L-24-267, Vistra Operations Company LLC (Vistra Opco) Application to Revise Technical Specifications to Implement an Online Monitoring Program

Vistra Operations Company LLC (Vistra Opco) Application to Revise Technical Specifications to Implement an Online Monitoring Program

ML25191A246
Person / Time
Site:	Beaver Valley, Davis Besse, Perry, Comanche Peak
Issue date:	07/10/2025
From:	John Lloyd Vistra Operations Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-24-267, CP-202400457, TXX-24082
Download: ML25191A246 (1)

Text

6555 SIERRA DRIVE IRVING, TEXAS 75039 o 214-812-4600 VISTRACORP.COM Jay Lloyd Vice President, Nuclear Engineering P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 L-24-267 CP-202400457 TXX-24082 July 10, 2025 ATTN: Document Control Desk Ref 10 CFR 50.90 U. S. Nuclear Regulatory Commission 10 CFR 50.91 Washington, DC 20555-0001 Beaver Valley Power Station (BVPS)

Docket Nos. 50-334 and 50-412 Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446 Davis-Bessie Nuclear Power Station (DBNPS)

Docket No. 50-346 Perry Nuclear Power Plant (PNPP)

Docket No. 50-440

Subject:

Application to Revise Technical Specifications to Implement an Online Monitoring Program

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Vistra Operations Company LLC (Vistra OpCo) is submitting a request for an amendment to the Technical Specifications (TS) for Beaver Valley Power Station (BVPS), Units 1 and 2, Comanche Peak Nuclear Power Plant (CPNPP), Units 1 and 2, Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), and Perry Nuclear Power Plant, Unit 1 (PNPP).

The proposed amendment would modify TS Definitions and add a new Online Monitoring Program. Vistra OpCo proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results.

The enclosure provides a description and assessment of the proposed changes.

Vistra OpCo requests approval of the proposed amendment within 6 months of completion of the NRCs acceptance review. Once approved, the amendment would be implemented within 90 days after issuance of the amendment.

There are no new regulatory commitments made in this submittal.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State Officials.

L-24-267 Page 2 of 2 Should you have any questions, please contact Nie Boehmisch at (254) 897-5064 or nicholas.boehmisch@luminant.com.

I state under penalty of perjury that the foregoing is true and correct.

Executed on July 10, 2025.

Enclosure:

Evaluation of the Proposed Change cc:

NRC Regional Administrator, Region I NRC Regional Administrator, Region III NRC Regional Administrator, Region IV NRC Project Manager, Fleet NRC Senior Resident Inspector BVPS NRC Senior Resident Inspector, CPNPP NRC Senior Resident Inspector, DBNPS NRC Senior Resident Inspector, PNPP Director BRP /DEP Site BRP /DEP Representative Sincerely, Jay Ll/&du1'f, 2025 14:18 CDT)

Jay Lloyd Environmental Monitoring & Emergency Response Manager, Texas Department of State Health Services Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board

Enclosure to L-24-267 Page 1 of 28 Evaluation of Proposed Change

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

2.1 Background

2.2 System Design and Operation 2.3 Reason for the Proposed Change 2.4 Description of Proposed Change

3. TECHNICAL EVALUATION 3.1 OLM Implementation Process Development 3.2 OLM Program Implementation 3.3 OLM Noise Analysis Implementation 3.4 Application Specific Action Items from AMS TR

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination Analysis 4.4 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS:

1.

Beaver Valley Power Station Technical Specification Mark-ups

2.

Beaver Valley Power Station Technical Specification Clean Typed

3.

Beaver Valley Power Station Technical Specification Bases Mark-ups (Information only)

4.

Comanche Peak Nuclear Power Plant Technical Specification Mark-ups

5.

Comanche Peak Nuclear Power Plant Technical Specification Clean Typed

6.

Comanche Peak Nuclear Power Plant Technical Specification Bases Mark-ups (Information only)

7.

Davis-Besse Nuclear Power Station Technical Specification Mark-ups

8.

Davis-Besse Nuclear Power Station Technical Specification Clean Typed

9.

Davis-Besse Nuclear Power Station Technical Specification Bases Mark-ups (Information only)

10. Perry Nuclear Power Plant Technical Specification Mark-ups

11. Perry Nuclear Power Plant Technical Specification Clean Typed

12. Perry Nuclear Power Plant Technical Specification Bases Mark-ups (Information only)

Enclosure to L-24-267 Page 2 of 28 1

SUMMARY

DESCRIPTION Pursuant to the provisions Section 50.90 of Title 10 Code of Federal Regulations (CFR), Vistra Operations Company LLC (Vistra OpCo) hereby requests a license amendment to the Beaver Valley Power Station (BVPS), Units 1 and 2, Comanche Peak Nuclear Power Plant (CPNPP),

Units 1 and 2, Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), and Perry Nuclear Power Plant, Unit 1 (PNPP) operating licenses. The proposed amendment revises Definitions and adds a new Online Monitoring Program. Vistra OpCo proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results.

2 DETAILED DESCRIPTION

2.1 Background

OLM technologies have been developed and validated for condition monitoring applications in a variety of process and power industries. This application of OLM is used to optimize maintenance of instrumentation and control (I&C) systems including online drift monitoring and assessment of dynamic failure modes of transmitters. Analysis and Measurement Services (AMS) Topical Report (TR) AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (References 1 and 2) focused on the application of OLM for monitoring drift of pressure, level, and flow transmitters in nuclear power plants. The TR addressed the following topics:

Advances in OLM implementation technology to extend transmitter calibration intervals Experience with OLM implementation in nuclear facilities Comparison between OLM results and manual calibrations Transmitter failure modes that can be detected by OLM Related regulatory requirements and industry standards and guidelines Procedures for implementation of OLM methodology Changes that must be made to existing technical specifications to adopt OLM AMS-TR-0720R2-A provided the NRC with the information needed to approve the AMS OLM methodology for implementation in nuclear power plants. The TR is intended to be used by licensees to support plant-specific technical specification changes to switch from time-based calibration frequency of pressure, level, and flow transmitters to a condition-based calibration frequency based on OLM results and to develop procedures to assess dynamic failure modes of pressure sensing systems using the noise analysis technique.

The NRC staff determined that the methodology outlined in the AMS OLM TR for applying OLM techniques to pressure, level, and flow transmitters can be used to provide reasonable assurance that required Technical Specifications (TS) instrument calibration requirements for transmitters will be maintained. This determination was based on the NRC staff finding that OLM techniques: a) are effective at identifying instrument calibration drift during plant operation, b) provide an acceptable means of identifying when manual transmitter calibration using traditional calibration methods are needed, and c) will maintain an acceptable level of performance that is traceable to calibration prime standards.

The NRC staff found that implementation of an OLM program in accordance with the approved AMS OLM TR provides an acceptable alternative to periodic manual calibration surveillance requirements upon implementation of the application-specific action items (ASAI) in Section 4.0 of its safety evaluation. The ASAIs are addressed in Section 3.4 below.

Enclosure to L-24-267 Page 3 of 28 2.2 System Design and Operation 2.2.1 Beaver Valley Power Station The transmitters to be included in the Online Monitoring Program provide input to the Reactor Trip Systems (RTS) and Engineered Safety Feature Actuation Systems (ESFAS) and are used for Post Accident Monitoring (PAM), the Remote Shutdown Systems (RSS), Overpressure Protection System (OPPS), and Reactor Coolant System (RCS) Leakage Detection Instrumentation.

The RTS initiates a unit shutdown, based on the values of selected unit parameters, to protect against violating the core fuel design limits and RCS pressure boundary during anticipated operational occurrences and to assist the Engineered Safety Features Systems in mitigating accidents. The RTS and related instrumentation are identified in TS Table 3.3.1-1, Reactor Trip System Instrumentation.

The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the RCS pressure boundary, and to mitigate accidents. The ESFAS and related instrumentation are identified in TS Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation.

The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations. This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for Design Basis Accidents. The PAM instrumentation is identified in TS Table 3.3.3-1, Post Accident Monitoring Instrumentation.

The RSS provides the operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. The RSS instrumentation is addressed in TS 3.3.4, Remote Shutdown System, and Unit 1 Updated Final Safety Analysis Report (UFSAR) Table 7.4-1, REMOTE SHUTDOWN PANEL MONITORING INSTRUMENTATION, and Unit 2 UFSAR Table 7.4-1, INSTRUMENTS AND CONTROLS OUTSIDE MAIN CONTROL ROOM FOR COLD SHUTDOWN.

The OPPS controls RCS pressure at low temperatures, so the integrity of the reactor coolant pressure boundary is not compromised by violating the pressure and temperature limits. OPPS provides the allowable combinations for pressure and temperature during cooldown, shutdown, and heatup to keep from violating the pressure and temperature limits. The OPPS instrumentation is addressed in TS 3.4.12, Overpressure Protection System (OPPS).

The RCS Leakage Detection Instrumentation provides the means for detecting RCS leakage.

The containment sump used to collect unidentified leakage is instrumented to detect increases above the normal fill rates. The RCS Leakage Detection Instrumentation is addressed in TS 3.4.15, RCS Leakage Detection Instrumentation.

The RTS, ESFAS, PAM, RSS, OPPS, and RCS Leakage Detection Instrumentation transmitters were evaluated in accordance with the methodology in AMS-TR-0720R2-A. The transmitters to be included in the OLM program and the bases for their selection can be found in AMS report BVR2405R0, "OLM Amenable Transmitters Report for Beaver Valley (Reference 3).

Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency will not create any physical changes to the plants. The changes will not impact how the plant operates. Vistra OpCo will use condition-based frequency to determine when transmitter calibrations are needed instead of performing calibrations based on a calendar frequency. Existing calibration methods will be used when it is determined that transmitter calibration is needed.

Enclosure to L-24-267 Page 4 of 28 2.2.2 Comanche Peak Nuclear Power Plant The transmitters to be included in the Online Monitoring Program provide input to the RTS and ESFAS and are used for PAM, the RSS, Low Temperature Overpressure Protection (LTOP),

and RCS Leakage Detection Instrumentation.

The RTS initiates a unit shutdown, based on the values of selected unit parameters, to protect against violating the core fuel design limits and RCS pressure boundary during anticipated operational occurrences and to assist the Engineered Safety Features Systems in mitigating accidents. The RTS and related instrumentation are identified in TS Table 3.3.1-1, Reactor Trip System Instrumentation.

The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the RCS pressure boundary, and to mitigate accidents. The ESFAS and related instrumentation are identified in TS Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation.

The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations. This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for Design Basis Accidents. The PAM instrumentation is identified in TS Table 3.3.3-1, Post Accident Monitoring Instrumentation.

The RSS provides the operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. The RSS instrumentation is identified in TS Table 3.3.4-1, Remote Shutdown System Functions.

The LTOP controls RCS pressure at low temperatures, so the integrity of the reactor coolant pressure boundary is not compromised by violating the pressure and temperature limits. LTOP provides the allowable combinations for pressure and temperature during cooldown, shutdown, and heatup to keep from violating the pressure and temperature limits. The LTOP instrumentation is addressed in TS 3.4.12, Low Temperature Overpressure Protection (LTOP)

System.

The RCS Leakage Detection Instrumentation provides the means for detecting RCS leakage.

The containment sump used to collect unidentified leakage is instrumented to detect increases above the normal fill rates. The containment air cooler condensate flow rate monitor is instrumented to alarm for increases of above the normal flow rates. The RCS Leakage Detection Instrumentation is addressed in TS 3.4.15, RCS Leakage Detection Instrumentation.

The RTS, ESFAS, PAM, RSS, LTOP, and RCS Leakage Detection Instrumentation transmitters were evaluated in accordance with the methodology in AMS-TR-0720R2-A. The transmitters to be included in the OLM program and the bases for their selection can be found in AMS report COP2402R0, "OLM Amenable Transmitters Report for Comanche Peak (Reference 4).

Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency will not create any physical changes to the plants. The changes will not impact how the plant operates. Vistra OpCo will use condition-based frequency to determine when transmitter calibrations are needed instead of performing calibrations based on a calendar frequency. Existing calibration methods will be used when it is determined that transmitter calibration is needed.

2.2.3 Davis-Besse Nuclear Power Station The transmitters to be included in the Online Monitoring Program provide input to the Reactor Protection System (RPS), Safety Feature Actuation System (SFAS), Steam and Feedwater

Enclosure to L-24-267 Page 5 of 28 Rupture Control System (SFRCS), and Anticipatory Reactor Trip System (ARTS) and are used for PAM, the RSS, Decay Heat Removal (DHR) System interlock, and RCS Leakage Detection Instrumentation, and Auxiliary Feedwater (AFW) Steam Generator Level Control.

The RPS initiates a reactor trip to protect against violating the core fuel design limits and the RCS pressure boundary during anticipated operational occurrences. By tripping the reactor, the RPS also assists the SFAS in mitigating accidents. The RPS and related instrumentation are identified in identified in TS Table 3.3.1-1, Reactor Protection System Instrumentation.

The SFAS initiates necessary safety systems, based on the values of selected unit Parameters, to automatically prevent or limit fission product and energy release from the core, to isolate the containment vessel, and to initiate the operation of Engineered Safety Features (ESF) equipment in the event of a loss-of-coolant accident (LOCA) and main steam line break (MSLB).

The SFAS and related instrumentation are identified in identified in TS Table 3.3.5-1, Safety Features Actuation System Instrumentation.

The SFRCS is designed to automatically start the AFW System in the event of a MSLB, main feedwater (MFW) line rupture, a low level in the steam generators or a loss of all four reactor coolant pumps. SFRCS is designed to automatically isolate the Main Steam System and MFW System in the event of a MSLB or MFW line rupture. The SFRCS and related instrumentation are identified in identified in TS Table 3.3.11-1, Steam and Feedwater Rupture Control System Instrumentation.

The ARTS initiates a reactor trip when a sensed parameter exceeds its setpoint value, indicating the approach of an unsafe condition thereby reducing the magnitude of pressure and temperature transients on the RCS caused by loss of main feedwater events or turbine trips.

The ARTS and related instrumentation are identified in identified in TS Table 3.3.16-1, Anticipatory Reactor Trip System Instrumentation.

The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations. This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for Design Basis Accidents. The PAM instrumentation is identified in TS Table 3.3.17-1, Post Accident Monitoring Instrumentation.

The RSS provides the operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. The RSS instrumentation is addressed in TS 3.3.18, Remote Shutdown System, and described in UFSAR Section 7.4.1.6, Auxiliary Shutdown Panel.

The DHR System interlock function isolates the high pressure RCS from the low pressure piping of the DHR System when the RCS pressure is above the design pressure of the DHR System piping and components. The DHR System interlock instrumentation is addressed in TS 3.4.14, RCS Pressure Isolation Valve (PIV) Leakage.

The RCS Leakage Detection Instrumentation provides the means for detecting significant reactor coolant pressure boundary (RCPB) degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure. The containment sump used to collect unidentified leakage is instrumented to allow detecting increases above the normal flow rates.

The RCS Leakage Detection Instrumentation is addressed in TS 3.4.15, RCS Leakage Detection Instrumentation.

The AFW System provides a safety related source of feedwater to the secondary side of the steam generators in the event of a loss of normal feedwater flow to remove reactor decay heat.

The AFW Steam Generator Level Control Instrumentation is addressed in TS 3.7.5, Emergency Feedwater (EFW).

Enclosure to L-24-267 Page 6 of 28 The RPS, SFAS, SFRCS, ARTS, PAM, RSS, DHR System interlock, RCS Leakage Detection Instrumentation, AFW Steam Generator Level Control transmitters were evaluated in accordance with the methodology in AMS-TR-0720R2-A. The transmitters to be included in the OLM program and the bases for their selection can be found in AMS report DVB2403R0, "OLM Amenable Transmitters Report for Davis-Besse (Reference 5).

Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency will not create any physical changes to the plants. The changes will not impact how the plant operates. Vistra OpCo will use condition-based frequency to determine when transmitter calibrations are needed instead of performing calibrations based on a calendar frequency. Existing calibration methods will be used when it is determined that transmitter calibration is needed.

2.2.4 Perry Nuclear Power Plant The transmitters to be included in the Online Monitoring Program provide input to the RPS and various engineered safety features and are used for PAM, the RSS, and RCS Leakage Detection Instrumentation.

The RPS initiates a reactor scram, when one or more monitored parameters exceed their specified limit, to preserve the integrity of the fuel cladding and the RCS and minimize the energy that must be absorbed following design basis accidents (DBAs). The RPS and related instrumentation are identified in TS Table 3.3.1.1-1, Reactor Protection System Instrumentation.

The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations. This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for DBAs. The PAM instrumentation is identified in TS Table 3.3.3.1-1, Post Accident Monitoring Instrumentation.

The RSS provides the operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. The RSS instrumentation is addressed in TS 3.3.3.2, Remote Shutdown System, and described in UFSAR Section 7.4.1.4, Remote Shutdown System (RSS).

The End of Cycle Recirculation Pump Trip (EOC-RPT) instrumentation initiates a RPT to reduce the peak reactor pressure and power resulting from turbine trip or generator load rejection transients to provide additional margin to core thermal safety limits. The EOC-RPT instrumentation is addressed in TS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT)

Instrumentation.

The Anticipated Transient Without Scram (ATWS) RPT System initiates an RPT, adding negative reactivity, following events in which a scram does not (but should) occur, to lessen the effects of an ATWS event. The RPS and related instrumentation is addressed in TS 3.3.4.2, Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation.

The Emergency Core Cooling System (ECCS) instrumentation initiates appropriate responses from the systems to ensure that fuel is adequately cooled in the event of a DBA or transient.

The ECCS instrumentation is identified in TS Table 3.3.5.1-1, Emergency Core Cooling System Instrumentation.

