Text

Issuance of Amendment Adoption of Technical Specification Task Force Traveler 425
	ML15317A307
Person / Time
Site:	Nine Mile Point
Issue date:	11/30/2015
From:	Mozafari B; Plant Licensing Branch 1
To:	Bryan Hanson; Exelon Nuclear, Nine Mile Point
	Mozafari B
References
	CAC MF5364
	Download: ML15317A307 (159)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 30, 2015 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear Nine Mile Point Nuclear Station, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT 2 - ISSUANCE OF AMENDMENT RE: ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER 425 (CAC NO. MF5364)

Dear Mr. Hanson:

The Commission has issued the enclosed Amendment No. 152 to Renewed Facility Operating License No. NPF-69 for the Nine Mile Point Nuclear Station, Unit No. 2 (NMP2). The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated November 19, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14329A353), as supplemented by letters dated July 10, 2015 (ADAMS Accession No. ML15191A013), September 10, 2015 (ADAMS Accession No. ML15254A069), and September 24, 2015 (ADAMS Accession No. ML15271A029).

This amendment revises the TSs to require that changes to specific surveillance frequencies will be made in accordance with Nuclear Energy Institute 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies" (ADAMS Accession No. ML071360456). The change is the adoption of NRG-approved Technical Specification Task Force (TSTF) Standard Technical Specifications Change Traveler TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF [Risk-Informed TSTF] Initiative Sb" (ADAMS Accession No. ML090850642).

The Federal Register(FR) notice published on July 6, 2009 (74 FR 31996), announced the availability of TSTF-425, Revision 3.

B. Hanson A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely, ,

11ru~v~r Brenda L. Mozafari, Sr. Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410

Enclosures:

1. Amendment No. 152 to NPF-69

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NINE MILE POINT NUCLEAR STATION, LLC EXELON GENERATION COMPANY. LLC DOCKET NO. 50-410 NINE MILE POINT NUCLEAR STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 152 Renewed License No. NPF-69

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A The application for amendment by Exelon Generation Company, LLC (Exelon, the licensee) dated November 19, 2014, as supplemented by letters dated July 10, September 10, and September 24, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-69 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 152, are hereby incorporated into this license.

Exelon Generation Company, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 120 days.

FOR THE NUCLEAR REGULATORY COMMISSION Travis L. Tate, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: November 30, 201 5

ATTACHMENT TO LICENSE AMENDMENT NO. 152 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-69 DOCKET NO. 50-410 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page Page4 Page 4 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

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(1) Maximum Power Level Exelon Generation is authorized to operate the facility at reactor core power levels not in excess of 3988 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 152 are hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Fuel Storage and Handling (Section 9.1. SSER 4)*

a. Fuel assemblies, when stored in their shipping containers, shall be stacked no more than three containers high.

b. When not in the reactor vessel, no more than three fuel assemblies shall be allowed outside of their shipping containers or storage racks in the New Fuel Vault or Spent Fuel Storage Facility.

c. The above three fuel assemblies shall maintain a minimum edge-to-edge spacing of twelve (12) inches from the shipping container array and approved storage rack locations.

d. The New Fuel Storage Vault shall have no more than ten fresh fuel assemblies uncovered at any one time.

(4) Turbine System Maintenance Program (Section 3.5.1.3.10. SER)

The operating licensee shall submit for NRC approval by October 31, 1989, a turbine system maintenance program based on the manufacturer's calculations of missile generation probabilities.

(Submitted by NMPC letter dated October 30, 1989 from C.D. Terry and approved by NRC letter dated March 15, 1990 from Robert Martin to Mr. Lawrence Burkhardt, Ill).

The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report (SER) and/or its supplements wherein the license condition is discussed.

Renewed License No. NPF-69 Amendment 117through 140, 141, 143, 144, 146, 147, 148, 150, 151, 152

Control Rod OPERABILITY 3.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. --------------NOTE-------------- D.1 Restore compliance 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Not applicable when with BPWS.

THERMAL POWER

> 10% ATP. OR

D.2 Restore control rod 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Two or more inoperable to OPERABLE status.

control rods not in compliance with banked position withdrawal sequence (BPWS) and not separated by two or more OPERABLE control rods.

E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, C, or D not met.

OR Nine or more control rods inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Determine the position of each control rod. In accordance with the Surveillance Frequency Control Pro ram (continued)

NMP2 3.1.3-3 Amendment 9+, 152

Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.3.2 Deleted SR 3.1.3.3 ------------------------------ NOTE ----------------------------

Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM.

Insert each withdrawn control rod In accordance at least one notch. with the Surveillance Frequency Control Proqram.

SR 3.1.3.4 Verify each control rod scram time from In accordance fully withdrawn to notch position 05 is with s; 7 seconds. SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 (continued)

NMP2 3.1.3-4 Amendment 91, 130, 152

Control Rod Scram Times 3.1.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.4.2 Verify, for a representative sample, each In accordance tested control rod scram time is within the with the limits of Table 3.1.4-1 with reactor steam Surveillance dome pressure :2'. 800 psig. Frequency Control Program SR 3.1.4.3 Verify each affected control rod scram time Prior to is within the limits of Table 3.1.4-1 with declaring any reactor steam dome pressure. control rod OPERABLE after work on control rod or CRD System that could affect scram time SR 3.1.4.4 Verify each affected control rod scram time Prior to is within the limits of Table 3.1.4-1 with exceeding reactor steam dome pressure :2'. 800 psig. 40% ATP after fuel movement within the affected core cell Prior to exceeding 40%

RTP after work on control rod or CRD System that could affect scram time NMP2 3.1.4-2 Amendment 91, 132, 152

Control Rod Scram Accumulators 3.1.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2 Declare the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months associated control rod inoperable.

D. Required Action B.1 or D.1 ------------NOTE------------

C.1 and associated Not applicable if all Completion Time not inoperable control met. rod scram accumulators are associated with fully inserted control rods.

Place the reactor Immediately mode switch in the shutdown position.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify each control rod scram accumulator In accordance pressure is;::: 940 psig. with the Surveillance Frequency Control Pro ram NMP2 3.1.5-3 Amendment 9+, 152

Rod Pattern Control 3.1.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Nine or more OPERABLE B.1 ------------NOTE-----------

control rods not in RWM may be bypassed compliance with BPWS. as allowed by LCO 3.3.2.1.

.Suspend withdrawal of Immediately control rods.

AND B.2 Place the reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months mode switch in the shutdown position.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 Verify all OPERABLE control rods comply In accordance with with BPWS. the Surveillance Frequency Control Program NMP2 3.1.6-2 Amendment Q.:t-, 152

SLC System 3.1.7 3.1 REACTIVITY CONTROL SYSTEMS 3.1 .7 Standby Liquid Control (SLC) System LCO 3.1. 7 Two SLC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SLC subsystem A.1 Restore SLC subsystem 7 days inoperable. to OPERABLE status.

B. Two SLC subsystems B.1 Restore one SLC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable. subsystem to OPERABLE status.

c. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 Verify available volume of sodium In accordance with pentaborate solution is within the limits the Surveillance of Figure 3.1.7-1. Frequency Control Program (continued)

NMP2 3.1.7-1 Amendment 91, 125, 152

SLC System 3.1.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.7.2 Verify temperature of sodium pentaborate In accordance with solution is 2". 70°F. the Surveillance Frequency Control Program SR 3.1.7.3 Verify temperature of pump suction piping In accordance with up to the pump suction valve is;::: 70F. the Surveillance Frequency Control Program SR 3.1.7.4 Verify continuity of explosive charge. In accordance with the Surveillance Frequency Control Program SR 3.1.7.5 Verify the concentration of sodium In accordance with pentaborate in solution is within the the Surveillance limits of Figure 3.1.7-1. Frequency Control Program Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after water or sodium pentaborate is added to solution Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after solution temperature is restored to 2". 70°F SR 3.1.7.6 Verify each SLC subsystem manual, power In accordance with operated, and automatic valve in the flow the Surveillance path that is not locked, sealed, or Frequency Control otherwise secured in position is in the Program correct position, or can be aligned to the correct position.

(continued)

NMP2 3.1.7-2 Amendment 9-+, 152

SLC System 3.1.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.7.7 Verify each pump develops a flow rate In accordance

?. 41.2 gpm at a discharge pressure with the

?. 1335 psig. lnservice Testing Program SR 3.1.7.8 Verify flow through one SLC subsystem In accordance with the from pump into reactor pressure vessel. Surveillance Frequency Control Program SR 3.1.7.9 Verify all heat traced piping between In accordance with the storage tank and pump suction valve is Surveillance Frequency unblocked. Control Program Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after piping temperature is restored to

?. 70°F SR 3.1.7.10 Verify sodium pentaborate enrichment Prior to is~ 92 atom percent B-10. addition to SLC tank NMP2 3.1.7-3 Amendment 91, 111, 117, 123, 140, 143, 151, 152

SDV Vent and Drain Valves 3.1.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.8.1 -------------------------------NOTE ------------------------------

Not required to be met on vent and drain valves closed during periormance of SR 3.1.8.2.

Verify each SDV vent and drain valve is In accordance with open. the Surveillance Frequency Control Program SR 3.1.8.2 Cycle each SDV vent and drain valve to the In accordance with fully closed and fully open position. the Surveillance Frequency Control Program SR 3.1.8.3 Verify each SDV vent and drain valve: In accordance with the Surveillance

a. Closes in s; 30 seconds after receipt Frequency Control of an actual or simulated scram Program signal; and

b. Opens when the actual or simulated scram signal is reset.

NMP2 3.1.8-2 Amendment 9+, 152

APLHGR 3.2.1 3.2 POWER DISTRIBUTION LIMITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

LCO 3.2.1 All APLHGRs shall be less than or equal to the limits specified in the COLA.

APPLICABILITY: THERMAL POWER ~ 23% ATP.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Any APLHGR not within A.1 Restore APLHGR(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limits. within limits.

B. Required Action and B.1 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to< 23% ATP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify all APLHGRs are less than or equal Once within to the limits specified in the COLA. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after

~ 23% RTP In accordance with the Surveillance Frequency Control Program NMP2 3.2.1-1 Amendment 91, 140, 152

MCPR 3.2.2 3.2 POWER DISTRIBUTION LIMITS 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR)

LCO 3.2.2 All MCPRs shall be greater than or equal to the MCPR operating limits specified in the COLR.

APPLICABILITY: THERMAL POWER 2 23% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any MCPR not within A.1 Restore MCPR(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limits. within limits.

B. Required Action and B.1 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to< 23% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Verify all MCPRs are greater than or equal Once within to the limits specified in the COLA. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 223% ATP In accordance with the Surveillance Frequency Control Program (continued)

NMP2 3.2.2-1 Amendment 91, 140, 152

LHGR 3.2.3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 LINEAR HEAT GENERATION RATE (LHGR)

LCO 3.2.3 All LHGRs shall be less than or equal to the limits specified in the COLA.

APPLICABILITY: THERMAL POWER~ 23% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any LHGR not within A.1 Restore LHGR(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limits. within limits.

B. Required Action and B.1 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to< 23% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify all LHGRs are less than or equal to Once within the limits specified in the COLA. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after

23% ATP In accordance with the Surveillance Frequency Control Program NMP2 3.2.3-1 Amendment 91, 140, 152

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS

N0 TE -----------------------------------------------------------

1. Refer to Table 3.3.1.1-1 to determine which SRs apply for each RPS 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function Maintains RPS trip capability.

SURVEILLANCE FREQUENCY SR 3.3.1.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.2 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.3 --------------------------- NOTE-----------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER ~ 23% ATP.

Verify the absolute difference between In accordance with the average power range monitor (APRM) the Surveillance channels and the calculated power Frequency Control

2% RTP while operating at ~ 23% RTP. Program SR 3.3.1.1.4 --------------------------- NOTE-----------------------------

For Functions 1.a and 1.b, not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

NMP2 3.3.1.1-4 Amendment91, 92, 123, 140, 151, 152

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1. 1.5 Verify the source range monitor (SAM) and Prior to fully intermediate range monitor (IRM) channels Withdrawing overlap. SR Ms SR 3.3.1 .1.6 --------------------------- NOTE-----------------------------

Only required to be met during entry into MODE 2 from MODE 1.

Verify the IRM and APRM channels overlap. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.7 Calibrate the local power range monitors. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.8 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1 .1.9 Calibrate the trip units. In accordance with the Surveillance Frequency Control Program SR 3.3.1. 1. 10 -------------------------- NOTES----------------------------

1. For Function 2.a, not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE2.

2. For Function 2.e, the CHANNEL FUNCTIONAL TEST only requires toggling the appropriate outputs of In accordance with the APRM.

the Surveillance Frequency Control Perform CHANNEL FUNCTIONAL TEST.

Program (continued)

NMP2 3.3.1.1-5 Amendment Q1, 92, 151,152

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.11 Perform CHANNEL CALIBRATION In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.12 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.13 ----------------------------N 0 TES ----------------------------

1. Neutron detectors are excluded.

2. For Functions 1.a and 2.a, not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2.

3. For Function 2.e, the CHANNEL CALIBRATION only requires a verification of OPRM-Upscale setpoints in the APRM by the review of the "Show Parameters" display.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.14 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.15 Verify Turbine Stop Valve - Closure, and In accordance with Turbine Control Valve Fast Closure, Trip the Surveillance Oil Pressure - Low Functions are not Frequency Control bypassed when THERMAL POWER is~ 26% RTP. Program (continued)

NMP2 3.3.1.1-6 Amendment~. 152

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.16 Deleted SR 3.3.1.1.17 -------------------------- NOTES---------------------------

1. Function 2.f digital electronics are excluded.

2. For Functions 3 and 4, the sensor response time may be assumed to be the design sensor response time.

3. Deleted.

4. For Function 9, the RPS RESPONSE TIME is measured from start of turbine control valve fast closure.

Verify the RPS RESPONSE TIME is within limits.

In accordance with the Surveillance Frequency Control Program NMP2 3.3.1.1-7 Amendment 9+,-9-2, 152

SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS

-------------------N 0 TE -----------------------------------------------------------

Refer to Table 3.3.1.2-1 to determine which SRs apply for each applicable MODE or other specified condition.

SURVEILLANCE FREQUENCY SR 3.3.1.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.1.2.2 -------------------------- NOTES----------------------------

1. Only required to be met during CORE ALTERATIONS.

2. One SRM may be used to satisfy more than one of the following.

Verify an OPERABLE SRM detector is In accordance with located in: the Surveillance Frequency Control

a. The fueled region; Program

b. The core quadrant where CORE AL TERA TIONS are being performed when the associated SRM is included in the fueled region; and

c. A core quadrant adjacent to where CORE ALTERATIONS are being performed, when the associated SRM is included in the fueled region.

SR 3.3.1.2.3 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program (continued)

NMP2 3.3.1.2-3 Amendment 9+, 152

SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS (continued}

SURVEILLANCE FREQUENCY SA 3.3.1 .2.4 --------------------------- 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: In accordance with the Surveillance

a. ?: 3.0 cps with a signal to noise Frequency Control ratio ?: 2: 1; or Program

b. > 1.3 cps with a signal to noise ratio ?: 5: 1.

SR 3.3.1.2.5 --------------------------- NOTE-----------------------------

The determination of signal to noise ratio is 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.

Perform CHANNEL FUNCTIONAL TEST and In accordance with determination of signal to noise ratio. the Surveillance Frequency Control Program SR 3.3.1.2.6 --------------------------- NOTE-----------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after IRMs on Range 2 or below.

