Text

Perry Nuclear Power Plant, Unit 1 - Issuance of Amendment Concerning Adoption of TSTF-425, Relocate Surveillance Frequencies to Licensee Control (CAC No. MF3720) (L-14-106)
	ML15307A349
Person / Time
Site:	Perry
Issue date:	02/23/2016
From:	Green K J; Plant Licensing Branch III
To:	Hamilton D B; FirstEnergy Nuclear Operating Co
	Green K J, NRR/DORL/LPLIII-1
References
	CAC MF3720, L-14-106
	Download: ML15307A349 (165)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. David B. Hamilton Site Vice President February 23, 2016 FirstEnergy Nuclear Operating Company Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT NO. 1 -ISSUANCE OF AMENDMENT CONCERNING ADOPTION OF TSTF-425, "RELOCATE SURVEILLANCE FREQUENCIES TO LICENSEE CONTROL" (CAC NO. MF3720) (L-14-106)

Dear Mr. Hamilton:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 171 to Facility Operating License No. NPF-58 for Perry Nuclear Power Plant, Unit No. 1. The amendment consists of changes to the technical specifications (TSs) in response to your application dated March 25, 2014, as supplemented by letters dated October 7, 2014, and August 24, 2015. The amendment modifies the TSs by relocating specific surveillance frequencies to a controlled program. The proposed changes are consistent with the NRG-approved Technical Specifications Task Force (TSTF) Traveler, TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative Sb."

D. Hamilton A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Docket No. 50-440

Enclosures:

1. Amendment No. 171 to NPF-58 2. Safety Evaluation cc w/encls: Distribution via ListServ Sincerely, Kimberly J. Green, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION, LLC OHIO EDISON COMPANY DOCKET NO. 50-440 PERRY NUCLEAR POWER PLANT, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 171 License No. NPF-58 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that: A. The application for license filed by FirstEnergy Nuclear Operating Company, et al. (the licensee, FENOC), dated March 25, 2014, as supplemented by letters dated October 7, 2014, and August 24, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied. 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 Facility Operating License No. NPF-58 is hereby amended to read as follows: (2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 171, are hereby incorporated into the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. 3. This license amendment is effective as of its date of its issuance and shall be implemented within 120 days of the date of issuance.

Attachment:

Changes to the Facility Operating License No. NPF-58 and Technical Specifications FOR THE NUCLEAR REGULA TORY COMMISSION David J. wlona, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: February 23, 2016 ATTACHMENT TO LICENSE AMENDMENT NO. 171 FACILITY OPERATING LICENSE NO. NPF-58 DOCKET NO. 50-440 Replace the following pages of the 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-58 License NPF-58 -4 -TSs TSs REMOVE INSERT REMOVE INSERT REMOVE INSERT REMOVE INSERT 1.0-6 1.0-6 3.3-69 3.3-69 3.6-26 3.6-26 3.8-9 3.8-9 3.1-10 3.1-10 3.3-72 3.3-72 3.6-30 3.6-30 3.8-10 3.8-10 3.1-13 3.1-13 3.3-75 3.3-75 3.6-33 3.6-33 3.8-11 3.8-11 3.1-17 3.1-17 3.3-79 3.3-79 3.6-35 3.6-35 3.8-12 3.8-12 3.1-19 3.1-19 3.4-4 3.4-4 3.6-38 3.6-38 3.8-13 3.8-13 3.1-21 3.1-21 3.4-6 3.4-6 3.6-39 3.6-39 3.8-14 3.8-14 3.1-22 3.1-22 3.4-7 3.4-7 3.6-41 3.6-41 3.8-15 3.8-15 3.1-25 3.1-25 3.4-8 3.4-8 3.6-43 3.6-43 3.8-23 3.8-23 3.2-1 3.2-1 3.4-9 3.4-9 3.6-47 3.6-47 3.8-25 3.8-25 3.2-2 3.2-2 3.4-11 3.4-11 3.6-48 3.6-48 3.8-26 3.8-26 3.2-3 3.2-3 3.4-13 3.4-13 3.6-50 3.6-50 3.8-27 3.8-27 3.3-3 3.3-3 3.4-18 3.4-18 3.6-52 3.6-52 3.8-33 3.8-33 3.3-4 3.3-4 3.4-20 3.4-20 3.6-55 3.6-55 3.8-34 3.8-34 3.3-5 3.3-5 3.4-23 3.4-23 3.6-58 3.6-58 3.8-37 3.8-37 3.3-6 3.3-6 3.4-25 3.4-25 3.6-60 3.6-60 3.8-39 3.8-39 3.3-12 3.3-12 3.4-27 3.4-27 3.6-60a 3.6-60a 3.9-1 3.9-1 3.3-13 3.3-13 3.4-29 3.4-29 3.6-64 3.6-64 3.9-2 3.9-2 3.3-14b 3.3-14b 3.4-32 3.4-32 3.6-67 3.6-67 3.9-3 3.9-3 3.3-14c 3.5-4 3.5-4 3.6-69 3.6-69 3.9-4 3.9-4 3.3-16 3.3-16 3.5-5 3.5-5 3.6-70 3.6-70 3.9-7 3.9-7 3.3-17 3.3-17 3.5-7 3.5-7 3.6-72 3.6-72 3.9-8 3.9-8 3.3-22 3.3-22 3.5-8 3.5-8 3.7-2 3.7-2 3.9-9 3.9-9 3.3-24 3.3-24 3.5-9 3.5-9 3.7-3 3.7-3 3.9-12 3.9-12 3.3-25 3.3-25 3.5-11 3.5-11 3.7-6 3.7-6 3.9-15 3.9-15 3.3-27 3.3-27 3.5-12 3.5-12 3.7-7 3.7-7 3.10-5 3.10-5 3.3-28 3.3-28 3.6-7 3.6-7 3.7-10 3.7-10 3.10-8 3.10-8 3.3-30 3.3-30 3.6-8 3.6-8 3.7-12 3.7-12 3.10-11 3.10-11 3.3-31 3.3-31 3.6-15 3.6-15 3.7-13 3.7-13 3.10-12 3.10-12 3.3-38 3.3-38 3.6-16 3.6-16 3.7-14 3.7-14 3.10-14 3.10-14 3.3-38a 3.6-17 3.6-17 3.7-15 3.7-15 3.10-15 3.10-15 3.3-46 3.3-46 3.6-19 3.6-19 3.7-18 3.7-18 3.10-17 3.10-17 3.3-53 3.3-53 3.6-20 3.6-20 3.7-20 3.7-20 3.10-21 3.10-21 3.3.53a 3.3.53a 3.6-21 3.6-21 3.8-5 3.8-5 3.10-22 3.10-22 3.3-62 3.3-62 3.6-23 3.6-23 3.8-6 3.8-6 5.0-15c 5.0-15c 3.3-66 3.3-66 3.6-25 3.6-25 3.8-7 3.8-7 5.0-15d 3.8-8 3.8-8 renewal. Such sale and leaseback transactions are subject to the representations and conditions set forth in the above mentioned application of January 23, 1987, as supplemented on March 3, 1987, as well as the letter of the Director of the Office of Nuclear Reactor Regulation dated March 16, 1987, consenting to such transactions. Specifically, a lessor and anyone else who may acquire an interest under these transactions are prohibited from exercising directly or indirectly any control over the licenses of PNPP Unit 1. For purposes of this condition the limitations of 10 CFR 50.81, as now in effect and as may be subsequently amended, are fully applicable to the lessor and any successor in interest to that lessor as long as the license for PNPP Unit 1 remains in effect; these financial transactions shall have no effect on the license for the Perry Nuclear facility throughout the term of the license. (b) Further, the licensees are also required to notify the NRC in writing prior to any change in: (i) the terms or conditions of any lease agreements executed as part of these transactions; (ii) the PNPP Operating Agreement; (iii) the existing property insurance coverage for PNPP Unit 1; and (iv) any action by a lessor or others that may have an adverse effect on the safe operation of the facility. C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now and hereafter in effect; and is subject to the additional conditions specified or incorporated below: (1) Maximum Power Level FENOC is authorized to operate the facility at reactor core power levels not in excess of 3758 megawatts thermal (100% power) in accordance with the conditions specified herein. (2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 171 are hereby incorporated into the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. (3) Antitrust Conditions a. FirstEnergy Nuclear Generation, LLC and Ohio Edison Company Amendment No. 171 Definitions 1.1 1.1 Definitions (continued) SHUTDOWN MARGIN (SOM) THERMAL POWER TURBINE BYPASS SYSTEM RESPONSE TIME PERRY -UNIT 1 SOM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that: a. The reactor is*xenon free. b. The moderator temperature is 68°F. corresponding to the most reactive state: and c. All control rods are fully inserted except for the single control rod of highest reactivity worth. which is assumed to be fully withdrawn. With control rods not capable of being fully inserted. the reactivity worth of these control rods must be accounted for in the determination of SOM. THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant. The TURBINE BYPASS SYSTEM RESPONSE TIME consists of two components: a. The time from initial movement of the main turbine stop valve or control valve until 80% of the turbine bypass capacity is established: and b. The time from initial movement of the main turbine stop valve or control valve until initial movement of the turbine bypass valve. The response time may be measured by means of any series of sequential. overlapping. or total steps so that the entire response time is measured. 1. 0-6 Amendment No. 171

Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS SR 3.1.3.1 SR 3.1.3. 2 SR 3.1. 3. 3 PERRY -UNIT 1 SURVEILLANCE FREQUENCY Determine the position of each control rod. In accordance with the Surveillance Frequency Control Program -------------------NOTE--------------------Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RPCS. Insert each withdrawn control rod at least In accordance one notch. with the Surveillance Frequency Control Program Verify each control rod scram time from fully withdrawn to notch position 13 is 7 seconds. 3.1-10 In accordance with SR 3.1.4.1. SR 3.1.4.2. SR 3.1.4.3. and SR 3.1.4.4 (continued) Amendment No.171 Control Rod Scram Times 3.1.4 SURVEILLANCE REQUIREMENTS (continued) SR 3.1.4. 2 SR 3.1.4.3 SR 3.1.4.4 PERRY -UNIT 1 SURVEILLANCE Verify. for a representative sample. each tested control rod scram time is within the limits of Table 3.1.4-1 with reactor steam dome pressure 950 psig. Verify each affected control rod scram time is within the limits of Table 3.1.4-1 with any reactor steam dome pressure. Verify each affected control rod scram time is within the limits of Table 3.1.4-1 with reactor steam dome pressure 950 psig. 3.1-13 FREQUENCY In accordance with the Surveillance Frequency Control Program Prior to declaring control rod OPERABLE after work on control rod or CRD System that could affect scram time Prior to exceeding 40% RTP after fuel movement within the affected core cell AND Prior to exceeding 40% RTP after work on control rod or CRD System that could affect scram time Amendment No.171 Control Rod Scram Accumulators 3.1.5 ACTIONS CONDITION REQUIRED ACTION C. (continued) C.2 Declare the associated control rod inoperable. D. Required Action and D.l --------NOTE---------associated Completion Not applicable if all Time of Required inoperable control Action B.l or C.l not rod scram met. accumulators are associated with fully inserted control rods, ---------------------Place the reactor mode switch in the shutdown position. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.1.5.1 Verify each control rod scram accumulator pressure is 1520 psig. PERRY -UNIT 1 3.1-17 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No . 171 ACTIONS (continued) CONDITION B. Nine or more OPERABLE B.l control rods not in compliance with BPWS. REQUIRED ACTION Affected control rods may be bypassed in RACS in accordance with SR 3.3.2.1.9 for insertion only. Control Rod Pattern 3.1.6 COMPLETION TIME Suspend withdrawal of Immediately control rods. SURVEILLANCE REQUIREMENTS AND B.2 SURVEILLANCE Place the reactor mode switch in the shutdown position. SR 3.1.6.l Verify all OPERABLE control rods comply with BPWS. PERRY -UN IT I 3. 1-19 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months FREQUENCY In accordance with the Survei 11 ance Frequency Control Program No . 171 SURVEILLANCE REQUIREMENTS SR 3 .1. 7 .1 SR 3.1. 7 .2 SR 3.1. 7 .3 SR 3.1. 7 .4 SR 3.1. 7 .5 PERRY -UNIT 1 SURVEILLANCE Verify available volume of borax-boric acid solution is within the limits of Figure 3.1.7-1. Verify temperature of borax-boric acid solution is 70°F. Verify temperature of pump suction piping is 70°F. Verify continuity of explosive charge. Verify the concentration of boron in solution is within the limits of Figure 3.1. 7-1. 3.1-21 SLC System 3.1. 7 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance w.ith the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after water or boron is added to solution AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after solution temperature is restored to 70°F (continued) Amendment No. 171 URVEILLANCE REQUIREMENTS (continued) SR 3.1.7.6 SR 3.1. 7. 7 SR 3.1. 7. 8 SR 3.1. 7. 9 PERRY -UNIT 1 SURVEILLANCE Verify each SLC subsystem manual. power operated. and automatic valve in the flow path that is not locked. sealed. or otherwise secured in position. is in the correct position. or can be aligned to the correct position. Verify each pump develops a flow rate 32.4 gpm at a discharge pressure 1220 psig. Verify flow through one SLC subsystem from pump into reactor pressure vessel. Veri.fy all heat traced piping between storage tank and pump suction is unblocked. 3.1-22 SLC System 3.1. 7 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Inservice Testing Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after pump suction piping temperature is restored to 70°F Amendment No. 171 SDV Vent and Drain Valves 3 .1.8 SURVEILLANCE REQUIREMENTS SR 3 .1. 8 .1 SR 3. 1. 8. 2 SR 3 .1. 8. 3 PERRY -UNIT 1 SURVEILLANCE -------------------NOTE--------------------Not required to be met on vent and drain valves closed during performance of SR 3. 1. 8. 2. Verify each SDV vent and drain valve is open. Cycle each SDV vent and drain valve to the fully closed and fully open position. Verify each SDV vent and drain valve: a. Closes in 30 seconds after receipt of an actual or simulated scram signal ; and b. Opens when the actual or simulated scram signal is reset. 3.1-25 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 3.2 POWER DISTRIBUTION LIMITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) APLHGR 3.2.1 LCO 3.2.1 All APLHGRs shall be less than or equal to the limits specified in the COLR. APPLICABILITY: THERMAL POWER 2 23.8% RTP. ACTIONS CONDITION REQUIRED ACTION A. Any APLHGR not within A. l Restore APLHGR(s) to limits. within limits. B. Required Action and B.1 Reduce THERMAL POWER associated Completion to < 23. 8% RTP. Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3. 2 .1.1 Verify all APLHGRs are less than or equal to the limits specified in the COLR. PERRY -UN IT 1 3.2-1 COMPLETION TIME 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 4 hours FREQUENCY Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 2 23.8% RTP AND In accordance with the Surveillance Frequency Control Program Amendment No. 171 3.2 POWER DISTRIBUTION LIMITS 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR) MCPR 3.2.2 LCD 3. 2. 2 All MCPRs sha 11 be greater than or equal to the MCPR operating limits specified in the COLR. APPLICABILITY: THERMAL 23.8% RTP. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any MCPR not within A. l Restore MCPR(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limits. within limits. B. Required Action and B.l Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to< 23.8% RTP. Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.l Verify all MCPRs are greater than or equal Once within to. the limits specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 23.8% RTP PERRY -UN IT 1 3.2-2 AND In accordance with the Survei l lance Frequency Control Program Amendment No.171 3.2 POWER DISTRIBUTION LIMITS 3.2.3 LINEAR HEAT GENERATION RATE (LHGR) LHGR 3.2.3 LCO 3.2.3 All LHGRs shall be less than or equal to the limits specified in the COLR. APPLICABILITY: THERMAL POWER 23.8% RTP. ACTIONS CONDITION REQUIRED ACTION COMPLETION TI ME A. Any LHGR not within A.1 Restore LHGR(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limits. within limits. B. Required Action and B.1 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to< 23.8% RTP. Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify all LHGRs are less than or equal to Once within* the limits specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 23.8% RTP PERRY -UNIT 1 3.2-3 AND In accordance with the Surveillance Frequency Control Program Amendment No. 171 RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS -------------------------------------NOTES------------------------------------1. Refer to Table 3.3.1.1-1 to determine which SRs apply for each RPS Function. 2. When a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains RPS trip capability. SURVEILLANCE FREQUENCY SR 3.3.1.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.2 ------------------NOTE-------------------Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL 23.8% RTP. -----------------------------------------Verify the absolute difference between In accordance the average power range monitor (APRM) with the channels and the calculated power Surveillance 2% RTP while operating at 23.8% RTP. Frequency Control Program SR 3.3.1.1.3 the channel to conform to a In accordance ca ibrated flow signal. with the Surveillance Frequency Control Program SR 3.3.1.1.4 --------------., ---NOTE ---*_ ---------------Not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2. -----------------------------------------Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued) PERRY -UNIT 1 3.3-3 Amendment No . 171 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.3.1.1.5 Perform CHANNEL FUNCTIONAL TEST. SR 3.3.1.1.6 Verify the source range monitor CSRM) and intermediate range monitor (IRM) channels overlap. SR 3.3.1.1.7 ------------------NOTE-------------------RPS Instrumentation 3.3.1.1 FREQUENCY In accordance with the Surveillance Frequenc.p Control rogram Prior to withdrawing SRMs f rbm the fully inserted position Only to be met during entry into MODE 2 rom MODE 1. -----------------------------------------Verify the IRM and APRM channels overlap. In accordance with the Surveillance Frequenc.p Control rogram SR 3.3.1.1.8 Calibrate the local power range monitors. In accordance with the Surveillance Frequency . Control Program SR 3.3.1.1.9 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.10 Calibrate the trip unit. In accordance with the Surveillance Frequenc.p Control rogram (continued) PERRY -UNIT 1 3.3-4 Amendment No . 1 71 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.3.1.1.11 ------------------NOTES------------------SR 3. 3 .1.1. 12 1. Neutron detectors and flow reference transmitters are excluded. 2. For Function 2.a. not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2. Perform CHANNEL CALIBRATION. Perform CHANNEL FUNCTIONAL TEST. SR 3.3.1.1.13 ------------------NOTES------------------1. Neutron detectors are excluded. 2. For IRMs. not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2. Perform CHANNEL CALIBRATION. SR 3.3.1.1.14 Verify the APRM flow Biased Simulated Thermal-High time constant is within the limits specified in the COLR. SR 3.3.1.1.15 Perform LOGIC SYSTEM FUNCTIONAL TEST. PERRY -UN IT 1 3.3-5 RPS Instrumentation 3.3.1.1 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program <continued) Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued) SR 3.3.1.1.16 SR 3.3.1.1.17 SURVEILLANCE Verify Turbine Stop Valve Closure and Turbine Control Valve Fast Closure Trip Oil Pressure-Low Functions are not bypassed when THERMAL POWER is 38% RTP. Calibrate flow reference transmitters. SR 3.3.1.1.18 ------------------NOTES------------------SR 3. 3 .1.1.19 PERRY -UN IT 1 1. Neutron detectors are excluded. 2. For Functions 3. 4 and 5 in Table 3.3.1.1-1, the channel sensors are excluded. Verify the RPS RESPONSE TIME is within limits. Perform CHANNEL FUNCTIONAL TEST 3.3-6 RPS Instrumentation 3.3.1.1 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Contra l Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS -------------------------------------NOTE-------------------------------------Refer to Table 3.3.1.2-1 to determine which SRs apply for each applicable MODE or other specified conditions. SR 3.3.1.2.l SR 3 . 3 . 1. 2 . 2 SR 3 . 3 . 1. 2 . 3 PERRY -UN IT 1 SURVEILLANCE Perform CHANNEL CHECK. ------------------NOTES------------------1. Only required to be met during CORE ALTERATIONS. 2. One SRM may be used to satisfy more than one of the following. Verify an OPERABLE SRM detector is located in: a. The fueled region; b. The core quadrant where CORE ALTERATIONS are being performed when the associated SRM is included tn the fueled region: and c. A core quadrant adjacent to where CORE ALTERATIONS are being performed. when the associated SRM is included in the fueled region.

