Text

Issuance of Amendment No. 301 to Relocate Specific Surveillance Frequencies to a Licensee-Controlled Program
	ML20280A827
Person / Time
Site:	Davis Besse
Issue date:	11/03/2020
From:	Blake Purnell; Plant Licensing Branch III
To:	Tony Brown; Energy Harbor Nuclear Corp
	Purnell B
References
	EPID L-2019-LLA-0252
	Download: ML20280A827 (148)
	v • d • e

November 3, 2020 Mr. Terry J. Brown Site Vice President Energy Harbor Nuclear Corp.

Mail Stop P-DB-3080 5501 North State Route 2 Oak Harbor, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT NO. 301 TO RELOCATE SPECIFIC SURVEILLANCE FREQUENCIES TO A LICENSEE-CONTROLLED PROGRAM (EPID L-2019-LLA-0252)

Dear Mr. Brown:

The U.S. Nuclear Regulatory Commission (NRC or Commission) has issued the enclosed Amendment No. 301 to Renewed Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse). The amendment is in response to the FirstEnergy Nuclear Operating Company application dated November 14, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19318F668), as supplemented by the letter from Energy Harbor Nuclear Corp. dated June 23, 2020 (ADAMS Accession No. ML20175A900).

Effective February 27, 2020, the facility operating license for Davis-Besse was transferred from FirstEnergy Nuclear Generation, LLC (owner) and FirstEnergy Nuclear Operating Company (operator) to Energy Harbor Nuclear Generation LLC (owner) and Energy Harbor Nuclear Corp.

(operator) (ADAMS Accession No. ML20030A440). Upon completion of this license transfer, Energy Harbor Nuclear Corp. assumed the responsibility for all licensing actions under NRC review at the time of the transfer and requested that the NRC continue its review of these actions (ADAMS Accession No. ML20054B733).

The amendment revises the Davis-Besse technical specifications by relocating specific surveillance frequencies to a licensee-controlled program. The changes are based on Technical Specification Task Force (TSTF) traveler TSTF-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b (ADAMS Package Accession No. ML090850642).

T. Brown A copy of the NRC staffs Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions Federal Register notice.

Sincerely,

/RA/

Blake Purnell, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosures:

1. Amendment No. 301 to NPF-3

2. Safety Evaluation cc: Listserv

ENERGY HARBOR NUCLEAR CORP.

AND ENERGY HARBOR NUCLEAR GENERATION LLC DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE DOCKET NO. 50-346 Amendment No. 301 Renewed License No. NPF-3

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

A. The application for amendment filed by FirstEnergy Nuclear Operating Company dated November 14, 2019, as supplemented by the letter from Energy Harbor Nuclear Corp. dated June 23, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

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-3 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 301, are hereby incorporated in the renewed license. Energy Harbor Nuclear Corp. shall operate the facility in accordance with the Technical Specifications.

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

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Joel S.

Joel S. Wiebe Date: 2020.11.03 Wiebe 13:03:15 -05'00' Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: November 3, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 301 RENEWED FACILITY OPERATING LICENSE NO. NPF-3 DOCKET NO. 50-346 Replace the following pages of the Renewed Facility Operating License and 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.

Remove Insert License NPF-3 License NPF-3 L-5 L-5 Technical Specifications Remove Insert Remove Insert 3.1.1-1 3.1.1-1 3.3.11-3 3.3.11-3 3.1.2-2 3.1.2-2 -- 3.3.11-4 3.1.4-3 3.1.4-3 3.3.12-2 3.3.12-2 3.1.5-2 3.1.5-2 3.3.13-2 3.3.13-2 3.1.6-1 3.1.6-1 3.3.14-1 3.3.14-1 3.1.7-3 3.1.7-3 -- 3.3.14-2 3.1.8-3 3.1.8-3 3.3.15-2 3.3.15-2 3.1.9-2 3.1.9-2 -- 3.3.15-3 3.1.9-3 3.1.9-3 3.3.16-2 3.3.16-2 3.2.1-3 3.2.1-3 3.3.16-3 3.3.16-3 3.2.2-1 3.2.2-1 -- 3.3.16-4 3.2.3-1 3.2.3-1 3.3.17-2 3.3.17-2 3.2.4-3 3.2.4-3 3.3.17-3 3.3.17-3 3.3.1-3 3.3.1-3 3.3.18-2 3.3.18-2 3.3.1-4 3.3.1-4 3.4.1-2 3.4.1-2 3.3.1-5 3.3.1-5 3.4.2-1 3.4.2-1 3.3.1-6 3.3.1-6 3.4.3-2 3.4.3-2 3.3.1-7 3.3.1-7 3.4.4-2 3.4.4-2

-- 3.3.1-8 3.4.5-2 3.4.5-2 3.3.3-2 3.3.3-2 3.4.6-2 3.4.6-2 3.3.4-2 3.3.4-2 -- 3.4.6-3 3.3.4-3 3.3.4-3 3.4.7-2 3.4.7-2 3.3.5-2 3.3.5-2 3.4.8-2 3.4.8-2 3.3.5-3 3.3.5-3 3.4.9-2 3.4.9-2 3.3.6-1 3.3.6-1 3.4.11-2 3.4.11-2 3.3.7-1 3.3.7-1 3.4.12-2 3.4.12-2 3.3.8-2 3.3.8-2 3.4.13-2 3.4.13-2 3.3.9-2 3.3.9-2 3.4.14-3 3.4.14-3 3.3.10-1 3.3.10-1 3.4.14-4 3.4.14-4 3.3.10-2 3.3.10-2 3.4.15-3 3.4.15-3 3.3.11-2 3.3.11-2 3.4.16-2 3.4.16-2

Technical Specifications (Continued)

Remove Insert Remove Insert 3.5.1-1 3.5.1-1 3.7.14-1 3.7.14-1 3.5.1-2 3.5.1-2 3.7.15-1 3.7.15-1

-- 3.5.1-3 3.7.17-1 3.7.17-1 3.5.2-2 3.5.2-2 3.7.18-2 3.7.18-2 3.5.2-3 3.5.2-3 3.8.1-5 3.8.1-5 3.5.4-2 3.5.4-2 3.8.1-6 3.8.1-6 3.6.2-4 3.6.2-4 3.8.1-7 3.8.1-7 3.6.3-5 3.6.3-5 3.8.1-8 3.8.1-8 3.6.3-7 3.6.3-7 3.8.1-9 3.8.1-9 3.6.4-1 3.6.4-1 3.8.1-10 3.8.1-10 3.6.5-1 3.6.5-1 3.8.1-11 3.8.1-11 3.6.6-2 3.6.6-2 3.8.1-12 3.8.1-12 3.6.6-3 3.6.6-3 3.8.3-2 3.8.3-2 3.6.7-1 3.6.7-1 -- 3.8.3-3 3.7.2-2 3.7.2-2 3.8.4-2 3.8.4-2 3.7.3-2 3.7.3-2 3.8.6-3 3.8.6-3 3.7.4-1 3.7.4-1 3.8.6-4 3.8.6-4

-- 3.7.4-2 -- 3.8.6-5 3.7.5-3 3.7.5-3 3.8.7-2 3.8.7-2 3.7.5-4 3.7.5-4 3.8.8-2 3.8.8-2 3.7.5-5 3.7.5-5 3.8.9-2 3.8.9-2 3.7.6-1 3.7.6-1 3.8.10-2 3.8.10-2 3.7.7-2 3.7.7-2 3.9.1-1 3.9.1-1 3.7.8-2 3.7.8-2 3.9.2-2 3.9.2-2 3.7.9-1 3.7.9-1 3.9.4-2 3.9.4-2 3.7.10-2 3.7.10-2 3.9.5-3 3.9.5-3 3.7.10-3 3.7.10-3 3.9.6-1 3.9.6-1 3.7.11-1 3.7.11-1 5.5-14 5.5-14 3.7.12-2 3.7.12-2 -- 5.5-15 3.7.13-2 3.7.13-2

2.C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level Energy Harbor Nuclear Corp. is authorized to operate the facility at steady state reactor core power levels not in excess of 2817 megawatts (thermal). Prior to attaining the power level, Toledo Edison Company shall comply with the conditions identified in Paragraph (3) (o) below and complete the preoperational tests, startup tests and other items identified in Attachment 2 to this license in the sequence specified. Attachment 2 is an integral part of this renewed license.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 301, are hereby incorporated in the renewed license.

Energy Harbor Nuclear Corp. shall operate the facility in accordance with the Technical Specifications.

(3) Additional Conditions The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following the issuance of the renewed license or within the operational restrictions indicated. The removal of these conditions shall be made by an amendment to the renewed license supported by a favorable evaluation by the Commission:

(a) Energy Harbor Nuclear Corp. shall not operate the reactor in operational Modes 1 and 2 with less than three reactor coolant pumps in operation.

(b) Deleted per Amendment 6 (c) Deleted per Amendment 5 L-5 Renewed License No. NPF-3 Amendment No. 301

SDM 3.1.1 3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 SHUTDOWN MARGIN (SDM)

LCO 3.1.1 The SDM shall be within the limits specified in the COLR.

APPLICABILITY: MODES 3, 4, and 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. SDM not within limits. A.1 Initiate boration to restore 15 minutes SDM to within limits.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify SDM is within the limits specified in the In accordance COLR. with the Surveillance Frequency Control Program Davis-Besse 3.1.1-1 Amendment 301

Reactivity Balance 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2.1 ------------------------------NOTES-----------------------------

1. The predicted reactivity values shall be adjusted (normalized) to correspond to the measured core reactivity prior to exceeding a fuel burnup of 60 effective full power days (EFPD) after each fuel loading.

2. This Surveillance is not required to be performed prior to entry into MODE 2.

Verify measured core reactivity balance is within Prior to entering

+/- 1% k/k of predicted values. MODE 1 after each fuel loading AND

NOTE--------

Only required after 60 EFPD In accordance with the Surveillance Frequency Control Program Davis-Besse 3.1.2-2 Amendment 301

CONTROL ROD Group Alignment Limits 3.1.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more CONTROL D.1.1 Verify SDM is within limit. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months RODS inoperable.

OR D.1.2 Initiate boration to restore 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months SDM to within limit.

AND D.2 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify individual CONTROL ROD positions are In accordance within 6.5% of their group average height. with the Surveillance Frequency Control Program SR 3.1.4.2 Verify CONTROL ROD freedom of movement In accordance (trippability) by moving each individual CONTROL with the ROD that is not fully inserted 3% in any direction. Surveillance Frequency Control Program SR 3.1.4.3 -------------------------------NOTE------------------------------

With rod drop times determined with less than four reactor coolant pumps operating, operation may proceed provided operation is restricted to the pump combination operating during the rod drop time determination.

Verify the rod drop time for each CONTROL ROD, Prior to reactor from the fully withdrawn position, is 1.58 seconds criticality after from power interruption at the CONTROL ROD drive each removal of cabinets to 3/4 insertion (25% withdrawn position) the reactor vessel with Tavg 525F. head Davis-Besse 3.1.4-3 Amendment 301

Safety Rod Insertion Limits 3.1.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify each safety rod is fully withdrawn. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.1.5-2 Amendment 301

APSR Alignment Limits 3.1.6 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 AXIAL POWER SHAPING ROD (APSR) Alignment Limits LCO 3.1.6 Each APSR shall be OPERABLE, unless fully withdrawn, and shall be aligned within 6.5% of its group average height.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One APSR inoperable, A.1 Perform SR 3.2.3.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months not aligned within its limits, or both. AND 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after each APSR movement B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 Verify position of each APSR is within 6.5% of the In accordance group average height. with the Surveillance Frequency Control Program Davis-Besse 3.1.6-1 Amendment 301

Position Indicator Channels 3.1.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Declare the rod(s) Immediately associated Completion inoperable.

Time of Condition A or B not met.

OR The absolute position indicator channel and the relative position indicator channel inoperable for one or more rods.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 Verify the absolute position indicator channels and In accordance the relative position indicator channels agree within with the the limit specified in the COLR. Surveillance Frequency Control Program Davis-Besse 3.1.7-3 Amendment 301

PHYSICS TESTS Exceptions - MODE 1 3.1.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.8.1 Verify THERMAL POWER is 85% RTP. In accordance with the Surveillance Frequency Control Program SR 3.1.8.2 -------------------------------NOTE------------------------------

Only required to be met when THERMAL POWER is

> 20% RTP.

Perform SR 3.2.5.1. In accordance with the Surveillance Frequency Control Program SR 3.1.8.3 Verify High Flux trip setpoint is 10% RTP higher In accordance than the THERMAL POWER at which the test is with the performed, with a maximum setting of 90% RTP. Surveillance Frequency Control Program SR 3.1.8.4 Verify SDM is within the limits specified in the In accordance COLR. with the Surveillance Frequency Control Program Davis-Besse 3.1.8-3 Amendment 301

PHYSICS TESTS Exceptions - MODE 2 3.1.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. SDM not within limit. B.1 Initiate boration to restore 15 minutes SDM to within limit.

AND B.2 Suspend PHYSICS TESTS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months exceptions.

C. RCS lowest loop C.1 Suspend PHYSICS TESTS 30 minutes average temperature not exceptions.

within limit.

D. High Flux trip setpoint is D.1 Suspend PHYSICS TESTS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months not within limit. exceptions.

OR Nuclear instrumentation high startup rate control rod withdrawal inhibit inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.9.1 Perform a CHANNEL FUNCTIONAL TEST on each Once within nuclear instrumentation high startup rate control rod 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to withdrawal inhibit and High Flux channel. initiating PHYSICS TESTS SR 3.1.9.2 Verify the RCS lowest loop average temperature is In accordance

> 520°F. with the Surveillance Frequency Control Program Davis-Besse 3.1.9-2 Amendment 301

PHYSICS TESTS Exceptions - MODE 2 3.1.9 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.9.3 Verify THERMAL POWER is 5% RTP. In accordance with the Surveillance Frequency Control Program SR 3.1.9.4 Verify SDM is within the limits specified in the In accordance COLR. with the Surveillance Frequency Control Program Davis-Besse 3.1.9-3 Amendment 301

Regulating Rod Insertion Limits 3.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify regulating rod groups are within the sequence In accordance and overlap limits as specified in the COLR. with the Surveillance Frequency Control Program SR 3.2.1.2 Verify regulating rod groups meet the insertion limits In accordance as specified in the COLR. with the Surveillance Frequency Control Program SR 3.2.1.3 Verify SDM is within the limit specified in the COLR. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to achieving criticality Davis-Besse 3.2.1-3 Amendment 301

APSR Insertion Limits 3.2.2 3.2 POWER DISTRIBUTION LIMITS 3.2.2 AXIAL POWER SHAPING ROD (APSR) Insertion Limits LCO 3.2.2 APSRs shall be positioned within the limits specified in the COLR.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. APSRs not within limits. A.1 ---------------NOTE--------------

Only required when THERMAL POWER is

> 20% RTP.

