SURVEILLANCE FREQUENCY SR 3.8.1.15------------------NOTES-------------------1.This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated z 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or until operating temperatures stabilized loaded z 5450 kW and5740 kW for DG 11 and DG 12, and 2 3300 kW for DG 13.Momentary transients outside of the load range do not invalidate this test.2.All DG starts may be preceded by an engine prelube period.Verify each DG starts and achieves: a.in10 seconds, voltage 2 3744 V and frequency z 58.8 Hz;and b.steady state voltage 2 3744 V and4576 V and frequency 2 58.8 Hz and61.2 Hz.lk months (continued)

GRAND GULF 3.8-13 Amendment No.

Attachment 2 GNRO-2012/00096 Page 63 of 68 AC Sources-Operat i ng 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.16 SURVEILLANCE

NOT E--------------------This Surveillance shall not be performed in MODE 1.2, or 3 (Not Applicable to DG 13).However, credit may be taken for unplanned events that satisfy this SR.Verify each DG: a.Synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power;b.Transfers loads to offsite power source;and c.Returns to ready-to-load operation.

FREQUENCY r T&months (continued)

GRAND GULF 3.8-13a Amendment No.155 Attachment 2 GNRO-2012/00096 Page 64 of 68 SURVEILLANCE REQUIREMENTS (continued)

AC Sources-Operating

3.8.1 SURVEILLANCE

FREQUENCY SR 3.8.1.17 SR 3.8.1.18-------------------

NOTE--------------------Credit may be taken for unplanned events that satisfy this SR.Verify, with a DG operating in test mode and connected to its bus, an actual or simulated ECCS initiation signal overrides the test mode by: a.Returning DG to ready-to-load operation; and b.Automatically energizing the emergency loads from offsite power.-----------

NOTE--------------------This Surveillance shall not be performed in MODE 1, 2, or 3.However, credit may be taken for unplanned events that satisfy this SR.Verify interval between each sequenced load block is within+/-10%of design interval for each automatic load sequencer.

t monthsi.months (continued)

GRAND GULF 3.8-14 Amendment No.153 Attachment 2 GNRO-2012/00096 Page 65 of 68 AC Sources-Operat i ng 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

Verify, on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ECCS initiation signal: SR 3.8.1.19 SURVEI LLANCE-------------------NOTES-------------------1.All DG sta rts may be preceded by an engine prelube period.2.This Surveillance shall not be performed in MODE 1, 2, or 3 (Not Applicable to DG 13).However, credit may be taken for unplanned events that satisfy this SR.a.De-energization of emergency buses;b.Load shedding from emergency buses for Divisions 1 and 2;and c.DG auto-starts from standby condition and: 1.energizes permanently connected loads in10 seconds, 2.energizes auto-connected emergency loads, 3.achieves steady state voltage 2 3744 V and4576 V, 4.achieves steady state frequency58.8 Hz and61.2 Hz, and 5.supplies permanently connected and auto-connected emergency loads for5 minutes.FREQUENCY 1 f&months GRANO GULF 3.8-15 Amendment No.

Attachment 2 GNRO-2012/00096 Page 66 of 68 SURVEILLANCE REQUIREMENTS (continued)

DC Sources-Operati ng 3.8.4 SURVEILLANCE FREQUENCY SR 3.8.4.3 SR 3.8.4.4 SR 3.8.4.5 SR 3.8.4.6 Verify battery cells, cell plates, and racks show no visual indication of physical damage or abnormal deterioration that could degrade battery performance.

Remove visible corrosion and verify battery cell to cell and terminal connections are coated with anti-corrosion material.Verify battery connection resistance is$1.5 E-4 ohm for inter-cell connections,$1.5 E-4 ohm for inter-rack connections,$1.5 E-4 ohm for inter-tier connections, and$1.5 E-4 ohm for terminal connections.

Verify each Division 1 and 2 required battery charger supplies400 amps at125 V for10 hours;and the Division 3 battery charger supplies50 amps at L 125 V for4 hours.1 monthst months rmmonths (continued)

GRAND GULF 3.8-28 Amendment No.+rB, 142 Attachment 2 GNRO-2012/00096 Page 67 of 68 DC Sources-Operating

3.8.4 SURVEILLANCE

REQUIREMENTS (continued)

SR 3.8.4.7 SURVEILLANCE-------------------

NOTES-----------------

--1.SR 3.8.4.8 may be performed in lieu of SR 3.8.4.7 once per 60 months.2.This Surveillance shall not be performed in MODE 1, 2, or 3 (not applicable to Division 3).However, credit may be taken for unplanned events that satisfy this SR.Verify battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test.FREQUENCYmonths (continued)

GRAND GULF 3.8-29 Amendment No.

Attachment 2 GNRO-2012/00096 Page 68 of 68 Programs and Manuals 5.5 5.5 Programs and Manuals (continued)

5.5.7 Ventilation

Filter Testing Program (VFTP)A program shall be established to implement the following required testing of Engineered Safety Feature (ESF)filter ventilation systems at the frequencies specified in Regulatory Guide 1.52, Revision 2..Flowrate ESF Ventilation System for each of the ESF systems that an inplace test efficiency particulate air (HEPA)filters shows a penetration and system bypass<0.05%when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1975 at the system flowrate specified below+/-10%: , except thata.testing specified at a frequency of 18 months is required at a frequency of 24 months.SGTS CRFA 4000 cfm 4000 cfm b.Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass<0.05%when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1975 at the system flowrate specified below+/-10%: ESF Ventilation System Flowrate SGTS 4000 cfm c.Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM 03803-1989 at a temperature of 30°C and the relative humidity specified below: ESF Ventilation System SGTS Penetration 0.5%RH 70%(continued)

GRAND GULF 5.0-12 Amendment No.+44,145 Attachment 3 GNRO-2012/00096 Proposed Technical Specification Bases Changes (Mark-up)

Attachment 3 GNRO-2012/00096 Page 1 of 72 List of affected Technical Specifications Bases pages: B 3.1-43 B 3.6-13 B 3.1-49 B 3.6-25 B 3.6-35 B 3.6-39 B 3.3-26 B 3.6-40 B 3.3-27a B 3.6-46 B 3.3-28 B 3.6-47 B 3.3-29a B 3.6-65 B 3.3-38 B 3.6-76 B 3.3-47 B 3.6-82 B 3.3-60 B 3.6-87a B 3.3-66 B 3.6-94 B 3.3-75 B 3.6-95 B 3.3-76 B 3.6-101 B 3.3-86 B 3.6-119 B 3.3-123 B 3.6-130 B3.3-135 B 3.3-169 B 3.7-7 B3.3-170 B 3.7-10 B 3.3-170a B 3.7-16a B 3.3-182 B 3.7-21 B3.3-183 B 3.3-194 B 3.8-18 B 3.3-207 B 3.8-18a B 3.3-213 B 3.8-20 B 3.3-217 B 3.8-22 B 3.3-231 B 3.8-23 B 3.3-237 B 3.8-24 B 3.3-238 B 3.8-25a B 3.8-27 B 3.8-28 B 3.4-11 B 3.8-30 B 3.4-12 B 3.8-30a B 3.4-20 B 3.8-31 B 3.4-37 B 3.8-56a B 3.8-57 B 3.5-11 B 3.8-58 B 3.5-12 B 3.5-14 B 3.5-25 B 3.5-26 Attachment 3 GNRO-2012/00096 Page 2 of 72 SLC System B 3.1.7 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.1.7.7 Demonstrating each SLC System pump develops a flow rate 3 41.2 gpm at a discharge pressure1340 psig without actuating the pump's relief valve ensures that pump performance has not degraded during the fuel cycle.This minimum pump flow rate requirement ensures that, when combined with the sodium pentaborate solution concentration requirements, the rate of negative reactivity insertion from the SLC System will adequately compensate for the positive reactivity effects encountered during power reduction, cooldown of the moderator, and xenon decay.This test confirms one point on the pump design curve, and is indicative of overall performance.

Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance.

The Frequency of this Surveillance is in accordance with the Inservice Testing Program.SR 3.1.7.8 This Surveillance ensures that there is a functioning flow path from the boron solution storage tank to the RPV, including the firing of an explosive valve.The replacement charge for the explosive valve shall be from the same manufactured batch as the one fired or from another batch that has been certified by having one of that batch successfully fired.Other administrative controls, such as those that limit the shelf life of the explosive charges, must be followed.The pump and explosive valve tested such that both flow paths are at alternatingonth lntervals.

The Surveillance may be performed in separate steps to prevent injecting boron into the RPV.An acceptable method for verifying flow from the pump to the RPV is to pump demineralized water from a test tap'" till oogll olle 5LCsubsystem and into the RPV.The f&month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown these components usually pass the Surveillance test when performed at the month Frequency; therefore, the Frequency was concluded to e acce table from a reliability standpoint.

24 (continyed)

GRAND GULF B 3.1-43 LBBER 19936 Attachment 3 GNRO-2012/00096 Page 3 of 72 BASES SURVEILLANCE REQUIREMENTS SDV Vent and Drain Valves B 3.1.8 SR 3.1.8.3 (continued) reset signal, the opening of the SDV vent and drain valves is verified.The LOGIC SYSTEM FUNCTIONAL TEST in LCD 3.3.1.1 and the scram time testing of control rods in LCD 3.1.3,"Control Rod OPERABILITY," overlap this Surveillance to provide complete testing of the assumed 58 Fe ty FaneL i oli.Tti\9iB-month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown these usually pass the Surveillance when performed at th B-month Frequency; therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1.UFSAR, Section 4.6.1.1.2.4.2.6.

2.10 CFR 50.67,"Accident Source Terms." 3.NUREG-0803,"Generic Safety Evaluation Report Regarding Integrity of BWR Scram System Piping," August 1981.GRAND GULF B 3.1-49-l Be-0-Hr5&-

Attachment 3 GNRO-2012/00096 Page 4 of 72 BASES SURVEILLANCE REQUIREMENTS (continued)

RPS Instrumentation B 3.3.1.1 SR 3.3.1.1.7 LPRM gain settings are determined from the Core power distribution calculated by the Core Performance Monitoring system based on the local flux profiles measured by the Traversing Incore Probe (TIP)System.This establishes the relative local flux profile for appropriate representative input to the APRM System.The 2000 MWO/T (megawatt days/ton)Frequency is based on operating experience with LPRM sensitivity changes.For the purpose of calculating this surveillance frequency, the ton (T)unit of weight is expressed in terms of metric tons of uranium fuel residing in the reactor core.SR 3,3.1.1.8 and SR 3,3,1.1,11 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.

The 92 day Frequency of SR 3.3,1.1.8 is based on the reliability analysis of Reference 9.month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown that these components usually pass the Surveillance when performed month Frequency.

24 (continued)

GRAND GULF B 3.3-26 LDC 07045 Attachment 3 GN RO-20 12/00096Page5 of 72 BASES SURVEILLANCE REQUIREMENTS RPS Instrumentation B 3.3.1.1 SR 3.3.1.1.10.

SR 3.3.1.1.12 and SR 3.3.1.1.17 (continued)

Note 3 to SR 3.3.1.1.10 states that the APRM recirculation flow transmitters are excluded from CHANNEL CALIBRATION of Function 2.d, Average Power Range Monitor Flow Biased Simulated Thermal Power-High.Calibration of the flow transmitters is performed on an lS-month frequency (SR 3.3.1.1.17).SR 3.3.1.1.10 for thedesignatedfunction is modified by two notes identified in Table 3.3.1.1-1.

The first note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value.Evaluating channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology.

The purpose of the assessment is to ensure confidence in channel performance prior to returning the channel to service.Performance of these channels will be evaluated under the Corrective Action Program.Entry into the Corrective Action Program ensures required review and documentation of the condition to establish a reasonable expectation for continued OPERABILITY.

