NMP1L3248, Supplement to the Response to Request for Additional Information by the Office of Nuclear Reactor Regulation to Support Review of Nine Mile Point Nuclear Station, Unit 1, License Amendment Request to Apply TSTF-542, Revision 2, Reactor Pre

Supplement to the Response to Request for Additional Information by the Office of Nuclear Reactor Regulation to Support Review of Nine Mile Point Nuclear Station, Unit 1, License Amendment Request to Apply TSTF-542, Revision 2, Reactor Pres

ML18306A774
Person / Time
Site:	Nine Mile Point
Issue date:	11/02/2018
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2017-LLA-0426, NMP1L3248
Download: ML18306A774 (32)

Text

200 Exelon Way Exelon Generation@ Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 NMP1L3248 November 2, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 NRC Docket No. 50-220

Subject:

Supplement to the Response to Request for Additional Information by the Office of Nuclear Reactor Regulation to Support Review of Nine Mile Point Nuclear Station, Unit 1, License Amendment Request to Apply TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control

References:

1. Letter from J. Barstow (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request-Revise Technical Specifications to Apply TSTF-542, 'Reactor Pressure Vessel Water Inventory Control,' Revision 2," dated December 15, 2017

2. Email from M. Marshall (Senior Project Manager, U.S Nuclear Regulatory Commission) to R. Reynolds (Exelon), "Nine Mile Point, Unit 1-Request for Additional Information Regarding Reactor Pressure Vessel Water Inventory Control License Amendment request (L-2017-LLA-0426}," dated August 15, 2018

3. Letter from J. Barstow (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information by the Office of Nuclear Reactor Regulation to Support Review of Nine Mile Point Nuclear Station, Unit 1, License Amendment Request to Apply TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control," dated October 1, 2018 By letter dated December 15, 2017 (Reference 1), Exelon Generation Company, LLC (Exelon) requested to change the Nine Mile Point Unit 1 (NMP1) Technical Specifications (TS). The proposed amendment request would apply Technical Specification Task Force (TSTF)-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

U.S. Nuclear Regulatory Commission Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Docket No. 50-220 November 2, 2018 Page 2 A public meeting was held on August 7, 2018, between Exelon and the NRC to discuss the license amendment request to revise the NMP1 TS by replacing existing requirements related to "operations with a potential for draining the reactor vessel" with new requirements on reactor pressure vessel water inventory control with a focus on the proposed technical specifications mark-ups provided in Reference 1.

On August 15, 2018 (Reference 2), the NRC identified areas where additional information was necessary to complete the review. A public meeting was held on September 13, 2018, to discuss the planned RAI response with the NRC Staff.

On October 1, 2018, Reference 3 was submitted in response to the questions of Reference 2. to this letter contains a supplement to the NRC's request for additional information. Attachment 2 to this letter contains the marked-up TS and TS Bases pages supporting the supplemental information. This supplemental information was discussed with the NRC during the public meeting held on October 18, 2018. Attachment 3 contains the clean TS pages supporting the supplemental information.

Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference 1. The supplemental information attached to this letter does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Furthermore, the supplemental information attached to this letter does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no commitments contained in this response.

If you should have any questions regarding this submittal, please contact Ron Reynolds at 610-765-5247.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of November 2018.

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James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC : Supplement to Response to Request for Additional Information : Revised TS and TS Bases Markup Pages : Revised TS Clean Pages

U.S. Nuclear Regulatory Commission Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Docket No. 50-220 November 2, 2018 Page 3 cc: USNRC Region I Regional Administrator w/attachments USN RC Senior Resident Inspector - NMP USNRC Project Manager, NRA - NMP A. L. Peterson, NYSERDA

ATTACHMENT 1 Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 NRC Docket No. 50-220 Supplement to Response to Request for Additional Information

Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Page 1 of 12 Docket No. 50-220 The following RAls are addressed in this supplement and reflect the information as a result of the public meeting with the NRC on October 18, 2018.

RAI (1 )(b) - supplement to the original response.

RAI (1 )(d) - original response superseded by this supplement.

RAI (1 )(e) - original response superseded by this supplement.

RAI (4) - original response superseded by this supplement.

RAI (5) - original response superseded by this supplement.

RAI (6) - original response superseded by this supplement.

RAI (9) - supplement to the original response.

The supplemental information responses in Attachment 1 are formatted by starting with the original RAI question from Reference 2 followed by Exelon's original RAI response from Reference 3, then followed by supplemental to Exelon's original RAI response.

The revised TS and TS Bases pages in Attachment 2 are formatted to retain all previous markups as well as the new supplemental information. All new supplemental information is annotated in red text outlined in blue. Italicized notes are included on the markups to summarize the supplemental information.

RAI (1):

b) Since the NMP1 core spray design does not have channels that start an entire ECCS subsystem, as described in the TSTF-542, revision 2 bases for STS 3.3.5.2, provide technical justification for the "Manual" parameter under the "Start Core Spray Pumps" function in Proposed TS Marked-Up Tables 3.6.2m and 4.6.2m.

Original Exelon Response to RAI (1) b) The manual parameter for the NMP1 Start Core Spray pumps is removed from Tables 3.6.2.m and 4.6.2.m. The NMP1 design does not include a single button or switch to provide for a full system start. As a result of removing the Manual Parameter for Start Core Spray Pumps, the remaining parameter in Table 3.6.2m and 4.6.2m is reformatted by changing the number from (2) to (1) and deleting the conditional description, "and (1) above." This allows for the revised pages 247b and 247d to read correctly with Reactor Pressure as the required parameter. Additionally, this results in note (b) being removed from the Notes Table and on page 247b. All remaining notes are re-sequenced.

Corresponding changes are made to the TS Bases (page 248a) and included in Attachment 2 for your information.

