ML041250358

License Amendment Request Pursuant to 10CFR50.90: Revising Intermediate Range Monitoring Instrumentation Surveillance Frequency

ML041250358
Person / Time
Site:	Perry
Issue date:	04/26/2004
From:	Kanda W FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-91-004, PY-CEI/NRR-2764L
Download: ML041250358 (23)

Text

FENOC Perry Nuclear Power Plant 10 Center Road FirstEnergy Nuclear Operating Company Perry, Ohio 44081 Wilisam R. Kanda 440-280-5579 Vice President - Nuclear Fax. 440-2808029 April 26, 2004 PY-CEI/NRR-2764L United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 License Amendment Request Pursuant to 10CFR50.90: Revising Intermediate Range Monitoring Instrumentation Surveillance Frequency Ladies and Gentlemen:

Nuclear Regulatory Commission (NRC) review and approval of a license amendment for the Perry Nuclear Power Plant (PNPP) is requested. The proposed amendment would revise the frequency of the Mode 5 Intermediate Range Monitoring (IRM) Instrumentation CHANNEL FUNCTIONAL TEST contained in Technical Specification 3.3.1.1 from 7 days to 31 days.

The methodology used to analyze the change in testing frequency is based upon guidance contained in Generic Letter 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-month Fuel Cycle" and EPRI Report TI-1 03335, "Guidelines for Instrument Calibration Extension/Reduction Programs." The methodology requires the performance of a drift analysis. The drift analysis that was performed is similar to the drift analyses that were used to support a license amendment which requested the extension of various PNPP technical specification surveillances for a 24-month operating cycle (letter PY-CEI/NRR-2398L, dated June 17, 1999 -TAC No. MA5930).

A similar change to revise the IRM surveillance frequencies was submitted by the Vermont Yankee Nuclear Power Station (ADAMS Accession Number ML031490416) in May 2003.

Approval of the license amendment is requested prior to December 31, 2004, with the amendment being implemented within 90 days following its effective date. This will support implementation prior to the PNPP 100 Refueling Outage which is scheduled for early 2005.

This request is considered a cost beneficial licensing change due to anticipated cost savings in refueling outage duration.

April 26, 2004 PY-CEIINRR-2764L Page 2 of 2 If you have questions or require additional information, please contact Mr. Vernon K. Higaki, Manager - Regulatory Affairs, at (440) 280-5294.

Very truly yours, A

Attachments:

1. Notarized FirstEnergy Nuclear Operating Company Affidavit

2. Description, Background, Technical Analysis, Regulatory Analysis, and Environmental Consideration for the Proposed Technical Specification Change

3. Significant Hazards Consideration

4. Technical Specification Page Annotated with Proposed Change

5. Technical Specification Bases Page Annotated with Proposed Change

6. Proposed Operational Requirements Manual Change

7. Commitments cc:

NRC Project Manager NRC Resident Inspector NRC Region Ill State of Ohio Joseph J. Hagan, Senior Vice President, FENOC PY-CEI/NRR-2764L Page 1 of 1 I, William R. Kanda, hereby affirm that (1) I am Vice President - Perry, of the FirstEnergy Nuclear Operating Company, (2) I am duly authorized to execute and file this certification as the duly authorized agent for The Cleveland Electric Illuminating Company, Toledo Edison Company, Ohio Edison Company, and Pennsylvania Power Company, and (3) the statements set forth herein are true and correct to the best of my knowledge, information and belief.

William R. Kandbo Subscribed to and affirmed before me, the 3' day of a o

L°O Y

(Aopl f

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1K' JANE E. MOTE Notary Public. State of Ohio My Commission Expires Feb. 20, 2005 (Recorded in Lake County)

PY-CEI/NRR-2764L Page 1 of 9

1.0 DESCRIPTION

This License Amendment Request, which is being submitted to the Nuclear Regulatory Commission (NRC) for review and approval, proposes the revision of the frequency of the Mode 5 Intermediate Range Monitoring (IRM) Instrumentation channel functional test from 7 days to 31 days. The methodology used to analyze the change in testing frequency is based upon guidance contained in Generic Letter 91-04, 'Changes in Technical Specification Surveillance Intervals to Accommodate a 24-month Fuel Cycle",

and EPRI Report TI-1 03335, 'Guidelines for Instrument Calibration Extension/Reduction Programs."