Perform SR 3.2.5.1. Once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND A.2 Restore APSRs to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limits.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Verify APSRs are within acceptable limits specified In accordance in the COLR. with the Surveillance Frequency Control Program Davis-Besse 3.2.2-1 Amendment 301

AXIAL POWER IMBALANCE Operating Limits 3.2.3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 AXIAL POWER IMBALANCE Operating Limits LCO 3.2.3 AXIAL POWER IMBALANCE shall be maintained within the limits specified in the COLR.

APPLICABILITY: MODE 1 with THERMAL POWER > 40% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. AXIAL POWER A.1 Perform SR 3.2.5.1. Once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months IMBALANCE not within limits. AND A.2 Reduce AXIAL POWER 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months IMBALANCE within limits.

B. Required Action and B.1 Reduce THERMAL 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months associated Completion POWER to 40% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify AXIAL POWER IMBALANCE is within limits In accordance as specified in the COLR. with the Surveillance Frequency Control Program Davis-Besse 3.2.3-1 Amendment 301

QPT 3.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.4.1 Verify QPT is within limits as specified in the COLR. In accordance with the Surveillance Frequency Control Program AND

NOTE--------

Only required to be performed if both Condition C was entered and THERMAL POWER is 60%

of ALLOWABLE THERMAL POWER When QPT has been restored to less than or equal to the steady state limit, once every hour for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , or until verified acceptable at 95% RTP Davis-Besse 3.2.4-3 Amendment 301

RPS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. (continued) AND F.2.2 Initiate action to reduce 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months since the THERMAL POWER to last calorimetric heat

< 98.4% RTP. balance based on UFM readings AND F.2.3 Reset High Flux - High 82 hours9.490741e-4 days 0.0228 hours 1.35582e-4 weeks 3.1201e-5 months since the Setpoint Allowable Value to last calorimetric heat

< 103.3% RTP. balance based on UFM readings G. UFM instrumentation not G.1 Initiate action to reduce Immediately used to perform THERMAL POWER to SR 3.3.1.2. < 73.8% RTP.

AND THERMAL POWER

> 50% RTP.

AND Three RCPs operating.

SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.1-1 to determine which SRs apply to each RPS Function.

SURVEILLANCE FREQUENCY SR 3.3.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.1-3 Amendment 301

RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.2 ------------------------------NOTES-----------------------------

1. Adjust power range channel output if the calorimetric heat balance calculation results exceed power range channel output by

> 2% RTP.

2. Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is 15% RTP.

Compare result of calorimetric heat balance In accordance calculation to power range channel output. with the Surveillance Frequency Control Program SR 3.3.1.3 ------------------------------NOTES-----------------------------

1. Neutron detectors are excluded from CHANNEL CALIBRATION.

2. For Function 8, flow rate measurement sensors may be excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.1-4 Amendment 301

RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.4 ------------------------------NOTES-----------------------------

1. Adjust the power range channel imbalance output if the absolute value of the offset error is 2.5%.

2. Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is 50% RTP.

Compare results of out of core measured AXIAL In accordance POWER IMBALANCE (API0) to incore measured with the AXIAL POWER IMBALANCE (API1) as follows: Surveillance Frequency (RTP/TP)(API0 - API1) = offset error. Control Program SR 3.3.1.5 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.6 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.1.7 -------------------------------NOTE------------------------------

For Function 8, flow rate measurement sensors are only required to be calibrated.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.1-5 Amendment 301

RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.8 -------------------------------NOTE------------------------------

Neutron detectors are excluded from RPS RESPONSE TIME testing.

Verify that RPS RESPONSE TIME is within limits. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.1-6 Amendment 301

RPS Instrumentation 3.3.1 Table 3.3.1-1 (page 1 of 2)

Reactor Protection System Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER FROM SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS ACTION C.1 REQUIREMENTS VALUE

1. High Flux -

a. High Setpoint 1,2(a),3(b) D SR 3.3.1.1 104.9% RTP(e) with four SR 3.3.1.2 pumps operating, and SR 3.3.1.3(c)(d) 80.6% RTP when reset SR 3.3.1.8 for three pumps operating per LCO 3.4.4, "RCS Loops - MODES 1 and 2"

b. Low Setpoint 2(f),3(f),4(f), E SR 3.3.1.1 5% RTP 5(f) SR 3.3.1.3

2. RC High Temperature 1,2 D SR 3.3.1.1 618F SR 3.3.1.5 SR 3.3.1.7

3. RC High Pressure 1,2(a),3(b) D SR 3.3.1.1 2355 psig SR 3.3.1.5 SR 3.3.1.7 SR 3.3.1.8

4. RC Low Pressure 1,2(a) D SR 3.3.1.1 1900 psig SR 3.3.1.5 SR 3.3.1.7 SR 3.3.1.8 (a) When not in shutdown bypass operation.

(b) With any CRD trip breaker in the closed position, the CRD System capable of rod withdrawal, and not in shutdown bypass operation.

(c) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(d) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint, or a value that is more conservative than the Limiting Trip Setpoint; otherwise, the channel shall be declared inoperable. The Limiting Trip Setpoint and the methodology used to determine the Limiting Trip Setpoint, the predefined as-found acceptance criteria band and the as-left setpoint tolerance band are specified in the Technical Requirements Manual.

(e) 103.3% RTP when reset per ACTION F due to UFM instrumentation not being used to perform SR 3.3.1.2 when THERMAL POWER is > 50% RTP.

(f) During shutdown bypass operation with any CRD trip breaker in the closed position and the CRD System capable of rod withdrawal.

Davis-Besse 3.3.1-7 Amendment 301

RPS Instrumentation 3.3.1 Table 3.3.1-1 (page 2 of 2)

Reactor Protection System Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER FROM SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS ACTION C.1 REQUIREMENTS VALUE

5. RC Pressure - Temperature 1,2(a) D SR 3.3.1.1 (16.25

Tout -

SR 3.3.1.5(c)(d) 7899.0) psig SR 3.3.1.7(c)(d)

6. Containment High Pressure 1,2,3(g) D SR 3.3.1.1 4 psig SR 3.3.1.5 SR 3.3.1.6

7. High Flux/Number of 1,2(a) D SR 3.3.1.1 < 55.1% RTP with one Reactor Coolant Pumps On SR 3.3.1.3 pump operating in each SR 3.3.1.8 loop,

< 0.0% RTP with two pumps operating in one loop and no pumps operating in the other loop,

< 0.0% RTP with one pump or no pumps operating

8. Flux - Flux - Flow 1,2(a) D SR 3.3.1.1 Flux - Flux - Flow SR 3.3.1.3 Allowable Value envelope SR 3.3.1.4 in COLR SR 3.3.1.7 SR 3.3.1.8

9. Shutdown Bypass High 2(f),3(f),4(f), E SR 3.3.1.1 1820 psig Pressure 5(f) SR 3.3.1.5 SR 3.3.1.7 (a) When not in shutdown bypass operation.

(c) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(d) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint, or a value that is more conservative than the Limiting Trip Setpoint; otherwise, the channel shall be declared inoperable. The Limiting Trip Setpoint and the methodology used to determine the Limiting Trip Setpoint, the predefined as-found acceptance criteria band and the as-left setpoint tolerance band are specified in the Technical Requirements Manual.

(f) During shutdown bypass operation with any CRD trip breaker in the closed position and the CRD System capable of rod withdrawal.

(g) With any CRD trip breaker in the closed position and the CRD System capable of rod withdrawal.

Davis-Besse 3.3.1-8 Amendment 301

RPS - RTM 3.3.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Open all CRD trip breakers. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not OR met in MODE 4 or 5.

C.2 Remove power from all 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR CRD trip breakers.

Two or more RTMs inoperable in MODE 4 or 5.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.3-2 Amendment 301

CRD Trip Devices 3.3.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, or 3. C.2.1 Open all CRD trip breakers. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR C.2.2 Remove power from all 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months CRD trip breakers.

D. Required Action and D.1 Open all CRD trip breakers. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B OR not met in MODE 4 or 5.

D.2 Remove power from all 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months CRD trip breakers.

E. ------------NOTE------------ E.1 Restore the channel(s) to Prior to entering Required Action E.1 OPERABLE status. MODE 4, when in shall be completed MODE 5 for whenever this Condition > 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is entered.

One or both SCR relay trip channels inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.4.1 Perform CHANNEL FUNCTIONAL TEST on CRD In accordance trip breakers. with the Surveillance Frequency Control Program Davis-Besse 3.3.4-2 Amendment 301

CRD Trip Devices 3.3.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.4.2 Perform CHANNEL FUNCTIONAL TEST on SCR In accordance relay trip channels. with the Surveillance Frequency Control Program Davis-Besse 3.3.4-3 Amendment 301

SFAS Instrumentation 3.3.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.3 ---------------NOTE--------------

Only required for RCS Pressure - Low Low channels.

Reduce RCS pressure 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

< 660 psig.

AND B.4 ---------------NOTE--------------

Only required for Containment Pressure -

High, Containment Pressure - High High, and Borated Water Storage Tank - Low Low channels.

Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.5-1 to determine which SRs apply to each SFAS instrumentation Parameter.

SURVEILLANCE FREQUENCY SR 3.3.5.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.5-2 Amendment 301

SFAS Instrumentation 3.3.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.5.2 -------------------------------NOTE------------------------------

When an SFAS channel is placed in an inoperable status solely for performance of this Surveillance, entry into associated Conditions and Required Actions may be delayed for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , provided two other channels of the same SFAS instrumentation Parameter are OPERABLE.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.3 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.5.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.5.5 Verify SFAS RESPONSE TIME within limits. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.5-3 Amendment 301

SFAS Manual Initiation 3.3.6 3.3 INSTRUMENTATION 3.3.6 Safety Features Actuation System (SFAS) Manual Initiation LCO 3.3.6 Two manual initiation channels of each one of the SFAS Functions below shall be OPERABLE:

a. SFAS; and

b. Containment Spray.

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when associated engineered safety features equipment is required to be OPERABLE.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more SFAS A.1 Restore channel to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Functions with one OPERABLE status.

channel inoperable.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.6.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.6-1 Amendment 301

SFAS Automatic Actuation Logic 3.3.7 3.3 INSTRUMENTATION 3.3.7 Safety Features Actuation System (SFAS) Automatic Actuation Logic LCO 3.3.7 All the SFAS automatic actuation output logics shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when associated engineered safety features equipment is required to be OPERABLE.

ACTIONS

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

Separate Condition entry is allowed for each automatic actuation output logic.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more automatic A.1 Place associated output 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months actuation output logics logic in trip.

inoperable.

OR A.2 Place associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months component(s) in engineered safety features configuration.

OR A.3 Declare the associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months component(s) inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.7.1 Perform automatic actuation output logic CHANNEL In accordance FUNCTIONAL TEST. with the Surveillance Frequency Control Program Davis-Besse 3.3.7-1 Amendment 301

EDG LOPS 3.3.8 SURVEILLANCE REQUIREMENTS

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

When EDG LOPS instrumentation is placed in an inoperable status solely for performance of a Surveillance, entry into associated Conditions and Required Actions may be delayed up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided the other channel monitoring the Function for the bus is OPERABLE and the two channels monitoring the Function for the other bus are OPERABLE.

SURVEILLANCE FREQUENCY SR 3.3.8.1 -------------------------------NOTE------------------------------

The as-left instrument setting shall be returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.8.2 -------------------------------NOTE------------------------------

The as-left instrument setting shall be returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit.

Perform CHANNEL CALIBRATION with Allowable In accordance Value as follows: with the Surveillance

a. Degraded Voltage 3712 volts (dropout) and Frequency 3771 volts (pickup) with a time delay of Control Program 6.4 seconds and 7.9 seconds; and

b. Loss of Voltage 2071 volts (dropout) and 2492 volts (pickup) with a time delay of 0.42 seconds and 0.58 seconds.

Davis-Besse 3.3.8-2 Amendment 301

Source Range Neutron Flux 3.3.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.3 Open CONTROL ROD 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months drive trip breakers.

AND B.4 Verify SDM is within the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months limits specified in the COLR. AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter C. One or more source C.1 Initiate action to restore 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months range neutron flux affected channel(s) to channels inoperable with OPERABLE status.

neutron flux

> 1E-10 amp on the intermediate range neutron flux channels.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.9.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.9.2 -------------------------------NOTE------------------------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.9-2 Amendment 301

Intermediate Range Neutron Flux 3.3.10 3.3 INSTRUMENTATION 3.3.10 Intermediate Range Neutron Flux LCO 3.3.10 Two intermediate range neutron flux channels shall be OPERABLE.

APPLICABILITY: MODE 2, MODES 3, 4, and 5 with any CONTROL ROD drive (CRD) trip breaker in the closed position and the CRD System capable of rod withdrawal.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One channel inoperable. A.1 Reduce neutron flux to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 1E-10 amp.

B. Required Action and B.1 ---------------NOTE--------------

associated Completion Plant temperature changes Time of Condition A not are allowed provided the met. temperature change is accounted for in the OR calculated SDM.

Two channels inoperable. Suspend operations Immediately involving positive reactivity changes.

AND B.2 Open CRD trip breakers. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Davis-Besse 3.3.10-1 Amendment 301

Intermediate Range Neutron Flux 3.3.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.10.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.10.2 -------------------------------NOTE------------------------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.10-2 Amendment 301

SFRCS Instrumentation 3.3.11 SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.11-1 to determine which SRs shall be performed for each SFRCS Function.