The Reactor Core Isolation Cooling (RCIC) System instrumentation initiates actions to ensure adequate core cooling when the reactor vessel is isolated from its primary heat sink (the main condenser) and normal coolant makeup flow from the Reactor Feedwater System is unavailable, such that initiation of the low pressure ECCS pumps does not occur. The RCIC

Enclosure to L-24-267 Page 7 of 28 System instrumentation is identified in TS Table 3.3.5.3-1, Reactor Core Isolation Cooling System Instrumentation.

The Primary Containment and Drywell Isolation instrumentation initiates closure of appropriate primary containment isolation valves and the drywell isolation valves. The function of the primary containment isolation valves, in combination with other accident mitigation systems, is to limit fission product release during and following postulated DBAs. The Primary Containment and Drywell Isolation instrumentation is identified in TS Table 3.3.6.1-1, Primary Containment and Drywell Isolation Instrumentation.

The Residual Heat Removal (RHR) Containment Spray System is initiated to condense steam in the containment atmosphere. This ensures that containment pressure is maintained within its limits following a DBA. The RHR Containment Spray System instrumentation is identified in TS Table 3.3.6.2-1, RHR Containment Spray System Instrumentation.

The Suppression Pool Makeup (SPMU) System provides water from the upper containment pool to the suppression pool, by gravity flow, after a DBA to ensure that primary containment temperature and pressure design limits are met. The SPMU System instrumentation is identified in TS Table 3.3.6.3-1, Suppression Pool Makeup System Instrumentation.

The Relief and Low-Low Set (LLS) instrumentation is provided to support two modes of safety/relief valve (S/RV) operation-the relief function (all valves) and the LLS function (selected valves). The relief function of the S/RVs prevents overpressurization of the nuclear steam system. The LLS function of the S/RVs is designed to mitigate the effects of postulated pressure loads on the containment by preventing multiple actuations in rapid succession of the S/RVs subsequent to their initial actuation. The Relief and LLS instrumentation addressed in TS 3.3.6.4, Relief and Low-Low Set (LLS) Instrumentation.

The Control Room Emergency Recirculation (CRER) System is designed to provide a radiologically controlled environment to ensure the habitability of the control room for the safety of control room operators under all plant conditions. The CRER System instrumentation is identified in TS Table 3.3.7.1-1, Control Room Emergency Recirculation System Instrumentation.

The RCS Leakage Detection instrumentation provides the means for detecting RCS leakage.

The drywell floor drain sump used to collect unidentified leakage is instrumented to detect increases above the normal fill rates. Condensate from the upper drywell air coolers is monitored by a flow transmitter that provides indications and alarms in the control room. The RCS Leakage Detection Instrumentation is addressed in TS 3.4.7, RCS Leakage Detection Instrumentation.

The ECCS is designed, in conjunction with the primary and secondary containment, to limit the release of radioactive materials to the environment following a DBA. The ECCS instrumentation is addressed in TS 3.5.1, ECCS - Operating.

The Mark III pressure suppression containment is designed to condense, in the suppression pool, the steam released into the drywell in the event of a DBA. The steam discharged to the pool carries the noncondensibles from the drywell. The Drywell Vacuum Relief System is the means by which noncondensibles are transferred from the primary containment back to the drywell. The Drywell Vacuum Relief System instrumentation is addressed in TS 3.6.5.6, Drywell Vacuum Relief System.

The RPS, various engineered safety features, PAM, RSS, and RCS Leakage Detection transmitters were evaluated in accordance with the methodology in AMS-TR-0720R2-A. The transmitters to be included in the OLM program and the bases for their selection can be found in AMS report PER2401R0, "OLM Amenable Transmitters Report for Perry (Reference 6).

Enclosure to L-24-267 Page 8 of 28 Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency will not create any physical changes to the plants. The changes will not impact how the plant operates. Vistra OpCo will use condition-based frequency to determine when transmitter calibrations are needed instead of performing calibrations based on a calendar frequency. Existing calibration methods will be used when it is determined that transmitter calibration is needed.

2.3 Reason for the Proposed Change Vistra OpCo is proposing to use the NRC-approved OLM methodology described in AMS-TR-0720R2-A. The use of the NRC-approved OLM methodology ensures that plant safety is maintained by demonstrating that transmitters are functioning correctly. The OLM methodology encompasses environmental and process conditions in the assessment of transmitter calibration.

The use of condition-based monitoring for transmitter calibration provides additional safety benefits, as described in AMS-TR-0720R2-A. The use of OLM will result in elimination of unnecessary transmitter calibration and associated opportunities for human errors. Elimination of unnecessary calibrations will also reduce calibration-induced damage to transmitters and other plant equipment. The use of OLM provides for timely detection of out-of-calibration transmitters. It eliminates occupational exposure or human error opportunities related to calibration activities that were unnecessary. Experience has shown that human errors during calibration of transmitters that did not require recalibration have resulted in additional repairs to correct the mistakes.

2.4 Description of the Proposed Change The proposed TS changes are an adaptation from the illustrative changes presented in AMS-TR-0720R2-A that simplify the required plant-specific changes. The proposed Definition changes eliminated the need to modify the Channel Calibration and Response Time Surveillance Requirements. The proposed Online Monitoring Program description was reorganized to better align with the OLM implementation activities.

2.4.1 Beaver Valley Power Station Vistra OpCo proposes to change definitions of CHANNEL CALIBRATION, ESF RESPONSE TIME, and RTS RESPONSE TIME in BVPS TS 1.1 Definitions.

Current definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

Proposed definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL

Enclosure to L-24-267 Page 9 of 28 CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

Current definition of ESF RESPONSE TIME The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

Proposed definition of ESF RESPONSE TIME The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

Current definition of RTS RESPONSE TIME The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

Proposed definition of RTS RESPONSE TIME The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

Vistra OpCo proposes to add a new Online Monitoring Program TS 5.5.16 for BVPS, as shown below.

5.5.16 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

Enclosure to L-24-267 Page 10 of 28 The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a. Implementation of online monitoring for transmitters that have been evaluated during the plant operating cycle in accordance with the NRC approved methodology.

1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check.

2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance.

3) Calibration checks of identified transmitters no later than during the next refueling outage.

4) Documentation of the results of the online monitoring data analysis.

b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next refueling outage.

c. Performance of calibration checks for transmitters at the specified backstop frequencies.

d. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

2.4.2 Comanche Peak Nuclear Power Plant Vistra OpCo proposes to change definitions of CHANNEL CALIBRATION, ESF RESPONSE TIME, and RTS RESPONSE TIME in CPNPP TS 1.1 Definitions.

Current definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

Proposed definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

Current definition of ESF RESPONSE TIME The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and

Enclosure to L-24-267 Page 11 of 28 sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

Proposed definition of ESF RESPONSE TIME The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

Current definition of RTS RESPONSE TIME The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

Proposed definition of RTS RESPONSE TIME The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

Vistra OpCo proposes to add a new Online Monitoring Program TS 5.5.24 for CPNPP, as shown below.

5.5.24 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a. Implementation of online monitoring for transmitters that have been evaluated during the plant operating cycle in accordance with the NRC approved methodology.

1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check.

Enclosure to L-24-267 Page 12 of 28

2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance.

3) Calibration checks of identified transmitters no later than during the next refueling outage.

4) Documentation of the results of the online monitoring data analysis.

b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next refueling outage.

c. Performance of calibration checks for transmitters at the specified backstop frequencies.

d. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

2.4.3 Davis-Besse Nuclear Power Station Vistra OpCo proposes to change definitions of CHANNEL CALIBRATION, RPS RESPONSE TIME, SFAS RESPONSE TIME, and SFRCS RESPONSE TIME in DBNPS TS 1.1 Definitions.

Current definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST.

Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

Proposed definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

Current definition of RPS RESPONSE TIME The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until electrical power is interrupted at the control rod drive trip breakers. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

Proposed definition of RPS RESPONSE TIME The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until electrical power is interrupted at the control rod drive trip breakers. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

Enclosure to L-24-267 Page 13 of 28 Current definition of SFAS RESPONSE TIME The SFAS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its SFAS actuation setpoint at the channel sensor until the SFAS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

Proposed definition of SFAS RESPONSE TIME The SFAS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its SFAS actuation setpoint at the channel sensor until the SFAS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

Current definition of SFRCS RESPONSE TIME The SFRCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its SFRCS actuation setpoint at the channel sensor until the SFRCS equipment is capable of performing its safety function (i.e., valves travel to their required positions, pumps discharge pressures reach their required values, etc.). The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

Proposed definition of SFRCS RESPONSE TIME The SFRCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its SFRCS actuation setpoint at the channel sensor until the SFRCS equipment is capable of performing its safety function (i.e., valves travel to their required positions, pumps discharge pressures reach their required values, etc.). The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

Vistra OpCo proposes to add a new Online Monitoring Program TS 5.5.19 for DBNPS, as shown below.

5.5.19 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a. Implementation of online monitoring for transmitters that have been evaluated during the plant operating cycle in accordance with the NRC approved methodology.

Enclosure to L-24-267 Page 14 of 28

1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check.

2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance.

3) Calibration checks of identified transmitters no later than during the next refueling outage.

4) Documentation of the results of the online monitoring data analysis.

b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next refueling outage.

c. Performance of calibration checks for transmitters at the specified backstop frequencies.

d. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

2.4.4 Perry Nuclear Power Plant Vistra OpCo proposes to change definitions of CHANNEL CALIBRATION, ECCS RESPONSE TIME, EOC-RPT SYSTEM RESPONSE TIME, ISOLATION SYSTEM RESPONSE TIME, and RPS RESPONSE TIME in PNPP TS 1.1 Definitions.

Current definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is calibrated.

Proposed definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor (excluding transmitters in the Online Monitoring Program), alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is calibrated.

Current definition of ECCS RESPONSE TIME The ECCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. Exceptions are stated in the individual surveillance requirements.

Enclosure to L-24-267 Page 15 of 28 Proposed definition of ECCS RESPONSE TIME The ECCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. Exceptions are stated in the individual surveillance requirements. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

Current definition of EOC-RPT SYSTEM RESPONSE TIME The EOC - RPT SYSTEM RESPONSE TIME shall be that time interval from initial movement of the associated turbine stop valve or the turbine control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

Proposed definition of EOC-RPT SYSTEM RESPONSE TIME The EOC - RPT SYSTEM RESPONSE TIME shall be that time interval from initial movement of the associated turbine stop valve or the turbine control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

Current definition of ISOLATION SYSTEM RESPONSE TIME The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. Exceptions are stated in the individual surveillance requirements.

Proposed definition of ISOLATION SYSTEM RESPONSE TIME The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. Exceptions are stated in the individual surveillance requirements. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

Current definition of RPS RESPONSE TIME The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. The response time may be measured by means of any series of sequential.

overlapping, or total steps so that the entire response time is measured. Exceptions are stated in the individual surveillance requirements.

Enclosure to L-24-267 Page 16 of 28 Proposed definition of RPS RESPONSE TIME The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. The response time may be measured by means of any series of sequential.

overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

Exceptions are stated in the individual surveillance requirements.

Vistra OpCo proposes to add a new Online Monitoring Program TS 5.5.17 for PNPP, as shown below.

5.5.17 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a. Implementation of online monitoring for transmitters that have been evaluated during the plant operating cycle in accordance with the NRC approved methodology.

1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check.

2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance.

3) Calibration checks of identified transmitters no later than during the next refueling outage.

4) Documentation of the results of the online monitoring data analysis.

b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next refueling outage.

c. Performance of calibration checks for transmitters at the specified backstop frequencies.

d. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

3 TECHNICAL EVALUATION 3.1 OLM Implementation Process Development This section describes the steps that were performed to implement the OLM program for BVPS, CPNPP, DBNPS, and PNPP by following the steps identified in AMS-TR-0720R2-A Section 11.1.1. This work is documented in the AMS reports on OLM Amenable Transmitters (References 3, 4, 5, and 6) and OLM Analysis Methods and Limits (References 7, 8, 9, and 10).

The AMS reports on OLM Amenable Transmitters address steps 1-6 from AMS-TR-0720R2-A Section 11.1.1. These steps were designed to arrive at a list of transmitters that can be included in an OLM program and determine how to obtain OLM data. The BVPS, CPNPP, DBNPS, and PNPP transmitters to be included in the OLM program and the bases for their selection can be found in the AMS reports on OLM Amenable Transmitters.

Enclosure to L-24-267 Page 17 of 28 3.1.1 Determine if Transmitters are Amenable to OLM AMS-TR-0720R2-A Chapter 12 includes Table 12.4 that lists the nuclear grade transmitter models that are amenable to OLM. Any transmitter model that is not listed in this table should only be added to the OLM program if it can be shown by similarity analysis that its failure modes are the same as the listed transmitter models or otherwise detectable by OLM.

3.1.2 List Transmitters in Each Redundant Group This step establishes how to group the transmitters and evaluates the redundancy of each group.

3.1.3 Determine if OLM Data Covers Applicable Setpoints This step evaluates the OLM data for each group to determine if it covers applicable setpoints.

Additional details are described in AMS-TR-0720R2-A Chapter 14.

3.1.4 Calculate Backstops A backstop, as described in AMS-TR-0720R2-A Chapter 13, must be established for each group of redundant transmitters amenable to OLM as a defense against common mode drift.

The backstop identifies the maximum period between calibrations without calibrating at least one transmitter in a redundant group.

3.1.5 Establish Method of Data Acquisition OLM data is normally available in the plant computer or an associated data historian. If data is not available from the plant computer or historian, a custom data acquisition system including hardware and software must be employed to acquire the data.

3.1.6 Specify Data Collection Duration and Sampling Rate OLM data must be collected during startup, normal operation, and shutdown periods at the highest sampling rate by which the plant computer takes data. AMS-TR-0720R2-A Chapter 15 describes a process to determine the minimum sampling rate for OLM data acquisition to monitor for transmitter drift. AMS-TR-0720R2-A Chapter 8 describes a process to help determine the optimal sampling rate and minimum duration of OLM data collection.

AMS report on OLM Analysis Methods and Limits (References 7, 8, 9, and 10) address steps 7-8 from AMS-TR-0720R2-A Section 11.1.1 These steps address the calculation of the OLM limits and establish the methods of OLM data analysis.

3.1.7 Identify Data Analysis Methods OLM implementations must employ both simple averaging and parity space methods for data analysis as described in AMS-TR-0720R2-A Chapter 6.

3.1.8 Establish OLM Limits OLM limits must be established as described in AMS-TR-0720R2-A Chapter 7 for each group of redundant transmitters. Calculation of OLM limits must be based on combining uncertainties of components of each instrument channel from the transmitter in the field to the OLM data storage.

The AMS report on OLM Analysis Methods and Limits provides the OLM Limit calculations for the transmitters that are amenable to OLM at BVPS, CPNPP, DBNPS, and PNPP.

3.2 OLM Program Implementation This section summarizes the steps that must be followed to implement the OLM program for transmitter drift monitoring at BVPS, CPNPP, DBNPS, and PNPP in accordance with AMS-TR-0720R2-A. The steps described in this section are repeated at each operating cycle at BVPS, CPNPP, DBNPS, and PNPP to identify the transmitters that should be scheduled for a

Enclosure to L-24-267 Page 18 of 28 calibration check using data from periods of startup, normal operation, and shutdown. Additional details regarding the OLM Program Implementation discussed in this section are contained in the AMS reports on OLM Drift Monitoring Program (References 11, 12, 13, and 14).

AMS-TR-0720R2-A Section 11.1.2 identifies eleven steps that must be followed each operating cycle to identify the transmitters that should be scheduled for a calibration check at the ensuing outage. Table 1 provides a mapping between AMS-TR-0720R2-A Section 11.1.2 and the LAR section where the item is addressed. Implementation of these steps is performed using the AMS Bridge and the AMS Calibration Reduction System (CRS) software programs that were developed by AMS under their 10 CFR Part 50 Appendix B software Quality Assurance (QA) program.

Table 1: Mapping to AMS-TR-0720R2-A Section 11.1.2 Item Step Step Number in Section 11.1.2 of AMS-TR-0720R2-A LAR Section 1

Retrieve OLM Data 9

3.2.1 2

Perform Data Qualification 10 3.2.2 3

Select Appropriate Region of Any Transient Data 11 3.2.3 4

Perform Data Analysis 12 3.2.4 5

Plot the Average Deviation for Each Transmitter 13 3.2.5 6

Produce a Table for Each Group That Combines All Results 14 3.2.6 7

Determine OLM Results for Each Transmitter 15 3.2.7 8

Address Uncertainties in the Unexercised Portion of Transmitter Range 16 3.2.8 9

Select Transmitters to Be Checked for Calibration as a Backstop 17 3.2.9 10 Perform Dynamic Failure Mode Assessment 18 3.2.10 11 Produce a Report of Transmitters Scheduled for Calibration Check 19 3.2.11 3.2.1 Retrieve OLM Data The first step in performing transmitter drift monitoring is to retrieve the OLM data. OLM data must be retrieved during periods of startup, normal operation, and shutdown. The method of data acquisition, data collection duration, sampling rate, and list of sensors whose data will be retrieved have been established as described in Section 3.1 of this document. The OLM data for BVPS, CPNPP, DBNPS, and PNPP will be retrieved using the AMS Bridge software which will retrieve data from the plant data historian and produce binary data files that are compatible with the AMS Calibration Reduction System (CRS) software or as a text files from the data historian or other data sources at each plant site, as applicable. AMS procedure OLM2201, Procedure for Online Monitoring Data Retrieval, has been developed for performing the data retrieval using the AMS Bridge software (Reference 15).

