Text

Clinton Power Station, Unit No. 1 - Issuance of Amendment No. 192 Technical Specification Change for the Relocation of Specific Surveillance Frequency Requirements on TSTF-425
	ML102380477
Person / Time
Site:	Clinton
Issue date:	02/15/2011
From:	DiFrancesco N J; Plant Licensing Branch III
To:	Pacilio M J; Exelon Generation Co
	DiFrancesco N, NRR/DORL/LPL3-2, 415-1115
References
	TAC ME3332
	Download: ML102380477 (160)
	v • d • e

UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555*0001 February 15, 2011 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 CLINTON POWER STATION, UNIT NO.1-ISSUANCE OF AMENDMENT NO. 192 RE: TECHNICAL SPECIFICATION CHANGE FOR THE RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS BASED ON TECHNICAL SPECIFICATION TASK FORCE (TSTF)-425 (TAC NO. ME3332) Dear Mr.

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the Amendment No. 192 to Facility Operating License No. NPF-62 for the Clinton Power (CPS), Unit No.1. The amendment is in response to your application dated February 15, (Agencywide Documents Access and Management System (ADAMS) Accession ML 100470787), as supplemented by letter dated May 21,2010 (ADAMS Accession ML The amendment relocates selected Surveillance Requirement frequencies from the technical specifications to a licensee-controlled program. This change is based on NRC-approved industry TSTF change TSTF-425, "Relocate Surveillance Frequencies Licensee Control-Risk Informed Technical Specification Task Force Initiative 5b," Revision (ADAMS Accession Package No.

A copy of the Safety Evaluation is also enclosed.

The Notice of Issuance will be included in Commission's next biweekly Federal Register <C . Nicholas J. DiFrancesco, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-461

Enclosures:

1. Amendment No. 192 to NPF-62 2. Safety Evaluation cc w/encls: Distribution via Listserv UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, DOCKET NO. CLINTON POWER STATION. UNIT AMENDMENT TO FACILITY OPERATING Amendment No.192 License No. NPF-62 The U.S. Nuclear Regulatory Commission (the Commission) has found that: The application for amendment by Exelon Generation Company, LLC (the licensee), dated February 15, 2010, as supplemented by letter dated May 21, 2010, 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; The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; 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; 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 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. 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-62 is hereby amended to read as follows:

-Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 192, are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. This license amendment is effective as of its date of issuance and shall be implemented within 120 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION IRA by E. Brown forI Robert D. Carlson, Chief Plant licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating license Date of Issuance:

February 15, 2011 ATTACHMENT TO LICENSE AMENDMENT NO. FACILITY OPERATING LICENSE NO. DOCKET NO. 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 License NPF-62 Page 3 3.1-9 3.1-10 3.1-12 3.1-17 3.1-19 3.1-20 3.1-21 3.1-22 3.1-25 3.2-1 3.2-2 3.2-3 3.3-3 3.3-4 3.3-5 3.3-6 3.3-12 3.3-13 3.3-14b 3.3-16 3.3-17 3.3-21 3.3-23 3.3-24 3.3-26 3.3-27 3.3-29 3.3-38 3.3-46 License NPF-62 Page 3 3.1-9 3.1-10 3.1-12 3.1-17 3.1-19 3.1-20 3.1-21 3.1-22 3.1-25 3.2-1 3.2-2 3.2-3 3.3-3 3.3-4 3.3-5 3.3-6 3.3-12 3.3-13 3.3-14b 3.3-16 3.3-17 3.3-21 3.3-23 3.3-24 3.3-26 3.3-27 3.3-29 3.3-38 3.3-46 Remove Insert TSs TSs 3.3-54 3.3-54 3.3-63 3.3-63 3.3-67 3.3-67 3.3-71 3.3-71 3.3-74 3.3-74 3.3-76 3.3-76 3.3-79 3.3-79 3.3-82 3.3-82 3.4-3 3.4-3 3.4-6 3.4-6 3.4-9 3.4-9 3.4-11 3.4-11 3.4-13 3.4-13 3.4-19 3.4-19 3.4-21 3.4-21 3.4-24 3.4-24 3.4-26 3.4-26 3.4-28 3.4-28 3.4-30 3.4-30 3.4-33 3.4-33 3.5-4 3.5-4 3.5-5 3.5-5 3.5-8 3.5-8 3.5-9 3.5-9 3.5-11 3.5-11 3.5-12 3.5-12 3.6-8 3.6-8 3.6-15 3.6-15 3.6-16 3.6-16 3.6-18 3.6-18 3.6-19a 3.6-19a 3.6-20 3.6-20 3.6-21 3.6-21 3.6-23 3.6-23 3.6-25 3.6-25 3.6-27a 3.6-27a 3.6-30 3.6-30 3.6-31 3.6-31 3.6-33 3.6-33 3.6-35 3.6-35 3.6-39 3.6-39 3.6-40 3.6-40 Remove Insert TSs TSs 3.6-42 3.6-42 3.6-44 3.6-44 3.6-45 3.6-45 3.6-50 3.6-50 3.6-53 3.6-53 3.6-54a 3.6-54a 3.6-54b 3.6-54b 3.6-60 3.6-60 3.6-64 3.6-64 3.6-65 3.6-65 3.6-66 3.6-66 3.6-67 3.6-67 3.6-70 3.6-70 3.7-2 3.7-2 3.7-3 3.7-3 3.7-6 3.7-6 3.7-7 3.7-7 3.7-10 3.7-10 3.7-12 3.7-12 3.7-13 3.7-13 3.7-14 3.7-14 3.8-4 3.8-4 3.8-5 3.8-5 3.8-6 3.8-6 3.8-6a 3.8-6a 3.8-7 3.8-7 3.8-8 3.8-8 3.8-9 3.8-9 3.8-10 3.8-10 3.8-11 3.8-11 3.8-12 3.8-12 3.8-13 3.8-13 3.8-14 3.8-14 3.8-15 3.8-15 3.8-22 3.8-22 3.8-23 3.8-23 3.8-25 3.8-25 3.8-32 3.8-32 3.8-33 3.8-33 3.8-35 3.8-35 3.8-38 3.8-38 3.8-41 3.8-41 Remove Insert TSs TSs 3.8-43 3.8-43 3.8-45 3.8-45 3.9-1 3.9-1 3.9-2 3.9-2 3.9-3 3.9-3 3.9-7 3.9-7 3.9-8 3.9-8 3.9-9 3.9-9 3.9-12 3.9-12 3.9-15 3.9-15 3.10-5 3.10-5 3.10-8 3.10-8 3.10-11 3.10-11 3.10-12 3.10-12 3.10-14 3.10-14 3.10-15 3.10-15 3.10-17 3.10-17 3.10-18 3.10-18 3.10-22 3.10-22 3.10-23 3.10-23 3.10-24 3.10-24 3.10-26 3.10-26 5.0-16c 5.0-16c

-Exelon Generation Company, pursuant to the Act and to 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility. 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 or hereafter in effect; and is subject to the additional conditions specified or incorporated below: (1 Maximum Power Level Exelon Generation Company is authorized to operate the facility at reactor core power levels not in excess of 3473 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein. Technical Soeci'fications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 192, are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical SpeCifications and the Environmental Protection Plan. Amendment No.1 92 Control Rod OPERABILITY 3.1. 3 ACTIONS (Continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and associated Completion Time of Condition A, C, or D not met. E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR Nine or more control rods inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1. 3.1 Determine the position of each control rod. In accordance with the Surveillance Frequency Control Program SR 3.1. 3.2 Deleted (continued)

CLINTON 3.1-9 Amendment No. 192 Control Rod OPERABILITY 3.1. 3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1. 3.3 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 one notch. SR 3.1. 3.4 Verify each control rod scram time from fully withdrawn to notch 13 is :r;; 7 seconds. SR 3.1. 3.5 Verify each control rod does not go to the withdrawn overt ravel In accordance with the Surveillance Frequency Control Program In accordance with SR 3.1. 4 .1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 Each time the control rod is withdrawn to "full out" position AND Prior to declaring control rod OPERABLE after work on control rod or CRD System that could affect coupling CLINTON 3.1-10 Amendment No. 192 3.1.4 Control Rod Scram Times SURVEILLANCE REQUIREMENTS During single control rod scram time Surveillances, the control rod drive (CRD) pumps shall be isolated from the associated scram accumulator.

SR 3.1.4.1 SURVEILLANCE Verify each control rod scram time is within the limits of Table 3.1.4-1 with reactor steam dome pressure 950 psig. FREQUENCY Prior to 40% RTP after fuel movement within the reactor pressure vessel SR SR 3.1.4.2 3.1.4.3 Verify, for a representative tested control rod scram time limits of Table 3.1.4-1 with dome pressure 950 psig. , each is within the reactor steam Verify each affected control rod scram time is within the limits of Table 3.1.4-1 with any reactor steam dome pressure.

Prior to exceeding 40% RTP after each reactor shutdown 120 days 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 (continued)

CLINTON 3.1-12 Amendment No. 192 Control Rod Scram Accumulators 3.1. 5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more control rod scram accumulators inoperable with reactor steam dome pressure < 600 psig. C.l AND C.2 Verify all control rods associated with accumulators are fully inserted.

Declare the associated control rod Immediately upon discovery of charging water header pressure < 1520 psig 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months D. Required Action and associated Completion Time of Required Action 8.1 or C.l not met. D.1 Not applicable if all control rod scram accumulators are associated with fully inserted control rods. Place the reactor mode switch in the shutdown position.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE each control rod scram accumulator pressure is 1520 psig. SR 3.1. 5.1 FREQUENCY In accordance with the Surveillance Frequency Control Program CLINTON 3.1-17 Amendment 192 Control Rod Pattern 3.1. 6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Nine or more OPERABLE control rods not in compliance with BPWS. B.l AND B.2 Affected control rods may be bypassed in RACS in accordance with SR 3.3.2.1.9 for insertion only. Suspend withdrawal of control rods. Place the reactor mode switch in the shutdown tion. Immediately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.1.6.1 Verify all OPERABLE control rods comply with BPWS. FREQUENCY In accordance with the Surveillance Frequency Control Program CLINTON 3.1-19 Amendment No. 192 SLC System 3.1. 7 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC) System LCO 3.1.7 Two SLC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SLC subsystem inoperable.

A.1 Restore SLC subsystem to OPERABLE status. 7 days B. Two SLC subsystems inoperable.

B.l Restore one SLC subsystem to OPERABLE status. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months C. Required Action and associated Completion Time not met. C.1 AND C.2 Be in MODE 3. Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE available volume of sodium pentaborate solution is within the limits of Figure 3.1.7-1. SR 3.1.7.1 FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.1-20 Amendment No. 192 SLC System 3.1. 7 SURVEILLANCE REQUIREMENTS (continued)

SR SR SR SR 3.1.7.2 3.1.7.3 3.1.7.4 3.1.7.5 SURVEILLANCE Verify temperature of sodium pentaborate 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. FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program 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 SR 3.1.7.6 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.

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 In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.1-21 Amendment No. 192 SLC System 3.1. 7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.7.7 41.2 1220 each pump develops a flow rate gpm at a discharge pressure In accordance with the Inservice Testing Program SR 3.1.7.8 pump flow through one SLC subsystem from into reactor pressure vessel. In accordance with the Frequency Control Program SR 3.1.7.9 Verify all piping between storage pump suction is unblocked.

tank and 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 CLINTON 3.1-22 Amendment No. 192 SDV Vent and Drain Valves 3.1. 8 SURVEILLANCE REQUIREMENTS SR 3.1.8.1 SURVEILLANCE Not required to be met on vent and drain valves closed during performance of SR 3.1.8.2. Veri each SDV vent and drain valve is open. FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.1.8.2 Cycle each SDV vent and drain valve to fully closed and fully open position.

the In accordance with the Surveillance Frequency Control Program SR 3.1.8.3 Verify each SDV vent and drain valve: a. b. Closes in S 30 seconds after receipt of an actual or simulated scram signal; and when the actual or simulated scram signal is reset. In accordance with the Surveillance Frequency Control Program CLINTON 3.1-25 Amendment No. 192 3.2.1 APLHGR 3.2 POWER DISTRIBUTION LIMITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) 3.2.1 All APLHGRs shall be less than or equal to the limits specified in the COLR. APPLICABILITY:

THERMAL POWER 21.6% RTP. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any APLHGR not within limi ts. A.1 Restore APLHGR(s) to within limits. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 < 21.6% RTP. Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.2.1.1 Veri all APLHGRs are less than or equal to the limits specified in the COLR. FREQUENCY Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 21. 6% RTP AND In accordance with the Surveillance Frequency Control Program 3.2-1 Amendment No. 192 MCPR 3.2.2 3.2 POWER DISTRIBUTION 3.2.2 MINIMUM CRITICAL LIMITS POWER RATIO (MCPR) LCO 3.2.2 All MCPRs shall be greater than or equal operating limits specified in the COLR. to the MCPR APPLICABILITY:

THERMAL POWER 21.6% RTP. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any MCPR not within limits. A.l Restore MCPR(s) to within limits. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 < 21. 6% RTP. Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.2.2.1 Verify all MCPRs are greater than or equal to the limits specified in the COLR. FREQUENCY Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 21. 6% RTP AND In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.2-2 Amendment No. 192 LHGR 3.2.3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 LINEAR HEAT GENERATION RATE (LHGR) LCO 3.2.3 All LHGRs shall be less specified in the COLR. than or equal to the limits APPLICABILITY:

THERMAL POWER 2 21.6% RTP. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any LHGR not within limi ts. A.l Restore LHGR(s) to within limits. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 < 21.6% RTP. Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.2.3.1 Veri all LHGRs are less than or equal to the limits specified in the COLR. FREQUENCY Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after ;;:: 21. 6% RTP AND In accordance with the Surveillance Frequency Control Program CLINTON 3.2-3 Amendment No. 192 Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS Refer to Table 3.3.1.1-1 to determine which SRs apply for each RPS Function. 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.