SURVEILLANCE FREQUENCY SR 3.3.11.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.11.2 -------------------------------NOTE------------------------------

When a channel is placed in an inoperable status solely for performance of the CHANNEL FUNCTIONAL TEST, entry into the associated Conditions and Required Actions may be delayed for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months provided the channels providing input to the other actuation channel are OPERABLE.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.11.3 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.11.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.11-2 Amendment 301

SFRCS Instrumentation 3.3.11 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.11.5 Verify SFRCS RESPONSE TIME is within limits. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.11-3 Amendment 301

SFRCS Instrumentation 3.3.11 Table 3.3.11-1 (page 1 of 1)

Steam and Feedwater Rupture Control System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS REQUIREMENTS VALUE

1. Main Steam Line 1,2,3(a) 4 per steam line SR 3.3.11.1 600.2 psig Pressure - Low SR 3.3.11.2(b)(c)

SR 3.3.11.3(b)(c)

SR 3.3.11.5

2. Feedwater/Steam 1,2,3 4 per feedwater SR 3.3.11.1 176.8 psid Generator Differential line SR 3.3.11.2(b)(c)

Pressure - High SR 3.3.11.3(b)(c)

SR 3.3.11.5

3. Steam Generator Level - 1,2,3 4 per steam SR 3.3.11.1 17.3 inches Low generator (SG) SR 3.3.11.2(b)(c)

SR 3.3.11.4(b)(c)

SR 3.3.11.5

4. Loss of RCPs 1,2,3 4 SR 3.3.11.1 1384.6 amps SR 3.3.11.2 and SR 3.3.11.3 106.5 amps SR 3.3.11.5 (a) With main steam line pressure 750 psig during a shutdown and with main steam line pressure > 800 psig during a heatup.

(b) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint, or a value that is more conservative than the Limiting Trip Setpoint; otherwise, the channel shall be declared inoperable. The Limiting Trip Setpoint and the methodology used to determine the Limiting Trip Setpoint, the predefined as-found acceptance criteria band and the as-left setpoint tolerance band are specified in the Technical Requirements Manual.

Davis-Besse 3.3.11-4 Amendment 301

SFRCS Manual Initiation 3.3.12 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.12.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.12-2 Amendment 301

SFRCS Actuation 3.3.13 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.13.1 -------------------------------NOTE------------------------------

When a channel is placed in an inoperable status solely for performance of the CHANNEL FUNCTIONAL TEST, entry into the associated Conditions and Required Actions may be delayed for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months provided the other actuation channel is OPERABLE.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.13-2 Amendment 301

Fuel Handling Exhaust - High Radiation 3.3.14 3.3 INSTRUMENTATION 3.3.14 Fuel Handling Exhaust - High Radiation LCO 3.3.14 Two channels of Fuel Handling Exhaust - High Radiation shall be OPERABLE.

APPLICABILITY: During movement of irradiated fuel assemblies in the spent fuel pool building.

ACTIONS

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

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Declare the associated Immediately inoperable. Spent Fuel Pool Area Emergency Ventilation System train inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.14.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.14.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.14-1 Amendment 301

Fuel Handling Exhaust - High Radiation 3.3.14 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.14.3 Perform CHANNEL CALIBRATION with a trip In accordance setpoint of < 2 times Background. with the Surveillance Frequency Control Program Davis-Besse 3.3.14-2 Amendment 301

Station Vent Normal Range Radiation Monitoring 3.3.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. Required Action and D.1 Suspend movement of Immediately associated Completion irradiated fuel assemblies.

Time of Condition A or B not met during movement of irradiated fuel assemblies.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.15.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.15.2 -------------------------------NOTE------------------------------

When a channel is placed in an inoperable status solely for performance of this Surveillance, entry into associated Conditions and Required Actions may be delayed for up to 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months provided the other channel is OPERABLE.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.15-2 Amendment 301

Station Vent Normal Range Radiation Monitoring 3.3.15 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.15.3 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.15-3 Amendment 301

ARTS Instrumentation 3.3.16 ACTIONS (continued)

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

associated Completion Only applicable for Time not met. Function 1.

Reduce THERMAL 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months POWER to < 45% RTP.

AND B.2 ---------------NOTE--------------

Only applicable for Functions 2 and 3.

Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.16-1 to determine which SRs apply to each ARTS instrumentation Function.

SURVEILLANCE FREQUENCY SR 3.3.16.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.16.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.16-2 Amendment 301

ARTS Instrumentation 3.3.16 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.16.3 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.3.16-3 Amendment 301

ARTS Instrumentation 3.3.16 Table 3.3.16-1 (page 1 of 1)

Anticipatory Reactor Trip System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE FUNCTION CONDITIONS CHANNELS REQUIREMENTS

1. Turbine Trip > 45% RTP 3 SR 3.3.16.1 SR 3.3.16.3

2. Trip of Both Main Feed Pump Turbines 1 3 SR 3.3.16.1 SR 3.3.16.3

3. Output Logic 1 4 SR 3.3.16.2 Davis-Besse 3.3.16-4 Amendment 301

PAM Instrumentation 3.3.17 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more Functions C.1 Restore one channel to 7 days with two required OPERABLE status.

channels inoperable.

D. Required Action and D.1 Enter the Condition Immediately associated Completion referenced in Time of Condition C not Table 3.3.17-1 for the met. channel.

E. As required by Required E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action B.2 or D.1 and referenced in AND Table 3.3.17-1.

E.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months F. As required by Required F.1 Initiate action in accordance Immediately Action D.1 and with Specification 5.6.5.

referenced in Table 3.3.17-1 SURVEILLANCE REQUIREMENTS

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

These SRs apply to each PAM instrumentation Function in Table 3.3.17-1 except where identified in the SR.

SURVEILLANCE FREQUENCY SR 3.3.17.1 Perform CHANNEL CHECK for each required In accordance instrumentation channel that is normally energized. with the Surveillance Frequency Control Program Davis-Besse 3.3.17-2 Amendment 301

PAM Instrumentation 3.3.17 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.17.2 -------------------------------NOTE------------------------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION for Functions 1, In accordance 11, 12, 14, 15, 16, and 17. with the Surveillance Frequency Control Program SR 3.3.17.3 Perform CHANNEL CALIBRATION for Functions 2, In accordance 3, 4, 5, 6, 7, 8, 9, 10, and 13. with the Surveillance Frequency Control Program Davis-Besse 3.3.17-3 Amendment 301

Remote Shutdown System 3.3.18 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.18.1 Perform CHANNEL CHECK for each required In accordance instrumentation channel that is normally energized. with the Surveillance Frequency Control Program SR 3.3.18.2 -------------------------------NOTE------------------------------

Reactor trip breaker indication and control rod position switches are excluded from this Surveillance.

Perform CHANNEL CALIBRATION for each In accordance required instrumentation channel. with the Surveillance Frequency Control Program SR 3.3.18.3 Verify each control circuit and transfer switch In accordance required for a serious control room or cable with the spreading room fire is capable of performing the Surveillance intended function. Frequency Control Program Davis-Besse 3.3.18-2 Amendment 301

RCS Pressure, Temperature, and Flow DNB Limits 3.4.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 -------------------------------NOTE------------------------------

With three RCPs operating, the limits are applied to the loop with two RCPs in operation.

Verify RCS loop pressure 2064.8 psig with In accordance four RCPs operating or 2060.8 psig with with the three RCPs operating. Surveillance Frequency Control Program SR 3.4.1.2 -------------------------------NOTE------------------------------

With three RCPs operating, the limits are applied to the loop with two RCPs in operation.

Verify RCS hot leg temperature 610F. In accordance with the Surveillance Frequency Control Program SR 3.4.1.3 Verify RCS total flow 389,500 gpm with four RCPs In accordance operating or 290,957 gpm with three RCPs with the operating. Surveillance Frequency Control Program SR 3.4.1.4 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after stable thermal conditions are established at 70% RTP.

Verify RCS total flow rate is within limit by In accordance measurement. with the Surveillance Frequency Control Program Davis-Besse 3.4.1-2 Amendment 301

RCS Minimum Temperature for Criticality 3.4.2 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.2 RCS Minimum Temperature for Criticality LCO 3.4.2 Each RCS loop average temperature (Tavg) shall be 525F.

APPLICABILITY: MODE 1, MODE 2 with keff 1.0.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Tavg in one or more RCS A.1 Be in MODE 2 with keff 30 minutes loops not within limit. < 1.0.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.2.1 Verify RCS Tavg in each loop 525F. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.4.2-1 Amendment 301

RCS P/T Limits 3.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 -------------------------------NOTE------------------------------

Only required to be performed during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing.

Verify RCS pressure, RCS temperature, and RCS In accordance heatup and cooldown rates are within the limits with the specified in the PTLR. Surveillance Frequency Control Program Davis-Besse 3.4.3-2 Amendment 301

RCS Loops - MODES 1 and 2 3.4.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.4.1 Verify required RCS loops are in operation. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.4.4-2 Amendment 301

RCS Loops - MODE 3 3.4.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify one RCS loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.5.2 Verify, for each required RCS loop, SG secondary In accordance side water level is: with the Surveillance

a. 18 inches above the lower tube sheet if Frequency associated reactor coolant pump is operating; or Control Program

b. 35 inches above the lower tube sheet if reactor coolant pumps are not operating.

SR 3.4.5.3 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated In accordance power available to each required pump. with the Surveillance Frequency Control Program Davis-Besse 3.4.5-2 Amendment 301

RCS Loops - MODE 4 3.4.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Two required loops B.1 Suspend operations that Immediately inoperable. would cause introduction of coolant into the RCS with OR boron concentration less than required to meet SDM Required loop not in of LCO 3.1.1.

operation.

AND B.2 Initiate action to restore one loop to OPERABLE status and operation. Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify required DHR or RCS loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.6.2 Verify, for each required RCS loop, SG secondary In accordance side water level is: with the Surveillance

a. 18 inches above the lower tube sheet if Frequency associated reactor coolant pump is operating; or Control Program

b. 35 inches above the lower tube sheet if reactor coolant pumps are not operating.

Davis-Besse 3.4.6-2 Amendment 301

RCS Loops - MODE 4 3.4.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.6.3 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated In accordance power available to each required pump. with the Surveillance Frequency Control Program Davis-Besse 3.4.6-3 Amendment 301

RCS Loops - MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify required DHR or RCS loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.7.2 Verify, for each required RCS loop, SG secondary In accordance side water level is 35 inches above the lower tube with the sheet. Surveillance Frequency Control Program SR 3.4.7.3 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated In accordance power available to each required DHR pump. with the Surveillance Frequency Control Program Davis-Besse 3.4.7-2 Amendment 301

RCS Loops - MODE 5, Loops Not Filled 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No required DHR loop B.1 Suspend operations that Immediately OPERABLE. would cause introduction of coolant into the RCS with OR boron concentration less than required to meet SDM Required DHR loop not of LCO 3.1.1.

in operation.

AND B.2 Initiate action to restore one Immediately DHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify required DHR loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.8.2 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated In accordance power available to each required DHR pump. with the Surveillance Frequency Control Program Davis-Besse 3.4.8-2 Amendment 301

Pressurizer 3.4.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 Verify pressurizer water level 228 inches. In accordance with the Surveillance Frequency Control Program SR 3.4.9.2 Verify capacity of essential pressurizer heaters is In accordance 85 kW. with the Surveillance Frequency Control Program Davis-Besse 3.4.9-2 Amendment 301

Pressurizer PORV 3.4.11 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.1 -------------------------------NOTE------------------------------

Not required to be performed with block valve closed in accordance with the Required Actions of this LCO.

Perform one complete cycle of the block valve. In accordance with the Surveillance Frequency Control Program SR 3.4.11.2 Perform one complete cycle of the PORV. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.4.11-2 Amendment 301

LTOP 3.4.12 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Disable capability of both 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Associated Completion high pressure injection Time not met. pumps to inject water into the RCS.

AND D.2 Disable makeup pump 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months suction automatic transfer to the borated water storage tank on low makeup tank level.

AND D.3 Verify makeup tank level 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 73 inches.

AND D.4 Verify RCS pressure and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months pressurizer level in Acceptable Region of Figure 3.4.12-1 or 3.4.12-2, as applicable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 Verify RCS to DHR isolation valves open with In accordance control power removed. with the Surveillance Frequency Control Program SR 3.4.12.2 Verify DHR System relief valve lift setpoint In accordance 330 psig in accordance with the INSERVICE with the TESTING PROGRAM. INSERVICE TESTING PROGRAM Davis-Besse 3.4.12-2 Amendment 301

RCS Operational LEAKAGE 3.4.13 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.13.1 ------------------------------NOTES-----------------------------

1. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

2. Not applicable to primary to secondary LEAKAGE.

Verify RCS operational LEAKAGE is within limits by In accordance performance of RCS water inventory balance. with the Surveillance Frequency Control Program SR 3.4.13.2 -------------------------------NOTE------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

Verify primary to secondary LEAKAGE is In accordance 150 gallons per day through any one SG. with the Surveillance Frequency Control Program Davis-Besse 3.4.13-2 Amendment 301

RCS PIV Leakage 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1 Perform CHANNEL CHECK on the DHR System In accordance interlock channel common to Safety Features with the Actuation System (SFAS) instrumentation. Surveillance Frequency Control Program SR 3.4.14.2 ------------------------------NOTE-------------------------------

Only required to be performed in MODES 1 and 2.

Verify: In accordance with the

a. Leakage from each RCS PIV is equivalent to Surveillance 5.0 gpm at an RCS pressure of 2155 psig; and Frequency Control Program

b. When current measured rate is > 1 gpm, the current measured rate has not exceeded the AND rate determined by the previous test by an amount that reduces the margin between Prior to entering measured leakage rate and 5.0 gpm by 50%. MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months SR 3.4.14.3 -------------------------------NOTE------------------------------

Not required to be met when the DHR System interlock function is disabled in accordance with LCO 3.4.12.

Verify DHR System interlock function prevents the In accordance valves from being opened with a simulated or actual with the RCS pressure signal 328 psig. Surveillance Frequency Control Program Davis-Besse 3.4.14-3 Amendment 301

RCS PIV Leakage 3.4.14 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.14.4 -------------------------------NOTE------------------------------

Not required to be met when the DHR System interlock function is disabled in accordance with LCO 3.4.12.

