Text

Response to Request for Additional to Information Relative to Request to Revise Technical Specifications, 18-to 24-Month Fuel Cycle Extension
	ML020930092
Person / Time
Site:	Hatch
Issue date:	03/27/2002
From:	Sumner H; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	HL-6215 TR 103335
	Download: ML020930092 (39)
	v • d • e

Lewis Sumner Southern Nuclear Vice President Operating Company, Inc.

Hatch Project Support 40 Inverness Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7279 Fax 205.992.0341 Nh SOUTHERN COMPANY March 27, 2002 Energy to Serve Your World'S Docket Nos. 50-321 50-366 HL-6215 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Edwin I. Hatch Nuclear Plant Response to Request for Additional Information Relative to Request to Revise Technical Specifications:

18- to 24-Month Fuel Cycle Extension Ladies and Gentlemen:

By letter dated September 20, 2001, Southern Nuclear Operating Company (SNC) submitted to the NRC proposed Technical Specifications (TS) changes to support the implementation of a 24-month fuel cycle. On January 29, 2002, the NRC/NRR Hatch Project Manager forwarded to SNC a Request for Additional Information containing NRC Staff review requests related to SNC's September 20, 2001, submittal. Enclosure 1 provides documentation of the NRC's requests followed by SNC' s responses. Enclosure 2 contains SNC's Evaluation of the NRC Status Report on the Staff Review of EPRI Technical Report 103335, "Guidelines for Instrument Calibration Extension/Reduction Programs," which is referenced in Enclosure 1. Enclosure 3 contains revisions to Unit I and Unit 2 TS Table 3.3.1.1-1, Surveillance Requirement (SR) 3.3.5.1, and SR 3.3.5.2 transmitted in SNC's original amendment request dated September 20, 2001. The Enclosure 3 revisions are in response to NRC Request Nos. 13 and 14 provided in Enclosure 1.

The revised Unit 1 and Unit 2 TS pages supersede the corresponding pages contained in Enclosure 7 of the original submittal. Enclosure 4 contains the associated marked-up TS pages that supersede the corresponding pages contained in Enclosure 8 of the original submittal. Enclosures 1 through 6 of the original submittal are unchanged.

Should you have any questions in this regard, please contact this office.

Respectfully submitted, H. L. Sumner, Jr.

TWL/sp

Enclosures:

I. Response to Request for Additional Information

2. SNC's Evaluation of the NRC Status Report on the Staff Review of EPRI Technical Report 103335, "Guidelines for Instrument Calibration Extension/Reduction Programs"

3. Revised Proposed Technical Specifications Pages

4. Marked-Up Revised Proposed Technical Specifications Pages ADDI2

U.S. Nuclear Regulatory Commission Page 2 March 27, 2002 cc: Southern Nuclear Operating Company Mr. P. H. Wells, Nuclear Plant General Manager SNC Document Management (R-Type A02.001)

U.S. Nuclear Regulatory Commission, Washington, D.C.

Mr. L. N. Olshan, Project Manager - Hatch U.S. Nuclear Regulatory Commission, Region II Mr. L. A. Reyes, Regional Administrator Mr. J. T. Munday, Senior Resident Inspector - Hatch HL-6215

Enclosure 1 Edwin I. Hatch Nuclear Plant Response to Request for Additional Information Technical Specifications 18- to 24-Month Fuel Cycle Extension NRC Request No. 1 Page El -6, Second paragraph. Please list any and all conservative assumptions that were made in the various analyses.

SNC Response:

Specifically, the cited paragraph states:

The HNP design guide utilizes the as-found/as-left (AFAL) analysis methodology to statistically determine drift for current calibration intervals. Using recommendations from the EPRI TR-103335 and NRC review comments to the TR, the time dependence of the current drift was evaluated, where possible, and conservative assumptions were made in extrapolating current drift values to new drift values to be used for a 24-month fuel cycle.

Table 1 is a listing of drift studies supporting the Plant Hatch 24-Month Fuel Cycle Extension Project, where conservative assumptions were used for extrapolation purposes.

NRC Request No. 2 Page E3.2 [sic], Paragraph3.2. "Statisticaltest [sic] not covered by this design may be utilized provided..." Please indicate whether and where such tests were actually used.

SNC Response:

The cited passage states:

Statistical tests not covered by this design guide may be utilized providing the Engineer performing the analysis adequately justifies the use of the tests.

No such tests were used in support of the Plant Hatch 24-Month Fuel Cycle Extension Project. of SNC's original submittal is an overall methodology for drift studies at Plant Hatch, and although the document was generated for use on this project, it is not intended to be limited in use to this project.

NRC Request No. 3 Page E3-5, Section 3.4.2. We agree that the smaller the sample pool, the largeris the (statistical) penalty. However, a minimum sample size needs to be address [sic]. Also please tabulate the sample size usedfor the various analyses/function. Staff has accepted the minimum sample size of 30 previously. If a sample size of less than 30 is usedfor Hatch then please provide thejustificationfor that case.

HL-6215 El-1

Enclosure I Response to Request for Additional Information Technical Specifications 18- to 24-Month Fuel Cycle Extension SNC Response:

There were only two instances where the drift data population for a drift study was < 30 data points. In each case, no outliers were removed. The justifications for performing the analysis in each of the drift studies, which are copied directly from the engineering judgments within the drift studies, are provided below.

1. SNC-009 Rosemount 1153 Series B or D Pressure Transmitters, with Range Code 9 Justification: This analysis was performed with a total number of 24 analyzed drift values. In most cases, statistically, a data set is not considered valid unless at least 30 data values are used. However, in this case, all data possible was analyzed from these transmitters from 1990 until the present time. Cursory analysis of the data within the Outliers page shows the data to be relatively consistent. This is evidence that the data distribution is likely to be reasonably accurate as analyzed. Additionally, the method of determining the analyzed drift value for 24 data values uses a very high Normality Adjustment Factor (NAF) and Tolerance Interval Factor (TIF) for 95/95 confidence, providing the required conservatism for use in setpoint calculations. A similar plant, which recently submitted for a 24-month fuel cycle, showed significantly smaller Analyzed Drift values, in a much larger data set, which addressed this instrument type. Therefore, although this study only analyzes 24 drift data points, the results are conservative for the application.

2. SNC-0 11 Rosemount 1153 Series B or D Differential Pressure Transmitters, with Range Codes 4-8 Justification: This analysis was performed with a total number of 22 analyzed drift values. In most cases, statistically, a data set is not considered valid unless at least 30 data values are used. However, in this case, all data possible was analyzed from these transmitters from 1990 until the present time. Cursory analysis of the data within the Outliers page shows the data to be relatively consistent, and the W-Test results show that the data is likely from a normal distribution. These facts are evidence that the data distribution is likely to be reasonably accurate as analyzed.

Additionally, the method of determining the analyzed drift value for 22 data values uses a very high Tolerance Interval Factor (TIF) for 95/95 confidence, providing the required conservatism for use in setpoint calculations. Another similar plant, which recently submitted for a 24-month fuel cycle, showed significantly smaller Analyzed Drift values, in a much larger data set, which addressed this instrument type. Therefore, although this calculation only analyzes 22 drift data points, the analysis results are considered conservative for the application.

NRC Request No. 4:

Page E3-5, Table 1: 95/95 Tolerance Interval Factors. Table values are slightly smaller than those given in the general literature(cf, Robert Odeh and DonaldOwen, "Tablesfor Normal Tolerance Limits, "Marcel Dekker, Inc, New York, 1980.) Please identify the source ofyour table entries.

SNC Response:

TIF values are from Table VII(a) of "Statistics for Nuclear Engineers and Scientists Part 1: Basic Statistical Inference," William J. Beggs; February 1981, which is Reference 7.3.7 of Enclosure 3 of HL-6215 El-2 Response to Request for Additional Information Technical Specifications 18- to 24-Month Fuel Cycle Extension SNC's original submittal. In the research process to answer this question, the values were again verified to correctly match those in Reference 7.3.7.

NRC Request No. 5 PagesE3- 10 and E-11, OutlierAnalysis. Outlieranalysis is served only to identify a single observation that may be consideredfor exclusionfrom the database. It does not provide a statisticallicense to exclude questionable datapoints without an appropriateengineeringjudgement. Also, even statistical procedures (at least those developed in the generalliterature)do not permit the exclusion of more than one point. Although SNC recognizes this limitation (page E3-11, line 14from the bottom), it violates this rule as a special case (Page E3- 11, line 5from the bottom). Please identify data points that were consideredoutliers and whether these points were excludedfrom the analysis. Pleasejustify the exclusion of more than one data point as outlier.

SNC Response:

Only 4 drift studies in support of the 24-Month Fuel Cycle Extension Project allowed the removal of more than 1 outlier. The justifications for these are given below.