SR SR 3.3.1.1.1 3.3.1.1.2 SURVEILLANCE Perform CHANNEL CHECK.

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER 21.6% RTP. Verify the absolute difference between the average power range monitor (APRM) channels and the calculated power 2% RTP while operating at 21.6% RTP. FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program SR SR 3.3.1.1.3 3.3.1. 1. 4 Adjust the channel to conform to a calibrated flow signal.

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 In accordance with the Surveillance Frequency Control Program (continued) 3.3-3 Amendment No. 192 RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.5 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3 . 3 . 1. 1. 6 Verify the source range monitor (SRM) and intermediate range monitor (IRM) channels overlap. Prior to withdrawing SRMs from the fully inserted tion SR 3.3.1.1.7 Only required to be met during entry into MODE 2 from MODE 1. Veri the IRM and APRM channels overlap. In accordance with the Surveillance Frequency Control Program 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 analog module. In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.3-4 Amendment No. 192 RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.11

1. Neutron detectors 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.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.12 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3. 3 . 1. 1. 13

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.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.14 Verify the APRM Flow Biased Simulated Thermal Power-High time constant is within the limits specified in the COLR. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.15 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.3-5 Amendment No. 192 RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.16 Veri Turbine Stop Valve Closure and Turbine Control Valve Fast Closure Trip Oil Pressure-Low Functions are not bypassed when THERMAL POWER is > 33.3% RTP. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.17

1. Neutron detectors are excluded.

2. For Functions 3, 4, and 5 in Table 3.3.1.1-1, the channel sensors are excluded.

3. The STAGGERED TEST BASIS Frequency for each Function shall be determined on a per channel basis. Verify the RPS RESPONSE TIME is within limits. In accordance with the Surveillance Frequency Control Program CLINTON 3.3-6 Amendment No. 192 Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS Refer to Table 3.3.1.2-1 to determine which SRs apply for each applicable MODE or other specified conditions.

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

1. Only required to be met during CORE ALTERATIONS.

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

Veri an OPERABLE SRM detector is located In accordance in: with the Surveillance The fueled region; Frequency Control The core quadrant where CORE Program ALTERATIONS are being performed when the associated SRM is included in the fueled region; and A core quadrant adjacent to where CORE ALTERATIONS are. being performed, when the associated SRM is included in the fueled region. SR 3 . 3 . 1. 2 . 3 Perform CHANNEL In accordance with the Surveillance Frequency Control Program (continued) 3.3-12 Amendment No. 192 SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3 . 3 . 1. 2 .4 SURVEILLANCE 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 3.0 cps. FREQUENCY In accordance with the Surveillance Frequency Control Program SR SR 3.3.1.2.5 3.3.1.2.6 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.

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program CLINTON 3.3-13 Amendment No. 192 OPRM Instrumentation 3.3.1.3 SURVEILLANCE REQUIREMENTS 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.

SURVEILLANCE FREQUENCY SR 3.3.1.3.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.3.2 Calibrate the local power range monitors.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.3.3 Neutron detectors are excluded.

Perform CHANNEL CALIBRATION.

The for the trip function shall be as in the COLR. setpoints specified In accordance with the Surveillance Frequency Control Program SR 3.3.1.3.4 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.3.5 Verify OPRM is not bypassed when THERMAL POWER is 25% RTP and recirculation drive flow is the value corresponding to 60% of rated core flow. In accordance with the Surveillance Frequency Control Program SR 3.3.1.3.6 Neutron detectors are excluded.

Verify the limits. RPS RESPONSE TIME is within In accordance with the Surveillance Frequency Control Program CLINTON 3.3-l4b Amendment No. 192 Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS Refer to Table 3.3.2.1-1 to determine which SRs apply for each Control Rod Block Function. 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.

SURVEILLANCE FREQUENCY SR 3.3.2.1.1 Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after THERMAL POWER is greater than the RWL high power setpoint (HPSP) Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program 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 > 29.2% RTP and less than or equal to the RWL HPSP. Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.3 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. In accordance with the Surveillance Frequency Control Program (continued) 3.3-16 Amendment No. 192 Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.1.4 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 s 16.7% RTP in MODE 1. Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.5 Calibrate the low power setpoint analog trip modules. The Allowable Value shall be > 16.7% RTP and s 29.2% RTP. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.6 Verify the RWL high power Function is not bypassed when THERMAL POWER is > 70% RTP. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.7 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3 . 3 . 2 . 1. 8 Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after reactor mode switch is in the shutdown position.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.9 the bypassing and movement of control rods required to be bypassed in Rod Action Control System (RACS) is in conformance with applicable analyses by a second licensed operator or other qualified member of the technical staff. Prior to and during the movement of control rods bypassed in RACS CLINTON 3.3-17 Amendment No. 192 PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.1.1 Applicable for each Function in Table 3.3.3.1-1.

Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3. 3 . 3 . 1. 2 Deleted SR 3.3.3.1.3 Applicable for each Function in Table 3.3.3.1-1.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program CLINTON 3.3-21 Amendment No. 192 Remote Shutdown System 3.3.3.2 3.3 INSTRUMENT ATION 3.3.3.2 Remote Shutd own Sy stem 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 COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable.

Function to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR Perform CHANNEL CHECK for each required instrumentation channel that is normally energized.

FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) 3.3-23 Amendment No. 192 Remote Shutdown System 3.3.3.2 SURVEILLANCE REQUIREMENTS (continued)

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

In accordance with the Surveillance Frequency Control Program SR 3.3.3.2.3 Perform CHANNEL CALIBRATION for each required instrumentation channel. In accordance with the Surveillance Frequency Control Program CLINTON 3.3-24 Amendment No. 192 EOC-RPT Instrumentation 3.3.4.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more Functions with two channels inoperable.

B.1 Place one channel in affected Function in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months C. One or more Functions with three or more channels inoperable.

C.1 Restore two channels in affected Function to OPERABLE status. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months O. Required Action and associated Completion Time not met. 0.1 Remove the associated recirculation pump fast speed breaker from service. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OR -0.2 Reduce THERMAL POWER to < 33.3% RTP. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 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 EOC-RPT trip capabil SURVEILLANCE FREQUENCY SR 3.3.4.1.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.3-26 Amendment No. 192 EOC-RPT Instrumentation 3.3.4.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.4.1.2 SURVEILLANCE Perform CHANNEL CALIBRATION.

The Allowable Values shall be: a. b. TSV Closure: s 7% closed; and TCV Fast Closure, Pressure-Low: 465 Oil g. FREQUENCY In accordance with the Surveillance Frequency Control Program SR SR SR 3.3.4.1.3 3.3.4.1.4 3.3.4.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST, including breaker actuation.

Verify TSV Closure and TCV Fast Closure, Oil Pressure-Low Functions are not bypassed when THERMAL POWER is 33.3% RTP. Verify the EOC-RPT SYSTEM RESPONSE TIME is within limits. In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program CLINTON 3.3-27 Amendment No. 192 ATWS-RPT Instrumentation 3.3.4.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action associated Completion Time met. and not C.1 OR Remove the associated recirculation pump from service. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months C.2 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS SR SR SR SR 3.3.4.2.1 3.3.4.2.2 3.3.4.2.3 3.3.4.2.4 SURVEILLANCE Perform CHANNEL CHECK. Perform CHANNEL FUNCTIONAL TEST. Calibrate the trip units. Perform CHANNEL CALIBRATION.

The Allowable Values shall be: a. Reactor Vessel Water Level-Low Low, Level 2: -50.0 inches; and b. Reactor Steam Dome Pressure-High:

1143 psig. 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 SR 3.3.4.2.5 Perform LOGIC SYSTEM FUNCTIONAL including breaker actuation.

TEST, In accordance with the Surveillance Frequency Control Program CLINTON 3.3-29 Amendment Nc. 192 ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS

NOTES-------------Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function. 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 3.c, 3.f, 3.g, and 3.h, provided the associated Function or the redundant Function maintains ECCS initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.3 Calibrate the analog module. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.4 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.6 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program 3.3-38 Amendment No. 192 RCIC System Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

NOTES-------------Refer to Table 3.3.5.2-1 to determine which SRs apply for each RCIC Function. When a channel is placed in an inoperable status sol 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 2 and 5; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions I, 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 Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.3 Calibrate the analog module. 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 3.3-46 Amendment No. 192 Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS Refer to Table 3.3.6.1-1 to determine which SRs apply for each Primary Containment and Drywell Isolation Function. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3. 3 . 6. 1. 2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3 . 3 . 6. 1. 3 Calibrate the analog trip module. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.4 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.5 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3 . 3 . 6 .

1. 6 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued) 3.3-54 Amendment No. 192 Secondary Containment Isolation Instrumentation 3.3.6.2 SURVEILLANCE REQUIREMENTS Refer to Table 3.3.6.2-1 to determine which SRs apply for each Secondary Containment Isolation Function. 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 secondary containment isolation capability.

SURVEILLANCE FREQUENCY SR SR SR SR SR SR 3.3.6.2.1 3.3.6.2.2 3.3.6.2.3 3.3.6.2.4 3.3.6.2.5 3.3.6.2.6 Perform CHANNEL CHECK. Perform CHANNEL FUNCTIONAL TEST. Calibrate the analog module. Perform CHANNEL CALIBRATION.

Perform LOGIC SYSTEM FUNCTIONAL TEST. Perform CHANNEL CALIBRATION.

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 In accordance with the Surveillance Frequency Control Program 3.3-63 Amendment No. 192 Containment System Instrumentation 3.3.6.3 SURVEILLANCE REQUIREMENTS Refer to Table 3.3.6.3-1 to determine which SRs apply for each RHR Containment Spray System Function. 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 lity. SURVEILLANCE FREQUENCY SR SR SR SR SR SR 3.3.6.3.1 3.3.6.3.2 3.3.6.3.3 3.3.6.3.4 3.3.6.3.5 3.3.6.3.6 Perform CHANNEL CHECK. Perform CHANNEL FUNCTIONAL TEST. Calibrate the analog module. Perform CHANNEL CALIBRATION.

Perform LOGIC SYSTEM FUNCTIONAL TEST. Perform CHANNEL CALIBRATION.

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 In accordance with the Surveillance Frequency Control Program 3.3-67 Amendment No. 192 SPMU System Instrumentation 3.3.6.4 SURVEILLANCE REQUIREMENTS Refer to Table 3.3.6.4-1 to determine which SRs apply for each SPMU Function. 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 3.3.6.4.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.6.4.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.4.3 Calibrate the analog module. In accordance with the Surveillance Frequency Control Program SR 3.3.6.4.4 Calibrate the analog comparator unit. In accordance with the Surveillance Frequency Control Program SR 3.3.6.4.5 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.4.6 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program (continued) 3.3-71 Amendment No. 192 Relief and LLS Instrumentation 3.3.6.5 3.3 INSTRUMENTATION 3.3.6.5 Relief and Low-Low Set (LLS) Instrumentation 3.3.6.5 Two relief and LLS instrumentation systems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. B. OR One trip system inoperable.

Required Action and associated Completion Time of Condition A not met. Two trip systems inoperable.

A.l OR -A.2 B.l B.2 Restore trip system to OPERABLE status. Declare associated relief and LLS valve(s) inoperable.

Be in MODE 3. Be in MODE 4. 7 days 7 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours 3.3-74 Amendment No. 192 Control Room Ventilation System Instrumentation 3.3.7.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met. B.1 Place one Control Room Ventilation subsystem in the high radiation mode of operation.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR B.2 Declare associated Control Room Ventilation subsystem inoperable.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months SURVEILLANCE REQUIREMENTS Refer to Table 3.3.7.1-1 to determine which SRs apply for each Function. 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 Room Ventilation initiation capability.

FREQUENCY SR 3.3.7.1.1 Perform CHANNEL In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.2 Perform CHANNEL FUNCTIONAL In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.3 Perform CHANNEL In accordance with the Surveillance Frequency Control Program 3.3-76 Amendment No. 192 Instrumentation 3.3.8.1 SURVEILLANCE REQUIREMENTS

NOTES------------Refer to Table 3.3.8.1-1 to determine which SRs apply for each LOP Function. 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.

SR 3.3.8.1.1 SURVEILLANCE Deleted FREQUENCY SR SR SR 3.3.8.1.2 3.3.8.1.3 3.3.8.1.4 Perform CHANNEL FUNCTIONAL TEST. Perform CHANNEL CALIBRATION.

Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program 3.3-79 Amendment No. 192 RPS Electric Power Monitoring 3.3.8.2 SURVEILLANCE REQUIREMENTS SR 3.3.8.2.1 SURVEILLANCE Only required to be performed prior to entering MODE 2 or 3 from MODE 4, when in MODE 4 for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Perform CHANNEL FUNCTIONAL TEST. FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.3.8.2.2 Perform CHANNEL CALIBRATION.

Allowable Values shall be: a. Overvoltage Bus A 127.3 V Bus B 126. 7 V b. Undervoltage Bus A 115.0 V Bus B 114.7 V c. Underfrequency (with time seconds) Bus A 57 Hz Bus B 57 Hz The 4.0 In accordance with the Surveillance Frequency Control Program SR 3.3.8.2.3 Perform a system functional test. In accordance with the Surveillance Frequency Control Program CLINTON 3.3-82 Amendment No. 192 3.4.1 Recirculation Loops Operating SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.1.1 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: 10% of rated core flow when ting at < 70% of rated core flow; and S 5% of rated core flow when operating at of rated core flow. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.4-3 Amendment No. 192 FCVs 3.4.2 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.2 Flow Control Valves (FCVs) LCO A recirculation loop FCV shall be OPERABLE in each operating recirculation loop.