Verify DHR System interlock function causes the In accordance valves to close automatically with a simulated or with the actual RCS pressure signal 328 psig. Surveillance Frequency Control Program SR 3.4.14.5 Perform CHANNEL CALIBRATION on the DHR In accordance System interlock channels. with the Surveillance Frequency Control Program Davis-Besse 3.4.14-4 Amendment 301

RCS Leakage Detection Instrumentation 3.4.15 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of required containment In accordance atmosphere radioactivity monitor. with the Surveillance Frequency Control Program SR 3.4.15.2 Perform CHANNEL FUNCTIONAL TEST of required In accordance containment atmosphere radioactivity monitor. with the Surveillance Frequency Control Program SR 3.4.15.3 Perform CHANNEL CALIBRATION of required In accordance containment atmosphere radioactivity monitor. with the Surveillance Frequency Control Program SR 3.4.15.4 Perform CHANNEL CALIBRATION of containment In accordance sump monitor. with the Surveillance Frequency Control Program Davis-Besse 3.4.15-3 Amendment 301

RCS Specific Activity 3.4.16 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.16.1 Verify reactor coolant gross specific activity In accordance 100/ Ci/gm. with the Surveillance Frequency Control Program SR 3.4.16.2 -------------------------------NOTE------------------------------

Only required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT I-131 In accordance specific activity 1.0 Ci/gm. with the Surveillance Frequency Control Program AND Between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after THERMAL POWER change of 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period SR 3.4.16.3 -------------------------------NOTE------------------------------

Not required to be performed until 31 days after a minimum of 2 EFPD and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

Determine . In accordance with the Surveillance Frequency Control Program Davis-Besse 3.4.16-2 Amendment 301

CFTs 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.1 Core Flooding Tanks (CFTs)

LCO 3.5.1 Two CFTs shall be OPERABLE.

APPLICABILITY: MODES 1 and 2, MODE 3 with Reactor Coolant System (RCS) pressure > 800 psig.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CFT inoperable due A.1 Restore boron 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to boron concentration concentration to within not within limits. limits.

B. One CFT inoperable for B.1 Restore CFT to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reasons other than OPERABLE status.

Condition A.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B AND not met.

C.2 Reduce RCS pressure to 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months 800 psig.

D. Two CFTs inoperable. D.1 Enter LCO 3.0.3. Immediately Davis-Besse 3.5.1-1 Amendment 301

CFTs 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify each CFT isolation valve is fully open. In accordance with the Surveillance Frequency Control Program SR 3.5.1.2 Verify borated water volume in each CFT is In accordance 12.6 feet and 13.3 feet. with the Surveillance Frequency Control Program SR 3.5.1.3 Verify nitrogen cover pressure in each CFT is In accordance 580 psig and 620 psig. with the Surveillance Frequency Control Program SR 3.5.1.4 Verify boron concentration in each CFT is In accordance 2600 ppm and 3500 ppm. with the Surveillance Frequency Control Program AND

NOTE--------

Only required to be performed for affected CFT Once within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after each solution volume increase of 80 gallons that is not the result of addition from the borated water storage tank Davis-Besse 3.5.1-2 Amendment 301

CFTs 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.5 Verify power is removed from each CFT isolation In accordance valve operator. with the Surveillance Frequency Control Program Davis-Besse 3.5.1-3 Amendment 301

ECCS - Operating 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify each ECCS manual, power operated, and In accordance automatic valve in the flow path, that is not locked, with the sealed, or otherwise secured in position, is in the Surveillance correct position. Frequency Control Program SR 3.5.2.2 Verify each ECCS pump's developed head at the In accordance test flow point is greater than or equal to the with the required developed head. INSERVICE TESTING PROGRAM SR 3.5.2.3 Verify ECCS piping is full of water by venting the In accordance ECCS pump casings and discharge piping high with the points. Surveillance Frequency Control Program AND Prior to declaring ECCS OPERABLE after draining ECCS piping SR 3.5.2.4 Verify each ECCS automatic valve in the flow path In accordance that is not locked, sealed, or otherwise secured in with the position, actuates to the correct position on an Surveillance actual or simulated actuation signal. Frequency Control Program SR 3.5.2.5 Verify each ECCS pump starts automatically on an In accordance actual or simulated actuation signal. with the Surveillance Frequency Control Program Davis-Besse 3.5.2-2 Amendment 301

ECCS - Operating 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.6 Verify the correct position of each mechanical stop In accordance for the following valves: with the Surveillance

a. DH-14A; and Frequency Control Program

b. DH-14B.

SR 3.5.2.7 Verify, by visual inspection, each ECCS train In accordance containment sump suction inlet is not restricted by with the debris and suction inlet trash racks and screens Surveillance show no evidence of structural distress or abnormal Frequency corrosion. Control Program SR 3.5.2.8 Verify the following: In accordance with the

a. Each BWST outlet valve and containment Surveillance emergency sump valve actuate to the correct Frequency position on a manual actuation of the Control Program containment emergency sump valve; and

b. The actuation time of each BWST outlet valve and containment emergency sump valve is

< 75 seconds.

Davis-Besse 3.5.2-3 Amendment 301

BWST 3.5.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.4.1 -------------------------------NOTE------------------------------

Only required to be performed when ambient air temperature is < 35F or > 90F.

Verify BWST borated water temperature is 35F In accordance and 90F. with the Surveillance Frequency Control Program SR 3.5.4.2 Verify BWST borated water volume is In accordance 500,100 gallons and 550,000 gallons. with the Surveillance Frequency Control Program SR 3.5.4.3 Verify BWST boron concentration is 2600 ppm In accordance and 2800 ppm. with the Surveillance Frequency Control Program Davis-Besse 3.5.4-2 Amendment 301

Containment Air Locks 3.6.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1 ------------------------------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.

Perform required air lock leakage rate testing in In accordance accordance with the Containment Leakage Rate with the Testing Program. Containment Leakage Rate Testing Program SR 3.6.2.2 Verify only one door in the air lock can be opened at In accordance a time. with the Surveillance Frequency Control Program Davis-Besse 3.6.2-4 Amendment 301

Containment Isolation Valves 3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Secondary containment E.1 Restore secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months bypass leakage not containment bypass within limit. leakage to within limit.

F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND F.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each 48 inch containment purge and exhaust In accordance valve is closed with control power removed. with the Surveillance Frequency Control Program SR 3.6.3.2 -------------------------------NOTE------------------------------

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

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

Davis-Besse 3.6.3-5 Amendment 301

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.5 Perform leakage rate testing for containment purge Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and exhaust valves with resilient seals. after each valve closure, if valve opened in MODE 1, 2, 3, or 4 AND Prior to entering MODE 4 from MODE 5 if valve opened in other than MODE 1, 2, 3, or 4 AND Prior to entering MODE 2 from MODE 3 each time the plant has been in any combination of MODE 3, 4, 5, or 6 for

> 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , if not performed in the previous 184 days SR 3.6.3.6 Verify each automatic containment isolation valve In accordance that is not locked, sealed, or otherwise secured in with the position, actuates to the isolation position on an Surveillance actual or simulated actuation signal. Frequency Control Program SR 3.6.3.7 Verify the combined leakage for all secondary In accordance containment bypass leakage paths is 0.03 La. with the Containment Leakage Rate Testing Program Davis-Besse 3.6.3-7 Amendment 301

Containment Pressure 3.6.4 3.6 CONTAINMENT SYSTEMS 3.6.4 Containment Pressure LCO 3.6.4 Containment pressure shall be -14 inches water gauge and

+25 inches water gauge.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment pressure A.1 Restore containment 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months not within limits. pressure to within limits.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1 Verify containment pressure is within limits. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.6.4-1 Amendment 301

Containment Air Temperature 3.6.5 3.6 CONTAINMENT SYSTEMS 3.6.5 Containment Air Temperature LCO 3.6.5 Containment average air temperature shall be 120F.

APPLICABILITY: MODES 1, 2, 3, and 4.

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

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.1 Verify containment average air temperature is within In accordance limit. with the Surveillance Frequency Control Program Davis-Besse 3.6.5-1 Amendment 301

Containment Spray and Air Cooling Systems 3.6.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two required E.1 Restore one required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months containment air cooling containment air cooling trains inoperable. train to OPERABLE status.

F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition C, D, AND or E not met.

F.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months G. Two containment spray G.1 Enter LCO 3.0.3. Immediately trains inoperable.

OR Any combination of three or more required trains inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power In accordance operated, and automatic valve in the flow path that with the is not locked, sealed, or otherwise secured in Surveillance position is in the correct position. Frequency Control Program SR 3.6.6.2 Operate each required containment air cooling train In accordance for 15 minutes. with the Surveillance Frequency Control Program Davis-Besse 3.6.6-2 Amendment 301

Containment Spray and Air Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.6.3 Verify each containment spray pump's developed In accordance head at the flow test point is greater than or equal to with the the required developed head. INSERVICE TESTING PROGRAM SR 3.6.6.4 Verify each required containment air cooling train In accordance starts automatically on an actual or simulated with the actuation signal. Surveillance Frequency Control Program SR 3.6.6.5 Verify each required containment air cooling train In accordance cooling water flow rate is 1150 gpm. with the Surveillance Frequency Control Program SR 3.6.6.6 Verify each automatic containment spray valve in In accordance the flow path that is not locked, sealed, or otherwise with the secured in position, actuates to the correct position Surveillance on an actual or simulated actuation signal. Frequency Control Program SR 3.6.6.7 Verify each containment spray pump starts In accordance automatically on an actual or simulated actuation with the signal. Surveillance Frequency Control Program SR 3.6.6.8 Verify each spray nozzle is unobstructed. Following maintenance that could result in nozzle blockage.

Davis-Besse 3.6.6-3 Amendment 301

TSP Storage 3.6.7 3.6 CONTAINMENT SYSTEMS 3.6.7 Trisodium Phosphate Dodecahydrate (TSP) Storage LCO 3.6.7 The TSP storage baskets shall contain 290 ft3 of TSP.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. TSP storage baskets A.1 Restore TSP storage 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months contain < 290 ft3 of TSP. baskets to 290 ft3 of TSP.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 5. 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.7.1 Verify contained volume of TSP in the TSP storage In accordance baskets is within limit. with the Surveillance Frequency Control Program Davis-Besse 3.6.7-1 Amendment 301

MSIVs 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Verify isolation time of each MSIV is within limits. In accordance with the INSERVICE TESTING PROGRAM SR 3.7.2.2 Verify each MSIV actuates to the isolation position In accordance on an actual or simulated actuation signal. with the Surveillance Frequency Control Program Davis-Besse 3.7.2-2 Amendment 301

MFSVs, MFCVs, and associated SFCVs 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two valves in the same D.1 Isolate affected flow path. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months flow path inoperable.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND E.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify the isolation time of each MFSV is within In accordance limits. with the INSERVICE TESTING PROGRAM SR 3.7.3.2 Verify the isolation time of each MFCV and SFCV is In accordance within limits. with the Surveillance Frequency Control Program SR 3.7.3.3 Verify each MFSV, MFCV, and SFCV actuates to In accordance the isolation position on an actual or simulated with the actuation signal. Surveillance Frequency Control Program Davis-Besse 3.7.3-2 Amendment 301

TSVs 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Turbine Stop Valves (TSVs)

LCO 3.7.4 Four TSVs shall be OPERABLE.

APPLICABILITY: MODES 1, MODES 2 and 3 except when all TSVs are closed.

ACTIONS

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

Separate Condition entry is allowed for each TSV.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more TSVs A.1 Close inoperable TSV. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable.

AND A.2 Verify inoperable TSV is Once per 7 days closed B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify isolation time of each TSV is within limits. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.7.4-1 Amendment 301

TSVs 3.7.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.4.2 Verify each TSV actuates to the isolation position on In accordance an actual or simulated actuation signal. with the Surveillance Frequency Control Program Davis-Besse 3.7.4-2 Amendment 301

EFW 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required MDFP train F.1 Initiate action to restore Immediately inoperable in MODE 4. MDFP train to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 -------------------------------NOTE------------------------------

In MODE 1 40% RTP and MODES 2, 3, and 4, the MDFP train valves are allowed to be in the non-correct position, provided the valves are capable of being locally realigned to the correct position.

Verify each EFW manual, power operated, and In accordance automatic valve in each water flow path and in both with the steam supply flow paths to the AFW pumps, that is Surveillance not locked, sealed, or otherwise secured in position, Frequency is in the correct position. Control Program SR 3.7.5.2 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching 800 psig in the steam generators.

Verify the developed head of each AFW pump at the In accordance flow test point is greater than or equal to the with the required developed head. Surveillance Frequency Control Program Davis-Besse 3.7.5-3 Amendment 301

EFW 3.7.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.3 -------------------------------NOTE------------------------------

Not required to be performed until 73 hours8.449074e-4 days 0.0203 hours 1.207011e-4 weeks 2.77765e-5 months after MDFP train is aligned to the AFW System.

Operate the MDFP train. In accordance with the Surveillance Frequency Control Program SR 3.7.5.4 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching 800 psig in the steam generators.

Verify each AFW automatic valve that is not locked, In accordance sealed, or otherwise secured in position, actuates to with the the correct position on an actual or simulated Surveillance actuation signal. Frequency Control Program SR 3.7.5.5 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching 800 psig in the steam generators.

Verify each AFW pump starts automatically on an In accordance actual or simulated actuation signal. with the Surveillance Frequency Control Program Davis-Besse 3.7.5-4 Amendment 301

EFW 3.7.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.6 Verify proper alignment of the required AFW flow Prior to entering paths by verifying flow from the condensate storage MODE 2 following tanks to each steam generator. refueling or whenever plant has been in MODE 5, MODE 6, or defueled for a cumulative period of > 30 days SR 3.7.5.7 Verify proper alignment of the required MDFP flow Prior to entering paths by verifying flow from the condensate storage MODE 3 following tanks to each steam generator. refueling or whenever plant has been in MODE 5, MODE 6, or defueled for a cumulative period of > 30 days SR 3.7.5.8 Perform CHANNEL CHECK on each AFW train In accordance Steam Generator Level Control System. with the Surveillance Frequency Control Program SR 3.7.5.9 Perform CHANNEL FUNCTIONAL TEST on each In accordance AFW train Steam Generator Level Control System. with the Surveillance Frequency Control Program SR 3.7.5.10 Perform CHANNEL CALIBRATION on each AFW In accordance train Steam Generator Level Control System. with the Surveillance Frequency Control Program Davis-Besse 3.7.5-5 Amendment 301

CSTs 3.7.6 3.7 PLANT SYSTEMS 3.7.6 Condensate Storage Tanks (CSTs)

LCO 3.7.6 The CSTs shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. The CSTs inoperable. A.1 Verify by administrative 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months means OPERABILITY of backup water supply. AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND A.2 Restore CSTs to 7 days OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 4 without 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months reliance on steam generator for heat removal.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify usable volume in the CSTs is 270,300 gal. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.7.6-1 Amendment 301

CCW System 3.7.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.7.1 -------------------------------NOTE------------------------------

Isolation of CCW flow to individual components does not render CCW System inoperable.