A. Drift Studies SNC-002 and SNC-012 only removed 2 outliers each. These drift studies involve the 5-point calibrations of Barton 763 pressure transmitters and Rosemount 1154 Series gauge pressure transmitters. These studies each had large sample sizes (222 and 102, respectively), and they each involve a complicated calibration process. Because of the complexity of the calibrations performed on these instruments (and therefore the difficulty in specifically diagnosing calibration problems) and the large number of drift data points included, removal of only one outlier in this situation is considered overly restrictive, and not conducive to accurately representing the actual performance of the devices. Therefore, two drift data points were removed as outliers.

B. Drift study SNC-001 removed 3 outliers, based upon the same reasoning, but the data set was significantly larger (303 drift values). Once again, because of the complexity of the calibrations performed on these instruments (and therefore the difficulty in specifically diagnosing calibration problems) and the large number of drift data points included, removal of only one outlier in this situation is considered overly restrictive, and not conducive to accurately representing the actual performance of the devices. Therefore, three drift data points were removed as outliers.

C. Drift study SNC-004 removed 14 outliers. In this case, because of the extremely large size of the data set (1616 drift data points), removal of only one outlier is not appropriate, since the data could be significantly skewed by a very small percentage of the data points, shown as outliers. Of the 14 outliers, 8 are from 2U61-N105B, which was identified as a poor performer, and has since been replaced. The data from this poor performer, which should no longer exist, could significantly skew the data and give an unrealistic model of device performance to be observed after implementation of the 24-Month Fuel Cycle Extension Project. Therefore, the 14 outliers are removed from the data set.

Note that in all cases, the number of outliers removed is < 2% of the total data population, and in 3 of the 4 cases, the outliers represented are < 1%. Therefore, although the outliers removed are greater 1, the removal of the outliers is anticipated to more accurately reflect actual device performance after implementation of the 24-Month Fuel Cycle Extension Project. If the drift values derived do not encompass the observed drift following project implementation, the improved instrument-monitoring HL-6215 E1-3 Response to Request for Additional Information Technical Specifications 18- to 24-Month Fuel Cycle Extension program will detect this condition and appropriately initiate design action, maintenance action, or both to correct the problem.

NRC Request No. 6 Page E3-16, Table 3. The table considers both one and two standarddeviations and characterizes the total percentage of the normal distributionbetween paired limits as 68.27% and 95.45%, respectively.

The discussion thatfollows the table considers only the 2 standarddeviation boundary. Please elaborate.

SNC Response:

The two limits shown in Table 3 are intended to help the user understand the expected distribution of data within a normal distribution; however, the only specific limit used as a criterion is the 2 standard deviation limit. SNC's experience with drift studies indicates that if the 2 standard deviation limit is met, the 1 standard deviation limit will either be met or extremely close to passing. The drift data is typically either normally distributed or conservatively treated as normally distributed. As is evident by this passage, the object is to establish a model for the drift error, which can be conservatively used in setpoint analysis. The process defined by this paragraph effectively establishes such a model.

NRC Request No. 7 Page E3-16, Paragraph3.8. Please indicate where (and whether) binomial variables(pass/fail)were used at all and if so, where.

SNC Response:

Binomial variables were not used in support of the Plant Hatch 24-Month Fuel Cycle Extension Project.

NRC Request No. 8 Page E3-19, Firstparagraph.Regression Time Dependency Analytical Tests. SNC states that if R2 (where R is the correlation coefficient) is greater than 0.3, the drift is linearly time dependent.

Conversely, if R2 is less than or equal to 0.3, the drift is treatedas time independent. This criterion is arbitraryand unsupportablefor several reasons:

If the population correlationcoefficient is exactly zero (0.00), drift and time are independent only if both drift and timefollow the normal distribution. Since time is fixed, time does notfollow the normal distribution.

If time and drift are independent, one could possibly test whether the sample correlationcoefficients differ from zero significantly. This test, which is afunction of the sample size, was not conducted by SNC. Be aware that the power of the statisticaltest in the determinationof departurefrom zero correlation is afunction of the sample size.

2 The use of R2, ratherthan R, is misleading. Note that if R = 0.3 then R = 0.55, which, intuitively, is an unacceptably high correlation.

Pleaseprovide the justificationfor using this criterion.

HL-6215 El-4 Response to Request for Additional Information Technical Specifications 18- to 24-Month Fuel Cycle Extension SNC Response:

The R2 test is not intended to be supportable independently, but as one diverse check among several. Use of any specific criterion for this value could prove to be acceptable or unacceptable, based upon the perspective of the reviewer. Therefore, the use of:

"* various statistical tests, with their own objective criteria, and

"* graphical data to help in engineering judgment of the directionality and magnitude of the data over time is the only defendable approach to the specific determination of time dependency. As shown by 2 of SNC's original submittal, the F Test, the P Test, the R test, and visual examinations of data within the regression plots, scatter plot, and binning plot are all used to determine the time dependency of drift data. The overall process of time dependency determination is anticipated to conservatively identify data sets that appear to have time-dependent attributes.

Even given all of the above arguments against the R2 test, the test still provides a measure of the correlation of the drift data versus linear time dependency of drift data for a given device type. In other words, if the drift data for a given device type is 100% linearly time dependent and is repeatable from device to device, the R2 value and, therefore, the R value will be equal to 1. An objective and nonrigorously determined criterion of 0.3 is used for the R2 value at this time. It is fully anticipated that if the criterion is changed to a value more palatable for other reviewers, when the entire process is applied as stated, no changes in determination of time dependency will be realized for any analyzed devices.

In each drift study, the results of rigorous statistical determination methods were checked versus the intuitive indications from the scatter plots, binning plots, and regression plots to ensure a correct and conservative determination was made.

NRC Request No. 9 Page E3-20, second bullet. Significance of the F-Test. Why was the level of significance chosen at the 2.5% level?

SNC Response:

This comment highlights an error made in Enclosure 3 of SNC's original submittal. The manual was originally developed using the 2.5% level with an action item to confirm the significance level prior to production of drift calculations. Per a discussion with Mr. Dan Laury of the NRC and Mr. Kirk Melson of EXCEL Services on May 22, 2001, the correct level of significance to be used for the FINV function in the EXCEL spreadsheet is 5%. The 5% significance was used on all SNC drift studies; however, Enclosure 3 was inadvertently left at 2.5% after that conversation.

NRC Request No. 10 Page E3-24, Paragraph4.1.1.9. Data exclusion by the responsible engineer. How many data points is he allowed to exclude?

HL-6215 El-5 Response to Request for Additional Information Technical Specifications 18- to 24-Month Fuel Cycle Extension SNC Response:

The responsible engineer is allowed to remove all invalid data values without numerical limits. If the responsible engineer notes that data values were taken on a specific Barton transmitter up to 1997, and the transmitter was replaced in 1997 with a Rosemount transmitter, all data prior to 1997 (no matter how many data points there are) is eliminated, because following implementation of the 24-Month Fuel Cycle Extension Project, Rosemount transmitters will always be used in this application. In the same way, where any situation causes the data taken to be invalid in representing the actual device performance, whatever the cause, the responsible engineer is allowed to remove the data without regard to the number of data points. If the data population dropped to unacceptably low levels, the standard drift study would not be performed, since an adequate volume of valid drift data was not available.

NRC Request No. 11 Page E3-27,first paragraph.Normality test. What level of significance was used in the statisticaltests?

SNC Response:

The Chi-Square Tests are performed in accordance with EPRI TR-103335R1, "Statistical Analysis of Instrument Calibration Data - Guidelines for Instrument Calibration Extension/Reduction Programs,"

October 1998, which is Reference 7.1.1 of Enclosure 3 of SNC's original submittal. The Chi-Square Tests are performed at the 5% significance level.

The D Prime and W Tests are performed per ANSI N15.15-1974, "Assessment of the Assumption of Normality (Employing Individual Observed Values)," which is Reference 7.1.4 of Enclosure 3 of SNC's original submittal. The W Tests are performed at the 5% significance level, and the D Prime Tests (two sided) are performed at the 2.5% Significance level.

NRC Request No. 12 Page EJ-6 states that HNP utilizes EPRI-103335 and NRC review comments to the TR. Please discuss how HNP methodology addresseseach of the NRC's review comments on the EPRI document. Also Section 3.1 of the methodology does not reference NRC review comments.

SNC Response:

Enclosure 2 of this submittal lists the specific NRC comments to the EPRI TR-103335 and shows how each comment was considered in the development of the SNC drift methodology and the 24-Month Fuel Cycle Extension Project.

NRC Request No. 13 For some instrumentationchannelfunctional test (CFT) duration has been increasedform [sic] 3 months

[sic]to 24 months. Compliance with GL 91-04 does not provide the basisfor changing the durationfrom 3 months to 24 months. Therefore, these functions should either be removedform [sic] the request or HL-6215 El-6 Response to Request for Additional Information Technical Specifications 18- to 24-Month Fuel Cycle Extension other basis based on PRA and deterministic analysisshould be providedfor these functions.