Perform CHANNEL FUNCTIONAL TEST and In accordance with determination of signal to noise ratio. the Surveillance Frequency Control Program (continued)

NMP2 3.3.1.2-4 Amendment 94-, 152

SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.1.2.7 -------------------------- NOTES----------------------------

1. Neutron detectors are excluded.

2. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after IRMs on Range 2 or below.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program NMP2 3.3.1.2-5 Amendment 9-1-,152

Control Rod Block Instrumentation 3.3.2.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. One or more Reactor E.1 Suspend control rod Immediately Mode Switch - Shutdown withdrawal.

Position channels inoperable. AND E.2 Initiate action to Immediately fully insert all insertable control rods in core cells containing one or more fuel assemblies.

SURVEILLANCE REQUIREMENTS

N0 TES ------------------------------------ ----------------------

1. Refer to Table 3.3.2.1-1 to determine which SRs apply for each Control Rod Block Function.

2. When an RBM 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains control rod block capability.

SURVEILLANCE FREQUENCY SR 3.3.2.1.1 --------------------------- NOTE-----------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after any control rod is withdrawn at

~ 10% RTP in MODE 2.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

NMP2 3.3.2.1-3 Amendment 9-+. 152

Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.1.2 --------------------------- NOTE-----------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after THERMAL POWER is$; 10% ATP in MODE 1.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.3 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2. 1.4 --------------------------- NOTE-----------------------------

Neutron detectors are excluded.

Verify the ABM: In accordance with the Surveillance

a. Low Power Range - Upscale Function is not Frequency Control bypassed when APRM Simulated Thermal Program Power is ~ 28% and < 63% ATP and a peripheral control rod is not selected.

b. Intermediate Power Range - Upscale Function is not bypassed when APRM Simulated Thermal Power is ~ 63% and

< 83% ATP and a peripheral control rod is not selected.

c. High Power Range - Upscale Function is not bypassed when APRM Simulated Thermal Power is ~ 83% RTP and a peripheral control rod is not selected.

(continued)

NMP2 3.3.2.1-4 Amendment 91, 123, 152

Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.1.5 Verify the RWM is not bypassed when In accordance with THERMAL POWER is::;; 10% RTP. the Surveillance Frequency Control Program SR 3.3.2.1.6 --------------------------- NOTE-----------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after reactor mode switch is in the shutdown position.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.7 --------------------------- NOTE-----------------------------

Neutron detectors are excluded.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.8 Verify control rod sequences input to the Prior to RWM are in conformance with BPWS. declaring RWM OPERABLE following loading of sequence into RWM NMP2 3.3.2.1-5 Amendment 94-, 152

Feedwater System and Main Turbine High Water Level Trip Instrumentation 3.3.2.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 --------------NOTE--------------

associated Completion Only applicable if Time not met. inoperable channel is the result of an inoperable feedwater pump breaker.

Remove affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months feedwater pump(s) from service.

C.2 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to< 23% ATP.

SURVEILLANCE REQUIREMENTS

N0 TE --------------------------------------------------------------

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided feedwater system and main turbine high water level trip capability is maintained.

SURVEILLANCE FREQUENCY SR 3.3.2.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.2.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

NMP2 3.3.2.2-2 Amendment 91, 140,152

Feedwater System and Main Turbine High Water Level Trip Instrumentation 3.3.2.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.2.3 Perform CHANNEL CALIBRATION. The In accordance with Allowable Value shall be ~ 203.8 inches. the Surveillance Frequency Control Program SR 3.3.2.2.4 Perform LOGIC SYSTEM FUNCTIONAL TEST, In accordance with including breaker and valve actuation. the Surveillance Frequency Control Program NMP2 3.3.2.2-3 Amendment 9+,152

PAM Instrumentation 3.3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Enter the Condition Immediately associated Completion referenced in Time of Condition C Table 3.3.3.1-1 for not met. the channel.

E. As required by E.1 Be in MODE3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Required Action D.1 and referenced in Table 3.3.3.1-1.

F. As required by F.1 Initiate action in Immediately Required Action D.1 accordance with and referenced in Specification 5.6.6.

Table 3.3.3.1-1.

SURVEILLANCE REQUIREMENTS

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

1. These SRs apply to each Function in Table 3.3.3.1-1, except where identified in the SR.

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the other required channel in the associated Function is OPERABLE.

SURVEILLANCE FREQUENCY SR 3.3.3.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program (continued)

NMP2 3.3.3.1-2 Amendment 9+,152

PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.3.1.2 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program NMP2 3.3.3.1-3 Amendment 91, 124,152

Remote Shutdown System 3.3.3.2 SURVEILLANCE REQUIREMENTS

N0 TE -----------------------------------------------------------

When an instrumentation 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE FREQUENCY SR 3.3.3.2. i Perform CHANNEL CHECK for each required In accordance with instrumentation channel that is normally the Surveillance energized. Frequency Control Program SR 3.3.3.2.2 Verify each required control circuit and In accordance with transfer switch is capable of performing the Surveillance the intended functions. Frequency Control Program SR 3.3.3.2.3 Perform CHANNEL CALIBRATION for each In accordance with required instrumentation channel. the Surveillance Frequency Control Program NMP2 3.3.3.2-2 Amendment 9+,152

EOC-RPT Instrumentation 3.3.4.1 SURVEILLANCE REQUIREMENTS

N 0 TE -------------------------------------------------------------

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains EOC-RPT trip capability.

SURVEILLANCE FREQUENCY SR 3.3.4.1.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.4. 1.2 Perform CHANNEL CALIBRATION. The In accordance with Allowable Values shall be: the Surveillance Frequency Control

a. TSV - Closure: ~ 7% closed; and Program

b. TCV Fast Closure, Trip Oil Pressure - Low: ? 465 psig.

SR 3.3.4. 1.3 Perform LOGIC SYSTEM FUNCTIONAL TEST, In accordance with including breaker actuation. the Surveillance Frequency Control Program SR 3.3.4.1.4 Verify TSV - Closure and TCV Fast Closure, In accordance with Trip Oil Pressure - Low Functions are not the Surveillance bypassed when THERMAL POWER is? 26% ATP. Frequency Control Program SR 3.3.4.1.5 ------------------------------ NOTE-----------------------------

Breaker arc suppression time may be assumed from the most recent performance of SR 3.3.4.1.6.

Verify the EOC-RPT SYSTEM RESPONSE TIME In accordance with is within limits. the Surveillance Frequency Control Program (continued)

NMP2 3.3.4.1-3 Amendment 91, 140,152

EOC-RPT Instrumentation 3.3.4.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.4.1.6 Determine RPT breaker arc suppression In accordance with time. the Surveillance Frequency Control Program NMP2 3.3.4.1-4 Amendment 9+,152

ATWS-RPT Instrumentation 3.3.4.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION Tl ME B. One Function with B.1 Restore AlWS-RPT trip 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ATWS-RPT trip capability.

capability not maintained.

c. Both Functions with C.1 Restore AlWS-RPT trip 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ATWS-RPT trip capability for one capability not Function.

maintained.

D. Required Action and D.1 Remove the associated 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion recirculation pump Time not met. breaker(s) from service.

OR 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 0.2 Be in MODE2.

SURVEILLANCE REQUIREMENTS

N0 TE -----------------------------------------------------------

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains A TWS-RPT trip capability.

SURVEILLANCE FREQUENCY SR 3.3.4.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program (continued)

NMP2 3.3.4.2-2 Amendment 9-+,152

ATWS-RPT Instrumentation 3.3.4.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.4.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.4.2.3 Calibrate the analog trip modules. In accordance with the Surveillance Frequency Control Program SR 3.3.4.2.4 Verify, for the Reactor Vessel Steam Dome In accordance Pressure - High Function, the low with the frequency motor generator trip is not Surveillance bypassed for> 29 seconds when THERMAL Frequency POWER is > 5% ATP. Control Program SR 3.3.4.2.5 Perform CHANNEL CALIBRATION. The In accordance Allowable Values shall be: with the Surveillance

a. Reactor Vessel Water Level - Low Low, Frequency Level 2: ~ 101.8 inches; and Control Program

b. Reactor Vessel Steam Dome Pressure - High: ::;; 1080 psig.

SR 3.3.4.2.6 Perform LOGIC SYSTEM FUNCTIONAL TEST, In accordance including breaker actuation. with the Su rvei Ilance Frequency Control Program NMP2 3.3.4.2-3 Amendment 9+,152

ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS

-------- N 0 TES -------------- --------------------------------------------

1. Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 3.e, 3.g, 3.h, and 3.i; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions other than 3.e, 3.g, 3.h, and 3.i, provided the associated Function or the redundant Function maintains ECCS initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.5 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.6 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program NMP2 3.3.5.1-8 Amendment 9+,152

RCIC System Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

N0 TES ------------------ ----------------------------------------

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 4 and 5; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1, 2, and 3 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.3 Calibrate the trip units. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program NMP2 3.3.5.2-3 Amendment 9-1-,152

Primary Containment Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS

------------------- N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.6.1-1 to determine which SRs apply for each Primary Containment Isolation 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.2 Deleted SR 3.3.6.1.3 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.4 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.5 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.6 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

NMP2 3.3.6.1-4 Amendment 91, 147,152

Primary Containment Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.6.1.7 ------------------------------- NOTE-----------------------------

The sensor response time may be assumed to be the design sensor response time.

Verify the ISOLATION SYSTEM RESPONSE TIME In accordance with is within limits. the Surveillance Frequency Control Program NMP2 3.3.6.1-5 Amendment 9+, 152

Secondary Containment Isolation Instrumentation 3.3.6.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.1.2 Declare associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months secondary containment isolation valves inoperable.

AND C.2.1 Place the associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months standby gas treatment (SGT) subsystem in operation.

OR C.2.2 Declare associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months SGT subsystem inoperable.

SURVEILLANCE REQUIREMENTS

--------------- --------------- N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.6.2-1 to determine which SRs apply for each Secondary Containment Isolation 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program (continued)

NMP2 3.3.6.2-2 Amendment 9-1-, 152

Secondary Containment Isolation Instrumentation 3.3.6.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.6.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program NMP2 3.3.6.2-3 Amendment 9+,152

CREF System Instrumentation 3.3.7.1 SURVEILLANCE REQUIREMENTS

--------------------- N0 TES ----------------------------------------------- -----------

1. Refer to Table 3.3.7.1-1 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains CREF initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.7.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SA 3.3.7.1.3 Calibrate the trip units. In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program NMP2 3.3.7.1-3 Amendment 9+,152

Mechanical Vacuum Pump Isolation Instrumentation 3.3.7.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Isolate the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion associated mechanical Time not met. vacuum pump(s).

OR C.2 Remove the associated 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months mechanical vacuum pump breaker(s) from service.

OR C.3 Isolate the main 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months steam lines.

OR C.4 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS

N0 TE ---------------------- ---- ---------------------------------

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided mechanical vacuum pump isolation capability is maintained.

SURVEILLANCE FREQUENCY SR 3.3. 7 .2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Proa ram SR 3.3.7.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

NMP2 3.3.7.2-2 Amendment 9+, 152

Mechanical Vacuum Pump Isolation Instrumentation 3.3.7.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.7.2.3 Perform CHANNEL CALIBRATION. The In accordance Allowable Value shall be ~ 3.6 x full with the power background. Surveillance Frequency Control Program SR 3.3.7.2.4 Perform LOGIC SYSTEM FUNCTIONAL TEST In accordance with including isolation valve and mechanical the Surveillance vacuum pump breakers actuation. Frequency Control Program NMP2 3.3.7.2-3 Amendment 9+, 152

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 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provided the associated Function maintains LOP initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.8.1.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.8.1.2 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.8.1.3 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program NMP2 3.3.8.1-2 Amendment 9+, 152

RPS Electric Power Monitoring - Logic 3.3.8.2 SURVEILLANCE REQUIREMENTS

N0 TE -----------------------------------------------------------

When an RPS electric power monitoring assembly is placed in an inoperable status solely for performance of required Surveillances, entry into the associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the other RPS electric power monitoring assembly for the associated RPS logic bus maintains trip capability.

SURVEILLANCE FREQUENCY SR 3.3.8.2.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.8.2.2 Perform CHANNEL CALIBRATION. The In accordance Allowable Values shall be: with the Surveillance

a. Overvoltage (with time delay set to Frequency Control

2.5 seconds) Program Bus A

: :;; 130.2 V Bus B:::;; 129.8 V

b. Undervoltage (with time delay set to

2.5 seconds)

Bus A:::::: 115.5 V Bus B : : : 114.2 V

c. Underfrequency (with time delay set to s; 2.5 seconds)

Bus A:::: 57.5 Hz Bus B 2 57.5 Hz SR 3.3.8.2.3 Perform a system functional test. In accordance with the Surveillance Frequency Control Program NMP2 3.3.8.2-4 Amendment 9+;-9-9, 152

RPS Electric Power Monitoring - Scram Solenoids 3.3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Initiate action to Immediately associated Completion fully insert all Time of Condition A or insertable control B not met in MODE 5 rods in core cells with any control rod containing one or withdrawn from a core more fuel assemblies.

cell containing one or more fuel assemblies.

SURVEILLANCE REQUIREMENTS

N0 TE -------------------------------------- ---------------------

When an RPS electric power monitoring assembly is placed in an inoperable status solely for performance of required Surveillances, entry into the associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the other RPS electric power monitoring assembly for the associated RPS scram solenoid bus maintains trip capability.

SURVEILLANCE FREQUENCY SR 3.3.8.3.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

NMP2 3.3.8.3-2 Amendment ff-1-,152

RPS Electric Power Monitoring - Scram Solenoids 3.3.8.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.8.3.2 Perform CHANNEL CALIBRATION. The In accordance with Allowable Values shall be: the Surveillance Frequency Control

a. Overvoltage (with time delay set to Program s 2.5 seconds)

Bus As 127.6 V Bus B s 127.6 V

b. Undervoltage (with time delay set to s 2.5 seconds)

Bus A ~ 113.0 V Bus B ~ 113.6 V

c. Underfrequency (with time delay set to s 2.5 seconds)

Bus A~ 57.5 Hz Bus B ~ 57.5 Hz SR 3.3.8.3.3 Perform a system functional test. In accordance with the Surveillance Frequency Control Program NMP2 3.3.8.3-3 Amendment 9+,-99, 152

Recirculation Loops Operating 3.4.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 ------------------------------ N0 TE-----------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after both recirculation loops are in operation.

Verify jet pump loop flow mismatch with In accordance both recirculation loops in operation is: with the Surveillance

a. $ 10% of rated core flow when Frequency Control operating at an effective core flow Program

< 70% of rated core flow; and

b. ::; 5% of rated core flow when operating at an effective core flow ~ 70% of rated core flow.

NMP2 3.4.1-3 Amendment Q..:1.,-92, 152

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

N0 TE -----------------------------------------------------------

Separate Condition entry is allowed for each FCV.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required A.1 Lock up the FCV. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months FCVs inoperable.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.2.1 Verify each FCV fails "as is" on loss of In accordance hydraulic pressure at the hydraulic unit. with the Surveillance Frequency Control Program (continued)

NMP2 3.4.2-1 Amendment 9-+, 152

FCVs 3.4.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.4.2.2 Verify average rate of each FCV movement In accordance is: with the Surveillance

a. ::; 11 % of stroke per second for Frequency Control opening; and Program

b. :::; 11 % of stroke per second for closing.

NMP2 3.4.2-2 Amendment 9+, 152

Jet Pumps 3.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 ----------------------------- NOTES-----------------------~----

1. Not required to be performed until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after associated recirculation loop is in operation.

2. Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after> 23% RTP.