Verify each CCW manual, power operated, and In accordance automatic valve in the flow path servicing safety with the related equipment, that is not locked, sealed, or Surveillance otherwise secured in position, is in the correct Frequency position. Control Program SR 3.7.7.2 Verify each CCW automatic valve in the flow path In accordance that is not locked, sealed, or otherwise secured in with the position, actuates to the correct position on an Surveillance actual or simulated actuation signal. Frequency Control Program SR 3.7.7.3 Verify each required CCW pump starts automatically In accordance on an actual or simulated actuation signal. with the Surveillance Frequency Control Program Davis-Besse 3.7.7-2 Amendment 301

SWS 3.7.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 -------------------------------NOTE------------------------------

Isolation of SWS flow to individual components does not render the SWS inoperable.

Verify each SWS manual, power operated, and In accordance automatic valve in the flow path servicing safety with the related equipment, that is not locked, sealed, or Surveillance otherwise secured in position, is in the correct Frequency position. Control Program SR 3.7.8.2 Verify each SWS automatic valve in the flow path In accordance that is not locked, sealed, or otherwise secured in with the position, actuates to the correct position on an Surveillance actual or simulated actuation signal. Frequency Control Program SR 3.7.8.3 Verify each required SWS pump starts automatically In accordance on an actual or simulated actuation signal. with the Surveillance Frequency Control Program Davis-Besse 3.7.8-2 Amendment 301

UHS 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS)

LCO 3.7.9 The UHS shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. UHS inoperable. A.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND A.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Verify water level of UHS is 562 ft International In accordance Great Lakes Datum. with the Surveillance Frequency Control Program SR 3.7.9.2 Verify average water temperature of UHS is 90F. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.7.9-1 Amendment 301

CREVS 3.7.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. CRE boundary D.1 Suspend movement of Immediately inoperable during irradiated fuel assemblies.

movement of irradiated fuel assemblies.

E. Two CREVS trains E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREVS train for 15 minutes. In accordance with the Surveillance Frequency Control Program SR 3.7.10.2 Perform required CREVS filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.7.10.3 Verify Control Room Normal Ventilation System In accordance isolates on an actual or simulated actuation signal. with the Surveillance Frequency Control Program Davis-Besse 3.7.10-2 Amendment 301

CREVS 3.7.10 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.10.4 Perform required CRE unfiltered air inleakage In accordance testing in accordance with the Control Room with the Control Envelope Habitability Program. Room Envelope Habitability Program SR 3.7.10.5 Verify the system makeup flow rate is 270 cfm and In accordance 330 cfm when supplying the control room with with the outside air. Surveillance Frequency Control Program Davis-Besse 3.7.10-3 Amendment 301

CREATCS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Temperature Control System (CREATCS)

LCO 3.7.11 Two CREATCS trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREATCS train A.1 Restore CREATCS train to 30 days inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Verify each CREATCS train has the capability to In accordance remove the assumed heat load. with the Surveillance Frequency Control Program Davis-Besse 3.7.11-1 Amendment 301

Station EVS 3.7.12 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 Operate each Station EVS train for 15 minutes. In accordance with the Surveillance Frequency Control Program SR 3.7.12.2 Perform required Station EVS filter testing in In accordance accordance with the Ventilation Filter Testing with the VFTP Program (VFTP).

SR 3.7.12.3 Verify each Station EVS train actuates on an actual In accordance or simulated actuation signal. with the Surveillance Frequency Control Program SR 3.7.12.4 Verify one Station EVS train can attain a negative In accordance pressure 0.25 inches water gauge in the annulus with the 4 seconds after the flow rate is 7200 cfm and Surveillance 8800 cfm. Frequency Control Program SR 3.7.12.5 Verify each Station EVS filter cooling bypass In accordance damper can be opened. with the Surveillance Frequency Control Program Davis-Besse 3.7.12-2 Amendment 301

Spent Fuel Pool Area EVS 3.7.13 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two Spent Fuel Pool C.1 Suspend movement of Immediately Area EVS trains irradiated fuel assemblies in inoperable. the spent fuel pool building.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 Operate each Spent Fuel Pool Area EVS train for In accordance 15 minutes. with the Surveillance Frequency Control Program SR 3.7.13.2 Perform required Spent Fuel Pool Area EVS filter In accordance testing in accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.7.13.3 Verify each Spent Fuel Pool Area EVS train In accordance actuates on an actual or simulated actuation signal. with the Surveillance Frequency Control Program SR 3.7.13.4 Verify one Spent Fuel Pool Area EVS train can In accordance maintain a negative pressure 0.125 inches water with the gauge relative to outside atmosphere. Surveillance Frequency Control Program SR 3.7.13.5 Verify each Spent Fuel Pool Area EVS filter cooling In accordance bypass damper can be opened. with the Surveillance Frequency Control Program Davis-Besse 3.7.13-2 Amendment 301

Spent Fuel Pool Water Level 3.7.14 3.7 PLANT SYSTEMS 3.7.14 Spent Fuel Pool Water Level LCO 3.7.14 The spent fuel pool water level shall be 23 ft over the top of irradiated fuel assemblies seated in the storage racks.

APPLICABILITY: During movement of irradiated fuel assemblies in spent fuel pool.

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

level not within limit. LCO 3.0.3 is not applicable.

Suspend movement of Immediately irradiated fuel assemblies in spent fuel pool.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.14.1 Verify the spent fuel pool water level is 23 ft above In accordance the top of irradiated fuel assemblies seated in the with the storage racks. Surveillance Frequency Control Program Davis-Besse 3.7.14-1 Amendment 301

Spent Fuel Pool Boron Concentration 3.7.15 3.7 PLANT SYSTEMS 3.7.15 Spent Fuel Pool Boron Concentration LCO 3.7.15 The spent fuel pool boron concentration shall be 630 ppm.

APPLICABILITY: When fuel assemblies are stored in the spent fuel pool and a spent fuel pool verification has not been performed since the last movement of fuel assemblies in the spent fuel pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Spent fuel pool boron -------------------NOTE--------------------

concentration not within LCO 3.0.3 is not applicable.

limit. ------------------------------------------------

A.1 Suspend movement of fuel Immediately assemblies in the spent fuel pool.

AND A.2.1 Initiate action to restore Immediately spent fuel pool boron concentration to within limit.

OR A.2.2 Initiate action to perform a Immediately fuel storage pool verification.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.15.1 Verify the spent fuel pool boron concentration is In accordance within limit. with the Surveillance Frequency Control Program Davis-Besse 3.7.15-1 Amendment 301

Secondary Specific Activity 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Secondary Specific Activity LCO 3.7.17 The specific activity of the secondary coolant shall be 0.10 Ci/gm DOSE EQUIVALENT I-131.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Specific activity not A.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months within limit.

AND A.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.17.1 Verify the specific activity of the secondary coolant In accordance is 0.10 Ci/gm DOSE EQUIVALENT I-131. with the Surveillance Frequency Control Program Davis-Besse 3.7.17-1 Amendment 301

Steam Generator Level 3.7.18 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.18.1 Verify steam generator water level to be within In accordance limits. with the Surveillance Frequency Control Program Davis-Besse 3.7.18-2 Amendment 301

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated In accordance power availability for each offsite circuit. with the Surveillance Frequency Control Program SR 3.8.1.2 ------------------------------NOTES-----------------------------

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

2. A modified EDG start involving idling and/or gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.8 must be met.

Verify each EDG starts from standby conditions and In accordance achieves steady state voltage 4088 V and with the 4400 V, and frequency 59.5 Hz and 60.5 Hz. Surveillance Frequency Control Program Davis-Besse 3.8.1-5 Amendment 301

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

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

1. EDG 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 EDG at a time.

4. This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2 or SR 3.8.1.8.

Verify each EDG is synchronized and loaded and In accordance operates for 60 minutes at a load 2340 kW and with the 2600 kW. Surveillance Frequency Control Program SR 3.8.1.4 Verify each day tank contains 4000 gal of fuel oil. In accordance with the Surveillance Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from each In accordance day tank. with the Surveillance Frequency Control Program SR 3.8.1.6 Verify interval between each sequenced load block In accordance is within +/- 10% of design interval for each with the emergency load sequencer and each emergency Surveillance time delay relay. Frequency Control Program Davis-Besse 3.8.1-6 Amendment 301

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.7 Verify the fuel oil transfer system operates to In accordance transfer fuel oil from fuel oil storage tank to the day with the tank. Surveillance Frequency Control Program SR 3.8.1.8 -------------------------------NOTE------------------------------

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

Verify each EDG starts from standby condition and In accordance achieves: with the Surveillance

a. In 10 seconds, voltage 4070 V and Frequency frequency 59.5 Hz; and Control Program

b. Steady state voltage 4088 V and 4400 V, and frequency 59.5 Hz and 60.5 Hz.

SR 3.8.1.9 -------------------------------NOTES----------------------------

1. SR 3.8.1.9.a is only required to be met when the unit auxiliary source is supplying the electrical power distribution subsystem.

2. The automatic transfer portion of SR 3.8.1.9.a and all of SR 3.8.1.9.b shall not normally be performed in MODE 1 or 2. However, they may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify automatic and manual transfer of AC power In accordance sources from: with the Surveillance

a. The unit auxiliary source to the pre-selected Frequency offsite circuit; and Control Program

b. The normal offsite circuit to the alternate offsite circuit.

Davis-Besse 3.8.1-7 Amendment 301

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.10 ------------------------------NOTES-----------------------------

1. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

2. If performed with the EDG 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 EDG rejects a load greater than or equal In accordance to its associated single largest post-accident load, with the and following load rejection, the frequency is Surveillance 66.75 Hz. Frequency Control Program Davis-Besse 3.8.1-8 Amendment 301

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.11 ------------------------------NOTES-----------------------------

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

2. This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

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

a. De-energization of essential buses; Frequency Control Program

b. Load shedding from essential buses; and

c. EDG auto-starts from standby condition and:

1. Energizes permanently connected loads in 10 seconds;

2. Energizes auto-connected shutdown loads through individual time delay relays;

3. Maintains steady-state voltage 4088 V and 4400 V;

4. Maintains steady-state frequency 59.5 Hz and 60.5 Hz; and

5. Supplies permanently connected and auto-connected shutdown loads for 5 minutes.

Davis-Besse 3.8.1-9 Amendment 301

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.12 -------------------------------NOTE------------------------------

This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify each EDG's noncritical automatic trips are In accordance bypassed on actual or simulated loss of voltage with the signal on the essential bus or an actual or simulated Surveillance Safety Features Actuation System (SFAS) actuation Frequency signal. Control Program SR 3.8.1.13 ------------------------------NOTES-----------------------------

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

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

3. If performed with EDG 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 EDG operates for 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months s: In accordance with the

a. For 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded 2730 kW and Surveillance 2860 kW; and Frequency Control Program

b. For the remaining hours of the test loaded 2340 kW and 2600 kW.

Davis-Besse 3.8.1-10 Amendment 301

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.14 ------------------------------NOTES-----------------------------

1. This Surveillance shall be performed within 5 minutes of shutting down the EDG after the EDG has operated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months loaded 2340 kW and 2600 kW.

Momentary transients outside of load range do not invalidate this test.

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

Verify each EDG starts and achieves: In accordance with the

a. In 10 seconds, voltage 4070 V and Surveillance frequency 59.5 Hz; and Frequency Control Program

b. Steady state voltage 4088 V and 4400 V, and frequency 59.5 Hz and 60.5 Hz.

Davis-Besse 3.8.1-11 Amendment 301

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.15 ------------------------------NOTES-----------------------------

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

2. This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of offsite power In accordance signal in conjunction with an actual or simulated with the SFAS actuation signal: Surveillance Frequency

a. De-energization of essential buses; Control Program

b. Load shedding from essential buses;

c. EDG auto-starts from standby condition and:

1. Energizes permanently connected loads in 10 seconds;

2. Energizes auto-connected emergency loads through load sequencer and individual time delay relays;

3. Achieves steady-state voltage 4088 V and 4400 V;

4. Achieves steady-state frequency 59.5 Hz and 60.5 Hz; and

5. Supplies permanently connected and auto-connected emergency loads for 5 minutes.

Davis-Besse 3.8.1-12 Amendment 301

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action and F.1 Declare associated EDG Immediately associated Completion inoperable.

Time of Condition A, B, C, D, or E not met.

OR One or more EDGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, D, or E.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains In accordance 32,000 gal of fuel. with the Surveillance Frequency Control Program SR 3.8.3.2 Verify lube oil inventory for each EDG is 260 gal. In accordance with the Surveillance Frequency Control Program SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil In accordance are tested in accordance with, and maintained within with the Diesel the limits of, the Diesel Fuel Oil Testing Program. Fuel Oil Testing Program Davis-Besse 3.8.3-2 Amendment 301

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.3.4 Verify each required EDG air start receiver pressure In accordance is 210 psig. with the Surveillance Frequency Control Program SR 3.8.3.5 Check for and remove accumulated water from each In accordance fuel oil storage tank. with the Surveillance Frequency Control Program Davis-Besse 3.8.3-3 Amendment 301

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is greater than or In accordance equal to the minimum established float voltage. with the Surveillance Frequency Control Program SR 3.8.4.2 Verify each required battery charger supplies In accordance 475 amps at greater than or equal to the minimum with the established float voltage for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Surveillance Frequency OR Control Program Verify each required battery charger can recharge the battery to the fully charged state within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

SR 3.8.4.3 ------------------------------NOTES-----------------------------

1. The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.3.

2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4. Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to supply, and In accordance maintain in OPERABLE status, the required actual with the or simulated emergency loads for the design duty Surveillance cycle when subjected to a battery service test. Frequency Control Program Davis-Besse 3.8.4-2 Amendment 301

Battery Parameters 3.8.6 ACTIONS (continued)

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

Time of Condition A, B, C, D, or E not met.

OR One or more batteries with one or more battery cells float voltage 2.07 V and float current > 2 amps.

OR SR 3.8.6.6 not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 -------------------------------NOTE------------------------------

Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.