(Table 3.3-1-1-1 [sic] function 7a, SR 3.3.5.1.3 and 3.3.5.2.3)

SNC Response:

The request to change the 92-day Frequency of the CHANNEL FUNCTIONAL TEST [Technical Specifications (TS) Table 3.3.1.1-1, Function 7.a; SR 3.3.5.1.3; and SR 3.3.5.2.3 to a 24-month Frequency is being removed from the amendment request. The revised TS pages showing the changes are included in Enclosure 3 of this submittal, and the revised marked-up TS pages are included in . These revised pages replace the corresponding pages provided in Enclosures 7 and 8 of SNC's original submittal dated September 20, 2001.

NRC Request No. 14 For some instrument [sic] channel calibrationrequirement is changed to channelfunctional test. Again GL 91-04 does not provide the basisfor this change. Therefore, either provide the basisfor the request or remove the changefor these functions. (Table 3.3.1-1-1 [sic],function 7b, SR 3.3.5.1.3 and 3.3.5.2.3)

SNC Response:

The request to change the CHANNEL CALIBRATION requirement of Table 3.3.1.1-1, Function 7.b; SR 3.3.5.1.3; and SR 3.3.5.2.3 to a CHANNEL FUNCTIONAL TEST requirement is being removed from the amendment request. The revised TS pages are included in Enclosure 3 of this submittal, and the revised marked-up TS pages are included in Enclosure 4. The revised TS pages showing the changes are included in Enclosure 3 of this submittal, and the revised marked-up TS pages are included in Enclosure 4. These revised pages replace the corresponding pages provided in Enclosures 7 and 8 of SNC's original submittal dated September 20, 2001.

HL-6215 El-7 Response to Request for Additional Information Technical Specifications 18- to 24-Month Fuel Cycle Extension TABLE 1 DRIFT STUDY CONSERVATIVE ASSUMPTIONS

SUMMARY

Study No. Device Conservative Assumptions for Extrapolation SNC-001 Barton 764 1. Although drift is characterized as time independent, the Differential extrapolation is conservatively performed as though drift was Pressure moderately time dependent, by means of Square Root of the Transmitters Sum of the Squares (SRSS).

2. The worst case data point for drift, as determined by a comparison of the value, [2 x Standard Deviation + Abs Value of Mean], is applied across the entire instrument span.

SNC-002 Barton 763 1. Although drift is characterized as time independent, the Pressure extrapolation is conservatively performed as though drift was Transmitters moderately time dependent, by means of SRSS.

2. The worst case data point for drift, as determined by a comparison of the value, [2 x Standard Deviation + Abs Value of Mean], is applied across the entire instrument span.

SNC-004 Transmation Although there was only one valid time bin, the switches rarely 361ODRA / had to be adjusted. Therefore, the drift is considered to be much 3620DRA smaller than originally anticipated. The extrapolation is Temperature performed as though drift was moderately time dependent, by Switches means of SRSS.

SNC-007 Rosemount 1. The binning analyses showed that only one time bin was 1151DP4-8 populated significantly. Therefore, there was not enough Differential time diverse information to make a solid conclusion about Pressure time dependency. For the purposes of extrapolation, the drift Transmitters was conservatively treated as moderately time dependent per the methodology and extrapolated for the longer time interval by the SRSS method.

2. The worst case data point for drift, as determined by a comparison of the value, [2 x Standard Deviation + Absolute Value of Mean], is applied across the entire instrument span.

SNC-009 Rosemount 1153, 1. The binning analyses showed that only one time bin was Range 9 Pressure populated significantly. Therefore, there was not enough Transmitters time diverse information to make a solid conclusion about time dependency. For the purposes of extrapolation, the drift was conservatively treated as moderately time dependent per the methodology and extrapolated for the longer time interval by the SRSS method.

2. The worst case data point for drift, as determined by a comparison of the value, [2 x Standard Deviation + Absolute Value of Mean], is applied across the entire instrument span.

HL-6215 El-8 Response to Request for Additional Information Technical Specifications 18- to 24-Month Fuel Cycle Extension Study No. Device Conservative Assumptions for Extrapolation SNC-010 Rosemount 1153 1. Although drift is characterized as time independent, the Range 4-8 extrapolation is conservatively performed as though drift was Pressure moderately time dependent, by means of SRSS.

Transmitters 2. The worst case data point for drift, as determined by a comparison of the value, [2 x Standard Deviation + Abs Value of Mean], is applied across the entire instrument span.

SNC-01 1 Rosemount 1153, 1. The binning analyses showed that only one time bin was Range 4-8 populated significantly. Therefore, there was not enough Differential time diverse information to make a solid conclusion about Pressure time dependency. For the purposes of extrapolation, the drift Transmitters was conservatively treated as moderately time dependent per the methodology and extrapolated for the longer time interval by the SRSS method.

2. The worst case data point for drift, as determined by a comparison of the value, [2 x Standard Deviation + Absolute Value of Mean], is applied across the entire instrument span.

SNC-012 Rosemount 1154, 1. The binning analyses showed that only one time bin was Range 4-8 populated significantly. Therefore, there was not enough Pressure time diverse information to make a solid conclusion about Transmitters time dependency. For the purposes of extrapolation, the drift was conservatively treated as moderately time dependent per the methodology and extrapolated for the longer time interval by the SRSS method.

2. The worst case data point for drift, as determined by a comparison of the value, [2 x Standard Deviation + Absolute Value of Mean], is applied across the entire instrument span.

SNC-013 Rosemount 1154, 1. Although drift is characterized as only slightly time Range 4-8 independent, the extrapolation is conservatively performed Differential as though drift was moderately time dependent, by means of Pressure SRSS.

Transmitters 2. The worst case data point for drift, as determined by a comparison of the value, [2 x Standard Deviation + Abs Value of Mean], is applied across the entire instrument span.

SNC-015 Agastat TR Time The binning analyses showed that only one time bin was Delay Relays populated significantly. Therefore, there was not enough time diverse information to make a solid conclusion about time dependency. For the purposes of extrapolation, the drift was conservatively treated as moderately time dependent per the methodology and extrapolated for the longer time interval by the SRSS method.

HL-6215 El-9 Response to Request for Additional Information Technical Specifications 18- to 24-Month Fuel Cycle Extension Study No. Device Conservative Assumptions for Extrapolation SNC-016 Agastat 7000 Although drift is characterized as time independent, the Series Time extrapolation is conservatively performed as though drift was Delay Relays moderately time dependent, by means of SRSS.

SNC-018 ASCO 214A261 Although drift is characterized as time independent, the (Undervoltage extrapolation is conservatively performed as though drift was Function) moderately time dependent, by means of SRSS.

SNC-019 ASCO 214A262 Although drift is characterized as time independent, the (Underfrequency extrapolation is conservatively performed as though drift was Function) moderately time dependent, by means of SRSS.

SNC-021 GE 184C5988G2 1. The binning analyses showed that only one time bin was TUs - Voltage populated significantly. Therefore, there was not enough Outputs time diverse information to make a solid conclusion about time dependency. For the purposes of extrapolation, the drift was conservatively treated as moderately time dependent per the methodology and extrapolated for the longer time interval by the SRSS method.

2. The worst case data point for drift, as determined by a comparison of the value, [2 x Standard Deviation + Absolute Value of Mean], is applied across the entire instrument span.

SNC-025 Struth Dunn The binning analyses showed that only one time bin was 236ABX135NE populated significantly. Therefore, there was not enough time Time Delay diverse information to make a solid conclusion about time Relays dependency. For the purposes of extrapolation, the drift was conservatively treated as moderately time dependent per the methodology and extrapolated for the longer time interval by the SRSS method.

SNC-032 ASCO 214A261 Although drift is characterized as time independent, the (Time Delay extrapolation is conservatively performed as though drift was Function) moderately time dependent, by means of SRSS.

SNC-033 ASCO 214A262 Although drift is characterized as time independent, the (Time Delay extrapolation is conservatively performed as though drift was Function) moderately time dependent, by means of SRSS.

HL-6215 El-10

Enclosure 2 Edwin. I. Hatch Nuclear Plant SNC's Evaluation of the NRC Status Report on the Staff Review of EPRI Technical Report-103335, "Guidelines for Instrument Calibration Extension/Reduction Programs" HL-6215

Enclosure 2 Edwin. I. Hatch Nuclear Plant Evaluation of the NRC Status Report on the Staff Review of EPRI Technical Report-103335, "Guidelines for Instrument Calibration Extension/Reduction Programs" The following are excerpts or paraphrases from the NRC Status Report on the Staff review of EPRI Technical Report (TR)-103335, "Guidelines for Instrument Calibration Extension/Reduction Programs,"

dated March 1994. These excerpts are followed by Southern Nuclear Operating Company's (SNC's) interpretation of EPRI TR-103335. SNC's interpretations were used in the development of the Design Guide for instrument drift studies contained in Enclosure 3 of SNC's Technical Specifications (TS) original amendment request dated September 20, 2001. These interpretations were also used in the development of the 24-Month Fuel Cycle Extension Project for Plant Hatch.