MODES 1 and 2. ACTIONS Separate Condition entry is allowed for each FCV. CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required FCVs inoperable.

A.l Lock up the FCV. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months B. Required Action and B.l Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.2.1 Veri each FCV fails "as is" on loss of hydraulic pressure at the hydraulic unit. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.4-6 Amendment No. 192 3.4.3 Pumps SURVEILLANCE REQUIREMENTS SR 3.4.3.1 SURVEILLANCE 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 Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after> 21.6% RTP. Verify at least two of the following criteria (a, b, and c) are satisfied for each operating recirculation loop: Recirculation loop drive flow versus flow control valve position differs by S 10% from established patterns. Recirculation loop drive flow versus total core flow differs by S 10% from established patterns. 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.

FREQUENCY In accordance with the Surveillance Frequency Control Program 3.4 9 Amendment No. 192 3.4.4 S!RVs SURVEILLANCE REQUIREMENTS SURVEILLANCE r FREQUENCY SR 3.4.4.1 Verify the safety function lift setpoints of the required S!RVs are as follows: Number of Setpoint S!RVs jpsig) 7 1165 +/- 34.9 5 1180 +/- 35.4 4 1190 +/- 35.7 Following testing, lift settings shall be within +/- 1%. In accordance with the Inservice Testing Program SR 3.4.4.2 Valve actuation may be excluded.

Verify each required relief function S!RV actuates on an actual or simulated automatic initiation signal. In accordance with the Surveillance Frequency Control Program SR 3.4.4.3 Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test. Verify each required S!RV actuator strokes when manually actuated.

In accordance with the Surveillance Frequency Control Program CLINTON 3.4-11 Amendment No. 192 3.4.5 RCS Operational LEAKAGE ACTIONS (continued)

REQUIRED ACTION CONDITION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 associated Time of Condition A B not 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.2 Be in MODE 4. Pressure LEAKAGE SURVEILLANCE REQUIREMENTS SURVEILLANCE SR Verify RCS unidentified LEAKAGE, total LEAKAGE, and unidentified LEAKAGE increase are within limits. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.4-13 Amendment No. 192 3.4.7 RCS Leakage Detection Instrumentation SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Perform CHANNEL CHECK of required drywe11 atmospheric monitoring system. In accordance with the Surveillance Frequency Control Program SR 3.4.7.2 Perform CHANNEL FUNCTIONAL TEST of required leakage detection instrumentation.

In accordance with the Surveillance Frequency Control Program SR 3.4.7.3 Perform CHANNEL CALIBRATION of required leakage detection instrumentation.

In accordance with the Surveillance Frequency Control Program CLINTON 3.4-19 Amendment No. 192 3.4.8 RCS fic Activity SURVEILLANCE REQUIREMENTS SURVEILLANCE SR Only required to be performed in MODE 1. Verify reactor coolant DOSE EQUIVALENT 1-131 specific activity is :::; O. 2 IlC i I gm. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.4-21 Amendment No. 192 3.4.9 RHR Shutdown Cooling System--Hot Shutdown ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No RHR shutdown cool subsystem in operation.

AND E.l Initiate action to restore one RHR shutdown cooling subsystem or one recirculation pump to operation.

Immediately No recirculation pump in operation.

B.2 Verify reactor coolant circulation by an alternate method. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of no reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter B.3 Monitor reactor coolant temperature and pressure.

Once per hour SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.9.1 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.

FREQUENCY In accordance with the Surveillance Frequency Control program CLINTON 3.4-24 Amendment No. 192 RHR Shutdown Cool System--Cold Shutdown 3.4.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No RHR shutdown cooling subsystem in operation.

No recirculation pump in operation.

B.1 AND B.2 Verify reactor coolant circulating by an alternate method. Monitor reactor coolant temperature and pressure.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of no reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter Once per hour SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.10.1 Verify one RHR shutdown cool subsystem or recirculation pump is operating.

FREQUENCY In accordance with the Surveillance Frequency Control Program CLINTON 3.4-26 Amendment No. 192 RCS PiT Limits 3.4.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

Required Action C.2 shall be completed if this Condition is entered. Requirements of the LCO not met in other than MODES 1, 2, and 3. C.1 C.2 Initiate action to restore parameter(s) to within limits. Determine RCS is acceptable for operation.

Immediately Prior to entering MODE 2 or 3 SURVEILLANCE REQUIREMENTS SR 3.4.11.1 SURVEILLANCE FREQUENCY Only required to be performed during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing. Verify: In accordance with the a. RCS pressure and RCS temperature are Surveillance within the limits of Figures 3.4.11 I, Frequency 3.4.11-2 and 3.4.11-3; and Control Program b. RCS heatup and cooldown rates are as indicated on the figures. (continued)

CLINTON 3.4-28 Amendment No. 192 RCS PIT Limits 3.4.11 SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.11.5 SURVEILLANCE

1. Only required to be performed when tensioning the reactor vessel head bolting studs. 2. Only required to be met with> 10% of the reactor vessel head bolting studs fully tensioned.

Verify reactor vessel flange and head flange temperatures are 70°F. FREQUENCY In accordance with the Surveillance Frequency Control Program SR SR 3.4.11.6 3.4.11.7 Not required to be performed until 30 minutes after RCS temperature s SO°F in MODE 4. Verify reactor vessel flange and head flange temperatures are 70°F.

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 90°F in MODE 4. Veri reactor vessel flange and head flange temperatures are 70°F. In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.4-30 Amendment No. 192 Reactor Steam Dome Pressure 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Reactor Steam Dome LCO 3.4.12 The reactor steam dome pressure shall be s 1045 APPLICABILITY:

MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor steam dome A.1 Restore reactor steam 15 minutes pressure not within dome pressure to limit. within limit. B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.12.1 Verify reactor steam dome pressure is s 1045 psig. FREQUENCY In accordance with the Surveillance Frequency Control Program CLINTON 3.4-33 Amendment No. 192 ECCS 3.S.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.S.1.1 Veri for each ECCS ection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve. In accordance with the Surveillance Frequency Control Program SR 3.S.1.2 Low pressure coolant ection (LPCI) subsystems may be considered OPERABLE during alignment and for heat removal with reactor steam dome pressure less than the residual heat removal cut in permissive pressure in MODE 3, if capable of manually realigned and not otherwise inoperable.

Verify each ECCS injection/spray 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.

In accordance with the Surveillance Frequency Control Program SR 3.5.1. 3 Verify ADS accumulator supply pressure is 2': 140 ps In accordance with the Surveillance Frequency Control Program SR 3. S.1. 4 Verify each ECCS pump the specified flow rate with the specified pump differential pressure.

SYSTEM LPCS LPCI HPCS FLOW RATE 2': 5010 gpm 2': SOSO gpm 2': SOlO gpm PUMP DIFFERENTIAL 2': 290 psid 2': 113 psid 2': 363 psid In accordance with the Inservice Testing (continued)

CLINTON 3.S-4 Amendment No. 192 3.5.1 ECCS -Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1. 5 SR 3.5.1. 6 SR 3.5.1.7 SR 3.5.1. 8 Vessel ection/spray may be excluded.

Verify each ECCS ection/spray subsystem actuates on an actual or simulated automatic initiation signal.

Valve actuation may be excluded.

Verify the ADS actuates on an actual or simulated automatic initiation signal.

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.

ECCS actuation instrumentation is excluded.

Veri the ECCS RESPONSE TIME for each ECCS injection/spray subsystem is within limits. 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 CLINTON 3.5-5 Amendment No. 192 3.5.2 ECCS-Shutdown SURVEILLANCE REQUIREMENTS SR SR 3.5.2.1 3.5.2.2 SURVEILLANCE Verify, for each required low pressure ECCS injection/spray subsystem, the suppression pool water level is 12 ft 8 inches. Verify, for the required High Pressure Core Spray (HPCS) System, the: a. Suppression pool water level is 12 ft 8 inches; or b. RCIC storage tank available water volume is 125,000 gal. FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program SR 3.5.2.3 Veri ,for each required ECCS injection/

spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve. In accordance with the Surveillance Frequency Control Program SR 3.5.2.4 One low pressure coolant injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned and not otherwise inoperable.

Verify each required ECCS ection/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.

In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.5-8 Amendment No. 192 3.5.2 ECCS Shutdown SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5 Verify each required ECCS pump develops the In accordance specified flow rate with the specified pump with the differential pressure.

Inservice Testing Program PUMP DIFFERENTIAL SYSTEM FLOW RATE PRESSURE LPCS 5010 gpm 290 psid LPCI 5050 gpm 113 psid HPCS 5010 gpm 363 psid SR Vessel injection/spray may be excluded.

Veri each required ECCS injection/spray In Accordance subsystem actuates on an actual or with the simulated automatic initiation signal. Surveillance Frequency Control Program 3.5-9 Amendment No. 192 3.5.3 RCIC System SURVEILLANCE REQUIREMENTS SR 3.5.3.1 SURVEILLANCE Verify the RCIC System piping is filled with water from the pump discharge valve the ection valve. to FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.5.3.2 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.

In accordance with the Surveillance Frequency Control Program SR 3.5.3.3 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 1045 psig and 920 psig, the RCIC pump can develop a flow rate 600 gpm against a system head corresponding to reactor pressure.

In accordance with the Surveillance Frequency Control Program SR 3.5.3.4 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 135 psig, the RCIC pump can develop a flow rate 600 gpm against a system head corresponding to reactor pressure.

In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.5-11 Amendment No. 192 3.5.3 RCIC tern SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR Vessel ection may be excluded.

Veri the RCIC System actuates on an actual or simulated automatic initiation signal. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.5-12 Amendment No. 192 Primary Containment Air Locks 3.6.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.2.1

1. Only required to be met during MODES 1, 2, and 3. 2. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. 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 Te Program. In accordance with the Primary Containment Leakage Rate Testing Program SR 3.6.1.2.2 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. In accordance with the Surveillance Frequency Control program CLINTON 3.6-8 Amendment No. 192 PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE 3.6.1.3.1 Only to be met in MODES 1, 2, and 3. Not required to be met when the 36 inch primary containment purge valves are open for pressure control, ALARA or air quality considerations for personnel entry. Also not required to be met during Surveillances or special testing on the purge system that requires the valves to be open. The 36 inch primary containment purge lines shall not be opened with a 12 inch primary containment purge line open nor with a drywell vent and purge supply or exhaust line open. Verify each 36 inch primary containment purge valve is closed. FREQUENCY In accordance with the Surveillance Frequency Control program (continued) 3.6-15 Amendment No. 192 PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3 . 6 . 1. 3 . 2 Valves and blind flanges in high radiation areas may be verified by use of administrative means. 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 is required to be closed during accident conditions is closed. FREQUENCY In accordance with the Surveillance Frequency Control program (continued) 3.6-16 Amendment No. 192 PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3. 6. 1. 3 . 4 Verify the isolation time of each power operated and each automatic PCIV, except MSIVs, is within limits. In accordance with the Inservice Testing Program SR 3.6.1.3.5 Only required to be met in MODES 1, 2, and 3. Perform leakage rate testing for each primary containment purge valve with resilient seals. Once wi thin 92 days after opening the valve In accordance with the Primary Containment Leakage Rate Testing Program SR 3.6.1.3.6 Verify the isolation time of each MSIV is 3 seconds and 5 seconds. In accordance with the Inservice Testing Program SR 3.6.1.3.7 Verify each automatic PCIV actuates to the isolation position on an actual or simulated isolation signal. In accordance with the Surveillance Frequency Control program (continued)

CLINTON 3.6-18 Amendment No. 192 PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3. 11 Only required to be met in MODES I, 2, and 3. Verify that the combined leakage rate for both primary containment feedwater penetrations is 2 gpm when pressurized to :;:: 1.1 P a

In accordance with the Primary Containment Leakage Rate Testing Program. SR 3.6.1.3.12 Verify each instrumentation line excess flow check primary containment isolation valve actuates within the required range. In accordance with the Surveillance Frequency Control program CLINTON 3.6-19a Amendment No. 192 Primary Containment Pressure 3.6.l.4 3.6 SYSTEMS 3.6.1.4 Containment Pressure 3.6.1.4 Primary containment to secondary containment differential pressure shall be -0.25 psid and 0.25 psid. APPLICABILITY:

MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. B. Primary containment to secondary containment differential pressure not within limits. Required Action and associated Completion Time not met. A.l B.1 ANDB.2 Restore primary containment to secondary containment differential pressure to within limits. Be in MODE 3. Be in MODE 4. 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 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR Verify primary containment to secondary containment differential pressure is within limits. FREQUENCY In accordance with the Surveillance Frequency Control program 3.6-20 Amendment No. 192 Containment Air Temperature 3.6.1.S 3.6 SYSTEMS 3.6.1.S Containment Air Temperature 3.6.1.S containment average air temperature shall be :::; 122°F. APPLICABILITY:

MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. B. Primary containment average air temperature not within limit. Required Action and associated Completion Time not met. A.1 B.l ANDB.2 Restore primary containment average air temperature to within limit. Be in MODE 3. Be in 1'10 DE 4. 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 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.1.5.1 Verify primary containment average air temperature is within limit. FREQUENCY In accordance with the Surveillance Frequency Control program 3.6-21 Amendment No. 192 LLS Valves 3.6.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.6.1 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 the test. Verify each LLS valve actuator strokes when manually actuated.

In accordance with the Surveillance Frequency Control Program SR 3 . 6 . 1. 6 . 2 Valve actuation may be excluded.