Verify at least two of the following In accordance criteria (a, b, and c) are satisfied for with the each operating recirculation loop: Surveillance Frequency Control

a. Jet pump loop flow versus flow control Program valve position differs by $ 10% from established patterns.

b. Jet pump loop flow versus recirculation loop drive flow differs by $ 10% from established patterns.

c. Each jet pump diffuser to lower plenum differential pressure differs by $ 20%

from established patterns.

NMP2 3.4.3-2 Amendment 91, 140, 152

RCS Operational LEAKAGE 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met.

C.2 Be in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Pressure boundary LEAKAGE exists.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify RCS unidentified and identified In accordance LEAKAGE and unidentified LEAKAGE increase with the are within limits. SuNeillance Frequency Control Program NMP2 3.4.5-2 Amendment 9+, 152

RCS Leakage Detection Instrumentation 3.4.7 SURVEILLANCE REQUIREMENTS

----------------------------------------------N 0 TE ----------------------------------------------------------

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the other required leakage detection instrumentation is OPERABLE.

SURVEILLANCE FREQUENCY SR 3.4.7.1 Perform CHANNEL CHECK of required drywell In accordance atmospheric monitoring system. with the Surveillance Frequency Control Program SR 3.4.7.2 Perform CHANNEL FUNCTIONAL TEST of the In accordance drywall floor drain tank fill rate with the monitoring system. Surveillance Frequency Control Program SR 3.4.7.3 Perform source check of required drywell In accordance with atmospheric monitoring system. the Surveillance Frequency Control Program SR 3.4.7.4 Perform CHANNEL FUNCTIONAL TEST of required In accordance with drywell atmospheric monitoring system. the Surveillance Frequency Control Program SR 3.4.7.5 Perform CHANNEL CALIBRATION of required In accordance with leakage detection instrumentation. the Surveillance Frequency Control Program NMP2 3.4.7-3 Amendment 91 , 139, 152

RCS Specific Activity 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2.2.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months B.2.2.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 ---------------------------NOTE-------------------------------

Only required to be performed in MODE 1.

Verify reactor coolant DOSE In accordance with EQUIVALENT 1-131 specific activity is the Surveillance s; 0.2 µCi/gm. Frequency Control Program NMP2 3.4.8-2 Amendment 9+, 152

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 --------------------------- NOTE-----------------------------

Not required to be met until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after reactor steam dome pressure is less than the AHR cut-in permissive pressure.

Verify one AHR shutdown cooling subsystem In accordance with or recirculation pump is operating. the Surveillance Frequency Control Program SR 3.4.9.2 --------------------------- NOTE----------------------------- In accordance with Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the Surveillance reactor steam dome pressure is less Frequency Control than the AHR cut-in permissive pressure. Program Verify AHR shutdown cooling subsystem Locations susceptible to gas accumulation are sufficiently filled with water.

NMP2 3.4.9-3 Amendment 91, 150, 152

AHR Shutdown Cooling System - Cold Shutdown 3.4.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No AHR shutdown B.1 Verify reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in coolant circulating discovery of no operation. by an alternate reactor coolant method. circulation No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.2 Monitor reactor Once per hour coolant temperature and pressure.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.10.1 Verify one RHR shutdown cooling subsystem In accordance with or recirculation pump is operating. the Surveillance Frequency Control Program SR 3.4.10.2 Verify AHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program NMP2 3.4.10-2 Amendment 91, 150, 152

RCS PIT Limits 3.4.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. -----------NOTE-----------------

Required Action C.2 C.1 Initiate action to Immediately shall be completed if restore parameter(s) this Condition is to within limits.

entered.

AND Requirements of the C.2 Determine RCS is Prior to LCO not met in other acceptable for entering MODE 2 than MODES 1, 2, operation. or3 and 3.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.1 --------------------------- NOTE-----------------------------

Only required to be performed during RCS heatup and cooldown operations, and RCS system leakage and hydrostatic testing.

Verify: In accordance with the Surveillance

a. RCS pressure and RCS temperature are Frequency Control within the applicable limits specified Program in the PTLR;

b. RCS heatup and cooldown rates are within limits specified in the PTLR; and

c. RCS temperature change during system leakage and hydrostatic testing is maintained within limits specified in the PTLR.

(continued)

NMP2 3.4.11-2 Amendment 91, 145, 152

RCS PIT Limits 3.4.11 SURVEILLANCE REQUIREMENTS (continued}

SURVEILLANCE FREQUENCY SR 3.4.11.5 ---------------------------- NOTE-----------------------------

Only required to be met in single loop operation with THERMAL POWER :s 30% ATP or the operating jet pump loop flow :s 50%

rated jet pump loop flow.

Verify the difference between the bottom Once within 15 head coolant temperature and the RPV minutes prior coolant temperature is within limits specified in the to an increase PTLR. in THERMAL POWER or an increase in jet pump loop flow SR 3.4.11.6 ---------------------------- NOTE-----------------------------

Only required to be met in single loop operation when the idle recirculation loop is not isolated from the APV, and with THERMAL POWER :s 30% ATP or the operating jet pump loop flow s 50% rated jet pump loop flow.

Verify the difference between the reactor Once within 15 coolant temperature in the recirculation minutes prior loop not in operation and the RPV coolant o an increase temperature is within limits specified in the PTLR. in THERMAL POWER or an increase in jet pump loop flow SR 3.4.11.7 ---------------------------- NOTE-----------------------------

Only required to be performed when tensioning the reactor vessel head bolting studs.

Verify reactor vessel flange and head In accordance with flange temperatures are within limits specified in the Surveillance the PTLR. Frequency Control Program (continued)

NMP2 3.4.11-4 Amendment 91, 145, 152

RCS Prr Limits 3.4.11 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.11.8 ---------------------------- NOTE-----------------------------

Not required to be performed until 30 minutes after RCS temperatures 80°F in MODE 4.

Verify reactor vessel flange and head In accordance with flange temperatures are within limits specified in the Surveillance the PTLR. Frequency Control Program SR 3.4.11.9 ---------------------------- NOTE-----------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after RCS temperature s 90°F in MODE 4.

Verify reactor vessel flange and head In accordance with flange temperatures are within limits specified in the Surveillance the PTLR. Frequency Control Program NMP2 3.4.11-5 Amendment 91, 145,152

Reactor Steam Dome Pressure 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Reactor Steam Dome Pressure LCO 3.4.12 The reactor steam dome pressure shall be ::; 1035 psig.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor steam dome A.1 Restore reactor steam 15 minutes pressure not within dome pressure to limit. within limit.

8. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 Verify reactor steam dome pressure is In accordance with

1035 psig. the Surveillance Frequency Control Program NMP2 3.4.12-1 Amendment 9+, 152

ECCS - Operating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray In accordance with subsystem, locations susceptible to the Surveillance gas accumulation are sufficiently filled Frequency Control with water. Program SR 3.5.1.2 --------------------------- NOTE ----------------------------

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the residual heat removal cut-in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

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

Not required to be met for system vent paths opened under administrative control Verify each ECCS injection/spray subsystem manual, power operated, and automatic valve In accordance with in the flow path, that is not locked, the Surveillance sealed, or otherwise secured in position, Frequency Control is in the correct position. Program SR 3.5.1.3 Verify: In accordance with the Surveillance

a. For each ADS nitrogen receiver discharge Frequency Control header, the pressure is 2'. 160 psig; and Program

b. For each ADS nitrogen receiver tank, the pressure is 2'. 334 psig.

(continued)

NMP2 3.5.1-4 Amendment 91, 150, 152

ECCS - Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.4 Verify each ECCS pump develops the ln accordance specified flow rate with the specified with the developed head. lnservice Testing Program TOTAL SYSTEM FLOW RATE DEVELOPED HEAD LPCS 2 6350 gpm 2 284 psid LPCS A, B 2 7450 gpm 2 127 psid LPCIC 2 7450 gpm 2 140 psid HPCS 2 6350 gpm 2. 327 psid SR 3.5.1.5 -----------------------------NOTE-----------------------------

Vessel injection/spray may be excluded.

Verify each ECCS injection/spray subsystem In accordance with actuates on an actual or simulated the Surveillance automatic initiation signal. Frequency Control Program SR 3.5.1.6 -----------------------------NOTE------------------------------

Valve actuation may be excluded.

Verify the ADS actuates on an actual or In accordance with simulated automatic initiation signal. the Surveillance Frequency Control Program SR 3.5.1.7 -----------------------------NOTE------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify each required ADS valve actuator In accordance with strokes when manually actuated. the Surveillance Frequency Control Program (continued)

NMP2 3.5.1-5 Amendment 9+, 152

ECCS - Operating 3.5.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.5.1.8 -----------------------------NOTE------------------------------

1nstrumentation response time may be assumed to be the design instrumentation response time.

Verify the ECCS RESPONSE TIME for each ECCS In accordance with injection/spray subsystem is within limits. the Surveillance Frequency Control Program NMP2 3.5.1-6 Amendment 9-+, 152

ECCS - Shutdown 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action C.2 D.1 Initiate action to Immediately and associated restore secondary Completion Time not containment to met. OPERABLE status.

D.2 Initiate action to Immediately restore one standby gas treatment subsystem to OPERABLE status.

AND D.3 Initiate action to Immediately restore isolation capability in each required secondary containment penetration flow path not isolated.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for each required low pressure ECCS In accordance with injection/spray subsystem, the suppression the Surveillance pool water level is ~ 195 ft. Frequency Control Program (continued)

NMP2 3.5.2-2 Amendment 9-+,152

ECCS - Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for the required High Pressure Core In accordance with Spray (HPCS) System, the: the Surveillance Frequency Control

a. Suppression pool water level is Program

~ 195 ft; or

b. Condensate storage tank B water level is~ 26.9 ft.

SR 3.5.2.3 Verify, for each required ECCS injection/ In accordance with spray subsystem, locations susceptible to gas the Surveillance accumulation are sufficiently filled with water. Frequency Control Program SR 3.5.2.4 ----------------------------NOTE----------------------------------

One low pressure coolant injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned and not otherwise inoperable.

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

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

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

(continued)

NMP2 3.5.2-3 Amendment 91, 150, 152

ECCS - Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5 Verify each required ECCS pump develops the In accordance specified flow rate with the specified with the developed head. lnservice Testing TOTAL Program SYSTEM FLOW RATE DEVELOPED HEAD LPCS ;;::: 6350 gpm 2:: 284 psid LPCIA,B ;;::: 7450 gpm ;;::: 127 psid LPCIC ;;::: 7450 gpm ;;::: 140 psid HPCS ;;::: 6350 gpm ;;::: 327 psid SR 3.5.2.6 ----------------------------NOTE----------------------------------

Vessel injection/spray may be excluded.

Verify each required ECCS injection/spray In accordance with subsystem actuates on an actual or the Surveillance simulated automatic initiation signal. Frequency Control Program SR 3.5.2.7 ----------------------------NOTE----------------------------------

lnstrumentation response time may be assumed to be the design instrumentation response time.

Verify the ECCS RESPONSE TIME for each ECCS In accordance with injection/spray subsystem is within limits. the Surveillance Frequency Control Program NMP2 3.5.2-4 Amendment 9-+,152

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 Verify the RCIC System locations susceptible to In accordance with gas accumulations are sufficiently filled with water. the Surveillance Frequency Control Program SR 3.5.3.2 ---------------------------NOTE ------------------------------

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

Verify each RCIC System manual, power In accordance with operated, and automatic valve in the flow the Surveillance path, that is not locked, sealed, or Frequency Control otherwise secured in position, is in the Program correct position.

SR 3.5.3.3 --------------------------- NOTE ----------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure :s 1035 psig In accordance with and ~ 935 psig, the RCIC pump can develop a the Surveillance flow rate ~ 600 gpm against a system head Frequency Control corresponding to reactor pressure. Program SR 3.5.3.4 --------------------------- NOTE ----------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure :s 165 psig, In accordance with the RCIC pump can develop a flow rate the Surveillance

~ 600 gpm against a system head Frequency Control corresponding to reactor pressure. Program (continued)

NMP2 3.5.3-2 Amendment 91, 150,152

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS continued SU AVE ILLANCE FREQUENCY SR 3.5.3.5 --------------------------- NOTE ----------------------------

Vessel injection may be excluded.

Verify the RCIC System actuates on an In accordance with actual or simulated automatic initiation the Surveillance signal. Frequency Control Program NMP2 3.5.3-3 Amendment 9+,152

Primary Containment 3.6.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.1.3 ----------------------------NOTE-------------------------------

SR 3.6.1.1.2 may be performed in lieu of SR 3.6.1.1.3.

Verify, at an initial differential In accordance with pressure of<:: 3 psid: the Surveillance Frequency Control

a. The leakage rate through each Program drywall-to-suppression chamber bypass leak path containing suppression chamber-to-drywell vacuum breakers is less than or equal to the equivalent through an orifice 0.000648 ft2; and

b. The combined leakage rate through all four drywall-to-suppression chamber bypass leak paths containing suppression chamber-to-drywall vacuum breakers is less than or equal to the equivalent through an orifice 0.001296 ft2.

NMP2 3.6.1.1-3 Amendment 9-+, 152

Primary Containment Air Locks 3.6.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1 .2.1 -------------------------- NOTES----------------------------

1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

2. Results shall be evaluated against acceptance criteria applicable to SR 3.6.1 .1.1.

Perform required primary containment air In accordance lock leakage rate testing in accordance with 1O CFR 50 with 1O CFR 50 Appendix J Testing Program Appendix J Plan. Testing Program Plan SR 3.6.1.2.2 Verify only one door in the primary In accordance with containment air lock can be opened at a the Surveillance time. Frequency Control Program NMP2 3.6.1.2-5 Amendment B+,152

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.1 --------------------------- NOTE-----------------------------

Not required to be met when the 12 inch and 14 inch primary containment purge valves are open for inerting, de-inerting, pressure control, ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open, provided:

a) the Standby Gas Treatment (SGT)

System is OPERABLE; or b) the primary containment full flow line to the SGT System is isolated and one SGT subsystem is OPERABLE.

Verify each 12 inch and 14 inch primary In accordance with containment purge valve is closed. the Surveillance Frequency Control Program SR 3.6. 1.3.2 -------------------------- NOTES----------------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment isolation In accordance with manual valve and blind flange that is the Surveillance located outside primary containment and Frequency Control not locked, sealed, or otherwise secured Program and is required to be closed during accident conditions is closed.