The second note requires that the as-left setting for the channel be within the as-left tolerance of the Nominal Trip Setpoint (NTSP).Where a setpoint more conservative than the NTSP issued in the plant surveillance procedures, theleft and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint.This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained.

If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NSP, then the channel shall be declared inoperable.

The second note also requires the NTSP and the methodologies for calculating the as-left and the as-found tolerances to be in the Technical Requirements ManualThe Frequency of fa months for SR 3.3.1.1.12 and SR 3.3.1.1.17 is based upon the assumption of the magnitude of equipment drift in the setpoint analysis.(continued)

GRAND GULF B 3.3-27a LBDER 1ea27 Attachment 3 GNRO-2012/00096 Page 6 of 72 RPS Instrumentation B 3.3.1.1 BASES 3.3.1.1.13 SR The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel.The functional testing of control rods, in LCD 3.1.3,"Control Rod OPERABILITY," and SDV vent and drain valves, in LCO 3.1.8,"Scram Discharge Volume (SDV)Vent and Drain Valves," overlaps this Surveillance to provide testing of the assumed safety function.-----Themonth Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown that these components usually pass the Surveillance when the month Frequency.

24 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.1.14 This SR ensures that scrams initiated from the Turbine Stop Valve Closure, Trip Oil Pressure-Low and Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Functions will not be inadvertently bypassed when THERMAL POWER is 2 35.4%RTP.This involves calibration of the bypass channels.Adequate margins for the instrument setpoint methodology are incorporated into the actual setpoint.Because main turbine bypass flow can affect this setpoint nonconservatively (THERMAL POWER is derived from turbine first stage pressure), the main turbine bypass valves must remain closed at THERMAL POWER35.4%RTP to ensure that the calibration remains valid.If any bypass channel setpoint is nonconservative (i.e., the Functions are bypassed at35.4%RTP, either due to open main turbine bypass va1ve(s)or other reasons), then the affected Turbine Stop Valve, Trip Oil Pressure-Low and Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Functions are considered inoperable.

Alternatively, the bypass channel can be placed in the conservative condition (nonbypass).

If placed in the nonbypass condition, this SR is met and the channel is considered OPERABLE.The Frequencymonths is based on engineering judgment and reliability of the components.(continued)

GRAND GULF B 3.3-28 LBDER 12035 Attachment 3 GNRO-2012/00096 Page 7 of 72 BASES SURVEI L LANCE REQUIREMENTS RPS Instrumentation B 3.3.1.1 SR 3.3.1.1.15 (continued)

RPS RESPONSE TIME tests are conducted on an 18 month STAGGERED TEST BASIS.Note 3 requires STAGGERED TEST BASIS Frequency to be determined based on 4 channels per trip system, in lieu of the 8 channels specified in Table 3.3.1.1-1 for the MSIV Closure Function.This Frequency is based on the logic interrelationships of the various channels required to produce an RPS scram si nal.Therefore, staggered testing result in response time verification of these devices every months.This Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience, which shows that random failures of instrumentation components causing serious time degradation, but not channel failure, are infrequent.

SR 3.3.1.1.16 and SR 3,3.1.1.18 Deleted (continued)

GRAND GULF B 3.3-29a LeBER 19927 Attachment 3 GNRO-2012/00096 Page 8 of 72 BASES SURVEILLANCE REQUIREMENTS SRM Instrumentation B 3.3.1.2, SR 3.3.1.2.5 (continued)

The Nate to the Surveillance allows the Surveillance to be delayed until entry into the specified condition of the The SR must be performed in MODE 2 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of entering MODE 2 with lAMs on Range 2 or below.The allowance to enter the Applicability with the 31 day Frequency not met is reasonable, based on the limited time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed after entering the Applicability and the inability to the Surveillance while at higher power levels.Although the Surveillance could be performed while on IRM Range 3, the plant would nat be expected to maintain steady state operation at this power level.In this event, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency 1s reasonable, based on the SRMs*being otherwise verified to be OPERABLE (i.e., satisfactorily the CHANNEL CHECK)and the time required to the Surveillances.

SR 3.3.1.2.6 Performance of a CHANNEL CALIBRATION verifies the perfonlance of the SAM detectors and associated circuitry.

The Frequency considers the plant reqUired to the test, the ease of perfonling the test, and the likelihood of a change in the syst..or component status.The neutron detectors are excluded fro.the CHANNEL CALIBRATION because they cannot readily be adjusted.The detectors are fission charlbers that are designid to have a relatively constant sensitivity aver the range, Ind with In accuracy specified for a fixed useful life.The Note to the Surveillance allows the Surveillance to be delayed until entry into the specified condition of the Applicability.

The SR must be performed in MODE 2 within 24 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of entering MODE 2 with lAMs on Range 2 or elow.The allowance to enter the Applicability with the n Frequency nat met is reasonable, based on the limited time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed after entering the Applicability and the inability to perform the Surveillance while at higher power levels.Although the Surveillance could be performed while on IRK Range 3, the plant would not be expected to maintain steady state operation at this power level.In this event, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is reasonable, based on the SRMs being (continued)

GRAND GULF B 3.3-38 Revision No.0 Attachment 3 GNRO-2012/00096 Page 9 of 72 Control Rod Block Instrumentation B 3.3.2.1 BASES SURVEILLANCE REQUIREMENTS SR 3.3.2.1.6 (continued) in the nonbypassed condition, the SR is met and the RWL would not be considered inoperable.

Because main turbine bypass steam flow can affect the HPSP nonconservatively for the RWL, the RWL is considered inoperable with any main turbine bypass valve open.The Frequency of 92 days is based on the setpoint methodology utilized for these channels.SR 3.3*2.1.7 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor.This test verifies that the channel responds to the measured parameterwithinthe necessary range and accuracy.CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Frequency is based upon the assumption of the magnitude of equipment drift in the setpoint analysis.SR3.3.2*1.8 The CHANNEL FUNCTIONAL TEST for the Reactor ModeShutdown Position Function is performed by attempting to withdraw any control rod with the reactor mode switch in the shutdown position and verifying a control rod black occurs.As noted in the SR, the Surveillance is nat required to be perforled until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the reactor mode switch is in the shutdown position, since testing of this interlock with the reactor mode switch in any ather position cannot be performed without using jumpers, lifted leads, or movable limits.This allows entry into MODES 3 and 4 if themonth Frequency is not met per SR 3.0.2.

Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown these components usually pass the Surveillance when performed at the 18 month Frequency.(continued)

GRAND GULF B 3.3-47 Revision No.0 Attachment 3 GNRO-2012/00096 Page 10 of 72 BASES SURVEILLANCE REQUIREMENTS PAM Instrumentation B 3.3.3.1 SR 3.3.3.1.1 (continued)

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including isolation, indication, and readability.

If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.The Frequency of 31 days is based upon plant operating experience with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given function in any 31 day interval is rare.The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of those displays associated with the required channels of this LCO.SR 3.3.3.1.2 Deleted SR 3.3.3.1.3 all Functions a CHANNEL CALIBRATION is performed everymonths, or approximately at every refueling.

CHANNEL CALIBRATION is a complete check of the instrument loop including the sensor.The test verifies that the channel responds to the measured parameter with the necessary range and accuracy.The Frequency is based on operating experience and consistency with the typical industry refueling cycles.For Functions 12 and 13 the CHANNEL CALIBRATION consists of an electronic calibration of the channel, not including the detector, for range decades above 10R/hr and a one point calibration check of the detector below 10R/hr with an installed or portable gamma source.The neutron detectors are excluded from the CHANNEL CALIBRATION because they cannot readily be adjusted.The detectors are fission (continued)

GRAND GULF B 3.3-60 LDC 03102 Attachment 3 GNRO-2012/00096 Page 11 of 72 Remote Shutdown System B 3.3.3.2 BASES SURVEILLANCE REQUIREMENTS SR 3.3.3.2.1 (continued)

The Frequency is based upon plant operating experience that demonstrates channel failure is rare.SR 3.3.3.2.2 SR 3.3.3.2.2 verifies each required Remote Shutdown System transfer switch and control circuit performs the intended function.This verification is performed from the reMOte shutdown panel and locally, as appropriate.

Operation of the equipment from the remote shutdown panel is not necessary.

The Surveillance can be satisfied by performance of a continuity check.This will ensure that if the control rOQl becomes inaccessible, the plant can be placed and maintained in MODE 3 from the re.ote shutdown panel and the local control stattons.However, this Surveillance ts not required to be performed only during a plant outage.Operating experience demonstrates that Remote Shutdown System control channels usually pass the Surveillance when performed at the month Frequency.

SR 3.3.3.2.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor.The test verifies the channel responds to measured parameter values with the necessary range and 1 24Th.anth Frequency is based upon operating experience and is consistent with the typtca1 industry refueling cycle.REFERENCES GRANO GULF 1.10 CFR SO, Appendix A, GDC 19.B 3.3-66 Revision No.0 Attachment 3 GNRO-2012/00096 Page 12 of 72 BASES SURVEILLANCE REQUIREMENTS (continued)

EOC-RPT Instrumentation B 3.3.4.1 SR 3.3.4.1.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel.The system functional test of the pump breakers is included as a part of this test, overlapping the LOGIC SYSTEM FUNCTIONAL TEST, to provide complete testing of the associated safety function.Therefore, if a breaker is incapable of operating, the associated instrument channel would also be inoperable.

Themonth Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown these components usually pass the Surveillance test when performed at the Frequency.

24 SR 3.3.4.1.5 This SR ensures that an EOC-RPT initiated from the TSV Closure, Trip Oil Pressure-Low and TCV Fast Closure, Trip Oil Pressure-Low Functions will not be inadvertently bypassed when THERMAL POWER is?35.4%RTP.This involves calibration of the bypass channels.Adequate margins for the instrument setpoint methodologies are incorporated into the actual setpoint.Because main turbine bypass flow can affect this setpoint nonconservatively (THERMAL POWER is derived from first stage pressure), the main turbine bypass valves must remain closed at THERMAL POWER z 35.4%RTP to ensure that the calibration remains valid.If any bypass channel's setpoint is nonconservative (i.e., the Functions are bypassed at z 35.4%RTP either due to open main turbine bypass valves or other reasons), the affected TSV Closure, Trip Oil Pressure-Low and TCV Fast Closure, Trip Oil Pressure-Low Functions are considered inoperable.

Alternatively, the bypass channel can be placed in the conservative condition (nonbypass).

If placed in the nonbypass condition, this SR is met and the channel conside RABLE.24 The Frequency of months has shown that channel bypass failures between successive tests are rare.(continyed)

GRAND GULF B 3.3-75 LBDER 12935 Attachment 3 GNRO-2012/00096 Page 13 of 72 EOC-RPT Instrumentation B 3.3.4.1 BASES SR 3.3.4.1.6 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.The EOC-RPT SYSTEM RESPONSE TIME acceptance criteria are included in the applicable plant procedures.

A Note to the Surveillance states that breaker interruption time may be assumed from the most recent performance of SR 3.3.4.1.7.

This is allowed since the time to open the contacts after energization of the trip coil and the arc suppression time are short and do not appreciably change, due to the design of the breaker opening device and the fact that the breaker is not routinely cycled.

SYSTEM RESPONSE TIME tests are conducted on anmonth STAGGERED TEST BASIS.Each test includes two turbine control valve channels from one trip system and two turbine stop valve channels from the other trip system.Response times cannot be determined at power because operation of final actuated devices is required.Therefore, this Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience, which shows that random failures of instrumentation components that cause serious response time degradation, but not channel faiTure, are infrequent occurrences.

SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.4.1.7 This SR ensures that the RPT breaker interruption time is provided to the EOC-RPT SYSTEM RESPONSE TIME test.Breaker Interruption time is defined*as Breaker Response time plus Arc Suppression time.Breaker Response is the time from application of voltage to the trip coil until the main contacts separate.Arc Suppression is the time from main contact separation until the complete suppression of the electrical arc across the open contacts.Breaker Response shall be verified by testing and added to the manufacturer's design Arc Suppression time of 12 ms to determine Breaker Interruption time.The breaker arc suppression time shall be validated by the performance of periodic contact gap (continued)

GRAND GULF B 3.3-76 Revision No.0 Attachment 3 GNRO-2012/00096 Page 14 of 72 ATWS-RPT Instrumentation B 3.3.4.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.4.2.4 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor.This test verifies that the channel responds to the measured parameter within the necessary range and accuracy.CHANNEL CALIBRATIONleavesthe channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Frequency is based upon the assumption of the magnitude of equipment drift in the setpoint analysis.SR 3.3.4.2.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel.The system functional test of the pump breakers, included as part of this Surveillance, overlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide complete testing of the assumed safety function.Therefore, if a breaker is incapable of operating, the associated instrument channel(s) be inoperable.month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power..Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency.

REFERENCES 1.UFSAR, Section 5.4.1.7.10.

2.NEOE-770-06-1,"Bases For Changes To Surveillance Test Intervals and Allowed Out-of-Service Times For Selected Instrumentation Technical Specifications," February 1991.GRAND GULF B 3.3-86 Revision No.0 Attachment 3 GNRO-2012/00096 Page 15 of 72 ECCS Instrumentation B 3.3.5.1 BASES S83.3.5.1.6 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel.The system functional testing performed in LCO 3.5.1, LCO 3.5.2, LCO 3.8.1, and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety function.

,month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage (except for Division III which can be tested in any operational condition) and the potential for unplanned transients if the Surveillance were performed with the reactor at power.Operating experience has shown these components usually pass the Surveillance when performed at____month Frequency.

SURVEILLANCE REQUIREMENTS (continued)

REFERENCES 1.UFSAR, Section 5.2.2.UFSAR, Section 6.3.3.UFSAR, Chapter 15.4.NEDC-30936-P-A,"BWR Owners'Group Technical Specification Improvement Analyses for ECCS Actuation Instrull1entation.

Part 2, t.December 1988.5.Regulatory Guide 1.105 t'*Setpoi nts for Safety-Rel ated Instrumentation." Revision 3.GRAND GULF B 3.3-123 LeBER 11847 Attachment 3 GNRO-2012/00096 Page 16 of 72 BASES RCIC System Instrumentation 8 3.3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.5.2.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel.The system functional testing performed in LCO 3.5.3 overlaps this Surveillance to provide complete testing of the safety function.1241--

Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown that these components usually pass the Surveillance when performed at the Frequency.REFERENCES 1.NEDE-770-06-2,"Addendum to Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Sped fi cati ons," February 1991.2.Regulatory Guide 1.105,"Setpoints for Safety-Related Instrumentation," Revision 3.GRAND GULF B 3.3-135 LBDeR 11047 Attachment 3 GNRO-2012/00096 Page 17 of 72 BASES SURVEILLANCE REQUIREMENTS (continued)

Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 SR3.3.6.1.2 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.

The Frequency is based on reliability analysis described in References 5 and 6.SR3.3.6.1.3 The calibration of trip units consists of a test to provide a check of the actual trip setpoints.

The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.1-1.

For Function 1.c, Main Steam Line FlowHigh, there is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found settings are consistent with those established by the setpoint methodology.

If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis.Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Frequency of 92 days is based on the reliability analysis of References 5 and 6.SR 3.3.6.1.4.

SR 3.3.6.1.5.

and SR CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor.This test verifies the channel responds to the measured parameter within the necessary range and accuracy.CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Frequency of SR 3.3.6.1.4, SR 3.3.6.1.5, and SR is based on the assumption of the magnitude of equipment drift in the setpoint analysis.(continued)

GRAND GULF B 3.3-169 LBDCR 12035 Attachment 3 GN RO-20 12/00096 Page 18 of 72 Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 BASES 16 and SR 3.3.6.1.81 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel.The system functional testing performed on jsolation valves in LCO 3.6.1.3 and LCO 3.6.5.3 overlaps..to rovide complete testing of the assumed safety function.month based on the need to perform this Surveillance under the conditions apply during a plant outage and the potential for an unplanned transient if'.the reactor at power The 18 month Frequency for SR 3.3.6.1.6 is based on the current frequency for performinq this Surveillance.

Operating experience has sown t ese components usua y pass the Surveillance when performed at theFrequency.

SR 3.3.6.1.8SR 3.3.6.1.'1'(SURVEILLANCE REQUIREMENTS (continued)

This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.Testing is performed only on channels where the assumed response time does not correspond to the diesel generator (DG)start time.For channels assumed to respond within the OG start time, sufficient margin exists in the 10 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific measurement test.Testing of the closure times of the MSIVs is not included in this Surveillance since the closure time of the MSIVs is tested by SR 3.6.1.3.6.

ISOLATION SYSTEM RESPONSE TIME acceptance criteria for this instrumentation is included in the applicable plant procedures.

As Noted, the channel sensor may be excluded from response time testing.This allowance to not perform specific response time testing of the sensors is applicable when the alternate testing requirements and restrictions of Reference 7 are performed.

As stated in Reference 7, analysis has demonstrated that other Technical Specification testing requirements (CHANNEL CALIBRATIONS, CHANNEL CHECKS, CHANNEL FUNCTIONAL TESTS, and LOGIC SYSTEM FUNCTIONAL TESTS)and actions taken in response to NRC Bulletin 90-01 Supplement 1 are sufficient to identify failure modes or degradation in (continued)

GRAND GULF B 3.3-170 LOC 97078 instrument response times and assure operation of the analyzed instrument loops within acceptable limits.Reference 7 also identifies that there are no known channel sensor failure modes identified that can be detected by response time testing that cannot also be detected by other Technical Specification required surveillances.

Therefore, when the requirements, including sensor types, of Reference 7 are complied with, adequate assurance of the response time of the sensors is provided.This assurance of the response time of the sensors when combined with the response time testing of the remainder of the channel ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.The calibration shall be performed such that fast ramp or step change to system components during calibrations is performed to verify that the response of the transmitter to the input change is prompt.Technicians shall monitor for response time degradation during the performance of calibrations.

Technicians shall be appropriately trained to ensure they are aware of the consequences of instrument response time degradation.

These items are commitments made per Reference B.If the alternate testing requirements of Reference 7 are not complied with then the entire channel will be response time tested including the sensors.ISOLATION SYSTEM RESPONSE TIME tests 24 instrumentation are conducted on an month STAGGERED TEST BASIS.This test Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience that shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent.

Analysis has shown that with the upper containment pool cavity flooded and the gates removed, adequate time exists to allow operator action necessary to terminate the inventory loss prior to reaching reactor level 3.This analysis takes credit for the pool level being greater than or equal to 22 feet 8 inches above the reactor vessel flange.Verifying the upper containment pool level is greater than or equal to 22 feet 8 inches on a four hour frequency provides assurance that the operators have enough time to detect and terminate a drain down event.Attachment 3 GNRO-2012/00096 Page 19 of 72 BASES SURVEI LLANCE REQUIREMENTS SR Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 3030601£(continued)(continued)

I GRAND GULF B 3.3-170a LDC 03039 Attachment 3 GNRO-2012/00096 Page 20 of 72 BASES SURVEILLANCE REQUIREMENTS (continued)

Secondary Containment Isolation Instrumentation B 3.3.6.2 SR 3.3.6.2.3 Calibration of trip units prOVides a check of the actual trip setpoints.

The channel must be declared inoperable if the trip setting 1s discovered to be less conservative than the Allowable Value specified in Table 3.3.6.2-1.

If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, performance is still within the requirements of the plant safety analysis.Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Frequency of days is based on the reliability analysis of References 3 and 4.SR 3.3.6.2.4 and SR 3.3.6.2.5 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor.This test verifies the channel responds to the measured parameter within the necessary range and accuracy.CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Frequency of SR 3.3.6.2.4 and SR 3.3.6.2.5 is based upon the assumption of the magnitude of equipment drift in the setpoint analysis.SR 3.3.6.2.6 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel.The system functional testing, performed on SCIVs and the SGT System in LCO 3.6.4.2 and LCO 3.6.4.3, respectively, overlaps this Surveillance to provide complete of the assumed safety functton.month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the (continued)

GRAND GULF B 3.3-182 Revision No.0 Attachment 3 GNRO-2012/00096 Page 21 of 72 BASES Secondary Containment Isolation Instrumentation B 3.3.6.2 SURVEILLANCE REQUIREMENTS SR 3.3.6.2.6 (continued)

Surveillance were performed with the reactor at Operating experience has shown these components the Survei 11 ance when performed at the f monthSR 3.3.6.2.7 power.usually pass Frequency.

This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.Testing is performed only on channels where the assumed response time does not correspond to the diesel generator (DG)start time.For channels assumed to respond within the DG start time, sufficient margin exists in the 10 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific measurement test.Testing of the closure times of the isolation dampers is not included in this Surveillance since the closure time of the isolation dampers is tested by SR 3.6.4.2.2.

ISOLATION SYSTEM RESPONSE TIME acceptance criteria for this instrumentation is included in the applicable plant procedures.

A Note to the Surveillance states that the radiation detectors may be excluded from ISOLATION SYSTEM RESPONSE TIME testing.This Note is necessary because of the difficulty of generating an appropriate detector input signal and because the principles of detector operation virtually ensure an instantaneous response time.Response time for radiation detector channels shall be measured from detector output or the input of the first electronic component in the channel.ISOLATION SYSTEM RESPONSE TIME tests are conducted on anmonth STAGGERED TEST BASIS.This Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences.(continued)

GRAND GULF B 3.3-183 Revision No.0 SURVEILLANCE REQUIREMENTS Attachment 3 GNRO-2012/00096 Page 22 of 72 BASES RHR Containment Spray System Instrumentation B 3.3.6.3 SR 3.3.6.3.3 (continued) tr.ip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis.Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The.Frequency of 92 days is based upon the reliability analysis of Reference 3.SR 3.3.6.3.4 and SR 3.3.6.3.5 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor.This test**verifies that the channel responds to the measured par..eter within the necessary range and accuracy.CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Frequency of SR 3.3.6.3.4 and SR 3.3.6.3.5 is based on the assumption of the.agnitude of equipment drift in the setpoint analysis.SR 3.3.6.3.6 The LOGIC SYSTEM FUNCTIONAL TEST delOnstrates the'OPERABILITY of the required initiation logic for a specific channel.The syst..functional testing performed in lCO 3.6.1.7,-Residual Heat R8IOval (RHR)Containment Spray,-overlaps this Surveillance to prOVide complete of the assumed safety function.

Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were with the reactor at power.Operating experience has shown these components usually pass the Surveillance when performed atmonth Frequency.(continued)

GRAND GULF B 3.3-194 Revision No.1 Attachment 3 GNRO-2012/00096 Page 23 of 72 BASES SURVEILLANCE REQUIREMENTS (continued)

SPMU System Instrumentation B 3.3.6.4 SR 3.3.6.4.4 and SR 3.3.6.4.5 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor.This test verifies that the channel responds to the measured parameter within the necessary range and accuracy.CHANNEL CALIBRATION leaves the channel adjusted to account for instrUMent drifts'between successive calibrations consistent with the plant specific setpoint methodology.

The Frequency of SR 3.3.6.4.4 and SR 3.3.6.4.5 is based on the assumption of.the magnitUde of equipment drift in the setpoint analysis.SR 3.3.6.4.6 The LOGIC SYSTEM FUNCTIONAL TEST delOnstrates the OPERABILITY of the required initiation logic for a specific channel.The system functional testing performed in LCO 3.6.2.4,*Suppression Pool Makeup (SPMU)System,*overlaps this Surveillance to provide complete testing of the assu..d safety function.

Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown these components*usually pass the Surveillance when perfor.ed at the month Frequency.