Verify the LLS System actuates on an actual or simulated automatic initiation signal. In accordance with the Surveillance Frequency Control Program CLINTON 3.6-23 Amendment No. 192 RHR Containment Spray System 3.6.1.7 SURVEILLANCE REQUIREMENTS SR 3.6.1.7.1 SURVEILLANCE 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.

FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.6.1.7.2 Verify each RHR pump develops a flow rate of 3800 gpm on recirculation flow through the associated heat exchanger to the suppression pool. In accordance with the Inservice Testing Program SR 3.6.1.7.3 Veri each RHR containment spray subsystem automatic valve in the flow path actuates to its correct position an actual or simulated automatic initiation signal. on In accordance with the Surveillance Frequency Control Program SR 3.6.1.7.4 Verify each spray nozzle is unobstructed.

Following activities that could result in nozzle blockage CLINTON 3.6-25 Amendment No. 192 FWLCS 3.6.1.9 3.6 CONTAINMENT SYSTEMS 3.6.1.9 Feedwater Leakage Control System (FWLCS) LCO 3.6.1.9 Two FWLCS subsystems shall be OPERABLE.

APPLICABILITY:

MODES I, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One FWLCS subsystem inoperable.

A.1 Restore FWLCS subsystem to OPERABLE status. 30 days B. C. Two FWLCS subsystems inoperable.

Required Action and associated Completion Time not met. B.1 Restore one FWLCS subsystem to OPERABLE status.

LCO 3.0.4.a is not applicable when entering MODE 3.

C.1 Be in MODE 3. 7 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.1. 9 . 1 Perform a system functional test of each FWLCS subsystem.

FREQUENCY In accordance with the Surveillance Frequency Control Program CLINTON 3.6-27a Amendment No. 192 Suppression Average Temperature 3.6.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR Verify suppression pool average temperature is within the icable limits. FREQUENCY In accordance with the Surveillance Frequency Control Program AND 5 minutes when performing test that adds heat to the suppression pool 3.6-30 Amendment No. 192 I Suppression Pool Water Level 3.6.2.2 3.6 CONTAINMENT 3.6.2.2 Suppression Pool Water LCO 3.6.2.2 pool water level shall ;::: 18 ft 11 inches and 19 ft 5 inches, 2: 18 ft 11 inches and 20 ft 1 inches, in MODE 3 with reactor pressure less than 235 psig APPLICABILITY:

MODES I, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Suppression water level not within limits. A.1 Restore suppression water level to within limits. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months B. Required Action and associated ion Time not met. B.1 ANDB.2 Be in MODE 3. Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.2.2.1 Verify suppression water level is within limits. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.6-31 Amendment No. 192 RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Veri 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.

In accordance with the Surveillance Frequency Control Program SR 3.6.2.3.2 Verify each RHR pump develops a flow rate 4550 gpm through the associated heat exchanger to the suppression pool. In accordance with the Inservice Testing Program CLINTON 3.6-33 Amendment No. 192 SPMU System 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR Verify upper containment pool water level In accordance is: with the Surveillance Frequency Control Program el. 825 ft 6 inches; el. 825 ft 10 inches when the inclined fuel transfer pool to steam dryer storage pool gate is not open; and el. 827 ft 1 inch when the reactor cavity to steam dryer storage pool gate is not open. OR Reactor cavity pool level el. 824 ft 7 inches in MODE 3 with reactor pressure less than 235 OR Suppression pool water level 19 ft 9 inches in MODE 3 with reactor pressure less than 235 In accordance temperature is $ 120°F. SR 3.6.2.4.2 upper containment pool water with the Surveillance Frequency Control Program In accordance operated, and automatic valve that is not SR 3.6.2.4.3 Verify each SPMU subsystem manual, power with the locked, sealed, or otherwise secured in Surveillance position is in the correct position.

Frequency Control Program SR Actual makeup to the suppression pool may be excluded.

Verify each subsystem automatic In accordance valve actuates to the correct position on with the an actual or simulated automatic Surveillance initiation signal. Frequency Control Program 3.6-35 Amendment No. 192 Primary Containment and Drywell Hydrogen Igniters 3.6.3.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and associated Completion Time not met. C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SR 3.6.3.2.1 SURVEILLANCE ze each primary containment and drywell hydrogen igniter division and perform current versus voltage measurements to verify required igniters in service. FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.6.3.2.2 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 division and perform current versus voltage measurements to veri required igniters in service. In accordance with the Surveillance Frequency Control Program SR 3.6.3.2.3 Veri each required igniter in inaccessible areas develops sufficient current draw for a 1700°F surface temperature.

In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.6-39 Amendment No. 192 Primary Containment and Drywell Hydrogen 3.6.3.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.6.3.2.4 Verify each required in accessible areas develops a surface temperature of 1700°F. FREQUENCY In accordance with the Surveillance Frequency Control Program CLINTON 3.6-40 Amendment No. 192 Containment 1 Mixing Systems 3.6.3.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.3.1 Operate each Containment!Drywell In accordance Mixing System. with the Surveillance Frequency Control Program each Containment!Drywell In accordance System flow rate is 800 scfm. SR 3.6.3.3.2 with the Surveillance Frequency Control Program CLINTON 3.6-42 Amendment No. 192 Secondary Containment 3.6.4.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Secondary containment inoperable during movement of recently irradiated fuel assemblies in the primary or secondary containment, or during OPDRVs. C .1 LCO 3.0.3 is not applicable.

Suspend movement of recently irradiated fuel assemblies in the primary and secondary containment.

Immediately AND C.2 Initiate action suspend OPDRVs. to Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify secondary containment vacuum is 2 0.25 inch of vacuum water gauge. In accordance with the Surveillance Frequency Control Program SR 3.6.4.1.2 Verify all secondary containment equipment hatches are closed and sealed. In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.6-44 Amendment No. 192 Secondary Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.4.1.3 Verify one door in each access to secondary containment is closed, except during normal entry and exit. In accordance with the Surveillance Frequency Control Program SR 3.6.4.1.4 Verify the secondary containment can be drawn down to 0.25 inch of vacuum water gauge within the time required using one Standby Gas Treatment (SGT) subsystem.

In accordance with the Surveillance Frequency Control Program SR 3.6.4.1.5 Veri the secondary containment can be maintained 0.25 inch of vacuum water gauge for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months using one SGT subsystem at a flow rate 4400 cfm. In accordance with the Surveillance Frequency Control Program CLINTON 3.6-45 Amendment No. 192 scros 3.6.4.2 SURVEILLANCE REQUIREMENTS SR 3.6.4.2.1 SURVEILLANCE

1. Valves, dampers, and blind flanges in high radiation areas may be verified by use of administrative means. 2. Not required to be met for SCIOs that are open under administrative controls.

Verify each secondary containment isolation manual valve, damper, and blind flange that is required to be closed during accident conditions is closed. FREQUENCY In accordance with the Surveillance Frequency Control Program SR SR 3.6.4.2.2 3.6.4.2.3 Verify the isolation time of each power operated and each automatic SCIO is wi thin limi ts . Verify each automatic SCIO actuates to the isolation position on an actual or simulated automatic isolation signal. In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program CLINTON 3.6-50 Amendment No. 192 SGT System 3.6.4.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two SGT subsystems E.l Suspend movement of Immediately inoperable during recently irradiated movement of recently fuel assemblies in the irradiated fuel primary and secondary assemblies in the containment.

primary or secondary containment, or during AND OPDRVs. E.2 Initiate action to Immediately suspend OPDRVs. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for In accordance 10 continuous hours with heaters with the operating.

Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required SGT filter testing in accordance with the Ventilation Filter Testing Program (VFTP). In accordance with the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual or simulated initiation signal. In accordance with the Surveillance Frequency Control Program SR 3.6.4.3.4 Veri each SGT filter cooling bypass damper can be opened and the fan started. In accordance with the Surveillance Frequency Control Program CLINTON 3.6-53 Amendment No. 192 Drywell 3.6.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.6.5.1.2 An inoperable air lock door does not invalidate the previous successful performance of the overall drywell air lock leakage rate test. Perform overall drywell air lock leakage rate test at 3.0 psig. FREQUENCY In accordance with the Surveillance Frequency Control Program (con tinued) CLINTON 3.6-54a Amendment No. 192 1 3.6.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR Veri bypass is less than or equal to the bypass leakage limit. However, during the first unit startup following bypass testing performed in accordance with this SR, the acceptance criterion is s 10% of the drywell bypass leakage limit. FREQUENCY 24 months following 2 consecutive tests with bypass leakage greater than the bypass leakage limit until 2 consecutive tests are less than or to the bypass leakage limit AND 48 months following a test with bypass leakage greater than the bypass leakage limit

1. The next required performance of this SR may be delayed to November 23, 2008. 2. SR 3.0.2 is not applicable for extensions

> 12 months. In accordance with the Surveillance Frequency Control Program (continued) 3.6-54b Amendment No. 192 Air Lock 3.6.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR Only required to be performed upon entry into drywell. Verify only one door in the drywell air lock can be opened at a time. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.6-60 Amendment No. 192 Drywell Isolation Valves 3.6.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.3.1 Veri each 24 inch drywell vent and purge supply isolation valve is sealed closed. In accordance with the Surveillance Frequency Control Program SR 3.6.5.3.2 Not required to be met when the 36 inch and either the 10 inch or 24 inch drywell vent and purge exhaust valves are open for pressure control, ALARA or air quality considerations for personnel entry. Also not required to be met during Surveillances or special testing of the purge system that requires the valves to be open. The drywell vent and purge exhaust valves shall not be opened with a 12 inch or 36 inch primary containment purge system supply or exhaust line open. Verify each 10 inch, 24 inch, and 36 inch drywell vent and purge exhaust isolation valve is closed. In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.6-64 Amendment No. 192 Drywell Isolation Valves 3.6.5.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 3.6.5.3.3 Valves and blind flanges in high radiation areas may be verified by use of administrative means. Not required to be met for drywell isolation valves that are open under administrative controls.

Verify each required drywell isolation Prior to manual valve and blind that is entering MODE 2 required to be closed during accident or 3 from conditions is closed. MODE 4, if not performed in the previous 92 In accordance required power operated and each required SR 3.6.5.3.4 Verify the isolation time of each with the automatic drywell isolation valve is Inservice wi thin limits. Testing Program SR 3.6.5.3.5 Verify each required automatic drywell In accordance isolation valve actuates to the isolation with the position on an actual or simulated Surveillance isolation signal. Frequency Control Program 3.6-65 Amendment No. 192 Drywell Pressure 3.6.5.4 3.6 CONTAINMENT SYSTEMS 3.6.5.4 Drywell Pressure LCO 3.6.5.4 l-to-primary containment differential pressure shall -0.2 psid and 1.0 psid. APPLICABILITY:

MODES 1, 2, and 3. ACTIONS be CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell-to-primary containment differential pressure not within limits. B. Required Action and associated Completion Time not met. A.l B.l AND B.2 Restore containment differential pressure to within limits. Be in MODE 3. Be in MODE 4. 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 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.5.4.1 Verify drywell-to-primary containment differential pressure is within limits. FREQUENCY In accordance with the Surveillance Frequency Control Program CLINTON 3.6-66 Amendment No. 192 Drywell Air Temperature 3.6.5.5 3.6 CONTAINMENT SYSTEMS 3.6.5.5 Drywell Air LCO 3.6.5.5 Drywell average air temperature shall be S APPLICABILITY:

MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell average air temperature not within limit. B. Required Action and associated Completion Time not met. A.l B.l ANDB.2 Restore drywell average air temperature to within limit . Be in MODE 3. Be in MODE 4. 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 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.5.5.1 Verify drywe11 average air temperature is within limit. FREQUENCY In accordance with the Surveillance Frequency Control Program CLINTON 3.6-67 Amendment No. 192 Drywell Post-LOCA Vacuum Relief System 3.6.5.6 SURVEILLANCE REQUIREMENTS SR 3.6.5.6.1 SURVEILLANCE

1. Not required to be met for drywell post-LOCA vacuum relief valves open during Surveillances.

2. Not red to be met for drywell post-LOCA vacuum relief valves open when performing their intended function.

Veri each drywell post-LOCA vacuum relief valve is closed. FREQUENCY In accordance with the Surveillance Frequency Control program SR SR 3.6.5.6.2 3.6.5.6.3 Perform a functional test of each drywell post-LOCA vacuum relief valve. Verify the opening pressure differential of each drywell post-LOCA vacuum relief valve is 0.2 psid. In accordance with the Surveillance Frequency Control program In accordance with the Surveillance Frequency Control Program CLINTON 3.6-70 Amendment No. 192 3.7.1 Division 1 and 2 SX Subsystems and UHS Actions (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and associated Completion Time of Condition A not met. OR 0.1 AND D.2 Be in MODE 3. Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours Division 1 and 2 SX subsystems inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify UHS water volume is 593 acre-ft. In accordance with UHS Erosion, Sediment Monitoring, and Dredging Program SR 3.7.1.2 Veri each required SX 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.

In accordance with the Surveillance Frequency Control Program SR 3.7.1.3 Verify each SX subsystem actuates on an actual or simulated initiation signal. In accordance with the Surveillance Frequency Control Program CLINTON 3.7-2 Amendment No. 192 3.7 PLANT SYSTEMS 3.7.2 Division 3 Shutdown Service Water (SX) Division Subsystem 3 SX Subsystem 3.7.2 LCO 3.7.2 The Division 3 SX subsystem shall be OPERABLE.

APPLICABILITY:

MODES I, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Division 3 SX subsystem inoperable.