Verify each battery float current is 2 amps. In accordance with the Surveillance Frequency Control Program SR 3.8.6.2 Verify each battery pilot cell voltage is > 2.07 V. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.8.6-3 Amendment 301

Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.3 Verify each battery connected cell electrolyte level is In accordance greater than or equal to minimum established with the design limits. Surveillance Frequency Control Program SR 3.8.6.4 Verify each battery pilot cell temperature is greater In accordance than or equal to minimum established design limits. with the Surveillance Frequency Control Program SR 3.8.6.5 Verify each battery connected cell voltage is In accordance

> 2.07 V. with the Surveillance Frequency Control Program Davis-Besse 3.8.6-4 Amendment 301

Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.6 -------------------------------NOTE------------------------------

This Surveillance shall not be performed in MODE 1, 2, 3, or 4. Credit may be taken for unplanned events that satisfy this SR.

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

of the expected life with capacity

< 100% of manufacturer's rating AND 24 months when battery has reached 85% of the expected life with capacity 100% of manufacturer's rating Davis-Besse 3.8.6-5 Amendment 301

Inverters - Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify, for each inverter, correct inverter voltage, In accordance frequency, and alignment to the associated with the 120 VAC vital bus. Surveillance Frequency Control Program Davis-Besse 3.8.7-2 Amendment 301

Inverters - Shutdown 3.8.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify, for the required inverter, correct inverter In accordance voltage, frequency, and alignment to the associated with the 120 VAC vital bus. Surveillance Frequency Control Program Davis-Besse 3.8.8-2 Amendment 301

Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A, B, AND or C not met.

D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. Two or more electrical E.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to In accordance required AC, DC, and AC vital bus electrical power with the distribution subsystems. Surveillance Frequency Control Program Davis-Besse 3.8.9-2 Amendment 301

Distribution Systems - Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.4 Declare associated Immediately required decay heat removal subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.10.1 Verify correct breaker alignments and voltage to In accordance required AC, DC, and AC vital bus electrical power with the distribution subsystems. Surveillance Frequency Control Program Davis-Besse 3.8.10-2 Amendment 301

Boron Concentration 3.9.1 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 Boron concentrations of the Reactor Coolant System (RCS) and the refueling canal shall be maintained within the limit specified in the COLR.

APPLICABILITY: MODE 6.

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

Only applicable to the refueling canal when connected to the RCS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Boron concentration not A.1 Suspend positive reactivity Immediately within limit. additions.

AND A.2 Initiate action to restore Immediately boron concentration to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 Verify boron concentration is within the limit In accordance specified in the COLR. with the Surveillance Frequency Control Program Davis-Besse 3.9.1-1 Amendment 301

Nuclear Instrumentation 3.9.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.9.2.2 -------------------------------NOTE------------------------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Davis-Besse 3.9.2-2 Amendment 301

DHR and Coolant Circulation - High Water Level 3.9.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.4 Close equipment hatch and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months secure with four bolts.

AND A.5 Close one door in each air 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months lock.

AND A.6 Verify each penetration 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months providing direct access from the containment atmosphere to the outside atmosphere is either closed with a manual or automatic isolation valve, blind flange, or equivalent, or is capable of being closed by a Containment Purge and Exhaust Isolation System.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.4.1 Verify one DHR loop is in operation and circulating In accordance reactor coolant at a flow rate of 2800 gpm. with the Surveillance Frequency Control Program Davis-Besse 3.9.4-2 Amendment 301

DHR and Coolant Circulation - Low Water Level 3.9.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one DHR loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.9.5.2 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated In accordance power available to the required DHR pump that is with the not in operation. Surveillance Frequency Control Program Davis-Besse 3.9.5-3 Amendment 301

Refueling Canal Water Level 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Refueling Canal Water Level LCO 3.9.6 Refueling canal water level shall be maintained 23 ft above the top of the reactor vessel flange.

APPLICABILITY: During movement of irradiated fuel assemblies within containment.

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

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify refueling canal water level is 23 ft above the In accordance top of reactor vessel flange. with the Surveillance Frequency Control Program Davis-Besse 3.9.6-1 Amendment 301

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.17 Control Room Envelope Habitability Program (continued) occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body for the duration of the accident. The program shall include the following elements:

a. The definition of the CRE and the CRE boundary;

b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance;

c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Section C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0;

d. Measurements, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREVS, operating at the flow rate required by the VFTP, at a Frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 24 month assessment of the CRE boundary;

e. The quantitative limits on unfiltered air leakage 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 Specification 5.5.17.c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA 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; and

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 Specifications 5.5.17.c and 5.5.17.d, respectively.

5.5.18 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications Davis-Besse 5.5-14 Amendment 301

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.18 Surveillance Frequency Control Program (continued) 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 those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, Risk-Informed Technical Specifications Initiative 5b, 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.

Davis-Besse 5.5-15 Amendment 301

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 301 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-3 ENERGY HARBOR NUCLEAR CORP.

ENERGY HARBOR NUCLEAR GENERATION LLC DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 DOCKET NO. 50-346

1.0 INTRODUCTION

By application dated November 14, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19318F668), FirstEnergy Nuclear Operating Company (FENOC) submitted a license amendment request (LAR) for Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse). Effective February 27, 2020, the facility operating license for Davis-Besse was transferred from FirstEnergy Nuclear Generation, LLC (owner) and FENOC (operator) to Energy Harbor Nuclear Generation LLC (owner) and Energy Harbor Nuclear Corp.

(operator) (ADAMS Accession No. ML20030A440). Upon completion of this license transfer, Energy Harbor Nuclear Corp. (EHNC) assumed the responsibility for all licensing actions under U.S. Nuclear Regulatory Commission (NRC or Commission) review at the time of the transfer and requested that the NRC continue its review of these actions (ADAMS Accession No. ML20054B733). This safety evaluation (SE) uses the licensee to refer to the operator of Davis-Besse (i.e., FENOC or EHNC) at the time the action occurred.

The proposed amendment would revise the Davis-Besse technical specifications (TSs) to relocate specific surveillance frequencies to a licensee-controlled program. The proposed changes are based on the Technical Specification Task Force (TSTF) traveler TSTF-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF [Risk-Informed TSTF] Initiative 5b (ADAMS Package Accession No. ML090850642). The NRC published a notice in the Federal Register on July 6, 2009 (74 FR 31996) announcing the availability of TSTF-425, Revision 3, for adoption by licensees and provided a model SE for the NRC staff to use to more efficiently process LARs to adopt TSTF-425, Revision 3.

By letter dated June 23, 2020 (ADAMS Accession No. ML20175A900), EHNC supplemented the application in response to an NRC request for additional information dated June 2, 2020 (ADAMS Accession No. ML20154K764). The supplemental letter provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards Enclosure 2

consideration determination as published in the Federal Register on January 28, 2020 (85 FR 5053).

2.0 REGULATORY EVALUATION

2.1 Description of Proposed Changes The licensee proposed to modify the Davis-Besse TSs by relocating specific surveillance frequencies from the following TS sections to a new surveillance frequency control program (SFCP):

3.1 Reactivity Control Systems 3.2 Power Distribution Limits 3.3 Instrumentation 3.4 Reactor Coolant System (RCS) 3.5 Emergency Core Cooling Systems (ECCS) 3.6 Containment Systems 3.7 Plant Systems 3.8 Electrical Power Systems 3.9 Refueling Operations The requirements for the SFCP will be added to the administrative controls section of the Davis-Besse TSs as TS 5.5.18, Surveillance Frequency Control Program. Once implemented, the SFCP will allow the licensee to make changes to the relocated surveillance frequencies in accordance with the Nuclear Energy Institute (NEI) guidance in NEI 04-10, Revision 1, Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies, dated April 2007 (ADAMS Accession No. ML071360456). By letter dated September 19, 2007 (ADAMS Accession No. ML072570267), the NRC staff approved NEI 04-10, Revision 1, as an acceptable methodology for referencing in licensing actions to the extent specified in NEI 04-10, Revision 1, and under the conditions delineated in the associated NRC SE.

The proposed Davis-Besse TS 5.5.18 reads as follows:

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 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 Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, Risk-Informed Technical Specifications Initiative 5b, 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 LAR stated that the proposed changes are consistent with the NRC-approved TSTF-425, Revision 3. TSTF-425 states that all surveillance frequencies can be relocated to the SFCP except:

Frequencies that reference other approved programs for the specific interval (such as the Inservice 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 LAR included a markup of the TS Bases for each affected surveillance indicating that the surveillance frequency will be controlled under the SFCP.

The LAR proposed other changes and deviations from TSTF-425, Revision 3, which are discussed in SE Section 3.3, Deviations from TSTF-425 and Other Changes.

2.2 Applicable Commission Policy Statements In the Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, published in the Federal Register on 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 TSs. In this 1993 publication, the NRC states, in part:

The Commission believes that it would be inappropriate at this time to allow requirements which meet one or more of the first three criteria[1] 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 of determining the degree of regulatory conservatism that may be warranted for particular decisions.

1 The criteria specified in the final policy statement have been incorporated into Section 50.36(c)(2)(ii) of Title 10 of the Code of Federal Regulations.

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.

The NRC provided additional detail concerning the use of PRA in the Use of Probabilistic Risk Assessment Methods in Nuclear Regulatory Activities; Final Policy Statement, published in the Federal Register on August 16, 1995 (60 FR 42622). In this publication, the NRC states, in part:

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 NRCs 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 Commissions 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 NRCs deterministic approach and supports the NRCs 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 Commissions 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.

2.3 Regulatory Requirements Title 10 to the Code of Federal Regulations (10 CFR) Section 50.36, Technical specifications, establishes the regulatory requirements related to the content of TSs. Section 50.36(a)(1) requires an application for an operating license to include proposed TSs. A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TSs.

Pursuant to 10 CFR 50.36, TSs are required to include items in the following categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs);

(4) design features; and (5) administrative controls. These categories will remain in the Davis-Besse 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 SFCP is intended to ensure that surveillance frequencies are sufficient to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.

Existing regulatory requirements, such as 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants (i.e., the Maintenance Rule), and 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, require licensees to monitor surveillance test failures and implement corrective actions to address such failures. Such failures can result in the licensee increasing the frequency of a surveillance test. In addition, the proposed TS 5.5.18 would require the licensee to monitor the performance of systems, structures, and components (SSCs) for surveillance frequencies that are decreased under the SFCP to assure reduced testing does not adversely impact the SSCs.

2.4 Regulatory Guidance Regulatory Guide (RG) 1.174, Revision 2, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis (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 RG also provides risk acceptance guidelines for evaluating the results of such evaluations.

RG 1.177, Revision 1, An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications (ADAMS Accession No. ML100910008), describes an acceptable risk-informed approach specifically for assessing proposed TS changes.

RG 1.200, Revision 2, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities (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 decisionmaking for light-water reactors (LWRs).

Consistent with Regulatory Issue Summary 2007-06, Regulatory Guide 1.200 Implementation (ADAMS Accession No. ML070650428), the NRC staff uses RG 1.200, Revision 2, to assess the technical adequacy of the PRA used to support risk-informed applications received after March 2010.

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 for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, provides general guidance for evaluating the technical basis for proposed risk-informed changes. This guidance references the same criteria as RG 1.174, Revision 2, and RG 1.177, Revision 1, 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 is explicitly related 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 in core damage frequency (CDF) or risk, the increases should be small and consistent with the intent of the Commissions Safety Goal Policy Statement (60 FR 42622); and The impact of the proposed change should be monitored using performance measurement strategies.

Guidance on evaluating the technical adequacy of the licensees PRA results is provided in Section 19.1, Revision 3, Determining the Technical Adequacy of Probabilistic Risk Assessment for Risk-Informed License Amendment Requests After Initial Fuel Load (ADAMS Accession No. ML12193A107), of NUREG-0800.

The NRC staffs guidance for review of the TSs is in Chapter 16, Revision 3, Technical Specifications (ADAMS Accession No. ML100351425), of NUREG-0800. As described therein, as part of the regulatory standardization effort, the staff has prepared improved standard technical specifications (STS) for each of the LWR nuclear steam supply systems and associated balance-of-plant equipment systems. On November 20, 2008 (ADAMS Package Accession No. ML082900616), the NRC issued a license amendment to convert the TSs at Davis-Besse to TSs based, in part, on the improved STS in NUREG-1430, Revision 3, Standard Technical Specifications: Babcock and Wilcox Plants, Volume 1, published June 2004. Subsequently, the NRC issued NUREG-1430, Revision 4, Volume 1 (ADAMS Accession No. ML12100A177), in April 2012, which incorporated the changes identified in TSTF-425, Revision 3.

More specific guidance for reviewing risk-informed TS changes is provided in Section 16.1, Revision 1, Risk-Informed Decision Making: Technical Specifications (ADAMS Accession No. ML070380228), of NUREG-0800. This includes guidance for reviewing changes to surveillance frequencies as part of risk-informed decisionmaking.

3.0 TECHNICAL EVALUATION

The proposed amendment would revise the Davis-Besse TSs by adding TS 5.5.18 to the administrative controls section, which would specify the requirements for the SFCP, and relocating specific surveillance frequencies to the SFCP. The proposed TS 5.5.18 would require the licensee to use NEI 04-10, Revision 1, to make changes to surveillance frequencies within the SFCP. Enclosure B, Documentation of Davis-Besse PRA Technical Adequacy, of the LAR and the licensees June 23, 2020, letter provided documentation regarding the technical adequacy of the Davis-Besse PRA as recommended in RG 1.200, Revision 2.

NEI 04-10, Revision 1, states that PRA methods are used with plant performance data and other considerations to identify and justify modifications to the surveillance frequencies of equipment at nuclear power plants. This is consistent with guidance in RG 1.174, Revision 2, and RG 1.177, Revision 1, that supports changes to surveillance test intervals.

3.1 Key Principles RG 1.177, Revision 1, identifies five key safety principles required for risk-informed changes to TSs (see SE Section 2.4). Each of these principles is addressed by NEI 04-10, Revision 1.

Sections 3.1.1 through 3.1.5 of this SE discuss the five key principles and provide the NRC staffs evaluation of how each principle is satisfied by the LAR.

3.1.1 The Proposed Change Meets Current Regulations The regulations in 10 CFR 50.36(c)(3) require TSs to include SRs, 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 SRs in the Davis-Besse TSs require the licensee to perform tests, calibrations, or inspections 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 manufacturers recommendations. The licensees use of the NRC-approved methodologies in NEI 04-10, Revision 1, provides an approach to establish risk-informed surveillance frequencies that complements the deterministic approach and supports the NRCs traditional defense-in-depth philosophy.