(continued)

NMP2 3.6.1.3-10 Amendment Q.:t.,152

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1 .3.3 ------------------ -------- N 0 TES----------------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment isolation Prior to manual valve and blind flange that is entering MODE 2 located inside primary containment and or 3 from not locked, sealed, or otherwise secured MODE 4, if and is required to be closed during primary accident conditions is closed. containment was de-inerted while in MODE 4, if not performed within the previous 92 days SR 3.6.1.3.4 Verify continuity of the traversing In accordance with incore probe (TIP) shear isolation valve the Surveillance explosive charge. Frequency Control Program SR 3.6.1 .3.5 Verify the isolation time of each power In accordance operated, automatic PCIV, except MSIVs, with the is within limits. lnservice Testing Program (continued)

NMP2 3.6.1.3-11 Amendment 9+, 152

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.6 Perform leakage rate testing for each In accordance with primary containment purge valve with the Surveillance resilient seals. Frequency Control Program AND Once within 92 days after opening the valve SR 3.6.1.3.7 Verify the isolation time of each MSIV is In accordance

: 3 seconds and ~ 5 seconds. with the lnservice Testing Program SR 3.6.1.3.8 Verify each automatic PCIV actuates to In accordance with the isolation position on an actual or the Surveillance simulated isolation signal. Frequency Control Program SR 3.6.1.3.9 Verify a representative sample of reactor In accordance with instrumentation line EFCVs actuates to the Surveillance the isolation position on an actual or Frequency Control simulated instrument line break signal. Program SR 3.6.1.3.10 Remove and test the explosive squib from In accordance with each shear isolation valve of the TIP the Surveillance System. Frequency Control Program SR 3.6.1.3.11 Verify the leakage rate for the secondary In accordance containment bypass leakage paths is with 10 CFR 50 within the limits of Table 3.6.1.3-1 when Appendix J pressurized to 2:: 40 psig. Testing Program Plan (continued)

NMP2 3.6.1.3-12 Amendment 9-+,--Be, 152

Drywell and Suppression Chamber Pressure 3.6.1.4 3.6 CONTAINMENT SYSTEMS 3.6.1.4 Drywall and Suppression Chamber Pressure LCO 3.6.1.4 Drywett and suppression chamber pressure shalt be

~ 14.2 psia and :::; 15.45 psia.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywall or suppression A.1 Restore drywall and 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months chamber pressure not suppression chamber within limits. pressure to within limits.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.4.1 Verify drywell and suppression chamber In accordance with pressure is within limits. the Surveillance Frequency Control Program NMP2 3.6.1.4-1 Amendment 9-i,152

Drywell Air Temperature 3.6.1.5 3.6 CONTAINMENT SYSTEMS 3.6.1.5 Drywall Air Temperature LCO 3.6.1.5 Drywall average air temperature shall be ~ 150°F.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell average air A.1 Restore drywell 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months temperature not within average air limit. temperature to within limit.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.5.1 Verify drywell average air temperature is In accordance with within limit. the Surveillance Frequency Control Program NMP2 3.6.1.5-1 Amendment 9+,152

RHR Drywell Spray 3.6.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6. 1.6.1 Verify each AHR drywell spray subsystem In accordance with manual and power operated valve in the the Surveillance flow path that is not locked, sealed, or Frequency Control otherwise secured in position, is in the Program correct position or can be aligned to the correct position.

SR 3.6.1.6.2 Verify, by administrative means, that In accordance with each required AHR pump is OPERABLE. the Surveillance Frequency Control Program SR 3.6.1.6.3 Verify each drywell spray nozzle is Following unobstructed. maintenance that could result in nozzle blockage NMP2 3.6.1.6-2 Amendment 91, 122, 152

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.7.1 -------------------------- NOTES----------------------------

1. Not required to be met for vacuum breakers that are open during Surveillances.

2. Not required to be met for vacuum breakers open when performing their intended function.

Verify each vacuum breaker is closed. In accordance with the Surveillance Frequency Control Program SR 3.6.1.7.2 --------------------------- NOTE-----------------------------

Not required to be met for vacuum breaker 21SC*RV36B for the remainder of Cycle 9.

Perform a functional test of each vacuum In accordance with breaker. the Surveillance Frequency Control Program Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after any discharge of steam to the suppression chamber from the safety/relief valves SR 3.6.1.7.3 Verify the opening setpoint of each In accordance with vacuum breaker is$ 0.25 psid. the Surveillance Frequency Control Program NMP2 3.6.1.7-3 Amendment 91, 98, 108,152

Suppression Pool Average Temperature 3.6.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1 . 1 Verify suppression pool average In accordance with temperature is within the applicable the Surveillance limits. Frequency Control Program 5 minutes when performing testing that adds heat to the suppression pool NMP2 3.6.2.1-3 Amendment 9-+, 152

Suppression Pool Water Level 3.6.2.2 3.6 CONTAINMENT SYSTEMS 3.6.2.2 Suppression Pool Water Level LCO 3.6.2.2 Suppression pool water level shall be ~ 199 ft 6 inches and

201 ft APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Suppression pool water A.1 Restore suppression 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months level not within pool water level to limits. within limits.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.2.1 Verify suppression pool water level is In accordance with within limits. the Surveillance Frequency Control Program NMP2 3.6.2.2-1 Amendment f>>,152

AHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each AHR suppression pool cooling In accordance with subsystem manual and power operated valve the Surveillance in the flow path that is not locked, Frequency Control sealed, or otherwise secured in position, Program is in the correct position or can be aligned to the correct position.

SR 3.6.2.3.2 Verify each required AHR pump develops a In accordance flow rate 2". 7 450 gpm through the with the associated heat exchanger while operating lnservice in the suppression pool cooling mode. Testing Program SR 3.6.2.3.3 Verify AHR suppression pool cooling subsystem In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program NMP2 3.6.2.3-2 Amendment 91, 150, 152

AHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify each AHR suppression pool spray In accordance with subsystem manual and power operated valve the Surveillance in the flow path that is not locked, Frequency Control sealed, or otherwise secured in position, Program is in the correct position or can be aligned to the correct position.

SR 3.6.2.4.2 Verify each required RHR pump develops a In accordance flow rate ~ 450 gpm while operating in with the the suppression pool spray mode. lnservice Testing Program SR 3.6.2.4.3 Verify AHR suppression pool spray subsystem In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program NMP2 3.6.2.4-2 Amendment 91, 150, 152

Primary Containment Oxygen Concentration 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Primary Containment Oxygen Concentration LCO 3.6.3.2 The primary containment oxygen concentration shall be

< 4.0 volume percent.

APPLICABILITY: MODE 1 during the time period:

a. From 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 15% ATP following startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing THERMAL POWER to < 15% RTP prior to the next scheduled reactor shutdown.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment A.1 Restore oxygen 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months oxygen concentration concentration to not within limit. within limit.

B. Required Action and B.1 Reduce THERMAL POWER 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months associated Completion to~ 15% ATP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.2.1 Verify primary containment oxygen In accordance with concentration is within limits. the Surveillance Frequency Control Program NMP2 3.6.3.2-1 Amendment 9+, 152

Secondary Containment 3.6.4.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Secondary containment C.1 -----------NOTE-----------

inoperable during LCO 3.0.3 is not movement of recently irradiated applicable.

fuel assemblies in the secondary containment or during OPDRVs. Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

C.2 Initiate action to Immediately suspend OPDAVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify secondary containment vacuum is In accordance with

~ 0.25 inch of vacuum water gauge. the Surveillance Frequency Control Program SR 3.6.4.1.2 Verify all secondary containment In accordance with equipment hatches are closed and sealed. the Surveillance Frequency Control Program (continued)

NMP2 3.6.4.1-2 Amendment 91, 101, 152

Secondary Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.4.1.3 Verify one secondary containment access In accordance with door in each access opening is closed. the Surveillance Frequency Control Program SR 3.6.4.1.4 Verify the secondary containment can be In accordance with drawn down to ;: : : 0.25 inch of vacuum the Surveillance water gauge in :::;; 66. 7 seconds using one Frequency Control standby gas treatment (SGT) subsystem. Program SR 3.6.4.1.5 Verify the secondary containment can be In accordance with maintained ;: : : 0.25 inch of vacuum water the Surveillance gauge for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months using one SGT subsystem Frequency Control at a flow rate :::;; 2670 cfm. Program NMP2 3.6.4.1-3 Amendment B+, 152

SCI Vs 3.6.4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 -------------------------- NOTES----------------------------

1. Valves 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 In accordance with isolation manual valve and blind flange the Surveillance that is not locked, sealed, or otherwise Frequency Control secured and is required to be closed Program during accident conditions is closed.

SR 3.6.4.2.2 Verify the isolation time of each power In accordance with operated, automatic SCIV is within the Surveillance limits. Frequency Control Program SR 3.6.4.2.3 Verify each automatic SCIV actuates to In accordance with the isolation position on an actual or the Surveillance simulated automatic isolation signal. Frequency Control Program NMP2 3.6.4.2-4 Amendment 9+, 152

SGT System 3.6.4.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. (continued)

E.3 Initiate action to Immediately suspend OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for In accordance with

1O continuous hours with heaters the Surveillance operating. Frequency Control Program SR 3.6.4.3.2 Perform required SGT filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.6.4.3.3 Verify each SGT subsystem actuates on an In accordance with actual or simulated initiation signal. the Surveillance Frequency Control Program SR 3.6.4.3.4 Verify each SGT decay heat removal air In accordance with inlet valve can be opened. the Surveillance Frequency Control Program NMP2 3.6.4.3-3 Amendment 91, 101, 152

SW System and UHS 3.7.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 ------------------------------ NOTE-----------------------------

Not required to be met if SR 3.7.1.5 and SR 3.7.1.8 satisfied.

Verify the water temperature of the intake In accordance with tunnels is~ 38°F. the Surveillance Frequency Control Program SR 3.7.1.2 Verify the water level in the SW pump In accordance with intake bay is ~ 233.1 ft. the Surveillance Frequency Control Program SR 3.7.1.3 Verify the water temperature of In accordance with each SW subsystem supply header is~ 84°F. the Surveillance Frequency Control Program 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when supply header water temperature is

?.'. 78°F SR 3.7.1.4 Verify each required SW pump is in In accordance with operation. the Surveillance Frequency Control Program (continued)

NMP2 3.7.1-3 Amendment 91, 119,152

SW System and UHS 3.7.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.1.5 ------------------------------ NOTE-----------------------------

Not required to be met if SR 3. 7.1.1 satisfied.

Verify, for each intake deicer heater In accordance with division, the current of each required the Surveillance heater feeder cable is within the limit. Frequency Control Program SR 3.7.1.6 ------------------------------ NOTE-----------------------------

lsolation of flow to individual components does not render SW System inoperable.

Verify each SW subsystem manual, power In accordance with operated, and automatic valve in the flow the Surveillance path servicing safety related systems or Frequency Control components, that is not locked, sealed, or Program otherwise secured in position, is in the correct position.

SR 3.7.1.7 Verify each SW subsystem actuates on an In accordance with actual or simulated initiation signal. the Surveillance Frequency Control Program SR 3.7.1.8 -------------- ---------------- N0 TE-----------------------------

Not required to be met if SR 3.7.1.1 satisfied.

Verify, for each intake deicer heater In accordance with division, the resistance of each required the Surveillance heater feeder cable and associated heater Frequency Control elements is within the limit. Program NMP2 3.7.1-4 Amendment 9-+, 152

CREF System 3.7.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREF subsystems ------------------NOTE------------------

inoperable with safety LCO 3.0.3 is not applicable.

function not maintained during movement of recently irradiated fuel assemblies in F.1 Suspend movement of Immediately the secondary containment recently irradiated or during OPDRVs. fuel assemblies in the secondary containment.

One or more CREF AND subsystems inoperable due to inoperable CRE boundary F.2 Initiate action to suspend Immediately during movement of recently OPDRVs.

irradiated fuel assemblies in the secondary containment or during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Operate each CREF subsystem for 2 1 continuous In accordance with hour. the Surveillance Frequency Control Program SR 3.7.2.2 Perform required CREF System filter testing in In accordance accordance with the Ventilation Filter Testing with the VFTP Program (VFTP).

SR 3.7.2.3 Verify each CREF subsystem actuates on an actual In accordance with or simulated initiation signal. the Surveillance Frequency Control Program (continued)

NMP2 3.7.2-3 Amendment 91, 95, 97, 125, 126, 152

Control Room Envelope AC System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. Required Action and ------------------NOTE-------------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition C or D not met during movement of recently irradiated fuel H.1 Suspend movement of Immediately assemblies in the recently irradiated fuel secondary containment assemblies in the or during OPDRVs. secondary containment.

AND H.2 Initiate action to suspend OPDRVs. Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify each control room envelope AC In accordance with subsystem has the capability to remove the the Surveillance assumed heat load for the Main Control Room Frequency Control area and the Relay Room area. Program NMP2 3.7.3-4 Amendment~. 152

Main Condenser Offgas 3.7.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 ------------------------------ NOTE---------------------------

Not required to be performed until 31 days after any main steam line not isolated and SJAE in operation.

Verify the gross gamma activity rate of the In accordance with noble gases is ::;; 350,000 µCi/second after the Surveillance decay of 30 minutes.

Frequency Control Program Once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after a

50% increase in the nominal steady state fission gas release after factoring out increases due to changes in THERMAL POWER level NMP2 3.7.4-2 Amendment 9+, 152

Main Turbine Bypass System 3.7.5

3. 7 PLANT SYSTEMS 3.7.5 Main Turbine Bypass System LCO 3.7.5 The Main Turbine Bypass System shall be OPERABLE.

OR LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)," limits for an inoperable Main Turbine Bypass System, as specified in the COLR, are made applicable.

APPLICABILITY: THERMAL POWER~ 23% ATP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the A.1 Satisfy the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months LCO not met. requirements of the LCO.

B. Required Action and B.1 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to< 23% ATP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 Perform a system functional test. In accordance with the Surveillance Frequency Control Program SR 3.7.5.2 Verify the TURBINE BYPASS SYSTEM RESPONSE In accordance with TIME is within limits. the Surveillance Frequency Control Program NMP2 3.7.5-1 Amendment91, 140,152

Spent Fuel Storage Pool Water Level 3.7.6

3. 7 PLANT SYSTEMS 3.7.6 Spent Fuel Storage Pool Water Level LCO 3.7.6 The spent fuel storage pool water level shall be 2:: 22 ft 3 inches over the top of irradiated fuel assemblies seated in the spent fuel storage pool racks.

APPLICABILITY: During movement of irradiated fuel assemblies in the spent fuel storage pool, During movement of new fuel assemblies in the spent fuel storage pool with irradiated fuel assemblies seated in the spent fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Spent fuel storage A.1 ------------NOTE------------

pool water level not LCO 3.0.3 is not within limit. applicable.

Suspend movement of Immediately fuel assemblies in the spent fuel storage pool.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify the spent fuel storage pool water In accordance with level is : : : 22 ft 3 inches over the top of the Surveillance irradiated fuel assemblies seated in the Frequency Control spent fuel storage pool racks. Program NMP2 3.7.6-1 Amendments+, 152

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two required DGs E.1 Restore one required 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months inoperable. DG to OPERABLE status. OR 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if Division 3 DG is inoperable F. Required Action and F.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Associated Completion Time of Condition A, AND B, C, D, or E not met.

F.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months G. Three or more required G.1 Enter LCO 3.0.3. Immediately AC sources inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and In accordance with indicated power availability for each the Surveillance required otfsite circuit. Frequency Control Program (continued)

NMP2 3.8.1-5 Amendment 9+, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.2 ------------------------------ NOTE-----------------------------

All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

Verify each required DG starts from standby conditions and achieves:

a. In s; 1O seconds, voltage;;:: 3950 V for In accordance with Division 1 and 2 DGs and ;::: 3820 V for the Surveillance Division 3 DG, and frequency;;:: 58.8 Hz Frequency Control for Division 1 and 2 DGs and ;::: 58.0 Hz Program for Division 3 DG; and

b. Steady state voltage ;;:: 3950 V and s; 4370 V and frequency ;::: 58.8 Hz and s; 61.2 Hz.

(continued)

NMP2 3.8.1-6 Amendment 9-1-, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 ----------------------------- NOTES----------------------------

1. DG loadings may include gradual loading as recommended by the manufacturer.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4. This SR shall be preceded by, and immediately follow, without shutdown, a successful performance of SR 3.8.1.2.

Verify each required DG is synchronized and In accordance with loaded and operates for 2 60 minutes at a the Surveillance load 2 3960 kW and :::; 4400 kW for Division 1 Frequency Control and 2 DGs, and 2 2340 kW and $ 2600 kW for Program Division 3 DG.