2.0 PROPOSED TECHNICAL SPECIFICATION CHANGE Technical Specification (TS) 3.3.1.1, 'Reactor Protection System (RPS) Instrumentation" will be revised by creating a new IRM Surveillance Requirement (SR), SR 3.3.1.1.19, for the performance of a CHANNEL FUNCTIONAL TEST during Mode 5, and revising Table 3.3.1.1-1, Items 1.a and 1.b to delete the current IRM Mode 5 surveillance, SR 3.3.1.1.5, and replace it with the new surveillance, SR 3.3.1.1.19.

3.0 BACKGROUND

SYSTEM DESCRIPTION The IRM instrumentation monitors neutron flux from the upper portion of the source range to the lower portion of the power range, i.e., the intermediate range.

The IRM instrumentation has eight channels; each channel includes one fission chamber detector that can be positioned in the core by remote control. The detectors are inserted into the core for a reactor startup and are withdrawn after the reactor mode selector switch is placed in the RUN position (Mode 1).

Each IRM instrument channel consists of a fission chamber that is connected to a preamplifier. The preamplifier converts current pulses to voltage pulses and conditions the signal. Preamplification is selected by a remote range switch that provides 10 ranges of increasing attenuation (the first six are called low range, the last four are called high range). As the neutron flux of the reactor core increases, the signal from the fission chamber is attenuated to keep the output signal within the scale of the control room indicator. The preamplifier output signal is further conditioned, and is provided to the Reactor Protection System (RPS) and the Rod Control and Information System (RC&IS).

The IRM remote range switches must be upranged or downranged to follow increases and decreases in power within the intermediate range to prevent either a scram or a rod block. The IRM detectors will be inserted into the core whenever the IRM instrument channels are needed to monitor neutron flux, and withdrawn from the core, when they are not needed to prevent unnecessary burnup of the fission chambers.

PY-CEI/NRR-2764L Page 2 of 9 RPS Interface The eight IRM channels are arranged such that two IRM channels are associated with each of the four RPS trip channels. This arrangement allows one IRM channel in each RPS trip channel to be bypassed, while still maintaining the RPS channel trip function.

Each IRM channel includes trip circuits to trip when a preset upscale level is reached or if an inoperative channel condition exists.

The reactor mode switch arms the IRM trips to initiate a reactor scram. With the reactor mode switch in REFUEL (Mode 5) or STARTUP (Mode 2), an IRM Neutron Flux High or Inoperative trip signal actuates a Neutron Monitoring System (NMS) trip of the RPS. Only one of the IRM channels must trip to initiate an NMS trip of the associated RPS trip subsystem. Therefore, for a reactor scram to occur, one IRM channel in each of the two RPS trip subsystems need to trip.

This trip function is designed to prevent fuel damage resulting from abnormal operating transients within this neutron power range. The most significant source of reactivity change is control rod withdrawal. The IRM provides a diverse protection to the Rod Pattern Controller (RPC) which monitors and controls the movement of control rods at low power. The RPC prevents the withdrawal of an out of sequence control rod, which could lead to an unacceptable power excursion. The IRM trip mitigates this transient.

The IRM scram function is also capable of mitigating other reactivity excursions during a reactor startup, such as cold water injection, but no credit for this is assumed.

The controls and testing associated with maintaining the RPS functions are contained within the Technical Specifications. This license amendment proposes changes to a Technical Specification testing frequency.

RC&IS Interface The IRMs send signals to the RC&IS which can inhibit the movement or selection of control rods.

The eight IRM channels are arranged such that four IRM channels are associated with each of the two RC&IS rod block logic circuits. Mechanical switches in the IRM detector drive systems provide position signals to the RC&IS rod block logic circuits which are used to indicate that a detector is not fully inserted. Each mechanical switch provides input to each of the rod block logic circuits.

Examples of IRM channel conditions that can initiate a rod block are: 1) an IRM upscale alarm, 2) an IRM inoperative alarm, 3) an IRM detector not fully inserted into the core, and 4) IRM downscale (bypassed in Range 1).