Enclosure to L-24-267 Page 19 of 28 3.2.2 Perform Data Qualification OLM data retrieved from plant historians sometimes contains anomalies such as spikes, missing data, stuck data, and saturated data. The portion of data containing these anomalies should be excluded, filtered, and/or cleaned prior to analysis. The AMS CRS software provides functionality for these tasks and will be used to perform data qualification. AMS procedure OLM2202, Procedure for Performing Online Monitoring Data Qualification and Analysis, has been developed for performing data qualification and analysis using the AMS CRS software (Reference 16).

3.2.3 Select Appropriate Region of Any Transient Data The AMS CRS software provides means to select the regions of transient data as described in Step 11 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform these selections.

This activity is part of OLM data analysis and is addressed in the data qualification and analysis procedure.

3.2.4 Perform Data Analysis Several tasks that must be performed in OLM data analysis for startup, normal operation, and shutdown data including:

1. Calculate the process estimate,

2. Calculate the deviation of each transmitter from the process estimate and plot the

outcome,

3. Partition the deviation data into region(s) by percent of span,

4. Calculate and plot the average deviation for each region versus percent of span,

5. Select appropriate process estimation techniques, filtering parameters, and remove any

outliers,

6. Determine if average deviations exceed OLM limits for any region, and

7. Review, document, and store the details and results of analysis.

The AMS CRS software provides functionality for performing these tasks and will be used to perform OLM data analysis. Detailed steps for performing OLM data analysis are provided in the data qualification and analysis procedure.

3.2.5 Plot the Average Deviation for Each Transmitter The AMS CRS software provides functionality for plotting the average deviation for each transmitter as described in Step 13 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

3.2.6 Produce a Table for Each Group That Combines All Results The AMS CRS software provides functionality for producing a table for each group of redundant transmitters that combines all results as described in Step 13 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

3.2.7 Determine OLM Results for Each Transmitter OLM results must be produced by the OLM analyst upon completion of data analysis for a complete operating cycle. The AMS CRS software provides functionality for producing these results as described in Step 15 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

Enclosure to L-24-267 Page 20 of 28 3.2.8 Address Uncertainties in the Unexercised Portion of Transmitter Range The AMS CRS software provides functionality for addressing uncertainties in the unexercised portion of the transmitter ranged as described in Step 13 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

3.2.9 Select Transmitters to Be Checked for Calibration as a Backstop The AMS procedure OLM2202 is also used for maintaining the backstops for OLM. It provides detailed steps for selecting transmitters to be checked for calibration as a backstop as described in Step 17 of Section 11.1.2 of AMS-TR-0720R2-A.

3.2.10 Perform Dynamic Failure Mode Assessment As described in Step 18 of Section 11.1.2 of AMS-TR-0720R2-A, dynamic failure mode assessment must be performed using the noise analysis technique to cover dynamic failures that are not detectable by the OLM process for transmitter drift monitoring. Details on how this will be addressed for BVPS, CPNPP, DBNPS, and PNPP are described in LAR Section 3.3.

3.2.11 Produce a Report of Transmitters Scheduled for Calibration Check The results of OLM analysis must be compiled in a report and independently reviewed. The transmitters that have been flagged must be scheduled for a calibration check at the next opportunity. The AMS CRS software provides functionality for producing this report and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

3.3 OLM Noise Analysis Implementation Some licensees have extended or eliminated transmitter response time testing requirements with NRC approval based, in part, on the performance of manual calibrations. Manual calibrations will not be performed except on transmitters that are flagged by OLM. The noise analysis methodology is provided in this document to enable licensees to assess the dynamic failure modes of transmitters that are not covered by the OLM process for transmitter drift monitoring.

This section summarizes the steps that must be followed to implement the noise analysis technique for transmitter dynamic failure mode assessment at BVPS, CPNPP, DBNPS, and PNPP in accordance with AMS-TR-0720R2-A. Additional details regarding the implementation of the noise analysis technique discussed in this section are provided in the AMS report on Noise Analysis Program (References 17, 18, 19, and 20).

As described in Section 11.3.3 of AMS-TR-0720R2-A, six steps must be followed to assess dynamic failure modes of pressure transmitters. Table 2 provides a mapping of the six steps in Section 11.3.3 of AMS-TR-0720R2-A and the section where they are addressed in this document. Implementation of these steps is performed using qualified noise data acquisition equipment and software programs that were developed by AMS under their 10 CFR Part 50 Appendix B software Quality Assurance (QA) program.

For BVPS, CPNPP, DBNPS, and PNPP, the transmitters with response time requirements have been identified in AMS report on OLM Amenable Transmitters (References 3, 4, 5, and 6).

Enclosure to L-24-267 Page 21 of 28 Table 2: Mapping to AMS-TR-0720R2-A Section 11.3.3 Item Step Step Number in Section 11.3.3 of AMS-TR-0720R2-A LAR Section 1

Select Qualified Noise Data Acquisition Equipment 1

3.3.1 2

Connect Noise Data Acquisition Equipment to Plant Signals 2

3.3.2 3

Collect and Store Data for Subsequent Analysis 3

3.3.3 4

Screen Data for Artifacts and Anomalies 4

3.3.4 5

Perform Data Analysis 5

3.3.5 6

Review and Document Results 6

3.3.6 3.3.1 Select Qualified Noise Data Acquisition Equipment The first step in performing noise analysis is to select qualified noise data acquisition equipment. This equipment must have a valid calibration traceable to the National Institute of Standards and Technology and meet a set of performance criteria detailed Step 1 of Section 11.3.3 of AMS-TR-0720R2-A. The equipment used to acquire data at BVPS, CPNPP, DBNPS, and PNPP will be the AMS OLM data acquisition system which is comprised of hardware and software that has been developed and tested using AMS 10 CFR Part 50 Appendix B hardware and software QA program.

3.3.2 Connect Noise Data Acquisition Equipment to Plant Signals AMS Procedure NPS1501, Procedure for Noise Data Collection from Plant Sensors, is used for the connection of the noise data acquisition equipment for performing noise analysis testing (Reference 21). This procedure identifies the locations for connection to process signals as well as the qualified personnel who may connect the data acquisition system at these locations. The noise data acquisition system should be connected to as many transmitters as allowed by the number of data acquisition channels and the plant procedures. Multiple transmitters (e.g., up to

32) can be tested simultaneously to reduce the test time. Each data acquisition channel must be connected to the transmitter current loop as shown in Section 11.3.3 of AMS-TR-0720R2-A.

3.3.3 Collect and Store Data for Subsequent Analysis The noise data should be collected during normal plant operation at full temperature, pressure, and flow and analyzed in real time or stored to be analyzed later. However, noise data taken at other conditions is acceptable as long as there is enough process fluctuation with sufficient amplitude and frequency content to drive the transmitters to reveal their dynamic characteristics.

Noise data collection will be performed using AMS OLM Data Acquisition software which has been developed and tested using AMS software verification and validation program which conforms to 10 CFR Part 50 Appendix B. The use of this software for noise data acquisition is addressed in the AMS procedure for performing noise analysis testing (Reference 21).

3.3.4 Screen Data for Artifacts and Anomalies Noise data may contain anomalies that must be excluded, filtered, and/or cleaned prior to data analysis. AMS Procedure NAR2201, Procedure for Performing Dynamic Failure Mode Assessment Using Noise Analysis, is used for performing noise analysis data analysis (Reference 22) and will be performed using AMS noise analysis software.

Enclosure to L-24-267 Page 22 of 28 3.3.5 Perform Data Analysis Noise data analysis will be performed as described in Section 11.3.3 Step 5 in AMS-TR-0720R2-A using AMS noise analysis software. General data analysis steps for the analyst as well as detailed steps for performing noise data analysis are also provided in the AMS procedure for performing noise analysis data analysis (Reference 22).

3.3.6 Review and Document Results Results of noise data analysis will be reviewed and approved by qualified personnel and documented in a report. This process is detailed in the AMS procedure for performing noise analysis data analysis (Reference 22).

3.4 Application Specific Action Items from AMS OLM TR The NRC approval of the AMS OLM TR required implementation of the ASAIs in Section 4.0 of its safety evaluation. Five ASAIs were identified, and each is addressed below.

ASAI 1 - Evaluation and Proposed Mark-up of Existing Plant Technical Specifications When preparing a license amendment request to adopt OLM methods for establishing calibration frequency, licensees should consider markups that provide clear requirements for accomplishing plant operations, engineering data analysis, and instrument channel maintenance. Such TS changes would need to include appropriate markups of the TS tables describing limiting conditions for operation and surveillance requirements, the technical basis for the changes, and the administrative programs section.

Response to ASAI 1: The proposed changes to the BVPS, CPNPP, DBNPS, and PNPP Technical Specifications are identified in Section 2.4 and shown in Attachments 1, 4, 7 and 10.

The proposed changes modify applicable Definitions and add a new program for OLM in the Administrative Controls. No changes to the Technical Specification tables describing Limiting Conditions for Operation or Surveillance Requirements were necessary.

ASAI 2 - Identification of Calibration Error Source When determining whether an instrument can be included in the plant OLM program, the licensee shall evaluate calibration error source in order to account for the uncertainty due to multiple instruments used to support the transfer of transmitter signal data to the data collection system. Calibration errors identified through OLM should be attributed to the transmitter until testing can be performed on other support devices to correctly determine the source of calibration error and reallocate errors to these other loop components.

Response to ASAI 2: Calibration error is evaluated as part of the calculation of OLM limits as described in Section 3.1.8. The calculation of OLM limits is based on combining uncertainties of components of each instrument channel from the transmitter in the field to the OLM data storage. The OLM data assessment methods described in Section 3.2.7 include guidance to consider calibration errors identified through OLM as coming from the transmitter until testing can be performed on other support devices to correctly determine the source of calibration error and reallocate errors to these other loop components.

ASAI 3 - Response Time Test Elimination Basis If the plant has eliminated requirements for performing periodic RT testing of transmitters to be included in the OLM program, then the licensee shall perform an assessment of the basis for RT test elimination to determine if this basis will remain valid upon implementation of the OLM program and to determine if the

Enclosure to L-24-267 Page 23 of 28 RT test elimination will need to be changed to credit the OLM program rather than the periodic calibration test program.

Response to ASAI 3: BVPS and PNPP previously eliminated requirements for performing periodic response time testing based on the periodic calibration of transmitters that are proposed to be included in the OLM program. BVPS and PNPP proposes to change the basis for response time test elimination to the methodology described in Section 3.3, which is based on the noise analysis methodology described in Section 11.3 of the AMS OLM TR.

ASAI 4 - Use of Calibration Surveillance Interval Backstop In its application for a license or license amendment to incorporate OLM methods for establishing calibration surveillance intervals, applicants or licensees should describe how they intend to apply backstop intervals as a means for mitigating the potential that a process group could be experiencing undetected common mode drift characteristics.

Response to ASAI 4: The Vistra OpCo OLM programs for BVPS, CPNPP, DBNPS, and PNPP adopt the calibration surveillance interval backstop methods described in Section 3.2.9, which is based on the backstop methodology described in Section 13 of the AMS OLM TR.

The UFSAR for BVPS and CPNPP will be modified to add the use of AMS-TR-0720R2-A to the appropriate parts of Chapter 1. The use of OLM to switch from time-based calibration frequency of pressure, level, and flow transmitters to a condition-based calibration frequency based on OLM results will be added to the appropriate parts of BVPS, CPNPP, DBNPS, and PNPP UFSAR Chapter 7, including a list of transmitters included in the OLM program. The appropriate parts of UFSAR Chapter 7 will also be changed to describe the use of OLM assess dynamic failure modes of pressure-type sensing systems using the noise analysis technique to support the continued elimination of transmitter response time testing.

ASAI 5 - Use of Criteria other than in AMS OLM TR for Establishing Transmitter Drift Flagging Limit In its application for a license or license amendment to incorporate OLM methods for establishing calibration surveillance intervals, applicants or licensees should describe whether they intend to adopt the criteria within the AMS OLM TR for flagging transmitter drift or whether they plan to use a different methodology for determining this limit.

Response to ASAI 5: The Vistra OpCo OLM programs for BVPS, CPNPP, DBNPS, and PNPP adopt the two averaging techniques (i.e., simple average and parity space) described in Section 6 of the AMS OLM TR for flagging transmitter drift.

4 REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36 Technical Specifications. Part (3) of this regulation sets the governing requirements for the inclusion of Surveillance Requirements in the Technical Specifications included in the Operating License for a commercial nuclear power plant.

(3) 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.

Vistra OpCo proposes to use the AMS OLM methodology for BVPS, CPNPP, DBNPS, and PNPP as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results.

Enclosure to L-24-267 Page 24 of 28 10 CFR Part 50 Appendix A. General Design Criterion 21, Protection System Reliability and Testability, requires, in part, that plant protection systems be designed to permit periodic testing during reactor operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred.

Criterion 21, Protection System Reliability and Testability. The protection system shall be designed for high functional reliability and in-service testability commensurate with the safety functions to be performed. Redundancy and independence designed into the protection system shall be sufficient to assure that (1) no single failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the required minimum redundancy unless the acceptable reliability of operation of the protection system can be otherwise demonstrated. The protection system shall be designed to permit periodic testing of its functioning when the reactor is in operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred.

General Design Criterion 21 is applicable to BVPS Unit 2, CPNPP, DBNPS, and PNPP but its equivalent for BVPS Unit 1 is General Design Criterion 19 due to the vintage of the plant.

Vistra OpCo proposes to use the AMS OLM methodology for BVPS, CPNPP, DBNPS, and PNPP as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The OLM methodology is also proposed to be used to assess dynamic failure modes of pressure sensing systems.

Regulatory Guide 1.118, Revision 3, Periodic Testing of Electric Power and Protection Systems, endorses with qualification the IEEE Standard 338-1987, IEEE Standard Criteria for the Periodic Surveillance Testing of Nuclear Power Generating Station Safety Systems.

Regulatory Guide 1.118 is applicable to BVPS Unit 2, CPNPP, DBNPS, and PNPP but BVPS Unit 1 did not adopt due to the vintage of the plant.

Vistra OpCo proposes to use the AMS OLM methodology as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results.

IEEE Standard 338-1977. This standard contains the following requirements related to calibration:

6.3.3 Channel Calibration Verification Tests. A channel calibration verification test should prove that with a known precise input, the channel gives the required output, analog, or bistable. Additionally, in analog channels, linearity and hysteresis may be checked. If the required output is achieved, the test is acceptable. If the required output is not achieved (for example, the bistable trip did not occur at the required set point or the analog output was out of tolerance) or saturation or foldover is observed and adjustment or alignment of gain, bias, trip set, etc., is required, the test is unacceptable. Adjustment or alignment procedures are maintenance activities and are outside the scope of this standard. Test results, however, shall be recorded in accordance with ANSI/ANS 3.2-1982, or the equivalent. Following maintenance or other appropriate disposition of the unacceptable results, a successful rerun of the channel calibration verification test shall be performed.

6.5.2 Changes to Test Interval. The effect of testing intervals on performance of equipment shall be reevaluated periodically to determine if the interval used is an effective factor in maintaining equipment in an operational status. The following shall be considered:

Enclosure to L-24-267 Page 25 of 28 History of equipment performance, particularly experienced failure rates and potential significant increases in failure rates.

Corrective action associated with failures.

Performance of equipment in similar plants or environment, or both.

Plant design changes associated with equipment.

Detection of significant changes of failure rates.

Test intervals may be changed to agree with plant operational modes provided it can be shown that such changes do not adversely affect desired performance of the equipment being tested. Tests need not be performed on systems or equipment when they are not required to be operable or are tripped. If tests are not conducted on such systems, they shall be performed prior to returning the system to operation.

Vistra OpCo proposes to use the AMS OLM methodology for BVPS, CPNPP, DBNPS, and PNPP as the technical basis to support plant-specific Technical Specification changes to switch to time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on the OLM results for a given transmitter.

IEEE Standard 338-2012. This standard contains the following requirements related to calibration:

5.3.3.2 On-line monitoring. On-line monitoring (OLM) techniques enable the determination of portions of an instrument channels status during plant operation. This methodology is an acceptable input for establishing calibration frequency of those monitored portions of instrument channels without adversely affecting reliability.

Continuous monitoring shall be employed, e.g., through the plant computer.

Periodic manual testing is either a maintenance or surveillance task and is not on-line monitoring.

On-line monitoring shall ensure that setpoint calculation assumptions and the safety analysis assumptions remain valid.

Vistra OpCo proposes to use the AMS OLM methodology for BVPS, CPNPP, DBNPS, and PNPP as the technical basis to support plant-specific Technical Specification changes to switch to time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on the OLM results for a given transmitter.

4.2 Precedent The Vistra OpCo license amendment request is based the NRC-approved Analysis and Measurement Services Corporation Topical Report AMS-TR-0720R2, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (References 1 and 2). Two precedents were identified. NRC approved a license amendment request submitted by Southern Nuclear Operating Company for Vogtle Electric Generating Plant Units 1 and 2 to extend calibration intervals of nuclear plant pressure transmitters using AMS-TR-0720R2 (References 23 and 24). NRC approved a license amendment request submitted by Southern Nuclear Operating Company for Farley Nuclear Plant, Units 1 and 2, and Edwin I.

Hatch Nuclear Plant, Units 1 and 2, to extend calibration intervals of nuclear plant pressure transmitters using AMS-TR-0720R2 (References 25 and 26).