SR 3.8.1.4 Verify each required day tank contains In accordance with 2 403 gal of fuel oil for Division 1 and 2 the Surveillance DGs and 2 282 gal for Division 3 DG. Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from In accordance with each required day tank. the Surveillance Frequency Control Program SR 3.8.1.6 Verify each required fuel oil transfer In accordance with subsystem operates to automatically the Surveillance transfer fuel oil from the storage tank to Frequency Control the day tank. Program (continued)

NMP2 3.8.1-7 Amendment 9+,152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.7 -------------------------------NOTES-----------------------------

1. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3 DG). However, credit may be taken for unplanned events that satisfy this SR.

2. If performed with DG synchronized with offsite power, it shall be performed within the power factor limit. 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 required DG rejects a load In accordance with greater than or equal to its associated the Surveillance single largest post-accident load, and Frequency Control following load rejection, the frequency is Program

~ 64.5 Hz for Division 1 and 2 DGs and

~ 66. 75 Hz for Division 3 DG.

(continued)

NMP2 3.8.1-8 Amendment 9~, 133, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.8 ----------------------------- NOTES----------------------------

1. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3 DG). However, credit may be taken for unplanned events that satisfy this SR.

2. 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 required DG operating within In accordance with the power factor limit does not trip and the Surveillance voltage is maintained: Frequency Control Program

a. ::; 4576 V during and following a load rejection of a load ~ 4400 kW for Division 1 and 2 DGs; and

b. ~ 5824 V during and following a load rejection of a load ~ 2600 kW for Division 3 DG.

(continued)

NMP2 3.8.1-9 Amendment 91, 133, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.9 ----------------------------- 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 Division 3 DG).

However, credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of In accordance with offsite power signal: the Surveillance Frequency Control

a. De-energization of emergency buses; Program

b. Load shedding from emergency buses for Divisions 1 and 2 only; and

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads in s; 13.20 seconds,

2. energizes auto-connected shutdown loads for Division 1 and 2 DGs only, through the associated automatic load sequence time delay relays,

3. maintains steady state voltage

~ 3950 V and s; 4370 V,

4. maintains steady state frequency

~ 58.8 Hz and s; 61 .2 Hz, and

5. supplies permanently connected and auto-connected shutdown loads for

5 minutes for Division 1 and 2 DGs and supplies permanently connected shutdown loads for

5 minutes for Division 3 DG.

(continued)

NMP2 3.8.1-10 Amendment 91, 133, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.10 ----------------------------- NOTES----------------------------

1. All DG starts may be preceded by an engine prelube period.

2. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3 DG). However, credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated Emergency In accordance with Core Cooling System (ECCS) initiation the Surveillance signal each required DG auto-starts from Frequency Control standby condition and: Program

a. In:=; 1O seconds after auto-start, achieves voltage ;::: 3950 V for Division 1 and 2 DGs and 2 3820 V for Division 3 DG, and frequency;::: 58.8 Hz for Division 1 and 2 DGs and 2 58.0 Hz for Division 3 DG;

b. Achieves steady state voltage ;::: 3950 V and :=; 4370 V and frequency 2 58.8 Hz and:=; 61.2 Hz;

c. Operates for 2 5 minutes;

d. Permanently connected loads remain energized from the offsite power system for Divisions 1 and 2 only; and

e. Emergency loads are auto-connected through the associated automatic load sequence time delay relays to the offsite power system for Divisions 1 and 2 only.

(continued)

NMP2 3.8.1-11 Amendment 91, 133, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.11 ------------------------------- NOTE-----------------------------

This Surveillance shall not be performed in MODE 1, 2, or 3 (not applicable to Division 3 DG). However, credit may be taken for unplanned events that satisfy this SR.

Verify each required DG's automatic trips In accordance with are bypassed on actual or simulated loss of the Surveillance voltage signal on the emergency bus Frequency Control concurrent with an actual or simulated ECCS Program initiation signal except:

a. Engine overspeed; and

b. Generator differential current.

(continued)

NMP2 3.8.1-12 Amendment 91, 133, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.12 ----------------------------- NOTES----------------------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. This Surveillance shall not be performed in MODE 1 or 2 unless the other two DGs are OPERABLE. If either of the other two DGs become inoperable, this Surveillance shall be suspended. However, credit may be taken for unplanned events that satisfy this SR.

3. 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 required DG operating within In accordance with the power factor limit operates for the Surveillance 2 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: Frequency Control Program

a. For 2 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded 2 4620 kW and

4840 kW for Division 1 and 2 DGs, and 2 2730 kW and ~ 2860 kW for Division 3 DG; and

b. For the remaining hours of the test loaded 2 3960 kW and ::::: 4400 kW for Division 1 and 2 DGs, and 2 2340 kW and~ 2600 kW for Division 3 DG.

(continued)

NMP2 3.8.1-13 Amendment 9+, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.13 ----------------------------- NOTES----------------------------

1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated 2 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded ~ 3960 kW for Division 1 and 2 DGs, and 2 2340 kW for Division 3 DG.

Momentary transients below the load limit do not invalidate this test.

2. All DG starts may be preceded by an engine prelube period.

Verify each required DG starts and In accordance with achieves: the Surveillance Frequency Control

a. In $ 1O seconds, voltage ~ 3950 V for Program Division 1 and 2 DGs and 2 3820 V for Division 3 DG, and frequency~ 58.8 Hz for Division 1 and 2 DGs and 2 58.0 Hz for Division 3 DG; and

b. Steady state voltage 2 3950 V and s 4370 V and frequency 2 58.8 Hz ands 61.2 Hz.

(continued)

NMP2 3.8.1-14 Amendment 9-1-, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.14 ------------------------------ NOTE-----------------------------

This Surveillance shall not be performed in MODE 1, 2, or 3 (not applicable to Division 3 DG). However, credit may be taken for unplanned events that satisfy this SR.

Verify each required DG: In accordance with the Surveillance

a. Synchronizes with offsite power source Frequency Control while loaded with emergency loads upon Program a simulated restoration of offsite power;

b. Transfers loads to offsite power source; and

c. Returns to ready-to-load operation.

SR 3.8.1.15 ------------------------------ N0 TE-----------------------------

This Surveillance shall not be performed in MODE 1, 2, or 3 (not applicable to Division 3 DG). However, credit may be taken for unplanned events that satisfy this SR.

Verify, with a DG operating in test mode In accordance with and connected to its bus, an actual or the Surveillance simulated ECCS initiation signal overrides Frequency Control the test mode by: Program

a. Returning DG to ready-to-load operation; and

b. Automatically energizing the emergency load from offsite power.

(continued)

NMP2 3.8.1-15 Amendment 91, 133, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.16 ------------------------------ 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 In accordance with block, for the Division 1 and 2 DGs only, the Surveillance is ~ 90% of the design interval for each Frequency Control automatic load sequence time delay relay. Program (continued)

NMP2 3.8.1-16 Amendment 9+, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.17 ----------------------------- 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 Division 3 DG).

However, credit may be taken for unplanned events that satisfy this SR.

Verify, on an actual or simulated loss of In accordance with offsite power signal in conjunction with an the Surveillance actual or simulated ECCS initiation signal: Frequency Control Program

a. De-energization of emergency buses;

b. Load shedding from emergency buses for Divisions 1 and 2 only; and

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads in s 1O seconds,

2. for Divisions 1 and 2, energizes auto-connected emergency loads through the associated automatic load sequence time delay relays and for Division 3, energizes auto-connected emergency loads,

3. maintains steady state voltage

3950 V and

:;; 4370 V,

4. maintains steady state frequency

58.8 Hz and::;; 61.2 Hz, and

5. supplies permanently connected and auto-connected emergency loads for

5 minutes.

(continued)

NMP2 3.8.1-17 Amendment 91, 133, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.18 ------------------------------ NOTE-----------------------------

All DG starts may be preceded by an engine prelube period.

Verify, when started simultaneously from In accordance with standby condition, each Division 1, 2, the Surveillance and 3 DG achieves, in ::; 1O seconds, voltage Frequency Control 2 3950 V for Division 1 and 2 DGs and Program 2 3820 V for Division 3 DG, and frequency 2 58.8 Hz for Division 1 and 2 DGs and 2 58.0 Hz for Division 3 DG.

NMP2 3.8.1-18 Amendment 9+, 152

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains: In accordance with the Surveillance

a. 2 50,000 gal of fuel for Division 1 DG Frequency Control and Division 2 DG; and Program

b. 2 35,342 gal of fuel for Division 3DG.

SR 3.8.3.2 Verify lube oil inventory is: In accordance with the Surveillance

a. 2 99 gal for Division 1 DG and Frequency Control Division 2 DG; and Program

b. 2 168 gal for Division 3 DG.

SR 3.8.3.3 Verify fuel oil properties of new and In accordance stored fuel oil are tested in accordance with the Diesel with, and maintained within the limits of, Fuel Oil the Diesel Fuel Oil Testing Program. Testing Program SR 3.8.3.4 Verify each DG air start receiver pressure In accordance with is: the Surveillance Frequency Control

a. 2 225 psig for Division 1 DG and Program Division 2 DG; and

b. 2 190 psig for Division 3 DG.

SR 3.8.3.5 Check for and remove accumulated water from In accordance with each fuel oil storage tank. the Surveillance Frequency Control Program NMP2 3.8.3-3 Amendment 9-+, 152

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is ~ 130 V In accordance with on float charge. the Surveillance Frequency Control Program SR 3.8.4.2 Verify no visible corrosion at battery In accordance with terminals and connectors. the Surveillance Frequency Control Program Verify battery connection resistance is

~ 20% above the resistance as measured during installation for intercell and terminal connections.

SR 3.8.4.3 Verify battery cells, cell plates, and In accordance with racks show no visual indication of physical the Surveillance damage or abnormal deterioration that could Frequency Control degrade battery performance. Program SR 3.8.4.4 Remove visible corrosion and verify battery In accordance with cell to cell and terminal connections are the Surveillance coated with anti-corrosion material. Frequency Control Program SR 3.8.4.5 Verify battery connection resistance is In accordance with

S 20% above the resistance as measured the Surveillance during installation for intercell and Frequency Control terminal connections. Program (continued)

NMP2 3.8.4-2 Amendment 9-1-, 152

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.6 Verify each required Division 1 and 2 In accordance with battery charger supplies ~ 300 amps and the the Surveillance required Division 3 battery charger Frequency Control supplies ~ 40 amps at ~ 130 V for Program

~ 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

SR 3.8.4.7 ----------------------------- NOTES----------------------------

1. The modified performance discharge test in SR 3.8.4.8 may be performed in lieu of the service test in SR 3.8.4. 7 provided the modified performance discharge test completely envelops the service test.

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 In accordance with supply, and maintain in OPERABLE status, the Surveillance the required emergency loads for the design Frequency Control duty cycle when subjected to a battery Program service test.

(continued)

NMP2 3.8.4-3 Amendment 91, 136, 152

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.4.8 ------------------------------ NOTE-----------------------------

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 ~ 80% of the In accordance with manufacturer's rating when subjected to a the Surveillance performance discharge test or a modified Frequency Control performance discharge test. Program 12 months when battery shows degradation or has reached 85%

of expected life with capacity

< 100% of manufacture r's rating 24 months when battery has reached 85% of the expected life with capacity

~ 100% of manufacturer's rating NMP2 3.8.4-4 Amendment 91, 136, 152

Battery Cell Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Declare associated Immediately associated Completion battery inoperable.

Time of Condition A not met.

One or more batteries with average electrolyte temperature of the representative cells

< 65°F.

One or more batteries with one or more battery cell parameters not within Table 3.8.6-1 Category C limits.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 Verify battery cell parameters meet In accordance Table 3.8.6-1 Category A limits. with the Surveillance Frequency Control Program (continued)

NMP2 3.8.6-2 Amendment 9+,152

Battery Cell Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.2 Verify battery cell parameters meet In accordance with Table 3.8.6-1 Category B limits. the Surveillance Frequency Control Program Once within 7 days after battery discharge

< 107 v Once within 7 days after battery overcharge

> 142 v SR 3.8.6.3 Verify average electrolyte temperature of In accordance with representative cells is ~ 65°F. the Surveillance Frequency Control Program NMP2 3.8.6-3 Amendment 9-+, 152

Inverters - Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct emergency UPS inverter In accordance with voltage, frequency, and alignment to the Surveillance 120 VAC uninterruptible panels. Frequency Control Program NMP2 3.8.7-2 Amendment 9+, 152

Distribution Systems - Operating 3.8.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two or more electrical F.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct breaker alignment and power In accordance with availability to required AC, DC, and the Surveillance 120 VAC uninterruptible electrical power Frequency Control distribution subsystems. Program NMP2 3.8.8-3 Amendment 9-1-, 152

Distribution Systems - Shutdown 3.8.9 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to Immediately suspend operations with a potential for draining the reactor vessel.

A.2.4 Initiate actions to Immediately restore required AC, DC, and 120 VAC uninterruptible electrical power distribution subsystems to OPERABLE status.

A.2.5 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and power In accordance with availability to required AC, DC, and the Surveillance 120 VAC uninterruptible electrical power Frequency Control distribution subsystems. Program NMP2 3.8.9-2 Amendment 9-+, 152

Refueling Equipment Interlocks 3.9.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 Perform CHANNEL FUNCTIONAL TEST on each of In accordance with the following required refueling equipment the Surveillance interlock inputs: Frequency Control Program

a. All-rods-in,

b. Refueling platform position,

c. Refueling platform fuel grapple, fuel-loaded,

d. Refueling platform monorail hoist, fuel-loaded,

e. Refueling platform frame-mounted hoist, fuel-loaded, and

f. Service platform hoist, fuel-loaded.

NMP2 3.9.1-2 Amendment 9-+, 152

Refuel Position One-Rod-Out Interlock 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Refuel Position One-Rod-Out Interlock LCO 3.9.2 The refuel position one-rod-out interlock shall be OPERABLE.

APPLICABILITY: MODE 5 with the reactor mode switch in the refuel position and any control rod withdrawn.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Refuel position one- A.1 Suspend control rod Immediately rod-out interlock withdrawal.

inoperable.

AND A.2 Initiate action to Immediately fully insert all insertable control rods in core cells containing one or more fuel assemblies.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.2.1 Verify reactor mode switch locked in refuel In accordance with position. the Surveillance Frequency Control Program (continued)

NMP2 3.9.2-1 Amendment 9+, 152

Refuel Position One-Rod-Out Interlock 3.9.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.9.2.2 --------------------------- NOTE-----------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after any control rod is withdrawn.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program NMP2 3.9.2-2 Amendment 9-i, 152

Control Rod Position 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Control Rod Position LCO 3.9.3 All control rods shall be fully inserted.

APPLICABILITY: When loading fuel assemblies into the core.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more control A.1 Suspend loading fuel Immediately rods not fully assemblies into the inserted. core.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 Verify all control rods are fully inserted. In accordance with the Surveillance Frequency Control Program NMP2 3.9.3-1 Amendment 9+, 152

Control Rod OPERABILITY - Refueling 3.9.5 3.9 REFUELING OPERATIONS 3.9.5 Control Rod OPERABILITY - Refueling LCO 3.9.5 Each withdrawn control rod shall be OPERABLE.

APPLICABILITY: MODE 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more withdrawn A.1 Initiate action to Immediately control rods fully insert inoperable. inoperable withdrawn control rods.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 ---------------------------N 0 TE------ -------------------------

Not required to be performed until 7 days after the control rod is withdrawn.

Insert each withdrawn control rod at least In accordance one notch. with the Surveillance Frequency Control Program SR 3.9.5.2 Verify each withdrawn control rod scram In accordance accumulator pressure is ~ 940 psig. with the Surveillance Frequency Control Program NMP2 3.9.5-1 Amendment 9-+, 152

RPV Water Level - Irradiated Fuel 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Reactor Pressure Vessel (RPV) Water Level - Irradiated Fuel LCO 3.9.6 RPV water level shall be 2:'. 22 ft 3 inches above the top of the RPV flange.