Supplement to Original Exelon Response to RAI (1)

This information supplements the original response to RAI (1) b submitted by Reference 3.

b) Additionally, because the NMP1 design does not include a single button or switch to provide for a full system start, the wording of the re-sequenced Note (b) is revised from, "The

Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Page 2 of 12 Docket No. 50-220 Instrumentation that initiates the Core Spray System ... ," to, "The Instrumentation that allows for injection of the Core Spray System ... " This is consistent with the purpose of Open Core Spray Discharge Valves Parameter. In addition, Note (b) is relocated on Table 3.6.2m from the Parameter column to the Reactor Mode Switch Position columns to be consistent with the NMP1 Custom Technical Specification {CTS) convention.

RAI (1):

d) On Page 79a of the Proposed TS Marked-Up, Specification e of Surveillance Requirement 4.1.9 states, "Verify the required core spray subsystem actuates on a manual initiation signal, in accordance with the Surveillance Frequency Control Program." Considering that the NMP1 core spray design does not have manual initiation capability to start an entire subsystem with a manual initiation channel, please provide technical justification for Specification e.

Original Exelon Response to RAI (1) d) Specification e of Surveillance Requirement 4.1.9 is removed from page 79b. See Attachment 2 for the revised Specification 3.1.9 and 4.1.9. As described in the response to RAl(1 )(b) above, NMP1 does not have the manual initiation capability as described in TSTF-542, Rev 2.

Supplement to Original Exelon Response to RAI (1)

This response supersedes, in its entirety, the response to RAI (1) d submitted by Reference 3.

d) Specification e of Surveillance Requirement 4.1.9 is restored to page 79b and revised from its original content to state, "Verify the required Core Spray subsystem can be manually operated, in accordance with the Surveillance Frequency Control Program. Vessel spray may be excluded." NMP1 does not have the manual initiation capability as described in TSTF-542, Rev 2. The NMP1 Core Spray system is able to be manually started through the use of control switches in the main control room, as verified by the surveillance test. The revised page 79b is provided in Attachment 2.

RAI (1):

e) On page 247b of the Proposed TS Mark-Up, the Table 3.6.2m parameter, "Reactor Pressure and (1) above," listed under Open Core Spray Discharge Valves has "1 per pump" in the columns for "Minimum No. of Tripped or Operable Trip Systems" and "Minimum No. of Operable Instrument Channels per Operable Trip System." This parameter originated from Table 3.6.2d, which has "2" in the same columns. This requirement is similar to the TSTF-542 standard technical specification {STS) Table 3.3.5.2-1 Function 1.a, Core Spray -

Reactor Steam Dome Pressure - Low (Injection Permissive). This function's mode 4 and 5

Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Page 3 of 12 Docket No. 50-220 requirements were moved from STS Table 3.3.5.1-1 Function 1.c; the same number of required channels per function were maintained in Table 3.3.5.2-1.

The LAR includes technical justifications for several variations from TSTF-542, Revision 2, but the LAR does not include a technical justification for this variation. Provide technical justification for this variation.

Original Exelon Response to RAI (1) e) The Table 3.6.2m, Parameter (2), is revised from 1 per pump to 2 for the Minimum No. of Tripped or Operable Trip Systems and for the Minimum No. of Operable Instrument Channels per Operable Trip System. This is consistent with TSTF-542, Rev 2 Table 3.3.5.2-1, Function 1.a Core Spray Reactor Steam Dome Pressure - Low (Injection Permissive). The revised Table 3.6.2m and 4.6.2m is provided in Attachment 2.

Supplement to Original Exelon Response to RAI (1)

This response supersedes, in its entirety, the response to RAI (1) e submitted by Reference 3.

e) The Table 3.6.2m, Parameter (2), is revised from "1 per pump" to "2" for the Minimum No. of Tripped or Operable Trip Systems. The Minimum No. of Operable Instrument Channels per Operable Trip System is revised from "1 per pump" to "1." The configuration of the circuitry is one-out-of-two, taken twice. There are two trip systems, labeled 11 and 12. Each trip system has two channels, with only one channel required from trip system 11 (either 11-1 or 11-2), and one channel required from trip system 12 (either 12-1 or 12-2). This is consistent with TSTF-542, Rev 2, Table 3.3.5.2-1, Function 1.a, Core Spray Reactor Steam Dome Pressure - Low (Injection Permissive). The revised Table 3.6.2m and 4.6.2m is provided in Attachment 2.

RAI (4):

The licensee proposed NMP1 TS Marked-Up Tables 3.6.2m and 4.6.2m to capture the TSTF-542, Revision 2, RPVWIC instrumentation requirements. The notes for these proposed tables are similar to the TSTF-542, Revision 2 STS 3.3.5.2 conditions, required actions, and completion times. Specifically, proposed NMP1 Marked-Up Tables 3.6.2m and 4.6.2m notes (d) and (e) are similar to TSTF-542, Revision 2, STS 3.3.5.2 Conditions D and E, respectively. The LAR describes the variations from TSTF-542, Revision 2. However, the application does not contain an explanation for how the equivalents to Conditions A, 8, and C in TSTF-542, Revision 2 STS 3.3.5.2 were incorporated. The LAR includes technical justifications for several variations from TSTF-542, Revision 2, but the LAR does not include a technical justification for this variation.

Provide justification for the variation from the TSTF-542, Revision 2 conditions, required actions, and completion times.

Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Page 4 of 12 Docket No. 50-220 Original Exelon Response to RAI (4)

The proposed revision to the NMP1 TS Tables 3.6.2m and 4.6.2m are structured in the NMP1 custom technical specification format.

STS 3.3.5.2, Condition A requires entering the condition referenced in Table 3.3.5.2-1 for the channel. To be consistent with the NMP1 custom technical specification format, the notes in Table 3.6.2m and 4.6.2m have been modified to include the requirements of Condition B and C, described below. This variation is acceptable.