4.3 No Significant Hazards Consideration Determination Analysis Vistra OpCo has evaluated the proposed changes to the BVPS, CPNPP, DBNPS, and PNPP Technical Specifications (TS) using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

Enclosure to L-24-267 Page 26 of 28 The proposed changes revise the following TSs:

BVPS TS 1.1 definitions for CHANNEL CALIBRATION, ESF RESPONSE TIME, and RTS RESPONSE TIME CPNPP TS 1.1 definitions for CHANNEL CALIBRATION, ESF RESPONSE TIME, and RTS RESPONSE TIME DBNPS TS 1.1 definitions for CHANNEL CALIBRATION, RPS RESPONSE TIME, SFAS RESPONSE TIME, and SFRCS RESPONSE TIME PNPP TS 1.1 definitions for CHANNEL CALIBRATION, ECCS RESPONSE TIME, EOC-RPT SYSTEM RESPONSE TIME, ISOLATION SYSTEM RESPONSE TIME, and RPS RESPONSE TIME The proposed changes add new Online Monitoring Program TSs, as shown below:

BVPS TS 5.5.16 Online Monitoring Program CPNPP TS 5.5.24 Online Monitoring Program DBNPS TS 5.5.19 Online Monitoring Program PNPP TS 5.5.17 Online Monitoring Program Vistra OpCo proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency will not create any physical changes to the plant. The use of the NRC-approved OLM methodology ensures that plant safety is maintained by demonstrating that transmitters are functioning correctly.

As required by 10 CFR 50.91(a), the Vistra OpCo analysis of the issue of no significant hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change uses online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency will not create any physical changes to the plant. The use of the NRC-approved OLM methodology ensures that plant safety is maintained by demonstrating that transmitters are functioning correctly.

The proposed changes do not adversely affect accident initiators or precursors, and do not alter the design assumptions, conditions, or configuration of the plant or the way the plant is operated or maintained.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.

Existing calibration methods will be used when the need for transmitter calibration is determined. The change does not alter assumptions made in the safety analysis but ensures that the transmitters operate as assumed in the accident analysis. The proposed change is consistent with the safety analysis assumptions. Therefore, the proposed change

Enclosure to L-24-267 Page 27 of 28 does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.

The change does not alter assumptions made in the safety analysis but ensures that the transmitters operate as assumed in the accident analysis. The proposed change is consistent with the safety analysis assumptions. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

4.4 Conclusions In conclusion, based on the considerations discussed above, (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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public.

5 ENVIRONMENTAL CONSIDERATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6 REFERENCES

1. Analysis and Measurement Services Corporation letter to NRC dated August 20, 2021, Submittal of -A Version of Analysis and Measurement Services Corporation Topical Report AMS-TR-0720R2, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (Docket No. 99902075), (ADAMS Accession No. ML21235A493)

2. NRC Form 896, AMS Topical Report -A Verification, dated September 22, 2021 (ADAMS Accession No. ML21237A490)

3. AMS Report BVR2405R0, "OLM Amenable Transmitters Report for Beaver Valley

4. AMS Report COP2402R0, "OLM Amenable Transmitters Report for Comanche Peak

5. AMS Report DVB2403R0, "OLM Amenable Transmitters Report for Davis-Besse

6. AMS Report PER2401R0, "OLM Amenable Transmitters Report for Perry

7. AMS Report BVR2406R0, OLM Analysis Methods and Limits Report for Beaver Valley

8. AMS Report COP2403R0, OLM Analysis Methods and Limits Report for Comanche Peak

9. AMS Report DVB2404R0, OLM Analysis Methods and Limits Report for Davis-Besse

Enclosure to L-24-267 Page 28 of 28

10. AMS Report PER2402R0, OLM Analysis Methods and Limits Report for Perry

11. AMS Report BVR2407R0, OLM Drift Monitoring Program Report for Beaver Valley

12. AMS Report COP2404R0, OLM Drift Monitoring Program Report for Comanche Peak

13. AMS Report DVB2405R0, OLM Drift Monitoring Program Report for Davis-Besse

14. AMS Report PER2403R0, OLM Drift Monitoring Program Report for Perry

15. AMS Procedure OLM2201, Procedure for Online Monitoring Data Retrieval, December 2022

16. AMS Procedure OLM2202, Procedure for Performing Online Monitoring Data Qualification and Analysis, August 2024

17. AMS Report BVR2408R0, OLM Noise Analysis Program Report for Beaver Valley

18. AMS Report COP2405R0, OLM Noise Analysis Program Report for Comanche Peak

19. AMS Report DVB2406R0, OLM Noise Analysis Program Report for Davis-Besse

20. AMS Report PER2404R0, OLM Noise Analysis Program Report for Perry

21. AMS Procedure NPS1501, Procedure for Noise Data Collection from Plant Sensors, March 2015

22. AMS Procedure NAR2201, Procedure for Performing Dynamic Failure Mode Assessment Using Noise Analysis, August 2024

23. Southern Nuclear Operating Company letter NL-22-0764 to NRC dated December 21, 2022, License Amendment Request to Revise Technical Specification 1.1 and Add 5.5.23 to Use Online Monitoring Methodology, (ADAMS Accession No. ML22355A588)

24. NRC letter to Southern Nuclear Operating Company dated June 15, 2023, Vogtle Electric Generating Plant, Units 1 And 2 - Issuance of Amendments Regarding Revision to Technical Specifications to Use Online Monitoring Methodology, (ADAMS Accession No. ML23115A149)

25. Southern Nuclear Operating Company letter NL-22-0764 to NRC dated May 3, 2024, Farley Nuclear Plant - Units 1&2 and Hatch Nuclear Plant - Units 1&2 License Amendment Request to Revise Technical Specification 1.1 and Add Online Monitoring Program to Technical Specification 5.5, (ADAMS Accession No. ML24124A133)

26. NRC letter to Southern Nuclear Operating Company dated January 24, 2025, Joseph M. Farley Nuclear Plant, Units 1 and 2, and Edwin I. Hatch Nuclear Plant, Units 1 and 2 -

Issuance of Amendments Regarding Revision to Technical Specifications to Use Online Monitoring Methodology, (ADAMS Accession No. ML24351A080)

Enclosure to L-24-267 Beaver Valley Power Station Technical Specification Mark-ups

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

- NOTE -

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux signals (AFD) between the top and bottom halves of a two section excore neutron detector.

CERTIFIED FUEL HANDLER A CERTIFIED FUEL HANDLER is an individual who complies with the provisions of the CERTIFIED FUEL HANDLER training and retraining program required by Specification 5.3A.2.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

Beaver Valley Units 1 and 2 1.1 - 1 Amendments 308 / 198 INSERT:

(excluding transmitters in the Online Monitoring Program)

Definitions 1.1 1.1 Definitions ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from FEATURE (ESF) RESPONSE when the monitored parameter exceeds its actuation setpoint TIME INSERVICE TESTING PROGRAM LEAKAGE at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f).

LEAKAGE shall be:

a.

Identified LEAKAGE 1.

LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank; 2.

LEAKAGE into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or 3.

Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);

b.

Unidentified LEAKAGE All LEAKAGE (except RCP seal water injection or leakoff) that is not identified LEAKAGE; and c.

Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a fault in an RCS component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

Beaver Valley Units 1 and 2 1.1 - 3 Amendments 324 / 214 INSERT:

(including transmitters in the Online Monitoring Program)

Definitions 1.1 1.1 Definitions QUADRANT POWER TILT RATIO (QPTR)

RATED THERMAL POWER (RTP)

REACTOR TRIP SYSTEM (RTS) RESPONSE TIME QPTR shall be the ratio of the maximum upper excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RTP shall be a total reactor core heat transfer rate to the reactor coolant as specified in the Licensing Requirements Manual, and shall not exceed 2900 MWt.

The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

SHUTDOWN MARGIN (SDM)

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. However, with all RCCAs verified fully inserted by two independent means, it is not necessary to account for a stuck RCCA in the SDM calculation. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM, and b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level.

SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing all slave relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required slave relay. The SLAVE RELAY TEST shall include a continuity check of associated required testable actuation devices. The SLAVE RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

Beaver Valley Units 1 and 2 1.1 - 5 Amendments 324 / 214 INSERT:

(including transmitters in the Online Monitoring Program)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Surveillance Frequency Control Program (continued) b.

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1.

c.

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

Beaver Valley Units 1 and 2 5.5 - 22 Amendments 305 / 195 INSERT:

New TS 5.5.16 here

5.5.16 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a.

Implementation of online monitoring for transmitters that have been evaluated during the plant operating cycle in accordance with the NRC approved methodology.

1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check.

2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance.

3) Calibration checks of identified transmitters no later than during the next refueling outage.

4) Documentation of the results of the online monitoring data analysis.

b.

Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next refueling outage.

c.

Performance of calibration checks for transmitters at the specified backstop frequencies.

d.

The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

INSERT

Enclosure to L-24-267 Beaver Valley Power Station Technical Specification Clean Typed

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

- NOTE -

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux signals (AFD) between the top and bottom halves of a two section excore neutron detector.

CERTIFIED FUEL HANDLER A CERTIFIED FUEL HANDLER is an individual who complies with the provisions of the CERTIFIED FUEL HANDLER training and retraining program required by Specification 5.3A.2.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

Beaver Valley Units 1 and 2 1.1 - 1 Amendments TBD / TBD

Definitions 1.1 1.1 Definitions CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

CHANNEL OPERATIONAL A COT shall be the injection of a simulated or actual signal TEST (COT) into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS The COLR is the unit specific document that provides cycle REPORT (COLR) specific parameter limits for the current reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.3. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in ICRP 30, Supplement to Part 1, page 192-212, Table titled, "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity".

E - AVERAGE E shall be the average (weighted in proportion to the DISINTEGRATION ENERGY concentration of each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in MeV) for isotopes, other than iodines, with half lives > 15 minutes, making up at least 95% of the total noniodine activity in the coolant.

Beaver Valley Units 1 and 2 1.1 - 2 Amendments TBD / TBD

Definitions 1.1 1.1 Definitions ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from FEATURE (ESF) RESPONSE when the monitored parameter exceeds its actuation setpoint TIME at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

LEAKAGE LEAKAGE shall be:

a.

Identified LEAKAGE 1.

LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank; 2.

LEAKAGE into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or 3.

Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);

b.

Unidentified LEAKAGE All LEAKAGE (except RCP seal water injection or leakoff) that is not identified LEAKAGE; and c.

Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a fault in an RCS component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

Beaver Valley Units 1 and 2 1.1 - 3 Amendments TBD / TBD

Definitions 1.1 1.1 Definitions QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper excore detector RATIO (QPTR) calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) reactor coolant as specified in the Licensing Requirements Manual, and shall not exceed 2900 MWt.

REACTOR TRIP SYSTEM The RTS RESPONSE TIME shall be that time interval from (RTS) RESPONSE TIME when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

SHUTDOWN MARGIN (SDM)

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. However, with all RCCAs verified fully inserted by two independent means, it is not necessary to account for a stuck RCCA in the SDM calculation. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM, and b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level.

SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing all slave relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required slave relay. The SLAVE RELAY TEST shall include a continuity check of associated required testable actuation devices. The SLAVE RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

Beaver Valley Units 1 and 2 1.1 - 5 Amendments TBD / TBD

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Surveillance Frequency Control Program (continued) b.

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1.

c.

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

5.5.16 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMSTR- 0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a.

Implementation of online monitoring for transmitters that have been evaluated during the plant operating cycle in accordance with the NRC approved methodology.

1)

Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check.

2)

Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance.

3)

Calibration checks of identified transmitters no later than during the next refueling outage.

4)

Documentation of the results of the online monitoring data analysis.

b.

Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next refueling outage.

c.

Performance of calibration checks for transmitters at the specified backstop frequencies.

d.

The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

Beaver Valley Units 1 and 2 5.5 - 22 Amendments TBD / TBD

Enclosure to L-24-267 Beaver Valley Power Station Technical Specification Bases Mark-ups (Information only)

RTS Instrumentation B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The nominal trip setpoint and the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report.

For BVPS, the document containing the nominal trip setpoint, the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band is the LRM.

For the RTS Functions with a CHANNEL CALIBRATION modified by Note (l), the Note requires that the instrument channel setpoint be reset to a value within the "as left" setpoint tolerance band on either side of the nominal trip setpoint or to a value that is more conservative than the nominal trip setpoint. The conservative direction is established by the direction of the inequality sign applied to the associated Allowable Value.

Setpoint restoration and post-test verification assure that the assumptions in the plant setpoint methodology are satisfied in order to protect the safety analysis limits. If the channel can not be reset to a value within the required "as left" setpoint tolerance band on either side of the nominal trip setpoint, or to a value that is more conservative than the nominal trip setpoint (if required based on plant conditions) the channel is declared inoperable and the applicable ACTION is entered.

For the RTS Functions with a CHANNEL CALIBRATION modified by Notes (k) and (l), the "as found" and "as left" setpoint data obtained during COTs or CHANNEL CALIBRATIONS are programmatically trended to demonstrate that the rack drift assumptions used in the plant setpoint methodology are valid. If the trending evaluation determines that a channel is performing inconsistent with the uncertainty allowances applicable to the periodic surveillance test being performed, the channel is evaluated under the corrective action program. If the channel is not capable of performing its specified safety function, it is declared inoperable.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.10 is modified by Note 1 stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. In addition, this SR is modified by Note 2 stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range neutron detectors consists Beaver Valley Units 1 and 2 B 3.3.1 - 55 Revision 29 Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 11) and TS 5.5.16, Online Monitoring Program.

RTS Instrumentation B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)

- NOTE -

The following alternate means for verifying response times (i.e.,

summation of allocated times) is only applicable to Unit 2.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g.,

vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test.

WCAP-14036-P-A, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," and WCAP-15413, "Westinghouse 7300A ASIC-Based Replacement Module Licensing Summary Report" provide the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter. WCAP-15413 provides bounding response times where 7300 cards have been replaced with ASICs cards.

As appropriate, each channel's response must be verified at the Frequency specified in the Surveillance Frequency Control Program.

Each verification shall include at least one logic train such that both logic trains are verified at least once per the stated Frequency specified in the Surveillance Frequency Control Program. Response times cannot be determined during unit operation because equipment operation is required to measure response times. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Beaver Valley Units 1 and 2 B 3.3.1 - 58 Revision 29 Insert:

Alternately, the use of the allocated RTS RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

RTS Instrumentation B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.14 is modified by a Note stating that neutron detectors are excluded from RTS RESPONSE TIME testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal. Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response.

REFERENCES

1.

Westinghouse Setpoint Methodology for Protection Systems, WCAP-11419, Rev. 6 (Unit 1) and WCAP-11366, Rev. 7 (Unit 2).

2.

UFSAR, Chapter 7 (Unit 1 and Unit 2).

3.

UFSAR Chapter 14 (Unit 1) and UFSAR Chapter 15 (Unit 2).

4.

IEEE-279-1971.

5.

10 CFR 50.49.

6.

Westinghouse Nuclear Safety Advisory Letter NSAL-00-016, Rod Withdrawal from Subcritical Protection in Lower Modes, December 4, 2000.

7.

WCAP-14333-P-A, Rev. 1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, October 1998.

8.

WOG-06-17, WCAP-10271-P-A Justification for Bypass Test Time and Completion Time Technical Specification Changes for Reactor Trip on Turbine Trip, June 20, 2006.

9.

WCAP-15376-P-A, Rev. 1, Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times, March 2003.

10. Amendment No. 282 (Unit 1) and Amendment No. 166 (Unit 2),

December 29, 2008.

Beaver Valley Units 1 and 2 B 3.3.1 - 59 Revision 11 Insert:

11. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable.

SR 3.3.2.9 This SR ensures the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the accident analysis.

Response Time testing acceptance criteria are included in the Licensing Requirements Manual. Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip Setpoint value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g., pumps at rated discharge pressure, valves in full open or closed position). Each verification shall include at least one logic train such that both logic trains are verified at least once per the stated Frequency specified in the Surveillance Frequency Control Program.

For channels that include dynamic transfer functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer functions set to one or by such means as utilizing a step change input with the resulting measured response time compared to the response time specified in the LRM. Alternately, the response time test can be performed with the time constants set to their nominal value provided the required response time is analytically calculated assuming the time constants are set at their nominal values. The response time may be measured by a series of overlapping tests such that the entire response time is measured.

- NOTE -

The following alternate means for verifying response times (i.e.,

summation of allocated times) is only applicable to Unit 2.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:

Beaver Valley Units 1 and 2 B 3.3.2 - 52 Revision 29 Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 8) and TS 5.5.16, Online Monitoring Program.

ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g.,

vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," dated January 1996, provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test.

WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," and WCAP-15413, "Westinghouse 7300A ASIC-Based Replacement Module Licensing Summary Report" provide the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter. WCAP-15413 provides bounding response times where 7300 cards have been replaced with ASICs cards.

Testing of the final actuation devices, which make up the bulk of the response time, is included in the testing of each channel. The final actuation device in one train is tested with each channel. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 600 psig in the secondary side of the SGs.

Beaver Valley Units 1 and 2 B 3.3.2 - 53 Revision 29 Insert:

Alternately, the use of the allocated ESF RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

ESFAS Instrumentation B 3.3.2 BASES REFERENCES

1.

UFSAR Chapter 14 (Unit 1) and UFSAR Chapter 15 (Unit 2).

2.

IEEE-279-1971.

3.

Westinghouse Setpoint Methodology for Protection Systems, WCAP-11419, Rev. 6 (Unit 1) and WCAP-11366, Rev. 7 (Unit 2).

4.

10 CFR 50.49.

5.

WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

6.

WCAP-14333-P-A, Rev. 1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, October 1998.

7.

Amendment No. 282 (Unit 1) and Amendment No. 166 (Unit 2),

December 29, 2008.

Beaver Valley Units 1 and 2 B 3.3.2 - 54 Revision 29 Insert:

8. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

PAM Instrumentation B 3.3.3 BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.3.2 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. This SR is modified by Note 1 that excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation." In addition, this SR is modified by Note 2 that states the CHANNEL CALIBRATION surveillance is not applicable to the Penetration Flow Path Containment Isolation Valve Position Indication Function. The required valve position indication channels are verified by a Trip Actuating Operational Test (TADOT) in lieu of a CHANNEL CALIBRATION. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the Core Exit thermocouple sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.3.3 This Surveillance requires the performance of a TADOT. The TADOT is only required for the Penetration Flow Path Containment Isolation Valve Position Function on Table 3.3.3-1. The TADOT is adequate to verify the OPERABILITY of the required containment isolation valve position indication channels.