REFERENCES 1.UFSAR, Section 7.3.1.1.9.

2.UFSAR, Section 6.2.7.3.3.GENE-770-06-1,*Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instru.entation Technical Specifications,*

February 1991.GRAND GULF B 3.3-207 Revision No.0 Attachment 3 GNRO-2012/00096 Page 24 of 72 BASES SURVEILLANCE REQUIREMENTS Relief and LLS Instrumentation B 3.3.6.5 SR 3.3.6.5.2 (continued) equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Frequency of 92 days is based on the reliability analysis of Reference 2.SR 3.3.6.5.3 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor.This test verifies the channel responds to the measured parameter within the necessary range and accuracy.CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Frequency is based upon the assumption of the magnitude of equipment drift in the setpoint analysis.SR 3.3.6.5.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel.The system functional testing performed for S/RVs in LCO 3.4.4 and LCO 3.6.1.6 overlaps this Surveillance to complete testing of the assumed safety function.month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown these components usually pass the Surveillance when performed at the onth Frequency.

REFERENCES 1.UFSAR, Section 5.2.2.2.GENE-770-06-1,"Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," February 1991.GRAND GULF B 3.3-213 Revision No.0 Attachment 3 GNRO-2012/00096 Page 25 of 72 BASES ACTIONS(continued)

CRFA System Instrumentation B 3.3.7.1 With the required action and completion time not met, the associated isolation dampers must be closed.This effectively establishes the isolation made of CRFA operation.

The 1-hour completion time is intended to allow the operator time to establish this mode of operation.

It is acceptable because it minimizes risk while allowing time to establish the CRFA subsystem in operation.

SURVE I LLANCE REQUIREMENTS The Surveillance is also modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, provided the associated Function maintains CRFA System initiation capability.

Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken.SR 3.3.7.1.1 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel.The system functional testing performed in LCO 3.7.3,"Control Room Fresh Air (CRFA)System," overlaps this Surveillance to provide complete testing of the assumed functi on.----month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown these components usually pass the Surveillance when performed at the B8 month Frequency.(continued)

GRAND GULF B 3.3-217 LDC 00070 Attachment 3 GNRO-2012/00096 Page 26 of 72 LOP Instrumentation B 3.3.8.1 BASES SR SURVEILLANCE REQUIREMENTS SR 3.3.8.1.1 (continued)

The Frequency of 31 days is based on plant operating experience with regard to channel OPERABILITY and drift that demonstrates that failure of more than one channel of a given Function in any 31 day interval is rare.SR SR 3.3.8.1.3 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor.This test verifies the channel responds to the measured parameter within the necessary range and accuracy.CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodo logy. these Surveillances I The Frequency is based on the assumption of the magnitude of equipment drift in the setpoint analysis., and the current Surveillance performance.

The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel.The system functional testing performed in LeO 3.8.1 and LeO 3.8.2 overlaps this Surveillance to complete testing of the assumed safety functions.month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown these components usually pass the Surveillance when performed at the month Frequency.

REFERENCES 1.UFSAR, Sect ion 8.3.1.2.UFSAR, Section 5.2.3.UFSAR, Section 6.3.4.UFSAR, Chapter 15.(continued)

GRAND GULF B 3.3-231 Loe 98003 Attachment 3 GNRO-2012/00096 Page 27 of 72 BASES ACTIONS SURVEI LLANCE REQUIREMENTS RPS Electric Power Monitoring B 3.3.8.2 0.1 (continued)

All actions must continue until the applicable Required Actions are completed.

SR 3.3.8.2.1 A CHANNEL FUNCTIONAL TEST is performed on each overvoltage.

undervoltage.

and underfrequency 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.

As noted in the Surveillance, the CHANNEL FUNCTIONAL TEST is only required to be performed while the plant is in a condition in which the loss of the RPS bus will not jeopardize steady state power operation (the design of the system is such that the power source must be removed from service to conduct the Surveillance).

The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is intended to indicate an outage of sufficient duration to allow for scheduling and proper performance of the Surveillance.

The 184 day Frequency and the Note in the Surveillance are based on guidance provided in Generic Letter 91-09 (Ref.2).SR 3.3.8.2.2 CHANNEL CALIBRATION is a complete check the instrument loop and the sensor.This test verifies that the channel responds to the measured parameter within the necessary range and accuracy.CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.The Frequency is based upon the assumption of an calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.(continued)

GRAND GULF B 3.3-237 Revision No.0 Attachment 3 GNRO-2012/00096 Page 28 of 72 RPS Electric Power Monitoring B 3.3.8.2 BASES 3.3.8.2.3 SR SURVEILLANCE REQUIREMENTS (continued)

Performance of a system functional test demonstrates a required system actuation (simulated or actual)signal.The discrete relays/logic of the system will automatically trip open the associated power monitoring assembly circuit breaker.Only one signal per power monitoring assembly is required to be tested.This Surveillance overlaps with the CHANNEL CALIBRATION to provide complete testing of the safety function.The system functional test of the Class 1E circuit breakers is included as part of this test to provide complete testing of the safety function.If the breakers are incapable of operating, the associated electric power assembly would be inoperable.month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown that these components usually pass the Surveillance when performed at the Frequency.

.--------------------------241------

REFERENCES 1.UFSAR, Section 8.3.1.1.5.

2.NRC Generic Letter 91-09,"Modification of Surveillance Interval for the Electric Protective Assemblies in Power Supplies for the Reactor Protection System." GRAND GULF B 3.3-238 LDC 97048 Attachment 3 GNRO-2012/00096 Page 29 of 72 BASES ACTIONS (continued)

SURVE I LLANCE REQUIREMENTS FCVs B 3.4.2 B.1 If the FCVs are not deactivated (locked up)and cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply.To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.This brings the unit to a condition where the flow coastdown characteristics of the recirculation loop are not important.

The allowed Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging unit systems.SR 3.4.2.1 Hydraulic power unit pilot operated isolation valves located between the servo valves and the common"open" and"close" lines are required to close in the event of a loss of hydraulic pressure.When closed, these valves inhibit FCV motion by blocking hydraulic pressure from the servo valve to the common open and close lines as well as to the alternate sub100p.This Surveillance verifies FCV lockup on a loss of pressure.I24"l-.-.month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown these components usually pass the SR when performed at the Frequency.

Therefore, the Frequency was concludedte acceptable from a reliability standpoint.

24 SR 3.4.2.2 This SR ensures the overall average rate of FCV movement at positions is maintained within the analyzed limits.24 Th month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the (continued)

GRAND GULF B 3.4-11 Revision No.0 Attachment 3 GNRO-2012/00096 Page 30 of 72 BASES SURVEILLANCE REQUIREMENTS REFERENCES FCVs B 3.4.2 SR 3.4.2.2 (continued)

Surveillance were performed with the reactor at power.Operating experience has shown these components usually pass the SR when performed at the Frequency.

Therefore, the Frequency was concludedte acceptable from a reliability standpoint.

24 1.UFSAR, Section 15.3.2.2.UFSAR, Section 15.4.5.-..'I GRAND GULF B 3.4-12 Revision No.0 Attachment 3 GNRO-2012/00096 Page 31 of 72 BASES SURVEILLANCE REQUIREMENTS S/RVs B 3.4.4 SR 3.4.4.1 (continued) lift settings must be performed during shutdown, since this is a bench test, and in accordance with the Inservice Testing Program.The lift setting pressure shall correspond to ambient conditions of the valves'at nominal operating temperatures and pressures.

The safety lift setpoints will still be set within a tolerance of+/-1 percent, but the setpoints will be tested to within+/-3 percent to determine acceptance or failure of the as-found valve lift setpoint.If a valve is tested and the lift setpoint is found outside the 3 percent tolerance, two additional valves are to be tested (Reference 4).The Frequency was selected because this Surveillance must be performed during shutdown conditions and is based on the time between refue1ings.

SR3.4.4.2 The reqUired relief function S/RVs are reqUired to actuate automatically upon receipt of specific initiation signals.A system functional test is performed to verify the mechanical portions of the automatic relief function operate as designed when initiated either by an actual or simulated initiation signal.The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.5.4 overlaps this SR to provide complete testing of function.

Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown these components usually pass the SR when performed at the imonth Frequency.

Therefore, the Frequency was concludedte acceptable from a reliability standpoint.

24 This SR is modified by a Note that excludes valve actuation.

This prevents an RPV pressure b1owdown.SR 3.4.4.3 A manual actuation of each required S/RV (those valves removed and replaced to satisfy SR 3.4.4.1)is performed to (continued)

GRAND GULF B 3.4-20 Revision No.2 Attachment 3 GNRO-2012/00096 Page 32 of 72 BASES SURVEILLANCE REQUIREMENTS (continued)

RCS Leakage Detection Instrumentation B 3.4.7 SR 3.4.7.3 This SR requires the performance of a CHANNEL CALIBRATION of the required RCS leakage detection instrumentation channels.The calibration verifies the accuracy of the instrumentation, including the instruments located inside the drywell.The Frequency of is a typicalrefueling cycle and considers chAnnel rellablllty.Operating experience has proven this Frequency is acceptable.

REFERENCES 1.10 CFR 50, Appendix A, GDC 30.2.Regulatory Guide 1.45, Revision 0,"Reactor Coolant Pressure Boundary Leakage Detection System." May 1973.3.GEAP-5620,"Failure Behavior in ASTM AI06B Pipes Containing Axial Through-Wall Flaws," April 1968.4.NUREG-75/067,"Investigation and Evaluation of Cracking in Austenitic Stainless Steel Piping of Boiling Water Reactor Plants," October 1975.5.UFSAR, Section 5.2.5.5.3.

6.UFSAR, Section 5.2.5.2.GRAND GULF B 3.4-37 LBeCR 11968 Attachment 3 GNRO-2012/00096 Page 33 of 72 BASES SURVEILLANCE REQUIREMENTS ECCS-Operati ng B 3.5.1 SR 3.5.1.4 (continued) losses, and RPV pressure present during LOCAs.These values may be established during pre-operational testing.The Frequency for this Surveillance is in accordance with the Inservice Testing Program requirements.

SR 3.5.1.5 The ECCS subsystems are required to actuate automatically to perform their design functions.

This Surveillance test verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCS, LPCS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup, and actuation of all automatic valves to their required positions.

This Surveillance also ensures that the HPCS System will automatically restart on an RPV low water level (Level 2)signal received subsequent to an RPV hi gh water 1 evel (Level 8)tri p and that the sucti on is automatically transferred from the CST to the suppression pool.The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1,"Emergency Core Cooling System (ECCS)Instrumentation," overlaps this Surveillance to provide complete testing of the assumed safety function.f24l..--"month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage (except for Division III which can be tested in any operational condition) and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown that these components usually pass the SR when performed at the)18 month Frequency, which is based on the refueling cycle.Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance.

Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.(continued)

GRAND GULF B 3.5-11 LDC 02003

-Attachmen13*GNRO-2012/00096 Page 34 of 72 BASES ECCS-Operating B 3.5.1*SR 3.5.1.6 The ADS designated S/RVs are required to actuate automatically upon receipt of specific initiation signals.A system functional test is performed to demonstrate that the mechanical portions of the ADS function (i.e., solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components.

SR 3.5.1.7 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown that these components usually pass the SR when performed at the month Frequency, which is based on the refueling cycle.herefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note that excludes valve actuation.

This prevents an RPV pressure blowdown.SR 3.5.1.7 A manual actuation of each required ADS valve (those valves removed and replaced to satisfy SR 3.4.4.1)is performed to verify that the valve is functioning properly.This SR can be demonstrated by one of two methods.If performed by method 1), plant startup is allowed prior to performing this test because valve OPERABILITY and the setpoints for overpressure protection are verified, per ASME requirements (Ref.19), prior to valve installation.