STATUS REPORT Item 4.1, Section 1, "Introduction," Second Paragraph:

The staff has issued guidance on the second objective (evaluating extended surveillance intervals in support of longerfuel cycles) only for 18-month to 24-month refueling cycle extensions (GL 91-04).

Significant unresolved issues remain concerning the applicability of 18 month (or less) historical calibrationdata to extended intervals longer than 24 months (maximum 30 months), and instrument failure modes or conditions that may be present in instruments that are unattendedfor periods longer than 24 months.

HNP EVALUATION Extensions for longer than 24 months were not requested for any instrument calibrations or other surveillance requirements in this submittal.

STATUS REPORT Item 4.2, Section 2, "Principles of Calibration Data Analysis," First Paragraph:

This section describesthe general relation between the as-found and as-left calibrationvalues, and instrument drift. The term 'time dependent drift' is used. This should be clarifiedto mean time dependence of drift uncertainty, or in other words, time dependence of the standarddeviation of drift of a sample or a population of instruments.

HNP EVALUATION Both EPRI TR Revisions 0 and 1 failed to adequately determine whether a relationship between the magnitude of drift and the time interval between the calibration process existed. The drift analysis performed for HNP looked at the time-to-magnitude relationship using several different statistical and non-statistical methods. First, during the evaluation of data for grouping, data was grouped for the same or similar manufacturer, model number, and application combinations even though the t' statistical test HL-6215 E2-1 SNC's Evaluation of NRC Status Report on Staff Review of EPRI TR-103335 may have shown that the groups were not necessarily from the same population if the groups were performed on significantly different frequencies. This test grouping was made to ensure the analysis did not cover up a significant time dependent bias or random element magnitude shift.

After the standard deviation and other simple statistics are calculated, the data is evaluated for the time to magnitude relationship. If adequately time-diverse data is available, a time-binning analysis is performed on the data. Data is divided into time bins, based upon the time between calibrations. Statistics are computed for those bins, such as mean and standard deviation. These values are then plotted to expose any significant increases in the magnitude of the mean or standard deviation over time.

A regression analysis is performed, based upon the scatter of the raw "drift" values and a second regression analysis is performed on the absolute values of the "drift." For each of these regression analyses, statistical tests are performed to determine if time dependency is evident. These statistical tests are the R2 , F, and P value tests.

Finally, visual examination of the plots generated as a result of the scatter plot, binning analysis, regression analysis of drift, and the regression analysis of the absolute value of drift are used to make a final judgment on whether or not the random or mean values of drift are time dependent. Therefore, the mean and random aspects of drift are evaluated for time dependency.

STATUS REPORT Item 4.2, Section 2, "Principles of Calibration Data Analysis," Second Paragraph:

Drift is defined as as-found - as-left. As mentioned in the TR this quantity unavoidably contains uncertaintycontributionsfrom sources other than drift. These uncertaintiesaccountfor variabilityin calibrationequipment and personnel, instrumentaccuracy, and environmental effects. It may be difficult to separate these influencesfrom drift uncertainty when attempting to estimate drift uncertainty but this is not sufficient reason to group these allowances with a drift allowance. Theirpurpose is to provide sufficient margin to accountfor differences between the instrumentcalibrationenvironment and its operatingenvironment see Section 4.7 of this reportfor a discussion of combining other uncertainties into a "drift" term.

HNP EVALUATION The drift determined by analysis was compared to the equivalent set of variables in the setpoint calculation. Per Section 4.6.6 of Enclosure 3, Drift Analysis Design Guide, the Analyzed Drift Value is not comprised of drift alone; this value also contains errors from M&TE and device Reference Accuracy.

It could also include other effects, but it is conservative to assume the other effects are not included, since they cannot be quantified and are not expected to fully contribute to the errors observed.

The errors associated with the environment were not considered in the comparison of the Analyzed Drift values to the setpoint calculation values. The environmental effects are considered separately from the Analyzed Drift term, within the setpoint calculation.

HL-6215 E2-2 SNC's Evaluation of NRC Status Report on Staff Review of EPRI TR-103335 STATUS REPORT Item 4.2, Section 2, "Principles of Calibration Data Analysis," Third Paragraph:

The guidance of Section 2 is acceptableprovided that time dependency of driftfor a sample or population is understoodto be time dependent [sic] of the uncertainty statistic describing the sample or population; e.g., the standarddeviation of drift. A combination of other uncertaintieswith drift uncertainty may obscure any existing time dependency of drift uncertainty, and should not be done before time dependency analysis is done.

HNP EVALUATION Time dependency evaluations were performed on the basic as-left/as-found data. Obviously other error contributors are contained in this data, but it is impossible to separate the contribution due to drift from the contribution due to Measurement and Test Equipment and Reference Accuracy. All of these terms will fully contribute to the observed errors. Using the raw values appears to give the most reliable interpretation of the time dependency for the calibration process, which is the true value of interest. No other uncertainties are combined with the basic as-left/as-found data for time dependency determination.

STATUS REPORT Item 4.3, Section 3, "Calibration Data Collection," Second Paragraph:

When grouping instruments, as well as manufacturermake and model, care should be taken to group only instruments that experience similar environments andprocess effects. Also, changes in manufacturing method, sensor element design, or the quality assuranceprogram under which the instrument was manufacturedshould be consideredas reasonsfor separatinginstruments into different groups.

Instrument groups may be divided into subgroups on the basis of instrument age,for the purpose of investigating whether instrument age is afactor in drift uncertainty.

HNP EVALUATION Instruments were originally grouped based upon manufacturer make, model number, and specific range of setpoint or operation. The groups were then evaluated, and combined based upon Section 3.5.4 of the design guide. The appropriateness of the grouping was then tested based upon a t-Test (two samples assuming unequal variances). The t-Test defines the probability, associated with a Student's t-Test, that two samples are likely to have come from the same underlying population. Instrument groups were not divided into subgroups based upon age.

STATUS REPORT Item 4.3, Section 3, "Calibration Data Collection," Second Paragraph (continued):

Instrument groups shouldalso be evaluatedfor historical instrument anomalies orfailure modes that may not be evident in a simple compilation of calibrationdata. This evaluation should confirm that almost all instruments in a group performed reliably and almost all requiredonly calibrationattendance.

HL-6215 E2-3 SNC's Evaluation of NRC Status Report on Staff Review of EPRI TR-103335 HNP EVALUATION A separate surveillance test failure evaluation was performed for the procedures implementing the surveillance requirements. This evaluation identified calibration-related and noncalibration-related failures for single instruments, and groups of instruments supporting a specific function. After all relevant device and multiple device failures were identified, a cross-check of failures across manufacturer make and model number was also performed to determine if common mode failures could present a problem for the cycle extension. This evaluation confirmed that almost all instruments in a group (associated with extended TS line items) performed reliably and most failures were detected by more frequent testing.

STATUS REPORT Item 4.3, Section 3, "Calibration Data Collection," Third Paragraph:

Instruments within a group should be investigatedforfactors that may cause correlationbetween calibrations. Commonfactors may cause data to be correlated, including common calibration equipment, same personnelperforming calibrations,and calibrationsoccurringin the same conditions.

The group, not individual instruments within the group, should be testedfor trends.

HNP EVALUATION Instruments were only investigated for correlation factors where multiple instruments appeared to have been driven out of tolerance by a single factor. Correlation may exist between the specific type of test equipment (e.g., Fluke 863 on the 0-200 mV range) and the personnel performing calibrations for each plant. This correlation would only affect the measurement if it caused the instrument performance to be outside expected boundaries, e.g., where additional errors should be considered in the setpoint analysis or where it showed a defined bias. Because Measurement and Test Equipment (M&TE) is calibrated more frequently than most process components being monitored, the effect of test equipment between calibrations is considered to be negligible and random. The setting tolerance, readability, and other factors which are more personnel based, would only affect the performance if there was a predisposition to leave or read settings in a particular direction (e.g., always in the more conservative direction). Plant training and evaluation programs are designed to eliminate this type of predisposition. Therefore, the correlation between M&TE and instrument performance, or between personnel and instrument performance has not been evaluated. Observed as-found values outside the allowable tolerance [Leave As-Is-Zone (LAIZ) or Allowable Value] were evaluated to determine if a common cause existed as a part of the data entry evaluation.