STS 3.3.5.2, Condition B is associated with vessel isolation and requires declaring associated penetration flow path(s) incapable of automatic isolation and calculating drain time. A note (g) has been added for Tables 3.6.2m and 4.6.2m on page 247h to perform this action. This is consistent with the format of the NMP1 custom technical specifications and is an acceptable variation. The marked-up page 247h is provided in Attachment 2.

STS 3.3.5.2, Condition C requires placing the instrument channel into trip, with a 1-hour completion time, and is associated with the water injection functions. A note (h) has been added to Notes for Tables 3.6.2m and 4.6.2m on page 247h to include this requirement. This is an acceptable variation. The marked-up page 247h is provided in Attachment 2.

Supplement to Original Exelon Response to RAI (4)

This Response supersedes, in its entirety, the response to RAI (4) submitted by Reference 3.

This Response also revises the original submittal (Reference 1), Section 2.2.5, Instrumentation Technical Specification Variations (Table 3.3.5.2-1).

The format of this supplement lists the individual TSTF-542, Revision 2, ACTION from STS 3.3.5.2, followed by how that ACTION is captured in NMP1 Tables 3.6.2m and 4.6.2m, to align to the NMP1 CTS format. Additionally, the notes for Tables 3.6.2m and 4.6.2m are updated as described below to ensure consistent implementation of the RPV WIG requirements and concept into this new instrumentation table.

Additionally, a cross-reference table of the changes to RAI (4) is included at the end of this supplemental information response starting on page 9 of 12. This cross-reference table is provided to summarize the changes and facilitate the review of the Notes for Tables 3.6.2m and 4.6.2m.

Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Page 5 of 12 Docket No. 50-220 CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.2-1 for the channel.

NMP1 implementation of Condition A:

STS 3.3.5.2, Condition A requires entering the Condition referenced in Table 3.3.5.2-1 for the channel. To be consistent with the NMP1 CTS format, the notes in Table 3.6.2m and 4.6.2m are modified to include the requirements of Conditions 8 through E directly into the table. This incorporates Condition A into the NMP1 custom format, as described for the implementation of each Condition below. This variation is acceptable.

REQUIRED ACTION COMPLETION CONDITION TIME B. As required by Required 8.1 Declare associated Immediately Action A.1 and referenced penetration flow path(s) in Table 3.3.5.2-1 incapable of automatic isolation.

AND 8.2 Calculate DRAIN TIME. Immediately NMP1 implementation of Condition 8.

STS Table 3.3.5.2-1, Condition 8, is associated with isolation of penetration flow paths credited in calculating Drain Time. For NMP1 this is addressed on page 247c for Table 3.6.2m as the parameters for Primary Coolant Isolation on a Low-Low Reactor Water Level signal for 1(a) for Cleanup isolation and 1(b) for Shutdown Cooling isolation. Note (g) was added by the RA!

response (Reference 3) to require declaring the associated penetration flow paths incapable of automatic isolation and calculating drain time. This addition of Note (g) in the RAI response (Reference 3} was incorrect and is removed in this supplement. The original submittal (Reference 1) included Note (e}, which was copied from the original NMP1 TS Table 3.6.2b.

Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Page 6 of 12 Docket No. 50-220 Note (e) was modified to include the actions of Condition B; however, it retained incorrect information from Table 3.6.2b from which it was derived. The RAI response re-sequenced Note (e) to Note (c) but did not remove the incorrect information. The re-sequenced Note (c) is revised to delete the first sentence starting, "In the cold shutdown and refueling conditions ... "

This sentence is a restatement of the applicability which is annotated on Table 3.6.2m in Note (a). This clarification was necessary when included in Table 3.6.2b but is not necessary when transferred to the new Table 3.6.2m. The re-sequenced Note (c), sub item 3, is deleted as this is not required for Condition 8. The completion time of, "Immediately," is added to re-sequenced Note (c). Additionally, re-sequenced Note (c) is revised to include the applicability Note (b) in Table 3.3.5.2-1 which states, "When automatic isolation of the associated penetration flow path(s) is credited in calculating drain time." The Condition A requirement of, "One or more channels inoperable," is also added to re-sequenced Note (c).

The application of re-sequenced Note (c) is corrected in Table 3.6.2m by applying only to Parameter (1 )(a) and (1 )(b).

In Reference 1, Note (d) was transferred from Table 3.6.2b as Note (f) to include the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> surveillance note. This 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> surveillance note is not required for the new Reactor Pressure Vessel Water Inventory Control instrumentation table and is removed. The new Note (d) in Table 3.6.2m had been incorrectly modified with the requirements of Condition 8, which are contained in Note (c), and carried forward requirements associated with Table 3.6.2b that do not align with the RPV WIG concepts per TSTF-542 and these details have been deleted. Because Notes (c) and (d) are applied to the same parameter, repeating the information in Note (d) is not necessary. The combined changes described above result in removing Note (d) from NMP1 CTS page 247g. This also negates the need to clarify the cross-reference to Specification 3.6.2a (13) provided in the response to RAI 6 of Reference 3. The TS bases pages 249 and 249a have been revised to align with these changes. Removing Note (d) results in re-sequencing the remaining notes. This is summarized in the cross-reference table at the end of the RAI (4) supplement.

The allowable value referenced in the STS Table 3.3.5.2-1 is equivalent to Set Point in the NMP1 CTS format. The surveillance requirements from STS Table 3.3.5.2-1 are reflected in NMP1 CTS Table 4.6.2m.

REQUIRED ACTION COMPLETION CONDITION TIME C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Action A.1 and referenced in Table 3.3.5.2-1.

Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Page 7 of 12 Docket No. 50-220 NMP1 implementation of Condition C.

Condition C is associated with the injection permissive instrumentation in STS Table 3.3.5.2-1.