These rod blocks provide assurance that no control rod is withdrawn during low neutron flux level operations unless proper neutron monitoring capability is available and neutron flux is being correctly monitored. Additionally, the IRM upscale rod block PY-CEI/NRR-2764L Page 3 of 9 provides a means to stop rod withdrawal in time to avoid conditions requiring RPS action (scram) in the event that a rod withdrawal error is made during low neutron flux level operations.

To permit continued reactor operation during repair or calibration of IRM equipment that provide rod block interlocks, manual bypasses are permitted. Each RC&IS rod block logic circuit is permitted to have only one IRM channel bypassed at a time. This results in a maximum of two IRM channels that can be bypassed in the RC&IS. This configuration ensures that the neutron flux in the core is adequately monitored.

The controls and testing associated with maintaining the RC&IS rod block functions are contained within the Operational Requirements Manual (ORM). Changes to the ORM are controlled by 10 CFR 50.59. Changes to the ORM are required to reflect the changes proposed by this license amendment. The proposed ORM changes are described in Attachment 6 and are being forwarded to the NRC for informational purposes. Since the changes proposed to the Technical Specifications and the ORM both extend the CHANNEL FUNCTIONAL testing frequency, yet affect different functions, the PNPP staff will commit to implement the changes to both the Technical Specifications and the ORM at the same time. Attachment 7 contains this commitment.

FUNCTIONS AFFECTED BY PROPOSED CHANGE The proposed TS change affects the IRM Neutron Flux - High and Inop trip functions

• for Mode 5.

The Neutron Flux - High trip function provides a diverse protection to the RPC which monitors and controls the movement of control rods at low power. The RPC prevents the withdrawal of an out of sequence control rod, which could lead to an unacceptable power excursion. The IRM trip mitigates this transient. The IRM scram function is also capable of mitigating other reactivity excursions during a reactor startup, such as cold water injection, but no credit for this is assumed. The function's Allowable Value is contained in TS Table 3.3.1.1-1, Function 1.

The Inop function provides assurance that a minimum number of IRMs are operable.

The function is performed by a bistable. A reference voltage and a voltage proportional to the output of the High Voltage Power Supply (HVPS) enters the bistable (the HVPS provides voltage to the IRM detector). The reference voltage is slightly less than the voltage from the HVPS. Anytime an IRM mode switch is placed into a position other than OPERATE, the preamplifier is disconnected, or a circuit module is not plugged in, the reference voltage will change and exceed the HVPS voltage, thereby tripping the bistable. If the HVPS voltage drops below a set level, the voltage from the HVPS becomes less than the reference voltage, thereby tripping the bistable. The Inop function is not credited in the accident analysis. Hence, there is no TS Allowable Value for this function.

PY-CEI/NRR-2764L Page 4 of 9

4.0 TECHNICAL ANALYSIS

METHODOLOGY The methodology used to analyze the change in the Technical Specification IRM Mode 5 testing frequency is based upon the guidance contained in Generic Letter 91-04.

Generic Letter 91-04 identifies seven steps to follow in order to evaluate instrumentation changes. The seven steps, with the PNPP evaluation for the IRM surveillance change, are described below.

Step 1 "Confirm that instrument drift as determined by as-found and as-left calibration data from surveillance and maintenance records has not, except on rare occasions, exceeded acceptable limits for a calibration interval."

PNPP Evaluation The effect of longer channel functional intervals on the IRM channels was evaluated by performing a review of the surveillance test history for the affected instrument channels, including, where necessary, an instrument drift study. In this case, a drift study was performed for the IRM Neutron Flux - High setpoint. The IRM surveillance test history review evaluated 1066 surveillance tests. The tests were performed over the past 13 years, and were selected due to their ready availability and large size. The evaluation demonstrated that the instrument drift is such that the setpoint has not exceeded its allowable value and in only one case, did the setpoint exceed its Leave As Is (LAIZ) calibration acceptance tolerance. Since there is no TS Allowable Value associated with the IRM Inop function, a drift study was not performed.

Step 2 "Confirm that the values of drift for each instrument type (make, model, and range) and application have been determined with a high probability and a high degree of confidence. Provide a summary of the methodology and used to determine the rate of instrument drift with time based upon historical plant calibration data."