A.l Declare High Pressure Core Spray System inoperable.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Veri each required Division 3 SX 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 ion. In accordance with the Surveillance Frequency Control Program SR 3.7.2.2 Verify the Division 3 SX subsystem actuates on an actual or simulated initiation signal. In accordance with the Surveillance Frequency Control Program CLINTON 3.7-3 Amendment No. 192 3.7.3 Control Room Ventilation System ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. Two Control Room G.l Suspend movement of Immediately Ventilation subsystems irradiated fuel inoperable during assemblies in the movement of irradiated primary and secondary fuel assemblies in the containment.

primary or secondary containment, during AND CORE ALTERATIONS, or during OPDRVs. G.2 Suspend CORE Immediately ALTERATIONS.

OR AND One or more Control Room Ventilation G.3 Initiate action to Immediately subsystems inoperable suspend OPDRVs. due to inoperable CRE boundary during movement of irradiated fuel assemblies in the primary or secondary containment, during CORE ALTERATIONS, or during OPDRVs. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each Control Room Ventilation subsystem with flow through the makeup filter for 10 continuous hours with the heaters operating.

In accordance with the Surveillance Frequency Control Program SR 3.7.3.2 Operate each Control Room Ventilation In accordance subsystem with flow through the with the recirculation filter for 15 minutes. Surveillance Frequency Control Program (continued)

CLINTON 3.7-6 Amendment No. 192 3.7.3 Control Room Ventilation System SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.3.3 Perform required Control Room Ventilation filter testing in accordance with the Ventilation Filter Program (VFTP). In accordance with the VFTP SR 3.7.3.4 Veri each Control Room Ventilation subsystem actuates on an actual or simulated initiation signal. In accordance with the Surveillance Frequency Control Program SR 3.7.3.5 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program. In accordance with the Control Room Envelope Habitabili ty Program CLINTON 3.7-7 Amendment No. 192 3.7.4 Control Room AC System ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and associated Completion Time of Condition B not met during movement of irradiated fuel assemblies in the primary or secondary containment, during CORE ALTERATIONS, or during OPDRVs.

LCO 3.0.3 is not applicable.

E.l Suspend movement of irradiated fuel assemblies in the primary and secondary containment.

Immediately E.2 Suspend CORE ALTERATIONS.

Immediately AND E.3 Initiate action suspend OPDRVs. to Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE SR Verify each control room AC subsystem has the capability to remove the assumed heat load. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.7-10 Amendment No. 192 3.7.5 Main Condenser Offgas SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 Verify the radioactivity rate of the noble gases is 289 mCi/second after decay of 30 minutes. Once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after a 2: 50% increase in the nominal steady state fission gas release rate after factoring out increases due to changes in THERMAL POWER level SR 3.7.5.2 Not required to be performed until 31 days after any main steam line not isolated and SJAE in operation.

Veri the radioactivity rate of the noble gases is 289 mCi/second after decay of 30 minutes. In accordance with the Surveillance Frequency Control Program CLINTON 3.7-12 Amendment No. 192 Main Turbine Bypass 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 21.6% RTP. AC'I'IONS CONDITION REQUIRED ACTION COMPLETION TIME A. Main Turbine Bypass A.1 Restore Main Turbine 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months System inoperable.

Bypass System to OPERABLE status. 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 < 21. 6% RTP. Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify one complete cycle of-each main turbine bypass valve. In accordance with the Surveillance Frequency Control Program SR 3.7.6.2 Perform a system functional test. In accordance with the Surveillance Frequency Control Program SR 3.7.6.3 Verify the TURBINE BYPASS TIME is within limits. SYSTEM RESPONSE In accordance with the Surveillance Frequency Control Program CLINTON 3.7-13 Amendment No. 192 Fuel Pool Water Level 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Fuel Pool Water Level LCO 3.7.7 The fuel pool water level shall be 23 ft over the top of irradiated fue l assemblies seated in the spent fuel storage pool and upper containment fuel storage pool racks. APPLICABILITY:

During movement of irradiated fuel assemblies in the associated fuel storage pool. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel pool water level not within limit. A.I LCO 3.0.3 is not applicable.

Suspend movement of irradiated fuel assemblies in the associated fuel storage pool{s}. Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE SR Verify the fuel pool water level is 23 ft over the top of irradiated fuel assemblies seated in the storage racks. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.7-14 Amendment No. 92 3.8.1 AC Sources--Operat ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. Three or more required G.1 Enter LCO 3.0.3. Immediately AC sources inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and In accordance indicated power availability for each with the offsite circuit. Surveillance Frequency Control Program SR 3.8.1. 2 Performance of SR 3.8.1.7 satisfies this SR. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer.

When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met. In accordance conditions and achieves steady state Verify each DG starts from standby with the Surveillance voltage 4084 V and s 4580 V and frequency Frequency58.8 Hz and s 61.2 Hz. Control Program (continued) 3.8-4 Amendment No. 192 3.8.1 AC Sources--Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 DG loadings may include gradual loading as recommended by the manufacturer. Momentary transients outside the load range do not invalidate this test. This Surveillance shall be conducted on only one DG at a time. 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. Veri each DG operates for 60 minutes at In accordance a load 3482 kW for DG lA, 3488 kW for the Surveillance DG 18, and 1980 kW for DG 1C. Frequency Control Program In accordance the SR 3.8.1.4 Verify each tank contains 385 of fuel oil for DG lA and DG 18 and 240 gal Surveillance for DG 1C. Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from In accordance each day tank. with the Surveillance Frequency Control Program SR 3.8.1.6 Verify the fuel oil transfer system In accordance operates to automatical transfer fuel oil with the from the storage tank to the day tank. Surveillance Frequency Control Program (continued) 3.8-5 Amendment No. 192 AC Sources 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVE ILLANCE FREQUENCY SR 3.8.1.7 All DG starts may be preceded by an engine prelube period. Verify each DG starts from standby condition and achieves:

a. In s 12 seconds, voltage 4084 V and frequency 58.8 Hz; and b. Steady state voltage 4084 V and s 4580 V and frequency 58.8 Hz and :S 61.2 Hz. In accordance with the Surveillance Frequency Control Program SR 3.8.1. 8 This Surveillance shall not be performed in MODE 1 or 2. However, credit may be taken for unplanned events that satisfy this SR. Veri automatic and manual transfer of unit power supply from the normal offsite circuit to the alternate offsite circuit. In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.8-6 Amendment No. 192 3.8.1 AC Sources--Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.8.1.9 Credit may be taken for unplanned events that satisfy this SR. If performed with DG synchronized with offsite power, it shall be performed at a power factor < 0.9. Verify each DG ects a load greater than or to its associated single st post accident load and following load rejection, the engine speed is maintained less than nominal plus 75% of the difference between nominal speed and the overspeed trip setpoint or 15% above nominal, whichever is lower. FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) 3.8-6a Amendment No. 192 3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.8.1. 10 Credit may be taken for unplanned events that satisfy this SR. Verify each DG operating at a power factor 0.9 does not trip and voltage is maintained 5000 V for DG 1A and DG IB and 5824 V for DG 1C during and following a load rejection of a load 3482 kW for DG lA, 3488 kW for DG 18, and 1980 kW for DG 1C. FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.8-7 Amendment No. 192 3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE 3.8.1.11 All DG starts may be preceded by an engine prelube period. This Surveillance shall not be performed in MODE 1, 2, or 3. However, credit may be taken for unplanned events that satis this SR. Veri on an actual or simulated loss of offsite power signal: De-energization of emergency buses; Load shedding from emergency buses for Divisions 1 and 2; and DG auto-starts from standby condition and: energizes permanently connected loads in $12 seconds, energizes auto-connected shutdown loads, maintains steady state voltage 4084 V and $ 4580 V, maintains steady state frequency 58.8 Hz and $ 61.2 Hz, and supplies permanently connected and auto-connected shutdown loads for 5 minutes. FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) 3.8-8 Amendment No. 192 3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.12 SURVEILLANCE

1. All DG starts may be preceded by an engine period. 2. This Surveillance shall not be performed in MODE 1 or 2. However, credit may be taken for unplanned events that satis this SR. Verify on an actual or simulated Emergency Core Cooling System (ECCS) initiation signal each DG auto-starts from standby condition and: a. In 12 seconds after auto-start and during tests, achieves voltage 4084 V and frequency 58.8 Hz; b. Achieves steady state voltage 4084 V and 4580 V and frequency 58.8 Hz and 61.2 Hz; and c. Operates for 5 minutes. FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.8.1.13 Credit may be taken for unplanned events that satisfy this SR. Veri each DG's automatic trips are bypassed on an actual or simulated ECCS initiation signal except: a. Engine overspeed;

b. Generator differential current; and c. Overcrank for DG lA and DG lB. In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.8-9 Amendment No. 192 3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.8.1.14 Momentary transients outside the load and power factor ranges do not invalidate this test. Credit may be taken for unplanned events that satisfy this SR. Verify each DG operating at a power factor 0.9 operates for 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: For 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded 4062 kW for DG lA, 4069 kW for DG IE, and 2310 kW for DG lC; and For the remaining hours of the test loaded 3482 kW for DG lA, 3488 kW for DG 1B, and 1980 kW for DG 1C. FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) 3.8-10 Amendment No. 192 3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.8.1.15 This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded 3482 kW for DG lA, 3488 kW for DG IE, and 1980 kW for DG 1C. Momentary transients outside of the range do not invalidate this test. All DG starts may be preceded by an engine prelube period. Verify each DG starts and achieves: In 12 seconds, voltage 4084 V and frequency 58.8 Hz and Steady s ta te vol tage 4084 V and 4580 V and frequency 58.8 Hz and 61. 2 Hz. FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) 3.8-11 Amendment No. 192 3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.16 This Surveillance shall not be performed in MODE 1, 2, or 3. However, credit may be taken for unplanned events that satisfy this SR. Verify each DG: a. Synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power; b. Transfers loads to offsite power source; and c. Returns to ready-to-load operation.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.17 Credit may be taken for unplanned events that sati this SR. Veri 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 zing the emergency loads from offsite power. In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.8-12 Amendment No. 192 3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.8.1.18 This Surveillance shall not be performed in MODE I, 2, or 3. However, credit may be taken for unplanned events that satis this SR. Verify the sequence time is within +/- 10% of des for each load sequence timer. FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.8-13 Amendment No. 192 3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.19 SURVEILLANCE All DG starts may be preceded by an engine prelube period. This Surveillance shall not be performed in MODE 1, 2, or 3. However, credit may be taken for unplanned events that satis this SR. Veri , on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ECCS initiation signal: De-energization of emergency buses; Load shedding from emergency buses for Divisions 1 and 2; and DG auto-starts from standby condition and: energizes permanently connected loads in 12 seconds, energizes auto-connected emergency loads, achieves state voltage 4084 V and 4580 V, achieves steady state frequency 58.8 Hz and 61.2 Hz, and supplies permanently connected and auto-connected emergency loads for 5 minutes. FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) 3.8-14 Amendment No. 192 3.8.1 AC Sources-Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.8.1.

All DG starts may be preceded by an engine pre lube period. Verify, when started simultaneously from standby condition, each DG achieves: In 12 seconds, voltage 4084 V and frequency 58.8 Hz; and Steady state voltage 4084 V and 4580 V and frequency 58.8 Hz and 61.2 Hz. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.8-15 Amendment No. 192 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required Actions and associated Completion Time not met. F.l Declare associated DG inoperable.

Immediately OR One or more DGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, 0, or E. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.3.1 Verify each fuel oil storage tank contains: ;;:: 48,000 of fuel for DG 1A; ;;:: 45,000 gal of fuel for DG 18; and ;;:: 29,500 gal of fuel for DG 1C. SR 3.8.3.2 Verify lube oil inventory is: ;;:: 347 gal for each 16 engine; and ;;:: 284 gal for each 12 cylinder engine. FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued) 3.8-22 Amendment No. 192 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program. SR 3.8.3.4 Verify each required DG air start receiver pressure is 200 psig. SR 3.8.3.5 Check for and remove accumulated water from each fuel oil storage tank. In accordance with the Diesel Fuel Oil Testing Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program CLINTON 3.8-23 Amendment No. 192 3.8.4 DC Sources-Ope rat SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Veri battery terminal voltage is greater In accordance than or equal to the minimum established with the float voltage. Surveillance Frequency Control Program SR 3.8.4.2 Veri each Division 1 and 2 battery charger In accordance supplies 300 amps at greater than or equal with the to the minimum established float voltage for Surveillance Frequency4 hours and each Division 3 and 4 battery Control Program charger supplies 100 amps at greater than or equal to the minimum established float voltage for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Verify each battery charger can recharge the battery to the fully charged state within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state. SR 3.8.4.3 The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.3. This Surveillance shall not be performed in MODE 1, 2, or 3. However, credit may be taken for unplanned events that satisfy this SR. Verify battery capacity is adequate to In accordance supply, and maintain in OPERABLE status, the with the required emergency loads for the design Surveillance cycle when ected to a battery service Frequency test. Control Program 3.8-25 Amendment No. 192 3.8.6 Battery Parameters SURVEILLANCE REQUIREMENTS (continued)

FREQUENCY SURVEILLANCE SR 3.8.6.1 NOTE Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1. Verify each battery float current is < 2 amps. SR 3.8.6.2 Verify each > 2.07 V. pilot cell voltage is SR SR SR 3.8.6.3 3.8.6.4 3.8.6.5 Verify each connected cell level is greater than or equal to minimum established design limits. Verify each pilot cell temperature is greater than or equal to minimum established design limits. Verify each battery connected cell voltage is > 2.07 V. 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)

CLINTON 3.8-32 Amendment No. 192 3.8.6 Battery Parameters SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.8.6.6 This Surveillance shall not be performed in MODE 1, 2, or 3. However, credit may be taken for unplanned events that this SR. Verify battery capacity is 80 of the manufacturer's rating when subjected to a performance discharge test or a modified performance discharge test. 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 < 100% of manufacturer's rating 24 months when battery has reached 85% of the expected life with capacity>

100% of manufacturer's rating CLINTON 3.8-33 Amendment No. 92 3.8.7 Inverters-Operating ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Both RPS solenoid bus inverters inoperable.