Therefore, this SR is modified by a Note that states the Surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for manual actuation after the required pressure is reached is sufficient to achieve stable conditions for testing and (continued)

GRANO GULF B 3.5-12 LDC 99008 Attachment 3 GNRO-2012/00096 Page 35 of 72 ECCS-Operat i ng B 3.5.1 BASES SURVEILLANCE SR 3.5.1.8 (continued)

REQUIREMENTS ECCS SYSTEM RESPONSE TIME tests are conductedmonths.This Frequency is consistent with the typical industry refueling cycle and is based on industry operating experience.

REFERENCES 1.UFSAR, Section 6.3.2.2.3.

2.UFSAR, Section 6.3.2.2.4.

3.UFSAR, Section 6.3.2.2.1.

4.UFSAR, Section 6.3.2.2.2.

5.UFSAR, Section 15.6.6.6.UFSAR, Section 15.6.4.7.UFSAR, Section 15.6.5.8.10 CFR 50, Appendix K.9.UFSAR, Section 6.3.3.10.10 CFR 50.46.11.UFSAR, Section 6.3.3.3.12.Memorandum from R.L.Baer (NRC)to V.Stello, Jr.(NRC),"Recommended Interim Revisions to LCO's for ECCS Components," December 1, 1975.13.UFSAR, Section 6.3.3.7.8.

14.UFSAR, Section 7.3.1.1.1.4.2.

15.GNRI-96/00229, Amendment 130 to the Operating License.16.NEDO-32291-A,"System Analyses for Elimination of Selected Response Time Testing Requirements," October 1995.17.GNRI-97/00181, Amendment 133 to the Operating License GRAND GULF B 3.5-14 LDC 97078 Attachment 3 GNRO-20 12/00096 Page 36 of 72 BASES SURVEILLANCE REQUIREMENTS (continued)

RCIC System B 3.5.3 SR 3.5.3.3 and SR 3.5.3.4 The RCIC pump flow rates ensure that the system can maintain reactor coolant inventory during pressurized conditions with the RPV isolated.The flow tests for the RCIC System are performed at two different pressure ranges such that system capability to provide rated flow is tested both at the higher and lower operating ranges of the system.Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the RCIC System diverts steam flow.Since the required reactor steam pressure must be available to perform SR 3.5.3.3 and SR 3.5.3.4, sufficient time is allowed after adequate pressure and flow are achieved to perform these SRs.Reactor startup is allowed prior to performing the low pressure Surveillance because the reactor pressure is low and the time to satisfactorily perform the Surveillance is short.The reactor pressure is allowed to be increased to normal operating pressure since it is assumed that the low pressure test has been satisfactorily completed and there is no indication or reason to believe that RCIC is inoperable.

Therefore, these SRs are modified by Notes that state the Surveillances are not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the reactor steam pressure and flow are adequate to perform the test.24 A 92 day Frequency for SR 3.5.3.3 is consisten Inservice Testing Program requirements.

The month Frequency for SR 3.5.3.4 is based on the need to perform this Surveillance under the conditions that apply just prior to or during startup from a plant outage.Operating experience has shown that these components usually pass the sR when performed at the>ts month Frequency, which is based on the refueling cycle.Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.5.3.5 The RCIC System is required to actuate automatically to perform its design function.This Surveillance verifies that with a required system initiation signal (actual or simulated) the automatic initiation logic of RCIC will cause the system to operate as designed, including actuation of the system throughout its emergency operating sequence, (continued)

GRAND GULF B 3.5-25 Revision No.0 Attachment 3 GNRO-2012/00096 Page 37 of 72 RCIC System B 3.5.3 BASES SR 3.5.3.5 (continued) automatic pump startup and actuation of all automatic valves to their required positions.

This Surveillance test also ensures that the RCIC System will automatically restart on an RPV low water level (level 2)signal received subsequent to an RPV high water level (level 8)trip and that the suction is automatically transferred from the CST to the suppression pool.The LOGIC SYSTEM FUNCTIONAL TEST performed in lCO 3.3.5.2,"Reactor Core Isolation Cooling (RCIC)System Instrumentation." overlaps this Surveillance provide complete testing of the assumed safety function.24 , Th month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and thepotentialfor an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown that these components usuall Y r>-112 pass the SR when performed at the Frequency, wn,chis based on the refueling cycle.Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by a Note that excludes vessel injection during the Surveillance.

Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

SURVEILLANCE REQUIREMENTS REFERENCES 1.10 CFR 50, Appendix A, GOe 33.2.UFSAR, Section 5.4.6.2.3.Memorandum from R.L.Baer (NRC)to V.Stello, Jr.(NRC),"Recommended Interim Revisions to LCO's for ECCS Components," December 1, 1975.GRAND GULF B 3.5-26 Revision No.0 Attachment 3 GNRO-2012/00096 Page 38 of 72 Primary Containment Air Locks B 3.6.1.2 BASES 3.6.1.2.4 SR A seal pneumatic system test to ensure that pressure does not decay at a rate equivalent to>2 psig for a period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> from an initial pressure of 90 psig is an effective leakage rate test to verify system performance.

Themonth Frequency is based on the fact that operating experience has shown these components usually pass the Surveillance when performed at the month Frequency, which is based on the refueling cycle.erefore, the Frequency was concluded to be acceptabl rom a reliability standpoint.

24 SURVEI LLANCE REQUIREMENTS (continued)

REFERENCES 1.UFSAR, Section 3.8.2.10 CFR 50, Appendix J.3.UFSAR, Table 6.2-13.GRAND GULF B 3.6-13 LDC 99050 Attachment 3 GNRO-2012/00096 Page 39 of 72 BASSS SURVEILLANCE REQUIREMENTS PCIVs B 3.6.1.3 SR 3.6.1.3.7 (continued) each automatic PCIV will actuate to its isolation position on a primary containment isolation signal.The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.1.7 overlapS-this SRprovide complete testing of the safety function.Themonth Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown that-these componentsusually pass this Surveillance when performed at themonth Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.6.1.3.8 The analyses in Reference 2 is based on leakage that is less than the specified leakage rate.Leakage through any single main steam line must be100 scfh when tested at a pressure of 11.9 psig.Leakage through all four steam lines must be250 scfh when tested at P a (11.9 psig).The MSIV leakage rate must be verified to be in accordance with the leakage test requirements of Reference 3, as modified by approved exemptions.

A Note is added to this SR which states that these valves are only required to meet this leakage limit in MODES I, 2 and 3.In the other conditions, the Reactor Coolant System is not pressurized and specific primary containment leakage limits are not required.SR 3.6.1.3.9 Surveillance of hydrostatically tested lines provides assurance that the calculation assumptions of Reference 2 is met.This SR is modified by a Note that states these valves are only required to meet the combined leakage rate in MODES 1, 2, and 3 since this is when the Reactor Coolant System is (continued)

GRAND GULF B 3.6-25 LBDER 12035 Attachment 3 GNRO-2012/00096 Page 40 of 72 LLS valves 6 3.6.1.6 BASES SURVEILLANCE REQUIREMENTS SR 3.6.1.6.1 (continued)

The STAGGERED TEST BASIS Frequency ensures that both solenoids for each LLS valve relief-mode actuator are alternatively tested.The Frequency of the required relief-mode actuator testing is based on the tests required by ASME OM Part 1 (Ref.3), as implemented by the Inservice Testing program of specification 5.5.6.The testing Frequency required by the Inservice Testing Program is based on operating experience and valve performance.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.(Reference 4)SR3.6.1.6.2 The LLS designed S/RVS are required to actuate automatically upon receipt of specific initiation signals.A system functional test is performed to verify that the mechanical portions (i.e., solenoids) of the automatic LLS function operate as designed when initiated either by an actual or simulated automatic initiation signal.The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.5.4 overlaps this SR toprovide complete testing of the safety function.month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the surveillance were performed with the reactor at power.operating experience has shown these PMn24 pass the Surveillance when performed at the 78'ffionthFrequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by a Note that excludes valve actuation.

This prevents a reactor pressure vessel pressure blowdown.REFERENCES 1.GESSAR-II, Appendix 36, Attachment A, section 3BA.8.2.UFSAR, section 5.2.2.2.3.3.

3.ASME code of operation and Maintenance of Nuclear Power plants, Part 1.4.GNRI-96/00229, Amendment 130 to the Operating License.GRAND GULF 6 3.6-35 L6DCR 10006 Attachment 3 GNRO-2012/00096 Page 41 of 72 BASES SURVEILLANCE REQUIREMENTS RHR Containment Spray System B 3.6.1.7 SR 3.6.1.7.1 (continued)

A Note has been added to this SR that allows RHR containment spray subsystems to be considered OPERABLE during alignment to and operation in the RHR shutdown cooling mode when below the RHR cut in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

At these low pressures and decay heat levels (the reactor is shut down in MODE 3), a reduced complement of subsystems should provide the required containment pressure mitigation function thereby allowing operation of an RHR shutdown cooling loop when necessary.

SR 3.6.1.7.2 Verifying each RHR pump develops a flow rate7450 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that pump performance has not degraded below the required flow rate during the cycle.It is tested in the pool cooling mode to demonstrate pump OPERABILITY without spraying down equipment in primary containment.

Flow is a normal test of centrifugal pump performance required by the ASME Code,Section XI (Ref.2).This test confirms one point on the pump design curve and is indicative of overall Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance.

The Frequency of this SR is in accordance with the Inservice Testing Program.SR3.6.1.7.3 This SR verifies that each RHR containment spray subsystem automatic valve actuates to its correct position upon receipt of an actual or simulated automatic actuation signal.Actual spray initiation is not required to meet this SR.The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.3.6 overlaps this SR to provide complete testing of the safety funcb on.month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown that these components usually pass the Surveillance when performed at (continued)

GRANO GULF B 3.6-39 Revision No.0 Attachment 3 GNRO-2012/00096 Page 42 of 72 BASES RHR Containment Spray System B 3.6.1.7-..-0'SURVEILLANCE SR 3.6.1.7.3 (continued)

REQUIREMENTSmonth Frequency.

Therefore, the Frequency was to be acceptable from a reliability standpoint.

REFERENCES 1.UFSAR, Section 6.2.1.1.5.

2.ASHE, Boiler and Pressure Vessel Code,Section XI.GRAND GULF B 3.6-40 Revision No.0 Attachment 3 GNRO-2012/00096 Page 43 of 72 BASES ACTIONS (continued)

SURVEILLANCE REQUIREMENTS MSIV LCS B 3.6.1.9 C.I and C.2 If the MSIV LCS subsystem cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not_apply.

To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.The allowed Completion Times are reasonable, based on operating experience, to reach the required plant oonditions from full power conditions in an orderly manner and wi thout challenging plant systems.SR3.6.1.9.1 Each outboard MSIV LCS blower is operated for15 minutes to verify OPERABILITY.

The 31 day Frequency was developed considering the known reliability of the lCS blower and controls, the two subsystem redundancy, and the low probability of a significant degradation of the MSIV lCS subsystem occurring between surveillances and has been shown to be acceptable through operating experience.

SR 3.6.1.9.2 Deleted SR 3.6.1.9.3 A system functional test is performed to ensure that the MSIV LCS will operate through its operating sequence.This includes verifying that the automatic positioning of the valves and the operation of each interlock and timer are correct, that the blowers start and develop the required flow rate and the necessary vacumo.The (continued)

I GRANO GULF B 3.6-46 Revision No.2 Attachment 3 GNRO-2012/00096 Page 44 of 72 BASES SURVEILLANCE REQUIREMENTS REFERENCES MSIV LCS B 3.6.1.9 SR 3.6.1.9.3 (continued)

Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown that these components usually pass the Surveillance when performed at the onth Frequency.

Therefore, the Frequency was conclude 0 be acceptable from a reliability standpoint.