PNPP Evaluation The values of drift have been determined with a high degree of confidence and a high degree of probability. The PNPP staff has performed this drift evaluation using a PNPP-specific drift analysis program, which is consistent with EPRI Report TI-1 03335. The IRM drift analysis is similar to the drift analyses that were used to support a license amendment which requested the extension of various PNPP technical specification surveillances for a 24-month operating cycle (letter PY-CEI/NRR-2398L, dated June 17, 1999). The IRM drift analysis includes use of the EPRI IPASS Software, Revision 2, July 1999.

PY-CEIVNRR-2764L Page 5 of 9 The IPASS software utilizes the As Found/As Left (AFAL) analysis methodology to statistically determine drift for the current surveillance intervals. The AFAL methodology utilizes historical data obtained from surveillance tests. Of the 1066 surveillances reviewed, surveillances that were either performed once (not repeated within 7 days) or the time between surveillance performance was greater than approximately 9 days were not included in the IPASS evaluation. There were four instances which were determined to be Statistical Outliers at the 5% significance level and were not included in the analysis. After eliminating the Statistical Outliers and data points that were greater than 9 days, there were 785 data points included in the IPASS evaluation. A review of the 231 eliminated data points was performed. The results indicated that the majority of the data points reflect the drift characteristics comparable to the 7 day surveillance data.

Additionally, the data indicated that there is no apparent time dependency relative to the magnitude of the drift. Therefore, excluding these data points has no apparent affect upon the calculated drift.

As the surveillance data is loaded into IPASS, IPASS calculates the difference between the current as found value and the previous as left value. IPASS also performs other statistical analyses on the data. The results of the IPASS analyses determines the Tolerance Interval for the overall analysis. This Tolerance Interval is then used in determining the drift value for the instruments being evaluated.

Step 3 "Confirm that the magnitude of instrument drift has been determined with a high probability and a high degree of confidence for a bounding calibration interval of 30 months for each instrument type (make, model number, and range) and application that performs a safety function. Provide a list of the channels by TS section that identifies these instrument applications."

PNPP Evaluation In accordance with the methodology described in the previous section, the magnitude of instrument drift has been determined with a high degree of confidence and a high degree of probability for a bounding surveillance interval of 31 days + 25%. The instruments on which the drift analyses were performed are General Electric instruments, Model Number 368X102BBG004. The applicable Technical Specification (TS) is TS 3.3.1.1, Table 3.3.1.1-1, "Reactor Protection System Instrumentation",

Function 1.a, "Intermediate Range Monitors, Neutron Flux - High."

Step 4 "Confirm that a comparison of the projected instrument drift errors has been made with the values of drift used in the setpoint analysis. If this results in revised setpoints to accommodate larger drift errors, provide proposed TS changes to update trip setpoints. If the drift errors result in revised safety analysis to support existing setpoints, provide a summary of the updated analysis conclusions to confirm that safety limits and safety analysis assumptions are not exceeded."

PY-CEI/NRR-2764L Page 6 of 9 PNPP Evaluation The 31 day drift value was compared with the drift uncertainty associated with the specific instrument setpoint analysis. In no case was it necessary to change the existing setpoint analysis to accommodate a larger instrument drift error.

Step 5 "Confirm that the projected instrument errors caused by drift are acceptable for control of plant parameters to effect a safe shutdown with the associated instrumentation."

PNPP Evaluation As discussed in the previous sections, the calculated drift values were compared to drift allowances in the setpoint calculations and the General Electric design bases applicable to PNPP. The instruments can still be effectively utilized to perform a safe plant shutdown.

Step 6 "Confirm that all conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for channel checks, channel functional tests, and channel calibrations."

PNPP Evaluation Since the extrapolated drift was less than the drift value assumed in the PNPP IRM Neutron Flux - High setpoint calculations, no technical changes (e.g., Allowable Value or setpoints) were necessary to the plant surveillance procedures. The Inop trip function has no TS Allowable Value. The function is a bistable that compares two voltage inputs. If one voltage signal becomes greater than the other, the bistable actuates the trip function. The maintenance history review indicated the IRM channels are reliable, there has been only one failure of a trip unit. Hence, no changes to the plant surveillance procedures were necessary for the Inop function.

Step 7

'Provide a summary description of the program for monitoring and assessing the effects of increased calibration surveillance intervals on instrument drift and its effect on safety."