With the proposed changes, the SRs will remain in the Davis-Besse TSs as required by 10 CFR 50.36(c)(3). However, the relocated surveillance frequencies will be specified in the TSs by reference to the SFCP. The proposed TS 5.5.18 requires the applicable SRs to be performed at intervals sufficient to assure the associated LCOs are met. This change is analogous to other TS requirements in which the SRs are retained in TSs, but the related surveillance frequencies are specified in licensee-controlled documents. Thus, the proposed change complies with 10 CFR 50.36(c)(3) because the Davis-Besse TSs will retain 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 LCOs will be met.

The regulatory requirements in 10 CFR 50.65 and 10 CFR Part 50, Appendix B, Criterion XVI, and the proposed adoption of the monitoring requirements in NEI 04-10, Revision 1, will ensure that surveillance frequencies are sufficient to satisfy 10 CFR 50.36(c)(3), any performance deficiencies will be identified, and that appropriate corrective actions will be taken. The proposed SFCP will ensure that SRs specified in the TSs are performed at a frequency sufficient to assure that the above regulatory requirements are met.

Based on the above, the NRC staff concludes that the proposed changes meet the first key safety principle of RG 1.177, Revision 1, by complying with current regulations.

3.1.2 The Proposed Change is Consistent with Defense-in-Depth Philosophy The defense-in-depth philosophy is the second key safety principle of RG 1.177, Revision 1, and it 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 as compensatory measures associated with the change in licensing basis is avoided.

System redundancy, independence, and diversity are maintained commensurate with the expected frequency and consequences of challenges to the system. Because the scope of the proposed methodology is limited to revision of surveillance frequencies, the redundancy, independence, and diversity of plant systems are not affected.

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

Independence of physical barriers is not degraded.

Defenses against human errors are maintained.

The intent of the plants design criteria is maintained.

The proposed TS 5.5.18 will require the licensee to use NEI 04-10, Revision 1, to make changes to surveillance frequencies within the SFCP. NEI 04-10, Revision 1, uses both CDF and large early release frequency (LERF) metrics to evaluate the impact of proposed changes to surveillance frequencies. In accordance with RG 1.174, Revision 2, and RG 1.177,

Revision 1, changes to CDF and LERF are evaluated using a comprehensive risk analysis that assesses the impact of proposed changes, including contributions from human errors and common-cause failures. Defense-in-depth is explicitly included in the methodology as a qualitative consideration outside of the risk analysis and so is the potential impact on detection of component degradation that could lead to an increased likelihood of common-cause failures.

The NRC staff concludes that both the quantitative risk analysis and the qualitative considerations provide reasonable assurance that defense-in-depth will be maintained to ensure protection of public health and safety, 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 will be 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 licensing basis for Davis-Besse, 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. Therefore, the NRC 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 The Proposed Risk Increases Should be Small When proposed changes using the SFCP result in an increase in risk, the increases should be small and consistent with the intent of the Commissions Safety Goal Policy Statement.

RG 1.177, Revision 1, provides a framework for evaluating the risk impact of proposed changes to surveillance frequencies, which includes identification of the risk contribution from affected surveillances, determination of the risk impact from the change to the proposed surveillance frequency, and performance of sensitivity and uncertainty evaluations. The proposed TS 5.5.18 requires the licensee to use NEI 04-10, Revision 1, to change surveillance frequencies listed in the SFCP. NEI 04-10, Revision 1, satisfies the intent of the RG 1.177, Revision 1, guidelines for evaluating the change in risk and ensures that changes in risk are small by providing the methodology to support risk-informed TSs for control of surveillance frequencies.

3.1.4.1 PRA Technical Adequacy The technical adequacy of the licensees PRA must be commensurate with the safety significance of the proposed change to the TSs and the role the PRA plays in justifying the change. That is, the greater the 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 technical adequacy of the PRA. RG 1.200, Revision 2, provides guidance for assessing the technical adequacy of a PRA and endorses, with clarifications and qualifications, the use of the following:

1. The American Society of Mechanical Engineers (ASME) and American Nuclear Society (ANS) joint standard ASME/ANS RA-Sa-2009, Addenda to ASME/ANS RA-S-2008, Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications, February 2009 (the ASME/ANS PRA standard).

2. NEI 00-02, Revision 1, Probabilistic Risk Assessment (PRA) Peer Review Process Guidance, May 2006 (ADAMS Accession No. ML061510619), and NEI 00-02 Appendix D, Self Assessment Process for addressing ASME PRA Standard RA-Sb-2005, as endorsed by NRC Regulatory Guide 1.200, October 2006 (ADAMS Accession No. ML063390593).

3. NEI 05-04, Revision 2, Process for Performing Internal Events PRA Peer Reviews Using the ASME/ANS PRA Standard, November 2008 (ADAMS Accession No. ML083430462).

The Davis-Besse PRA model that will be used to support the SFCP currently includes internal events, internal flooding, and seismic events. The Davis-Besse fire PRA model, which is based on the internal events model, is being developed and will also be used with the SFCP once it becomes effective in June 2021. For the internal events PRA used in this application, the target capability level for supporting requirements is Capability Category II as defined in the ASME/ANS PRA standard. Any deficiencies in achieving Capability Category II are further assessed to determine the effect on potential decreases to surveillance frequencies in the SFCP. This includes the use of sensitivity studies, where appropriate, in accordance with NEI 04-10, Revision 1.

Section 2.3 of LAR Enclosure B describes the peer reviews for the Davis-Besse internal events PRA. In April 2008, a full-scope peer review addressing all technical elements (excluding large early release and internal flooding) was completed using NRC-endorsed standards in effect at the time. This peer review included a gap assessment for achieving Capability Category II for supporting requirements within the scope of the review. Subsequently, focused-scope peer reviews of the internal events PRA were conducted in accordance with the ASME/ANS PRA standard, as endorsed by RG 1.200, Revision 2, to address LERF in October 2011, internal flooding in July 2012, and a common-cause failure method upgrade in October 2017.

Section 2.3 of LAR Enclosure B also describes the peer review of the Davis-Besse fire PRA.

The fire PRA model was peer reviewed in June 2013 against Part 4 of the ASME/ANS PRA standard, as endorsed by RG 1.200, Revision 2, using the process defined in NEI 07-12, Revision 1, Fire Probabilistic Risk Assessment (FPRA) Peer Review Process Guidelines, June 2010 (ADAMS Package Accession No. ML102230049).

In October 2017, an independent assessment and closeout review addressed the licensees disposition to all facts and observations (F&Os) from the 2008, 2011, 2012, and 2013 peer reviews. The closeout review was based on Appendix X, Close Out of Facts and Observations (F&Os) (ADAMS Accession No. ML17086A451), of NEI 05-04. Supporting requirements that were reassessed were evaluated against the ASME/ANS PRA standard, except the F&Os for the seismic PRA were evaluated against a more recent revision of the ASME/ANS PRA standard (ASME/ANS RA-Sb-2013). For internal events, only supporting requirement SY-B10 remains at Capability Category I, with an open F&O to be resolved to support meeting Capability Category II. While the seismic PRA was assessed using a consensus standard that has not been endorsed by the NRC staff, the revisions from the currently endorsed

ASME/ANS PRA standard are judged to have negligible impact on model results. No F&Os were identified for the seismic PRA.

In a May 3, 2017, letter (ADAMS Accession No. ML17079A427), the NRC staff stated that licensees may use the guidance in Appendix X of NEI 04-10 on an interim basis subject to the following conditions of acceptance:

A PRA method is new if it has not been reviewed by the NRC staff. There are two ways new methods are considered accepted by the NRC staff: (1) they have been explicitly accepted by the NRC (i.e., they have been reviewed, and the acceptance has been documented in a safety evaluation, frequently-asked-questions, or other publicly available organizational endorsement), or (2) they have been implicitly accepted by the NRC (i.e.,

there has been no documented denial) in multiple risk-informed licensing applications. The NRCs treatment of a new PRA method for closure of F&Os is described in the memorandum U.S. Nuclear Regulatory Commission Staff Expectations for an Industry Facts and Observations Independent Assessment Process, dated May 1, 2017 (ADAMS Accession No. ML17121A271).

In order for the NRC to consider the F&Os closed so that they need not be provided in submissions of future risk-informed licensing applications, the licensee should adhere to the guidance in Appendix X in its entirety.

Following the Appendix X guidance will reinforce the NRC staffs confidence in the F&O closure process and potentially obviate the need for a more in-depth review.

In its June 23, 2020, letter, EHNC stated that the October 2017 independent assessment team followed the guidance in Appendix X to NEI 05-14 in its entirety. In addition, EHNC provided information addressing how the five criteria in Appendix X,Section X.1.3, for the selection of team members was met. Based on its review of this information, the NRC staff has reasonable assurance that NRCs conditions of acceptance on Appendix X of NEI 04-10 have been met.

The NRC staff evaluated the open, unresolved F&O for the Davis-Besse internal events PRA.

EHNCs June 23, 2020, letter states that modeling changes to address the F&O have been made to the working PRA model, which will go into effect in June 2021, as part of the scheduled model maintenance. For potential surveillance frequency changes considered before these modeling changes go into effect, the application assessment model will include these changes if a surveillance frequency change affects SSCs relevant to supporting requirement SY-B11. The NRC staff finds this acceptable because it is consistent with the methodology in NEI 04-10, Revision 1.

The October 2017 independent assessment and closeout review also addressed the licensees disposition for all F&Os from the 2013 fire PRA peer review. Five finding-level F&Os for the fire PRA remained open after the independent assessment. The NRC staff reviewed and accepted the disposition of these open F&Os in the SE for Amendment No. 300 to the Davis-Besse license (ADAMS Accession No. ML20213C726). As discussed in Section 3.6.1 of that SE, the independent assessment of the fire PRA determined that each associated supporting requirement met at least Capability Category II, which is sufficient technical quality to support the determination of risk-informed surveillance frequencies.

An additional focused-scope peer review completed in February 2018 concluded that these supporting requirements were met to at least Capability Category II with no new findings.

EHNCs June 23, 2020, letter states that a review of the analysis to verify no similar issues associated with F&O ES-A1-01 and F&O FQ-A1-01 will be done before the fire PRA model is made effective in June 2021. A working fire PRA model has been developed but it does not yet fully reflect the as-built, as-operated plant. Until it is updated, reviewed, and becomes the effective model, the fire PRA will only be used for consideration of risk insights and for sensitivity evaluations, as described in NEI 04-10, Revision 1.

Once the fire PRA model is ready to support implementation of the National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, the licensee will use it as part of the integrated analysis to evaluate surveillance frequency changes. When it becomes effective, the cumulative impact of all prior surveillance frequency changes will be assessed using the fire PRA model. The NRC staff finds this acceptable because it is consistent with the methodology in NEI 04-10, Revision 1.

Based on the preceding analysis, the NRC staff concludes that the licensee addressed the F&Os from the PRA peer reviews and demonstrated that they have no significant impact on the technical adequacy of the PRA. Except as noted above, the licensee followed the guidance in RG 1.200, Revision 2, for assessing the technical adequacy of the Davis-Bess internal events and fire PRA. The NRC staff found the use of an unendorsed revision (i.e., ASME/ANS RA-Sb-2013) to the ASME/ANS PRA standard to assess the seismic PRA to be acceptable. In addition, the NRC staff found the use of Appendix X to NEI 05-14 for the October 2017 independent assessment and closeout review to be acceptable. Therefore, the NRC staff concludes that the Davis-Besse PRA is of sufficient technical adequacy to support the evaluation of changes to TS surveillance frequencies that are relocated to the SFCP.

3.1.4.2 Scope of the PRA The proposed TS 5.5.18 requires changes to surveillance frequencies listed within the SFCP to be made using NEI 04-10, Revision 1, which requires the licensee to determine the potential impact of each surveillance frequency change on 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 are unavailable, the licensee may use 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 insignificant.

The licensee has PRA models for at-power internal events, internal flooding, seismic events, and fire. As required by the proposed TS 5.5.18, and in accordance with NEI 04-10, Revision 1, the licensee will use these PRA models to perform quantitative evaluations to support the development of changes to surveillance frequencies in the SFCP.

Davis-Besse does not have a PRA model for low-power or shutdown conditions. Section 4.0 of LAR Enclosure B states that, consistent with NEI 04-10, Revision 1, a qualitative evaluation of shutdown risk impacts associated with changes to surveillance test intervals will be conducted using the existing defense-in-depth shutdown safety assessment. This assessment is based on the principles contained in NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, December 1991 (ADAMS Accession No. ML14365A203).

For hazard groups for which Davis-Besse does not maintain a PRA model (e.g., high winds, floods, and other external events), the licensee relied on the progressive screening approach used in the program for individual plant examination of external events. Risk related to these hazards will be analyzed qualitatively when they are relevant to surveillance test interval changes. The NRC staff finds this to be consistent with NEI 04-10, Revision 1, and, therefore, acceptable.

The proposed TS 5.5.18 will require the licensee to comply with the NRC-approved methodology in NEI 04-10, Revision 1. Therefore, the NRC staff concludes that the licensees evaluation methodology will ensure the risk contribution of each surveillance frequency change is properly identified for evaluation and is consistent with Regulatory Position 2.3.2, Scope of the Probabilistic Risk Assessment for Technical Specification Change Evaluations, of RG 1.177, Revision 1.

3.1.4.3 PRA Modeling The NEI 04-10, Revision 1, 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 in the PRA, a quantitative evaluation of the risk impact may be carried out. The methodology adjusts the failure probability of the impacted SSCs, including any impacted common-cause failure 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.

The proposed TS 5.5.18 will require the licensee to comply with the NRC-approved methodology in NEI 04-10, Revision 1. Therefore, the NRC staff concludes that through the application of NEI 04-10, Revision 1, the Davis-Besse PRA modeling will ensure an acceptable evaluation of risk for each change to a surveillance frequency, and is consistent with Regulatory Position 2.3.3, Probabilistic Risk Assessment Modeling, 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. Section 1.0 of LAR Enclosure B states, in part:

Neither the current Davis-Besse PRA model nor the industry generic failure data, for which they are based upon, distinguish between the time-related failure contribution (i.e.; the standby time-related failure rate) and the cyclic demand-related failure contribution (i.e., the demand stress failure probability) for standby component failure modes. Since this distinction is not made, FENOC, in accordance with NEI 04-10, Revision 1, will assume that all failures are time-related in calculating the risk impact of a proposed [surveillance test interval]

adjustment, to obtain the maximum test-limited risk contribution. If a further breakdown of failure probability is required to remove conservatism from the risk impact calculation of a proposed surveillance frequency change, it shall be justified through data and/or engineering analyses. Furthermore, FENOC will abide by the cautionary sentence in NEI 04-10, Revision 1, Step 8, third

paragraph, which states: caution should be taken in dividing the failure probability into time-related and cyclic demand-related contributions because the test-limited risk can be underestimated when only part of the failure rate is considered as being time-related while this may not be the case.