Perform CHANNEL CHECK. 3.3-12 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No . 171 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.3.1.2.4 ------------------NOTE-------------------Not required to be met with less than or equal to four fuel assemblies adjacent to the SRM and no other fuel assemblies in the associated core quadrant. Verify count rate is: a. 3.0 cps. or b. 0.7 cps with a signal to noise ratio 2:1. SR 3.3.1.2.5 ------------------NOTE-------------------SR 3 . 3 . 1. 2 . 6 PERRY -UNIT 1 Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after IRMs on Range 2 or below. Perform CHANNEL FUNCTIONAL TEST. 1. Neutron detectors are excluded. 2. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after IRMs on Range 2 or below. Perform CHANNEL CALIBRATION. 3.3-13 SRM Instrumentation 3.3.1.2 FREQUENCY

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No . 171 OPRM Instrumentation 3.3.1.3 SURVEILLANCE REQUIREMENTS ------------------------------------NOTE-------------------------------------When a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . provided the OPRM maintains trip capability. SR 3 . 3 . 1. 3 . 1 SR 3.3.1.3.2 SR 3 . 3 . 1. 3 . 3 SR 3 . 3 . 1. 3 . 4 SR 3 . 3 . 1. 3 . 5 PERRY -UN IT 1 SURVEILLANCE Perform CHANNEL FUNCTIONAL TEST. Calibrate the local power range monitors. Neutron detectors are excluded. Perform CHANNEL CALIBRATION. Perform LOGIC SYSTEM FUNCTIONAL TEST. Verify OPRM is not bypassed when THERMAL POWER is 23.8% RTP and recirculation drive flow is < the* value corresponding to 60% of rated core flow. 3.3-14b FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program. In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 1 71 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE OPRM Instrumentation 3.3.1.3 FREQUENCY SR 3.3.1.3.6 ------------------NOTE-------------------PERRY -UNIT l Neutron detectors are excluded. Verify the RPS RESPONSE TIME is within limits. 3.3-14c In accordance with the Surveillance Frequency Control Program Amendment No. 171 Control Rod Block Instrumentation ' 3.3.2.1 SURVEILLANCE REQUIREMENTS -------------------------------------NOTES------------------------------------1. Refer to Table 3.3.2.1-1 to determine which SRs apply for each Control Rod Block Function. 2. When a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains control rod block capability. SR 3. 3 . 2 . 1. 1 SURVEILLANCE ------------------NOTE-------------------Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after THERMAL POWER is > 66.7% RTP. Perform CHANNEL FUNCTIONAL TEST. SR 3.3.2.1.2 Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after THERMAL POWER is > 33.3% RTP and 66. 7% RTP. Perform CHANNEL FUNCTIONAL TEST. SR 3.3.2.1.3 ------------------NOTE-------------------PERRY -UNIT 1 Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after any control rod is withdrawn in MODE 2. Perform CHANNEL FUNCTIONAL TEST. 3.3-16 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance . with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued) SR 3 . 3 . 2 . 1. 4 SR 3. 3. 2 .1. 5 SR 3 . 3 . 2 . 1. 6 SR 3.3.2.1.7 SURVEILLANCE ------------------NOTE-------------------Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after THERMAL POWER is 19% RTP in MODE 1. Perform CHANNEL FUNCTIONAL TEST. Calibrate the low power setpoint trip units. The Allowable Value shall be* > 19% RTP 33.3% RTP. Verify the RWL high power Function is not bypassed when THERMAL POWER is> 66.7% RTP. Perform CHANNEL CALIBRATION. SR 3.3.2.1.8 ------------------NOTE-------------------Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . after reactor mode switch is in the shutdown position. Perform CHANNEL FUNCTIONAL TEST. FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Survei 11 ance . Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) PERRY -UN IT 1 3.3-17 Amendment No. 171 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3 . 3 . 3 . 1. 1 Perform CHANNEL CHECK. SR 3 . 3 . 3 . 1. 2 Deleted. SR 3;3.3.1.3 Perform CHANNEL CALIBRATION. PERRY -UNIT 1 3.3-22 PAM Instrumentation 3.3.3.1 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No . 171 Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 The Remote Shutdown System Functions shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS ----------------------------------NOTE----------------------------------------Separate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION A. One or more required A.1 Restore required Functions inoperable. Function to OPERABLE status. B. Required Action and B.l Be in MODE 3. associated Completion Time not met. SURVEILLANCE REQUIREMENTS SR 3.3.3.2.1 PERRY -UNIT 1 SURVEILLANCE Perform CHANNEL CHECK for each required instrumentation channel that is normally energized. 3.3-24 COMPLETION TIME 30 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months FREQUENCY In accordance with the Surveillance Frequency Control Program (conttnued) Amendment No. 171 Remote Shutdown System 3.3.3.2 SURVEILLANCE RtOUIREMENTS (continued) SR 3.3.3.2.2 SR 3.3.3.2.3 PERRY -UN IT 1 SURVEILLANCE Verify each required control circuit and transfer switch is capable of performing the intended functions. Perform CHANNEL CALIBRATION for each required instrumentation channel, except valve position instrumentation. 3.3-25 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 ACTIONS (continued) CONDITION B. One or more Functions B.1 with EOC-RPT trip capability not maintained. C. Required Action and C.1 associated Completion Time not met. OR C.2 SURVEILLANCE REQUIREMENTS EOC-RPT Instrumentation 3.3.4.1 REQUIRED ACTION COMPLETION TIME Restore EOC-RPT trip 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months capability. . Remove the associated 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months recirculation pump fast speed breaker from service. Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to < 38% RTP. -------------------------------------NOTE-------------------------------------When a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . provided the associated Function maintains EOC-RPT trip capability. SURVEILLANCE SR 3 . 3 . 4 . 1. 1 Perform CHANNEL FUNCTIONAL TEST. PERRY -UNIT 1 3.3-27 FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) Amendment No . 171 EOC-RPT Instrumentation 3.3.4.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.3.4.1.2 Perform CHANNEL CALIBRATION. The Allowable Values shall be: SR 3 . 3 . 4 . 1. 3 SR 3 . 3 . 4 . 1. 4 a. TSV Closure: 7% closed: and b. TCV Fast Closure. Trip Oil Pressure-Low: 465 psig. Perform LOGIC SYSTEM FUNCTIONAL TEST. including breaker actuation. Verify TSV Closure and TCV Fast Closure. Trip Oil Pressure-Low Functions are not bypassed when THERMAL POWER 38% RTP. SR 3.3.4.1.5 ------------------NOTE-------------------SR 3 . 3 . 4 . 1. 6 PERRY -UN IT 1 Breaker arc suppression time may be assumed from the most recent performance of SR 3.3.4.1.6. Verify the EOC-RPT SYSTEM RESPONSE TIME is within limits. Determine RPT breaker arc suppression time. 3.3-28 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No . 171 ACTIONS (continued) CONDITION B. One Function with ATWS-RPT trip capab1 l ity not maintained. c. Both Functions wfth ATWS-RPT trip capability not maintained.

D. Required Action and associated Completion Time not met. SURVEILtANCE REQUIREMENTS B.1 C.l o.r OR D.2 ATWS-RPT Instrumentation 3.3.4.2 REQUIRED ACTION COMPLETION TIME Restore ATWS-RPT trip 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . capability. Restore ATWS-RPT trip 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months capability for one Function. Remove the associated 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months recirculation pump from service. Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ------------------------.: ---* --------NOTE -----------------------------*------When a channel is placed in an inoperable status solely for *of required entry into associated Conditions and Required-Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains ATWS-RPT trip capability. SURVEILLANCE SR 3.3.4.2.1 Perform CRANNEL CHECK. PERRY -UN IT 1 3.3-30 FREQUENCY In accordance with the

Surveillance Frequency Control Program <cont i n*ued) Amendment No. 171 ATWS-RPT Instrumentation 3.3.4.2 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.3.4.2.2 Perform CHANNEL FUNCTIONAL TEST. SR 3.3.4.2.3 Calibrate the trip unit. SR 3.3.4.2.4 Perform CHANNEL CALIBRATION. The Allowable Values shall be: SR 3.3.4.2.5 PERRY -UNIT 1 a. Reactor Vessel Water Level-Low Low. Level 2: 127.6 inches: and b. Reactor Vessel Pressure-High: :s; 1098 psig. Perform LOGIC SYSTEM FUNCTIONAL TEST. including breaker actuation. 3.3-31 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 SURVEILLANCE REQUIREMENTS ECCS Instrumentation 3.3.5.1 1. Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function. 2. When a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 3.c. 3.f. 3.g. and 3.h: and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions other than J.c. 3.f. 3.g. and 3.h. provided the associated Function or the redundant Function maintains ECCS initiation capability. SURVEILLANCE SR 3.3.5.1.1 Perform CHANNEL CHECK. SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST. SR 3.3.5.1.3 Calibrate the trip unit. SR 3.3.5.1.4 Perform CHANNEL CALIBRATION. SR 3.3.5.1.5 Perform CHANNEL CALIBRATION. PERRY -UNIT 1 3.3-38 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No . 171 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3. 3. 5. l. 6 Perform LOGIC SYSTEM FUNCTIONAL TEST. SR 3.3.5;1.7 Perform CHANNEL CALIBRATION. PERRY -UNIT 1 3.3-38a ECCS Instrumentation 3.3.5.1 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program ' . Amendment No. 171 SURVEILLANCE REQUIREMENTS RCIC System Instrumentation 3.3.5.2 -------------------------------------NOTES------------------------------------1. Refer to Table 3.3.5.2-1 to determine which SRs apply for each RCIC Function. 2. When a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 5: and Cb) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1. 2. 3. and 4 provided the associated Function maintains RCIC initiation capability. SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Proqram SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Control rogram SR 3.3.5.2.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.6 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program PERRY -UNIT 1 3.3-46 Amendment No. 171 Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS -------------------------------------NOTES------------------------------------1. Refer to Table 3.3.6.1-1 to determine which SRs apply for each Function. 2. When a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . provided the associated Function maintains isolation capability. SURVEILLANCE SR 3 . 3 . 6 . 1. 1 Perform CHANNEL CHECK. SR 3.3.6.1.2 ----------------NOTE--------------------SR 3. 3. 6 . 1. 3 PERRY -UN IT 1 for Function 1.e in Table 3.3.6.1-1. this SR is applicable only to the Di'vision 3 and 4 instruments.

Perform CHANNEL FUNCTIONAL TEST. Calibrate the trip unit. 3.3-53 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS (continued) SR 3. 3. 6. 1. 4 SR 3 . 3. 6 . 1. 5 SR 3 . 3. 6. 1. 6 SR 3. 3. 6. 1. 7 PERRY -UNIT 1 SURVEILLANCE Perform CHANNEL CALIBRATION. Perform LOGIC SYSTEM FUNCTIONAL TEST. ------------------NOTE-------------------Channel sensors are excluded. Verify the ISOLATION SYSTEM RESPONSE TIME for the main steam isolation valves is within limits. For Function l.e in Table 3.3.6.1-1, this SR is applicable only to the Division 1 and 2 instruments. Perform CHANNEL FUNCTIONAL TEST. 3.3-53a rnEQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 RHR Containment Spray System Instrumentation 3.3.6.2 SURVEILLANCE REQUIREMENTS -------------------------------------NOTES------------------------------------1. Refer to Table 3.3.6.2-1 to determine which SRs apply for each RHR Containment Spray System Function. 2. When a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . provided the associated Function maintains RHR containment spray initiation capability. SURVEILLANCE FREQUENCY SR 3.3.6.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.6 Perform CHANNEL CALIBRATION In accordance with the Surveillance Frequency Control Proqram PERRY -UNIT 1 3.3-62 Amendment No . 171 SURVEILLANCE REQUIREMENTS SPMU System Instrumentation 3.3.6.3 -------------------------------------NOTES------------------------------------1. Refer to Table 3.3.6.3-1 to determine which SRs apply for each SPMU Function. 2. When a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . provided the associated Function maintains SPMU initiation capability. SURVEILLANCE FREQUENCY SR 3.3.6.3.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequencp Control rogram SR 3.3.6.3.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.3.3 Calibrate the trip unit. In accordance with the Surveillance Control rogram SR 3.3.6.3.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequencp . Control rogram SR 3.3.6.3.5 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequencp Control rogram SR 3.3.6.3.6 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program PERRY -UNIT 1 3.3-66 Amendment No. 171 Relief and LLS Instrumentation 3.3.6.4 SURVEILLANCE REQUIREMENTS -------------------------------------NOTE-------------------------------------When a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . provided the associated Function maintains LLS or relief initiation capability. as applicable. SR 3.3.6 4.1 SR 3.3.6.4.2 SR 3.3.6.4.3 SR 3.3.6.4.4 PERRY -UNIT 1 SURVEILLANCE Perform CHANNEL FUNCTIONAL TEST. Calibrate the trip unit. Perform CHANNEL CALIBRATION. The Allowable Values shall be: a. Relief Function Low: Medium: High. b LLS Function Low open: close: Medium open: close: High open: close: 1103 +/- 15 psig 1113 +/- 15 psig 1123 +/- 15 psig 1033 +/- 15 psig 926 +/- 15 psig 1073 +/- 15 psig 936 +/- 15 psig 1113 +/- 15 psig 946 +/- 15 psig Perform LOGIC SYSTEM FUNCTIONAL TEST. 3 3-69 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 SURVEILLANCE REQUIREMENTS CRER System Instrumentation 3.3.7.1 -------------------------------------NOTES------------------------------------1. Refer to Table 3.3.7.1-1 to determine which SRs apply for each Function. 2. When a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains CRER initiation capability. SURVEILLANCE SR 3.3.7.1.l Perform CHANNEL CHECK. SR 3.3.7.1.2 Perform CHANNEL FUNCTIONAL TEST. SR 3.3.7.1.3 Calibrate the trip unit. SR 3.3.7.1.4 Perform CHANNEL CALIBRATION. SR 3.3.7.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. PERRY -UNIT 1 3.3-72 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 SURVEILLANCE REQUIREMENTS LOP Instrumentation 3.3.8.1 -------------------------------------NOTES------------------------------------1. Refer to Table 3.3.8.1-1 to determine which SRs apply for each LOP Function. 2. When a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provided the associated Function maintains DG initiation capability. SURVEILLANCE SR 3. 3 . 8 . 1. 1 Perform CHANNEL CHECK. SR 3 . 3. 8. 1. 2 Perform CHANNEL FUNCTIONAL TEST. SR 3 . 3. 8 . 1. 3 Perform CHANNEL CALIBRATION. SR 3. 3 . 8 . 1. 4 Perform LOGIC SYSTEM FUNCTIONAL TEST. PERRY -UNIT 1 3.3-75 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 RPS.Electric Power Monitoring 3.3.8.2 SURVEILLANCE REQUIREMENTS SR 3.3.8.2.1 SURVEILLANCE ------------------NOTE-------------------Only required to be performed prior to entering MODE 2 or 3 from MODE 4. when in MODE 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Perform CHANNEL FUNCTIONAL TEST. SR 3.3.8.2.2 Perform CHANNEL CALIBRATION. The Allowable Values shall be: SR 3.3.8.2.3 PERRY -UNIT 1 a. Overvoltage Bus A 132 V Bus B 132 V b. Undervoltage Bus A 108 V Bus B 108 V c. Underfrequency (with time delay set 4.0 seconds) Bus A 57 Hz Bus B ;?:: 57 Hz Perform a system functional test. 3.3-79 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 Recirculation Loops Operating 3.4.1 SURVEILLANCE REQUIREMENTS SR 3.4.1.1 PERRY -UNIT 1 SURVEILLANCE -------------------NOTE--------------------Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after both recirculation loops are in operation. Verify recirculation loop jet pump flow mismatch with both recirculation loops in operation is: a. 10% of rated core flow when operating at < 70% of rated core flow; and b. 5% of rated core fl ow when operating at 70% of rated core flow. 3.4-4 (next page is 3.4-6) FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 171 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.2 Flow Control Valves (FCVs) FCVs 3.4.2 LCO 3.4.2 A recirculation loop FCV shall be OPERABLE in each operating recirculation loop. APPLICABILITY: MODES 1 and 2. ACTIONS -------------------------------------NOTE-------------------------------------Separate Condition entry is allowed for each FCV. CONDITION REQUIRED ACTION A. One or two reguired A.1 Lock up the FCV. FCVs inoperable. B. Required Action and B.1 Be in MODE 3. associated Completion Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.2.l Verify each FCV fails "as is" on loss of hydraulic pressure at the hydraulic unit. PERRY -UNIT 1 3.4-6 COMPLETION TIME 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 12 hours FREQUENCY In accordance with the Survei 11 ance Frequency Control Program (continued) Amendment No.171 SURVEILLANCE REQUIREMENTS (continued) SR 3.4.2.2 PERRY -UN IT 1 SURVEILLANCE Verify average rate of each FCV movement is: a. 11% of stroke per second for opening; and