PNPP Evaluation The IRM channels will be monitored and trends evaluated in accordance with the PNPP drift analysis program. The PNPP program includes the following components.

As-found and as-left calibration data will be recorded for each channel functional test (the exception is that as-found as-left data for the Inop function will not be recorded PY-CEI/NRR-2764L Page 7 of 9 since there is no TS allowable value). This will identify occurrences of instruments found outside of their allowable value, or instruments whose performance is not as assumed in the drift or setpoint analysis.

When as-found conditions are outside the allowable value, an evaluation will be performed to determine if the drift or setpoint analysis is still valid, to evaluate the effect on plant safety, and to evaluate instrument operability.

ANALYSIS The proposed license amendment revises the Technical Specification Mode 5 CHANNEL FUNCTIONAL TEST from every 7 days to every 31 days. The purpose of the test is to ensure the channel will perform its intended function.

The Mode 5 functional test is only one of several SRs that are performed to ensure operability of the IRMs. The IRM CHANNEL CALIBRATION (SR 3.3.1.1.13) is a complete check of the instrument loop. This test verifies the instrument channel responds to the measured parameter within the necessary range and accuracy. The CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations. This SR is required to be performed every 24 months. The frequency of the SR is based upon the assumption of the drift used in the setpoint analysis. The LOGIC SYSTEM FUNCTIONAL TEST (SR 3.3.1.1.15) demonstrates the operability of the of the trip logic upon receipt of either an actual or simulated automatic trip signal. This SR is required to be performed every 24 months.

The frequency is based upon operating experience. These SRs test the same components and logic as the CHANNEL FUNCTIONAL tests. Therefore, assurance is provided that the IRMs will perform the required functions. Further assurance of the operability of the IRMs during low power operations is provided by the CHANNEL CALIBRATION that has to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after achieving Mode 2 (from Mode 1) and that overlap between the Average Power Range Monitoring channels and IRMs must be verified during this plant maneuver (SR 3.3.1.1.7). The proposed Technical Specification change does not impact either of these SRs.

Additionally, a CHANNEL CHECK is performed once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the instrumentation is required to be operable (SR 3.3.1.1.1) to confirm proper operation of channel instrumentation. This check verifies agreement among the different channels of indication and confirms operation of channel components. The CHANNEL CHECK verifies that the instrument channel continues to operate properly between each CHANNEL CALIBRATION. Additionally, when the IRMs are operable, control room personnel continually monitor the indications from these instrument channels. Hence, these two methods provide assurance that through significant changes in indication or deviations among channels, failures in channel components will be detected.

Analyses have been performed using the guidance contained in Generic Letter 91-04.

The results of the analyses indicates that there is sufficient margin within the existing total drift uncertainty allocation to account for the drift associated with the extension of the surveillance testing interval to 31 days.

PY-CEI/NRR-2764L Page 8 of 9 A review of the surveillance test history was performed for the past 13 years and of the 1066 IRM functional tests performed during the review period, there were no cases of a setpoint exceeding its allowable value and only one occasion in which the As Found value was outside of the LAIZ and required adjustment. Since the performance of the weekly channel function test also includes a go/no-go test of the Inop function, the surveillance test history review also evaluated the Inop function. The test review did not note problems associated with the Inop function. Therefore, the IRMs are considered reliable and will perform the design functions when required.

A review of the maintenance history of the IRM channels has been performed.

Maintenance work orders generated between 1988 and 2003 were reviewed. There was only 1 documented occurrence of a trip unit failure. The unit was replaced. The one component that had repeat failures, which occurred on multiple IRM channels, was the failure of the IRM INOP INHIBIT Switch (S4). The S4 switch is only used during channel testing. The switch is a pushbutton switch that when actuated (pushed) prevents an inoperative trip condition caused by taking the channel Selector Switch out of OPERATE. In 2000, the S4 switch was replaced with a more reliable switch. Since this time, there have been no additional problems with the component.

The 4 IRM HVPSs were each replaced twice. The first time was for preventative measures (no failures occurred) and the second time was for replacement with an improved model in support of a plant modification. Overall, the small number of failures indicates the IRMs are reliable and will perform its design functions when required.