APPLICABILITY: During movement of irradiated fuel assemblies within the RPV.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RPV water level not A.1 Suspend movement of Immediately within limit. irradiated fuel assemblies within the RPV.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify RPV water level is 2! 22 ft 3 inches In accordance with above the top of the RPV flange. the Surveillance Frequency Control Program NMP2 3.9.6-1 Amendment 9+, 152

RPV Water Level - New Fuel or Control Rods 3.9.7 3.9 REFUELING OPERATIONS 3.9.7 Reactor Pressure Vessel (RPV) Water Level - New Fuel or Control Rods LCO 3.9.7 RPV water level shall be<:: 22 ft 3 inches above the top of irradiated fuel assemblies seated within the RPV.

APPLICABILITY: During movement of new fuel assemblies or handling of control rods within the RPV when irradiated fuel assemblies are seated within the RPV.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RPV water level not A.1 Suspend movement of Immediately within limit. new fuel assemblies and handling of control rods within the RPV.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.7.1 Verify RPV water level is <:: 22 ft 3 inches In accordance above the top of irradiated fuel assemblies with the seated within the RPV. Surveillance Frequency Control Program NMP2 3.9.7-1 Amendment 9-+, 152

AHR - High Water Level 3.9.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.8.1 Verify one AHR shutdown cooling subsystem In accordance with is operating. the Surveillance Frequency Control Program SR 3.9.8.2 Verify required AHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulations are the Surveillance sufficiently filled with water. Frequency Control Program NMP2 3.9.8-3 Amendment 91, 150, 152

AHR - Low Water Level 3.9.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.9.1 Verify one AHR shutdown cooling subsystem In accordance with is operating. the Surveillance Frequency Control Program SR 3.9.9.2 Verify AHR shutdown cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently the Surveillance filled with water. Frequency Control Program NMP2 3.9.9-3 Amendment 91, 150, 152

Reactor Mode Switch Interlock Testing 3.10.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3.1 Place the reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months mode switch in the shutdown position.

OR A.3.2 -----------NOTE-------------

Only applicable in MODE 5.

Place the reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months mode switch in the refuel position.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.2.1 Verify all control rods are fully inserted In accordance in core cells containing one or more fuel with the assemblies. Surveillance Frequency Control Program SR 3.10.2.2 Verify no CORE ALTERATIONS are in progress. In accordance with the Surveillance Frequency Control Program NMP2 3.10.2-2 Amendment 9+, 152

Single Control Rod Withdrawal - Hot Shutdown 3.10.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.3.1 Perform the applicable SRs for the required According to LC Os. the applicable SRs SR 3.10.3.2 ---------------------------N 0 TE--------------------------------

Not required to be met if SR 3.10.3.1 is satisfied for LCO 3.10.3.d.1 requirements.

Verify all control rods, other than the In accordance with control rod being withdrawn, in a five by the Surveillance five array centered on the control rod Frequency Control being withdrawn, are disarmed. Program SR 3.10.3.3 Verify all control rods, other than the In accordance with control rod being withdrawn, are fully the Surveillance inserted. Frequency Control Program NMP2 3.10.3-3 Amendment B+, 152

Single Control Rod Withdrawal - Cold Shutdown 3.10.4 ACTIONS {continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more of the B.1 Suspend withdrawal of Immediately above requirements not the control rod and met with the affected removal of associated control rod not CAD.

insertable.

B.2.1 Initiate action to Immediately fully insert all control rods.

OR B.2.2 Initiate action to Immediately satisfy the requirements of this LCO.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.4.1 Perform the applicable SRs for the required According to LCOs. applicable SRs SR 3.10.4.2 ------------------------------ NOTE-----------------------------

Not required to be met if SR 3.10.4.1 is satisfied for LCO 3.10.4.c.1 requirements.

Verify all control rods, other than the In accordance with control rod being withdrawn, in a five by the Surveillance five array centered on the control rod Frequency Control being withdrawn, are disarmed. Program (continued)

NMP2 3.10.4-3 Amendment 9+, 152

Single Control Rod Withdrawal - Cold Shutdown 3.10.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.4.3 Verify all control rods, other than the In accordance with control rod being withdrawn, are fully the Surveillance inserted. Frequency Control Program SR 3.10.4.4 ------------------------------ NOTE-----------------------------

Not required to be met if SR 3.10.4. 1 is satisfied for LCO 3.10.4.b.1 requirements.

Verify a control rod withdrawal block is In accordance with inserted. the Surveillance Frequency Control Program NMP2 3.10.4-4 Amendments+, 152

Single CRD Removal - Refueling 3.10.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.1 Initiate action to Immediately fully insert all control rods.

OR A.2.2 Initiate action to Immediately satisfy the requirements of this LCO.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.5.1 Verify all controls rods, other than the In accordance with control rod withdrawn for the removal of the Surveillance the associated CRD, are fully inserted. Frequency Control Program SR 3.10.5.2 Verify all control rods, other than the In accordance with control rod withdrawn for the removal of the Surveillance the associated CAD, in a five by five array Frequency Control centered on the control rod withdrawn for Program the removal of the associated CAD, are disarmed.

SR 3.10.5.3 Verify a control rod withdrawal block is In accordance with inserted. the Surveillance Frequency Control Program (continued)

NMP2 3.10.5-2 Amendment 9-1-, 152

Single CRD Removal - Refueling 3.10.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.5.4 Perform SR 3.1.1.1. According to SR 3.1.1.1 SR 3.10.5.5 Verify no other CORE ALTERATIONS are in In accordance with progress. the Surveillance Frequency Control Program NMP2 3.10.5-3 Amendment 9+, 152

Multiple Control Rod Withdrawal - Refueling 3.10.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3.1 Initiate action to Immediately fully insert all control rods in core cells containing one or more fuel assemblies.

OR A.3.2 Initiate action to Immediately satisfy the requirements of this LCO.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.6.1 Verify the four fuel assemblies are removed In accordance with from core cells associated with each the Surveillance control rod or CRD removed. Frequency Control Program SR 3.10.6.2 Verify all other control rods in core cells In accordance with containing one or more fuel assemblies are the Surveillance fully inserted. Frequency Control Program SR 3.10.6.3 ------------------------------ NOTE-----------------------------

Only required to be met during fuel loading.

Verify fuel assemblies being loaded are in In accordance with compliance with an approved spiral reload the Surveillance sequence. Frequency Control Program NMP2 3.10.6-2 Amendment 9-+, 152

SOM Test - Refueling 3.10.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.8.2 ------------------------------ NOTE-----------------------------

Not required to be met if SR 3.10.8.3 satisfied.

According to Perform the MODE 2 applicable SRs for the applicable LCO 3.3.2.1, Function 2 of Table 3.3.2.1-1. SRs SR 3.10.8.3 ------------------------------ NOTE-----------------------------

Not required to be met if SR 3.10.8.2 satisfied.

Verify movement of control rods is in During control compliance with the approved control rod rod movement sequence for the SOM test by a second licensed operator or other qualified member of the technical staff.

SR 3.10.8.4 Verify no other CORE ALTERATIONS are in In accordance with progress. the Surveillance Frequency Control Program (continued)

NMP2 3.10.8-3 Amendment 9-:1-, 152

SOM Test - Refueling 3.10.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.8.5 Verify each withdrawn control rod does not Each time the go to the withdrawn overtravel position. control rod is withdrawn to "full out" position Prior to satisfying LCO 3.10.8.c requirement after work on control rod or CAD System that could affect coupling SR 3.10.8.6 Verify CRD charging water header pressure In accordance with

940 psig. the Surveillance Frequency Control Program NMP2 3.10.8-4 Amendment 9+, 152

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Control Room Envelope Habitability Program (continued)

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences.

Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

5.5.14 Surveillance Frequency Control Program This program provides controls for the Surveillance Frequencies. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of the Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequency listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequency," Revision 1.

c. The provision of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

NMP2 5.5-13 Amendment~. 152

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 152 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-69 NINE MILE POINT NUCLEAR STATION. LLC EXELON GENERATION COMPANY. LLC DOCKET NO. 50-410 NINE MILE POINT NUCLEAR STATION, UNIT 2

1.0 INTRODUCTION

By application dated November 19, 2014, as supplemented by letters dated July 10, 2015, September 10, 2015, and September 24, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML14329A353, ML15191A013, ML15254A069 and ML15271A029, respectively), Exelon Generation Company, LLC (the licensee) requested changes to the Technical Specifications (TSs) for Nine Mile Point Unit 2 (NMP2). The letters provided clarifying information that did not expand the scope of the application and did not change the staff's original proposed no significant hazards consideration (NSHC) determination as published in the Federal Register(FR) on March 17, 2015 (80 FR 13906). The proposed change would modify the NMP2, TSs by relocating specific surveillance requirement (SR) frequencies to a licensee-controlled program (i.e., the Surveillance Frequency Control Program (SFCP)) in accordance with Nuclear Energy Institute (NEI) 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies" (ADAMS Accession No. ML071360456). The proposed change is consistent with the adoption of U.S. Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) Change Traveler TSTF-425, Revision 3, "Relocated Surveillance Frequencies to Licensee Control - RITSTF [Risk-Informed TSTF] Initiative 5b" (ADAMS Accession No. ML090850642). The FR notice published on July 6, 2009 (74 FR 31996), announced the availability of TSTF-425, Revision 3.

When implemented, TSTF-425, Revision 3, relocates most periodic frequencies of TS surveillances to the SFCP, and provides requirements for the new program in the Administrative Controls section of the TSs. All surveillance frequencies can be relocated except:

Frequencies that reference other approved programs for the specific interval (such as the In-Service Testing Program or the Primary Containment Leakage Rate Testing Program);

Frequencies that are purely event-driven (e.g., "each time the control rod is withdrawn to the 'full out' position");

Frequencies that are event-driven, but have a time component for performing the surveillance on a one-time basis once the event occurs (e.g., "within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after thermal power reaching;:::: 95% RTP" [rated thermal power]); and

Frequencies that are related to specific conditions (e.g., battery degradation, age and capacity) or conditions for the performance of a surveillance requirement (e.g.,

"drywell to suppression chamber differential pressure decrease").

The licensee proposed to add the SFCP to TS Section 5.0, "Administrative Controls." The SFCP describes the requirements for the program to control changes to the relocated surveillance frequencies. The TS Bases for each affected surveillance are revised to state that the frequency is controlled under the SFCP. Various editorial changes have been made to the Bases to facilitate the addition of the Bases changes. The proposed changes to the Administrative Controls sections of the TSs to incorporate the SFCP include a specific reference to NEI 04-10, Revision 1, as the basis for making any changes to the surveillance frequencies once they are relocated out of the TSs.

In a letter dated September 19, 2007 (ADAMS Accession No. ML072570267), the NRC staff approved NEI Topical Report (TR) NEI 04-10, Revision 1, as acceptable for referencing in licensing actions to the extent specified and under the limitations delineated in NEI 04-10, Revision 1, and the safety evaluation (SE) providing the basis for NRC acceptance of NEI 04-10, Revision 1.

Other changes and deviations from TSTF-425, are discussed in Section 3.3 of this SE.

2.0 REGULATORY EVALUATION

2.1 Applicable Commission Policy Statements In the "Final Policy Statement: Technical Specifications for Nuclear Power Plants," dated July 22, 1993 (58 FR 39132) the NRC addressed the use of Probabilistic Safety Analysis {PSA, currently referred to as Probabilistic Risk Assessment or PRA) in STS. In this 1993 publication, the NRC states:

The Commission believes that it would be inappropriate at this time to allow requirements which meet one or more of the first three criteria [of Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36] to be deleted from Technical Specifications based solely on PSA (Criterion 4). However, if the results of PSA indicate that Technical Specifications can be relaxed or removed, a deterministic review will be performed ....

The Commission Policy in this regard is consistent with its Policy Statement on "Safety Goals for the Operation of Nuclear Power Plants," 51 FR 30028, published on August 21, 1986. The Policy Statement on Safety Goals states in part, " ... probabilistic results should also be reasonably balanced and supported through use of deterministic arguments. In this way, judgments can be made ...

about the degree of confidence to be given these [probabilistic] estimates and assumptions. This is a key part of the process for determining the degree of

regulatory conservatism that may be warranted for particular decisions. This defense-in-depth approach is expected to continue to ensure the protection of public health and safety." ...

The Commission will continue to use PSA, consistent with its policy on Safety Goals, as a tool in evaluating specific line-item improvements to Technical Specifications, new requirements, and industry proposals for risk-based Technical Specification changes.

Approximately two years later the NRC provided additional detail concerning the use of PRA in the "Final Policy Statement: Use of Probabilistic Risk Assessment in Nuclear Regulatory Activities," dated August 16, 1995 (60 FR 42622). In this publication, the NRC states:

The Commission believes that an overall policy on the use of PRA methods in nuclear regulatory activities should be established so that the many potential applications of PRA can be implemented in a consistent and predictable manner that would promote regulatory stability and efficiency. In addition, the Commission believes that the use of PRA technology in NRC regulatory activities should be increased to the extent supported by the state-of-the-art in PRA methods and data and in a manner that complements the NRC's deterministic approach ....

PRA addresses a broad spectrum of initiating events by assessing the event frequency. Mitigating system reliability is then assessed, including the potential for multiple and common cause failures. The treatment therefore goes beyond the single failure requirements in the deterministic approach. The probabilistic approach to regulation is, therefore, considered an extension and enhancement of traditional regulation by considering risk in a more coherent and complete manner....

Therefore, the Commission believes that an overall policy on the use of PRA in nuclear regulatory activities should be established so that the many potential applications of PRA can be implemented in a consistent and predictable manner that promotes regulatory stability and efficiency. This policy statement sets forth the Commission's intention to encourage the use of PRA and to expand the scope of PRA applications in all nuclear regulatory matters to the extent supported by the state-of-the-art in terms of methods and data ....

Therefore, the Commission adopts the following policy statement regarding the expanded NRC use of PRA:

(1) The use of PRA technology should be increased in all regulatory matters to the extent supported by the state-of-the-art in PRA methods and data and in a manner that complements the NRC's deterministic approach and supports the NRC's traditional defense-in-depth philosophy.

(2) PRA and associated analyses (e.g., sensitivity studies, uncertainty analyses, and importance measures) should be used in regulatory matters, where

practical within the bounds of the state-of-the-art, to reduce unnecessary conservatism associated with current regulatory requirements, regulatory guides, license commitments, and staff practices. Where appropriate, PRA should be used to support the proposal for additional regulatory requirements in accordance with 10 CFR 50.109 (Backfit Rule). Appropriate procedures for including PRA in the process for changing regulatory requirements should be developed and followed. It is, of course, understood that the intent of this policy is that existing rules and regulations shall be complied with unless these rules and regulations are revised.

(3) PRA evaluations in support of regulatory decisions should be as realistic as practicable and appropriate supporting data should be publicly available for review.

(4) The Commission's safety goals for nuclear power plants and subsidiary numerical objectives are to be used with appropriate consideration of uncertainties in making regulatory judgments on the need for proposing and backfitting new generic requirements on nuclear power plant licensees.

2.2 Applicable Regulations Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls. These categories will remain in the NMP2, TSs.

Paragraph 50.36(c)(3) of 10 CFR states, "Surveillance requirements are requirements relating to test, calibration, or inspection 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 will be met." The FR notice published on July 6, 2009 (74 FR 31996),

which announced the availability of TSTF-425, Revision 3, states that the addition of the SFCP to the TSs provides the necessary administrative controls to require that surveillance frequencies relocated to the SFCP are conducted at a frequency 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 will be met. The FR notice also states that changes to surveillance frequencies in the SFCP are made using the methodology contained in NEI 04-10, Revision 1, including qualitative considerations, results of risk analyses, sensitivity studies and any bounding analyses, and recommended monitoring of structures, systems, and components (SSCs), and are required to be documented.