STATUS REPORT Item 4.3, Section 3, "Calibration Data Collection," Fourth Paragraph:

TR-103335, Section 3.3, advises that older data may be excludedfrom analysis. It should be emphasized that when selecting datafor drift uncertainty time dependency analysis it is unacceptable to exclude data simply because it is old data. When selecting datafor drift uncertainty time dependency analysis, the objective should be to include datafor time spans at least as long as the proposed extended calibration interval, and preferably, several times as long, including calibrationintervals as long as the proposed interval. For limited extensions (e.g., a GL 91-04 extension), acceptableways to obtain this longer interval data include obtaining datafrom other nuclear-plantsorfrom other industriesfor identical or HL-6215 E2-4 SNC's Evaluation of NRC Status Report on Staff Review of EPRI TR-103335 close-to-identicalinstruments, or combining intervals between which the instrument was not reset or adjusted. If datafrom other sources is used, the source should be analyzedfor similarity to the target plant in procedures,process, environment methodology, test equipment, maintenanceschedules and personnel training. An appropriateconclusion of the data collectionprocess may be that there is insufficient data of appropriatetime spanfor a sufficient number of instruments to support statistical analysisof drift uncertaintytime dependency.

HNP EVALUATION Data was selected for the last 90 months (5 cycles). This data allowed for the evaluation of data with various different calibration spans over several calibration intervals to provide representative information for each type of instrument. Data from outside the HNP data set was not used to provide longer interval data. In most cases the time dependency determination was based upon calibrations performed at or near 18 months and data performed at shorter intervals (monthly, quarterly, or semiannually). There did not appear to be any time based factors that would be present from 18 to 24 months that would not have been present between 1, 3, 6, or 12 and 18 months. In some cases, it was determined that there was insufficient data to support statistical analysis of drift time dependency. For these cases, a correlation between drift magnitude and time was assumed and the calculation reflects time dependent drift values.

STATUS REPORT Item 4.3, Section 3, "Calibration Data Collection," Fifth Paragraph:

TR-103335, Section 3.3 provides guidance on the amount of data to collect. As a general rule, it is unacceptable to reject applicabledata, because biases in the data selection process may introduce biases in the calculatedstatistics. There are only two acceptable reasonsfor reducing the amount of data selected: enormity, and statisticaldependence. When the number of data points is so enormous that the data acquisition task would be prohibitively expensive, a randomized selection process, not dependent upon engineeringjudgment, should be used. This selection process should have three steps. In the first step, all data is screenedfor applicability,meaning that all datafor the chosen instrumentgrouping is selected, regardlessof the age of the data. In the second step, a proportion of the applicabledata is chosen by automated random selection, ensuring that the data recordsfor single instruments are complete, and enough individual instruments are included to constitute a statisticallydiverse sample. In the third step, the first two steps are documented. Data points should be combined when there is indication that they are statisticallydependent on each other, although alternateapproaches may be acceptable. See Section 4.5, below, on "combinedpoint" data selection and Section 4.4.1 on '0%, 25%1o, 50%, 75%, and 100% calibrationspan points'.

HNP EVALUATION A time interval of 90 months was selected as representative based upon HNP operating history. No data points were rejected from this time interval, and no sampling techniques were used.

HL-6215 E2-5 SNC's Evaluation of NRC Status Report on Staff Review of EPRI TR-103335 STATUS REPORT Item 4.4, Section 4, "Analysis of Calibration Data":

Sub-item, 4.4.1, Sections 4.3 and 4.4, Data Setup and Spreadsheet Statistics, First Paragraph:

The use of spreadsheets,databases,or other commercial software is acceptablefor data analysis provided that the software, and the operatingsystem used on the analysis computer, is under effective configurationcontrol. Care should be exercised in the use of Windows or similaroperatingsystems because of the dependence on shared libraries. Installationof other applicationsoftware on the analysis machine can overwrite shared librarieswith older versions or versions that are inconsistent with the software being usedfor analysis.

HNP EVALUATION The project used the Microsoft EXCEL spreadsheets to perform the drift analysis. This software was not treated as QA software. Therefore, computations were verified using hand verification and alternate software on different computers, such as EPRI Instrument Performance Analysis Software System (IPASS), Revision 2, and Lotus 1-2-3 spreadsheets.

STATUS REPORT Item 4.4, Section 4, "Analysis of Calibration Data":

Sub-item, 4.4.1, Sections 4.3 and 4.4, Data Setup and Spreadsheet Statistics, Second Paragraph:

Using either engineering units or per-unit (percentof span) quantities is acceptable. The simple statistic calculations(mean, sample standarddeviation, sample size) are acceptable. Data should be examined for correlationor dependence to eliminate over-optimistic tolerance interval estimates. For example, if the standarddeviation of drift can befitted with a regressionline through the 0%, 25%, 50%1c, 75%, and 100% calibrationspan points, there is reason to believe that drift uncertainty is correlatedover the five (ornine, if the data includes a repeatabilitysweep) calibrationdata points. An example is shown in TR-103335, Figure 5.4, and a related discussion is given in TR-103335 Section 5.1.3.

Confidence/toleranceestimates are based on (a) an assumption of normality (b) the number of points in the data set, and (c) the standarddeviation of the sample. Increasing the number ofpoints (utilizing each calibrationspan point) when data is statisticallydependent decreases the tolerancefactor k, which may falsely enhance the confidence in the predicted tolerance interval. To retain the information, but achieve a reasonablepoint count for confidence/toleranceestimates, the statisticallydependent datapoints should be combined into a composite data point. This retainsthe information but cuts the point count.

Fordrift uncertainty estimates with data similar to that in the TR example, an acceptablemethod requires that the number of independentdata points should be one-fifth (or one ninth) of the total number of data points in the example and a combined datapoint for each set offive span points should be selected that is representative of instrument performance at or near the span point most important to the purpose of the analysis (i.e., trip or normal operationpoint).

HNP EVALUATION The analysis for HNP used either engineering units or percent of calibrated span as appropriate to the calibration process. As an example, for switches that do not have a realistic span value, the engineering HL-6215 E2-6 SNC's Evaluation of NRC Status Report on Staff Review of EPRI TR-103335 units were used in the analyses; for analog devices, normally percent of span is used. The data was evaluated for dependence, normally dependence was found between points (0%, 25%, 50%, 75%, and 100%) for a single calibration. However, due to the changes in M&TE and personnel performing the calibrations, independence was found between calibrations of the same component on different dates. To ensure conservatism, the most conservative simple statistic values for the points closest to the point of interest were selected, or the most conservative values for any data point were selected. The multiplier was determined based upon the number of actual calibrations associated with the worst-case value selected. Selection of the actual number of calibrations is equivalent to the determination of independent points (e.g., one fifth or one ninth of the total data point count). Selection of the worst-case point is also more conservative than the development of a combined data point.

STATUS REPORT Item 4.4, Section 4, "Analysis of Calibration Data":

Sub-item 4.4.2, Section 4.5, "Outlier Analysis":

Rejection of outliers is acceptable only if a specific, direct reason can be documented for each outlier rejected. For example, a documented testerfailure would be causefor rejecting a calibrationpoint taken with the tester when it hadfailed. It is not acceptableto reject outliers on the basis of statisticaltests alone. Multiple passes of outlier statisticalcriterionare not acceptable. An outliertest should only be used to direct attention to datapoints, which are then investigatedfor cause. Five acceptable reasonsfor outlier rejectionprovided that they can be demonstrated,are given in the TR: data transcriptionerrors, calibrationerrors,calibrationequipment errors,failed instruments, and design deficiencies. Scaling or setpoint changes that are not annotatedin the data record indicate unreliabledata, and detection of unreliabledata is not causefor outlier rejection, but may be causefor rejection of the entire data set and the filing of a licensee event report. The usual engineeringtechnique of annotatingthe raw data record with the reasonfor rejecting it, but not obliteratingthe value, should be followed. The rejection of outliers typically has cosmetic effects: if sufficient data exists, it makes the results look slightly better; if insufficient data exists, it may mask a real trend. Consequently, rejection of outliers should be done with extreme caution and shouldbe viewed with considerablesuspicion by a reviewer.

HNP EVALUATION As stated in earlier questions about the HNP TS submittal, it is acceptable to remove one outlier from an analysis based upon statistical means, other than those using the engineering judgments mentioned in the EPRI document. The Design Guide is written with this as a general rule, but does allow up to 2.5% data removal, as an exception. This does not reduce the amount of scrutiny that the preparer and reviewer use in the entry and evaluation of the calibration data. The intent is to properly model device performance after completion of this project. As a general rule, no more than one outlier was removed from the drift population on the basis of being outliers. The few exceptions are justified in the response to RAI Question No. 5. The Design Guide was prepared with the exception of up to 2.5% to allow for appropriate engineering judgment in the analysis of instrumentation and the calibration thereof. Given very large sample sizes or complicated calibration processes, specific diagnosis of problems when reviewing procedure data is sometimes not possible. However, the data can contain errors which are very likely to be unrelated to drift or device performance, which should be removed, given an appropriate consideration from both the preparer and reviewer. For this project, rejection of outliers was performed with extreme caution and was viewed with considerable suspicion by the reviewer.