b. 11% of stroke per second for closi.ng. 3.4-7 FREQUENCY FCVs 3.4.2 In accordance with the Surveillance Frequency Control Program Amendment No. 171 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.3 Jet Pumps LCO 3.4.3 All jet pumps shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION A. One or more jet pumps A.1 inoperable. Be in MODE 3. SURVEILLANCE REQUIREMENTS SR 3.4.3.1 PERRY -UNIT 1 SURVEILLANCE 1. Not required to be performed until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after associated recirculation loop is in operation. 2. Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after > 25% RTP. Verify at least two of the following criteria (a. b; and c) are satisfied for each operating recirculation loop: a. Recirculation loop drive flow versus flow control valve position differs by 10% from established patterns. 3.4-8 Jet Pumps 3.4.3 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months FREQUENCY In accordance with the Survei 11 ance Frequency Control Program (continued) Amendment No. 171 SURVEILLANCE REQUIREMENTS SR 3.4.3.1 PERRY -UNIT l SURVEILLANCE (continued) b. Recirculation loop drive flow versus total core flow differs by s 10% from established patterns. c. Each jet pump diffuser to lower plenum differential pressure differs by s 20% from established patterns. or each jet pump flow differs by s 10% from established patterns. 3.4-9 Jet Pumps 3.4.3 FREQUENCY Amendment No. 171 S/RVs 3.4.4 SURVEILLANCE REQUIREMENTS (continued) SR 3.4.4.2 SR 3.4.4.3 PERRY -UN IT 1 SURVEILLANCE -------------------NOTE--------------------Valve actuation may be excluded. Verify each required relief function S/RV actuates on an actual or simulated automatic initiation signal. -------------------NOTE--------------------Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test. FREQUENCY In accordance with the Survei 11 ance Frequency Control Program Verify each required S/RV actuator strokes In accordance when manually actuated. with the Surveillance Frequency Control Program 3.4-11 Amendment No. 171 RCS Operational LEAKAGE 3.4.5 ACTIONS (continued) CONDITION REQUIRED ACTION SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.5.1 Verify RCS unidentified LEAKAGE. total LEAKAGE. and unidentified LEAKAGE increase are within limits. PERRY -UNIT 1 3.4-13 COMPLETION TIME FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 171 RCS Leakage Detection Instrumentation 3.4.7 SURVEILLANCE REQUIREMENTS SR 3.4.7.l SR 3.4.7.2 SR 3.4.7.3 PERRY -UNIT 1 SURVEILLANCE Perform CHANNEL CHECK of required drywell atmospheric monitoring system. Perform CHANNEL FUNCTIONAL TEST of required leakage detection instrumentation. Perform CHANNEL CALIBRATION of required leakage detection instrumentation. 3.4-18 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No.171 ACTIONS CONDITION REQUIRED ACTION B. (continued) B.2.2.1 Be in MODE 3. AND B.2.2.2 Be in MODE 4. SURVEILLANCE REQUIREMENTS SR 3.4.8.1 PERRY -UN IT 1 SURVEILLANCE -------------------NOTE--------------------Only required to be performed in MODE 1. Verify reactor coolant DOSE EQUIVALENT 1-131 specific activity is 0.2 µCi/gm. 3.4-20 RCS Specific Activity 3.4.8 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No.171 RHR Shutdown Cooling System-Hot Shutdown 3.4.9 SURVEILLANCE REQUIREMENTS SR 3.4.9.1 PERRY -UN IT I SURVEILLANCE -------------------NOTE--------------------Not required to be met until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after reactor steam dome pressure is less than the RHR cut in permissive pressure. Verify one RHR shutdown cooling subsystem or recirculation pump is operating. 3.4-23 FREQUENCY In accordance with the Surveillance Frequency * . Control Program Amendment No . 171 ACTIONS (continued) CONDITION 8. No RHR shutdown 8.1 cooling subsystem in operation. AND No recirculation pump in operation. AND 8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE RHR Shutdown Cooling System-Cold Shutdown 3.4.10 REQUIRED ACTION COMPLETION TIME Verify reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from coolant circulation discovery of no by an alternate reactor coolant method. circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter Monitor reactor Once per hour coolant temperature and pressure. FREQUENCY SR 3. 4. 10 .1 Verify one RHR shutdown cooling subsystem or recirculation pump is operating. In accordance with the Surveillance Frequency Control Program PERRY -UN IT 1 3.4-25 Amendment No. 171 ACTIONS (continued) CONDITION REQUIRED ACTION C. ---------NOTE---------C.l Initiate action to Required Action C 2 shall be completed if this Condition is restore parameter(s) to within limits. entered AND ----------------------C.2 Determine RCS is Requirements of the acceptable for LCO not met in other operation than MODES 1. 2. and 3. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3 4.11.1 Only required to be performed during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing. Verify: a. RCS pressure and RCS temperature are within the limits of Figure 3.4.11-1; and b. RCS heatup and cooldown rates are within the limits of Figure 3.4.11-1. PERRY -UN IT 1 3.4-27 RCS P/T Limits 3.4.11 COMPLETION TIME Immediately Prior to entering MODE 2 or 3 FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) Amendment No.171 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.4.11.5 Only required to be performed when tensioning the reactor vessel head bolting studs. Verify reactor vessel flange and head flange temperatures 70°F. SR 3.4.11.6 Not required to be performed until 30 minutes after RCS temperature 80°F in MODE 4. Verify reactor vessel flange and head flange temperatures 70°F. SR . 3 . 4 . 11 . 7 -------------------NOTE -------------------Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after RCS temperature l00°F in MODE 4. Verify reactor vessel flange and head flange temperatures 70°F. PERRY -UN IT 1 3.4-29 RCS P/T Limits 3.4.11 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Reactor Steam Dome Pressure Reactor Steam Dome Pressure 3.4.12 LCO 3.4.12 The reactor steam dome pressure shall 1045 psig. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION A. Reactor steam dome A.1 Restore reactor steam not within imit. . dome pressure to within limit. B. Required Action and B.1 Be in MODE 3. associated Completion Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.12.1 Verify reactor steam dome pressure ts 1045 psig. PERRY -UNIT 1 3.4-32 COMPLETION TIME 15 minutes 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No . 171 SURVEILLANCE REQUIREMENTS SR 3.5.1.1 SR 3.5.1. 2 SR 3. 5.1.3 SR 3.5.1.4 PERRY -UN IT 1 SURVEILLANCE Verify. for each ECCS injection/spray subsystem. the piping is filled with water from the pump discharge valve to the injection valve. -------------------NOTE--------------------Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the residual heat removal cut in permissive pressure in MODE 3. if capable of being manually realigned and not otherwise inoperable. Verify each ECCS injection/spray subsystem manual. power operated. and automatic valve in the flow path. that is not locked. sealed. or otherwise secured in position. is in the correct position. Verify ADS accumulator supply pressure is 150 psig. Verify each ECCS pump develops the specified flow rate with sufficient pump total head to overcome the total system resistance which includes the specified reactor-to-containment wetwell differential pressure. SYSTEM LPCS LPCI HPCS FLOW RATE 6110 gpm 7100 gpm 6110 gpm 3.5-4 CONTAINMENT WETWELL DIFFERENTIAL PRESSURE 128 psid 24 psid 200 psid ECCS-Operating 3.5.1 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the . Surveillance Frequency

Control Program In accordance with the Inservice Testing Program lcont1nueaJ Amendment No . 171 SURVEILLANCE REQUIREMENTS (continued) SR 3.5.1.5 SR 3.5.1.6 SR 3.5.1. 7 SR 3.5.1.8 PERRY -UNIT 1 SURVEILLANCE -------------------NOTE--------------------Vessel injection/spray may be excluded. Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal. -------------------NOTE--------------------Valve actuation may be excluded. Verify the ADS actuates on an actual or simulated automatic initiation signal. -------------------NOTE--------------------Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test. Verify each ADS valve actuator strokes when manually actuated. ------------------NOTE---------------------ECCS actuation instrumentation is excluded. Verify the ECCS RESPONSE TIME for each ECCS injection/spray subsystem is within limits. 3.5-5 ECCS-Operating 3.5.1 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 ACTIONS (continued) CONDITION REQUIRED ACTION D. Action C.2 D.1 Initiate action to an associated restore primary Completion Time not containment to met. OPERABLE status. AND D.2 Initiate action to restore isolation capability in each required primary containment penetration flow path not isolated. AND D.3 -------NOTE-------Entry and exit is permissible under administrative control. ------------------Initiate action to close one door in each primary containment air lock. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.5.2.1 Verify, for each required low pressure ECCS injection/spray subsystem. the suppression pool water level is 16 ft 6 in. PERRY -UN IT 1 3.5-7 ECCS-Shutdown 3.5.2 COMPLETION TIME Immediately Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency

Control Program (continued) Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued) SR 3.5.2.2 SR 3.5.2.3 SR 3.5.2.4 PERRY -UN IT 1 SURVEILLANCE Verify. for the required High Pressure Core Spray (HPCS) System. the: a. Suppression pool water level is 16 ft 6 in: or b. Condensate storage tank water volume 249.700 gal. Verify. for each required ECCS injection/ spray subsystem. the piping is filled with water from the pump discharge valve to the injection valve. -------------------NOTE--------------------One low pressure coolant injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal. if capable of being manually rea hgned and not otherwise i-noperab le. Verify each required ECCS injection/spray subsystem manual. power operated. and automatic valve in the flow path. that is not locked. sealed. or otherwise secured in position. is in the correct position. 3.5-8 ECCS-Shutdown 3.5.2 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued) SR 3.5.2.5 SR 3.5.2.6 PERRY -UNIT 1 SURVEILLANCE Verify each required ECCS pump develops the specified flow rate with sufficient pump total head to overcome the total system resistance which includes the specified reactor to containment wetwell differential pressure. SYSTEM LPCS LPCI HPCS FLOW RATE 6110 gpm 7100 gpm 6110 gpm REACTOR TO CONTAINMENT WETWELL DIFFERENTIAL PRESSURE 128 psid 24 psid 200 psid -------------------NOTE--------------------Vessel injection/spray may be excluded. Verify each required ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal. 3.5-9 ECCS-Shutdown 3.5.2 FREQUENCY In accordance with the Inservice Testing Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 SURVEILLANCE REQUIREMENTS SR 3.5.3.1 SR 3.5.3.2 SR 3.5.3.3 SR 3.5.3.4 PERRY -UNIT 1 SURVEILLANCE Verify the RCIC System piping is filled with water from the pump discharge valve to the injection valve. Verify each RCIC System manual. power operated. and automatic valve in the flow path. that is not locked. sealed. or otherwise secured in position. is in the correct position. -------------------NOTE--------------------Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test. Verify, with RCIC steam supply pressure 920-psig 1045 psig, the RCIC pump can develop a flow rate 700 gpm against a system head corresponding to reactor pressure. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test. Verify, with RCIC steam supply pressure 150 psig and 165 psig. the RCIC pump _can develop a flow rate 700 gpm against a system head corresponding to reactor pressure. 3.5-11 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Survei 11 ance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued) SR 3.5.3.5 PERRY -UN IT 1 SURVEILLANCE -------------------NOTE--------------------Vessel injection may be excluded. Verify the RCIC System actuates on an actual or simulated automatic initiation signal. 3.5-12 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 171 Primary Containment Air Locks 3.6.1.2 SURVEILLANCE REQUIREMENTS SR 3 . 6 . 1. 2 . 1 SR 3. 6 . 1. 2 . 2 PERRY -UN IT 1 SURVEILLANCE ------------------NOTES------------------1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. 2. During MODES 1. 2. and 3. results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.1. Perform required primary containment air lock leakage rate testing in accordance with the Primary Containment Leakage Rate Testing Program. Verify primary containment air lock seal air header pressure is 90 psig. 3.6-7 FREQUENCY In accordance with the Primary Containment Leakage Rate Testing Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 Primary Containment Air Locks 3.6.1.2 SURVEILLANCE REQUIREMENTS (continued) SR 3 . 6. 1. 2 . 3 SR 3 . 6. 1. 2 . 4 PERRY -UN IT 1 SURVEILLANCE ------------------NOTE-------------------Only required to be performed upon entry or exit through the primary containment air lock. Verify only one door in the primary. containment air lock can be opened at a time. Verify, from an initial pressure of 90 psig, the primary containment air lock seal pneumatic system pressure does not decay at a rate equivalent to > 1.5 psig for a period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . 3.6-8 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No . 171 SURVEILLANCE REQUIREMENTS SR 3 . 6 . 1. 3 . 1 SR 3 . 6 . 1. 3 . 2 PERRY -UNIT 1 SURVEILLANCE ------------------NOTE------------------Only required to be met in MODES 1. 2. and 3. Verify each inboard 42 inch primary containment purge valve is sealed closed except for one purge valve in a penetration flow path while in Condition D of this LCO. ------------------NOTES------------------1. Only required to be met in MODES 1. 2. and 3. 2. Not required to be met when the 18 inch or outboard 42 inch primary containment purge valves are open for pressure control. ALARA or air quality considerations for personnel entry. or Surveillances or special testing on the purge system that require the valves to be open. Verify each 18 inch and outboard 42 inch primary containment purge valve is closed. 3.6-15 PC I Vs 3.6.1.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued) SR 3 . 6 . 1. 3 . 3 PERRY -UNIT 1 SURVEILLANCE ------------------NOTES------------------1. Only required to be met in MODES 1. 2. and 3. 2. Valves and blind flanges in high radiation areas may be verified by use of administrative means. 3. Not required to be met for PCIVs that are open under administrative controls. Verify each primary containment isolation manual valve and blind flange that is located outside primary containment. drywell. and steam tunnel and not locked. sealed. or otherwise secured and is required to be closed during accident conditions is closed. 3.6-16 PC I Vs 3.6.1.3 FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued) SR 3 . 6 . 1. 3 . 5 SR 3 . 6 . 1. 3 . 6 SR 3. 6. 1. 3. 7 SR 3 . 6 . 1. 3 . 8 PERRY -UN IT 1 SURVEILLANCE Verify the isolation time of each power operated and each automatic PCIV. except MSIVs. is within limits. ------------------NOTE-------------------Only required to be met in MODES 1. 2. and 3. Perform leakage rate testing for each primary containment purge valve with resilient seals. Verify the isolation time of each MSIV is 2.5 seconds. 5 seconds. Verify each automatic PCIV actuates to the isolation position on an actual or simulated isolation signal. 3.6-17 PC I Vs 3.6.1.3 FREQUENCY In accordance with the Inservice Testing Program In accordance with the Surveillance Frequency Control Program AND Once within 92 days after opening the valve In accordance with the Inservice Testing Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No . 171 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.6.1.3.11 ------------------NOTES------------------1. Only required to be met in MODES 1. 2. and 3. 2. Feedwater lines are excluded. Verify combined leakage rate of 1 gpm times the total number of PCIVs through hydrostatically tested lines that penetrate the primary contatnment is not exceeded when these isolation valves are tested at 1.1 Pa. SR 3.6.1.3.12 ------------------NOTE------------------SR 3. 6 .1. 3 .13 PERRY -UNIT I Only required to be met in MODES 1. 2. and 3. Verify each outboard 42 inch primary containment purge valve is blocked to restrict the valve from opening > 50°. ------------------NOTE-------------------Not required to be met when the Backup Hydrogen Purge System isolation valves are open for pressure control. ALARA or air quality considerations for personnel entry. or Surveillances or special testing of the Backup hydrogen Purge System that require the valves to be open. Verify each 2 inch Backup Hydrogen Purge System isolation valve is closed. 3.6-19 PC I Vs 3.6.1.3 FREQUENCY In accordance with the Primary Containment Leakage Rate Testing Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 Primary Containment Pressure 3.6.1.4 3.6 CONTAINMENT SYSTEMS 3.6.1.4 Primary Containment Pressure LCD 3.6.1.4 Primary containment to secondary containment differential pressure shall -0.1 psid 1.0 psid. APPLICABILITY: MODES 1. 2. and 3. ACTIONS CONDITION REQUIRED ACTION A. Primary containment to A.1 Restore prim&ry secondary containment containment to differential pressure secondary containment not within limits. differential pressure to within limits. B. Required Action and B.1 Be in MODE 3. associated Completion AND Time not met. B.2 Be in MODE 4. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3 . 6 . 1. 4 . 1 PERRY -UNIT 1 Verify primary containment to secondary containment differential pressure is within limits. 3.6-20 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No.171 Primary Containment Air Temperature 3.6.1.5 3.6 CONTAINMENT SYSTEMS 3.6.1.5 Primary Containment Air Temperature LCO 3.6.1.5 Primary containment average air temperature shall 95°F. APPLICABILITY: MODES 1. 2. and 3. ACTIONS CONDITION REQUIRED ACTION A. Primary containment A.1 Restore primary average air containment average temperature not within 1 imit. air to within imit. B. Required Action and B.1 Be in MODE 3. associated Completion Time not met. AND B.2 Be in MODE 4. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3 . 6 . 1. 5 . 1 PERRY -UNIT 1 Verify primary containment average air temperature is within limit. 3.6-21 COMPLETION TIME 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 171 SURVEILLANCE REQUIREMENTS SR 3 . 6 . 1. 6 . 1 SR 3 . 6 . 1. 6 . 2 PERRY -UNIT 1 SURVEILLANCE ------------------NOTE-------------------Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test. Verify each LLS valve actuator strokes when manually actuated. ------------------NOTE-------------------Valve actuation may be excluded. Verify the LLS function of the six safety/relief valves actuates on an actual or simulated automatic initiation signal. 3.6-23 LLS Valves 3.6.1.6 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 RHR Containment Spray System 3.6.1. 7 SURVEILLANCE REQUIREMENTS SR 3 . 6 . 1. 7 . 1 SR 3. 6. 1. 7 . 2 SR 3.6.1. 7 .3 SR 3 . 6. 1. 7 . 4 PERRY -UN IT 1 SURVEILLANCE ---------.---------NOTE -------------------RHR containment spray subsystems may be considered OPERABLE during alignment and operation for decay heat removal when below the RHR cut in permissive pressure in MODE 3 if capable of being manually realigned and not otherwise inoperable. Verify each RHR containment spray subsystem manual. power operated. and automatic valve in the flow path that is not locked. sealed. or otherwise secured in position is in the correct position. Verify each RHR pump develops a flow rate of 5250 gpm on recirculation flow through the associated heat exchangers to the suppression pool. Verify each RHR containment spray subsystem automatic valve in the fl ow path actuates to its correct position on an actual or simulated automatic initiation signal. Verify each spray nozzle is unobstructed. 3.6-25 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Inservice Testing Program In accordance with the Surveillance Frequency Control Program Following maintenance which could result in nozzle blockage. Amendment No.171 3.6 CONTAINMENT SYSTEMS 3.6.1.8 Feedwater Leakage Control System (FWLCS) LCO 3.6.1.8 Two FWLCS subsystems shall be OPERABLE. APPLICABILITY: MODES 1. 2. and 3. ACTIONS CONDITION REQUIRED ACTION A. One FWLCS subsystem A.1 Restore FWLCS inoperable. subsystems to OPERABLE status. B. Two FWLCS subsystems B.1 Restore one FWLCS inoperable. subsystem to OPERABLE status. C. Required Action and C,1 Be in MODE 3. associated Completion Time not met. AND C.2 Be in MODE 4. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.1.8.1 Verify associated ECCS water leg pump operates properly. PERRY -UNIT 1 3.6-26 FWLCS 3.6.1.8 COMPLETION TIME 30 days 7 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No . 171 Primary Containment-Shutdown 3.6.1.10 SURVEILLANCE REQUIREMENTS SR 3 . 6. 1. 10 . 1 PERRY -UN IT 1 SURVEILLANCE ------------------NOTES------------------1. Not required to be met for pathways capable of being closed by OPERABLE primary containment automatic isolation valves. 2. Not required to be met for the Fire Protection System manual hose reel containment isolation valves. 3. Not required to be met for manual isolation valves open under administrative controls. Verify each penetration flow path. required to be closed during accident conditions. is closed. 3.6-30 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No . 171 Containment Vacuum Breakers 3.6.1.11 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.1.11.1 SR 3. 6. 1. 11 . 2 SR 3.6.1.11.3 PERRY -UN IT 1 1. Not required to be met for vacuum breakers open during Surveillances. 2. Not required to be met for vacuum breakers open when performing their intended function. Verify each vacuum breaker is closed. Perform a functional test of each required vacuum breaker and its associated isolation valve. Verify the opening pressure differential of each required vacuum breaker is 0.1 psid. and the opening setpoint of the vacuum breaker isolation valve is 0.052 psid 0.160 psid. 3.6-33 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No.171 ACTIONS (continued) CONDITION B. Required Action and B.1 associated Completion Time of Condition A AND not met in MODE 1. 2. or 3. B.2 C. Required Action and C.1 associated Completion Time of Condition A not met during movement of recently irradiated fuel assemblies in the AND primary containment. or during OPDRVs. C.2 SURVEILLANCE REQUIREMENT SURVEILLANCE Containment Humidity Control 3. 6.1.12 REQUIRED ACTION COMPLETION TIME Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Suspend movement of recently irradiated Immediately fuel assemblies in the primary containment. Initiate action to Immediately suspend OPDRVs. FREQUENCY SR 3.6.1.12.1 Verify containment average to-relative humidity to be within limits. In accordance with the Surveillance Frequency Control Program PERRY -UNIT 1 3.6-35 Amendment No . 171 Suppression Pool Average Temperature 3.6.2.1 ACTIONS (continued CONDITION REQUIRED ACTION E. Suppression pool E. l Depressurize the average temperature reactor vessel to > 120°F. < 200 psig. AND E.2 Be in MODE 4. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3 . 6 . 2 . 1. 1 Verify suppression pool average temperature is within the applicable limits. PERRY -UNIT 1 3.6-38 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours FREQUENCY In accordance with the Surveillance Frequency Control Program AND 5 minutes when