For NMP1 CTS, this is the Parameter to Open Core Spray Discharge Valves at the appropriate Reactor Pressure. The RAI response (Reference 3) added Note (h) to Table 3.6.2m, page 247b. With this Supplement, Note (h) is changed to Note (e) since Notes (d) and (g) were deleted as explained in the description above for Implementation of Condition B. See the cross-reference table at the end of the RAI (4) supplement summarizing the note changes. The revised Note (e) on page 247h includes the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> completion time to place the channel in trip and wording changes to align with the NMP1 CTS format for consistency. Note (e) is placed in the column reflecting the Minimum number of Operable Instrument Channels to align with the convention of the NMP1 CTS. This satisfies Condition C and is an acceptable variation.

Additionally, the applicability of the injection permissive parameter is modified with Note (a) to reflect the Shutdown Condition- Cold and Refuel Condition, with cross-reference to the tables for the Shutdown Condition-Hot. The allowable value referenced in the STS Table 3.3.5.2-1 is equivalent to Set Point in the NMP1 CTS format. The surveillance requirements from STS Table 3.3.5.2-1 are reflected in NMP1 CTS Table 4.6.2m.

CONDITION REQUIRED ACTION COMPLETION TIME D. As required by Required D.1 Restore channel to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Action A.1 and referenced OPERABLE status.

in Table 3.3.5.2-1.

NMP1 implementation of Condition D.

Condition D is associated with ensuring minimum flow protection when Core Spray system initiates or the Manual Initiation action. As described in the responses to RAI (1 )(b) and RAI (2)

(Reference 3), the NMP1 design does not include the Manual Initiation function described in TSTF-542. The NMP1 design does not have a minimum flow bypass. This function is provided by a relief valve on the discharge of the Core Spray pump to provide minimum flow protection and does not have instrumentation for opening. The water is redirected back to the Torus when the relief valve opens. This is described in the NMP1 UFSAR, Chapter VII, Section 2.1. There are no instruments or channel to restore and Condition D is not implemented. This is an acceptable variation based on the NMP1 design.

Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Page 8 of 12 Docket No. 50-220 REQUIRED ACTION COMPLETION CONDITION TIME E. Required Action and E.1 Declare associated low Immediately associated Completion pressure EGGS Time of Condition C or D injection/spray subsystem not met. inoperable.

NMP1 implementation of Condition E.

Condition Eis implemented by Note (e) in Table 3.6.2m. This requirement is added to Note (e) because Condition C is the only applicable condition. The format is modified to be consistent with the NMP1 CTS format.

Surveillance Requirements for 3.3.5.2 The TSTF-542, Revision 2 Surveillance Requirements (SR) are listed below, followed by the NMP1 implementation into the CTS format. The NMP1 TS definitions for Sensor Check and Instrument Channel Test are similar in definition to the STS CHANNEL CHECK and CHANNEL FUNCTIONAL TEST, respectively. The use of the NMP1 CTS terminology is an acceptable variation.

SR 3.3.5.2.1, Perform CHANNEL CHECK is applicable to STS Table 3.3.5.2-1 Function 1.a for Core Spray injection permissive, Function 3.a for AHR System Isolation and Function 4.a for RWCU System Isolation. For NMP1 CTS format, this is applied to Table 4.6.2m Open Core Spray Discharge Valves parameter as a Sensor Check (Page 247d) and to the Primary Coolant Isolation Parameter for Low-Low Reactor Water Level (Page 247e). The Manual Isolation Parameter does not require a sensor and therefore the Sensor Check SR is not applicable. The Sensor Check associated with the Open Core Spray Discharge Valve parameter aligns with the discussion provided in the supplemental response to RAI (3).

SR 3.3.5.2.2, Perform CHANNEL FUNCTIONAL TEST is applicable to STS Table 3.3.5.2-1 Function 1.a for Core Spray injection permissive, Function 3.a for AHR System Isolation and Function 4.a for RWCU System Isolation. For NMP1 CTS format, this is applied to Table 4.6.2m Open Core Spray Discharge Valves parameter as an Instrument Channel Test (Page 247d) and to the Primary Coolant Isolation Parameters for Low-Low Reactor Water Level and Manual (Page 247e).

SR 3.3.5.2.3, Perform LOGIC SYSTEM FUNCTIONAL TEST, is applicable to STS Table 3.3.5.2-1 for the Manual Initiation Function of Core Spray or Low Pressure Coolant Injection. As discussed in the response to RAI 1 in Reference 3, this function does not apply to the NMP1 design; therefore, this SR is not required for NMP1.

Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Page 9 of 12 Docket No. 50-220 Cross-Reference Summary for Changes to Notes for Tables 3.6.2m and 4.6.2m This table uses columns to summarize the note changes for Tables 3.6.2m and 4.6.2m. The original submittal (Reference 1) included 7 notes (a through g). This supplement to Reference 3 results in 5 notes (a through e).

Reference Reference 3 submittal Supplement to Reference 3 Final 1 submittal notes a a- no change a - no change a b b - deleted by RAI 1(b) response c c - becomes (b) with RAI 1(b) response b - no change from Reference 3 b d d - deleted by RAI 1(c) response e e - becomes (c) due to (b) and (c) c - no change from Reference 3 c deleted.

f f - becomes (d) due to (b) and (c) d - deleted by RAI (4) deleted. supplement described above g g - becomes (e) due to (b) and (c) e- deleted by supplement to RAI deleted. (5) described below f - added by RAI (8) response f - becomes (d) d g - added by RAI (4) response g - deleted by RAI (4) supplement described above h - added by RAI (4) response h - becomes (e) e RAI (5):

The LAA for NMP1 proposed that Surveillance Requirements Sensor Check, Instrument Channel Test, and Instrument Channel Calibration are to be included in Proposed TS Marked-Up 3.6.2m and 4.6.2m. These SRs differ from the STS SR wording in the equivalent section, TSTF-542, Revision 2 STS 3.3.5.2, of channel check, channel functional test, and logic system functional test. The NMP1 definitions for sensor checks and instrument channel tests are similar to the STS definitions for channel checks and channel functional tests, respectively.