E.l De-energize one RPS solenoid bus. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months F. red Action and associated Completion Time for Condition C, D, or E not met. F.l F.2 Be in MODE 3. Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE SR Verify correct inverter voltage, frequency, and alignment to red uninterruptible AC buses and RPS solenoid buses. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.8-35 Amendment No. 192 3.8.8 Inverters Shutdown SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.8.1 Verify correct inverter voltage, frequency, and alignments to required uninterruptible AC buses. FREQUENCY In accordance with the Surveillance Frequency Control Program CLINTON 3.8-38 Amendment No. 192 3.8.9 Distribution Systems Operating SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.9.1 Verify correct breaker alignments and to required AC, DC, and uninterruptible AC bus electrical power distribution subsystems.

FREQUENCY In accordance with the Surveillance Frequency Control Program CLINTON 3.8-41 Amendment No. 192 Distribution Systems--Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.2.3 Initiate action to suspend operations with a potential for the reactor vessel. Immediately AND A.2.4 Initiate actions to restore required AC, DC, and uninterruptible AC bus electrical power distribution subsystems to OPERABLE status. Immediately AND A.2.5 Declare associated required shutdown cooling subsystem(s) inoperable and not in operation.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE correct breaker al and to required AC, DC, and uninterruptible AC bus electrical power distribution subsystems.

SR 3.8.10.1 FREQUENCY In accordance with the Surveillance Frequency Control Program CLINTON 3.8-43 Amendment No. 192 SVC Protection Systems 3.8.11 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.11.1 For each required SVC Protection System, perform a local, visual check of the SVC system control and status panel to confirm satisfactory operation.

In accordance with the Surveillance Frequency Control Program SR 3.8.11.2 Perform a system functional test of each SVC protection subsystem, including breaker actuation.

In accordance with the Surveillance Frequency Control Program CLINTON 3.8-45 Amendment No. 192 Refueling Interlocks 3.9.1 3.9 OPERATIONS 3.9.1 Refueling Interlocks LCO 3.9.1 The refueling equipment interlocks shall be OPERABLE.

APPLICABILITY:

in-vessel fuel movement with equipment associated with the interlocks.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more refueling interlocks A.I in-vessel fuel movement with associated with the inoperable interlock(s) . Immediately OR A.2.1 Insert a control rod withdrawal block Immediately A.2.2 Veri all control rods are fully inserted.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE SR Perform CHANNEL FUNCTIONAL TEST on each of the following required refueling equipment interlock inputs: All-rods-in, Refuel platform ion, and Refuel platform main hoist, fuel loaded. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.9-1 Amendment No. 192 Refuel Position One-Rod-Out-Interlock 3.9.2 3.9 OPERATIONS 3.9.2 Refuel Position One-Rod-Out Interlock LCO 3.9.2 The refuel position one-rod-out interlock shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Refuel position rod-out interlock inoperable.

A.1 AND Suspend control rod withdrawal.

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

SURVEILLANCE REQUIREMENTS SURVEILLANCE NCY SR 3.9.2.1 Veri mode switch locked in refuel In accordance pos with the Surveillance Frequency Control Program SR Not required to be 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 accordance Perform CHANNEL FUNCTIONAL TEST. with the Surveillance Frequency Control Program 3.9-2 Amendment No. 192 Control Rod Position 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Control Rod LCO 3.9.3 All control rods shall be fully APPLICABILITY:

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

core. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 Veri all control rods are fully inserted.

In accordance with the Surveillance Frequency Control Program CLINTON 3.9-3 Amendment No. 192 Control Rod OPERABILITY-Refueling 3.9.5 3.9 REFUELING OPERATIONS 3.9.5 Control Rod OPERABILITY

-Re 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 control rods inoperable.

A.l Initiate action to fully insert inoperable withdrawn control rods. Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Not to be performed until 7 days after the control rod is withdrawn.

Insert each withdrawn control rod at least one notch. In accordance with the Surveillance Control Program SR 3.9.5.2 Veri each withdrawn control rod scram accumulator pressure is 1520 psig. In accordance with the Surveillance Frequency Control Program CLINTON 3.9-7 Amendment No. 192 RPV Water Level-Irradiated Fuel 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Reactor Pressure Vessel (RPV) Water Level--Irradiated Fuel LCO RPV water level shall be 22 ft 8 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 wi thin limit. A.I Suspend movement of irradiated fuel assemblies within the RPV. Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.6.1 Verify RPV water level is 22 ft 8 inches above the top of the RPV flange. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.9-8 Amendment No. 192 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 RPV water level shall be 2 23 ft above the top of irradiated fuel assemblies seated within the RPV. APPLICABILITY:

During movement of new fuel assemblies or handl of control rods within the RPV when irradiated fuel assemblies are seated within the RPV. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RPV water level not within limit. A.I Suspend movement of new fuel assemblies and handling of control rods within the RPV. Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.7.1 Veri RPV water level is 2 23 ft above the top of irradiated fuel assemblies seated within the RPV. FREQUENCY In accordance with the Surveillance Frequency Control Program 3.9-9 Amendment No. 192 3.9.8 RHR--High Water Level ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown cooling subsystem in operation.

C.l AND C.2 reactor coolant circulation by an alternate method. Monitor reactor coolant temperature.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of no reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter Once per hour SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.8.1 Verify one RHR shutdown cooling subsystem is operating.

FREQUENCY In accordance with the Surveillance Frequency Control Program CLINTON 3.9-12 Amendment No. 192 3.9.9 RHR--Low Water Level ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown cooling subsystem in operation.

C.l Verify reactor coolant circulation by an alternate method. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of no reactor coolant circulation AND AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter C.2 Monitor reactor coolant temperature.

Once per hour SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.9.1 Verify one RHR shutdown cooling subsystem is operating.

FREQUENCY In accordance with the Surveillance Frequency Control Program CLINTON 3.9-15 Amendment No. 192 Reactor Mode Switch Interlock Testing 3.10.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.2.1 Verify all control rods are fully inserted in core cells containing one or more fuel assemblies.

In accordance with the Surveillance Frequency Control Program SR 3.10.2.2 Verify no CORE ALTERATIONS are in progress.

In accordance with the Surveillance Frequency Control Program CLINTON 3.10-5 Amendment No. 192 Single Control Rod Withdrawal--Hot Shutdown 3.10.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.3.1 Perform the applicable SRs for the LCOs. red According to 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.l 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.

In accordance with the Surveillance Frequency Control Program SR 3.10.3.3 Verify all control rods, other than the control rod being withdrawn, are fully inserted.

In accordance with the Surveillance Frequency Control Program CLINTON 3.10-8 Amendment No. 192 Single Control Rod Withdrawal--Cold Shutdown 3.10.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 8. One or more of the above requirements not met with the affected control rod not insertable.

8.1 Suspend withdrawal of the control rod and removal of associated CRD. AND 8.2.1 Initiate action to fully insert all control rods. OR 8.2.2 Initiate action to satisfy the requirements of this LCO. Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.4.1 Perform the applicable SRs for the required LCOs. According to applicable SRs SR 3.10.4.2 Not required to be met if SR 3.10.4.1 is satisfied for LCO 3.10.4.c.1 requirements.

Verify all control rods, other than the control rod being withdrawn, in a five by five array centered on the control rod being withdrawn, are disarmed.

In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.10-11 Amendment No. 192 Control Rod Withdrawal--Cold Shutdown 3.10.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.4.3 Veri all control rods, other than the control rod withdrawn, are fully inserted.

In accordance with the Surveillance Frequency Control SR 3.10.4.4 Not required to be met if SR 3.10.4.1 is satisfied for LCO 3.10.4.b.1 rements. Verify a control rod withdrawal block is inserted.

In accordance with the Surveillance Frequency Control Program CLINTON 3.10-12 Amendment No. 192 Single CRD Removal Refue 3.10.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or above met. more of the not A.1 AND suspend the CRD removal of mechanism.

Immediately A.2.1 Initiate action to fully insert all control rods. Immediately OR A.2.2 Initiate action satisfy the requirements of LCO. to this Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.5.1 Veri all controls rods, other than the control rod withdrawn for the removal of the associated CRD, are fully inserted.

In accordance with the Surveillance Frequency Control Program SR 3.10.5.2 Veri all control 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.

In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.10-14 Amendment No. 192 Single CRD Removal-Refueling 3.10.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.5.3 Veri a control rod withrdrawal block is inserted.

In accordance with the Surveillance Frequency Control Program SR 3.10.5.4 Perform SR 3.1.1.1. According to SR 3.1.1.1 SR 3.10.5.5 Veri no CORE ALTERATIONS are in progress.

In accordance with the Surveillance Frequency Control Program CLINTON 3.10-15 Amendment No. 192 Mult Control Rod Withdrawal--Refueling 3.10.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or above met. more of the s not A.l control removal CRDs. withdrawal of rods and of associated Immediately AND A.2 loading assemblies.

fuel Immediately AND A.3.1 Initiate action to ful insert all control rods in core cells containing one or more fuel assemblies.

Immediately OR A. 3.2 to s of this LCO. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.10.6.1 Verify the four fuel assemblies are removed from core cells associated with each control rod or CRD removed. FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

CLINTON 3.10-17 Amendment No. 192 Multiple Control Rod Withdrawal--Refuel 3.10.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.6.2 Verify all other control rods in core cells containing one or more fuel assemblies are fully inserted.

In accordance with the Surveillance Frequency Control Program SR 3.10.6.3 Only required to be met during fuel loading. Verify fuel assemblies being loaded are in compliance with an approved spiral reload sequence.

In accordance with the Surveillance Frequency Control Program CLINTON 3.10-18 Amendment No. 192 SDM Test Refueling 3.10.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.8.2 Not red 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.

to the applicable SRs SR 3.10.8.3 Not to be met if SR 3.10.8.2 Veri 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. control rod movement SR 3.10.8.4 Veri no other CORE ALTERATIONS are in progress.

In accordance with the Surveillance Frequency Control (continued)

CLINTON 3.10-22 Amendment No. 192 SDM Test-Refuel 3.10.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.8.5 Veri go to each withdrawn control rod does not the withdrawn overtravel position.

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 SR 3.10.8.6 Veri CRD charging ;::: 1520 psig. water header pressure In accordance with the Surveillance Frequency Control Program CLINTON 3.10-23 Amendment No. 192 3.10.9 3.10 SPECIAL LCO 3.10.9 APPLICABILITY:

ACTIONS Training Startups 3.10.9 OPERATIONS Startups The low pressure coolant injection (LPCI) OPERABILITY requirements fied in LCO 3.5.1, "ECCS-Operating," may be changed to allow one residual heat removal subsystem to be aligned in the shutdown cooling mode for training startups, provided the following requirements are met: a. THERMAL POWER is 1% RTP; and b. Average reactor coolant temperature is < 200°F. MODE 2 with one LPCI subsystem suction valve closed. REQUIRED ACTION COMPLETION TIME CONDITION A. One or more of the A.l Place the reactor Immediately above requirements not mode switch in the met. shutdown SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.9.1 Veri THERMAL POV'JER is 1% RTP. In accordance with the Surveillance Frequency Control Program SR 3.10.9.2 Veri average is < 200°F. reactor coolant temperature In accordance with the Surveillance Frequency Control Program CLINTON 3.10-24 Amendment No. 192 Single Control Rod Withdrawal

-Refuel 3.10.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.10.1 Veri all control rods other than the control rod inserted.

withdrawn, are fully In accordance with the Surveillance Frequency Control Program SR 3.10.10.2 Veri no progress.

other CORE ALTERATIONS are in In accordance with the Surveillance Frequency Control Program CLINTON 3.10-26 Amendment No. 192 Programs and Manuals 5.5 Program and Manuals (continued) (continued) Measurement, at locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one subsystem of the Control Room Ventilation System, operating at the flow rate by the VFTP, at a Frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and used as a part of the 24 month assessment of the CRE 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 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 DBA consequences.

Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licens basis. The provisions of SR 3.0.2 are applicable to the Frequencies for assess CRE habitability, determining CRE unfiltered inleakage, and CRE pressure and assessing the CRE boundary as red by paragraph c and d, respectively.

5.5.16 program provides controls for Surveillance Frequencies.

shall ensure that Surveillance Requirements in the Technical ications are performed at intervals sufficient to assure the associated Lilniting Conditions for operation are met. The Surveillance Control Program shall contain a list of Frequencies Surveillance Requirements for which the Frequency is controlled by the program. Changes to the 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. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the ies established in the Surveillance Frequency Control Program. S.0-16c Amendment No. 192 UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 192 TO FACILITY OPERATING LICENSE NO. NPF-62 EXELON GENERATION COMPANY. LLC CLINTON POWER STATION, UNIT NO.1 DOCKET NO. 50-461

1.0 INTRODUCTION

By letter to the Nuclear Regulatory Commission (NRC, the Commission) dated February 2010, (Agencywide Documents Access and Management System (ADAMS) Accession ML 100470787), as supplemented by letter dated May 21, 2010 (ADAMS Accession ML 101450001), Exelon Generation Company, LLC (EGC, the licensee), requested changes the technical specifications (TSs), facility operating license, and surveillance requirements for Clinton Power Station (CPS), Unit The May 21,2010, supplement, contained clarifying information but did not change the staff's initial proposed finding of no significant hazards The requested change is the adoption of NRC-approved Technical Specifications Task (TSTF-425), Revision 3, "Relocate Surveillance Frequencies to Licensee Control-Informed Technical Specification Task Force (RITSTF) Initiative 5b" (Reference 1). implemented, TSTF-425 relocates most periodic frequencies of TS surveillances to a controlled program, the Surveillance Frequency Control Program (SFCP), and requirements for the new program in the Administrative Controls section of the TS. surveillance frequencies can be relocated Frequencies that reference other approved programs for the specific interval (such as the In-Service Testing Program or the Primary Containment Leakage Rate Testing Program (RTP>>; Frequencies that are purely event-driven (e.g., "each time the control rod is withdrawn to the 'full out' position");

Frequencies that are event-driven, but have a time component for performing the surveillance on a one-time basis once the event occurs (e.g., "within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after thermal power reaching 95 percent RTP"); and Frequencies that are related to specific conditions (e.g., battery degradation, age and capacity) or conditions for the performance of a SR (e.g., "drywell to suppression chamber differential pressure decrease").