performing testing that adds heat to the suppression pool Amendment No . 171 Suppression Pool Water Level 3.6.2.2 3.6 CONTAINMENT SYSTEMS 3.6.2.2 Suppression Pool Water Level LCO 3.6.2.2 Corrected suppression pool water level shall be 17 ft 9.5 inches 18 ft 6 inches. APPLICABILITY: MODES 1. 2. and 3. ACTIONS CONDITION REQUIRED ACTION A. Suppression water A.1 Restore suppression level not wi hin pool water level to limits. within limits. B. Required Action and B. l Be in MODE 3. associated Completion AND Time not met. B.2 Be in MODE 4. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.2.2.1 Verify suppression pool water level is within limits. PERRY -UNIT 1 3.6-39 COMPLETION TIME 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months FREQUENCY In accordance with the *Surveillance Frequency Control Program Amendment No. 171 RHR Suppression Pool Cooling System 3.6.2.3 SURVEILLANCE REQUIREMENTS SR 3.6.2.3.1 SR 3.6.2.3.2 PERRY -UNIT 1 SURVEILLANCE Verify each RHR suppression pool cooling subsystem manual. power operated. and automatic valve in the flow path that is not locked. sealed. or otherwise secured in position is in the correct position or can be aligned to the correct position. Verify each RHR pump develops a flow rate 7100 gpm through the associated heat exchangers to the suppression pool. 3.6-41 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Inservice Testing Program Amendment No. 171 SURVEILLANCE REQUIREMENTS SR 3.6.2.4.1 SR 3.6.2.4.2 SR 3.6.2.4.3 SR 3.6.2.4.4 SR 3.6.2.4.5 PERRY -UNIT 1 SURVEILLANCE Verify upper containment pool water level is: a. 22 ft 9 inches above the reactor pressure vessel (RPV) flange, OR b. 22 ft 5 inches above the RPV flange, and suppression pool water 17 ft 11.7 inches. Verify upper containment pool water temperature 110°F. Verify each SPMU subsystem manual. power operated. and automatic valve that is not locked. sealed. or otherwise secured in position is in the correct position. Verify a 11 required upper containment pool gates are in the stored position or are otherwise removed from the upper containment pool. ------------------NOTE -----*--------------Actual makeup to the suppression pool may be excluded. , Verify each SPMU subsystem automatic valve actuates to the correct position on an actual or simulated automatic initiation signal. 3.6-43 (next page is 3.6-46) SPMU System 3.6.2.4 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 Primary Containment and Drywell Hydrogen Igniters 3.6.3.2 ACTIONS (continued) CONDITION REQUIRED ACTION C. Required Action and C.1 associated Completion Be in MODE 3. Time not met. SURVEILLANCE REQUIREMENTS SR 3.6.3.2.1 SR 3.6.3.2.2 SR 3.6.3.2.3 PERRY -UNIT 1 SURVEILLANCE Energize each primary containment and drywell hydrogen igniter division and perform current versus voltage measurements to verify required igniters in service. ------------------NOTE-------------------Not required to be performed until 92 days after discovery of four or more igniters in the division inoperable. Energize each primary containment and drywell hydrogen igniter division and perform current versus voltage measurements to verify required igniters in service. Verify each required igniter in inaccessible areas develops sufficient current draw for a 1700°F surf ace temperature. 3.6-47 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No.171 Primary Containment and Drywell Hydrogen Igniters 3.6.3.2 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.6.3.2.4 Verify each required igniter in accessible areas develops a surface temperature 1700°F. PERRY -UNIT 1 3. 6-48 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No . 171 Combustible Gas Mixing System 3.6.3.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.3.3.1 Operate each combustible gas mixing subsystem 15 minutes. SR 3.6.3.3.2 Verify each combustible gas mixing subsystem flow rate is 500 scfm. PERRY -UNIT 1 3. 6-50 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No.171 Secondary Containment 3.6.4.1 ACTIONS (continued) CONDITION REQUIRED ACTION C. Secondary C. l Suspend movement of containment recently irradiated inoperable during fuel assemblies in movement of recently the primary irradiated fuel containment. assemblies in the primary containment. or during OPDRVs. AND C.2 Initiate action to suspend OPDRVs. SURVEILLANCE REQUIREMENTS SR 3 . 6 . 4 . 1. 1 SR 3.6.4.1.2 SR 3.6.4.1.3 PERRY -UN IT 1 SURVEILLANCE Verify secondary containment vacuum is 0.66 inch of vacuum water gauge. Verify the primary containment equipment hatch is closed and sealed and the shield blocks are installed adjacent to the shield building. Verify each secondary containment access door is closed. except when the access opening is being used for entry and exit. 3.6-52 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 ACTIONS (continued) CONDITION REQUIRED ACTION D. Required Action and D.1 Suspend movement of associated Completion recently irradiated Time of Condition A fuel assemblies in or B not met durinl movement of recent y the primary containment. irradiated fuel assemblies in the AND primary containment. or during OPDRVs. D.2 Initiate action to suspend OPDRVs. SURVEILLANCE REQUIREMENTS SR 3.6.4.2.1 PERRY -UN IT 1 SURVEILLANCE ------------------NOTES------------------1. Valves and blind flanges in high radiation areas may be verified by use of administrative means. 2. Not required to be met for SCIVs that are open under administrative controls. Verify each secondary containment isolation manual valve and blind flange that is not locked. sealed. or otherwise secured and is required to be closed during accident conditions is closed. 3.6-55 SCI Vs 3.6.4.2 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No.171 SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 SR 3.6.4.3.2 SR 3.6.4.3.3 PERRY -UNIT 1 SURVEILLANCE Operate each AEGT subsystem for 10 continuous hours with heaters operating. Perform required AEGT filter testing in accordance with the Ventilation Filter Testing Program CVFTP). Verify each AEGT subsystem actuates on an actual or simulated initiation signal. 3.6-58 AEGT System 3.6.4.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program Amendment No. 171 SURVEILLANCE REQUIREMENTS SR 3 . 6 . 5 . 1. 1 SR 3 . 6 . 5 . 1. 2 PERRY -UNIT 1 SURVEILLANCE Verify bypass leakage is less than or equal to the bypass leakage limit. However. during the first unit startup following bypass leakage testing performed in accordance with this SR. the acceptance criterion is 10% of the drywell bypass leakage limit. Visually inspect the exposed accessible interior and exterior surfaces of the drywell. 3.6-60 Drywell 3.6.5.1 FREQUENCY 24 months following 2 consecutive tests with bypass leakage greater than the bypass leakage limit AND 48 months following a test with bypass leakage greater than the bypass leakage limit AND SR 3.0.2 extensions are limited to 12 months. In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency

Control Program (continued) Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued) SR 3. 6. 5 . 1. 3 SR 3. 6. 5. 1. 4 PERRY -UNIT 1 SURVEILLANCE Quantify air lock door seal leakage rate when the gap between the door seals is pressurized to 2.5 psig. ------------------NOTE----------*---------An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. Quantify drywell air lock leakage by performing an air lock barrel leakage test at 2.5 psig. 3.6-60a Drywel l 3.6.5.1 FREQUENCY Once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each drywe 11 air lock door closing. In accordance with the Surveillance Frequency Control Program Amendment No . 171 SURVEILLANCE REQUIREMENTS SR 3.6.5.2.1 SR 3.6.5.2.2 SR 3.6.5.2.3 SR 3. 6. 5. 2 .4. SR 3.6.5.2.5 PERRY -UNIT 1 SURVEILLANCE Deleted. Verify drywell air lock seal air header pressure is 60 psig. Only required to be performed upon entry into drywell. Verify only one door in the drywell air lock can be opened at a time. Deleted. Verify, from an initial pressure of 60 psig. the drywell air lock seal pneumatic system pressure does not decay at a rate equivalent to > 3 psig for a period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . 3.6-64 Drywe 11 Air Lock 3.6.5.2 FREQUENCY In accordance with the Surveillance Frequency Control .Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No.171 Drywell Isolation Valves 3.6.5.3 SURVEILLANCE REQUIREMENTS SR 3.6.5.3.1 SR 3.6.5.3.2 SR 3.6.5.3.3 SR 3.6.5.3.4 SR 3.6.5.3.5 PERRY -UNIT 1 SURVEILLANCE Verify each 24 inch and 36 inch drywell purge supply and exhaust isolation valve is sealed closed. Deleted. 1. Valves and blind flanges in high radiation areas may be verified by use of administrative means. 2; Not required to be met for drywell isolation valves that are open under administrative controls. Verify each drywell isolation manual valve and blind flange that is not locked. sealed. or otherwise secured and is required to be closed during accident conditions is closed. Verify the isolation time of each power operated and each automatic drywell isolation valve is withtn limits. Verify each automatic drywell isolation valve actuates to the isolation position on an actual or simulated isolation signal. 3.6-67 FREQUENCY In accordance with the Surveillance Frequency Control Program Prior to entering MODE 2 or 3 from MODE 4. if not performed in the previous 92 days In accordance with the Inservice Testing Program In accordance with the Surveillance Frequency Control Program Amendment No . 171 3.6 CONTAINMENT SYSTEMS 3.6.5.4 Drywell Pressure Drywell Pressure 3.6.5.4 LCO 3.6.5.4 Drywell-to-primary containment differential pressure shall -0.5 psid and 2.0 psid. APPLICABILITY: MODES 1. 2. and 3. ACTIONS CONDITION REQUIRED ACTION A. Drywell-to-primary A.1 Restore drywell-to-containment primary containment differential pressure differential pressure not within limits. to within limits. B. Required Action and B.1 Be in MODE 3. associated Completion Time not met. AND B.2 Be in MODE 4. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.5.4.1 PERRY -UN IT 1 Verify drywell-to-primary containment differential pressure is within limits. 3.6-69 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 171 3.6 CONTAINMENT SYSTEMS 3.6.5.5 Drywell Air Temperature Drywell Air Temperature 3.6.5.5 LCO 3.6.5.5 Drywell average air temperature shall 145°F. APPLICABILITY: MODES 1. 2. and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell average air A.1 Restore drywe 11 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months temperature not within aven.1ge air limit. temperature to within limit. B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SR 3.6.5.5.1 PERRY -UN IT 1 SURVEILLANCE FREQUENCY Verify drywell average air temperature is In accordance within limit. with the Surveillance Frequency Control Program 3.6-70 Amendment No.171 Drywell Vacuum Relief System 3.6.5.6 ACTIONS (continued) CONDITION REQUIRED ACTION D. Required Action and D.1 associated Completion Time of Condition A. AND Be in MODE 3. B. or C not met. D.2 Be in MODE 4. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.5.6.1 -----------------NOTES-------------------1. Not required to be met for drywell vacuum breakers open during Surveillances. 2. Not required to be met for drywell vacuum breakers open when performing their intended function. COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours FREQUENCY Verify each drywell vacuum breaker and In accordance SR 3.6.5 .. 6.2 SR 3.6.5.6.3 PERRY -UNIT 1 its associated isolation valve is closed. with the Surveillance Frequency Control Program Perform a functional test of each drywell vacuum breaker and its associated isolation valve. Verify the opening pressure differenhal of each drywell vacuum breaker is 0.5 psid. and the allowable value of each associated isolation valve is 0.810 inches water gauge dp. 3.6-72 In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Contra l Program Amendment No. 171 ESW System-Div. 1 and 2 3.7.1 ACTIONS (continued) CONDITION REQUIRED ACTION B. Required Action and 8.1 Be in MODE 3. associated Completion Time of Condition A AND not met. B.2 Be in MODE 4. OR Both ESW Division 1 and Division 2 subsystems inoperable. SURVEILLANCE REQUIREMENTS SR 3. 7 .1.1 SR 3. 7 .1. 2 PERRY -UNIT 1 SURVEILLANCE Verify each required Division 1 and 2 ESW subsystem manual. power operated. and automatic valve in the flow path servici*ng safety related systems or components. that is not locked. sealed. or otherwise secured in position. is in the correct position. Verify each required Division 1 and 2 ESW subsystem actuates on an actual or simulated initiation signal. 3.7-2 COMPLETION TI ME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance *with the Surveillance Frequency Control Program Amendment No . 171 3.7 PLANT SYSTEMS 3.7.2 Emergency Service Water (ESW) System-Division 3 ESW System-Div. 3 3.7.2 LCO 3.7.2 The Division 3 ESW subsystem shall be OPERABLE. APPLICABILITY: MODES 1. 2. and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ESW Division 3 A.l subsystem inoperable. Declare High Pressure Immediately Core Spray System inoperable. SURVEILLANCE REQUIREMENTS SR 3.7.2.1 SR 3.7.2.2 PERRY -UN IT 1 SURVEILLANCE Verify each required Division 3 ESW subsystem manual. power operated. and . automatic valve in the flow path servicing safety related systems or components. that is not locked. sealed. or otherwise secured in position. is in the correct position. Verify the Division 3 ESW subsystem actuates on an actual or simulated initiation signal. 3.7-3 FREQUENCY In accordance with the

Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No . 171 ACTIONS (continued) CONDITION F. Two CRER subsystems inoperable during movement of recently irradiated fuel assemblies in the primary containment or fuel handling building. or during OPDRVs. One or more CRER subsystems inoperable due to inoperable CRE boundary during movement of recently irradiated fuel assemblies in the primary containment or fuel handling building. or during OPDRVs. SURVEILLANCE REQUIREMENTS F.l AND F.2 SURVEILLANCE REQUIRED ACTION Suspend movement of recently irradiated fuel assemblies in the primary containment and fuel handling building. Initiate action to suspend OPDRVs. SR 3.7.3.1 Operate each CRER subsystem for SR 3.7.3.2 10 continuous hours with the heaters operating. Perform required CRER filter testing in accordance with the Ventilation Filter Testing Program (VFTP). PERRY -UNIT 1 3.7-6 CRER System 3.7.3 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP (continued) Amendment No.171 SURVEILLANCE REQUIREMENTS (continued) SR 3.7.3.3 SR 3.7.3.4 SURVEILLANCE Verify each CRER subsystem actuates on an actual or simulated initiation signal. Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program. PERRY -UNIT 1 3.7-7 CRER System 3.7.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Control Room Envelope Habitability Program. Amendment No. 171 Control Room HVAC System 3.7.4 ACTIONS (continued) CONDITION E. Required Action and associated Completion Time of Condition B not met during movement of recently irradiated fue 1 assemblies in the Rrimary containment or fuel handling building, or during OPDRVs. SURVEILLANCE REQUIREMENTS REQUIRED ACTION LCO 3.0.3 is not applicable. E.l Suspend movement of recently irradiated fuel assemblies in the primary containment and fuel handling building. AND E.2 Initiate action to suspend OPDRVs. SURVEILLANCE SR 3.7.4.1 Verify each control room HVAC subsystem has the capability to remove the assumed heat load. . PERRY -UNIT 1 3.7-10 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 171 SURVEILLANCE REQUIREMENTS SR 3.7.5.1 SR 3.7.5.2 SURVEILLANCE Verify the release rate of the specified noble gases is 358 mCi/second after decay of 30 minutes. Not required to be performed until 31 days after any main steam line not isolated and SJAE in operation. Verify the release rate of the specified noble gases is 358 mCi/second after decay of 30 minutes. PERRY -UNIT 1 3.7-12 Main Condenser Offgas 3.7.5 FREQUENCY Once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after a ;:::: 50% increase in the nominal steady state fission gas release rate after factoring out increases due to changes . in THERMAL POWER level In accordance with the Surveillance Frequency Control Program Amendment No . 171 Main Turbine Bypass System 3.7.6 3.7 PLANT SYSTEMS 3.7.6 Main Turbine Bypass System LCO 3.7.6 The Main Turbine Bypass System shall be OPERABLE. APPLICABILITY: THERMAL POWER 23.8% RTP. ACTIONS CONDITION REQUIRED ACTION A. Main Turbine A.l Restore Main Turbine System inopera e. System to OP RABLE status. B. Required Action and B.1 Reduce THERMAL POWER associated Completion to< 23.8% RTP. Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3. 7 .6.1

Verify one complete cycle of each main turbine bypass valve. SR 3.7.6.2 Perform a system functional test. SR 3.7.6.3 Verify the TURBINE BYPASS SYSTEM RESPONSE TIME is within limits. PERRY -UNIT 1 3.7-13 COMPLETION TIME 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 4 hours FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Survei 11 ance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No . 171 3.7 PLANT SYSTEMS 3.7.7 Fuel Pool Water Level Fuel Pool Water Level 3.7.7 LCO 3.7.7 The fuel pool water level shall 23 ft over the top of irradiated fuel assemblies seated in the fuel handling building (FHB) and upper containment fuel storage racks. APPLICABILITY: During movement of irradiated fuel assembli.es in the associated fuel storage pools. ACTIONS CONDITION A. Fuel pool water level A.l not within limit. SURVEILLANCE REQUIREMENTS . SURVEILLANCE REQUIRED ACTION LCO 3.0.3 is not applicable. Suspend movement of irradiated fuel assemblies in the associated fuel storage pool ( s) . SR 3.7.7.1 Verify the fuel pool water level is 23 ft over the top of irradiated fuel assemblies seated in the storage racks. PERRY -UN IT 1 3.7-14 COMPLETION TIME Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No . 171 Fuel Handling Building 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Fuel Handling Building LCO 3.7.8 The fuel handling building CFHB) shall be OPERABLE. APPLICABILITY: During movement of recently irradiated fuel assemblies in the FHB. ACTIONS -------------------------------------NOTE-------------------------------------LCO 3.0.3 is not applicable. CONDITION REQUIRED ACTION A, FHB inoperable. A. l Suspend movement of recently irradiated fuel assemblies in the FHB. SURVEILLANCE REQUIREMENTS SR 3.7.8.1 SR 3.7.8.2 SURVEILLANCE Verify all FHB floor hatches and the shield blocks adjacent to the shield building are installed. and the FHB railroad track door is closed. Verify each FHB access door is closed. except when the access opening is being used for entry and exit. PERRY -UN IT 1 3.7-15 COMPLETION TIME Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No.171 Fuel Handling Building Ventilation Exhaust System 3.7.9 SURVEILLANCE REQUIREMENTS SURVE It LANCE SR 3.7.9.1 Operate each FHB ventilation exhaust subsystem for 10 continuous hours with heaters operating. SR 3. 7. 9. 2 Perform FHB ventilation exhaust filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

SR 3.7.9.3 Perform a system functional test. SR 3.7.9.4 Perform a CHANNEL FUNCTIONAL TEST of the FHB ventilation exhaust radiation monitor (noble gas) PERRY -UNIT 1 3.7-18 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No.171 SURVEILLANCE REQUIREMENTS SR 3.7.10.1 SR 3.7.10.2 PERRY -UNIT 1 SURVEILLANCE Verify each required ECCW subsystem manual. operated. and automatic valve in the flow path. that is not locked. sealed. or otherwise secured in position. is in the correct position or can be aligned to the correct position. Verify each ECCW subsystem actuates on an actual or simulated initiation signal. 3.7-20 ECCW System 3. 7 .10 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No . 171 AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SR 3.8.1.1 SR 3 .8.1.2 PERRY -UNIT 1 SURVEILLANCE Verify correct breaker alignment and indicated power availability for each required offsite circuit. ------------------NOTES--------------------1. Performance of SR 3.8.1.7 satisfies this SR. 2. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading. 3. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. Verify each DG starts from standby conditions and achieves: Steady state voltage 3900 V and s 4400 V and 58.8 Hz ands 61.2 Hz. 3.8-5 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Survei 11 ance Frequency Control Program (continued) Amendment No . 171 AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SR 3.8.1.3 SR 3.8.1.4 SR 3 .. 8.1.5 SR 3.8.1.6 PERRY -UNIT I SURVEILLANCE -------------------NOTES-------------------1. DG loadings may include gradual loading as recommended by the manufacturer. 2. Momentary transients outside the load range do not invalidate this test. 3. This Surveillance shall be conducted on only one DG at a time. 4. This SR shall be preceded by. and immediately follow. without shutdown. a successful performance of SR 3.8.1.2 or SR 3 . 8 . 1. 7 . Verify each DG operates for 60 minutes at a load 5600 kW and 7000 kW for Division 1 and 2 DGs. and 2600 kW for Division 3 DG. Verify each day tank contains 316 gal of fuel oil for Divisions 1 and 2 and 279 gal for Division 3. Check for and remove accumulated water from each day tank. Verify the fuel oil transfer system operates to automatically transfer fuel oil from the storage tank to the day tank. 3.8-6 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SR 3.8.1. 7 SR 3.8.1.8 PERRY -UNIT 1 SURVEILLANCE -------------------NOTE--------------------All DG starts may be preceded by an engine prelube period. Verify each DG starts from standby conditions and achieves: a. In 10 seconds for Division 1 and 2. and 13 seconds for Division 3. voltage 3900 V and frequency 58.8 Hz; and b. Steady state voltage 3900 V and 4400 V and frequency 58.8 Hz and 61.2 Hz. ---------------NOTE------------------------This Surveillance shall not be performed in* MODE 1 or 2 (not applicable to Division 3). However. credit may be taken for unplanned events that satisfy this SR. Verify manual transfer of unit power supply from the normal offsite circuit to the alternate offsite circuit. FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) 3.8-7 Amendment No. 171 AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SR 3 .8.1. 9 SURVEILLANCE -----------------NOTES--------------------1. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3). However. credit may be taken for unplanned events that satisfy this SR. 2. If performed with DG synchronized with offsite power. it shall be performed at a power factor 0.9. Verify each DG rejects a load greater than or equal to its associated single largest post-accident load. Following load rejection. engine speed is maintained less than nominal plus 75% of the difference between nominal speed and the overspeed trip setpoint. or 15% above nominal. whichever is less. SR 3.8.1.10 This Surveillance shall not be performed ion MODE 1 or 2 (not applicable to Division 3). However. credit may be taken for unplanned events that satisfy this SR. PERRY -UN IT 1 Verify each DG operating at a power factor 0.9 does not trip and voltage is maintained 4784 V for Division 1 and 2 DGs and $ 5000 V for Division 3 DG during and following a load rejection of a load 5600 kW for Division 1 and 2 DGs and 2600 kW for Division 3 DG. 3.8-8 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance . with the Surveillance Frequency Control Program (continued) Amendment No. 171 AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.8 1.11 -------------------NOTES-------------------PERRY -UNIT 1 1. All DG starts may be preceded by an engine prelube period. 2. This Surveillance shall not be performed in MODE 1. 2. or 3 (not applicable to Division 3). However. credit may be taken for unplanned events that satisfy this SR. Verify on an actual or simulated loss of offsite power signal: a. De-energization of emergency buses: b Load shedding from emergency buses for D1vis1ons 1 and 2: and c. DG auto-starts from standby condition and: 1. energizes permanently connected loads in 10 seconds for Division 1 and 2 DGs and 13 seconds for Div1s1on 3. 2. energizes auto-connected loads for Divisions 1 and 2. 3. maintains steady state voltage 3900 V 4400 V. 4. maintains steady state frequency 58.8 Hz and 61.2 Hz. and 5. supplies permanently connected and auto-connected loads for 5 minutes. 3 8-9 FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.8.1.12 -------------------NOTES-------------------1. All DG starts may be preceded by an engine prelube period. 2. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3). However. credit may be taken for unplanned events that satisfy this SR. Verify on an actual or simulated Emergency Core Cooling System <ECCS) initiation signal each DG auto-starts from standby condition and: a. 10 seconds for Division 1 and 2. and 13 seconds for Division 3. after auto-start and during tests. achieves voltage 3900 V and frequency 58.8 Hz; and b. Achieves steady state voltage 3900 V and 4400 V and frequency 58.8 Hz 61.2 Hz: and c. Operates 5 minutes. SR 3.8.1.13 This Surveillance shall not be performed in MODE 1. 2. or 3 (not applicable to Division 3). However. credit may be taken for unplanned events that satisfy this SR. PERRY -UNIT 1 Verify each DG's automatic trips are bypassed on an actual or simulated ECCS initiation signal except: a. Engine overspeed; and b. Generator differential current 3. 8-10 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.8.1.14 -------------------NOTES-------------------PERRY -UNIT 1 1. Momentary transients outside the load and power factor ranges do not invalidate this test. 2. Credit may be taken for unplanned events that satisfy this SR. Verify each DG operating at a power factor 5 0.9 operates 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: a. For 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded 6800 kW and 5 7000 kW for Division 1 and 2 DGs. and 2860 kW for Division 3 DG: and b. For the remaining hours of the test loaded 5600 kW and 5 7000 kW for Division 1 and 2 DGs. and 2600 kW for Division 3 DG. 3. 8-11 FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) Amendment No . 171 AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.8.1.15 ------------------NOTES-------------------1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months loaded 5600 kW and 7000 kW for Division 1 and 2 DGs. 2600 kW for Division 3 OG. Momentary transients outside of the load range do not invalidate this test. 2. All DG starts may be preceded by an engine prelube period. Verify each DG starts and achieves: a. Ins 10 seconds for Division 1 and 2. and s 13 seconds for Division 3. voltage 3900 V and frequency 58.8 Hz: and b. Steady state voltage 3900 V and s 4400 V and frequency 58.8 Hz and s 61.2 Hz. SR 3.8.1.16 Thi s Survei 11 ance sha 11 not be performed in MOOE 1. 2. or 3 (not applicable to Division 3). However. credit may be taken for unplanned events that satisfy this SR. PERRY -UNIT 1 Verify each OG: a. Synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power: b. Transfers loads to offsite power source; and c. Returns to ready-to-load operation. 3.8-12 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.8.1.17 This Surveillance shall not be performed in MODE 1. 2. or 3 (not applicable to Division 3). However. credit may be taken for unplanned events that satisfy this SR. Verify. with a DG operating in test mode and connected to its bus. an actual or simulated ECCS initiation signal overrides the test mode by: a. Returning DG to ready-to-load operation; and b. Automatically energizing the emergency loads from offsite power. SR 3.8.1.18 Thi s Survei 11 ance shall not be performed in MODE 1. 2. or 3. However. credit may be taken for unplanned events that satisfy this SR. PERRY -: UNIT 1 Verify for Division 1 and 2 OGs. the sequence time is within +/- 10% of design for each load sequence timer. 3.8-13 FREQUENCY In accordance

with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.8.1.19 -------------------NOTES-------------------PERRY -UNIT 1 1. All DG starts may be preceded by an engine prelube period. 2. This Surveillance shall not be performed in MODE 1. 2. or 3 (not applicable to Division 3). However. credit may be taken for unplanned events that satisfy this SR. Verify, on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ECCS initiation signal: a. De-energization of emergency buses: b. Load shedding from emergency buses for Divisions 1 and 2: and c. DG auto-starts from standby condition and: 1. energizes permanently connected 1 oads in 10 seconds for Divisions 1 and 2 and 13 seconds for Division 3. 2. energizes auto-connected emergency loads (for Division 3. verify energization 13 seconds). 3. achieves steady state voltage 3900 V 4400 V. 4. achieves steady state frequency 58.8 Hz and 61.2 Hz. and 5. supplies permanently connected and auto-connected emergency loads for 5 minutes. 3.8-14 FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.8.1.20 All DG starts may be preceded by an engine prelube period. PERRY -UNIT 1 Verify. from standby cond1t1on. each DG achieves: a. In 10 seconds for Division 1 and 2. and 13 seconds for Division 3. voltage 3900 V and frequency 58.8 Hz: and b. Steady state voltage 3900 V and 4400 V and frequency 58.8 Hz and 61.2 Hz. 3.8-15 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 171 Diesel Fuel Oil. Lube Oil. and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains: In accordance with the a. 73.700 gal of fuel for Div 1 DG Surveillance and Div 2 DG: and Frequencp Control rogram b. 36.700 gal of fuel for Div 3 DG. SR 3.8.3.2 Verify lube oil inventory is: In accordance with the a. ;::: 374 gal for Div 1 DG and Div 2 DG; Surveillance and Frequencp Control rogram b. ;::: 260 gal for Div 3 DG. SR 3.8.3.3 Verify fuel oil properties of new and In accordance stored fuel oil are tested in accordance with the Diesel with. and maintained within the limits of. Fuel Oil the Diesel Fuel Oil Testing Program. Testing Program SR 3.8.3.4 Verify each required DG air start receiver In accordance pressure is 210 psig. with the Surveillance Control rogram SR 3.8.3.5 Check for and remove accumulated water from In accordance each fuel oil storage tank. with the Surveillance Control rogram SR 3.8.3.6 For each fuel oil storage tank: In accordance with the a. Drain the fuel oil: Surveillance b. Remove the sediment: and Control rogram c. Clean the tank. PERRY -UN IT 1 3.8-23 Amendment No . 171 DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 SR 3.8.4.4 PERRY -UN IT 1 SURVEILLANCE Verify battery terminal voltage is 129 V on float charge. Verify no visible corrosion at battery terminals and connectors. Verify battery connection resistance is 5.0 E-5 ohm for inter-cell connections. 5 5.0 E-5 ohm for inter-rack connections. 5.0 E-5 ohm for inter-tier connections. 5 5.0 E-5 ohm for terminal connections: for Div 1 and Div 2 and 1.0 E-4 ohm for inter-cell connections. 1.0 E-4 ohm for inter-rack connections. 1.0 E-4 ohm for inter-tier connections. 1.0 E-4 ohm for terminal connections. for Div 3. Verify battery cells. cell plates. and racks show no visual indication of physical damage or abnormal deterioration that could degrade battery performance. Remove visible corrosion. and verify battery cell to cell and terminal connections are coated with anti-corrosion material. 3.8-25 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued) SR 3.8.4.5 SR 3.8.4.6 SR 3.8.4.7 PERRY -UNIT 1 SURVEILLANCE Verify battery connection resistance is 5.0 E-5 ohm for inter-cell connections. 5.0 E-5 ohm for inter-rack connections. 5.0 E-5 ohm for inter-tier connections. 5.0 E-5 ohm for terminal connections: for Div 1 and Div 2 and 1.0 E-4 ohm for inter-cell connections. 1.0 E-4 ohm for inter-rack connections. 1.0 E-4 ohm for inter-tier connections. 1.0 E-4 ohm for terminal connections for Div 3. Verify each required Division 1 and 2 battery charger supplies z 400 amps at z 125 V for z 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months s: and each required Division 3 battery charger supplies z 50 amps at z 125 V for z 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . SR 3.8.4.8 may be performed in lieu of SR 3.8.4.7. Verify battery capacity is adequate to supply. and maintain in OPERABLE status. the required emergency loads for the design duty cycle when subJected to a battery service test. 3.8-26 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued) SR 3.8.4.8 PERRY -UN IT 1 SURVEILLANCE -------------------NOTE-----------------Credit may be taken for unplanned events that satisfy this SR. Verify battery capacity is 80% of the manufacturer's rating when subJected to a performance discharge test. 3.8-27 DC Sources-Operating 3.8.4 FREQUENCY In accordance with the Surveillance 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 2 100% of manufacturer* s rat mg Amendment No. 171 ACTIONS (continued) CONDITION B. Required Action and B.1 associated Completion Time of Condition A not met. OR One or more batteries with average electrolyte