Existing regulatory requirements, such as 1O CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" (i.e., the Maintenance Rule), and 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," require licensee monitoring of surveillance test failures and implementing corrective actions to address such failures. Such failures can result in the licensee increasing the frequency at which a surveillance test is performed. In addition, the SFCP implementation guidance in NEI 04-10, Revision 1, requires monitoring the performance of SSCs for which surveillance frequencies are decreased to assure reduced testing does not adversely impact the SSCs.

2.3 Applicable NRC Regulatory Guides and Review Plans Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis" Revision 2, (ADAMS Accession No. ML100910006), describes an acceptable risk-informed approach for assessing the nature and impact of proposed permanent licensing-basis changes by considering engineering issues and applying risk insights. This regulatory guide also provides risk acceptance guidelines for evaluating the results of such evaluations.

RG 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," Revision 1, (ADAMS Accession No. ML100910008), describes an acceptable risk-informed approach specifically for assessing proposed TS changes.

RG 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 2, (ADAMS Accession No. ML090410014}, describes an acceptable approach for determining whether the quality of the PRA, in total or the parts that are used to support an application, is sufficient to provide confidence in the results, such that the PRA can be used in regulatory decision making for light water-reactors.

General guidance for evaluating the technical basis for proposed risk-informed changes is provided in Chapter 19, Section 19.2, "Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance" (ADAMS Accession No. ML071700658}, of NUREG-0800, "Standard Review Plan [SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition." Guidance on evaluating PRA technical adequacy is provided in the SRP, Chapter 19, Section 19.1, "Determining the Technical Adequacy of Probabilistic Risk Assessment for Risk-Informed License Amendment Requests After Initial Fuel Load," Revision 3, (ADAMS Accession No. ML12193A107). More specific guidance related to risk-informed TS changes is provided in SRP, Chapter 16, Section 16.1, "Risk-Informed Decisionmaking: Technical Specifications," Revision 1, (ADAMS Accession No. ML070380228), which includes changes to Completion Times as part of risk-informed decision making. Section 19.2 of the SRP references the same criteria as RG 1.177, Revision 1, and RG 1.174, Revision 2, and states that a risk-informed application should be evaluated to ensure that the proposed changes meet the following key principles:

The proposed change meets the current regulations, unless it explicitly relates to a requested exemption or rule change.

The proposed change is consistent with the defense-in-depth philosophy.

The proposed change maintains sufficient safety margins.

When proposed changes result in an increase CDF or risk, the increase(s) should be small and consistent with the intent of the Commission's Safety Goal Policy Statement.

The impact of the proposed change should be monitored using performance measurement strategies.

3.0 TECHNICAL EVALUATION

The licensee's adoption of TSTF-425, Revision 3, provides for administrative relocation of applicable surveillance frequencies, and provides for the addition of the SFCP to the Administrative Controls of TSs. TSTF-425, Revision 3, also requires the application of NEI 04-10, Revision 1, for any changes to surveillance frequencies within the SFCP. The licensee's application for the changes proposed in TSTF-425, Revision 3, included documentation regarding the PRA technical adequacy consistent with the requirements of RG 1.200, Revision 2. In accordance with NEI 04-10, Revision 1, PRA methods are used, in combination with plant performance data and other considerations, to identify and justify modifications to the surveillance frequencies of equipment at nuclear power plants. This is in accordance with guidance provided in RG 1.174, Revision 2, and RG 1.177, Revision 1, in support of changes to surveillance test intervals.

3.1 Review Methodology RG 1.177, Revision 1, identifies five key safety principles required for risk-informed changes to TSs. Each of these principles is addressed by NEI 04-10, Revision 1.

3.1.1 The Proposed Change Meets Current Regulations Section 50.36(c)(3) of 10 CFR requires that TSs include surveillances which are "requirements relating to test, calibration, or inspection to assure that necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The licensee is required by its TSs to perform surveillance tests, calibration, or inspection on specific safety-related equipment (e.g., reactivity control, power distribution, electrical, and instrumentation) to verify system operability. Surveillance frequencies are based primarily upon deterministic methods such as engineering judgment, operating experience, and manufacturer's recommendations. The licensee's use of NRG-approved methodologies identified in NEI 04-10, Revision 1, provides a way to establish risk-informed surveillance frequencies that complements the deterministic approach and supports the NRC's traditional defense-in-depth philosophy.

The SRs themselves are remaining in the TSs, as required by 10 CFR 50.36(c)(3). This change is analogous with other NRG-approved TS changes in which the SRs are retained in TSs, but the related surveillance frequencies are relocated to licensee-controlled documents, such as surveillances performed in accordance with the In-Service Testing Program and the Primary Containment Leakage Rate Testing Program. Thus, this proposed change complies with 10 CFR 50.36(c)(3) by retaining the requirements relating to test, calibration, or inspection 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 will be met.

The regulatory requirements in 10 CFR 50.65 and 10 CFR 50, Appendix B, and the monitoring required by NEI 04-10, Revision 1, ensure that surveillance frequencies are sufficient to assure that the requirements of 10 CFR 50.36 are satisfied and that any performance deficiencies will be identified and appropriate corrective actions taken. The licensee's SFCP ensures that SRs

specified in the TSs are performed at intervals sufficient to assure the above regulatory requirements are met. In light of the above, the NRC staff concludes that the proposed change meets the first key safety principle of RG 1.177 by complying with current regulations.

3.1.2 The Proposed Change Is Consistent With the Defense-in-Depth Philosophy The defense-in-depth philosophy (i.e., the second key safety principle of RG 1.177, Revision 1),

is maintained if:

A reasonable balance is preserved among prevention of core damage, prevention of containment failure, and consequence mitigation.

Over-reliance on programmatic activities to compensate for weaknesses in plant design is avoided.

System redundancy, independence, and diversity are preserved commensurate with the expected frequency, consequences of challenges to the system, and uncertainties (e.g., no risk outliers). (Because the scope of the proposed methodology is limited to revision of surveillance frequencies, the redundancy, independence, and diversity of plant systems are not impacted.)

Defenses against potential common cause failures are preserved, and the potential for the introduction of new common cause failure mechanisms is assessed.

Independence of barriers is not degraded.

Defenses against human errors are preserved.

The intent of the General Design Criteria in 10 CFR Part 50, Appendix A, is maintained.

TSTF-425, Revision 3, requires the application of NEI 04-10, Revision 1, for any changes to surveillance frequencies within the SFCP. NEI 04-10, Revision 1, uses both the core damage frequency (CDF) and the large early release frequency (LERF) metrics to evaluate the impact of proposed changes to surveillance frequencies. The guidance of RG 1.174, Revision 2, and RG 1.177, Revision 1, for changes to CDF and LERF is achieved by evaluation using a comprehensive risk analysis, which assesses the impact of proposed changes including contributions from human errors and common cause failures (CCFs). Defense-in-depth is also included in the methodology explicitly as a qualitative consideration outside of the risk analysis, as is the potential impact on detection of component degradation that could lead to an increased likelihood of CCFs. The NRC staff concludes that both the quantitative risk analysis and the qualitative considerations assure that a reasonable balance of defense-in-depth is maintained to ensure protection of public health and safety, thus satisfying the second key safety principle of RG 1.177, Revision 1.

3.1.3 The Proposed Change Maintains Sufficient Safety Margins The engineering evaluation that will be conducted by the licensee under the SFCP when frequencies are revised will assess the impact of the proposed frequency change to assure that sufficient safety margins are maintained. The guidelines used for making that assessment will include ensuring the proposed surveillance test frequency change is not in conflict with approved industry codes and standards or adversely affects any assumptions or inputs to the safety analysis, or, if such inputs are affected, justification is provided to ensure sufficient safety margin will continue to exist.

The design, operation, testing methods, and acceptance criteria for SSCs specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plants' licensing bases, including the Updated Final Safety Analysis Report and TS Bases, because these are not affected by changes to the surveillance frequencies.

Similarly, there is no impact to safety analysis acceptance criteria as described in the plant licensing basis. On this basis, the staff concludes that safety margins are maintained by the proposed methodology, and the third key safety principle of RG 1.177, Revision 1, is satisfied.

3.1.4 When Proposed Changes Result in an Increase in CDF or Risk. the Increases Should Be Small and Consistent with the Intent of the Commission's Safety Goal Policy Statement RG 1.177, Revision 1, provides a framework for evaluating the risk impact of proposed changes to surveillance frequencies which requires identification of the risk contribution from impacted surveillances, determination of the risk impact from the change to the proposed surveillance frequency, and performance of sensitivity and uncertainty evaluations. TSTF-425, Revision 3, provides for application of NEI 04-10, Revision 1, in the SFCP. NEI 04-10, Revision 1, satisfies the intent of RG 1.177, Revision 1, guidance for evaluation of the change in risk, and for assuring that such changes are small by providing the technical methodology to support risk-informed TSs for control of surveillance frequencies.

3.1.4.1 Quality of the PRA The quality of the licensee's PRA must be commensurate with the safety significance of the proposed TS change and the role the PRA plays in justifying the change. That is, the higher change in risk or the greater the uncertainty in that risk from the requested TS change, or both, the more rigor that must go into ensuring the quality of the PRA.

RG 1.200, Revision 2, provides regulatory guidance for assessing the technical adequacy of a PRA. The current revision (i.e., Revision 2) of this RG endorses (with clarifications and qualifications) the use of (1) the American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) RA-Sa-2009, "Addenda to ASME RA-S-2008 Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications" (i.e., the PRA Standard), (2) NEI 00-02, "PRA Peer Review Process Guidance" (ADAMS Accession Nos. ML061510619 and ML063390593), and (3) NEI 05-04, "Process for Performing Internal Events PRA Peer Reviews Using the ASME/ANS PRA Standard" (ADAMS Accession No. ML083430462).

The licensee has performed an assessment of the PRA models used to support the SFCP using the guidance of RG 1.200, Revision 2, to assure that the PRA models are capable of determining the change in risk due to changes to surveillance frequencies of SSCs, using plant-specific data and models. Capability Category II of the endorsed PRA standard is the target capability level for supporting requirements for the internal events PRA for this application. Any identified deficiencies to those requirements are assessed further to determine any impacts to proposed decreases to surveillance frequencies, including the use of sensitivity studies where appropriate, in accordance with NEI 04-10, Revision 1.

An internal events PRA peer review was performed in 2009, which, as clarified in response to PRA RAI 1 (ADAMS Accession Number ML15191A013), was performed against the latest PRA standard ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2. The licensee stated that the peer review resulted in 18 findings, which did not meet Capability Category II, and 34 suggestions that met Capability Category II. In the LAR the licensee submitted all peer review Facts and Observations (F&Os) that were not addressed. In response to PRA RAI 2, the licensee provided the list of F&Os applicable to the TSTF-425 application. The NRC staff reviewed (1) the summary of the peer review finding, (2) the licensee's resolution to the finding, and (3) the licensee's assessment of the impact on this application for the submitted F&Os to ensure that any deficiency in not meeting Capability Category II will be addressed and dispositioned for each surveillance frequency evaluation per the NEI 04-10 methodology. The NRC staffs assessment for the F&Os is provided below.

F&O 1-1, related to Supporting Requirement DA-C6, was created because the licensee did not include demands from causes other than surveillance tests in its plant specific estimation of demands on standby components. The Supporting Requirement directs the licensee to consider, in addition to surveillance tests, maintenance acts and operational demands. The NRC staff concludes that the inclusion of all of the sources of demands on standby components would assist the licensee in the estimation of the probability of failure on demand; however, outside of surveillance tests, which the licensee considered, this Supporting Requirement would minimally impact the calculation of change in CDF or LERF due to surveillance interval extensions.

F&O 2-5, related to Supporting Requirement DA-01, was created because the peer review team observed that the licensee's documentation stated that a Bayesian analysis was not done when there are no plant-specific failures. The licensee stated that it updated the model and documentation with Bayesian analysis for zero events down to failure rates on the order of 1E-3.

The licensee further states that it will continue to perform the Bayesian update for events with zero plant specific failures. Since the licensee has addressed the concern over Bayesian analysis for no observed plant failures and included the updated information in its best practices, the NRC staff finds the disposition acceptable for the application.

F&O 2-6, related to Supporting Requirement DA-04, was created because the peer review team did not find documentation that the licensee analyzed inconsistencies between the prior distribution and the plant-specific data in its Bayesian analysis. In response to the F&O, the licensee stated that it performed a review for inconsistencies and a few distributions were identified as potentially inconsistent. For these cases the licensee manipulated the prior distribution to be more representative of plant data; therefore, the NRC concludes that the licensee has properly addressed the F&O for this application.

F&O 5-2, related to Supporting Requirement IE-A6, was created because the licensee did not include routine system alignments in its calculation of initiating event frequencies. In the licensee's disposition, the licensee indicated that it performed a systematic evaluation that considered routine system alignments and provided documentation in the initiating events notebook. Therefore the NRC staff does not expect this to impact the determination of safety related component failure rates or establishment of surveillance intervals.

F&O 6-5, related to Supporting Requirement AS-C1, was created because the peer review team observed that the licensee's Accident Sequence notebook did not contain the event tree top event fault trees. Supporting Requirement AS-C1 requires proper documentation to support the peer review and facilitate PRA upgrades. The licensee stated that this documentation issue will be corrected. As this is a documentation concern, the NRC staff concludes that this would not impact the risk calculations to support changes to surveillance test intervals.

Based on the licensee's assessments using the currently applicable PRA standard and revision of RG 1.200, the NRC staff concludes that the level of PRA quality, combined with the proposed evaluation and disposition of gaps, is sufficient to support the evaluation of changes proposed to surveillance frequencies within the SFCP, and is consistent with Regulatory Position 2.3.1 of RG 1.177, Revision 1.

3.1.4.2 Scope of the PRA The licensee is required to evaluate each proposed change to a relocated surveillance frequency using the guidance contained in NEI 04-10, Revision 1, to determine its potential impact on risk (CDF and LERF) from internal events, fires, seismic, other external events, and shutdown conditions. In cases where a PRA of sufficient scope or quantitative risk models were unavailable, the licensee uses bounding analyses, or other conservative quantitative evaluations. A qualitative screening analysis may be used when the surveillance frequency impact on plant risk is shown to be negligible or zero.

NMP2 has an internal events PRA model, which it will use to perform quantitative evaluations to support the development of changes to surveillance frequencies in the SFCP, in accordance with NEI 04-10, Revision 1. In Section 2.3 of the LAR, "External Event Considerations," the licensee stated that external hazards were evaluated in the Individual Plant Examination of External Events (IPEEE). Internal fire events were addressed by using the EPRI Fire Induced Vulnerability Evaluation (FIVE) methodology. The licensee noted that the IPEEE fire model was incorporated into the internal events PRA model in a 2009 PRA update. In section 2.3 of the LAR, the licensee stated that it does not have a seismic PRA and that the IPEEE seismic evaluations used the Electronic Power Research Institute (EPRI) Seismic Margins Analysis (SMA) methodology. The licensee stated that high winds, floods, and other (HFO) external hazards were determined in the NMP2 IPEEE to be negligible contributors to overall plant risk.

Further, the licensee indicated that for the external hazards for which there is no PRA model, a qualitative or a bounding approach will be performed to provide justification for the acceptability of the proposed test interval change. The licensee's plan on addressing the fire risk and external events through use of qualitative or bounding analysis is an acceptable approach in accordance with NEI 04-10, Revision 1.