1.UFSAR, Section 6.7.1.2.UFSAR, Section 15.6.5.GRAND GULF B 3.6-47 Revision No.0 Attachment 3 GNRO-2012/00096 Page 45 of 72 BASES SURVEILLANCE REQUIREMENTS SPMU System B 3.6.2.4 SR 3.6.2.4.4 (continued) the gates installed if the Suppression Pool Low Level limit is increased to 18 ft 5 1/12 inches.(See Reference 3).The 31 day Frequency is appropriate because the gates are moved under procedural control and only the infrequent movement of these gates is required in MODES 1, 2, and 3.The provision to allow gate installation in MODES 1, 2, and 3 results in isolating a portion of the SPMU System dump volume.This provision does not apply to the separator pool weir wall extension gates.These gates are not readily accessible with the upper containment pool at its required level.Supporting analyses have shown that increasing the minimum suppression pool level adequately compensates for water trapped by isolating the fuel storage and/or fuel transfer canal areas.SR 3.6.2.4.5 This SR requires a verification that each SPMU subsystem automatic valve actuates to its correct position on receipt of an actual or simulated automatic initiation signal.This includes verification of the correct automatic positioning of the valves and of the operation of each interlock and timer.As noted, actual makeup to the suppression pool may be excluded.The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.4.6 overlaps this SR to provide complete testing of the safety funcb on.i 1'Ie>l-B-month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown that these components usually pass the Surveillance when performed atmonth Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by a NOTE that excludes makeup to the suppression pool.Since all active components are testable, makeup to the suppression pool is not required.(continued)

GRAND GULF B 3.6-65 LDC 02006 Attachment 3 GNRO-2012/00096 Page 46 of 72 BASES (continued)

Primary Containment and Drywell Hydrogen Igniters B 3.6.3.2 SURVEILLANCE REQUIREMENTS SR 3.6.3.2.1 and SR 3.6.3.2.2 These SRs verify that there are no physical problems that could affect the igniter operation.

Since the igniters are mechanically passive, they are not subject to mechanical failure.The only credible failures are loss of power or burnout.The verification that each required igniter is energized is performed by circuit current versus voltage measurement.

The Frequency of 184 days has been shown to be acceptable through operating experience because of the low failure occurrence, and provides assurance that hydrogen burn capability exists between the more rigorous 18 month Surveillances.

Operating experience has shown these components usually pass the Surveillance when performed at a 184 day Frequency.

Additionally, these surveillances must be performed every 92 days if four or more igniters in any division are inoperable.

The 92 day Frequency was chosen, recognizing that the failure occurrence is higher than normal.Thus, decreasing the Frequency from 184 days to 92 days is a prudent measure, since only one more inoperable igniters (for a total of five)will result in an inoperable igniter division.SR 3.6.3.2.2 is modified by a Note that indicates that the Surveillance is not required to be performed until 92 days after four or more igniters in the division are discovered to be inoperable.

SR 3.6.3.2.3 and SR 3.6.3.2.4 These functional tests are performed every 18 months to verify system OPERABILITY.

The current draw to develop a surface temperature of 2 17QO°F is verified for igniters in inaccessible areas, e.g., in a high radiation area.Additionally, the surface temperature of each accessible igniter is measured to be 2 1700°F to demonstrate that a temperature sufficient for ignition is achieved.Operating experience has shown that these components usually pass the Surveillance when performed at the Frequency.

Therefore, the Frequency was conclude 0 be acceptable from a reliability standpoint.

24 (continued)

GRAND GULF B 3.6-76 LDC 00056 Attachment 3 GNRO-2012/00096 Page 47 of 72 BASES SURVEILLANCE REQUIREMENTS Drywell purge System B 3.6.3.3 SR 3.6.3.3.2 (continued) that all associated controls are functioning properly.It also ensures that blockage, compressor failure, or excessive vibration can be detected for corrective action.The 92 day Frequency is consistent with Inservice Testing pr09ram Frequencies, operating experience, the known rellability of the compressor and controls, and the two redundant subsystems available.

SR 3.6.3.3.3 operating each drywell purge subsystem for15 minutes and verifying that each drywell purge subsystem flow rate is1000 scfm ensures that each subsystem is capable ofmaintaining drywell concentrations below theflammabil,ty month Frequency is based on the need to perform this surveillance under the conditions that apply during a plant outage when the drywell boundary is not required.operating experience has shown that these usually pass the Surveillance when performed atmonth Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.6.3.3.4 This SR verifies that the pressure differential required to open the vacuum breakers is1.0 psid and that the isolation valve differential pressure actuation instrumentation opens the valve at 0.0 to 1.0 psid Cdrywell minus containment).

This SR includes a CHANNEL CALIBRATION of the isolation valve differential pressure actuation operating experience has shown that these 24 om onents usually pass the surveillance when performed at th month Frequency.

Therefore.

the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1.Regulatory Guide 1.7.Revision 1.2.UFSAR.section 6.2.5.3.Technical Specification Amendment 145 to GGNS operating License.GRAND GULF B 3.6-82 LBDCR 10002 Attachment 3 GNRO-2012/00096 Page 48 of 72 BASES SURVEILLANCE REQUIREMENTS Secondary Containment B 3.6.4.1 SR 3.6.4.1.3 and SR 3.6.4.1.4 (continued) these 5Rs is to ensure that the SGT subsystem, being used for the test.functions Thppp is a separate LCD 3.6.4.3 with Surveillance Requirements which serves the primary purpose of ensuring OPERABILITY of the SGT system.SRs 3.6.4.1.3 and 3.6.4.1.4 need not be performed with each SGT subsystem.

The 5GT subsystem used for these Surveillances is staggered to ensure that in addition to the requirements of LCO 3.6.4.3, either SGT subsystem will perform this test.The inoperability of the SGT system does not necessarily constitute a failure of these Surveillances relative to the secondary containment OPERABILITY.

Operating experience has shown the secondary containment boundary usually passes these Surveillances when performed at the Frequency.

Therefore.

the Frequency was conclude 0 be acceptable from a reliability standooint.

.24 REFERENCES 1.UFSAR.Section 15.6.5.GRANO GULF 2.UFSAR, Section 15.7.4.B 3.6-87a LOC 06032 Attachment 3 GNRO-2012/00096 Page 49 of 72 BASES SURVEILLANCE REQUIREMENTS SCIVs B 3.6.4.2 SR 3.6.4.2.1 (continued) relatively easy, the 31 day Frequency was chosen to provide added assurance that the SCIVs are in the correct positions.

Two Notes have been added to this SR.The first Note applies to valves, dampers, rupture disks, and blind flanges located in high radiation areas and allows them to be verified by use of administrative controls.Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons.Therefore, the probability of misalignment of these SCIVs, once they have been verified to be in the proper position, is low.A second Note has been included to clarify that SCIVs that are open under administrative controls are not required to meet the SR during the time the SCIVs are open.SR 3.6.4.2.2 Verifying the isolation time of each power operated, automatic SCIV is within limits is required to demonstrate OPERABILITY.

The isolation time test ensures that the SCIV will isolate in a time period less than or equal to that assumed in the safety analyses.Generally, SCIVs must close within 120 seconds to support the functioning of the Standby Gas Treatment System.SCIVs may have analytical closure times based on a function other than secondary containment isolation, in which case the more restrictive time applies.The Frequency of this SR is in accordance with the Inservice Testing Program.SR 3.6.4.2.3 Verifying that each automatic SCIV closes on a secondary containment isolation signal is required to prevent leakage of radioactive material from secondary containment following a DBA or other accidents.

This SR ensures that each automatic SCIV will actuate to the isolation position on a secondary containment isolation signal.The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.2.6 overlaps this SR to provide complete testing of the safety The month 24 (.contlnued)

GRAND GULF B 3.6-94 LDC 06007 Attachment 3 GNRO-2012/00096 Page 50 of 72 SCIVs B 3.6.4.2 BASES SR 3.6.4.2.3 (continued)

UFSAR, Section 15.6.5.1.Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.Operating experience has shown these components usually pass the Surveillance when performed at the onth Frequency.

Therefore, the Frequency was conclude to be acceptable from a reliability standpoint.

REFERENCES SURVEILLANCE REQUIREMENTS 2.UFSAR, Section 6.2.3.3.UFSAR, Section 15.7.4.GRANO GULF B 3.6-95 LoC 99053 Attachment 3 GNRO-2012/00096 Page 51 of 72 BASES SURVEILLANCE REOUIREMENTS SGT System B 3.6.4.3 SR 3.6.4.3.3 (continued)

The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.2.6 overlaps this SR to provide complete testing of the safety function.While this Surveillance can be performed with the reactor at power, operating experience has shown these components usually pass the Surveillance when performed at the tB Frequency, which is based on the refueling cycle.Therefore, the Frequency was concluded to be acceptable a reliability standpoint.

REFERENCES 1.10 CFR 50, Appendix A, GDC 41.GRAND GULF 2.UFSAR, Section 6.5.3.B 3.6-101 LDC 00081,99069 Attachment 3 GNRO-2012/00096 Page 52 of 72 BASES SURVE I LLANCE REQUIREMENTS (continued)

Drywell Isolation Valve(s)B 3.6.5.3 SR 3.6.5.3.3 Verifying that the isolation time of each power operated, automatic drywell isolation valve is within limits is required to demonstrate OPERABILITY.

The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis.The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program.SR 3.6,5.3,4 Verifying that each automatic drywell isolation valve closes on a drywell isolation signal is required to prevent bypass leakage from the drywell following a DBA.This SR ensures each automatic drywell isolation valve will actuate to its isolation position on a drywell isolation signal.The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.1.7 overlaps this SR to provide complete testing of the safety function.Themonth Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power, since isolation of penetrations would eliminate cooling water flow and disrupt the normal operation of many critical components.

Operating experience has shown these components usually pass this Surveillance when performed at themonth Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1.UFSAR, Section 6.2.4.2.GNRI-96/00162, Issuance of Amendment No.126 to Facility Operating License No.NPF-29-Grand Gulf Nuclear Station, Unit 1 (TAC No.M94176), dated August 1, 1996.GRAND GULF B 3.6-119 LDC 06007 Attachment 3 GNRO-2012/00096 Page 53 of 72 BASES SURVEILLANCE REQUIREMENTS REFERENCES Drywell Vacuum Relief System B 3.6.5.6 SR 3.6.5.6.2 (continued)

This Surveillance includes a CHANNEL FUNCTIONAL TEST of the isolation valve differential pressure actuation instrumentation.

This provides assurance that the safety analysis assumptions are valid.The Frequency of this Surveillance is in accordance with Inservice Test Program.SR 3.6.5.6.3 Verification of the opening pressure differential is necessary to ensure that the safety analysis assumption that the vacuum breaker or isolation valve will open fully at a differential pressure of 1.0 psid is valid.This SR verifies that the pressure differential required to open the vacuum breakers is1.0 psid and that the isolation valve differential pressure actuation instrumentation opens the valve at 0.0 to 1.0 psid for the drywell purge vacuum relief subsystem and-1.0 to 0.0 psid for the post-LOCA vacuum relief subsystems (drywell minus containment).

This SR includes a CHANNEL CALIBRATION of the isolation valve differential pressure actuation instrumentation.

This Surveillance includes a of the position indication as necessary.

Ihe month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for violating the drywell boundary.Operating experience has shown these usually pass the Surveillance when performed at tne month Frequency, which is based on the refueling cycle.Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

1.UFSAR, Section 6.2.GRAND GULF B 3.6-130 Revision No.1 Attachment 3 GNRO-2012/00096 Page 54 of 72 BASES SURVEILLANCE REQUIREMENTS SSW System and UHS B 3.7.1 SR 3.7.1.4 (continued) is demonstrated by use of an actual or simulated initiation signal.This SR also verifies the automatic start capability of the SSW pump and cooling tower fans in each subsystem.

The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.5.1.6 overlaps this SR to provide complete testing of the safety function. Operating experience has shown tha these components usually pass the SR when performed on the month Frequency.

Therefore, this Frequency is concluded to be acceptable from a reliability standpoint.