However, the NMP1 definition for an instrument channel calibration does not align with the STS definition for a logic system functional test; it is similar to the STS definition for a channel

Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Page 10 of 12 Docket No. 50-220 calibration. The LAR includes technical justifications for several variations from TSTF-542, Revision 2, but the LAR does not include technical justifications for these variations.

Please provide technical justification for the following variations from TSTF-542, Revision 2 in NMP1 Proposed TS Marked-Up Tables 3.6.2m and 4.6.2m:

a) inclusion of an Instrument Channel Calibration SR, and b) omission of an equivalent to the TSTF-542, Revision 2 STS SR 3.3.5.2.3, "Logic System Functional Test."

Exelon Response to RAI (5)

The current NMP1 Custom Technical Specifications do not include Logic System Functional Tests as a requirement; therefore, the Logic System Functional Test SR was not included in the TSTF-542 submittal dated December 15, 2017. The SRs used are consistent with the current NMP1 Custom Technical Specification requirements. The Instrument Channel Calibration is the method used to ensure the circuitry performs as designed and the function is performed. The terminology used in the proposed TS change is consistent with the current NMP1 TS and the testing requirements in the NMP1 license basis. This variation is acceptable and supplements the discussion in Section 2.2.5.1 of Reference 1.

Supplement to Original Exelon Response to RAI (5)

This response supersedes, in its entirety, the response to RAI (5) submitted by Reference 3.

a) The NMP1 CTS SR for Instrument Channel Calibration is not being applied to the new surveillances added to Table 4.6.2m. See the attached TS markup pages 247d and 247e which this revision. This change aligns with the technical evaluation in TSTF-542, Revision 2, Section 3.3.3, which does not require channel calibrations in the cold shutdown or refuel conditions. This change also results in removing Note (e) associated with Table 4.6.2m. Note (e) was relabeled in Reference 3 and was originally proposed as Note (g) in Refence 1, Section 2.2.5.1. Note (e) is not required because the Instrument Channel Calibration are not required for Table 4.6.2m.

b) The logic system functional test does not apply to NMP1 CTS as described in the supplemental response to RAI (4) above.

RAI (6):

In the LAR, the interrelationship between some related specifications in the Proposed TS Marked-Up is unclear. For example, in Tables 3.6.2m and 4.6.2m, there are several table notes that state, " ... take the ACTION required by Specification 3.6.2a for that Parameter." However, under Specification a of LCO 3.6.2 in the Proposed TS Marked-Up, the actions would require entering the appropriate actions for inoperable core spray subsystems under LCO 3.1.4, which

Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Page 11 of 12 Docket No. 50-220 is only applicable during the "Power Operating Condition or Shutdown Condition - Hot," instead of LCO 3.1.9, which would apply when the reactor coolant temperature is less than or equal to 212 degrees Fahrenheit.

Verify the references related specifications are "linked" to the appropriate specification.

Exelon Response to RAI (6)

When directed to enter Specification 3.6.2a, Sub-Section (13) of 3.6.2a applies because Sub-section (13) is for RPV WIG and directs the operator to Specification 3.1.9 for actions. The Notes for Tables 3.6.2m and 4.6.2m are revised to reference LCO 3.6.2.a(13). The marked-up Notes for Tables 3.6.2m and 4.6.2m are provided in Attachment 2.

Supplement to Original Exelon Response to RAI (6)

This response supersedes, in its entirety, the response to RAI (6) submitted by Reference 3.

The information provided in Reference 3 included new Note (d) in Table 3.6.2m. This Note (d) incorrectly maintained requirements associated with Table 3.6.2b that do not align with the RPV WIG concepts described in TSTF-542. Therefore, Note (d) is deleted and remaining notes on Table 3.6.2m are re-sequenced. This change is discussed in more detail in the supplemental response to RAI (4) above. This change also eliminates the need to clarify the cross-reference to Specification 3.6.2a (13) as provided in the response to RAI (6) of Reference 3. The annotation of "(13)" is removed from page 247g for the Notes for Table 3.6.2m and 4.6.2m.

The re-sequenced Note (d) and Note (e) provide linkage to Specification 3.1.9 as required by STS Table 3.3.5.2, Table 1.

RAI (9):

TSTF-542, Revision 2 states the following (emphasis added):

[ ... ] an additional method of water injection, to augment the newly required ECCS subsystem, is also required when the Drain Time is less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />". This is especially true for action D, "Drain time< 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

In the LAR, LCO 3.1.9 in the Proposed TS Marked-Up would maintain only one core spray subsystem operable. The application does not contain an explanation for what additional method(s) of water injection would be used especially when drain time is less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Describe the additional method(s) of injection that would be used when taking the required action described in Specification e(1) of Proposed TS Marked-Up 3.1.9. In the description, state whether the additional method(s) of injection is able to operate without offsite electrical power.

Exelon Response to RAI (9)

Supplement to Response to Request for Additional Information TSTF-542, Reactor Pressure Vessel Water Inventory Control Page 12 of 12 Docket No. 50-220 Specification 3.1.9 is revised to include the requirement to operate without offsite electrical power. This is consistent with the NMP1 Custom Technical Specification format. The marked-up LCO 3.1.9 (page 79b) is included in Attachment 2.

Supplement to Original Exelon Response to RAI (9)

This response supersedes, in its entirety, the response to RAI (9) submitted by Reference 3:

Specification 3.1.9 is revised to include the requirement to operate without offsite electrical power. This is consistent with the NMP1 Custom Technical Specification format. The marked-up LCO 3.1.9 (page 79b) is included in Attachment 2.