temperature of the representative cells < 72°F. OR One or more batteries with one or more battery cell parameters not within Table 3.8.6-1 Category C limits. SURVEILLANCE REQUIREMENTS SURVEILLANCE Battery Cell Parameters 3.8.6 REQUIRED ACTION Declare associated battery inoperable. COMPLETION TIME Immediately FREQUENCY SR 3.8.6.1 Verify battery cell parameters meet Table 3.8.6-1 Category A limits. ln accordance with the Surveillance Frequency Control.Program (continued) PERRY -UN IT 1 3.8-33 Amendment No . 171 Battery Cell Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued) SR 3.8.6.2 SURVEILLANCE Verify battery cell parameters meet Table 3.8.6-1 Category B limits. SR 3.8.6.3 Verify average electrolyte temperature of representative cells is 72°F. PERRY -UNIT I 3.8-34 FREQUENCY In accordance with the Surveillance Frequency Control Program ANO Once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after battery overcharge > 145 v In accordance with the Surveillance Frequency Control Program Amendment No . 1 71 Distribution Systems-Operating 3.8.7 ACTIONS (continued) CONDITION REQUIRED ACTION C. Required Action and C.1 Be in MODE 3. associated Completion AND Time of Condition A or B not met. C.2 Be in MODE 4. D. One or more Division 3 D.1 Declare High Pressure AC or DC electrical Core Spray System power distribution inoperable. subsystems inoperable. E. Two or more divisions E.1 Enter LCO 3.0.3. with inoperable distribution subsystems that result in a loss of function. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.7.1 Verify correct breaker alignments and voltage to required AC and DC electrical power distribution subsystems. PERRY -UNIT 1 3. 8-37 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours Immediately Immediately FREQUENCY In accordance with the Survei l1 ance Frequency Control Program Amendment No . 171 Distribution Systems-Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION A. (continued) A.2.3 Initiate action to operations wit a potential for draining the reactor vessel. AND A.2.4 Initiate actions to restore required AC and DC electrical power distribution subsystems to OPERABLE status. AND A.2.5 Declare associated required shutdown cooling subsystem(s) inoperable and not in operation. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.8.1 Verify correct breaker alignments and voltage to required AC and DC electrical power distribution subsystems. PERRY -UNIT 1 3.8-39 COMPLETION TIME Immediately Inmediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No.171 Refueling Equipment Interlocks 3.9.1 3.9 REFUELING OPERATIONS 3.9.1 Refueling Equipment Interlocks LCO 3.9.1 The refueling equipment interlocks shall be OPERABLE. APPLICABILITY: During in-vessel fuel movement with equipment associated with the interlocks. ACTIONS CONDITION REQUIRED ACTION A. One or more required A.1 in-vessel refueling equipment fue movement with interlocks inoperable. equipment associated with the inoperable interlock (s). OR A.2.1 Insert a control rod withdrawal block. AND A.2.2 Verify all control rods ar*e fully inserted. SURVEILLANCE REQUIREMENTS SR 3. 9.1. l PERRY -UN IT 1 SURVEILLANCE *Perform CHANNEL FUNCTIONAL TEST on each of the following required refueling equipment interlock inputs: a. All-rods-in. b. Refuel platform position. and c. Refuel platform main hoist. fuel loaded. 3.9-1 COMPLETION TIME Immediately Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 171 3.9 REFUELING OPERATIONS Refuel Position One-Rod-Out Interlock 3.9.2 3.9.2 Refuel Position One-Rod-Out Interlock LCD 3.9.2 The refuel position one-rod-out interlock shall be OPERABLE. APPLICABILITY: MODE 5 with the reactor mode switch in the refuel position and any control rod withdrawn. ACTIONS CONDITION A. Refuel position rod-out interlock inoperable. A.1 AND REQUIRED ACTION Suspend control rod wi thdrawa 1 . COMPLETION TIME Immediately A.2 Initiate action to Immediately fully insert all insertable control rods i.n core cells containing one or more fuel assemblies. SURVEILLANCE REQUIREMENTS SR 3.9.2.1 PERRY -UN IT 1 SURVEILLANCE Verify reactor mode switch locked in refuel position. 3.9-2 FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) Amendment No . 171 Refuel Position One-Rod-Out Interlock 3.9.2 SURVEILLANCE REQUIREMENTS (continued) SR 3.9.2.2 PERRY -UNIT 1 SURVEILLANCE -------------------NOTE--------------------Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after any control rod is withdrawn. Perform CHANNEL FUNCTIONAL TEST. 3.9-3 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 171 3.9 REFUELING OPERATIONS 3.9.3 Control Rod Position LCO 3.9.3 All control rods shall be fully inserted. APPLICABILITY: When loading fuel assemblies into the core. ACTIONS CONDITION A. One or more control rods not fully inserted. A.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIRED ACTION Suspend loading fuel assemblies into the core. SR 3.9.3.1 Verify a 11 contra l rods are fully inserted. PERRY -UN IT I 3.9-4 Control Rod Position 3.9.3 COMPLETION TIME Inunediately FREQUENCY

In accordance with the Survei.11 ance Frequency Control Program Amendment No.171 Control Rod OPERABILITY-Refueling 3.9.5 3.9 REFUELING OPERATIONS 3.9.5 Control Rod OPERABILITY-Refueling LCO 3.9.5 Each withdrawn control rod shall be OPERABLE. APPLICABILITY: MODE 5. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more withdrawn A.1 control rods Initiate action to I1T111ediately inoperable. fully insert inoperable withdrawn control rods. SURVEILLANCE REQUIREMENTS SR 3.9.5.1 SURVEILLANCE -------------------NOTE--------------------Not required to be performed until 7 days after the control rod is withdrawn. FREQUENCY Insert each withdrawn control rod at least In accordance one notch. with the Surveillance Frequency Control Program SR 3.9.5.2 Verify each withdrawn control rod scram accumulator pressure is 1520 psig. In accordance with the Surveillance Frequency Control Program PERRY -UNIT 1 3.9-7 Amendment No.171 RPV Water Level-Irradiated Fuel 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Reactor Pressure Vessel (RPV) Water Level-Irradiated Fuel LCO 3.9.6 RPV water level shall 22 ft 9 inches above the top of the RPV flange. APPLICABILITY: During movement of irradiated fuel assemblies within the RPV. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RPV water level not within limit. A.1 Suspend movement of Inmediately irradiated fuel assemblies within the RPV. SURVEILLANCE REQUIREMENTS SURVEILLANCE. SR 3.9.6.1 Verify RPV water level is 22 ft 9 inches above the top of the RPV flange. PERRY -UNIT 1 3.9-8 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No . 171 RPV Water Level-New Fuel or Control Rods 3.9.7 3.9 REFUELING OPERATIONS 3.9.7 Reactor Pressure Vessel (RPV) Water Level-New Fuel or Control Rods LCO 3.9.7 RPV water level shall 23 ft above the top of irradiated fuel assemblies seated within the RPV. APPLICABILITY: During movement of new fuel assemblies or handling of control rods within the RPV when irradiated fuel assemblies are seated within the RPV. ACTIONS CONDITION A. RPV water level not within limit. A.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIRED ACTION Suspend movement of new fuel assemblies and handling of control rods within the RPV. SR 3.9.7.1 Verify RPV water level 23 ft above the top of irradiated fuel assemblies seated within the RPV. PERRY -UNIT 1 3.9-9 COMPLETION TIME Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 171 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.8.1 Verify one RHR shutdown cooling subsystem is operating. PERRY -UNIT 1 3.9-12 RHR-High Water Level 3.9.8 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 171 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.9.1 Verify one RHR shutdown cooling subsystem is operating. PERRY -UNIT 1 3. 9-15 RHR-Low Water Level 3.9.9 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 171 Reactor Mode Switch Interlock Testing 3.10.2 ACTIONS CONDITION A. C continued.) SURVEILLANCE REQUIREMENTS REQUIRED ACTION A.3.1 Place the reactor mode switch in the shutdown position. OR A.3.2 --------NOTE---------Only applicable in MODE 5. Place the reactor mode switch in the refuel position. SURVEILLANCE SR 3 .10. 2 .1 Verify all contra l rods are fully inserted in core cells containing one or more fuel assemblies. SR 3.10.2.2 Verify no CORE ALTERATIONS are in progress. PERRY -UNIT 1 3.10-5 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No.171 Single Control Rod Withdrawal-Hot Shutdown 3.10.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3. 10. 3. 1 Perform the applicable SRs for the required According to LCOs. the applicable SRs SR 3.10.3.2 Not required to be met if SR 3.10.3.1 is satisfied for LCO 3.10.3.d.1 requirements. Verify all control rods. other than the control rod being withdrawn. in a five by five array centered on the control rod being withdrawn, are disarmed. SR 3.10.3.3 Verify all control rods. other than the control rod being withdrawn. are fully inserted. PERRY -UNIT 1 3.10-8 In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 171 Single Control Rod Withdrawal-Cold Shutdown 3.10.4 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME 8. One or more of the 8.1 Suspend withdrawal of Immediately above requirements not the control rod and met with the affected removal of associated control rod not CRD. insertable. AND 8.2.1 Initiate action to Immediately fully insert all control rods. OR 8.2.2 Initiate action to satisfy the Immediately re3uirements of this LC . SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.4.1 Perform the applicable SRs for the required According to

LCOs. applicable SRs SR 3.10.4.2 Not required to be met if SR 3.10.4.1 is satisfied for LCD 3.10.4.c.1 requirements. PERRY -UNIT 1 Verify all control rods. other than the control rod being withdrawn. in a five by five array centered on the control rod being withdrawn. are disarmed. 3.10-11 In accordance with the Surveillance Frequency Control Program (continued) Amendment No.171 Single Control Rod Withdrawal-Cold Shutdown 3.10.4 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.10.4.3 Verify all control rods. other than the control rod being withdrawn. are fully inserted. SR 3.10.4.4 Not required to be met if SR 3.10.4.1 is satisfied for LCD 3.10.4.b.1 requirements. PERRY -UNIT 1 Verify a control rod withdrawal block is inserted. 3.10-12 FREQUENCY In accordance with the Surveillance Frequency Control Program ln accordance with the Surveillance Frequency Control Program Amendment No. 171 Single CRD Removal-Refueling 3.10.5 ACTIONS CONDITION REQUIRED ACTION A. (continued) A.2.1 Initiate action to fully insert all control rods. OR A.2.2 Initiate action to satisfy the requirements of this LCO. SURVEILLANCE REQUIREMENTS SR 3.10.5.1 SR 3.10.5.2 SR 3.10.5.3 PERRY -UN IT 1 SURVEILLANCE Verify a 11 contra ls rods. other than the control rod withdrawn for the removal of the associated CRD. are fully inserted. Verify a 11 contra l rods. other than the control rod withdrawn for the removal of the associated CRD. in a five by five array centered on the control rod withdrawn for the removal of the associated CRD. are disarmed. Verify a control rod withdrawal block is inserted. 3.10-14 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.10.5.4 Perform SR 3.1.1.1. Single CRO Removal-Refueling 3.10.5 FREQUENCY According to SR 3.1. l. l SR 3.10.5.5 Verify no CORE ALTERATIONS are in progress. In accordance with the Surveillance Frequency Control Program PERRY -UNIT 1 3.10-15 Amendment No. 171 Multiple Control Rod Withdrawal-Refueling 3.10.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3.1 Initiate action to Immediately fully insert all control rods in core cells containing one or more fuel . assemblies. OR A.3.2 Initiate action to satisfy the requirements of this LCO. SURVEILLANCE REQUIREMENTS SR 3.10.6.1 SR 3.10.6.2 SURVEILLANCE Verify the four fuel assemblies are removed from core cells associated with each control rod or CRD removed. Verify all other control rods in core cells containing one or more fuel assemblies are fully inserted. SR 3.10.6.3 Only required to be met during fuel loading. PERRY -UNIT 1 Verify fuel assemblies being loaded are in compliance with an approved spiral reload sequence. 3.10-17 Immediately FREQUENCY In accordance with the Survei.11 ance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No . 171 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.10.8.2 Not required to be met if SR 3.10.8.3 satisfied. Perform the MODE 2 applicable SRs for LCO 3.3.2.1. Function l.b of Table 3.3.2.1-1. SR 3.10.8.3 Not required to be met if SR 3.10.8.2 satisfied. Verify movement of control rods is in compliance with the approved control rod sequence for the SDM test by a second licensed operator or other qualified member of the technical staff. SR 3.10.8.4 . Verify no other CORE ALTERATIONS are in progress. PERRY -UN IT 1 3.10-21 SDM Test-Refueling 3.10.8 FREQUENCY According to the applicable SRs During control rod movement In accordance with the Surveillance Frequency Control Program (continued) Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.10.8.5 Verify each withdrawn control rod does not go to the withdrawn overtravel position. SR 3.10.8.6 Verify CRD charging water header pressure 1520 psig. PERRY -UNIT 1 3.10-22 SOM Test-Refueling 3.10.8 FREQUENCY Each time the control rod is withdrawn to "full out" position AND Prior to satisfying LCO 3.10.8.c requirement after work on control rod or CRD System that could affect coupling In accordance with the Surveillance Frequency Control Program Amendment No . 1 71 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Control Room Envelope Habitability Program (continued) protection is provided to permit access and occupancy of the CRE under design basis accident (OBA) conditions without personnel receiving radiation exposures in excess of 5 rem Total Effective Dose Equivalent (TEDE) 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 Sections C.l 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.l and C.2 of Regulatory Guide 1.197. Revision 0. d. Measurement of leakage through the outside air intake and exhaust dampers at a Frequency of 24 months. The results shall be trended and used as part of the periodic assessment of the CRE boundary. e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences. Unfiltered air inleakage 11m1ts for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis. f. .The provisions of SR 3.0.2 are applicable to the Freguencies for assessing CRE habitability. determining CRE unfiltered inleakage. and measuring outside air intake and exhaust damper leakage. as required by paragraphs c and d. respectively. (continued) PERRY -UNIT 1 5.0-15c Amendment No. 171 Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.15 Surve111 a nee Contra l Prog.r.!'.!m This program provides controls for Surveillance Frequencies. The program sha 11 ensure that Surve1 l lance Requirements spec1 fied 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 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. PERRY -UNIT 1 5.0-15d Amendment No. 171 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 171 TO FACILITY OPERATING LICENSE NO. NPF-58 FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION. LLC OHIO EDISON COMPANY PERRY NUCLEAR POWER PLANT. UNIT NO. 1 DOCKET NO. 50-440

1.0 INTRODUCTION

By application dated March 25, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 14084A165), as supplemented by letters dated October 7, 2014, and August 24, 2015 (ADAMS Accession Nos. ML 14281A125 and ML 15237A035, respectively), FirstEnergy Nuclear Operating Company (the licensee or FENOC) requested changes to the technical specifications (TSs) for the Perry Nuclear Power Plant, Unit 1 (PNPP or Perry). The supplemental letters dated October 7, 2014, and August 24, 2015, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register (FR) on September 16, 2014 (79 FR 55512). The proposed changes would revise the TSs by relocating specific surveillance requirement (SR) frequencies to a licensee-controlled program in accordance with Nuclear Energy Institute (NEI) 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies" (ADAMS Accession No. ML071360456). The requested changes are consistent with the U.S. NRG-approved Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) Change Traveler TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF [Risk-Informed TSTF] Initiative Sb" (ADAMS Accession No. ML090850642). The Federal Register notice published on July 6, 2009 (74 FR 31996), announced the availability of TSTF-425, Revision 3. When implemented, TSTF-425, Revision 3, relocates most periodic frequencies of TS surveillances to the Surveillance Frequency Control Program (SFCP), and provides requirements for the new SFCP in the Administrative Controls section of the TSs. All surveillance frequencies can be relocated except the following: Enclosure 2

Frequencies that reference other approved programs for the specific interval (such as the lnservice 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 95% RTP"); and

Frequencies that are related to specific conditions (e.g., battery degradation, age and capacity) or conditions for the performance of a surveillance requirement (e.g., "drywell to suppression chamber differential pressure decrease"). The licensee proposed to add the SFCP to TSs, Section 5.0, "Administrative Controls," Subsection 5.5, "Programs and Manuals." The SFCP describes the requirements for the program to control changes to the relocated surveillance frequencies. The TS Bases for each affected surveillance would be revised to state that the frequency is controlled under the SFCP. The existing TS Bases information describing the basis for the surveillance frequency will be relocated to the licensee-controlled SFCP. The proposed changes to the Administrative Controls section of the TSs to incorporate the SFCP include a specific reference to NEI 04-10, Revision 1, as the basis for making any changes to the surveillance frequencies once they are relocated out of the TSs. In a letter dated September 19, 2007 (ADAMS Accession No. ML072570267), the NRC staff approved Topical Report NEI 04-10, Revision 1, as acceptable for referencing in licensing actions, to the extent specified and under the limitations delineated in NEI 04-10, Revision 1, and in the NRC staff's safety evaluation (SE) for NEI 04-10, Revision 1. The licensee proposed other changes and deviations from TSTF-425, which are discussed in Section 3.3 of this SE.