HL-6215 E2-7 SNC's Evaluation of NRC Status Report on Staff Review of EPRI TR-103335 Significant conservatisms exist in the assumptions for extrapolation of drift values as computed per this Design Guide, which provide additional margin for the devices to drift. Additionally, if the removal of the data reduced the computed extrapolated drift to a value that is not consistent with the capability of the device, the improved drift-monitoring program will detect the problem and implement design activity, maintenance activity, or both to correct the problem.

STATUS REPORT Item 4.4, Section 4, "Analysis of Calibration Data":

Sub-item 4.4.3, Section 4.6, "Verifying the Assumption of Normality":

The methods described are acceptablein that they are used to demonstrate that calibrationdata or results are calculated as if the calibrationdata were a sample of a normally distributedrandom variable.

For example, a toleranceinterval which states that there is a 95%probabilitythat 95% of a sample drawnfrom a populationwillfall within tolerance bounds is based on an assumption of normality, or that the populationdistribution is a normal distribution. Because the unwarrantedremoval of outliers can have a significanteffect on the normality test, removal of significantnumbers of or sometimes any (in small populations), outliers may invalidate this test.

HNP EVALUATION The methods that were found acceptable were used for the HNP analysis. As previously addressed, in only one case did the number of outliers removed exceed one percent of the data population, and it was less than 2%. In three other cases, more than one outlier was removed, but those removed were less than one percent of the population. Finally, all other drift studies involved the removal of one or less outliers.

Therefore, the normality tests are still valid. Coverage analysis was used where the normality tests did not confirm the assumption of normality. This produces a conservative model of the drift data by expanding the standard deviation to provide adequate coverage.

STATUS REPORT Item 4.4, Section 4, "Analysis of Calibration Data":

Sub-item 4.4.4, Section 4.7, "Time-Dependent Drift Considerations," First through Ninth Paragraphs:

This section of the TR discusses a number of methods for detecting a time dependency in drift data, and one method of evaluating drift uncertainty time dependency. None of the methods uses aformal statisticalmodel for instrument drift uncertainty,and all but one of them focus on drift ratherthan drift uncertainty. Two conclusions are inescapable:regression analysis cannot distinguish drift uncertainty time dependency, and the slope and intercept of regression lines may be artifacts of sample size, rather than being statistically significant. Using the results of a regressionanalysis to rule out time dependency of drift uncertainty is circularreasoning: i.e., regressionanalysis eliminates time dependency of uncertainty; no time dependency is found; therefore, there is no time dependency.

HL-6215 E2-8 SNC's Evaluation of NRC Status Report on Staff Review of EPRI TR-103335 HNP EVALUATION Several different methods of evaluation for time dependency of the data were used for the analysis. One method, the binning analysis, was to evaluate the standard deviations at different calibration intervals.

This analysis technique is the most recommended method of determining time-dependent tendencies in a given sample pool. The test consists simply of segregating the drift data into different groups (bins) corresponding to different ranges of calibration or surveillance intervals, and comparing the standard deviations for the data in the various groups. The purpose of this type of analysis is to determine if the standard deviation or mean tends to become larger as the time between calibration increases. Simple regression lines, regression of the absolute value of drift, as well as R2, F, and P tests were generated and reviewed. Finally visual examinations of the scatter plot, binning plot, and both regression plots were used to assess or corroborate results. Where there was not sufficient data to perform the detailed evaluation, the data was assumed moderately time dependent. Whenever extrapolation of the drift value was required, in all cases, drift was assumed to be at least moderately time dependent for the purposes of extrapolation, even though many of the test results showed that the drift was time independent.

STATUS REPORT Item 4.4, Section 4, "Analysis of Calibration Data":

Sub-item 4.4.4, Section 4.7, "Time-Dependent Drift Considerations," Thirteenth and Fourteenth Paragraphs:

A model can be used either to bound or projectfuture valuesfor the quantity in question (drift uncertainty)forextended intervals. An acceptablemethod would use standardstatisticalmethods to show that a hypothesis (that the instruments under study have drift uncertaintiesbounded by the drift uncertaintypredictedby a chosen model) is true with high probability. Ideally, the method should use data that include instruments that were un-resetfor at least as long as the intended extended interval, or similardatafrom othersourcesfor instruments of like construction and environmental usage. The use of data of appropriatetime span is preferable; however, if this data is unavailable,model projection may be used provided the total projected interval is no greater than 30 months and the use of the model is justified. A follow-up program of drift monitoringshould confirm that model projectionsof uncertainty bounded the actual estimated uncertainty. If it is necessary to use generic instrument data or constructed intervals, the chosen data should be grouped with similar grouping criteriaas are applied to instruments of the plant in question, and Student's "t" test should be used to verify that the generic or constructed data mean appearsto come from the same population. The "F" test should be used on the estimate of sample variance. Fora target surveillanceinterval constructed of shorterintervals where instrument reset did not occur, the longer intervalsare statisticallydependent upon the shorter intervals; hence, either the constructed longer-intervaldata or the shorter-intervaldata should be used, but not both. In a constructed interval, drift = as-left(o) - as found(~sT), the intermediatevalues are not used.

When using samples acquiredfrom generic instrumentdrift analyses or constructed intervals, the variancesare not simply summed, but are combined weighted by the degrees offreedom in each sample.

HNP EVALUATION The General Electric interval extension process was used because the General Electric setpoint methodology was used for most RPS/ECCS setpoints.. Where the drift could be proven to be time independent for the analysis period, or shown to be only slightly time dependent, or just moderately time HL-6215 E2-9 SNC's Evaluation of NRC Status Report on Staff Review of EPRI TR-103335 dependent, the calculated drift value was extended based upon the formula:

Drift 30 = Drift calculated * (30/calculated drift time interval)11 2.

Where there is a strong indication of time dependent drift, the following formula is used:

Drift30 = Drift calculated * (30/calculated drift time interval).

STATUS REPORT Item 4.4, Section 4, "Analysis of Calibration Data":

Sub-item 4.4.5, Section 4.8, "Shelf Life of Analysis Results":

The TR gives guidance on how long analysis results remain valid. The guidance given is acceptable with the addition that once adequate analysis and documentation is presented and the calibrationinterval extended, a strongfeedback loop must be put into place to ensure drift, tolerance and operabilityof affected components are not negatively impacted. An analysisshould be re-performed if its predictions turn out to exceed predetermined limits set during the calibrationinterval extension study. A goal during the re-performanceshould be to discover why the analysis results were incorrect The establishmentof a review and monitoringprogram, as indicatedin GL 91-04, Enclosure 2, Item 7 is crucial to determining that the assumptions made during the calibrationintervalextension study were true. The methodology for obtaining reasonableand timely feedback must be documented.

HNP EVALUATION As discussed in the submittal documents the plant is committed to establish a trending program to provide feedback on the acceptability of the drift error extension. This program will evaluate any as-found condition outside the Leave-As-Is-Zone (LAIZ) and perform a detailed analysis of as-found values outside the Allowable Value. The drift analysis will be reperformed when the root cause analysis indicates drift is a probable cause for the performance problems.

STATUS REPORT Item 4.5, Section 5, "Alternative Methods of Data Collection and Analysis":

Section 5 discusses two alternativesto as-found/as-left (AFAL) analysis, combining the 0%, 25%, 50%,

75% and 100% span calibrationpoints, and the EPRI Instrument CalibrationReduction Program (ICRP).

Two alternatives to AFAL are mentioned: as-found/setpoint (AFSP)analysis and worse case as-found/as left (WCAFAL). Both AFSP and WCAFAL are more conservative than the AFAL method because they produce higher estimates of drift. Therefore, they are acceptablealternativesto AFAL drift estimation.

The combined-point method is acceptable, and in some cases preferable, if the combined value of interest is taken at the point important to the purpose of the analysis. That is, if the instrument being evaluated is used to control the plant in an operating range, the instrumentshould be evaluated near its operating point. If the instrument being evaluated is employed to trip the reactor,the instrument should be HL-6215 H2-10 SNC's Evaluation of NRC Status Report on Staff Review of EPRI TR-103335 evaluated near the trip point. The combined-pointmethod should be used if the statistic of interest shows a correlationbetween calibrationspan points, thus inflating the apparentnumber of data points and causing an overstatement of confidence in the results. The method by which the points are combined (e.g., nearestpoint interpolation,averaging)should be justified and documented.