A new program is added to the Administrative Controls of TS Section 5 as Specification 5.5.16. The new program is called the SFCP and describes the requirements for the program to control changes to the relocated surveillance frequencies.

The TS Bases for each of the affected SRs are revised to state that the frequency is set in accordance with the SFCP. Some SRs Bases do not contain a discussion of the frequency.

In these cases, the Bases describing the current frequency were added to maintain consistency with the Bases for similar surveillances.

These instances are noted in the markup along with the source of the text The proposed licensee changes to the Administrative Controls of the TS to incorporate the SFCP include a specific reference to Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specifications Initiative 5B, Risk-Informed Method for Control of Surveillance Frequencies," Revision 1 (Reference 2), as the basis for making any changes to the surveillance frequencies once they are relocated out of the TS. In a letter dated September 19,2007, the NRC staff approved NEI 04-10, Revision 1, (Agencywide Documents Assess and Management System (ADAMS) Accession No. ML072570267), as acceptable for referencing in licensing actions to the extent specified and under the limitations delineated in NEI 04-10, and the safety evaluation providing the basis for NRC acceptance of NEI 04-10.

2.0 REGULATORY EVALUATION

In the "Final Policy Statement:

Technical Specifications Improvements for Nuclear Power Plants" published in the Federal Register (58 FR 39132, July 22,1993), the NRC addressed the use of Probabilistic Safety Analysis (PSA), (currently referred to as Probabilistic Risk Assessment (PRA) in Standard Technical Specifications).

In discussing the use of PSA in Nuclear Power Plant Technical SpeCifications, the Commission wrote in part: The Commission believes that it would be inappropriate at this time to allow requirements which meet one or more of the first three criteria 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 determinil1g 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 change. Approximately two years later, the NRC provided additional detail concerning the use of PRA in the "Use of Probabilistic Risk Assessment in Nuclear Regulatory Activities; Final Policy Statement," published in the Federal Register (60 FR 42622, August 16,1995).

The Commission, in discussing the deterministic and probabilistic approach to regulation, and the Commission's extension and enhancement of traditional regulation, wrote in part: 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. The Commission provided its new policy, stating: Although PRA methods and information have thus far been used successfully in nuclear regulatory activities, there have been concerns that PRA methods are not consistently applied throughout the agency, that sufficient agency PRAlstatistics expertise is not available, and that the Commission is not deriving full benefit from the large agency and industry investment in the developed risk assessment methods. 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. Implementation of the policy statement will improve the regulatory process in three areas: Foremost, through safety decision making enhanced by the use of PRA insights; through more efficient use of agency resources; and through a reduction in unnecessary burdens on licensees.

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 (8ackfit 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.

In 10 CFR 50.36, the NRC established its regulatory requirements related to the content of the TS. 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) surveillance requirements; (4) design features; and (5) administrative controls.

As stated in 10 CFR 50.36(c)(3), "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." These categories will remain in the TS. The new TS SFCP provides the necessary administrative controls to require that surveillances 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. Changes to surveillance frequencies in the SFCP are made using the methodology contained in NEI 04-10, including qualitative considerations, results of risk analyses, sensitivity studies and any bounding analyses, and recommended monitoring of structures, systems, and components (SSCs), and required to be documented.

Furthermore, changes to frequencies are subject to regulatory review and oversight of the SFCP implementation through the rigorous NRC review of safety-related SSC performance provided by the reactor oversight program. Licensees are required by the TS to perform surveillance test, calibration, or inspection on specific safety-related system equipment (e.g., reactivity control, power distribution, electrical, and instrumentation) to verify system operability.

Surveillance frequencies, currently identified in the TS, are based primarily upon deterministic methods such as engineering judgment, operating experience, and manufacturer's recommendations.

The licensee's use of approved methodologies identified in NEI 04-10 provides a way to establish risk-informed surveillance frequencies that complement the deterministic approach and support the NRC's traditional defense-in-depth philosophy.

The licensee's SFCP ensures that SRs specified in the TS are performed at intervals sufficient to assure the above regulatory requirements are met. Existing regulatory requirements, such as 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and 10 CFR Part 50, Appendix B (corrective action program), require licensee monitoring of surveillance test failures and implementing corrective actions to address such failures.

One of these actions may be to consider increasing the frequency at which a surveillance test is performed.

In addition, the SFCP implementation guidance in NEI 04-10 requires monitoring the performance of SSCs for which surveillance frequencies are decreased to assure reduced testing does not adversely impact the SSCs. These requirements, and the monitoring required by NEI 04-10, 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. Regulatory Guide (RG) 1.17 4, "An Approach for Using Probabilistic Risk Assessment in Informed Decisions on Plant-Specific Changes to the Licensing Basis," (Reference 5), describes a risk-informed approach, acceptable to the NRC, 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.

In RG 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications," (Reference 3), it describes an acceptable risk-informed approach specifically for assessing proposed permanent TS changes. In RG 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," (Reference 4), it 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.

3.0 TECHNICAL EVALUATION The licensee's adoption of TSTF-425 for CPS provides for administrative relocation of applicable surveillance frequencies and provides for the addition of the SFCP to the administrative controls of the TS. TSTF-425 also requires the application of NEI 04-10 for any changes to surveillance frequencies within the SFCP. The licensee's application for the changes proposed in TSTF-425 included documentation regarding the PRA technical adequacy consistent with the requirements of RG 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 1 (Reference 4). In accordance with NEI 04-10, PRA methods are used in combination with plant performance data and other considerations to identify and justify modifications to the surveillance frequencies of equipment at nuclear power plants. This is in accordance with guidance provided in RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Informed Decisions on Plant-Specific Changes to the Licensing Basis," (Reference

5) and RG 1.177 in support of changes to surveillance test intervals.

RG 1.177 Five Key Safety Principles In RG 1.177, it identifies five key safety principles required for risk-informed changes to the Each of these principles is addressed by the industry methodology document, NEI The Proposed Change Meets Current Regulations The regulation at 10 CFR 50.36(c)(3) states that TSs will 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." NEI 04-10 provides guidance for relocating the surveillance frequencies from the TSs to a licensee-controlled program by providing an approved methodology for control of the surveillance frequencies.

The surveillances themselves would remain in the TSs, as required by 10 CFR 50.36(c)(3).

This change is consistent with other NRC-approved TS changes in which the surveillance frequencies are relocated to licensee-controlled documents, such as surveillances performed in accordance with the In-service Testing Program or the Primary Containment Leakage Rate Testing Program. Thus, this proposed change meets the first key safety principle of RG 1.177 by complying with current regulations. The Proposed Change Is Consistent With the Defense-in-Depth Philosophy Consistency with the defense-in-depth philosophy, the second key safety principle of RG is maintained 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 is System redundancy, independence, and diversity are preserved commensurate with the expected frequency, consequences of challenges to the system, and uncertainties (e.g., no risk outliers).

Because the scope of the proposed methodology is limited to revision of surveillance frequencies, the redundancy, independence, and diversity of plant systems are not impacted.

Defenses against potential common-cause failures are preserved, and the potential for the introduction of new common cause failure mechanisms is assessed. Independence of barriers is not degraded. Defenses against human errors are preserved. The intent of the General Design Criteria in 10 CFR Part 50, Appendix A, is maintained.

TSTF-425 requires the application of NEI 04-10 for any changes to surveillance frequencies within the SFCP. NEI 04-10 uses both the core damage frequency (CDF) and the large early

-7 release frequency (LERF) metrics to evaluate the impact of proposed changes to surveillance frequencies.

The guidance of RG 1.174 and RG 1.177 for changes to the CDF and the 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.

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 common-cause failures.

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. 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 with the principle 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 plant licensing basis (including the Updated Final Safety Analysis Report and bases to the TS), since 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. Thus, safety margins are maintained by the proposed methodology, and the third key safety principle of RG 1.177 is satisfied. When Proposed Changes Result in an Increase in Core Damage Frequency or Risk, the Increases Should Be Small and Consistent With the Intent of the Commission's Safety Goal Policy Statement In RG 1.177, it provides a framework for evaluating the risk impact of proposed changes to surveillance frequencies.

This requires the identification of the risk contribution from impacted surveillances, determination of the risk impact from the change to the proposed surveillance frequency, and performance of sensitivity and uncertainty evaluations.

TSTF-425 requires application of NEI 04-10 in the SFCP. NEI 04-10 satisfies the intent of RG 1.177 requirements for evaluating the change in risk, and for assuring that such changes are small. 3.1.4.1 Quality of the PRA The quality of the CPS PRA is compatible with the safety implications of the proposed TS change and the role the PRA plays in justifying the change. That is, the more the potential 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.

The licensee used RG 1.200 to address the technical adequacy of the CPS PRA. RG 1.200 is NRC's developed regulatory guidance, which endorses with comments and qualifications the use of the American Society of Mechanical Engineers (ASME) RA-Sb-2005, "Addenda to ASME RA-S-2002 Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications," (Reference 6), NEI 00-02, "PRA Peer Review Process Guidelines," (Reference 7), and NEI 05-04. "Process for Performing Follow-On PRA Peer Reviews Using the ASME PRA Standard" (Reference 8). The licensee has performed an assessment of the PRA models used to support the SFCP against the requirements of RG 1.200 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 ASME RA-8b-2005 is applied as the standard, and 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.

The NRC staff reviewed the licensee's assessment of the CPS PRA and the remaining open deficiencies that do not conform to capability Category II of the ASME PRA standard (Table A.2-2 of Attachment 2 of the license amendment request).

In addition, the licensee identified two open items from its original peer review (Table A.2-1 of Attachment 2 of the license amendment request).

The NRC staff's assessment of these open "gaps," to assure that they may be addressed and dispositioned for each surveillance frequency evaluation per the NEI 04-10 methodology, is provided below. Peer Review Item TH-8: Modeling assumptions regarding room cooling requirements should be supported by additional plant-specific calculations.

The licensee identified each plant area and described the assumptions used in the PRA model regarding the need for room cooling to support operation of plant equipment or habitability of the room. For those areas of the plant where the PRA assumed cooling was not required, a qualitative justification was identified which discussed the room volume and equipment layout. insights from normal operations of the equipment and the mission time of the equipment, the timing of room heatup if room cooling fails, and the compensatory measures which could be taken if room cooling is unavailable.

The qualitative disposition and conclusions regarding the PRA assumptions on room cooling are reasonable.

Peer Review Item HR-6: Pre-initiator human error probabilities are based on screening estimates only. The licensee identified that the contribution of pre-initiator events is only about 2 percent of the total CDF, and therefore, additional refinement of the probabilities would only further reduce the significance of these events. Gap #1: A review of initiating event precursors, identified as the events in NUREG-1275, has not been performed.

The licensee stated that the CPS initiating events scope includes events known to be relevant to Boiling Water Reactor (BWR)-6 plants, and that similar reviews conducted for other plants did not identify new initiating events. A review of such precursors is unlikely to identify new significant initiators for CPS. Gap #2: SWitchgear room cooling assumptions should be supported by a room cooling calculation.

As noted above in the disposition of peer review item TH-8, a qualitative disposition

-of room cooling assumptions, which included the switchgear rooms, was provided by the licensee.

Gap #3: The evaluation of pre-initiator human errors should consider specific elements of the standard (list of systems to consider, rules for identification and screening, procedures reviewed and disposition of the actions in the procedures, identification of activities requiring realignment of a system outside its normal operational or standby status). The licensee provided a detailed discussion of how its pre-initiator human failure events were developed based on systems analysis methods rather than the prescribed exhaustive review of procedures.

The licensee further noted that its CPS model includes 107 pre-initiator events, which is considered greater than typical BWR PRA models. Further, the licensee stated that only pre-initiator events associated with common-cause failure of multiple trains are typically significant to the results (Le., failure of a single component or train due to an alignment or miscalibration error is not a dominant failure mode). Based on these considerations, the licensee believes its treatment of pre-initiator human errors, while not conforming explicitly with the standard element, meets the intent of the standard to assure a rigorous and thorough review of potential errors. Gap #4: Pre-initiator human error probabilities are based on screening estimates only. This item is identical to peer review item HR-6 discussed above. Gap #5: Failure data development is not consistent with supporting requirement DA-10 of the standard; a review of test procedures for those failure modes which are fully tested should be conducted, and unplanned demands should be accounted.

The licensee stated that the CPS PRA conforms with the intent of this supporting requirement because its data is based on specific events, equipment rotation and run times, and completed test information.

Examples of the sensitivity of the failure probability calculations for equipment were provided to demonstrate that the quantitative impact from any incomplete estimation of the data are not significant.

Gap #6: Interviews with maintenance staff to supplement incomplete or limited maintenance information has not been conducted.