REFERENCES 1.Regulatory Guide 1.27, Revision 2, January 1976.2.UFSAR, Section 9.2.1.3.UFSAR, Table 9.2-3.4.UFSAR, Section 6.2.1.1.3.3.

5.UFSAR, Chapter 15.-6.UFSAR, Section 6.2.2.3.7.UFSAR, Table 6.2-2.GRAND GULF B 3.7-7 Revision No.0 Attachment 3 GNRO-2012/00096 Page 55 of72 BASES SURVEILLANCE REQUIREMENTS REFERENCES HPCS SWS B 3.7.2 SR 3.7.2.1 (continued) those valves capable of potentially being mispositioned are in the correct position.This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.Isolation of the HPCS SWS to components or systems may render those components or systems inoperable, but may not affect the OPERABILITY of the HPCS SWS.As such, when all HPCS SWS pumps, valves, and piping are OPERABLE, but a branch connection off the main header is isolated, the HPCS SWS needs to be evaluated to determine if it is still OPERABLE.The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

SR 3.7.2.2 This SR verifies that the automatic isolation valves of the HPCS SWS will automatically switch to the safety or emergency position to provide cooling water exclusively to the safety related equipment during an accident event.This is demonstrated by use of an actual or simulated initiation signal.This SR also verifies the automatic start capability of the HPCS SWS pump.The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.5.1.6 overlaps this SR to provide complete testing of the safety function.24 Operating experience has shown that t ese components usually pass the SR when performed at the onth Frequency.

Therefore, this Frequency is concluded to be acceptable from a reliability standpoint.

1.UFSAR, Section 9.2.1.2.UFSAR, Chapter 6.3.UFSAR, Chapter 15.GRAND GULF B 3.7-10 Revision No.0 Attachment 3 GNRO-2012/00096 Page 56 of 72 CRFA System B 3.7.3 BASES (continued)

SURVEILLANCE REQUIREMENTS SR 3.7.3,1 This SR verifies that a subsystem in a standby mode starts from the control room on demand and continues to operate, Standby systems should be checked periodically to ensure that they start and function properly.As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every month provides an adequate check on this system.Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the two subsystem redundancy available.

SR 3.7.3.2 This SR verifies that the required CRFA testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).The VFTP includes testing HEPA filter performance, and minimum system flow rate.Specific test frequencies and additional information are discussed in detail in the VFTP.SR 3.7.3,3 This SR verifies that each CRFA subsystem starts and operates and that the isolation valves close in s 4 seconds on an actual or simulated initiation signal.The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.1 overlaps this SR to provide complete testing of the safety function.While this Surveillance can be performed with the reactor at power, operating experience has shown these components usually pass the Surveillance when performed at themonth Frequency, which is based on the refueling cycle.Therefore, the Frequency was concluded to be acceptable 24 from a reliability standpoint.

SR 3.7.3.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE.The details of the testing are specified in the Control Room Envelope Habitability Program.(continued)

B 3.7-16a LBDCR 09001 I Attachment 3 GNRO-2012/00096 Page 57 of 72 BASES ACTIONS(continued)

Control Room AC System B 3.7.4 SURVEILLANCE REQUIREMENTS During OPDRVs if the Required Action and associated Completion Time of Condition B is not met, action must be taken to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room.This places the unit in a condition that minimizes risk.If applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release.Actions must continue until the OPORVs are suspended.

SR 3.7.4,1 This SR verifies that the heat removal capability of the system is sufficient to remove the control room heat load assumed in the safety analysis.The SR ofcombination of testing and calculation.

TheFrequency is appropriate since significant degradation of the Control Room AC System is not expected over this time period.REFERENCES 1.UFSAR, Section 6.4.GRAND GULF 2.UFSAR, Section 9.4.1.B 3.7-21 LDC 00070 Attachment 3 GNRO-2012/00096 Page 58 of 72 BASES SURVEILLANCE REQUIREMENTS AC Sources--Operating B 3.8.1 SR'3.8.1.6 (continued)

The design of the fuel transfer systems is such that pumps operate automatically in order to maintain an adequate volume of fuel oil in the day tanks during or following DG testing.Therefore, a 31 day Frequency is specified to correspond to the maximum interval for DG testing.SR 3.8.1.7 Under accident conditions, loads are sequentially connected to the bus by the load sequencing panel.The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the bus power supplies due to high motor starting currents.The load sequencing ensures that sufficient time exists for the bus power supply to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated.Reference 2 provides a summary of the automatic loading of ESF buses.This Surveillance is a manual test of the load shedding and sequencing panels and verifies the load shedding and sequencing panels respond within design criteria to the following test inputs: LOCA, bus undervoltage, bus undervoltage followed by LOCA, and LOCA followed by bus undervoltage.

The Frequency of 31 days is based on engineering judgment, taking into consideration plant conditions required to perform the Surveillance.

Operating experience has shown that these components usually pass the SR when performed at the 31 day Frequency.

Therefore, the Frequency was concluded toacceptable from a reliability standpoint.

SR 3.8.1.8 Transfer of each 4.16 kY ESF bus power supply from the normal offsite circuit to the alternate offsite circuit P.UIl the OPERABILITY of the alternate circuit.Themonth Frequency of the Surveillance is based on engineering judgment taking into consideration the plant conditions required to perform the Surveillance, and is (continued)

GRAND GULF B 3.8-18 Revision No.1 Attachment 3 GNRO-2012/00096 Page 59 of 72 BASES SURVEILLANCE REQUIREMENTS AC Sources--Operating B 3.8.1 SR 3.8.1.8 (continued) intended to be consistent with expected fuel cycle lengths.Operating experience has shown that these components usually pass the SR when performed on the Frequency.

Therefore, the Frequency was conclud to be acceptable from a reliability standpoint.

24.(continued)

GRAND GULF B 3.8-18a Revision No.1 Attachment 3 GNRO-2012/00096 Page 60 of 72 BASES SURVEILLANCE REQUIREMENTS AC Sources-Operating B 3.8.1 SR 3.8.1.9 (continued) 2)tripping its associated single largest load with the DG solely supplying the bus.If this load were to trip, it would result in the loss of the DG.As required by IEEE-308 (Ref.13), the load rejection test is acceptable if the increase in diesel speed does not exceed 75%of the difference between synchronous speed and the overspeed trip setpoint, or 15%above synchronous speed, whichever is lower.For the Grand Gulf Nuclear Station the lower value results from the firstite ria.----

Frequency is consistent with the recommendation of Regulatory Guide 1.9 (Ref.3).Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source.This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.

This SR has been modified by two Notes.Note 1 states;Credit may be taken for unplanned events that satisfy this SR.Examples of unplanned events may include: 1)Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and 2)Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible.Whensynchronizedwith offsite power, testing should be performed at a power factor of0.9 for DG 11 and DG 13 and0.89 for DG 12.These power factors are representative of the actual inductiveloadingthe DGs would see under design (continued)

GRAND GULF B 3.8-20 LDC 06007 Attachment 3 GNRO-2012/00096 Page 61 of 72 BASES AC Sources-Operating B 3.8.1 SURVEILLANCE SR 3.8.1.10 (continued)

REQUIREMENTSmonth Frequency is consistent with the of Regulatory Guide 1.9 (Ref.3)and is intended to be consistent with expected fuel cycle lengths.Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source.This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.

This SR has been modified by a two Notes.Note 1 states that credit may be taken for unplanned events that satisfy this SR.Examples of unplanned events may include: 1)Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and 2)Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible.When synchronized with offsite power, testing should be performed at a power factor of0.9 for DG 11 and DG 13 and0.89 for DG 12.These power factors are representative of the actual inductive loading the DGs would see under design basis accident conditions.

Under certain conditions, however, Note 2 allows the surveillance to be conducted at a power factor above the limit.These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to within the limits results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as close as practicable to the limit while still maintaining acceptable voltage limits on the emergency busses.In other circumstances, the grid voltage (continued)

GRAND GULF B 3.8-22 LDC 06007 Attachment 3 GNRO-2012/00096 Page 62 of 72 BASES SURVEILLANCE REQUIREMENTS AC Sources-Ope rat i ng B 3.8.1 SR 3.8.1.11 The Frequency of+8 months is consistent with the recommendations of Regulatory Guide 1.9 (Ref.3)takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source.This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.

This SR is modified by two Notes.The reason for Note 1 is to minimize wear and tear on the OGs during testing.For the purpose of this testing, the OGs must be started from standby conditions, that is, with the engine coolant and oil being continuously circulated and temperature maintained consistent with manufacturer recommendations for DG 11 and DG 12.For DG 13, standby conditions mean that the lube oil is heated by the jacket water and continuously circulated through a portion of the system as recommended by the vendor.Engine jacket water is heated by an immersion heater and circulates through the system by natural circulation.

Note 2 is not applicable to DG 13.The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems.Credit may be taken for unplanned events that satisfy this SR.Examples of unplanned events may include: 1)Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and 2)Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.(continued)

GRAND GULF B 3.8-23 LOC 02003 Attachment 3 GNRO-2012/00096 Page 63 of 72 BASES SURVEILLANCE REQUIREMENTS (continued)

AC Sources-Operating B 3.8.1 SR 3.8.1.12 This Surveillance demonstrates that the oG automatically starts and achieves the required voltage and frequency within the specified time (10 seconds)from the design basis actuation signal (LOCA signal)and operates for5 minutes.The 5 minute period provides sufficient time to demonstrate stability.

SR 3.8.1.12.d ensures that emergency loads are energized from the offsite electrical power system on an ECCS signal without loss of offsite power.The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the loading logic for loading onto offsite power.In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation.

For instance, ECCS injection valves are not desired to be stroked open, high pressure injection systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation.

In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of the offsite power system to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.The Frequencymonths takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with the expected fuel cycle lengths.Operating experience has shown that these components usually pass the SR when performed at the month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

Testing performed for this SR is normally conducted with the oG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source.This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.(continued)

GRANO GULF B 3.8-24 LoC 02003 Attachment 3 GNRO-2012/00096 Page 64 of 72 BASES SURVEILLANCE REQUIREMENTS SR 3.8.1.13 (continued)

AC Sources-Operat i ng B 3.8.1 minor problems that are not immediately detrimental to operation of the DG.month Frequency is based on engineering judgment, taking into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.Operating experience has that usually pass the SR when performed atmonth Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source.This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.(continued)

GRAND GULF B 3.8-25a LDC 01166 Attachment 3 GNRO-2012/00096 Page 65 of 72 BASES SURVEILLANCE REQUIREMENTS SR 3.8.1.14 (continued)

AC Sources-Operat i ng B 3.8.10.9.This power factor is chosen to be representative of the actual design basis inductive loading that the DG could experience.

During the test the generator voltage and frequency is 4160+/-416 volts and58.8 Hz and63 Hz within 10 seconds after the start signal and the steady state generator voltage and frequency is maintained within 4160+/-416 volts and 60+/-1.2 Hz for the duration of the test.r24l-----:.

.

Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref.3)takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycl e 1 engths.This Surveillance is modified by three Notes.Note 1 states that momentary transients due to changing bus loads do not invalidate this test.The DG 11 and 12 load band is provided to avoid routine overloading of the TOI DG.Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY.

Similarly, momentary power factor transients above the limit do not invalidate the test.Note 2 stipulates that credit may be taken for unplanned events that satisfy this SR.Examples of unplanned events may include: 1)Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and 2)Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

Note 3 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible.When synchronized with offsite power, testing should be performed at a power factor of0.9 for OG 11 and OG 13 and0.89 for OG 12.These power factors are representative of (continued)

GRAND GULF B 3.8-27 LDC 06007 Attachment 3 GNRO-2012/00096 Page 66 of 72 BASES SU RVEr LLANCE REQUIREMENTS SR 3.8.1.15 (continued)

AC Sources-Operati ng B 3.8.1 and frequency within 10 seconds.The 10 second time is derived from the requirements of the accident analysis to to a design basis large break LOCA.24 The month Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref.3).This SR has been modified by two Notes.Note 1 ensures that the test is performed with the diesel sufficiently hot.The requirement that the diesel has operated for at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at full load conditions or until operating temperatures stabilized prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions.