HNP EVALUATION The worst-case as-found/as-left method was used to verify manufacturer drift specifications, or to establish drift, where there was insufficient data to perform a rigorous drift analysis. The WCAFAL were evaluated against current allowances and manufacturer specifications. If the observed drift values were bounded, manufacturer specifications or current drift allowances were extrapolated to a surveillance interval of 30 months.

STATUS REPORT Item 4.6, Section 6, "Guidelines for Calibration and Surveillance Interval Extension Programs":

This section presents an example analysis in support of extending the surveillanceinterval of reactortrip bistablesfrom monthly to quarterly. Because these bistables exhibit little or no bias, and very small drift, the analysis example does not challenge the methodology presented in TR-103335 Section 4, and thus raises no acceptabilityissues related to drift analysis that have not already been covered. The bistables are also rack instruments,and thus not representativeof process instruments,for which drift is a greater concern. Bistables do not produce a variableoutput signal that can be compared to redundantdevice readingsby operationspersonnel, or during trending programs,and cannot be compared during channel checks, as redundantprocess instruments are. For these reasons the data presented in Section 6 have very little relationshipto use in the TR methodology for calibrationinterval extensionsfor process instruments. The binomialpass/fail methodology of Section 6.3 is acceptable as a method of complying with GL 91-04, Enclosure 2, item I for bistables, "Confirm that acceptable limiting values of drift have not been exceeded except in rare instances." This method provides guidancefor the definition of "rare" instances by describinghow to compute expected numbers of exceedancesfor an assumed instrument confidence /tolerance criterion (e.g., 95/95)for a large set of bistable data. There are other methods that would be acceptable, in particular,the X 2 testfor significance.

This test can be used to determine if the exceedance-of-allowable-limitsfrequency in the sample is probably due to chance or probably not due to chance,for a given nominalfrequency (e.g., 95% of drifts do not exceed allowable limits). This provides an acceptablemethod of complying with GL 91-04, Enclosure 2, item 1 in the general case.

HNP EVALUATION This specific HNP submittal did not extend any bistables from monthly to quarterly. Therefore, this section was not evaluated for the 24-Month Fuel Cycle Extension Project. However, a separate TS change request that requests an extension of functional testing for various instrumentation from quarterly to semiannually was submitted for NRC review. Failure analysis was performed for the procedures involved to ensure that these tests normally pass their surveillances at the current frequency.

Additionally, the drift was measured by as-found/as-left data analysis in the same manner as for process instrumentation and was considered in the applicable setpoint analyses. The approach taken with this extension request exceeds the requirements shown in the comments above, since rigorous drift analysis was performed for the bistables, instead of the X 2 test for significance.

HL-6215 E2-11 SNC's Evaluation of NRC Status Report on Staff Review of EPRI TR-103335 STATUS REPORT Item 4.7, Section 7, "Application to Instrument Setpoint Programs":

Section 7 is a short tutorial on combining uncertaintiesin instrument Setpoint calculations. Figure 7-1 of this section is inconsistent with ANSI/ISA-S67.04-1994, Part 1, Figure 1. Rack uncertainty is not combined with sensor uncertainty in the computation of the allowable value in the standard. The purpose of the allowable value is to set a limit beyond which there is reasonableprobabilitythat the assumptions used in the setpoint calculationwere in error. For channelfunctionaltests, these assumptionsnormally do not include an allowancefor sensor uncertainty (quarterly interval, sensornormally excluded). If a few instruments exceed the allowable value, this is probably due to instrument malfunction. If it happens frequently, the assumptions in the setpoint analysismay be wrong. Since the terminology used in Figure 7-1 is inconsistent with ANSI/ISA-S67.04-1994, PartI, Figure 1, the following correspondences are suggested: the 'Nominal Trip Setpoint' is the ANSI/ISA trip setpoint; ANSI/ISA value 'A' is the difference between TR 'Analytical Limit' and 'Nominal Trip Setpoint' [sic]; 'Sensor Uncertainty' is generally not included in the 'Allowable Value Uncertainty' and would requirejustification, the difference between 'Allowable Value' and 'Nominal Trip Setpoint' is ANSI/ISA value 'B'; the 'Leave-As Is-Zone' is equivalent to the ANSI/ISA value 'E' and the difference between 'System Shutdown' and

'Nominal Trip Setpoint' is the ANSI/lSA value 'D'. Equation 7-5 (page 7-7 of the TR) combines a number of uncertaintiesinto a drift term, D. If this is done, the reasons and the method of combination should be justified and documented. The justificationshould include an analysisof the differences between operationaland calibrationenvironments, including accident environments in which the instrument is expected to perform.

HNP EVALUATION Application of the drift values to plant setpoints was performed in accordance with the GE setpoint methodology for most RPS/ECCS setpoints. The Allowable Value defined for the GE setpoint methodology is defined as the operability limit when performing the channel calibration. No environmental terms are considered to be included in the drift term. Environmental effects and accuracy are included between the Analytical Limit and the Allowable Value. The difference between the setpoint and the Allowable Value are the drift (AFAL) and calibration tolerance. The HELB environment is used for setpoints of equipment required to remain operable during a HELB, but the effect is considered in the calculation of the Allowable Value.

STATUS REPORT Item 4.8, Section 8, "Guidelines for Fuel Cycle Extensions":

The TR repeats the provisions of Enclosure 2, GL 91-04, andprovides directguidance, by reference to preceding sections of the TR, on some of them.

HNP EVALUATION A discussion of how the Plant Hatch evaluations meet the guidance of GL 91-04 is provided in the original TS amendment request (18- to 24-Month Fuel Cycle Extension) dated September 20, 2001.

HL-6215 E2-12

Enclosure 3 Edwin I. Hatch Nuclear Plant Response to Request for Additional Information Technical Specifications 24-Month Fuel Cycle Extension Request Revised Proposed Technical Specifications Pages Unit 1 3.3-8 3.3-40 3.3-49 Unit 2 3.3-8 3.3-41 3.3-50 HL-6215

RPS Instrumentation 3.3.1.1 TabLe 3.3.1.1-1 (page 2 of 3)

Reactor Protection System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE

2. Average Power Range Monitor (continued)

e. Two-out-of-Four 1,2 2 G SR 3.3.1.1.1 NA Voter SR 3.3.1.1.10 SR 3.3.1.1.15 SR 3.3.1.1.16 1 3 (c) SR 3.3.1.1.1 NA

f. OPRM UpscaLe SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.13 SR 3.3.1.1.17 1,2 2 G SR 3.3.1.1.1 s 1085 psig

3. Reactor VesseL Steam Dome Pressure - High SR 3.3.1.1.9 SR 3.3.1.1.13 SR 3.3.1.1.15 1,2 2 G SR 3.3.1.1.1 t 0 inches

4. Reactor VesseL Water Level 3 SR 3.3.1.1.9 LeveL -Low, SR 3.3.1.1.13 SR 3.3.1.1.15 8 F SR 3.3.1.1.9 s 10% closed

5. Main Steam Isolation 1 Valve - CLosure SR 3.3.1.1.13 SR 3.3.1.1.15 G SR 3.3.1.1.1 5 1.92 psig

6. DryweLL Pressure-High 1,2 2 SR 3.3.1.1.9 SR 3.3.1.1.13 SR 3.3.1.1.15

7. Scram Discharge VoLume Water Level - High

a. Resistance Temperature 1,2 2 G SR 3.3.1.1.9 5 71 gatlons Detector SR 3.3.1.1.13 SR 3.3.1.1.15 (a) H SR 3.3.1.1.9 S 71 gallons 5 2 SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.12 S 71 gaLLons

b. FLoat Switch 1,2 2 G SR 3.3.1.1.15 II 5 (a) 2 H SR 3.3.1.1.12 S 71 gallons SR 3.3.1.1.15 (continued)

(a) With any controL red withdrawn from a core celt containing one or more fuel assemblies.

(c) Each APRM channel provides inputs to both trip systems.