The licensee identified that the maintenance information for important systems is complete, so refinements to the data for other systems would not be expected to have any significant impact on the results. The NRC staff concurs that additional refinement from staff interviews are unlikely to cause substantive changes given that the existing data used is consistent with that collected for maintenance rule implementation.

Gap #7: The internal flooding analysis and documentation were generally found to require updating to the requirements of the standard.

The licensee identified that this is complete, and that the results of the industry peer review are pending. Therefore, this deficiency has been addressed.

Gaps #8 and #9: Documentation updates are required for (1) significant basic events for initiators quantified as fault trees, (2) human actions and basic events which result in accidents being non-dominant, and (3) bases for mutually exclusive events. These are enhancements to the documentation which do not impact the technical,adequacy of the model. Gap #10: The uncertainty evaluation predates NUREG/CR-1855 and could therefore be enhanced.

The licensee states that this has no impact on the baseline PRA model and results,

-and that appropriate sensitivity and uncertainty evaluations for this application will be performed per NEI 04-10 guidelines.

Based on the licensee's assessment using the applicable PRA standard and RG 1.200, 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. 3.1.4.2 Scope of the PRA The licensee is required to evaluate each proposed change to a relocated surveillance frequency using the guidance contained in NEI 04-10 to determine its potential impact on risk, due to impacts from internal events, fires, seismic, other external events, and from shutdown conditions.

Consideration is made of both CDF and LERF metrics. In cases where a PRA of sufficient scope or where quantitative risk models were unavailable, the licensee uses bounding analyses, or other conservative quantitative evaluations.

A qualitative screening analysis may be used when the surveillance frequency impact on plant risk is shown to be negligible or zero. The licensee has developed a fire PRA model, which is an interim implementation of the methodology of NUREG/CR-6850 because not all tasks identified in this document are completely addressed.

The licensee identified the incomplete tasks, and characterized the limitations of its existing fire PRA model. For surveillance interval evaluations, the licensee intends to employ a limited use of the fire PRA model to obtain quantitative insights when needed to supplement a qualitative or bounding assessment.

The individual plant examination of external events (IPEEE) seismic margins analysis will be used to provide seismic insights.

Other external hazards were screened during the IPEEE assessment, and will therefore be qualitatively assessed for this application.

The licensee's evaluation methodology is sufficient to ensure the scope of the risk contribution of each surveillance frequency change is properly identified for evaluation, and is consistent with Regulatory Position 2.3.2 of RG 1.177. 3.1.4.3 PRA Modeling The licensee will determine whether the SSCs affected by a proposed change to a surveillance frequency are modeled in the PRA. Where the SSC is directly or implicitly modeled, a quantitative evaluation of the risk impact may be carried out. The methodology adjusts the failure probability of the impacted SSCs, including any impacted common-cause failure modes, based on the proposed change to the surveillance frequency.

Where the SSC is not modeled in the PRA, bounding analyses are performed to characterize the impact of the proposed change to the surveillance frequency.

Potential impacts on the risk analyses due to screening criteria and truncation levels are addressed by the requirements for PRA technical adequacy consistent with guidance contained in RG 1.200, and by sensitivity studies identified in NEI 04-10. The licensee will perform quantitative evaluations of the impact of selected testing strategy (i.e., staggered testing or sequential testing) consistently with the guidance of NUREG/CR-6141 and NUREG/CR-5497, as discussed in NEI 04-10.

-11 Thus, through the application of NEI 04-10, the CPS PRA modeling is sufficient to ensure an acceptable evaluation of risk for the proposed changes in surveillance frequency, and is consistent with regulatory position 2.3.3 of RG 1.177. 3.1.4.4 Assumptions for Time-Related Failure Contributions The failure probabilities of SSCs modeled in the CPS PRA include a standby time-related contribution and a cyclic demand-related contribution.

NEI 04-10 criteria adjust the time-related failure contribution of SSCs affected by the proposed change to surveillance frequency.

This is consistent with RG 1.177, Section 2.3.3, which permits separation of the failure rate contributions into demand and standby for evaluation of surveillance requirements.

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, and will be confirmed by the required monitoring and feedback implemented after the change in surveillance frequency is implemented.

The 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 beneficial risk impacts of reduced surveillance frequency, including reduced downtime, lesser potential for restoration errors, reduction of potential for test caused transients, and reduced test-caused wear of equipment, are identified qualitatively, but are conservatively not required to be quantitatively assessed.

Thus, through the application of NEI 04-10, the licensee has employed reasonable assumptions with regard to extensions of surveillance test intervals, and is consistent with Regulatory Position 2.3.4 of RG 1.177. 3.1.4.5 Sensitivity and Uncertainty Analyses In NEI 04-10, it requires sensitivity studies to assess the impact of uncertainties from key assumptions of the PRA, uncertainty in the failure probabilities of the affected SSCs, impact to the frequency of initiating events, and of any identified deviations from capability Category II of ASME PRA Standard (ASME RA-Sb-2005) (Reference 4). 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. Required monitoring and feedback of SSC performance once the revised surveillance frequencies are implemented will also be performed.

Thus, through the application of NEI 04-10, 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. 3.1.4.6 Acceptance Guidelines The licensee will 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

-12 surveillance frequencies using the guidance contained in NRC approved NEI 04-10 in accordance with the TS SFCP. Each individual change to surveillance frequency must show a risk impact below 1 E-6 per year for change to COF, and below 1 E-7 per year for change to LERF. These are consistent with the limits of RG 1.174 for very small changes in risk. Where the RG 1.174 limits are not met, the process either considers revised surveillance frequencies which are consistent with RG 1.174 or the process terminates without permitting the proposed changes. Where quantitative results are unavailable to permit comparison to acceptance guidelines, appropriate qualitative analyses are required to demonstrate that the associated risk impact of a proposed change to surveillance frequency is negligible or zero. Otherwise, bounding quantitative analyses are required which demonstrate the risk impact is at least one order of magnitude lower than the RG 1.174 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 below 1 E-5 per year for change to COF, and below 1 E-6 per year for change to LERF, and the total COF and total LERF must be reasonably shown to be less than 1 E-4 per year and 1 E-5 per year, respectively.

These are consistent with the limits of RG 1.174 for acceptable changes in risk, as referenced by RG 1.177 for changes to surveillance frequencies.

The NRC staff interprets this assessment of cumulative risk as a requirement to calculate the change in risk from a baseline model utilizing failure probabilities based on the surveillance frequencies prior to implementation of the SFCP, compared to a revised model with failure probabilities based on changed surveillance frequencies.

The NRC staff further notes that EGC includes a provision to exclude the contribution to cumulative risk from individual changes to surveillance frequencies associated with small risk increases (less than 5E-8 COF 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 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 compared to numerical acceptance guidelines.

Post implementation performance monitoring and feedback are also required to assure continued reliability of the components.

The licensee's application of NEI 04-10 provides reasonable acceptance guidelines and methods for evaluating the risk increase of proposed changes to surveillance frequencies, consistent with Regulatory Position 2.4 of RG 1.177. Therefore, the proposed EGC methodology satisfies the fourth key safety prinCiple of RG 1.177 by assuring any increase in risk is small 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 The licensee's adoption of TSTF-425 requires application of NEI 04-10 in the SFCP. NEI 04-10 requires performance monitoring of SSCs whose surveillance frequency has 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 degradation of SSC performance, the surveillance frequency will be reassessed in accordance with the methodology, in addition to any corrective actions which may apply as part of the maintenance rule requirements.

The performance monitoring and feedback specified in NEI 04-10 is sufficient to reasonably assure acceptable SSC performance and is consistent with Regulatory Position 3.2 of RG 1.177. Thus, the fifth key safety principle of RG 1.177 is satisfied.

3.2 Addition of Surveillance Frequency Control Program to Administrative Controls The licensee has included the SFCP and specific requirements into the Administrative Controls, TS Section 5.5.16, Surveillance Frequency Control Program, as follows: This program provides controls for Surveillance Frequencies.

The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure that the associated Limiting Conditions for Operation are met. The Surveillance Frequency Control Program shall contain a list of Frequencies of the Surveillance Requirements for which the Frequency is controlled by the program. 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. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to Frequencies established in the Surveillance Frequency Control 3.3 Summary and Conclusions The NRC staff has reviewed the licensee's proposed relocation of some surveillance frequencies to a licensee controlled document, and controlling changes to surveillance frequencies in accordance with a new program, the SFCP, identified in the administrative controls of the TS. The SFCP and TS Section 5.5.16 references NEI 04-10, which provides a risk-informed methodology using plant-specific risk insights and performance data to revise surveillance frequencies within the SFCP. This methodology supports relocating surveillance frequencies from TS to a licensee-controlled document, provided those frequencies are changed in accordance with NEI 04-10 which is specified in the Administrative Controls of the TS. The proposed licensee adoption of TSTF-425 and risk-informed methodology of NEI 04-10 as referenced in the Administrative Controls of the TS, satisfies the key principles of risk-informed decision making applied to changes to TS as delineated in RG 1.177 and RG 1.174, 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.

In 10 CFR 50.36(c)(3), it states 'Technical specifications will include items in the following categories:

Surveillance Requirements.

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 an owner-controlled document and administratively controlled in accordance with the TS SFCP, EGC continues to meet the regulatory requirement of 10 CFR 50.36, and specifically, 10 CFR 50.36( c)(3), surveillance requirements. STATE CONSULTATION In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendment.

The State official had no comments. ENVIRONMENTAL CONSIDERATION The amendment changes a requirement with respect to installation or use of a facility's components located within the restricted area as defined in 10 CFR Part 20 or changes a surveillance requirement.

The NRC staff has determined that the amendments involve 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 NRC has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (75 FR 23814; May 4,2010). Accordingly, the amendments meet 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 amendments. 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) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public. REFERENCES TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee RITSTF Initiative 5b," March 18, 2009. (ADAMS Accession No. ML090850642).

-15 NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 58, Informed Method for Control of Surveillance Frequencies," April 2007. (ADAMS Accession No. ML071360456). Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications," August 1998. (ADAMS Accession No. ML003740176). Regulatory Guide 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 1, January 2007. (ADAMS Accession No. ML070240001). Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Informed Decisions on Plant-Specific Changes to the Licensing 8asis," NRC, Revision 1, November 2002. (ADAMS Accession No. ML023240437). ASME PRA Standard ASME RA-Sb-2005, "Addenda to ASME RA-S-2002, "Standard for Probabilistic Risk Assessment for Nuclear Power Plant Application." NEI 00-02, Revision 1 "Probabilistic Risk Assessment (PRA) Peer Review Process Guidance, Revision 1, May 2006. (ADAMS Accession No. ML06151 0621). NEI 05-04, "Process for Performing Follow-On PRA Peer Reviews Using the ASME PRA Standard," Revision 0, August 2006. J. L. Hansen to U. S. NRC, "Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)," February 15,2010. (ADAMS Accession No. ML 100470787). J. L. Hansen to U. S. NRC, "Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control -RITSTF Initiative 58", (TAC No. ME3332)," May 21, 2010. (ADAMS Accession No. ML 101450001). "Safety Goals for the Operation of Nuclear Power Plants; Policy Statement; Correction and Republication," (51 FR 30028, August 21, 1986; "Safety Goal Policy Statement").

Principal Contributor:

A. Howe, NRRIDRA Date of issuance:

February 15, 2011 February 15, 2011 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 CLINTON POWER STATION, UNIT NO.1-ISSUANCE OF AMENDMENT NO. 192 RE: TECHNICAL SPECIFICATION CHANGE FOR THE RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS BASED ON TECHNICAL SPECIFICATION TASK FORCE (TSTF)-425 (TAC NO. ME3332) Dear Mr.

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the Amendment No. 192 to Facility Operating License No. NPF-62 for the Clinton Power (CPS), Unit No.1. The amendment is in response to your application dated February 15, (Agencywide Documents Access and Management System (ADAMS) Accession ML 100470787), as supplemented by letter dated May 21, 2010 (ADAMS Accession ML The amendment relocates selected Surveillance Requirement frequencies from the technical specifications (TSs) to a licensee-controlled program. This change is based on NRC-approved industry TSTF change TSTF-425, "Relocate Surveillance Frequencies Licensee Control-Risk Informed Technical Specification Task Force Initiative 5b," Revision (ADAMS Accession Package No.

A copy of the Safety Evaluation is also enclosed.

The Notice of Issuance will be included in Commission's next biweekly Federal Register Sincerely, IRA! Nicholas J. Difrancesco, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-461

Enclosures:

1. Amendment No. 192 to NPF-62 2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL3-2 RlF RidsOgcRp Resource RidsNrrLASRohrer Resource RidsNrrDirsltsb Resource RidsNrrPMClinton Resource RidsNrrDorlLpl3-2 Resource RidsNrrDorlDpr Resource RidsNrrRgn3MailCenter Resource RidsAcrsAcnw_MailCTR Resource ADAMS Accession no*.. ML 102380477 NRR-058 OFFICE LPL3-2/PM LPL3-2/LA NRR/APLA DIRSIITSB/BC OGC LPL3-2/BC LPL3-2/PM NAME NDiFrancesco Harris/Rohrer DHarrison*

REiliott DRoth RCarlson IfEBrown for) NDiFrancesco DATE 01/12/11 01/19/11 06/10/10 01/13/11 02/04/11 2/15/11 2/15/11 OFFICIAL RECORD COpy

v t e Letter Sequence Approval
TAC:ME3332, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Approved, Closed)
Initiation Request Acceptance Administration Questions 12 April 2010 22 April 2010 Answers 21 May 2010 Results Approval, Approval Other:
MONTHYEAR2010-04-22 [Table View]

ML102380477

Text

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

Enclosures:

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