There are several additional methods of water injection that can be used during a loss of offsite power and if Core Spray is not available. The water injection sources powered by the station Emergency Diesel Generators (EDGs) do not require loading shedding actions. The order is based on using reactor water quality sources first. The Control Rod Drive (CRD) system flow would be the first system selected for drain times less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

1. CRD System flow can be raised to provide RPV level control. The CRD pumps are powered by the station EDGs. Two CRD pumps can be operated in parallel for maximum system flow.

2. An alternate high-pressure water injection to the RPV can be accomplished through the Liquid Poison Pumps taking suction from the Liquid Poison Tank. The Liquid Poison Pumps are powered by the station EDGs.

3. An alternate high-pressure water injection to the Reactor Pressure Vessel (RPV) can be accomplished through the Liquid Poison Pumps taking suction from the Demineralized Water Tanks. The Liquid Poison Pumps are powered by the station EDGs.

4. The Containment Spray Raw Water to Core Spray System can be aligned to add water to Containment through the Core Spray header using a Containment Spray Raw Water Pump powered by the station EDGs.

5. The Fire Water System can be aligned to inject water into the RPV through the Reactor Feedwater System piping using the diesel driven fire pump. The diesel driven fire pump is used without off-site electrical power.

6. Portable FLEX pumps can be relocated as needed from their normally stored position and aligned to inject water into the RPV. The FLEX pumps are diesel driven.

7. Portable 8.5.b pumps can be relocated as needed from their normally stored position to inject water into the RPV. The 8.5.b pumps are diesel driven.

ATTACHMENT 2 Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 NRC Docket No. 50-220 Supplement to Response to Request for Additional Information Revised TS and TS Bases Markup Pages TS Marked-up Pages 79b 247b 247c 247f 247g 247h TS Bases Marked-up Pages (for information only) 249 249a

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT

d. If drain time < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and ;;:: 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, within 4 d. Verify each valve credited for automatically hours perform the following actions: isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal, in accordance with the (1) Verify secondary containment boundary is capable of being established in less than the Surveillance Frequency Control Program . IRAI 1 (d) I drain time.

and / &.- Verify the required core spray subs~R'I actua; ;*

(2) Verify each secondary containment penetration on a R'lanual initiation signal , in accordance 'Nith flow path is capable of being isolated in less \. ~~ Surveillance frequency Control PrograR'I .

than the drain time, ~ssels~ ~

and (3) Verify one RBEVS is capable of being placed in operation in less than the drain time.

'\

I

e. If drain time < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, immediately perform the e . Verify the required core spray following actions:

!RAIS 9 ancflo I subsystem can be manually (1) Initiate action to establish an additional method of operated , in accordance with the water injection with water sources capable without offsite Surveillance Frequency Control of maintaining RPV water level above -1 O electrical power Program . Vessel spray may be inches indicator scale for ;;:: 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. excluded .

and (2) Initiate action to establish secondary containment boundary, Supplement Note:

and Specification 4. 1.9e is reinserted and (3) Initiate action to isolate each secondary revised per Supplemental response to containment penetration flow path or verify it can RAJ 1(d).

be manually isolated from the control room. and (4) Initiate action to verify one RBEVS is capable of being placed in operation.

AMENDMENT NO. 79b

Reviewer notes:

Manual Parameter removal RAls 1(b) and 2 TABLE 3.6.2m Notes (b) & (d) removed per RAls 1(c) and RPV WATER INVENTORY CONTROL INSTRUMENTATION 1(f) - changed note (c) to (b)

Note (f) added per RAI 8. Limiting Condition for Operation Note (h) adder per RAI 4 Change from 1 per pump to 2 per RAI 1(e) Minimum No. of Operable Instrument Reactor Mode Switch Minimum No. Channels per Position in Which of Tripped or Operable {ft) Function Must Be Parameter Operable Trip Systems Trip Svstem Set Point Operable s::

a.

0 "C Qi  :::s

s  :::s ~ s::

.c: (I) C'll  :::s 0::: 0:::

START CORE SPRAY PUMPS (s}

~ M:mual 4- 4-(d} ~~

OPEN CORE SPRAY DISCHARGE VALVES AA ~~ I ..:-1 l(d)(e)

(~ Reactor Pressure and (1) above. ~~ 1 DOF Dl:lffiD (d} ~ ~ 365 psig (al(b) (a) (b)

~

ISupplement notes: -

Minimum No. of Operable Instrument Channels per Operable Trip System AMENDMENT NO. changed from 2 to 1 per Supplement Response to RA/ 1(e). 247b Note (f) changed to (d) and Note (h) changed to (e). Notes (b}, (d) and (e) relocated to align with the existing format of the NMP1 CTS for consistency per Supplemental R_e_sp _ o_n_s_e_t_o _R_A_l_(4_J_. _ _ _ _ __ __,

1

Supplement Notes:

Notes (d) and (g) removed and Reviewer notes: Note (c) corrected per Notes changes per RAls 1(b), 1(c) and 1(f) TABLE 3.6.2m Supplemental Response to RAJ (4) from (e) to (c) and from (f) to (d) .

RPV WATER INVENTORY CONTROL INSTRUMENTATION Limiting Condition for Operation Minimum No. of Operable Instrument Reactor Mode Switch Minimum No. Channels per Position in Which of Tripped or Operable (g) Function Must Be Parameter Operable Trip Systems Trio Svstem Set Point Operable c:

=

0 c.