HATCH UNIT 1 3.3-8 Proposed24month

ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS

NOTES ----------------------------

1. Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 3.c and 3.f; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions other than 3.c and 3.f provided the associated Function or the redundant Function maintains initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.5.1.3 Perform CHANNEL CALIBRATION. 92 days SR 3.3.5.1.4 Perform CHANNEL CALIBRATION. 24 months I SR 3.3.5.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. 24 months I HATCH UNIT I 3.3-40 Proposed24month

RCIC System Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

NOTES ----------------------------

I. Refer to Table 3.3.5.2-1 to determine which SRs apply for each RCIC Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 2; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1, 3, and 4 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.5.2.3 Perform CHANNEL CALIBRATION. 92 days SR 3.3.5.2.4 Perform CHANNEL CALIBRATION. 24 months I SR 3.3.5.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. 24 months I HATCH UNIT 1 3.3-49 Proposed24month

RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 2 of 3)

Reactor Protection System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE

2. Average Power Range Monitor (continued)

e. Two-out-of-Four 1,2 2 G SR 3.3.1.1.1 NA Voter SR 3.3.1.1.10 SR 3.3.1.1.15 SR 3.3.1.1.16

f. OPRM Upscale 1 3(c) I SR 3.3.1.1.1 NA SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.13 SR 3.3.1.1.17

3. Reactor Vessel Steam 1,2 2 G SR 3.3.1.1.1 ! 1085 psig Dome Pressure - High SR 3.3.1.1.9 SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.16

4. Reactor Vessel Water 1,2 2 G SR 3.3.1.1.1 2 0 inches Level - Low, Level 3 SR 3.3.1.1.9 SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.16

5. Main Steam Isolation 1 8 F SR 3.3.1.1.9 < 10% closed Valve - Closure SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.16

6. Drywell Pressure - High 1,2 2 6 SR 3.3.1.1.1 : 1.92 psig SR 3.3.1.1.9 SR 3.3.1.1.13 SR 3.3.1.1.15

7. Scram Discharge Volume Water Level - High

a. Resistance 1,2 2 G SR 3.3.1.1.9 S57.15 Temperature SR 3.3.1.1.13 gallons Detector SR 3.3.1.1.15 5 (a) H SR 3.3.1.1.9 S 57.15 2

SR 3.3.1.1.13 gallons SR 3.3.1.1.15

57.15

b. Float Switch 1,2 2 G SR 3.3.1.1.12 gallons I

SR 3.3.1.1.15 I

5 (a) 2 H SR 3.3.1.1.12 < 57.15 SR 3.3.1.1.15 gallons (continued)

(a) With any control rod withdrawn from a core cell containing one or more fuel assemblies.

(c) Each APRM channel provides inputs to both trip systems.

HATCH UNIT 2 3.3-8 Proposed24month

ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS

NOTES ----------------------------

1. Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 3.c and 3.f; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions other than 3.c and 3.f provided the associated Function or the redundant Function maintains initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.5.1.3 Perform CHANNEL CALIBRATION. 92 days SR 3.3.5.1.4 Perform CHANNEL CALIBRATION. 24 months I SR 3.3.5.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. 24 months I HATCH UNIT 2 3.3-41 Proposed24month

RCIC System Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

NOTES-------------------------------

1. Refer to Table 3.3.5.2-1 to determine which SRs apply for each RCIC Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 2; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1, 3, and 4 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.5.2.3 Perform CHANNEL CALIBRATION. 92 days SR 3.3.5.2.4 Perform CHANNEL CALIBRATION. 24 months I SR 3.3.5.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. 24 months I HATCH UNIT 2 3.3-50 Proposed24month

Enclosure 4 Edwin I. Hatch Nuclear Plant Response to Request for Additional Information Technical Specifications 24-Month Fuel Cycle Extension Request Marked-Up Revised Proposed Technical Specifications Pages Unit 1 3.3-8 3.3-40 3.3-49 Unit 2 3.3-8 3.3-41 3.3-50 HL-6215

RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 2 of 3)

Reactor Protection System Instrumentation APPLICABLE CONDITIONS MO1DES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE

2. Average Power Range Monitor (continued)

e. Two-out-of-Four 1,2 2 G SR 3.3.1.1.1 NA SR 3.3.1.1.10 Voter SR 3.3.1.1.15 SR 3.3.1.1.16 3.3.1.1.1 NA

f. OPRM Upscale 1 3 (c) SR SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.13 SR 3.3.1.1.17 G SR 3.3.1.1.1 s 1085 psig

3. Reactor Vessel Steam 1,2 2 SR 3.3.1.1.9 Dome Pressure -High SR 3.3.1.1.13 SR 3.3.1.1.15 G SR 3.3.1.1.1 t 0 inches

4. Reactor Vessel Water 1,2 2 SR 3.3.1.1.9 Level -Low, Level 3 SR 3.3.1.1.13 SR 3.3.1.1.15 a F SR 3.3.1.1.9 s 10% closed

5. Main Steam Isolation 1 SR 3.3.1.1.13 Valve - CLosure 3.3.1.1.15 SR G SR 3.3.1.1.1 1 1.92 psig

6. Drywell Pressure-High 1,2 2 SR 3.3.1.1.9 SR 3.3.1.1.13 SR 3.3.1.1.15

7. Scram Discharge Volume Water Level - High

a. Resistance Temperature 1,2 2 G SR 3.3.1.1.9 s 71 gallons SR 3.3.1.1.13 Detector SR 3.3.1.1.15 5(a) SR < 71 aaLLons 2 H.

SR 3.3.1.1.13 3.3.1.1.15 SR 1,2 2 G SR 3.3.1.1. 5 71 gallons

b. Float Switch 3.3.1.1.15 SR 5 (a) 2 H SR 3.3.1.1.W 5 71 gallons SR 3.3.1.1.15 (continued)

(a) With any control rod withdrawn from a core cell containing one or more fuel assemblies.

(c) Each APRM channel provides inputs to both trip systems.

HATCH UNIT 1 3.3-8 Amendment No. 213

ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS

NOTES

1. Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function.

of

2. When a channel is placed in an inoperable status solely for performance required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 3.c and 3.f; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions other than 3.c and 3.f provided the associated Function or the redundant Function maintains initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.5.1.3 Perform CHANNEL CALIBRATION. 92 days SR 3.3.5.1.4 Perform CHANNEL CALIBRATION. ýmonths *A rmonths SR 3.3.5.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST.

I ______________________________________________________

3.3-40 Amendment No. 195 HATCH UNIT I

RCIC System Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

NOTES ----------------------------

1. Refer to Table 3.3.5.2-1 to determine which SRs apply for each RCIC Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 2; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1, 3, and 4 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR. 3.3.5.2.3 Perform CHANNEL CALIBRATION. 92 days SR 3.3.5.2.4 Perform CHANNEL CALIBRATION. months SR 3.3.5.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. months 69A-HATCH UNIT 1 3.3-49 Amendment No. 195

RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 2 of 3)

Reactor Protection System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE

2. Average Power Range Monitor (continued)

e. Two-out-of-Four 1,2 2 G SR 3.3.1.1.1 NA Voter SR 3.3.1.1.10 SR 3.3.1.1.15 SR 3.3.1.1.16

f. OPRM Upscale 1 3 (c) I SR 3.3.1.1.1 NA SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.13 SR 3.3.1.1.17

3. Reactor Vessel Steam 1,2 2 G SR 3.3.1.1.1 S 1085 psig Dome Pressure - High SR 3.3.1.1.9 SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.16

4. Reactor Vessel Water 1,2 2 G SR 3.3.1.1.1 Z 0 inches Level - Low, Level 3 SR 3.3.1.1.9 SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.16

5. Main Steam IsoLation 1 8 F SR 3.3.1.1.9 S 10% closed Valve - CLosure SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.16

6. DrywetL Pressure- High 1,2 2 G SR 3.3.1.1.1 S 1.92 psig SR 3.3.1.1.9 SR 3.3.1.1.13 SR 3.3.1.1.15

7. Scram Discharge Volume Water Level - High

a. Resistance 1,2 2 G SR 3.3.1.1.9 5 57.15 Temperature SR 3.3.1.1.13 gallons Detector SR 3.3.1.1.15 5(a) 2 H SR 3.3.1.1.9 5 57.15 SR 3.3.1.1.13 gallons SR 3.3.1.1.15

b. Float Switch 1,2 2 G SR 3.3.1.1.1Iu ' - 57.15 SR 3.3.1.1.15 gaLlons 5 (a) 2 H SR 3.3.1.1.,3' < 57.15 SR 3.3.1.1.15 gallons (continued)

(a) With any control rod withdrawn from a core cell containing one or more fuel assemblies.

(c) Each APRM channel provides inputs to both trip systems.

HATCH UNIT 2 3.3-8 Amendment No. 154

ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS

NOTES

1. Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 3.c and 3.f; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions other than 3.c and 3.f provided the associated Function or the redundant Function maintains initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.5.1.3 Perform CHANNEL CALIBRATION. 92 days SR 3.3.5.1.4 Perform CHANNEL CALIBRATION. months I

SR 3.3.5.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST.

nhs HATCH UNIT 2 3.3-41 Amendment No. 137

RCIC System Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

NOTES-----------------------------

1. Refer to Table 3.3.5.2-1 to determine which SRs apply for each RCIC Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 2; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1, 3, and 4 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.5.2.3 Perform CHANNEL CALIBRATION. 92 days SR 3.3.5.2.4 Perform CHANNEL CALIBRATION. mjýo-nt hs SR 3.3.5.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. months HATCH UNIT 2 3.3-50 Amendment No. 135

ML020930092

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