2.0 REGULATORY EVALUATION

2.1 Applicable Commission Policy Statements In the "Final Policy Statement: Technical Specifications for Nuclear Power Plants," dated July 22, 1993 (58 FR 39132), the NRC addressed the use of Probabilistic Safety Analysis (PSA, currently referred to as Probabilistic Risk Assessment or PRA) in STS. In this 1993 publication, the NRC states: The Commission believes that it would be inappropriate at this time to allow requirements which meet one or more of the first three criteria [of Title 1 O of the Code of Federal Regulations (10 CFR), Section 50.36] to be deleted from Technical Specifications based solely on PSA (Criterion 4). However, if the results of PSA indicate that Technical Specifications can be relaxed or removed, a deterministic review will be performed. The Commission Policy in this regard is consistent with its Policy Statement on "Safety Goals for the Operation of Nuclear Power Plants," 51 FR 30028, published on August 21, 1986. The Policy Statement on Safety Goals states in part, "* *

probabilistic results should also be reasonably balanced and supported through use of deterministic arguments. In this way, judgments can be made * *

about the degree of confidence to be given these [probabilistic] estimates and assumptions. This is a key part of the process for determining the degree of regulatory conservatism that may be warranted for particular decisions. This defense-in-depth approach is expected to continue to ensure the protection of public health and safety." The Commission will continue to use PSA, consistent with its policy on Safety Goals, as a tool in evaluating specific line-item improvements to Technical Specifications, new requirements, and industry proposals for risk-based Technical Specification changes. Approximately two years later, the NRC provided additional detail concerning the use of PRA in the "Final Policy Statement: Use of Probabilistic Risk Assessment in Nuclear Regulatory Activities," dated August 16, 1995 (60 FR 42622). In this publication, the NRC states: The Commission believes that an overall policy on the use of PRA methods in nuclear regulatory activities should be established so that the many potential applications of PRA can be implemented in a consistent and predictable manner that would promote regulatory stability and efficiency. In addition, the Commission believes that the use of PRA technology in NRC regulatory activities should be increased to the extent supported by the state-of-the-art in PRA methods and data and in a manner that complements the NRC's deterministic approach .... PRA addresses a broad spectrum of initiating events by assessing the event frequency. Mitigating system reliability is then assessed, including the potential for multiple and common cause failures. The treatment therefore goes beyond the single failure requirements in the deterministic approach. The probabilistic approach to regulation is, therefore, considered an extension and enhancement of traditional regulation by considering risk in a more coherent and complete manner .... Therefore, the Commission believes that an overall policy on the use of PRA in nuclear regulatory activities should be established so that the many potential applications of PRA can be implemented in a consistent and predictable manner that promotes regulatory stability and efficiency. This policy statement sets forth the Commission's intention to encourage the use of PRA and to expand the scope of PRA applications in all nuclear regulatory matters to the extent supported by the state-of-the-art in terms of methods and data .... Therefore, the Commission adopts the following policy statement regarding the expanded NRC use of PRA: ( 1) The use of PRA technology should be increased in all regulatory matters to the extent supported by the state-of-the-art in PRA methods and data and in a manner that complements the NRC's deterministic approach and supports the NRC's traditional defense-in-depth philosophy. (2) PRA and associated analyses (e.g., sensitivity studies, uncertainty analyses, and importance measures) should be used in regulatory matters, where practical within the bounds of the state-of-the-art, to reduce unnecessary conservatism associated with current regulatory requirements, regulatory guides, license commitments, and staff practices. Where appropriate, PRA should be used to support the proposal for additional regulatory requirements in accordance with 10 CFR 50.109 (Backfit Rule). Appropriate procedures for including PRA in the process for changing regulatory requirements should be developed and followed. It is, of course, understood that the intent of this policy is that existing rules and regulations shall be complied with unless these rules and regulations are revised. (3) PRA evaluations in support of regulatory decisions should be as realistic as practicable and appropriate supporting data should be publicly available for review. (4) The Commission's safety goals for nuclear power plants and subsidiary numerical objectives are to be used with appropriate consideration of uncertainties in making regulatory judgments on the need for proposing and backfitting new generic requirements on nuclear power plant licensees. 2.2 Applicable Regulations In 10 CFR, Section 50.36, the NRC established its regulatory requirements related to the content of TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) SRs; (4) design features; and (5) administrative controls. These categories will remain in the PNPP TSs. Paragraph 50.36(c)(3) of 10 CFR states, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The FR notice published on July 6, 2009 (74 FR 31996), which announced the availability of TSTF-425, Revision 3, states that the addition of the SFCP to the TSs provides the necessary administrative controls to require that surveillance frequencies relocated to the SFCP are conducted at a frequency to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The FR notice also states that changes to surveillance frequencies in the SFCP are made using the methodology contained in NEI 04-10, Revision 1, including qualitative considerations, results of risk analyses, sensitivity studies and any bounding analyses, and recommended monitoring of structures, systems, and components (SSCs), and are required to be documented. Existing regulatory requirements, such as 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 licensee monitoring of surveillance test failures and implementing corrective actions to address such failures. Such failures can result in the licensee increasing the frequency of a surveillance test. In addition, by having the TSs require that changes to the frequencies listed in the SFCP be made in accordance with NEI 04-10, Revision 1, the licensee will be required to monitor the performance of SSCs for which surveillance frequencies are decreased to assure reduced surveillance testing does not adversely impact the SSCs. 2.3 Applicable NRC Regulatory Guides and Review Plans 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. ML 100910006), describes an acceptable risk-informed approach for assessing the nature and impact of proposed permanent licensing-basis changes by considering engineering issues and applying risk insights. This regulatory guide also provides risk acceptance guidelines for evaluating the results of such evaluations. RG 1.177, Revision 1, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications" (ADAMS Accession No. ML 100910008), 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 decision making for light-water reactors (LWRs). General guidance for evaluating the technical basis for proposed risk-informed changes is provided in NUREG-0800, "Standard Review Plan [SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," Chapter 19, Section 19.2, "Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance" (ADAMS Accession No. ML071700658). Guidance on evaluating PRA technical adequacy is provided in SRP, Chapter 19, 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. ML 12193A107). More specific guidance related to risk-informed TS changes is provided in SRP, Chapter 16, Section 16.1, Revision 1, "Risk-Informed Decisionmaking: Technical Specifications" (ADAMS Accession No. ML070380228), which includes changes to surveillance test intervals (STls) (i.e., surveillance frequencies) as part of risk-informed decision making. Section 19.2 of the SRP references the same criteria as RG 1.177, Revision 1, and RG 1.17 4, Revision 2, and states that a risk-informed application should be evaluated to ensure that the proposed changes meet the following key principles:

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

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

The proposed change maintains sufficient safety margins.

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

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

3.0 TECHNICAL EVALUATION

The licensee's adoption of TSTF-425, Revision 3, provides for administrative relocation of applicable surveillance frequencies to the SFCP, and provides for the addition of the SFCP to the Administrative Controls section of TSs. The changes to the Administrative Controls section of the TSs will also require the application of NEI 04-10, Revision 1, for any changes to surveillance frequencies within the SFCP. The licensee's application to implement the changes described in TSTF-425, Revision 3, included documentation regarding the PRA technical adequacy consistent with 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 provided in RG 1.17 4, Revision 2, and RG 1.177, Revision 1, in support of changes to STls. 3. 1 Review Methodology Regulatory Guide 1.177, Revision 1, identifies five key safety principles required for informed changes to TSs. Each of these principles is addressed by NEI 04-10, Revision 1. 3.1.1 The Proposed Change Meets Current Regulations Paragraph 50.36(c)(3) of 10 CFR Part 50 requires that TSs include surveillances which are "requirements relating to test, calibration, or inspection to assure that necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The licensee is required by its TSs to perform surveillance tests, calibration, or inspection on specific safety-related equipment (e.g., reactivity control, power distribution, electrical, and instrumentation) to verify system operability. Surveillance frequencies are based primarily upon deterministic methods such as engineering judgment, operating experience, and manufacturer's recommendations. The licensee's use of NRG-approved methodologies identified in NEI 04-10, Revision 1, provides a way to establish risk-informed surveillance frequencies that complements the deterministic approach and supports the NRC's traditional defense-in-depth philosophy. The SRs themselves are remaining in the TSs, as required by 10 CFR 50.36(c)(3). This change is analogous with other NRG-approved TS changes in which the SRs are retained in TSs, but the related surveillance frequencies are relocated to licensee-controlled documents, such as surveillances performed in accordance with the In-Service Testing Program and the Primary Containment Leakage Rate Testing Program. Thus, this proposed change complies with 10 CFR 50.36(c)(3) by retaining the requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The regulatory requirements in 10 CFR 50.65, 10 CFR Part 50, Appendix B, and the monitoring required by NEI 04-10, Revision 1, ensure that surveillance frequencies are sufficient to assure that the requirements of 10 CFR 50.36 are satisfied, and that any performance deficiencies will be identified and appropriate corrective actions taken. The licensee's SFCP ensures that SRs specified in the TSs are performed at intervals sufficient to assure the above regulatory requirements are met. Based on the above, the staff concludes that the proposed change meets 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 the Defense-in-Depth Philosophy The defense-in-depth philosophy is maintained if:

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

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

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

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

Independence of barriers is not degraded.

Defenses against human errors are preserved.

The intent of the General Design Criteria in 10 CFR Part 50, Appendix A, is maintained. The changes to the Administrative Controls section of the TSs will require the application of NEI 04-10, Revision 1, for any changes to surveillance frequencies within the SFCP. NEI 04-10, Revision 1, uses both the CDF and the large early release frequency (LERF) metrics to evaluate the impact of proposed changes to surveillance frequencies. The guidance of RG 1.17 4, Revision 2, and RG 1.177, Revision 1, for changes to CDF and LERF is achieved by evaluation using a comprehensive risk analysis, which assesses the impact of proposed changes including contributions from human errors and common cause failures (CCFs). Defense-in-depth is also included in the methodology explicitly as a qualitative consideration outside of the risk analysis, as is the potential impact on detection of component degradation that could lead to an increased likelihood of CCFs. Therefore, the NRC staff concludes that both the quantitative risk analysis and the qualitative considerations assure a reasonable balance of defense-in-depth is 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 is provided to ensure sufficient safety margin will continue to exist. The design, operation, testing methods, and acceptance criteria for SSCs specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plants' licensing bases, including the Updated Final Safety Analysis Report and TS Bases, because these are not affected by changes to the surveillance frequencies. Similarly, there is no impact to safety analysis acceptance criteria as described in the plant licensing basis. Based on the above, 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 When Proposed Changes Result in an Increase in CDF or Risk, the Increases Should Be Small and Consistent with the Intent of the Commission's Safety Goal Policy Statement RG 1.177, Revision 1, provides a framework for evaluating the risk impact of proposed changes to surveillance frequencies which requires identification of the risk contribution from impacted surveillances, determination of the risk impact from the change to the proposed surveillance frequency, and performance of sensitivity and uncertainty evaluations. The changes to the Administrative Controls section of the TSs will require application of NEI 04-10, Revision 1, in the SFCP. NEI 04-10, Revision 1, satisfies the intent of RG 1.177, Revision 1, guidance for evaluation of the change in risk, and for assuring that such changes are small by providing the technical methodology to support risk-informed TSs for control of surveillance frequencies. 3.1.4.1 Quality of the PRA The quality of the licensee's PRA must be commensurate with the safety significance of the proposed TS change and the role the PRA plays in justifying the change. That is, the 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 quality of the PRA. Regulatory Guide 1.200 provides regulatory guidance for assessing the technical adequacy of a PRA. The current revision (i.e., Revision 2) of this RG endorses, with clarifications and qualifications, the use of (1) American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) RA-Sa-2009, "Addenda to ASME RA-S-2008 Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications" (i.e., the PRA Standard), (2) NEI 00-02, "PRA Peer Review Process Guidance" (ADAMS Accession Nos. ML061510619 and ML063390593), and (3) NEI 05-04, "Process for Performing Internal Events PRA Peer Reviews Using the ASME/ANS PRA Standard" (ADAMS Accession No. ML083430462). The licensee has performed an assessment of the PRA models used to support the SFCP using the guidance of RG 1.200, Revision 2, to assure that the PRA models are capable of determining the change in risk due to changes to surveillance frequencies of SSCs, using plant-specific data and models. Capability Category II of the NRG-endorsed PRA standard is the target capability level for supporting requirements for the internal events PRA for this application. Any identified deficiencies to those requirements are assessed further to determine any impacts to proposed decreases to surveillance frequencies, including the use of sensitivity studies where appropriate, in accordance with NEI 04-10, Revision 1. In Enclosure B to the application dated March 25, 2014, the licensee summarized the following:

1997 probabilistic safety assessment (PSA) peer review certification;

2008 gap analysis self-assessment to ASME/ANS PRA Standard RA-Sb-2005, "Addenda to ASME RA-S-2002 Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications";