E::;:,

Q)

.c Q)

~

cu c:

en a:: en a::

PRIMARY COOLANT ISOLATION (1) Low-Low Reactor Water Level (a) Cleanup 2 2mJ~ "- 2: 5 inches (Indicator Scale)

(a) (a)

(b) Shutdown Cooling 2(e) 1-(e) 2~ 1(c)ffl] ) 2: 5 inches (Indicator Scale)

(a) (a)

(2) Manual 2 1 --- (a) (a)

AMENDMENT NO. 247c

Reviewer notes:

Manual Parameter removal RAls 1(b) and 2 Notes changes per RAls 1(b), 1(c) and 1(f) from (g) to (e)

TABLE 4.6.2m Remove Sensor Check SR per RAI 3 RPV WATER INVENTORY CONTROL INSTRUMENTATION Surveillance Requirement Instrument Instrument Channel Parameter Sensor Check Channel Test Calibration START CORE SPR.A.Y PUMPS w Man1e1a l ~ NGte .:µ9} NGte .:µ9}

OPEN CORE SPRAY DISCHARGE VALVES I.

(2)~ Reactor Pressure amJ ~fotA 1 1--- I Note1 ~ Nole 1<wl(e)l (1) above

~

1 Supplement notes:

Removed note (e) and requirement for Instrument Channel Calibration per RA/ (5) supplement.

I AMENDMENT NO. 247d

Reviewer notes:

Notes changes per RAls 1 (b), 1(c) and 1(f) from (g) to (e)

TABLE 4.6.2m RPV WATER INVENTORY CONTROL INSTRUMENTATION Surveillance Requirement Instrument Instrument Channel Parameter Sensor Check Channel Test Calibration PRIMARY COOLANT ISOLATION (Cleanup and Shutdown Cooling) \--........... _r-----

(1) Low-Low Reactor Water Note 1 Note 1 1~~ 1 ~fote 1Cgl [EB )

Level (2) Manual Note 1 ~-__/

jSupplement notes:

Removed note (e) and requirement for Instrument Channel Calibration per RA/ (5) supplement.

AMENDMENT NO. 247e

Reviewer notes: Supplement Notes:

Notes (b) & (d) removed per RAls 1(c) and 1(f), remaining notes re-sequenced. Revised Note (c) per Supplemental Response to RA/ (4).

NOTES FOR TABLES 3.6.2m AND 4.6.2m (a) The Parameters in this table are only applicable in the Shutdown Condition - Cold and Refuel. See Table 3.6.2b or Table 3.6.2d for Parameter applicability in the Shutdown Condition - Hot.

{b)

~ {G} ystem is not required to be operable if there is no fuel in the reactor vessel.

~ A channel may be placeG-in an inoper:atlle status for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for required swveillances 1J.<ithout placing the Trip System in the tripped condition provided at least one Operable lnstrnment Channel in the same Trip System is monitoring that parameter.

\l!Jith the number of Operable channels less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System requirement:

~ \"Ath one channel inoperable, place the inoperable channel in the tripped condition 1.vithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or take the ACTION required by Specification 3.6 .2a for that Parameter.

2.. \l\Jjth more than one channel inoperable, take the ACTION required by Specification 3.6.2a for that Parameter.

j(c) l{e} ( In the cold shutdown and refueling conditions, only one Operable Trip System is required provided shutdow;c_ o(;fulg s~ity is maintained.

!Applicable when automatic isolation of the associated penetration flow path(s) is credited in calculating drain time. __J

\l\Jjth one of the two required Operable Channels in the required Trip System not operable, place the inoperable channel in the tripped condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, otherwise With one or more channels inoperable, immediately 1.

~

2.

and Calculate drain time, .

~""='"""'."'""."""'""==~::,_----=-~~-..:=====:----.

Declare associated penetration flow path(s) incapable of automatic isolation, *-

~ a,. lmmAdi:::itAl 11 initi:::itA :::idion to rAi:;tnrA thA c:h:::innAI to onAr:::ihlA

- - ---- - - -----*.1 ------- - - - - -*- - - - - . - ---*- ***- -**-****-* *- -r-*--*- i:;t:::itui:;

~

b Immediately initiate action to isolate the shutdown cooling system)

AMENDMENT NO. 247f

Reviewer notes:

Notes (b) & (d) removed per RAls 1(c) and 1 (f), remaining notes re-sequenced .

Subsection (13) added per RAI 6.

NOTES FOR TABLES 3.6.2m AND 4.6.2m Trip System requirement f.or one trip system:

\

.t,. Declare associated penetration flm¥ path(s) incapable of automatic isolation ,

aRG

~ Calculate drain time, aRG

~ Place th& inoperable channel(s) in the tripped condition within ,

a.,. 12 hmns f.or Parameters common to SCRAM Instrumentation, and

~

lh 24 hoy"' for Paramole'8 not oommono, t SCRAM j£!

.. Instrumentation .

~ Take the ACTION reqYir:ed by Spec1fica . rion 3.6 .2a ~ that p eter.

VVith the nYmber of Operable Channels one less than required by the MinimYm Number of Operable lnstrnment Channels per Operable Trip System reqYirement for both trip systems: \I

.t,. Declare associated penetration flo path(s) incapable of aYtomatic isolation ,

)

1A' am.I

~ Calculate drain time, aAd

3. Place the inoperable channel(s) in one trip system in the tripped condition within one hour, aRG 4:- Place the inoperable channel(s) in the remaining trip system in the tripped condition within ,

\

a.,. 12 hnurs: for P:=m~mAlArs:

c:nmmnn to

-- * * -I SCRA~4 lns:tmm,mt:::ition

.. - - - * ... OO WO

md 000--.0- 0* 0-* <*-'-*- *** -**-

&.- 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> fur Parameters not common to SCRAM Instrumentation,

~

~ .

& Take the ACTION reqYired by Specification 3.6 .2a for that Parameter. ,,. - - - - - - - - - - -

1Supplement notes:

Note (d) deleted per Supplemental response to RA/ (4). Also removed (13) annotation AMENDMENT NO. added in RA/ (6) per Supplemental Response to RA/ (6). 2479

Reviewer notes:

Notes (b) & (d) removed per RAls 1(c) and 1(f), remaining notes re-sequenced .

Note (f) added per RAI 8.