A Note modifies the SRs to specify that SR 3.3.3.3 is only applicable to the Penetration Flow Path Containment Isolation Valve Position Function.

Due to the design of the instrument circuits involved, the TADOT, rather than the CHANNEL CALIBRATION, provides the more appropriate defined test to verify the OPERABILITY of these indication channels.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Beaver Valley Units 1 and 2 B 3.3.3 - 17 Revision 29 Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4) and TS 5.5.16, Online Monitoring Program.

PAM Instrumentation B 3.3.3 BASES REFERENCES

1.

Unit 1 Regulatory Guide 1.97 Submittals: (1) Duquesne Light Letter dated 10/13/86,

Subject:

Regulatory Guide 1.97, Revision 2, Supplemental Report (Complete RG 1.97 report attached),

(2) Duquesne Light Letter dated 4/22/87,

Subject:

RG 1.97, Revision 2, Response to Interim Review Results, (Item 10, Type A classification of the Primary Plant Demineralized Water Storage Tank Level removed), (3) Duquesne Light Letter dated 12/18/89,

Subject:

Response to NRC RG 1.97 Concerns, (Page 4, A1 classification of AFW Flow removed).

Unit 1 NRC Regulatory Guide 1.97 Safety Evaluation Reports (SERs): (1) NRC Letter dated 11/20/89,

Subject:

Completion of Review of Regulatory Guide 1.97 Conformance (TAC No. 51071),

(2) NRC Letter dated 12/30/91,

Subject:

Emergency Response Capability - Conformance to Regulatory Guide 1.97 (TAC No.

M75944), (3) NRC Letter dated 6/15/92,

Subject:

Emergency Response Capability - Conformance To Regulatory Guide 1.97 (TAC No. M75944), (4) NRC Letter dated 11/17/95,

Subject:

Conformance to Regulatory Guide 1.97, Revision 2, Post-Accident Neutron Flux Monitoring Instrumentation for BVPS Unit 1 (TAC No.

M81201).

Unit 2 Regulatory Guide 1.97 Submittal: UFSAR Table 7.5-1.

Unit 2 NRC Regulatory Guide 1.97 SER: NUREG-1057, Supplement No. 1, Section 7.5, May 1986 (original Unit 2 SER).

2.

Regulatory Guide 1.97, Rev. 2, December 1980.

3.

NUREG-0737, Supplement 1, "TMI Action Items."

Beaver Valley Units 1 and 2 B 3.3.3 - 18 Revision 0 Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Remote Shutdown System B 3.3.4 BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.4.2 CHANNEL CALIBRATION is a complete check of an indication instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the resistance temperature detectors (RTD) sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

This SR is modified by a Note that excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation."

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.4.3 SR 3.3.4.3 verifies each required Remote Shutdown System control circuit and transfer switch performs the intended function. This verification is performed from the remote shutdown panel and locally, as appropriate. Operation of the equipment from the remote shutdown panel is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the unit can be maintained in MODE 3 from the Emergency Shutdown Panels (PNL-SHUTDN for Unit 1 and PNL-2SHUTDN for Unit 2).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

10 CFR 50, Appendix A, GDC 19.

Beaver Valley Units 1 and 2 B 3.3.4 - 5 Revision 29 Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 2) and TS 5.5.16, Online Monitoring Program.

Insert:

2. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

OPPS B 3.4.12 BASES SURVEILLANCE REQUIREMENTS (continued)

COT will verify the setpoint is within the PTLR allowed maximum limits in the PTLR. PORV actuation could depressurize the RCS and is not required. The COT Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

A Note has been added indicating that this SR is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after decreasing any RCS cold leg temperature to the OPPS enable temperature specified in the PTLR. This Note provides an exception that allows the COT to be performed when the PORV lift setpoint can be reduced to the OPPS setting if desired. The COT is also met if the Surveillance has been successfully performed in accordance with the Surveillance Frequency Control Program prior to entering the applicable OPPS MODES.

SR 3.4.12.7 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required to adjust the whole channel so that it responds and the valve opens within the required range and accuracy to known input. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

10 CFR 50, Appendix G.

2.

Generic Letter 88-11.

3.

UFSAR Section 4.2.3 (Unit 1) and UFSAR Section 5.2.2.11 (Unit 2).

4.

Generic Letter 90-06.

Beaver Valley Units 1 and 2 B 3.4.12 - 12 Revision 29 Insert:

5. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 5) and TS 5.5.16, Online Monitoring Program.

RCS Leakage Detection Instrumentation B 3.4.15 BASES SURVEILLANCE SR 3.4.15.1 REQUIREMENTS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor. The check gives reasonable confidence that the channel is operating properly. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.15.2 SR 3.4.15.2 requires the performance of a COT on the required containment atmosphere radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specification Surveillance Requirements. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.15.3 and SR 3.4.15.4 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

Unit 1 UFSAR Appendix 1A, "1971 AEC General Design Criteria Conformance" and Unit 2 UFSAR Section 3.1, "Conformance with U.S. Nuclear Regulatory Commission General Design Criteria."

2.

Regulatory Guide 1.45, Revision 0, Reactor Coolant Pressure Boundary Leakage Detection Systems, May 1973.

3.

UFSAR Section 4.2.7.1 (Unit 1) and UFSAR Section 5.2.5 (Unit 2).

Beaver Valley Units 1 and 2 B 3.4.15 - 6 Revision 29 Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4) and TS 5.5.16, Online Monitoring Program.

Enclosure to L-24-267 Comanche Peak Nuclear Power Plant Technical Specification Mark-ups

Definitions 1.1 COMANCHE PEAK - UNITS 1 AND 2 1.1-1 1.0 USE AND APPLICATION 1.1 Definitions

---

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

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE (AFD)

AFD shall be the difference in normalized flux signals between the top and bottom halves of an excore neutron detector.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

Amendment No. 150, 174 INSERT:

(excluding transmitters in the Online Monitoring Program)

Definitions 1.1 1.1 Definitions (continued)

COMANCHE PEAK - UNITS 1 AND 2 1.1-3 DOSE EQUIVALENT XE-133 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-87, Kr-88, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, 1993, External Exposure to Radionuclides in Air, Water, and Soil, or using the dose conversion factors from Table B-1 of Regulatory Guide 1.109, Revision 1, NRC, 1977.

ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

INSERVICE TESTING PROGRAM The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f).

Amendment No. 150, 168, 179 INSERT:

(including transmitters in the Online Monitoring Program)

Definitions 1.1 1.1 Definitions (continued)

COMANCHE PEAK - UNITS 1 AND 2 1.1-6 REACTOR TRIP SYSTEM (RTS) RESPONSE TIME The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

SHUTDOWN MARGIN (SDM)

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the hot zero power temperatures.

SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing all slave relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required slave relay. The SLAVE RELAY TEST shall include a continuity check of associated testable actuation devices. The SLAVE RELAY TEST may be performed by means of any series of sequential, overlapping or total steps.

STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

Amendment No. 150, 179 INSERT:

(including transmitters in the Online Monitoring Program)

Programs and Manuals 5.5 5.5 Programs and Manuals COMANCHE PEAK - UNITS 1 AND 2 5.5-19 5.5.23 Risk Informed Completion Time Program (continued)

Amendment No. 183

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INSERT:

New TS 5.5.24 here

5.5.24 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a.

Implementation of online monitoring for transmitters that have been evaluated during the plant operating cycle in accordance with the NRC approved methodology.

1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check.

2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance.

3) Calibration checks of identified transmitters no later than during the next refueling outage.

4) Documentation of the results of the online monitoring data analysis.

b.

Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next refueling outage.

c.

Performance of calibration checks for transmitters at the specified backstop frequencies.

d.

The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

INSERT

Enclosure to L-24-267 Comanche Peak Nuclear Power Plant Technical Specification Clean Typed

Definitions 1.1 COMANCHE PEAK - UNITS 1 AND 2 1.1-1 1.0 USE AND APPLICATION 1.1 Definitions

---

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

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTUATION LOGIC TEST AXIAL FLUX DIFFERENCE (AFD)

CHANNEL CALIBRATION CHANNEL CHECK ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AFD shall be the difference in normalized flux signals between the top and bottom halves of an excore neutron detector.

A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

Amendment No. 150, 174, TBDTBD

Definitions 1.1 1.1 Definitions (continued)

COMANCHE PEAK - UNITS 1 AND 2 1.1-3 DOSE EQUIVALENT XE-133 ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME INSERVICE TESTING PROGRAM DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-87, Kr-88, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, 1993, External Exposure to Radionuclides in Air, Water, and Soil, or using the dose conversion factors from Table B-1 of Regulatory Guide 1.109, Revision 1, NRC, 1977.

The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f).

Amendment No. 150, 168, 179, TBDTBD

Definitions 1.1 1.1 Definitions (continued)

COMANCHE PEAK - UNITS 1 AND 2 1.1-6 REACTOR TRIP SYSTEM (RTS) RESPONSE TIME The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

SHUTDOWN MARGIN (SDM)

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the hot zero power temperatures.

SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing all slave relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required slave relay. The SLAVE RELAY TEST shall include a continuity check of associated testable actuation devices. The SLAVE RELAY TEST may be performed by means of any series of sequential, overlapping or total steps.

STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

Amendment No. 150, 179, TBDTBD

Programs and Manuals 5.5 5.5 Programs and Manuals COMANCHE PEAK - UNITS 1 AND 2 5.5-19 5.5.23 Risk Informed Completion Time Program (continued)

Amendment No. 183 188, TBD H

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5.5.24 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a.

Implementation of online monitoring for transmitters that have been evaluated during the plant operating cycle in accordance with the NRC approved methodology.

1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check.

2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance.

3) Calibration checks of identified transmitters no later than during the next refueling outage.

4) Documentation of the results of the online monitoring data analysis.

b.

Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next refueling outage.

Programs and Manuals 5.5 5.5 Programs and Manuals COMANCHE PEAK - UNITS 1 AND 2 5.5-20 Amendment No. TBD c

d

5.5.24 Online Monitoring Program (continued)

Performance of calibration checks for transmitters at the specified backstop frequencies.

The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

Enclosure to L-24-267 Comanche Peak Nuclear Power Plant Technical Specification Bases Mark-ups (Information only)

RTS Instrumentation B 3.3.1 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-51 Revision 88 SURVEILLANCE REQUIREMENTS SR 3.3.1.10 (continued)

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.10 is modified by Note 2 stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. This surveillance does not include verification of time delay relays. These relays are verified via response time testing per SR 3.3.1.16. Whenever an RTD is replaced in Functions 6 or 7, the next required CHANNEL CALIBRATION of the RTDs is accomplished by an inplace cross calibration that compares other sensing elements with the recently installed element.

The SR is modified by Note 3 stating that, prior to entry into MODES 2 or 1, power and intermediate range detector plateau verification is not required to be performed until 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after achieving equilibrium conditions with THERMAL POWER 90% RTP.

SR 3.3.1.10 for selected Functions is also modified by two Notes (q and r) as identified in Table 3.3.1-1. The selected Functions are those Functions that are LSSS and whose instruments are not mechanical devices (i.e. limit switches, float switches, and proximity detectors). Mechanical devices are excluded since it is not possible to trend these devices and develop as-left or as-found limits in the same manner as other instrumentation. The first Note (q) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of instrument performance will verify that the instrument will continue to behave in accordance with design-basis assumptions. The purpose of the assessment is to ensure confidence in the instrument performance prior to returning the instrument to service. These channels will also be identified in the Corrective Action Program. In accordance with procedures, entry into the Corrective Action Program will require review and documentation of the condition for OPERABILITY. The second Note (r) requires that the as-left setting for the instrument be returned to within the as-left tolerance of the Nominal Trip Setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left instrument setting cannot be returned to a setting within the as-left tolerance, then the instrument channel shall be declared inoperable. This second Note (r) requirement identifies the Limited Safety System Setting and allows an (continued)

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 16) and TS 5.5.24, Online Monitoring Program.

RTS Instrumentation B 3.3.1 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-54 Revision 88 SURVEILLANCE REQUIREMENTS SR 3.3.1.16 (continued)

For channels that include dynamic transfer Functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer Function time constants set at their nominal values.

---

REVIEWERS NOTE--------------------------------

Portions of the following Bases are applicable for plants adopting WCAP-14036-P-A and the methodology contained in Attachment 1 to TSTF-569.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be used for selected components provided that the components and methodology for verification have been previously NRC approved.

WCAP-14036-P-A, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," (Ref. 10) provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.

The response time may be verified for components that replace the components that were previously evaluated in reference 10, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, "Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing," (Ref. 15).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Response time verification in lieu of actual testing may be performed on RTS components in accordance with reference 10.

(continued)

Insert:

Alternately, the use of the allocated RTS RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

RTS Instrumentation B 3.3.1 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-56 Revision 88 REFERENCES (continued) 14.

Westinghouse Nuclear Safety Advisory Letter (NSAL) 09-1, Rod Withdrawal at Power Analysis for Reactor Coolant System Overpres-sure, February 4, 2009.

15. to TSTF-569, Methodology to Eliminate Pressure Sen-sor and Protection Channel (for Westinghouse Plants only)

Response Time Testing.

Insert:

16. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

ESFAS Instrumentation B 3.3.2 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-103 Revision 88 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.8 SR 3.3.2.8 is the performance of a TADOT. This test is a check of the Manual Actuation Functions and AFW pump start on trip of all MFW pumps.

The Safety Injection TADOT shall independently verify the OPERABILITY of the handswitch undervoltage and shunt trip contacts for both the Reactor Trip Breakers and Reactor Trip Bypass Breakers as well as the contacts for safety injection actuation. As a minimum, each Manual Actuation Function is tested up to, but not including, the master relay coils. This test overlaps with the master relay coil testing performed in accordance with SR 3.3.2.4. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The SR is modified by a Note that excludes verification of setpoints during the TADOT for manual initiation Functions. The manual initiation Functions have no associated setpoints.

SR 3.3.2.9 SR 3.3.2.9 is the performance of a CHANNEL CALIBRATION.

A CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable.

SR 3.3.2.9 for selected Functions is also modified by two Notes (q and r) as identified in Table 3.3.2-1. The selected Functions are those Functions that are LSSS and whose instruments are not mechanical devices (i.e. limit switches, float switches, and proximity detectors). Mechanical devices are excluded since it is not possible to trend these devices and develop as-left or as-found limits in the same manner as other instrumentation. The first Note (q) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of instrument performance will verify that the instrument will continue to behave in (continued)

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 15) and TS 5.5.24, Online Monitoring Program.

ESFAS Instrumentation B 3.3.2 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-105 Revision 88 SURVEILLANCE REQUIREMENTS SR 3.3.2.10 (continued)

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be used for selected components provided that the components and methodology for verification have been previously NRC approved.

WCAP-14036-P-A, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," (Ref. 11) provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.

The response time may be verified for components that replace the components that were previously evaluated in reference 11, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, "Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing," (Ref. 14).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Response time verification in lieu of actual testing may be performed on ESFAS components in accordance with reference 11.

This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 532 psig in the SGs.

SR 3.3.2.11 SR 3.3.2.11 is the performance of a TADOT as described in SR 3.3.2.8, except that it is performed for the P-4 Reactor Trip Interlock. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Function tested has no associated setpoint.

(continued)

Insert:

Alternately, the use of the allocated ESF RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

ESFAS Instrumentation B 3.3.2 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-106 Revision 88 REFERENCES 1.

FSAR, Chapter 6.

2.

FSAR, Chapter 7.

3.

FSAR, Chapter 15.

4.

IEEE-279-1971.

5.

10 CFR 50.49.

6.

WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

7.

Technical Requirements Manual.

8.

WCAP-10271-P-A, Supplement 3, September 1990.

9.

"Westinghouse Setpoint Methodology for Protection Systems Comanche Peak Unit 1, Revision 1," WCAP-12123, Revision 2, April, 1989.

10.

WCAP-13877-P-A, Revision 2, August 2000.

11.

Elimination of Periodic Protection Channel Response Time Tests, WCAP-14036-P-A, Revision 1, October 6, 1998.

12.

Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, WCAP-14333-P-A, Revision 1, October 1998.

13.

Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times, WCAP-15376-P-A, Revision 1, March 2003.

14. to TSTF-569, "Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only Response Time Testing.

Insert:

15. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

PAM Instrumentation B 3.3.3 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-123 Revision 88 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.3.3 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation." Whenever an RTD is replaced in Function 3 or 4, the next required CHANNEL CALIBRATION of the RTDs is accomplished by an inplace cross calibration that compares other sensing elements with the recently installed element.

Whenever a core exit thermocouple replaced in Functions 15 thru 18, the next required CHANNEL CALIBRATION of the core exit thermocouples is accomplished by an in-place cross calibration that compares the other sensing elements with the recently installed sensing element. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Containment Radiation Level (High Range) CHANNEL CALIBRATION may consist of an electronic calibration of the channel, not including the detector, for range decades above 10R/hr and a one point calibration check of the detector below 10R/hr with an installed or portable gamma source.

REFERENCES 1.

FSAR Section 7.5.

2.

Regulatory Guide 1.97, Revision 2, December 1980.

3.

NUREG-0737, Supplement 1, "TMI Action Items."

4.

Not used 5.

Generic Letter 83-37, NUREG-0373 Technical Specifications, November 1, 1983.

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 6) and TS 5.5.24, Online Monitoring Program.