The OG 11 and 12 load band is provided to avoid routine overloading of the TOI OG.Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain OG OPERABILITY.

Momentary transients due to changing bus loads do not invalidate this test.Note 2 allows all OG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.SR 3.8.1.16 As required by Regulatory Guide 1.9 (Ref.3)this Surveillance ensures that the manual synchronization and load transfer from the OG to each required offsite source can be made and that the OG can be returned toload status when offsite power is restored.It also ensures that the undervoltage logic is reset to allow the OG to reload if a subsequent loss of offsite power occurs.The OG is considered to be in ready-to-load status when the OG is at rated speed and voltage, the output breaker is open and can receive an auto-close signal on bus 24 undervoltage, and the load sequence logic is reset.The Frequency 0 recommendations of into consideration Surveillance.

months is consistent with the Regulatory Guide 1.9 (Ref.3)and takes plant conditions required to perform the Testing performed for this SR is normally conducted with the OG being tested (and the associated safety-related (continued)

GRAND GULF B 3.8-28 LDC 02003 Attachment 3 GNRO-2012/00096 Page 67 of 72 BASES AC Sources-Ope rat i ng B 3.8.1 SURVEILLANCE SR 3.8.1.17 (continued)

REQUIREMENTS Frequency is consistent with the of Regulatory Guide 1.9 (Ref.3)takes consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.into Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source.This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.

Credit may be taken for unplanned events that satisfy this SR.Examples of unplanned events may include: 1)Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and 2)Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

SR 3.8.1.18 Under accident conditions, loads are sequentially connected to the bus by the load sequencing panel.The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the bus power supplies due to high motor starting currents.The 10%load sequence time interval tolerance ensures that sufficient time exists for the bus power supplies to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated.Reference 2 provides a summary of the automatic loading of ESF buses.(continued)

GRAND GULF B 3.8-30 LDC 01166 Attachment 3 GNRO-2012/00096 Page 68 of 72 BASES AC Sources-Operating B 3.8.1 SURVEILLANCE REQUIREMENTS SR 3.8.1.18 The Frequency of onths is consistent with the recommendations of Regulatory Guide 1.9 (Ref.3)takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.(continued)

GRAND GULF B 3.8-30a LDC 01166 I Attachment 3 GNRO-2012/00096 Page 69 of 72 BASES SURVEILLANCE REQUIREMENTS AC Sources-Operating B 3.8.1 SR 3.8.1.18 (continued)

This SR is modified by a Note.The reason for the Note is that performing the Surveillance during these MODES would challenge plant safety systems.Credit may be taken for unplanned events that satisfy this SR.Examples of unplanned events may include: 1)Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and 2)Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

SR 3.8.1.19 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.This Surveillance demonstrates the DG operation, as discussed in the Bases for SR 3.8.1.11, during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal.For the purposes of this Surveillance the DG 13 autoconnected emergency loads are verified to be energized in S 20 seconds.In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading is verified.The Frequency 0 months takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle months.J: Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related (continued)

GRAND GULF B 3.8-31 LDC 02003 Attachment 3 GNRO-2012/00096 Page 70 of 72 BASES DC Sources-Operati ng B 3.8.4 SURVEILLANCE SR 3.8.4.3 (continued)

REQUIREMENTSmonth Frequency of the Surveillance is based on judgement, taking into consideration the desired unit conditions to perform the Surveillance.

Operating experience has shown that these components usually pass the SR when performed at the Frequency.

Therefore, the Frequency was concluded to e acceptable from a reliability standpoint.

24 (continued)

GRAND GULF B 3.8-56a LDC 99050 Attachment 3 GNRO-2012/00096 Page 71 of 72 DC Sources--Operating B 3.8.4 BASES SR 3.8.4.4 and SR 3.8.4.5 Visual inspection and resistance measurements of inter-cell, inter-rack, inter-tier, and terminal connections provides an indication of physical damage or abnormal deterioration that could indicate degraded battery condition.

The anti-corrosion material is used to ensure good electrical connections and to reduce terminal deterioration.

The visual inspection for corrosion is not intended to require removal of and inspection under each terminal connection.

The removal of visible corrosion is a preventive maintenance SR.The presence of visible corrosion does not necessarily represent a failure of this SR, prOVided visible corrosion is removed during performance of this Surveillance.

For the purposes of this SR oxidation is not considered corrosion provided the resistance of the connection(s) is within limits..month Frequency of the Surveillance is based on engineering judgement, taking into consideration the desired unit conditions to perform the Surveillance.

Operating experience has shown that these components usually pass the SR when performed at the Frequency.

Therefore; the Frequency was concludedte acceptable from a reliability standpoint.

24 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.6 Battery charger capability requirements are based on the design capacity of the chargers (Ref.4).According to Regulatory Guide 1.32 (Ref.9), the battery charger supply is required to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences.

The minimum required amperes and duration ensure that these requirements can be satisfied.

The Surveillance Frequency is acceptable, given the unit conditions reqUired to perform the test and the other administrative controls existing to ensure adequate charger performance during these intervals.

In addition, this Frequency is intende 0 be consistent with expected fuel cycle lengths.24 (continued)

GRAND GULF B 3.8-57 Revision No.0 Attachment 3 GNRO-2012/00096 Page 72 of 72 BASES DC Sources-operating B 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.7 A battery service test is a special test of the battery's capability'.

as found.to satisfy the design requirements (battery auty cycle)of the DC electrical power system.The discharge rate and test length (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for Division 1 and Division 2 and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for Division 3)correspond to the design duty cycle requirements as specified in Reference 4.

The surveillance Frequency of 1&months is consistent with the recommendations of Regulatory Guide 1.32 (Ref.9)and Regulatory Guide 1.129 (Ref.10), which state that the battery service test should be performed during refueling operations or at some other outage.with intervals between tests not to exceedmonths.This SR is modified by two Notes.Note 1 allows the once per 60 months of SR 3.8.4.8 in lieu of SR 3.8.4.7.This substitution is acceptable because SR 3.8.4.8 represents a more severe test of battery than SR 3.8.4.7.The reason for NOte 2 is that performing the surveillance would remove a required DC electrical power subsystem from service the electrical distribution system.and chailenge safety systems.The Division 3 test may be performed in MODE 1, 2.or 3 in conjunction with HPCS system outages.credit may be taken for unplanned events that satisfy the surveillance.

S8 3.8.4.8 A battery test is a test of constant current capacity of a battery, normally done in the as found condition.

after having been in service, to detect any change in the capacity determined by the acceptance test.The test is intended to determine overall battery degradation due to age and usage.The acceptance criteria for this surveillance is consistent with 1EEE-450 (Ref.8)and 1EEE-485 (Ref.11).These references recommend that the battery be replaced if its capacity is below 80%of the manufacturer's rating.A capacity of 80%shows that the battery rate of deterioration

s increasing, even if there is ample capacity to meet the load requirements.(continued)

GRANO GULF B 3.8-58 LBBER: 11&49 t Attachment 4 GNRO-2012/00096 Revised Technical Specification Changes (Clean Copy)

SURVEILLANCE REQUIREMENTS (continued)

SR 3.1.7.6 SR 3.1.7.7 SR 3.1.7.8 SR 3.1.7.9 SR 3.1.7.10 SURVEILLANCE Verify each SLC subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in the correct position, or can be aligned to the correct position.Verify each pump develops a flow rate41.2 gpm at a discharge pressure1340 psig.Verify flow through one SLC subsystem from pump into reactor pressure vessel.Determine Boron-10 enrichment in atom percent (E).Verify piping between the storage tank and the pump suction is not blocked.FREQUENCY 31 days In accordance with the Inservice Testing Program 24 months on a STAGGERED TEST BASIS Once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after boron is added to the solution.Once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after solution temperature is restored to>45°F GRAND GULF 3.1-23 Next page is 3.1-26.Amendment No.

SDV Vent and Drain Valves 3.1.8 SURVEILLANCE REQUIREMENTS SR 3.1.8.1 SR 3.1.8.2 SR 3.1.8.3 GRAND GULF SURVEILLANCE

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

Not required to be met on vent and drain valves closed during performance of SR 3.1.8.2.Verify each SDV vent and drain valve is open.Cycle each SDV vent and drain valve to the fully closed and fully open position.Verify each SDV vent and drain valve: a.Closes in30 seconds after receipt of an actual or simulated scram signal;and b.Opens when the actual or simulated scram signal is reset.3.1-27 FREQUENCY 31 days 92 days 24 months Amendment No.

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SR3.3.1.1.11 SR 3.3.1.1.12 SR 3.3.1.1.13 SR 3.3.1.1.14 SURVEILLANCE Perform CHANNEL FUNCTIONAL TEST.------------------NOTES------------------

1.Neutron detectors are excluded.2.For IRMs, not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 2.Perform CHANNEL CALIBRATION.

Perform LOGIC SYSTEM FUNCTIONAL TEST.Verify Turbine Stop Valve Closure, Trip Oil Pressure C Low and Turbine Control Valve Fast Closure Trip Oil PressureCLow Functions are not bypassed when THERMAL POWER is 2 35.4%RTP.FREQUENCY 24 months 24 months 24 months 24 months (continued)

GRAND GULF 3.3-5 Amendment No.+/-4+/-,

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE RPS Instrumentation 3.3.1.1 FREQUENCY SR 3.3.1.1.15 SR 3.3.1.1.16 SR 3.3.1.1.17 SR 3.3.1.1.18 SR 3.3.1.1.19 GRAND GULF------------------NOTES------------------

1.Neutron detectors are excluded.2.For Functions 3, 4, and 5 in Table 3.3.1.1-1, the channel sensors may be excluded.3.For Function 6, Un" equals 4 channels for the purpose of determining the STAGGERED TEST BASIS Frequency.

Verify the RPS RESPONSE TIME is within limits.Deleted Perform APRM recirculation flow transmitter calibration.

Deleted Perform CHANNEL CHECK.3.3-5a 24 months on a STAGGERED TEST BASIS 24 months 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (continued)

Amendment No.-l4+,+/--8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SRM Instrumentation 3.3.1.2 FREQUENCY SR 3.3.1.2.4 SR 3.3.1.2.5 SR 3.3.1.2.6 GRAND GULF------------------NOTE-------------------

Not required to be met with less than or equal to four fuel assemblies adjacent to the SRM and no other fuel assemblies in the associated core quadrant.Verify count rate is: a.3.0 cps, or b.0.7 cps with a signal to noise ratio2:1.------------------NOTE-------------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after IRMs on Range 2 or below.Perform CHANNEL FUNCTIONAL TEST.------------------NOTES------------------

1.Neutron detectors are excluded.2.Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after IRMs on Range 2 or below.Perform CHANNEL CALIBRATION.

3.3-12 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during CORE ALTERATIONS AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 31 days 24 months Amendment No.+W SR 3.3.2.1.4 Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY------------------NOTE-------------------

Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after THERMAL POWER is10%RTP in MODE 1.SR 3.3.2.1.5 SR 3.3.2.1.6 SR 3.3.2.1.7 SR 3.3.2.1.8 GRAND GULF Perform CHANNEL FUNCTIONAL TEST.Calibrate the low power setpoint trip units.The Allowable Value shall be10%RTP and35%RTP.Verify the RWL high power Function is not bypassed when THERMAL POWER is>70%RTP.Perform CHANNEL CALIBRATION.

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

Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after reactor mode switch is in the shutdown position.Perform CHANNEL FUNCTIONAL TEST.3.3-16 92 days 92 days 92 days 184 days 24 months (continued)

Amendment No.12(;),.li§.

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