Notes (g) and (h) added per RAI 4.

NOTES FOR TABLES 3.6.2m AND 4.6.2m

~ {g)

The trig circuit 'A'ill be calibrated and tested in accor:dance *nith the Surveillance Freauenc11 Control Proaram. the primarv sensor will be

• * * *yste= C~re Spr~ required to :e ~p=:-per 1: Surveillance intervals are specified in the Surveillance Frequency Control Program unless otherwise noted in Table 4.6.2m.

Specification 3.1.9, Reactor Pressure

~

~

Vessel (RPV) Water Inventory Control.

I (g) VVith one or more channels inoperable, declare the associated penetration itow paths incapable of alttomatic iselatiefl afld calculate draifl time.

~(e) With the number of Operable channels less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System requirement, place the inoperable channel in a tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or Immediately, declare the associated Core Spray subsystem per Specification 3.1.9 inoperable.

~

- - ,,,..- .,,,.,.. ----- --~-

!Supplement notes:

Deleted Notes (e) and (g) which were added per response to RA/ (4) and relabeled Note (f) to (d) and Note (h) changed to Note (e) to maintain the number sequence, and incorporated the Actions from STS Table 3.3.5.2-1 into Note (e) per Supplemental Response to RA/ (4). The wording in the resequenced Note (e) is modified to be consistent with the NMP1 CTS formatting and phrasing.

AMEl'>IDMENT NO. 247h

AITACHMENT3 Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 NRC Docket No. 50-220 Supplement to Response to Request for Additional Information Revised TS Clean Pages TS Clean Pages 79b 247b 247c 247d 247e 247f

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT

d. If drain time <36 hours and ~8 hours, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> d. Verify each valve credited for automatically perform the following actions: isolating a penetration flow path actuates to the isolation position on an actual or simulated (1) Verify secondary containment boundary is isolation signal, in accordance with the capable of being established in less than the Surveillance Frequency Control Program.

drain time,

e. Verify the required core spray subsystem can be and manually operated, in accordance with the (2) Verify each secondary containment penetration flow Surveillance Frequency Control Program. Vessel path is capable of being isolated in less than the spray may be excluded.

drain time, and (3) Verify one RBEVS is capable of being placed in operation in less than the drain time.

e. If drain time <8 hours, immediately perform the following actions:

(1) Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level above -1 O inches indicator scale for~ 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> without offsite electrical power, and (2) Initiate action to establish secondary containment boundary, and (3) Initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room, and (4) Initiate action to verify one RBEVS is capable of being placed in operation.

AMENDMENT NO. 79b

TABLE 3.6.2m RPV WATER INVENTORY CONTROL INSTRUMENTATION Limiting Condition for Operation Minimum No. of Operable Instrument Reactor Mode Switch Minimum No. Channels per Position in Which of Tripped or Operable Function Must Be Parameter Operable Trip Systems Trip System Set Point Operable c:

~

-0 "C

I

.c:

en a;

I 1i; a::: -

c.

I t::

ca en c:

I a:::

OPEN CORE SPRAY DISCHARGE VALVES (1) Reactor Pressure 2 1(d)(e) ~ 365 psig (a)(b) (a)(b)

AMENDMENT NO. 247b

TABLE 3.6.2m RPV WATER INVENTORY CONTROL INSTRUMENTATION Limiting Condition for Operation Minimum No. of Operable Instrument Reactor Mode Switch Minimum No. Channels per Position in Which of Tripped or Operable Function Must Be Parameter Operable Trip Systems Trip System Set Point Operable c:

3:

-0 "C

s

.c UJ a;

s

'Q; 0:::

c.

s

~

ns UJ c:

s 0:::

PRIMARY COOLANT ISOLATION (1) Low-Low Reactor Water Level (a) Cleanup 2 2(c) <!: 5 inches (a) (a)

(Indicator Scale)

(b) Shutdown Cooling 2 2(c) <!: 5 inches (a) (a)

(Indicator Scale)

(2) Manual 2 1 - (a) (a)

AMENDMENT NO. 247c

TABLE 4.6.2m RPV WATER INVENTORY CONTROL INSTRUMENTATION Surveillance Requirement Instrument Instrument Channel Parameter Sensor Check Channel Test Calibration OPEN CORE SPRAY DISCHARGE VALVES (1) Reactor Pressure Note 1 AMENDMENT NO. 247d

TABLE 4.6.2m RPV WATER INVENTORY CONTROL INSTRUMENTATION Surveillance Requirement Instrument Instrument Channel Parameter Sensor Check Channel Test Calibration PRIMARY COOLANT ISOLATION (Cleanup and Shutdown Cooling)

(1) Low-Low Reactor Water Note 1 Note 1 Level (2) Manual Note 1 AMENDMENT NO. 247e

NOTES FOR TABLES 3.6.2m AND 4.6.2m (a) The Parameters in this table are only applicable in the Shutdown Condition - Cold and Refuel. See Table 3.6.2b or Table 3.6.2d for Parameter applicability in the Shutdown Condition - Hot.

(b) The instrumentation that allows for injection of the Core Spray System is not required to be operable if there is no fuel in the reactor vessel.

(c) Applicable when automatic isolation of the associated penetration flow path(s) is credited in calculating drain time. With one or more channels inoperable, immediately

1. Declare associated penetration flow path(s) incapable of automatic isolation, and

2. Calculate drain time.

(d) Associated with the subsystem of Core Spray required to be Operable per Specification 3.1.9 Reactor Pressure Vessel (RPV) Water Inventory Control.

(e) With the number of Operable channels less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System, place the inoperable channel in a tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or Immediately, declare the associated Core Spray subsystem per Specification 3.1.9 inoperable.

Note 1: Surveillance intervals are specified in the Surveillance Frequency Control Program unless otherwise noted in Table 4.6.2m.

AMENDMENT NO. 247f