In the response to PRA RAI 3, provided in licensee's letter dated July 10, 2015, the licensee explained that it does not have a shutdown PRA model. The licensee further stated that changes to surveillance frequencies under the SFCP will consider low power and shutdown events in accordance with NEI 04-10, Revision 1, Section 4.0, Step 10. The NRC staff finds the licensee's plan to address low power and shutdown events through use of qualitative or bounding analyses acceptable, consistent with NEI 04-10, Revision 1, Section 4.0, Step 10.

Thus, the NRC staff concludes that through the application of NEI 04-10, Revision 1, the licensee's evaluation methodology is sufficient to ensure the scope of the risk contribution of each surveillance frequency change is properly identified for evaluation and is consistent with Regulatory Position 2.3.2 of RG 1.177, Revision 1.

3.1.4.3 PRA Modeling The licensee's methodology includes the determination of whether the SSCs affected by a proposed change to a surveillance frequency are modeled in the PRA. Where the SSC is directly or implicitly modeled, a quantitative evaluation of the risk impact may be carried out.

The methodology adjusts the failure probability of the impacted SSCs, including any impacted CCF modes, based on the proposed change to the surveillance frequency. Where the SSC is not modeled in the PRA, bounding analyses are performed to characterize the impact of the proposed change to the surveillance frequency. Potential impacts on the risk analyses due to screening criteria and truncation levels are addressed by the requirements for PRA technical adequacy consistent with guidance contained in RG 1.200, Revision 2, and by sensitivity studies identified in NEI 04-10, Revision 1.

Thus, the staff concludes that through the application of NEI 04-10, Revision 1, the NMP2, PRA modeling is sufficient to ensure an acceptable evaluation of risk for the proposed changes in surveillance frequency, and is consistent with Regulatory Position 2.3.3 of RG 1.177, Revision 1.

3.1.4.4 Assumptions for Time Related Failure Contributions The failure probabilities of SSCs modeled in PRAs may include a standby time-related contribution and a cyclic demand-related contribution. In Section 2.2.4 of Attachment 2 to the LAR, the licensee explained that the standby time-related contribution evaluation will be performed. The criteria in NEI 04-10, Revision 1, adjusts the time-related failure contribution of SSCs affected by the proposed change to a surveillance frequency. This is consistent with RG 1.177, Revision 1, Section 2.3.3, which permits separation of the failure rate contributions into demand and standby for evaluation of SRs. If the available data do not support distinguishing between the time-related failures and demand failures, then the change to surveillance frequency is conservatively assumed to impact the total failure probability of the SSC, including both standby and demand contributions. The SSC failure rate (per unit time) is assumed to be unaffected by the change in test frequency, such that the failure probability is assumed to increase linearly with time, and will be confirmed by the required monitoring and feedback implemented after the change in surveillance frequency is implemented. The NEI 04-10 process also requires consideration of qualitative sources of information with regards to potential impacts of test frequency on SSC performance, including industry and plant-specific operating experience, vendor recommendations, industry standards, and code-specified test

intervals. Thus the process is not reliant upon risk analyses as the sole basis for the proposed changes.

The potential benefits of a reduced surveillance frequency, including reduced downtime and reduced potential for restoration errors, test-caused transients, and test-caused wear of equipment, are identified qualitatively, but not quantitatively assessed. Thus, the NRC staff concludes that through the application of NEI 04-10, Revision 1, the licensee has employed reasonable assumptions with regard to extensions of surveillance test intervals, and is consistent with Regulatory Position 2.3.4 of RG 1.177, Revision 1.

3.1.4.5 Sensitivity and Uncertainty Analyses By having the TSs require that changes to the frequencies listed in the SFCP be made in accordance with NEI 04-10, Revision 1, the licensee will be required to have sensitivity studies to assess the impact of uncertainties from key assumptions of the PRA, uncertainty in the failure probabilities of the affected SSCs, impact on the frequency of initiating events, and any identified deviations from Capability Category II of the PRA standard. Where the sensitivity analyses identify a potential impact on the proposed change, revised surveillance frequencies are considered, along with any qualitative considerations that may bear on the results of such sensitivity studies. The licensee will also be required to perform monitoring and feedback of SSC performance once the revised surveillance frequencies are implemented. Thus, the NRC staff concludes that through the application of NEI 04-10, Revision 1, the licensee has appropriately considered the possible impact of PRA model uncertainty and sensitivity to key assumptions and model limitations and is consistent with Regulatory Position 2.3.5 of RG 1.177, Revision 1.

3.1.4.6 Acceptance Guidelines The licensee will be required to quantitatively evaluate the change in total risk (including internal and external events contributions) in terms of CDF and LERF for both the individual risk impact of a proposed change in surveillance frequency and the cumulative impact from all individual changes to surveillance frequencies using the guidance contained in NEI 04-10, Revision 1, in accordance with the TS SFCP. Each individual change to surveillance frequency must show a risk impact below 1E-6 per year for change to CDF, and below 1E-7 per year for change to LERF. These changes to CDF and LERF are consistent with the acceptance criteria of RG 1.174, Revision 2, for very small changes in risk. Where the RG 1.174, Revision 2, acceptance criteria are not met, the process either considers revised surveillance frequencies which are consistent with RG 1.174, Revision 2, or the process terminates without permitting the proposed changes. Where quantitative results are unavailable for comparison with the acceptance guidelines, appropriate qualitative analyses are required to demonstrate that the associated risk impact of a proposed change to surveillance frequency is negligible or zero.

Otherwise, bounding quantitative analyses are required which demonstrate the risk impact is at least one order of magnitude lower than the RG 1.174, Revision 2, acceptance guidelines for very small changes in risk. In addition to assessing each individual SSC surveillance frequency change, the cumulative impact of all changes must result in a risk impact less than 1E-5 per year for change to CDF, and less than 1E-6 per year for change to LERF, and the total CDF and total LERF must be reasonably shown to be less than 1E-4 per year and 1E-5 per year,

respectively. These values are consistent with the acceptance criteria of RG 1.174, Revision 2, as referenced by RG 1.177, Revision 1, for changes to surveillance frequencies.

Consistent with the NRC's SE dated September 19, 2007, for NEI 04-10, Revision 1, the licensee is required to calculate the total change in risk (i.e., the cumulative risk) by comparing a baseline model that uses failure probabilities based on surveillance frequencies prior to being changed per the SFCP to a revised model that uses failure probabilities based on the changed surveillance frequencies. The NRC staff further notes that the licensee includes a provision to exclude the contribution to cumulative risk from individual changes to surveillance frequencies associated with insignificant risk increases (i.e., less than 5E-8 CDF and 5E-9 LERF) once the baseline PRA models are updated to include the effects of the revised surveillance frequencies.

The quantitative acceptance guidance of RG 1.174, Revision 2, is supplemented by qualitative information to evaluate the proposed changes to surveillance frequencies, including industry and plant-specific operating experience, vendor recommendations, industry standards, the results of sensitivity studies, and SSC performance data and test history. The final acceptability of the proposed change is based on all of these considerations and not solely on the PRA results. Post implementation performance monitoring and feedback are also required to assure continued reliability of the components. The licensee's application of NEI 04-10, Revision 1, provides acceptable methods for evaluating the risk increase associated with proposed changes to surveillance frequencies, consistent with Regulatory Position 2.4 of RG 1.177, Revision 1.

Therefore, the NRC staff concludes that the proposed methodology satisfies the fourth key safety principle of RG 1.177, Revision 1, by assuring any increase in risk is small consistent with the intent of the Commission's Safety Goal Policy Statement.

3.1.5 The Impact of the Proposed Change Should Be Monitored Using Performance Measurement Strategies The licensee's adoption of TSTF-425, Revision 3, requires application of NEI 04-10, Revision 1, in the SFCP. NEI 04-10, Revision 1, requires performance monitoring of SSCs whose surveillance frequencies have been revised as part of a feedback process to assure that the change in test frequency has not resulted in degradation of equipment performance and operational safety. The monitoring and feedback includes consideration of Maintenance Rule monitoring of equipment performance. In the event of SSC performance degradation, the surveillance frequency will be reassessed in accordance with the methodology, in addition to any corrective actions which may be required by the Maintenance Rule. The performance monitoring and feedback specified in NEI 04-10, Revision 1, is sufficient to reasonably assure acceptable SSC performance and is consistent with Regulatory Position 3.2 of RG 1.177, Revision 1. Thus, the NRC staff concludes that the fifth key safety principle of RG 1.177, Revision 1, is satisfied.

3.2 Addition of Surveillance Frequency Control Program to Administrative Controls The licensee proposed including the SFCP and specific requirements into the NMP2, TSs, Section 5.5.14, as follows:

Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure that the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequency listed in the Surveillance Frequency Controlled Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the frequencies established in the Surveillance Frequency Control Program.

The proposed program is consistent with the model application of TSTF-425, and therefore, the NRC staff concludes that it is acceptable.

3.3 Deviations from TSTF-425 and Other Changes 3.3.1 Revised Clean TS Pages In its submittal dated November 19, 2014, the licensee only provided marked-up TS pages, but did not provide bases pages which provide reasons for such TS to assist in our review. Only providing mark-ups of the proposed TS changes satisfies the requirements of 10 CFR 50.90 "Application for amendment of license, construction permit, or early site permit," because the mark-ups fully describe the changes desired. The NRC staff finds that this is an administrative deviation from the NRC staff's model application for TSTF-425 implementation dated July 6, 2009 (74 FR 31996), but has no impact on the NRC staff's safety evaluation.

3.3.2 Definition of STAGGERED TEST BASIS In its submittal dated November 19, 2014, the licensee proposed to retain the definition of STAGGERED TEST BASIS in the TS Definition Section 1.1. This phrase is used in Administrative TS Section 5.5.13, "Control Room Habitability," which is not changed in this amendment. The NRC staff finds that this is an administrative deviation from the NRC staff's model application dated July 6, 2009 (74 FR 31996), but has no impact on the NRC staff's safety evaluation.

3.3.3 Differences between NMP2 TSs and NUREG-1433 In its submittal dated November 19, 2014, the licensee stated that the NMP2 TS SR numbers, and associated TS Bases numbers, differ from those in NUREG-1433, Revision 4, "Standard Technical Specifications - General Electric BWR/4 Plants," Volumes 1 and 2, and TSTF-425,

Revision 3. There are also surveillances contained in NUREG-1433 that are not contained in the NMP2 TSs. These surveillances identified in TSTF-425 for NUREG-1433 are not applicable to NMP2. These differences are administrative deviations from TSTF-425 that have no impact on the NRC staff's safety evaluation.

In its submittal dated November 19, 2014, the licensee requested that plant specific surveillance frequencies be relocated to the SFCP. The relocation of the plant-specific surveillance frequencies is consistent with TSTF-425 and with the NRC staff's model SE dated July 6, 2009 (74 FR 31996), including the scope exclusions identified in Section 1.0, "Introduction," of the model SE because the plant-specific surveillance frequencies involved fixed period frequencies.

Changes to the frequencies for these plant-specific surveillances would be controlled under the SFCP. Therefore, the NRC staff finds this acceptable.

3.3.4 TS Bases Variations In its submittal dated November 19, 2014, the licensee noted that the TSTF-425 TS Bases insert, "The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program," should be revised to state, "The Surveillance Frequency is controlled under the Surveillance Frequency Control Program." The licensee noted that this change is necessary because surveillance frequencies that were relocated, but not changed, under the SFCP may not have been based on operating experience, equipment reliability, or plant risk. The NRC agreed with the TSTF in a letter dated April 14, 2010 (ADAMS Accession No. ML100990099), that the wording of the TSTF-425 TS Bases does not apply to SFs relocated to the SFCP but not changed. This is an administrative deviation from TSTF-425 that has no impact on the NRC staff's safety evaluation because the NRC staff does not approve TS Bases changes.

3.4 Summary and Conclusions The NRC staff has reviewed the licensee's proposed relocation of some surveillance frequencies to a licensee-controlled document, and controlling changes to surveillance frequencies in accordance with a new program, the SFCP, identified in the Administrative Controls of TSs. The NRC staff confirmed that this amendment does not relocate surveillance frequencies that reference other approved programs for the specific interval, are purely event-driven, are event-driven but have a time component for performing the surveillance on a one-time basis once the event occurs, or are related to specific conditions. The SFCP and TS Section 5.5.14 references NEI 04-10, Revision 1, which provides a risk-informed methodology using plant-specific risk insights and performance data to revise surveillance frequencies within the SFCP. This methodology supports relocating surveillance frequencies from TSs to a licensee-controlled document, provided those frequencies are changed in accordance with NEI 04-10, Revision 1, which is specified in the administrative controls of the TSs.

The licensee's proposed adoption of TSTF-425, Revision 3, and risk-informed methodology of NEI 04-10, Revision 1, as referenced in the Administrative Controls of TSs, satisfies the key principles of risk-informed decision making applied to changes to TSs as delineated in RG 1.177, Revision 1, and RG 1.174, Revision 2, in that:

The proposed change meets current regulations;

The proposed change is consistent with defense-in-depth philosophy;

The proposed change maintains sufficient safety margins;

Increases in risk resulting from the proposed change are small and consistent with the Commission's Safety Goal Policy Statement; and

The impact of the proposed change is monitored with performance measurement strategies.

Section 50.36(c) of 10 CFR discusses the categories that will be included in TSs.

Section 50.36(c)(3) of 10 CFR discusses the specific category of Surveillance Requirements and states, "Surveillance requirements are requirements relating to test, calibration, or inspection 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 will be met." The NRC staff finds that with the proposed relocation of surveillance frequencies to a licensee-controlled document and administratively controlled in accordance with the TS SFCP, the licensee continues to meet 10 CFR 50.36(c)(3).

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

This amendment changes inspection or surveillance requirements or requirements with respect to installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff determined that the amendment involves no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. By FR notice dated March 17, 2015 (80 FR 13906), the NRC issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on these findings. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that 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.

Principal Contributors: Jonathan Evans, NRR/DRA Alice Erickson, NRR/DRA Mihaela Biro, NRR/DRA Date:November 30, 2015

B. Hanson A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely, IRA!

Brenda L. Mozafari, Sr. Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410

Enclosures:

1. Amendment No. 152 to NPF-69

2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDraApla LPLl-1 R/F RidsNrrDssStsb RidsNrrDorlLPL 1-1 RidsRgn1 MailCenter RidsNrrLAKGoldstein RidsACRS_MailCTR RidsNrrPMNineMilePoint TDimitriadis, Region 1 J. Evans, NRR P. Snyder, NRR M. Biro, NRR A Erickson, NRR ADAMS Access1on No.: ML15317A307 *SE t ransm1"tte db,y memo ML15251A325 OFFICE NRR/DORL/LPLl-1 /PM NRR/DORL/LPLl-1 /LA NRR/DRA/APLA/BC NRR/DSS/STSB/BC NAME BMozafari KGoldstein SRosenberg* RElliott DATE 11/19/2015 11/17/2015 10/30/2015 11/19/2015 OFFICE OGC /NLO NRR/DORL/LPLl-1 /BC NRR/DORL/LPLl-1 /PM NAME Jlindell TTate BMozafari DATE 11/30/2015 11/30/2015 11/30/2015 OFFICIAL RECORD COPY

v t e Letter Sequence Approval
CAC:MF5364, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Approved, Closed)
Initiation Acceptance... Administration Questions Answers 10 July 2015 10 September 2015 Results Approval Other:
MONTHYEAR2015-07-10 [Table View]

ML15317A307

Text

SUBJECT:

Dear Mr. Hanson:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

Enclosures:

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