Also, the cumulative impact of all risk-informed [surveillance test interval]

revisions on all applicable PRA evaluations (i.e., internal events, external events, and shutdown) is compared to the risk acceptance criteria as delineated in NEI 04-10, Revision 1. For those cases where the [surveillance test interval]

cannot be modeled in the plant PRA (or where a particular PRA model does not exist for a given hazard group), a qualitative or bounding analysis is performed to provide justification for the acceptability of the proposed test interval change.

The SSC failure rate is assumed to be unaffected by the change in test frequency, such that the failure probability is assumed to increase linearly with time. This assumption will be confirmed by the monitoring and feedback process described in NEI 04-10, Revision 1. The NEI 04-10, Revision 1, process requires consideration of qualitative sources of informationincluding industry and plant-specific operating experience, vendor recommendations, industry standards, and code-specified test intervalswhen evaluating potential impacts of changes to the test frequency on SSC performance. Therefore, the NRC staff finds that the SFCP at Davis-Besse would not solely rely on risk analyses as the basis for changes in surveillance frequencies because the proposed TS 5.5.18 will require the use of the methodology in NEI 04-10, Revision 1.

The potential beneficial risk impacts of a reduced surveillance frequencyincluding reduced downtime and reduced potential for restoration errors, test-caused transients, and test-caused wear of equipmentare identified qualitatively and are not required to be quantitatively assessed. Therefore, the NRC staff concludes that, through the application of NEI 04-10, Revision 1, Davis-Besse will use reasonable assumptions to extend surveillance test intervals, and the requested changes are consistent with Regulatory Position 2.3.4, Assumptions in Completion Time and Surveillance Frequency Evaluations, of RG 1.177, Revision 1.

3.1.4.5 Sensitivity and Uncertainty Analyses The proposed TS 5.5.18 requires changes to surveillance frequencies listed within the SFCP to be made using NEI 04-10, Revision 1. The NEI 04-10, Revision 1, methodology requires sensitivity studies to assess the impact of uncertainties in key assumptions of the PRA, uncertainties in the failure probabilities for affected SSCs, the frequency of initiating events, and deviations from Capability Category II of the ASME/ANS 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. In addition, NEI 04-10, Revision 1, requires the monitoring and feedback of SSC performance once the revised surveillance frequencies are implemented. Therefore, the NRC staff concludes that the licensee, through the application of NEI 04-10, Revision 1, will appropriately consider the possible impact of PRA model uncertainty and sensitivity to key assumptions and model limitations consistent with Regulatory Position 2.3.5, Sensitivity and Uncertainty Analyses Relating to Assumptions in Technical Specification Change Evaluations, of RG 1.177, Revision 1.

3.1.4.6 Acceptance Guidelines The proposed TS 5.5.18 requires changes to surveillance frequencies listed within the SFCP to be made using NEI 04-10, Revision 1. The NEI 04-10, Revision 1, methodology requires a quantitative evaluation of the change in total risk (including contributions from internal and external events) in terms of CDF and LERF for both the individual risk impact of a proposed surveillance frequency change and the cumulative impact from all individual changes to surveillance frequencies. Each individual change to a surveillance frequency must show a risk increase below 10-6 per year for CDF and below 10-7 per year for LERF. These changes to CDF and LERF are consistent with the acceptance guidelines of RG 1.174, Revision 2, for very small changes in risk. If the RG 1.174, Revision 2, acceptance guidelines are not met, then the surveillance frequencies must either be revised to be consistent with RG 1.174, Revision 2, or the process terminates without permitting the proposed changes. If 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 a surveillance frequency is negligible or insignificant. Otherwise, bounding quantitative analyses are required that 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 results in an increase in CDF and LERF of less than 10-5 per year and 10-6 per year, respectively. The total CDF and total LERF must be reasonably shown to be less than 10-4 per year and 10-5 per year, respectively. These values are consistent with the risk acceptance guidelines of RG 1.174, Revision 2, as referenced by RG 1.177, Revision 1, for changes to surveillance frequencies.

The quantitative risk acceptance guidelines of RG 1.174, Revision 2, are supplemented by qualitative information to evaluate changes to surveillance frequencies, including industry and plant-specific operating experience, vendor recommendations, industry standards, results of sensitivity studies, and SSC performance data and test history. The final acceptability of the proposed surveillance frequencies change is based on all these considerations and not solely on the PRA results. Post-implementation performance monitoring and feedback are also required to ensure continued reliability of the components. The NRC-approved 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, Acceptance Guidelines for Technical Specification Changes, of RG 1.177, Revision 1.

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

3.1.5 The Impact of the Proposed Change Should Be Monitored Using Performance Measurement Strategies The proposed TS 5.5.18 requires changes to surveillance frequencies listed within the SFCP to be made using NEI 04-10, Revision 1. The methodology in NEI 04-10, Revision 1, includes performance monitoring of SSCs whose surveillance frequencies have been revised as part of a feedback process to ensure that the change in test frequency has not resulted in degradation of equipment performance and operational safety. The monitoring and feedback include consideration of Maintenance Rule monitoring of equipment performance. In the event of SSC performance degradation, the surveillance frequency would be reassessed in accordance with the methodology in NEI 04-10, Revision 1, in addition to any corrective actions that may be required by the Maintenance Rule.

The performance monitoring and feedback process specified in NEI 04-10, Revision 1, which would be required by proposed TS 5.5.18, provides reasonable assurance of acceptable SSC performance and is consistent with Regulatory Position 3.2, Maintenance Rule Control, in RG 1.177, Revision 1. Therefore, the NRC staff concludes that the fifth key safety principle of RG 1.177, Revision 1, is satisfied.

3.1.6 NRC Conditions for NEI 04-10, Revision 1 Section 4.0 of the NRC staffs SE for NEI 04-10, Revision 1, states:

The NRC staff finds that the methodology in NEI 04-10, Revision 1 is acceptable for referencing by licensees proposing to amend their TSs to establish a SFCP provided the following conditions are satisfied:

1. The licensee submits documentation with regards to PRA technical adequacy consistent with the requirements of RG 1.200, Section 4.2.

2. When a licensee proposes to use PRA models for which NRC-endorsed standards do not exist, the licensee submits documentation which identifies the quality characteristics of those models, consistent with RG 1.200 Sections 1.2 and 1.3. Otherwise, the licensee identifies and justifies the methods to be applied for assessing the risk contribution for those sources of risk not addressed by PRA models.

Section 3.1.4.1 of this SE discusses the technical adequacy of the licensees PRA model and finds it to be consistent with NRC-endorsed guidance. As discussed in Section 3.1.4.1 of this SE, the NRC staff finds the information provided in the LAR, as supplemented, supports the licensees proposed PRA and, therefore, the conditions in the NRC staffs SE for NEI 04-10, Revision 1, have been met.

3.2 Addition of Surveillance Frequency Control Program to Administrative Controls As discussed in SE Section 2.1, the requirements for the SFCP will be added to the administrative controls section of Davis-Besses TSs as TS 5.5.18. Based on its review in SE Section 3.1, the NRC staff finds that the proposed SFCP is an acceptable program for controlling changes to surveillance frequencies. The staff finds that the proposed TS 5.5.18 includes the necessary program and applicability requirements, that those requirements are consistent with the TSTF-425, Revision 3, and that those requirements will ensure that LCOs are met. Therefore, the NRC staff finds proposed TS 5.5.18 acceptable.

3.3 Deviations from TSTF-425 and Other Changes The insert provided in TSTF-425, Revision 3, for revising the STS Bases states: The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. Instead of using the insert provided in TSTF-425, the LAR states the Davis-Besse TS Bases will be revised to include either The Surveillance Frequency is controlled under the Surveillance Frequency Control Program or The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program, as appropriate. In a letter dated April 14, 2010 (ADAMS Accession No. ML100990099), the NRC staff confirmed that the TS Bases insert for TSTF-425, Revision 3, applies to surveillance frequencies that are relocated and subsequently evaluated

and changed in accordance with the SFCP, but it does not apply to surveillance frequencies relocated to the SFCP that are not changed. The NRC staff determined that the Davis-Besse TS Bases inserts are consistent with the intent of TSTF-425, Revision 3, and do not impact the conclusions reached in the NRCs model SE for TSTF-425, Revision 3. Therefore, this deviation from TSTF-425, Revision 3, is acceptable.

TSTF-425, Revision 3, deletes the definition of staggered test basis from the STS. However, the licensee stated it will retain this definition in Davis-Besse TS Section 1.1, Definitions, due to its continued use in TS 5.5.17, Control Room Envelope Habitability Program. The NRC staff determined that this deviation from TSTF-425, Revision 3, is acceptable because this definition will continue to be used in TS 5.5.17.

The proposed Davis-Besse TS 5.5.18 uses the full title of NEI 04-10, Revision 1, instead of the partial title use in TSTF-425, Revision 3. The NRC staff finds this variation from TSTF-425, Revision 3, is acceptable because it is editorial.

LAR Attachment L-19-233 provided a cross-reference between the SRs in the Davis-Besse TSs and those in NUREG-1430 which are relevant to the adoption of TSTF-425, Revision 3. As discussed in Section 2.2 of LAR Enclosure A, FENOC Description and Assessment of the Proposed Amendment, the cross-reference contains the following:

1. NUREG-1430 SRs included in TSTF-425, Revision 3, and the corresponding Davis-Besse SRs with identical SR numbers;

2. NUREG-1430 SRs included in TSTF-425, Revision 3, and the corresponding Davis-Besse SRs with differing SR numbers;

3. NUREG-1430 SRs included in TSTF-425, Revision 3, that are not contained in the Davis-Besse TSs; and

4. Davis-Besse plant-specific SRs that are not contained in NUREG-1430 and, therefore, are not included in TSTF-425, Revision 3.

Some Davis-Besse SRs differ from the corresponding NUREG-1430 SRs in equipment names, grammatical structure, additional descriptive information, units of measurement for a parameter, or other differences as described in the cross-reference table. The NRC staff reviewed the differences related to items 1 and 2 above and determined that they are editorial. Therefore, the staff finds that these differences do not affect the applicability of TSTF-425, Revision 3, and they do not impact the conclusions reached in the NRC's model SE for TSTF-425, Revision 3.

The licensee also requested to relocate certain surveillance frequencies to the SFCP for SRs at Davis-Besse that are not contained in NUREG-1430 and, therefore, are not included in TSTF-425, Revision 3. These SRs are listed in Section 2.2 of LAR Enclosure A. The NRC staff reviewed these SRs and determined that the relocation of the associated surveillance frequencies to the SFCP is acceptable because they are fixed periodic frequencies that do not meet any of the four exclusion criteria in TSTF-425, Revision 3 (see Section 2.1 of this SE).

Therefore, the NRC staff finds that relocation of these surveillance frequencies to the SFCP is acceptable because the change is consistent with the intent of TSTF-425, Revision 3, and the SRs will continue to meet 10 CFR 50.36(c)(3).

3.4 Summary and Conclusions The NRC staff reviewed the licensees proposed relocation of certain TS surveillance frequencies to a licensee-controlled document that will be administratively controlled in accordance with a new SFCP, as specified in the proposed TS 5.5.18. The proposed TS 5.5.18 requires changes to surveillance frequencies listed within the SFCP to be made using NEI 04-10, Revision 1, which provides a risk-informed methodology for revising surveillance frequencies that uses plant-specific risk insights and performance data. This NRC-approved methodology supports relocating surveillance frequencies from TSs to a licensee-controlled document.

The proposed TS changes are consistent with TSTF-425, Revision 3, and the conditions in the NRC staffs SE for NEI 04-10, Revision 1, have been met. The use of the risk-informed methodology in NEI 04-10, Revision 1, as required by the proposed TS 5.5.18, satisfies the key principles of risk-informed decision making applied to changes to TSs as delineated in RG 1.174, Revision 2, and RG 1.177, Revision 1:

The proposed changes meet current regulations; The proposed changes are consistent with the defense-in-depth philosophy; The proposed changes maintain sufficient safety margins; Increases in risk resulting from the proposed changes are small and consistent with the Commissions Safety Goal Policy Statement; and The impact of the proposed changes is monitored with performance measurement strategies.

The regulations in 10 CFR 50.36(c) require, in part, that the TSs include SRs. The regulation in 10 CFR 50.36(c)(3) states that: 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 that will be administratively controlled in accordance with the SFCP, as specified in the proposed TS 5.5.18, the licensee will continue to meet the requirements in 10 CFR 50.36.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Ohio State official was notified on September 29, 2020, of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the installation or use of facility components located within the restricted areas as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite,

and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding, which was published in the Federal Register on January 28, 2020 (85 FR 5053), that the amendment involves no significant hazards consideration, and there has been no public comment on such finding.

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 Commission 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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Malcolm Patterson, NRR Jigar Patel, NRR Tarico Sweat, NRR Date of Issuance: November 3, 2020

ML20280A827 *by email OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA* NRR/DSS/STSB/BC*

NAME BPurnell SRohrer VCusumano DATE 10/08/2020 10/07/2020 9/14/2020 OFFICE NRR/DEX/EICB/BC* NRR/DRA/APLA/BC* NRR/DEX/EEOB/BC*

NAME MWaters RPascarelli BTitus DATE 10/19/2020 8/26/2020 10/05/2020 OFFICE OGC - NLO* NRR/DORL/LPL3/BC* NRR/DORL/LPL3/PM*

NAME KGamin NSalgado (JWiebe for) BPurnell DATE 10/22/2020 11/02/2020 11/03/2020

v t e Letter Sequence Approval
EPID:L-2019-LLA-0252, TSTF-425 (Approved, Closed)
Initiation Request Acceptance Administration Questions 2 June 2020 Answers 23 June 2020 Results Approval Other:
MONTHYEAR2020-11-03 [Table View]

ML20280A827

Text

SUBJECT:

Dear Mr. Brown:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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