Insert:

6. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Remote Shutdown System B 3.3.4 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-128 Revision 88 SURVEILLANCE REQUIREMENTS SR 3.3.4.1 (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.4.2 SR 3.3.4.2 verifies each required Remote Shutdown System HSP power and control circuit and transfer switch performs the intended function including isolation (as described in FSAR section 7.4). This verification is performed from the Hot Shutdown Panel and locally, as appropriate. Operation of the equipment from the remote shutdown panel is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the unit can be placed and maintained in MODE 3 from the remote shutdown panel and the local control stations. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.4.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the resistance temperature detectors (RTD) sensors is accomplished by an in-place cross calibration that compares the other sensing elements with the recently installed sensing element. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

10 CFR 50, Appendix A, GDC 3 and 19.

2.

FSAR Section 7.4 Insert:

3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 3) and TS 5.5.24, Online Monitoring Program.

LTOP System B 3.4.12 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.4-62 Revision 85 SURVEILLANCE REQUIREMENTS SR 3.4.12.8 (continued)

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance considers the unlikelihood of a low temperature overpressure event during this time.

A Note has been added indicating that this SR is required to be performed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after decreasing RCS cold leg temperature to 350°F. The test must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering the LTOP MODES.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.12.9 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required to adjust the whole channel so that it responds and the valve opens within the required range and accuracy to known input.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

10 CFR 50, Appendix G.

2.

Generic Letter 88-11.

3.

ASME, Boiler and Pressure Vessel Code,Section III.

4.

FSAR, Chapter 15.

5.

10 CFR 50, Section 50.46.

6.

10 CFR 50, Appendix K.

7.

Generic Letter 90-06.

8.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

9.

FSAR, Chapter 5.

Insert:

10. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 10) and TS 5.5.24, Online Monitoring Program.

RCS Leakage Detection Instrumentation B 3.4.15 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.4-81 Revision 85 SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.15.3, SR 3.4.15.4, and SR 3.4.15.5 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

10 CFR 50, Appendix A, Section IV, GDC 30.

2.

Regulatory Guide 1.45, Revision 0, Reactor Coolant Pressure Boundary Leakage Detection Systems, May 1973.

3.

FSAR, Section 5.2.

Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4) and TS 5.5.24, Online Monitoring Program.

Enclosure to L-24-267 Davis-Besse Nuclear Power Station Technical Specification Mark-ups

Definitions 1.1 Davis-Besse 1.1-1 Amendment 279 1.0 USE AND APPLICATION 1.1 Definitions

---

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

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ALLOWABLE THERMAL ALLOWABLE THERMAL POWER shall be the maximum POWER reactor core heat transfer rate to the reactor coolant permitted by consideration of the number and configuration of reactor coolant pumps (RCPs) in operation.

AXIAL POWER IMBALANCE AXIAL POWER IMBALANCE shall be the power in the top half of the core, expressed as a percentage of RATED THERMAL POWER (RTP), minus the power in the bottom half of the core, expressed as a percentage of RTP.

AXIAL POWER SHAPING APSRs shall be control components used to control the axial RODS (APSRs) power distribution of the reactor core. The APSRs are positioned manually by the operator and are not trippable.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of INSERT:

(excluding transmitters in the Online Monitoring Program)

Definitions 1.1 Davis-Besse 1.1-5 Amendment 279 1.1 Definitions REACTOR PROTECTION The RPS RESPONSE TIME shall be that time interval from SYSTEM (RPS) RESPONSE when the monitored parameter exceeds its RPS trip setpoint at TIME the channel sensor until electrical power is interrupted at the control rod drive trip breakers. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

SAFETY FEATURES The SFAS RESPONSE TIME shall be that time interval from ACTUATION SYSTEM (SFAS) when the monitored parameter exceeds its SFAS actuation RESPONSE TIME setpoint at the channel sensor until the SFAS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

SHUTDOWN MARGIN (SDM)

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All full length CONTROL RODS (safety and regulating) are fully inserted except for the single CONTROL ROD of highest reactivity worth, which is assumed to be fully withdrawn. With any CONTROL ROD not capable of being fully inserted, the reactivity worth of these CONTROL RODS must be accounted for in the determination of SDM;

b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level; and

c.

There is no change in APSR position.

STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, trains, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, trains, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, trains, channels, or other designated components in the associated function.

Insert:

In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

Definitions 1.1 Davis-Besse 1.1-6 Amendment 279 1.1 Definitions STEAM AND FEEDWATER The SFRCS RESPONSE TIME shall be that time interval from RUPTURE CONTROL when the monitored parameter exceeds its SFRCS actuation SYSTEM (SFRCS) setpoint at the channel sensor until the SFRCS equipment is RESPONSE TIME capable of performing its safety function (i.e., valves travel to their required positions, pumps discharge pressures reach their required values, etc.). The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

Insert:

In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

Programs and Manuals 5.5 Davis-Besse 5.5-15 Amendment 301 5.5 Programs and Manuals 5.5.18 Surveillance Frequency Control Program (continued) are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a.

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

b.

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1.

c.

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

INSERT:

New TS 5.5.19 here

5.5.19 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a.

Implementation of online monitoring for transmitters that have been evaluated during the plant operating cycle in accordance with the NRC approved methodology.

1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check.

2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance.

3) Calibration checks of identified transmitters no later than during the next refueling outage.

4) Documentation of the results of the online monitoring data analysis.

b.

Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next refueling outage.

c.

Performance of calibration checks for transmitters at the specified backstop frequencies.

d.

The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

Insert

Enclosure to L-24-267 Davis-Besse Nuclear Power Station Technical Specification Clean Typed

Definitions 1.1 Davis-Besse 1.1-1 Amendment TBD 1.0 USE AND APPLICATION 1.1 Definitions

---

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

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ALLOWABLE THERMAL ALLOWABLE THERMAL POWER shall be the maximum POWER reactor core heat transfer rate to the reactor coolant permitted by consideration of the number and configuration of reactor coolant pumps (RCPs) in operation.

AXIAL POWER IMBALANCE AXIAL POWER IMBALANCE shall be the power in the top half AXIAL POWER SHAPING RODS (APSRs)

CHANNEL CALIBRATION CHANNEL CHECK of the core, expressed as a percentage of RATED THERMAL POWER (RTP), minus the power in the bottom half of the core, expressed as a percentage of RTP.

APSRs shall be control components used to control the axial power distribution of the reactor core. The APSRs are positioned manually by the operator and are not trippable.

A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of

Definitions 1.1 Davis-Besse 1.1-5 Amendment TBD 1.1 Definitions REACTOR PROTECTION The RPS RESPONSE TIME shall be that time interval from SYSTEM (RPS) RESPONSE when the monitored parameter exceeds its RPS trip setpoint at TIME the channel sensor until electrical power is interrupted at the control rod drive trip breakers. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

SAFETY FEATURES ACTUATION SYSTEM (SFAS)

RESPONSE TIME The SFAS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its SFAS actuation setpoint at the channel sensor until the SFAS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology has been previously reviewed and approved by the NRC.

SHUTDOWN MARGIN (SDM)

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All full length CONTROL RODS (safety and regulating) are fully inserted except for the single CONTROL ROD of highest reactivity worth, which is assumed to be fully withdrawn. With any CONTROL ROD not capable of being fully inserted, the reactivity worth of these CONTROL RODS must be accounted for in the determination of SDM; b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level; and c.

There is no change in APSR position.

Definitions 1.1 Davis-Besse 1.1-6 Amendment TBD 1.1 Definitions STEAM AND FEEDWATER RUPTURE CONTROL SYSTEM (SFRCS)

RESPONSE TIME THERMAL POWER The SFRCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its SFRCS actuation setpoint at the channel sensor until the SFRCS equipment is capable of performing its safety function (i.e., valves travel to their required positions, pumps discharge pressures reach their required values, etc.). The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC..

THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, trains, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, trains, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, trains, channels, or other designated components in the associated function.

Programs and Manuals 5.5 Davis-Besse 5.5-15 Amendment TBD 5.5 Programs and Manuals 5.5.18 Surveillance Frequency Control Program (continued) are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a.

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

b.

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1.

c.

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

5.5.19 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a.

Implementation of online monitoring for transmitters that have been evaluated during the plant operating cycle in accordance with the NRC approved methodology.

1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check.

2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance.

3) Calibration checks of identified transmitters no later than during the next refueling outage.

4) Documentation of the results of the online monitoring data analysis.

Programs and Manuals 5.5 Davis-Besse 5.5-16 Amendment TBD 5.5 Programs and Manuals 5.5.19 Online Monitoring Program (continued)

Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next refueling outage.

Performance of calibration checks for transmitters at the specified backstop frequencies.

The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

b.

c.

d.

Enclosure to L-24-267 Davis-Besse Nuclear Power Station Technical Specification Bases Mark-ups (Information only)

RPS Instrumentation B 3.3.1 Davis-Besse B 3.3.1-27 Revision 32 BASES SURVEILLANCE REQUIREMENTS SR 3.3.1.6 A CHANNEL CALIBRATION is a complete check of the instrument channel, including the sensor. The test verifies that the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drift to ensure that the instrument channel remains operational between successive tests. CHANNEL CALIBRATION shall find that measurement errors and bistable setpoint errors are within the assumptions of the unit specific setpoint analysis. CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint analysis.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.7 A CHANNEL CALIBRATION is a complete check of the instrument channel, including the sensor. The test verifies that the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drift to ensure that the instrument channel remains operational between successive tests. CHANNEL CALIBRATION shall find that measurement errors and bistable setpoint errors are within the assumptions of the unit specific LTSP analysis. CHANNEL CALIBRATONS must be performed consistent with the assumptions of the unit specific setpoint analysis. Whenever a resistance temperature detector (RTD) sensing element is replaced, the next required CHANNEL CALIBRATION of the RTD sensors is accomplished by an inplace qualitative calibration that compares the other sensing elements with the recently installed sensing element. A Note to the SR states that for Function 8, Flux - Flux - Flow, only the flow rate measurement sensors are required to be calibrated.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 11) and TS 5.5.19, Online Monitoring Program.

RPS Instrumentation B 3.3.1 Davis-Besse B 3.3.1-29 Revision 32 BASES SURVEILLANCE REQUIREMENTS SR 3.3.1.8 This SR verifies individual channel actuation response times are less than or equal to the maximum values assumed in the accident analysis.

Individual component response times are not modeled in the analyses.

The analyses model the overall, or total, elapsed time from the point at which the parameter exceeds the analytical limit at the sensor to the point of rod insertion (CRD trip breakers open). Thus, this SR encompasses the reactor trip module components covered by LCO 3.3.3 and the operation of the mechanical components covered by LCO 3.3.4 (i.e., the CRD trip breakers). Response time testing acceptance criteria are included in Reference 2.

A Note to the Surveillance indicates that neutron detectors are excluded from RPS RESPONSE TIME testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal. Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response. The response time of the neutron flux signal portion of the channel shall be measured from the neutron detector output or from the input of the first electronic components in the channel.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Insert:

Alternately, the use of the allocated RPS RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

RPS Instrumentation B 3.3.1 Davis-Besse B 3.3.1-30 Revision 32 BASES REFERENCES

1.

Regulatory Guide 1.105, Revision 3, "Setpoints for Safety Related Instrumentation."

2.

Technical Requirements Manual.

3.

Figure 7.2-1, UFSAR 7.2.

4.

Table 15.1-2, UFSAR Section 15.1.2.

5.

10 CFR 50.49.

6.

ISA 67.04-Part II-1994, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation."

7.

ISA 67.04.02-2000, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation."

8.

UFSAR, Section 15.0.

9.

NRC SER for Amendment No. 185 to Facility Operating License No.

NPF-3, Davis-Besse, dated March 28, 1994.

10.

BAW-10167, May 1986.

Insert:

11. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

SFAS Instrumentation B 3.3.5 Davis-Besse B 3.3.5-14 Revision 32 BASES SURVEILLANCE REQUIREMENTS SR 3.3.5.2 (continued) the Surveillance. It is not acceptable to routinely remove channels from service for more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to perform required Surveillance testing.

A CHANNEL FUNCTIONAL TEST is performed on each required SFAS channel to ensure the entire channel will perform the intended functions.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable if all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. Any setpoint adjustment shall be consistent with the assumptions of the current unit specific setpoint analysis. The CHANNEL FUNCTIONAL TEST of the RCS Pressure - Low and - Low Low instrumentation includes the logic for the RCS pressure operating bypasses.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.3 and SR 3.3.5.4 CHANNEL CALIBRATION is a complete check of the instrument channel, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drift to ensure that the instrument channel remains operational between successive tests. CHANNEL CALIBRATION shall find that measurement errors and bistable setpoint errors are within the assumptions of the unit specific setpoint analysis. CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint analysis. The CHANNEL CALIBRATION of the RCS Pressure - Low and - Low Low instrumentation includes the RCS pressure operating bypass function.

The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 9) and TS 5.5.19, Online Monitoring Program.

SFAS Instrumentation B 3.3.5 Davis-Besse B 3.3.5-15 Revision 32 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.5.5 SR 3.3.5.5 ensures that the SFAS actuation channel response times are less than or equal to the maximum times assumed in the accident analysis. The response time values are the maximum values assumed in the safety analyses. Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time from the point at which the parameter exceeds the actuation setpoint value at the sensor to the point at which the end device is actuated.

Thus, this SR encompasses the automatic actuation logic components covered by LCO 3.3.7 and the operation of the mechanical ESF components. Response time testing acceptance criteria for this unit are included in Reference 8.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Table 7.3-2.

2.

UFSAR, Figures 7.3-1 through 7.3-8.

3.

UFSAR, Section 7.3.1.1.2.

4.

10 CFR 50.49.

5.

ISA RP 67.04-Part II - 1994, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation."

6.

ISA RP 67.04.02 - 2000, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation."

7.

UFSAR, Section 6.3.

8.

Technical Requirements Manual.

Insert:

Alternately, the use of the allocated SFAS RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

Insert:

9. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

SFRCS Instrumentation B 3.3.11 Davis-Besse B 3.3.11-14 Revision 32 BASES SURVEILLANCE REQUIREMENTS SR 3.3.11.3 and SR 3.3.11.4 (continued)

The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

SR 3.3.11.3 for Functions 1 and 2 and SR 3.3.11.4 for Function 3 are modified by two Notes as identified in Table 3.3.11-1. These Functions are an LSSS for protection system instrument channels that protect reactor core or RCS pressure boundary Safety Limits. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. For digital channel components, the as-found tolerance may be identical to the as-left tolerance since drift may not be an expected error. In these cases, a channel as-found value outside the as-left condition may be cause for component assessment. Evaluation of instrument performance will verify that the instrument will continue to behave in accordance with design basis assumptions. The purpose of the assessment is to ensure confidence in the instrument performance prior to returning the instrument to service. These channels will also be identified in the Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition for continued OPERABILITY.

The second Note requires that the as-left setting for the instrument be returned to within the as-left tolerance around the LTSP, or a value that is more conservative than the LTSP. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left instrument setting cannot be returned to a setting within the as-left tolerance or a setting more conservative than the LTSP, then the instrument channel shall be declared inoperable. The second Note also requires that the LTSP and the methodology used to determine the LTSP, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in the TRM (Ref. 6).

SR 3.3.11.5 This SR verifies individual channel actuation response times are less than or equal to the maximum value assumed in the accident analysis.

Individual component response times are not modeled in the analysis.

The analysis models the overall or total elapsed time, from the point at which the parameter exceeds the actuation setpoint value at the sensor, to the point at which the end device is actuated. Thus, this SR Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 7) and TS 5.5.19, Online Monitoring Program.

SFRCS Instrumentation B 3.3.11 Davis-Besse B 3.3.11-15 Revision 32 BASES SURVEILLANCE REQUIREMENTS SR 3.3.11.5 (continued) encompasses the automatic actuation logic components covered by LCO 3.3.13, "Steam and Feedwater Rupture Control System (SFRCS)

Actuation," and the operation of the mechanical components (i.e.,

auxiliary feedwater pumps, main steam isolation valves, main feedwater valves, and turbine stop valves). Response time testing acceptance criteria are included in the TRM (Ref. 6).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 7.4.1.3, Figure 7.4-4.

2.

10 CFR 50.49.

3.

ISA RP 67.04 Part II 1994, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation."

4.

ISA RP 67.04.02-2000, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation."

5.

UFSAR, Table 7.4-1.

6.

Technical Requirements Manual (TRM).

Insert:

7. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

Alternately, the use of the allocated SFRCS RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

ARTS Instrumentation B 3.3.16 Davis-Besse B 3.3.16-6 Revision 32 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.16.3 CHANNEL CALIBRATION is a complete check of the instrument channel, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drift between successive calibrations to ensure that the channel remains operational between successive tests. CHANNEL CALIBRATIONS must be performed consistent with the unit specific setpoint and tolerance.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

NUREG-0737, November 1979.

2.

UFSAR, Section 7.4.1.4 and Figure 7.4-8.

3.

NRC SER for BAW-10167, Supplement 3, January 7, 1998.

4.

NRC SER for BAW-10167, Supplement 2, July 8, 1992.

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 5) and TS 5.5.19, Online Monitoring Program.

Insert:

5. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

PAM Instrumentation B 3.3.17 Davis-Besse B 3.3.17-11 Revision 32 BASES SURVEILLANCE REQUIREMENTS SR 3.3.17.1 (continued)

Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE. If the channels are normally off scale during times when surveillance is required, the CHANNEL CHECK will only verify that they are off scale in the same direction. Offscale low current loop channels are verified to be reading at the bottom of the range and not failed downscale.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CHANNEL CHECK supplements less formal but more frequent checks of channels during normal operational use of the displays associated with this LCO's required channels.

SR 3.3.17.2 CHANNEL CALIBRATION is a complete check of the instrument channel, including the sensor. This test verifies the channel responds to measured parameters within the necessary range and accuracy.

A Note clarifies that the neutron detectors are not required to be tested as part of the CHANNEL CALIBRATION. There is no adjustment that can be made to the detectors. Furthermore, adjustment of the detectors is unnecessary because they are passive devices, with minimal drift.

Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the Incore Thermocouple sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4) and TS 5.5.19, Online Monitoring Program.

PAM Instrumentation B 3.3.17 Davis-Besse B 3.3.17-12 Revision 32 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.17.3 CHANNEL CAILIBRATION is a complete check of the instrument channel, including the sensor. This test verifies the channel responds to measured parameters within the necessary range and accuracy.

For the Containment High Range Radiation Monitors, a CHANNEL CALIBRATION may consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/hr, and a one point calibration check of the detector below 10 R/hr with a gamma source.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 7.13.

2.

Regulatory Guide 1.97.

3.

NUREG-0737, 1979.

Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4) and TS 5.5.19, Online Monitoring Program.

Remote Shutdown System B 3.3.18 Davis-Besse B 3.3.18-5 Revision 32 BASES SURVEILLANCE REQUIREMENTS SR 3.3.18.1 (continued) are off scale in the same direction. Off scale low current loop channels are verified to be reading at the bottom of the range and not failed downscale.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.18.2 CHANNEL CALIBRATION is a complete check of the instrument loop and sensor. The test verifies that the channel responds to measured parameters within the necessary range and accuracy.

Whenever a resistance temperature detector (RTD) is replaced, the next required CHANNEL CALIBRATION of the RTD sensor is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.18.3 SR 3.3.18.3 verifies each control circuit and transfer switch required for a serious control room fire or cable spreading room fire performs their intended function. This verification is performed from the remote shutdown panel and locally, as appropriate. Operation of the equipment from the remote shutdown panel or remotely is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if a serious control room or cable spreading room fire occurs, the requirement of the Fire Protection Program can be met. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 3) and TS 5.5.19, Online Monitoring Program.

Remote Shutdown System B 3.3.18 Davis-Besse B 3.3.18-6 Revision 32 BASES REFERENCES

1.

UFSAR, Appendix 3D.1.15, Criterion 19 - Control Room.

2.

10 CFR 50, Fire Protection.

Insert:

3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

RCS PIV Leakage B 3.4.14 Davis-Besse B 3.4.14-6 Revision 32 BASES SURVEILLANCE REQUIREMENTS SR 3.4.14.2 (continued) pressures. Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complimentary to the Frequency of prior to entry into MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months.

SR 3.4.14.3 and SR 3.4.14.4 Verifying that the DHR interlocks are OPERABLE ensures that RCS pressure will not pressurize the DHR system beyond 430 psig, the pressure at which this section of DHR piping was tested. The interlock setpoint that prevents the valves from being opened is set so the actual RCS pressure must be < 328 psig at the RCS pressure instrumentation tap to open the valves. This setpoint allows DH-11 and DH-12 to be opened by the operator prior to the point where net positive suction pressure is lost to the reactor coolant pumps. The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

These SRs are modified by Notes allowing the DHR System interlock function to be disabled when using the DHR System suction relief valve for cold overpressure protection in accordance with LCO 3.4.12. This allowance is necessary since opening and removing control power to the DHR System isolation valves (as required by LCO 3.4.12) disables the interlock.

SR 3.4.14.5 SR 3.4.14.5 requires the performance of a CHANNEL CALIBRATION of the DHR System interlock channels (both the channel common to SFAS instrumentation and the channel not common to SFAS instrumentation).

The calibration verifies the accuracy of the instrument string. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 9) and TS 5.5.19, Online Monitoring Program.

RCS PIV Leakage B 3.4.14 Davis-Besse B 3.4.14-7 Revision 32 BASES REFERENCES

1.

10 CFR 50.2.

2.

10 CFR 55a(c).

3.

10 CFR 50, Appendix A, Section V, GDC 55.

4.

NUREG-75/014, Appendix V, October 1975.

5.

Letter from D.G. Eisenhut, NRC, to all LWR Licenses, LWR Primary Coolant System Pressure Isolation Valves, February 23, 1980.

6.

Letter from J.F. Stoltz, NRC, to R.P. Crouse, Order for Modification of License Concerning Primary Coolant System Pressure Isolation Valves, April 20, 1981.

7.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

8.

10 CFR 50.55a(g).

Insert:

9. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

RCS Leakage Detection Instrumentation B 3.4.15 Davis-Besse B 3.4.15-6 Revision 32 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.15.3 and SR 3.4.15.4 These SRs require the performance of a CHANNEL CALIBRATION for each of the required RCS leakage detection instrumentation channels.

The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4) and TS 5.5.19, Online Monitoring Program.

RCS Leakage Detection Instrumentation B 3.4.15 Davis-Besse B 3.4.15-7 Revision 32 BASES REFERENCES

1.

10 CFR 50, Appendix A, Section IV, GDC 30.

2.

Regulatory Guide 1.45, Revision 0, REACTOR COOLANT PRESSURE BOUNDARY LEAKAGE DETECTION SYSTEMS, May 1973.

3.

USAR Section 5.2.4.

Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

EFW B 3.7.5 Davis-Besse B 3.7.5-10 Revision 32 BASES SURVEILLANCE REQUIREMENTS SR 3.7.5.8, SR 3.7.5.9, and SR 3.7.5.10 (continued) criteria, it may be an indication that the detector or the signal processing equipment has drifted outside its limit. If the channels are normally off scale during times when surveillance is required, the CHANNEL CHECK will only verify that they are off scale in the same direction.

A CHANNEL FUNCTIONAL TEST is performed on each channel to ensure the entire channel will perform the intended function.

CHANNEL CALIBRATION is a complete check of the instrument channel, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drift between successive calibrations to ensure that the channel remains operational between successive tests. CHANNEL CALIBRATIONS must be performed consistent with the unit specific setpoint and tolerance.

The CHANNEL CHECK supplements less formal, but more frequent, checks of channel operability during normal operational use of the displays associated with the LCO's required channels.

The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 9.2.7.

2.

UFSAR, Section 9.2.8.

3.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4) and TS 5.5.19, Online Monitoring Program.

Enclosure to L-24-267 0

Perry Nuclear Power Plant Technical Specification Mark-ups

1.0 USE ANO APPLICATION 1.1 Definitions Definitions 1.1

---

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

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

ACTIONS AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

CHANNEL CALIBRATION CHANNEL CHECK PERRY - UN IT l Definition ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

The APLHGR shall be applicable to a specific planar height and is equal to the sum of the LHGRs for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle at the height.

A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors.

The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST.

Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.

The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is calibrated.

A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

(continued) 1.0-1 Amendment No. 69 INSERT:

(excluding transmitters in the Online Monitoring Program)

1.1 Definitions (continued)

EMERGENCY CORE COOLING SYSTEM(ECCS)RESPONSE TIME END OF CYCLE RECIRCULATION PUMP TRIP (EOC-RPT) SYSTEM RESPONSE TIME Definitions 1.1 The ECCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e.,

the valves travel to their required positions, pump discharge pressures reach their required values, etc.).

Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. Exceptions are stated in the individual surveillance requirements.

The EOC - RPT SYSTEM RESPONSE TIME shall be that time interval from initial movement of the associated turbine stop valve or the turbine control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

INSERVICE TESTING PROGRAM The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f).

ISOLATION SYSTEM RESPONSE TIME PERRY - UNIT 1 The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. Exceptions are stated in the individual surveillance requirements.

(continued) 1.0-3 Amendment No.175 Insert:

In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

Definitions 1.1 1.1 Definitions (continued)

MINIMUM CRITICAL POWER RATIO CMCPR)

MODE OPERABLE~OPERABILITY RATED THERMAL POWER CRTP)

REACTOR PROTECTION SYSTEM CRPS) RESPONSE TIME PERRY - UN IT 1 The MCPR shall be the smallest critical power ratio CCPR) that exists in the core for each class of fuel. The C P~ is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition.

divided by the actual assembly operating power.

A MODE shall correspond to any one inclusive combination of mode switch position. average reactor coolant temperature. and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

A system. subsystem. division. component. or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation. controls. normal or emergency electrical power. cooling and seal water.

lubrication. and other auxiliary equipment that are required for the system. subsystem. division.

component. or device to perform its specified safety function(s) are also capable of performing their related support function(s).

RTP sha 11 be a tota 1 reactor core heat transfer rate to the reactor coolant of 3758 MWt.

The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids.

The response time may be measured by means of any series of sequential. overlapping, or total steps so that the entire response time is measured. Exceptions are stated in the individual surveillance requirements.

(continued)

1. 0-5 Amendment No. 112 Insert:

In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

Programs and Manuals 5.5 PERRY - UNIT 1 5.0-15e Amendment No. 193 5.5 Programs and Manuals 5.5.16 Battery Monitoring and Maintenance Program (continued) 4.

In Regulatory Guide 1.129, Regulatory Position 3, Subsection 5.4.1, State of Charge Indicator, the following statements in paragraph (d) may be omitted: When it has been recorded that the charging current has stabilized at the charging voltage for three consecutive hourly measurements, the battery is near full charge. These measurements shall be made after the initially high charging current decreases sharply and the battery voltage rises to approach the charger output voltage.

5.

In lieu of RG 1.129, Regulatory Position 7, Subsection 7.6, Restoration, the following may be used: Following the test, record the float voltage of each cell of the string.

b.

The program shall include the following provisions:

1.

Actions to restore battery cells with float voltage < 2.13V; 2.

Actions to determine whether the float voltage of the remaining battery cells is 2.13 V when the float voltage of a battery cell has been found to be < 2.13 V; 3.

Actions to equalize and test battery cells that had been discovered with electrolyte level below the top of the plates; 4.

Limits on average electrolyte temperature, battery connection resistance, and battery terminal voltage; and 5.

A requirement to obtain specific gravity readings of all cells at each discharge test, consistent with manufacturer recommendations.

Insert new TS 5.5.17 here

5.5.17 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a.

Implementation of online monitoring for transmitters that have been evaluated during the plant operating cycle in accordance with the NRC approved methodology.

1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check.

2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance.

3) Calibration checks of identified transmitters no later than during the next refueling outage.

4) Documentation of the results of the online monitoring data analysis.

b.

Performance of a calibration checks of any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next refueling outage.

c.

Performance of calibration checks for transmitter at the specified backstop frequencies.

d.

The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

Insert

Enclosure to L-24-267 1

Perry Nuclear Power Plant Technical Specification Clean Typed

Definitions 1.1 PERRY - UNIT 1 1.0-1 Amendment No. TBD 1.0 USE AND APPLICATION 1.1 Definitions

---

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

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific planar HEAT GENERATION RATE height and is equal to the sum of the LHGRs for all the fuel (APLHGR) rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle at the height.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor (except transmitters in the Online Monitoring Program), alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is calibrated.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

(continued)

Definitions 1.1 PERRY - UNIT 1 1.0-3 Amendment No. TBD 1.1 Definitions (continued)

EMERGENCY CORE COOLING The ECCS RESPONSE TIME shall be that time interval SYSTEM (ECCS) RESPONSE from when the monitored parameter exceeds its ECCS TIME initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e.,

the valves travel to their required positions, pump discharge pressures reach their required values, etc.).

Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. Exceptions are stated in the individual surveillance requirements. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

END OF CYCLE The EOC - RPT SYSTEM RESPONSE TIME shall be that RECIRCULATION PUMP TRIP time interval from initial movement of the associated (EOC-RPT) SYSTEM RESPONSE turbine stop valve or the turbine control valve to complete TIME suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

INSERVICE TESTING PROGRAM The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f).

ISOLATION SYSTEM The ISOLATION SYSTEM RESPONSE TIME shall be that RESPONSE TIME time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. Exceptions are stated in the individual surveillance requirements. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

(continued)

Definitions 1.1 PERRY - UNIT 1 1.0-5 Amendment No. TBD 1.1 Definitions (continued)

MINIMUM CRITICAL POWER The MCPR shall be the smallest critical power ratio (CPR)

RATIO (MCPR) that exists in the core for each class of fuel. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.

MODE A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

OPERABLE - OPERABILITY A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) reactor coolant of 3758 MWt.

REACTOR PROTECTION The RPS RESPONSE TIME shall be that time interval from SYSTEM (RPS) RESPONSE when the monitored parameter exceeds its RPS trip TIME setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

Exceptions are stated in the individual surveillance requirements (continued)

Programs and Manuals 5.5 PERRY - UNIT 1 5.0-15e Amendment No. TBD 5.5 Programs and Manuals 5.5.16 Battery Monitoring and Maintenance Program (continued) 4.

In Regulatory Guide 1.129, Regulatory Position 3, Subsection 5.4.1, State of Charge Indicator, the following statements in paragraph (d) may be omitted: When it has been recorded that the charging current has stabilized at the charging voltage for three consecutive hourly measurements, the battery is near full charge. These measurements shall be made after the initially high charging current decreases sharply and the battery voltage rises to approach the charger output voltage.

5.

In lieu of RG 1.129, Regulatory Position 7, Subsection 7.6, Restoration, the following may be used: Following the test, record the float voltage of each cell of the string.

b.

The program shall include the following provisions:

1.

Actions to restore battery cells with float voltage < 2.13V; 2.

Actions to determine whether the float voltage of the remaining battery cells is 2.13 V when the float voltage of a battery cell has been found to be < 2.13 V; 3.

Actions to equalize and test battery cells that had been discovered with electrolyte level below the top of the plates; 4.

Limits on average electrolyte temperature, battery connection resistance, and battery terminal voltage; and 5.

A requirement to obtain specific gravity readings of all cells at each discharge test, consistent with manufacturer recommendations.

5.5.17 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMSTR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a.

Implementation of online monitoring for transmitters that have been evaluated during the plant operating cycle in accordance with the NRC approved methodology.

(continued)

Programs and Manuals 5.5 PERRY - UNIT 1 5.0-15f Amendment No. TBD 5.5 Programs and Manuals 5.5.17 Online Monitoring Program (continued) 1.

Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check.

2.

Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance.

3.

Calibration checks of identified transmitters no later than during the next refueling outage.

4.

Documentation of the results of the online monitoring data analysis.

b.

Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next refueling outage.

c.

Performance of calibration checks for transmitters at the specified backstop frequencies.

d.

The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

Enclosure to L-24-267 2

Perry Nuclear Power Plant Technical Specification Bases Mark-ups (Information only)

BASES SURVEILLANCE REQUIREMENTS (continued)

PERRY - UN IT 1 SR 3. 3.1.1.10 RPS Instrumentation B 3.3.1.1 The calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.1.1-1.

If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value. the channel performance is still within the requirements of the plant safety analysis.

Under these conditions. the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.1.11. SR 3.3.1.1.13. and SR 3.3.1.1.17 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

Note 1 states that neutron detectors are excluded from CHANNEL CALIBRATION because of the difficulty of simulating a meaningful signal. Changes in neutron detector sensitivity are compensated for by performing the calorimetric calibration (SR 3.3.1.1.2) and the LPRM calibration against the TIPs (SR 3.3.1.1.8).

As also noted the flow reference transmitters are not calibrated in SR 3.3.1.1.11. but have a separate Surveillance (SR 3.3.1.1.17). A second note is provided in SR 3.3.1.1.11 and SR 3.3.1.1.13 that requires the APRM and IRM SRs to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of entering MODE 2 from MODE 1. Testing of the MODE 2 APRM and IRM Functions cannot be performed in MODE 1 without utilizing jumpers.

lifted leads. or movable links. This note allows entry into MODE 2 from MODE 1 if the associated Frequency is not met per SR 3.0.2. Twelve hours is based on operating experience and in consideration of providing a reasonable time in which to complete the SR.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

B 3.3-29 Revision No. 11 I

u~-

031 Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 12) and TS 5.5.17, Online Monitoring Program.

RPS Instrumentation B 3.3.1.1 PERRY - UNIT 1 B 3.3-31 Revision No. 13 BASES SURVEILLANCE SR 3.3.1.1.16 (continued)

REQUIREMENTS If any bypass channel setpoint is nonconservative (i.e., the Functions are bypassed at 38% RTP, either due to open main turbine bypass valve(s) or other reasons), then the affected Turbine Stop Valve Closure and Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Functions are considered inoperable. Alternatively, the bypass channel can be placed in the conservative condition (nonbypass). If placed in the nonbypass condition (Turbine Stop Valve-Closure and Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Functions are enabled), this SR is met and the channel is considered OPERABLE.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.1.18 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. The RPS RESPONSE TIME acceptance criteria are included in Reference 10.

As noted, neutron detectors are excluded from RPS RESPONSE TIME testing because the principles of detector operation virtually ensure an instantaneous response time. In addition, for Functions 3, 4 and 5, the associated sensors are not required to be response time tested. For these Functions, response time testing for the remaining channel components is required. This allowance is supported by Reference 11.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

Insert:

Alternately, the Online Monitoring Program 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A (Reference 12) is used to detect dynamic failures modes that can affect transmitter response time for transmitters in the Online Monitoring Program.

RPS Instrumentation B 3.3.1.1 BASES (continued)

REFERENCES 1.

2.

3.

4.

5.

6.

7.

8.

SR 3.3.1.1.19 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended Function.

The Surveillance Frequency is

/b-controlled under the Surveillance Frequency Control 0 37 Program.

USAR, Figure 7. 2-1.

USAR, Section 5.2.2.

USAR, Section 6.3.3.

USAR, Chapter 15.

USAR. Section 15.4.1.

NED0-23842. "Continuous Control Rod Withdrawal in the Startup Range," April 18. 1978.

USAR. Section 15.4.9.

Letter. P. Check (NRC) to G. Lainas (NRC). "BWR Scram Discharge System Safety Evaluation." December l, 1980. as attached to NRC Generic Letter dated December 9. 1980.

9.

NED0-30851-P-A. "Technical Specification Improvement Analyses for BWR Reactor Protection System." March 1988.

10.

GE DSDS 22A3771AJ.

11.

NED0-32291. "System Analyses for Elimination of Selected Response Time Testing Requirements."