2011 focused-scope peer review for the LERF portion of the PRA model; and

2012 focused-scope peer review for the internal flooding portion of thePRA model. The response to PRA Request for Additional Information (RAI) 1, provided in the licensee's letter dated October 7, 2014, provides the peer review facts and observations (F&Os) findings and suggestions for the 2008 gap analysis and the 2011 and 2012 focused-scope peer reviews. The response stated the "1997 PSA Peer Review Certification F&Os were not included as the follow-on reviews were a complete reevaluation to the PRA standard in effect and supersede this information. Therefore, the 1997 PSA Peer Review Certification F&Os are not considered relevant to the application." The response to RAI 2, provided in the licensee's letter dated August 24, 2015, clarifies that the 2008 independent gap assessment was considered to be equivalent to an industry peer review, but was not formally declared a peer review because utility peers were not part of the peer review team. The response also explained that the 2008 gap assessment reevaluated the F&Os from the 1997 peer review. The NRC staff notes that new peer reviews, which include consideration of previous peer review findings and the licensee's implementation of the resolution to those findings, can be used to close-out earlier peer review F&Os. The original findings of the newly peer-reviewed elements are then sunset/eliminated and replaced by any new findings resulting from the new peer review. The NRC staff also notes that gap assessments need to be performed if the latest peer review was not against the latest endorsed PRA Standard and associated revision to RG 1.200 (i.e., Revision 2). In Enclosure B to the application dated March 25, 2014, the licensee explained that both the LERF and internal flooding portions of the model were peer reviewed against the currently endorsed PRA Standard. In response to RAI 3, provided in the licensee's letter dated August 24, 2015, the results of the gap analysis to the currently endorsed PRA Standard were provided for the remaining portions of the PNPP PRA. The licensee explained that no gaps were identified as a result of this assessment. Therefore, the NRC staff concluded that the use of the F&Os from the 2008 gap analysis, with the additional gap analysis to the current PRA Standard, and the 2011 and 2012 focused-scope peer reviews was acceptable, and the F&Os from the 1997 PSA Peer Review Certification were not relevant to the application. The NRC staff reviewed (1) the summary of the peer review finding and (2) the licensee's resolution to the finding, for the F&Os listed in the responses to RAI 1, provided in the licensee's letter dated October 7, 2014, to determine whether any gaps in the PRA model were identified that could impact the application. The NRC staff assessed these peer review F&Os to ensure any deficiencies in meeting Capability Category II can be addressed for the SFCP per the NRG-approved NEI 04-10, Revision 1 methodology. The NRC staff concluded that the F&O dispositions were acceptable for this application, but noted several PRA revisions which could constitute "PRA upgrades" as defined in the PRA Standard. The PRA Standard defines upgrades as, "incorporation into a PRA model of a new methodology or significant changes in scope or capability that impact the significant accident sequences or the significant accident progression sequences." A PRA revision that constitutes a PRA upgrade requires a peer review, in accordance with the endorsed PRA Standard. The response to RAI 2, provided in the licensee's letter dated August 24, 2015, reviewed the disposition of model changes and discussed the PRA Standard Supporting Requirements that were evaluated as part of the focused-scope peer reviews, which would have identified gaps in the underlying logic model (i.e., the Internal Events PRA). As part of this review, the licensee determined that the change in offsite power recovery modeling was considered to be a PRA upgrade. The licensee stated that a focused-scope peer review was performed in July 2015 for the Supporting Requirements related to offsite power recovery: DA-A 1, DA-C 1, DA-C 16, AS-87, QU-A 1, QUA2, QU-A5, and QU-F2. In the RAI 2 Response Attachment, included in the licensee's letter dated August 24, 2015, the licensee stated: The offsite power recovery focused scope peer review did not result in any findings, but did identify a number of suggestions. Those suggestions were items to correct or enhance the documentation, and are not expected to have any impact on the results of the offsite power recovery analysis and implementation. The NRC staff reviewed the F&O suggestions and concluded that the recommendations for enhanced documentation would not impact this application. Based on the licensee's assessments using the currently applicable PRA standard and revision of RG 1.200, the NRC staff concludes that the level of PRA quality, combined with the evaluation and disposition of gaps, is sufficient to support the evaluation of changes proposed to surveillance frequencies within the SFCP, and is consistent with Regulatory Position 2.3.1 of RG 1.177, Revision 1. 3.1.4.2 Scope of the PRA The changes to the Administrative Controls section of the TSs will require the licensee to evaluate each proposed change to a relocated surveillance frequency using NEI 04-10, Revision 1, to determine its potential impact on risk (i.e., 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 uses bounding analyses, or other conservative quantitative evaluations. A qualitative screening analysis may be used when the surveillance frequency impact on plant risk is shown to be negligible or zero. The licensee has an at-power internal events and internal flooding PRA model. In accordance with NEI 04-10, Revision 1, the licensee will use these models to perform quantitative evaluations to support the development of changes to surveillance frequencies in the SFCP. This is acceptable because the NRC-approved methodology in NEI 04-10, Revision 1, allows for more refined analysis to be performed to support changes to surveillance frequencies in the SFCP. In Enclosure B to its application dated March 25, 2014, the licensee stated that the PNPP seismic PRA has not been completed. The licensee stated that until the seismic PRA is implemented, the results of the seismic margin assessment performed for the Individual Plant Examination of External Events (IPEEE) must be qualitatively evaluated for its impact on STI extensions. The licensee also stated that the PNPP PRA does not include a fire model and the results of the fire risk assessment performed for the IPEEE must be qualitatively assessed for its impact on STI extensions. The licensee also stated that its IPEEE concluded that the risk of other external events, such as high winds, floods, aircraft accidents, hazardous materials, and turbine missiles, determined that there are no significant events of concern. In accordance with NEI 04-1 O, Revision 1, the licensee can perform qualitative or quantitative analyses to evaluate the impact of external events on surveillance frequency changes. In Enclosure B to its application dated March 25, 2014, the licensee explained that PNPP does not currently have a low power or shutdown PAA model. However, the licensee explained that the PNPP SFCP will qualitatively assess shutdown events using the principles contained in NUMARC 91-06, "Guidelines for Industry Actions to Address Shutdown Management," (ADAMS Accession No. ML14365A203), consistent with NEI 04-10, Revision 1. Based on the above, the NRG staff concludes that through the application of NRG-approved NEI 04-10, Revision 1, the licensee's evaluation methodology is sufficient to ensure that the scope of the risk contribution of each surveillance frequency change is properly identified for evaluation and is consistent with Regulatory Position 2.3.2 of AG 1.177, Revision 1. 3.1.4.3 PAA Modeling The licensee's methodology includes the determination of whether the SSCs affected by a proposed change to a surveillance frequency are modeled in the PAA. Where the SSC is directly or implicitly modeled, a quantitative evaluation of the risk impact may be carried out. The methodology adjusts the failure probability of the impacted SSCs, including any impacted CCF modes, based on the proposed change to the surveillance frequency. Where the SSC is not modeled in the PAA, 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 PAA technical adequacy consistent with guidance contained in AG 1.200, and by sensitivity studies identified in NEI 04-10, Revision 1. Based on the above, the NRG staff concludes that through the application of NRG-approved NEI 04-10, Revision 1, the PNPP PAA modeling is sufficient to ensure an acceptable evaluation of risk for the proposed changes in surveillance frequency, and is consistent with Regulatory Position 2.3.3 of AG 1.177, Revision 1. 3.1.4.4 Assumptions for Time Related Failure Contributions The failure probabilities of SSCs modeled in PRAs may include a standby time-related contribution and a cyclic demand-related contribution. In Enclosure B to its application dated March 25, 2014, the licensee explained that the standby time-related contribution evaluation will be performed in accordance with NEI 04-10, Revision 1. NEI 04-10, Revision 1, criteria adjust the time-related failure contribution of SSCs affected by the proposed change to a surveillance frequency. This is consistent with AG 1.177, Revision 1, Section 2.3.3, which permits separation of the failure rate contributions into demand and standby for evaluation of SRs. If the available data do not support distinguishing between the time-related failures and demand failures, then the change to surveillance frequency is conservatively assumed to impact the total failure probability of the SSC, including both standby and demand contributions. The SSC failure rate (per unit time) is assumed to be unaffected by the change in test frequency, such that the failure probability is assumed to increase linearly with time, and will be confirmed by the required monitoring and feedback implemented after the change in surveillance frequency is implemented. The NEI 04-10 process requires consideration of qualitative sources of information with regards to potential impacts of test frequency on SSC performance, including industry and plant-specific operating experience, vendor recommendations, industry standards, and code-specified test intervals. Thus, the process is not reliant upon risk analyses as the sole basis for the proposed changes. The potential benefits of a reduced surveillance frequency, including reduced downtime and reduced potential for restoration errors, test-caused transients, and test-caused wear of equipment, are identified qualitatively, but are not quantitatively assessed. NEI 04-10, Revision 1, requires performance monitoring of SSCs whose surveillance frequencies have been revised as part of a feedback process to assure that the change in test frequency has not resulted in degradation of equipment performance and operational safety. The monitoring and feedback includes consideration of Maintenance Rule monitoring of equipment performance. In the event of SSC performance degradation, the surveillance frequency will be reassessed in accordance with the methodology, in addition to any corrective actions which may be required by the Maintenance Rule. Based on the above, the NRC staff concludes that through the application of NRG-approved NEI 04-10, Revision 1, the licensee has employed reasonable assumptions with regard to extensions of STls, and is consistent with Regulatory Position 2.3.4 of RG 1.177, Revision 1. 3.1.4.5 Sensitivity and Uncertainty Analyses By having the TSs require that changes to the frequencies listed in the SFCP be made in accordance with NEI 04-10, Revision 1, the licensee will be required to have sensitivity studies that assess the impact of uncertainties from key assumptions of the PRA, uncertainty in the failure probabilities of the affected SSCs, impact on the frequency of initiating events, and any identified deviations from Capability Category II of the PRA standard. Where the sensitivity analyses identify a potential impact on the proposed change, revised surveillance frequencies are considered, along with any qualitative considerations that may bear on the results of such sensitivity studies. The licensee will also be required to perform monitoring and feedback of SSC performance, once the revised surveillance frequencies are implemented. Based on the above, the NRC staff concludes that through the application of NRG-approved NEI 04-10, Revision 1, the licensee has appropriately considered the possible impact of PRA model uncertainty and sensitivity to key assumptions and model limitations and is consistent with Regulatory Position 2.3.5 of RG 1.177, Revision 1. 3.1.4.6 Acceptance Guidelines In accordance with the TS SFCP, the licensee will be required to quantitatively evaluate the change in total risk (including internal and external events contributions) in terms of CDF and LERF for both the individual risk impact of a proposed change in surveillance frequency and the cumulative impact from all individual changes to surveillance frequencies using NEI 04-10, Revision 1. Each individual change to surveillance frequency must show a risk impact below 1 E-6 per year for change to CDF, and below 1 E-7 per year for change to LERF. These changes to CDF and LERF are consistent with the acceptance criteria of RG 1.17 4, Revision 2, for very small changes in risk. Where the RG 1.17 4, Revision 2, acceptance criteria are not met, the process in NEI 04-10, Revision 1, either considers revised surveillance frequencies that are consistent with RG 1.17 4, Revision 2, or the process terminates without permitting the proposed changes. Where quantitative results are unavailable for comparison with the acceptance guidelines, appropriate qualitative analyses are required to demonstrate that the associated risk impact of a proposed change to surveillance frequency is negligible or zero. Otherwise, bounding quantitative analyses are required that demonstrate the risk impact is at least one order of magnitude lower than the RG 1.17 4, Revision 2, acceptance guidelines for very small changes in risk. In addition to assessing each individual SSC surveillance frequency change, the cumulative impact of all changes must result in a risk impact less than 1 E-5 per year for change to CDF, and less than 1 E-6 per year for change to LERF, and the total CDF and total LERF must be reasonably shown to be less than 1 E-4 per year and 1 E-5 per year, respectively. These values are consistent with the acceptance criteria of RG 1.17 4, Revision 2, as referenced by RG 1.177, Revision 1, for changes to surveillance frequencies. Consistent with the NRC's SE dated September 19, 2007, for NEI 04-10, Revision 1, the TS SFCP will require the licensee to calculate the total change in risk (i.e., the cumulative risk) by comparing a baseline model that uses failure probabilities based on surveillance frequencies prior to being changed per the SFCP to a revised model that uses failure probabilities based on the changed surveillance frequencies. The NRC staff further notes that the licensee includes a provision to exclude the contribution to cumulative risk from individual changes to surveillance frequencies associated with insignificant risk increases (i.e., less than 5E-8 CDF and 5E-9 LERF) once the baseline PRA models are updated to include the effects of the revised surveillance frequencies. The quantitative acceptance guidance of RG 1.174, Revision 2, is supplemented by qualitative information to evaluate the proposed changes to surveillance frequencies, including industry and plant-specific operating experience, vendor recommendations, industry standards, the results of sensitivity studies, and SSC performance data and test history. The final acceptability of the proposed change is based on all of these considerations and not solely on the PRA results. Post implementation performance monitoring and feedback are also required to assure continued reliability of the components. Based on the above, the NRC staff concludes that the licensee's application of NRG-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 of RG 1.177, Revision 1. Therefore, the staff concludes that the proposed methodology satisfies the fourth key safety principle of RG 1.177, Revision 1, by assuring any increase in risk is small consistent with the intent of the Commission's Safety Goal Policy Statement. 3.1.5 The Impact of the Proposed Change Should Be Monitored Using Performance Measurement Strategies The licensee's adoption of TSTF-425, Revision 3, requires application of NEI 04-10, Revision 1, in the SFCP. NEI 04-10, Revision 1, requires performance monitoring of SSCs whose surveillance frequencies have been revised as part of a feedback process to assure that the change in test frequency has not resulted in degradation of equipment performance and operational safety. The monitoring and feedback includes consideration of Maintenance Rule monitoring of equipment performance. In the event of SSC performance degradation, the surveillance frequency will be reassessed in accordance with the methodology, in addition to any corrective actions which may be required by the Maintenance Rule. The performance monitoring and feedback specified in NEI 04-10, Revision 1, is sufficient to reasonably assure acceptable SSC performance and is consistent with Regulatory Position 3.2 of RG 1.177, Revision 1. Thus, the staff concludes that the fifth key safety principle of RG 1.177, Revision 1, is satisfied. 3.2 Addition of Surveillance Frequency Control Program to Administrative Controls The licensee proposed including the SFCP and specific requirements into the PNPP TSs, Section 5.5.15, as follows: Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure that the associated Limiting Conditions for Operation are met. a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program. b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Technical Specifications Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies," Revision 1. c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program. The proposed program is consistent with the model application of TSTF-425 and, therefore, the staff concludes that it is acceptable. 3.3 Deviations from TSTF-425 and Other Changes In Section 2.2 of the application, dated March 25, 2014, the licensee identified deviations from TSTF-425, Revision 3. The staff's evaluation of the deviations is provided in the sections below. 3.3.1 Basis Insert Revision The insert provided in TSTF-425 for the TS Bases states, "The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk, and is controlled under the Surveillance Frequency Control Program." In a letter dated April 14, 2010 (ADAMS Accession No. ML 100990099), the NRC staff agreed that the insert applies to surveillance frequencies that are relocated and subsequently evaluated and changed in accordance with the SFCP, but does not apply to frequencies relocated to the SFCP but not changed. Therefore, the licensee revised the insert for the Bases to, "The Surveillance Frequency is controlled under the Surveillance Frequency Control Program." The licensee stated that this is an administrative deviation from TSTF-425 with no impact on the NRC staff's model SE dated July 6, 2009 (7 4 FR 31996). The NRC staff evaluated the proposed changes and finds that the changes submitted to the TS Bases are consistent with the TS changes. The staff agrees that the deviation is administrative in nature and does not impact the staff's model SE. Therefore, the staff finds these changes to be acceptable. 3.3.2 Technical Specification Section 5.5.15 Insert The TSTF-425 TS Section 5.5.15 insert references NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies." The licensee proposed the following revision to the reference to NEI 04-10 in TS Section 5.5.15: "Risk-Informed Technical Specifications Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies." The licensee stated that this is an administrative deviation from TSTF-425 with no impact on the NRC's model SE dated July 6, 2009 (74 FR 31996). The NRC staff evaluated this deviation and determined that the proposed change is the correct and full title of NEI 04-10, as transmitted to the NRC by NEI by letter April 19, 2007 (ADAMS Accession No. ML071360426). Therefore, the staff finds this administrative change to be acceptable. 3.3.3 Differences Between PNPP TSs and NUREG-1434 The licensee provided a cross reference between NUREG-1434, "Standard Technical Specifications General Electric BWR/6 Plants," SRs included in TSTF-425 versus the PNPP SRs included in the LAR. The licensee categorized the cross-reference into the following basic categories:

NUREG-1434 SRs included in TSTF-425 and corresponding PNPP SRs with identical SR numbers;

NUREG-1434 SRs included in TSTF-425 and corresponding PNPP SRs with differing SR numbers;

NUREG-1434 SRs included in TSTF-425 that are not contained in the PNPP TS; and

PNPP plant-specific SRs that are not contained in NUREG-1434. For the first three categories, the licensee considers the deviations to be administrative deviations from TSTF-425 with no impact on the NRC's model SE dated July 6, 2009 (74 FR 31996). The NRC staff has evaluated these deviations and agrees that they are administrative in nature, and do not impact the NRC's model SE. Therefore, the staff finds these deviations to be acceptable. For the last category, in Section 2.2 of the application dated March 25, 2014, the licensee identified the following PNPP plant-specific TSs and associated SRs that are not contained in NUREG-1434:

3.3.1.3, "Oscillation Power Range Monitor (OPRM) Instrumentation"

3.6.1.8, "Feedwater Leakage Control System (FWLCS)"

3.6.1.10, "Primary Containment -Shutdown"

3.6.1.11, "Containment Vacuum Breakers"

3.6.1.12, "Containment Humidity Control"

3.7.8, "Fuel Handling Building (FHB)"

3.7.9, "FHB Ventilation Exhaust System"

3. 7 .10, "Emergency Closed Cooling Water (ECCW) System" The licensee determined that, with the exception of SR 3.7.9.2, the PNPP plant-specific SRs involve fixed periodic frequencies and do not meet any of the four exclusion criteria of TSTF-425 (delineated in Section 1.0 of this SE). Changes to SR frequencies that do not meet the exclusion criteria would be controlled under the SFCP. The licensee stated that the SFCP provides the necessary administrative controls to require that surveillances related to testing, calibration, and inspection are conducted at a frequency to assure that the necessary quality of the systems and components is maintained, the facility operation will be within safety limits, and that the LCOs will be met. The licensee also stated that the changes to frequencies in the SFCP would be evaluated using the methodology and probabilistic risk guidelines contained in NEI 04-10, Revision 1, as approved by NRC letter dated September 19, 2007. The NEI 04-10, Revision 1 methodology includes qualitative considerations, risk analyses, sensitivity studies, and bounding analyses, as necessary, and recommended monitoring of the performance of SSCs for which frequencies are changed to assure that reduced testing does not adversely impact the SSCs. The NEI 04-10, Revision 1 methodology satisfies the five key safety principles specified in RG 1.177 relative to changes in surveillance frequencies. Therefore, the licensee stated that the proposed relocation of the PNPP-specific surveillance frequencies is consistent with TSTF 425 and with the NRC staff's model SE dated July 6, 2009 (74 FR 31996). The staff has evaluated the proposed deviation for the identified plant-specific TS SRs listed Section 2.2 of the application and has determined that the SR frequencies, with the exception of SR 3.7.9.2, do not meet any of the exclusion criteria in TSTF-425, Revision 3, and that the frequencies are fixed periodic frequencies. Surveillance Requirement 3.7.9.2 is not being relocated to the SFCP by the licensee. Therefore, the staff finds that relocation of these specific TS SR frequencies to the SFCP is acceptable. 3.4 Summary and Conclusions The NRC staff has reviewed the licensee's proposed relocation of specific surveillance frequencies to a licensee-controlled document, and controlling changes to these surveillance frequencies in accordance with a new program, the SFCP, identified in the Administrative Controls of TSs. The NRC staff confirmed that this amendment does not relocate surveillance frequencies that reference other approved programs for the specific interval, are purely driven, are event-driven but have a time component for performing the surveillance on a time basis once the event occurs, or are related to specific conditions. The SFCP and TSs Section 5.0, Subsection 5.5.15 references NEI 04-10, Revision 1, which provides a informed methodology using plant-specific risk insights and performance data to revise surveillance frequencies within the SFCP. This methodology supports relocating surveillance frequencies from TSs to a licensee-controlled document, provided those frequencies are changed in accordance with the NEI 04-10, Revision 1, which is specified in the Administrative Controls section of the TSs. The proposed licensee adoption of TSTF-425, Revision 3, and risk-informed methodology of NRG-approved NEI 04-10, Revision 1, as referenced in the Administrative Controls section of TSs, satisfies the key principles of risk-informed decision making applied to changes to TSs as delineated in RG 1.177 and RG 1.17 4, in that:

The proposed change meets current regulations;

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

The proposed change maintains sufficient safety margins;

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

The impact of the proposed change is monitored with performance measurement strategies. The regulation in 10 CFR 50.36(c) discusses the categories that will be included in TSs. The regulation in 10 CFR 50.36(c)(3) discusses the specific category of Surveillance Requirements and states: "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The NRC staff finds that with the proposed relocation of surveillance frequencies to a licensee-controlled document and administratively controlled in accordance with the TS SFCP, the licensee continues to meet the regulatory requirement of 10 CFR 50.36, and specifically, 10 CFR 50.36(c)(3), Surveillance Requirements.

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or changes the surveillance requirements. 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 that the amendment involves no significant hazards consideration and there has been no public comment on such finding (79 FR 55512). 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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Principal Contributor: D. Gennardo, NRR J. Evans, NRR Date: February 23, 2016

ML15307A349 *by email OFFICE DORL/LPL3-1 /PM DORL/LPL3-1/LA DRA/APLA/BC DSS/SRXB/BC NAME KGreen MHenderson SRosenberg CJackson DATE 01/29/16 01/26/16 10/30/2015 11/13/2015 OFFICE DSS/STSB/BC DE/El CB/BC* DE/EEEB DE/EEEB TMartinez-Navedo NAME RElliott MWaters (non-concur) SSom (non-concur) DATE 11/19/2015 11/22/2015 2/16/2016 2/02/2016 OFFICE DE/EEEB* DE/EEEB DE/EE EB DE/EEEB/BC NAME GMatharu (non-concur) SRay (non-concur) RMathew (non-concur) JZimmerman (non-concur) DATE 2/03/2016 2/03/2016 2/03/2016 2/03/2016 OFFICE OGC DORL/DD DORL/LPL3-1 /BC DORL/LPL3-1 /PM STurk (NLO w/noted NAME changes) GWilson DWrona KGreen DATE 2/10/2016 2/23/2016 2/22/2016 2/23/2016

v t e Letter Sequence Approval
CAC:MF3720, (Approved, Closed)
Initiation Acceptance... Administration Questions Answers Results Approval Other:
MONTHYEAR2016-02-23 [Table View]

ML15307A349