January 1994.

PERRY - UN IT 1 B 3.3-32 Rev1s1on No. 11 Insert:

12. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

PAM Instrumentation B 3.3.3.1 PERRY - UNIT 1 B 3.3-62 Revision No. 11 BASES SURVEILLANCE SR 3.3.3.1.1 (continued)

REQUIREMENTS The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of those displays associated with the required channels of this LCO.

SR 3.3.3.1.2 Deleted.

SR 3.3.3.1.3 CHANNEL CALIBRATION is a complete check of the instrument loop including the sensor. The test verifies that the channel responds to the measured parameter with the necessary range and accuracy. The CHANNEL CALIBRATION for the Penetration Flow Path, PCIV Position consists of the Position Indictor Test (PIT), which is conducted in accordance with the INSERVICE TESTING PROGRAM. The CHANNEL CABLIBRATION for primary Containment/Drywell Area Gross Gamma Radiation Monitors shall consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/hr and a one point calibration check of the detector below 10 R/hr with an installed or portable gamma source. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

Regulatory Guide 1.97, Instrumentation for Light-Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision 2, December 1980.

2.

USAR, Table 7.1-4.

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 3) and TS 5.5.17, Online Monitoring Program.

Insert:

3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

BASES SURVEILLANCE REQUIREMENTS (continued)

REFERENCES PERRY - UNIT 1 SR 3.3.3.2.2 Remote Shutdown System B 3.3.3.2 SR 3.3.3.2.2 verifies each required Remote Shutdown System control circuit and transfer switch performs the intended function. This verification is performed from the remote shutdown panel and locally, as appropriate. Operation of the equipment from the remote shutdown panel is not necessary.

The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible. the plant can be placed and maintained in MODE 3 from the remote shutdown panel and the local control stations. However. this Surveillance is not required to be performed only during a plant outage. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.3.2.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor.

The test verifies the channel responds to measured parameter values with the necessary range and accuracy.

Valve position Functions are excluded since channel performance is adequately determined during performance of other valve Surveillances.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

10 CFR 50, Appendix A. GDC 19.

B 3.3-67 Revision No. 11 I

l"-

6~1 Insert:

2. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 2) and TS 5.5.17, Online Monitoring Program.

BASES (continued)

SURVEILLANCE REQUIREMENTS PERRY - UN IT 1 EOC-RPT Instrumentation

~

B 3.3.4.1 The Surveillances are modified by a Note to indicate that 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 <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, provided the associated Function maintains EOC-RPT trip capability.

Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken.

This Note is based on the reliability analysis (Ref. 5) assumption of the average time required to perform channel surveillance. That analysis demonstrated that the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> testing allowance does not significantly reduce the probability that the recirculation pumps will trip when necessary.

SR 3. 3. 4. 1. 1 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3. 3. 4. 1. 2 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

B 3.3-75 Revision No. 11 I

lb-tR7 I

lb-b31 Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 6) and TS 5.5.17, Online Monitoring Program.

BASES SURVEILLANCE REQUIREMENTS (continued)

REFERENCES PERRY - UN IT 1 SR 3.3.4.1.5 EOC RPT Instrumentation B 3.3.4.1 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. The EOC-RPT SYSTEM RESPONSE TIME acceptance criteria are included in Reference 5.

A Note to the Surveillance states that breaker arc suppression time may be assumed from the most recent performance of SR 3.3.4.1.6. This is allowed since the arc suppression time is short and does not appreciably change.

Each EOC-RPT SYSTEM RESPONSE TIME test shall include at 1!;7 least the logic of one type of channel input, turbine control valve fast closure or turbine stop valve closure, such that both types of channel inputs are tested at the required frequency. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3. 3. 4. 1. 6 This SR ensures that the RPT breaker arc suppression time is provided to the EOC-RPT SYSTEM RESPONSE TIME test. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

USAR, Section 7.6.1.6.

2.

USAR, Section 5.2.2.

3.

USAR, Sections 15.1.1, 15.1.2. and 15.1.3.

(continued)

B 3.3-77 Revision No. 11 Insert:

Alternately, the Online Monitoring Program 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A (Reference 6) is used to detect dynamic failures modes that can affect transmitter response time for transmitters in the Online Monitoring Program.

BASES REFERENCES (continued)

PERRY - UN IT 1

4.

Deleted.

5.

GE DSDS 22A6083.

B 3.3-78 EOC-RPT Instrumentation B 3.3.4.1 Revision No. 11 lb-I 0~7 Insert:

6. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

BASES SURVEILLANCE REQUIREMENTS (continued)

REFERENCES PERRY - UN IT 1 SR 3.3.4.2.4 ATWS-RPT Instrumentation B 3.3.4.2 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.4.2.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel.

The system functional test of the pump breakers.

included as part of this Surveillance. overlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide complete testing of the assumed safety function. Therefore. if a breaker is incapable of operating, the associated instrument channel(s) would be also inoperable.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

USAR. Section 7.6.1.12.

2.

GENE-770-06-1. "Bases For Changes To Survei 11 ance Test Intervals and Allowed Out-of-Service Times For Selected Instrumentation Technical Specifications."

February 1991.

B 3.3-87 Revision No. 11 I

fb-0'31 Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 3) and TS 5.5.17, Online Monitoring Program.

Insert:

3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

BASES SURVEILLANCE REQUIREMENTS PERRY - UN IT 1 SR 3.3.5.1.3 (continued)

ECCS Instrumentation B 3.3.5.1 Allowable Value specified in Table 3.3.5.1-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology. but is not beyond the Allowable Value. the channel performance is still within the requirements of the plant safety analyses.

Under these conditions. the setpoint must be readjusted to be equal to or more conservative than the setting accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.1.4. SR 3.3.5.1.5 and SR 3.3.5.1.7 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3. 3. 5. 1. 6 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel.

The system functional testing performed in LCO 3.5.1. LCO 3.5.2. LCO 3.8.1. and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety function.

The HPCS LOGIC SYSTEM FUNCTIONAL TEST Surveillance may be performed in any mode.

(continued)

B 3.3-122 Revision No. 11 I

lb-0'!1 Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 6) and TS 5.5.17, Online Monitoring Program.

BASES SURVEILLANCE REQUIREMENTS REFERENCES PERRY - UN IT 1 SR 3.3.5.1.6 (continued)

ECCS Instrumentation B 3.3.5.1 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

USAR, Section 5.2.

2.

USAR, Section 6.3.

3.

USAR, Chapter 15.

4.

NEDC-30936-P-A, "BWR Owners' Group Technical Specification Improvement Analyses for ECCS Actuation Instrumentation, Part 2," December 1988.

5.

Plant Data Book, Tab R, Section 6.2.9.

B 3.3-123 Revision No. 11 I~

Insert:

6. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

RCIC System Instrumentation B 3.3.5.3 PERRY - UNIT 1 B 3.3-134 Revision No. 12 BASES SURVEILLANCE SR 3.3.5.3.2 (continued)

REQUIREMENTS The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.3.3 The calibration of trip units provides a check of the actual trip setpoints.

The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.5.3-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be re-adjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.3.4 and SR 3.3.5.3.6 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter with the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.3.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.5.3 overlaps this Surveillance to provide complete testing of the safety function.

(continued)

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 2) and TS 5.5.17, Online Monitoring Program.

RCIC System Instrumentation B 3.3.5.3 PERRY - UNIT 1 B 3.3-135 Revision No. 12 BASES SURVEILLANCE SR 3.3.5.3.5 (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

GENE-770-06-2, "Addendum to Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," February 1991.

Insert:

2. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

BASES SURVEILLANCE REQUIREMENTS PERRY - UN IT 1 Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 SR 3.3.6.1.2 (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

For Function l.e, "Main Steam Line Pipe Tunnel Temperature

- High", this SR is applicable only to the Division 3 and 4 ambient temperature channels.

Divisions 1 and 2 are monitored by digital instrument channels, which are functionally tested on semiannual basis by SR 3.3.6.1.7.

SR

3. 3. 6. 1. 3 The calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.1-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis.

Under these conditions. the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR

3. 3. 6. 1. 4 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3. 3. 6.1. 5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel.

The system functional testing performed on PCIVs (continued)

B 3.3-171 Revision No. 11 I

)b-037 Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 15) and TS 5.5.17, Online Monitoring Program.

BASES SURVEILLANCE REQUIREMENTS PERRY - UN IT 1 Pr1mary Conta1nment and Drywell Isolat1on Instrumentation B 3.3.6.1 SR 3.3.6.1.5 (continued) in LCO 3.6.1.3 and on drywell isolation valves in LCO 3.6.5.3 overlaps this Surveillance to provide complete testing of the assumed safety funct1on.

The Surveillance lb--

Frequency ls controlled under the Surveillance Frequency 031 Control Program.

SR 3. 3. 6. 1. 6 This SR ensures that the individual channel response times are less than or equal to the max1mum values assumed in the accident analysis. Testing is performed only on channels where the assumed response t1me does not correspond to the d1esel generator COG) start time.

For channels assumed to respond with1n the DG start time, sufficient margin exists in the 10 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific measurement test. The instrument response times must be added to the PCIV closure times to obtain the ISOLATION SYSTEM RESPONSE TIME.

ISOLATION SYSTEM RESPONSE TIME acceptance criteria are included in References 7 and 8.

The Note to SR 3.3.6.1.6 states that channel sensors are excluded from response time testing requirements.

Response time testing for the remaining channel components is required. This is supported by Reference 9.

The Surveillance Frequency is controlled under the Surve1llance Frequency Control Program.

SR

3. 3. 6. 1. 7 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

(continued)

B 3.3-172 Revision No. 11 I

lb-0!>;

Insert:

Alternately, the Online Monitoring Program 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A (Reference 15) is used to detect dynamic failures modes that can affect transmitter response time for transmitters in the Online Monitoring Program.

BASES REFERENCES (continued)

PERRY - UN IT 1 Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 11.

Deleted.

12.

USAR. Section 15.7.6

13.

Deleted.

14.

USAR. Section 7.6.1.3 B 3.3-173a Revision No. 10 ti.:;-

oi'Z 1t;-

01'2.

Insert:

15. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

BASES SURVEILLANCE REQUIREMENTS (continued)

PERRY - UN IT 1 SR 3.3.6.2.2 RHR Containment Spray System Instrumentation B 3.3.6.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure the entire channel will perform the intended function.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.6.2.3 The calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.2-1.

If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis.

Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.6.2.4 and SR 3.3.6.2.6 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

B 3.3-183 Revision No. 11 I

lb-031 I

lb-

~...,

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 4) and TS 5.5.17, Online Monitoring Program.

BASES SURVEILLANCE REQUIREMENTS (continued)

REFERENCES PERRY - UN IT 1 RHR Containment Spray System Instrumentation B 3.3.6.2 SR 3.3.6.2.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.6.1. 7, "Residual Heat Removal (RHR) Containment Spray," overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

USAR, Section 7.3.1.1.4.

2.

USAR, Section 6.2.1.1.5.

, 3.

GENE-770-06-1, "Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications."

February 1991.

B 3.3-184 Revision No. 11 I lh-037 Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

BASES SURVEILLANCE REQUIREMENTS (continued)

PERRY - UN IT 1 SR 3.3.6.3.2 SPMU System Instrumentation B 3.3.6.3 A CHANNEL FUNCTIONAL TEST is performed on each required_

channel to ensure the entire channel will perform the intended function.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.6.3.3 The calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.3-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.6.3.4 and SR 3.3.6.3.5 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

B 3.3-194 Revision No. 11 l"-

10~1 I~

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 4) and TS 5.5.17, Online Monitoring Program.

BASES SURVEILLANCE REQUIREMENTS (continued)

REFERENCES PERRY - UNIT 1 SR 3.3.6.3.6 SPMU System Instrumentation B 3.3.6.3 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel.

The system functional testing performed in LCD 3.6.2.4, "Suppression Pool Makeup (SPMU) System,"

overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

USAR, Section 7.3.1.1.12.

2.

USAR, Section 6.2.7.

3.

GENE-770-06-1, "Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications,"

February 1991.

B 3.3-195 Revision No. 11 I

fb-037 Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

BASES SURVEILLANCE REQUIREMENTS (continued)

REFERENCES PERRY - UN IT 1 SR 3.3.6.4.3 Relief and LLS Instrumentation B 3.3.6.4 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adJusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.6.4.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel.

The system functional testing performed for S/RVs in LCO 3.4.4 and LCO 3.6.1.6 overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

USAR. Section 5.2.2.

2.

GENE-770-06-1. "Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications."

February 1991.

B 3.3-201 Revision No. 11 I!;

Insert:

3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 3) and TS 5.5.17, Online Monitoring Program.

BASES SURVEILLANCE REQUIREMENTS (continued)

PERRY - UN IT 1 SR 3. 3. 7. 1. 3 CRER System Instrumentation B 3.3.7.1 The calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.7.1-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate

-setpoint methodology, but is not beyond the Allowable Value. the channel performance is still within the requirements of the plant safety analysis.

Under these conditions. the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3. 3. 7. 1. 4 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR

3. 3. 7. 1. 5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel.

The system functional testing performed in LCO 3.7.3. "Control Room Emergency Recirculation (CRER)

System." over 1 aps this Survei 11 ance to provide comp 1 ete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

B 3.3-210 Revision No. 11 I

/b-

~1 I~

I

)b-011 Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 10) and TS 5.5.17, Online Monitoring Program.

BASES (continued)

REFERENCES PERRY - UN IT 1

1.

USAR. Section 7.3.1.1.7.

2.

USAR. Section 6.4.

3.

USAR. Chapter '15.

CRER System Instrumentation B 3.3.7.1

4.

GENE-770-06-1. "Bases for Changes to Survei 11 ance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications."

February 1991.

5.

NEDC-31677P-A. "Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation." July 1990.

6.

NEDC-30851P-A. Supplement 2. "Technical Specification Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation.". March 1989.

7.

Deleted.

8.

Deleted.

9.

USAR. Section 15.7.6 B 3.3-211 Revision No. 10 Insert:

10. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

BASES SURVEILLANCE REQUIREMENTS (continued)

REFERENCES PERRY - UN IT 1 RCS Leakage Detection Instrumentation B 3.4.7 SR 3.4.7.3 This SR requires the performance of a CHANNEL CALIBRATION of the required RCS leakage detection instrumentation channels.

The calibration verifies the accuracy of the instrumentation. including the instruments located inside the drywell.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

10 CFR 50. Appendix A. GDC 30.

2.

Regulatory Guide 1.45. Revision 0. "REACTOR COOLANT PRESSURE BOUNDARY LEAKAGE DETECTION SYSTEMS."

May 1973.

3.

GEAP-5620. "Failure Behavior in ASTM A106B Pipes Containing Axial Through-Wall Flaws.:* April 1968.

4.

NUREG-75/067. "Investigation and Evaluation of Cracking in Austenitic Stainless Steel Piping of Boiling Water Reactor Plants." October 1975.

5.

USAR. Section 5.2.5.5.3.

6.

USAR. Section 5.2.5.2.

B 3.4-39 Revision No. 11 I

lb"

~'1 Insert:

7. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 7) and TS 5.5.17, Online Monitoring Program.

BASES SURVEILLANCE REQUIREMENTS PERRY - UN IT 1 SR 3.5.1.7 (continued)

ECCS-Operating B 3.5.1 SR 3.5.1.6 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCD 3.3.5.1.6 overlap this Surveillance to provide complete testing of the safety function.

The Surveillance Frequency Ib-is controlled under the Surveillance Frequency Control

~1 Program.

SR 3.5.1.8 This SR ensures that the ECCS RESPONSE TIMES are within limits for each of the ECCS injection and spray subsystems.

This SR is modified by a note which identifies that the associated ECCS actuation instrumentation is not required to be response time tested.

Response time testing. of the remaining subsystem components is required. Th\\s is supported by Reference 15.

Response time testing acceptance criteria are included in Reference 16.

(continued)

B 3.5-13a Revision No. 11 Insert:

Alternately, the Online Monitoring Program 'noise analysis' technique implemented in accordance with AMS-TR-0720R2-A (Reference 17) is used to detect dynamic failures modes that can affect transmitter response time for transmitters in the Online Monitoring Program.

BASES SURVEILLANCE REQUIREMENTS REFERENCES PERRY - UN IT 1 ECCS-Operating B 3.5.1 SR 3.5.1.8 (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

USAR. Section 6.3.2.2.3.

2.

USAR. Section 6.3.2.2.4.

3.

USAR, Section 6.3.2.2.1.

4.

USAR. Section 6.3.2.2.2.

5.

USAR. Section 15.6.6.

6.

USAR. Section 15.6.4.

7.

USAR. Section 15.6.5.

8.

10 CFR 50, Appendix K.

9.

USAR. Section 6.3.3.

10.

10 CFR 50.46.

11.

USAR. Section 6.3.3.3.

12.

Memorandum from R.L. Baer CNRC) to V. Stello, Jr.

(NRC), "Recommended Interim Revisions to LCO's for ECCS Components," December l, 1975.

13.

USAR, Section 5.2.2.4.1.

14.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

15.

NED0-32291, "System Analyses for Elimination of Selected Response Time Testing Requirements."

January 1994.

16.

USAR. Section 6.3, Table 6.3-1.

B 3.5-14 Revision No. 11 Insert:

17. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

BASES SURVEILLANCE REQUIREMENTS REFERENCES PERRY - UN IT 1 SR 3.6.5.6.3 (continued)

Drywell Vacuum Relief System B 3.6.5.6 Performance of this SR'includes a CHANNEL CALIBRATION of the isolation valve actuation instrumentation.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

USAR, Section 6.2.

2.

USAR, Section 7.7.1.12.

B 3.6-155 Revision No. 11 Insert:

3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Reference 3) and TS 5.5.17, Online Monitoring Program.