CONCLUSION Based upon the high degree of reliability of the IRMs, the failure-detection capability confirmed by required instrument testing, the continuous monitoring of the instrumentation, and the drift analysis for the extended surveillance interval, the effect upon the IRM functions by the proposed Technical Specification change on system availability is minimal.

5.0 REGULATORY ANALYSIS

SIGNIFICANT HAZARDS CONSIDERATION The Significant Hazards Consideration for the proposed Technical Specification change is contained in Attachment 3.

6.0 ENVIRONMENTAL CONSIDERATION

The proposed Technical Specification change request was evaluated against the criteria of 10 CFR 51.22 for environmental considerations. The proposed change does not involve a significant hazards consideration (refer to Attachment 3), does not significantly change the types or significantly increase the amounts of effluents that may be released offsite, and does not significantly increase individual or cumulative PY-CEI/NRR-2764L Page 9 of 9 occupational radiation exposures. Based on the foregoing, it has been concluded that the proposed Technical Specification change meets the criteria given in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.

PY-CEI/NRR-2764L Page 1 of 2 SIGNIFICANT HAZARDS CONSIDERATION The proposed amendment is requesting Nuclear Regulatory Commission review and approval of changes to the Perry Nuclear Power Plant (PNPP) Technical Specifications which revises the interval of the Mode 5 Intermediate Range Monitoring (IRM)

Instrumentation "CHANNEL FUNCTIONAL TEST" from 7 days to 31 days. The methodology used to analyze the change in testing frequency is based upon the guidance contained in Generic Letter (GL) 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-month Fuel Cycle."

The standards used to arrive at a determination that a request for amendment involves no significant hazards considerations are included in the Nuclear Regulatory Commission's regulation, 10 CFR 50.92, which states that the operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any previously evaluated; or (3) involve a significant reduction in a margin of safety.

The proposed amendment has been reviewed with respect to these three factors, and it has been determined that the proposed change does not involve a significant hazard because:

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed Technical Specifications (TS) change involves an increase in the Mode 5 CHANNEL FUNCTIONAL TEST interval for Reactor Protection System (RPS) Intermediate Range Monitor (IRM) from 7 days to 31 days. The proposed TS change does not alter the design or functional requirements of the RPS or IRM systems. Evaluation of the proposed testing interval change demonstrated that the availability of IRMs to prevent or mitigate the consequences of a control rod withdrawal event at low power levels are not significantly affected because of other, more frequent testing that is performed, the availability of redundant systems and equipment, and the high reliability of the IRM equipment.

Furthermore, using the guidance of GL 91-04, a historical review of surveillance test results and associated maintenance records did not indicate evidence of any failure that would invalidate the above conclusions.

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

2..The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed TS change involves an increase in the Mode 5 IRM CHANNEL FUNCTIONAL TEST interval from 7 days to 31 days. Existing TS testing requirements ensure the operability of the IRMs. The proposed TS change does not introduce any failure mechanisms of a different type than those previously evaluated, PY-CEI/NRR-2764L Page 2 of 2 since no physical changes to the plant are being made. No new or different equipment is being installed, and no installed equipment is being operated in a different manner. As a result, no new failure modes are introduced. In addition, the manner in which surveillance tests are performed remain unchanged.

Furthermore, using the guidance of GL 91-04, a historical review of surveillance test results and associated maintenance records did not indicate evidence of any failure that would invalidate the above conclusions.

Therefore, the proposed TS change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. The proposed change does not involve a significant reduction in a margin of safety.

The proposed Technical Specifications (TS) change involves an increase in the Mode 5 CHANNEL FUNCTIONAL TEST interval for Reactor Protection System (RPS) Intermediate Range Monitor (IRM) from 7 days to 31 days. The impact on system operability is minimal, based upon the performance of the more frequent Channel Checks, continuous Control Room monitoring when the IRMs are in use, and the overall IRM reliability. Evaluations show there is no evidence of time-dependent failures that would impact the availability of the IRMs.

Furthermore, using the guidance of GL 91-04, a historical review of surveillance test results and associated maintenance records did not indicate evidence of any failure that would invalidate the above conclusions.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based upon the reasoning presented above, the requested change does not involve a significant hazards consideration.

PY-CEVNRR-2627L Page 1 of 2 RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.16 Verify Turbine Stop Valve Closure and 24 months Turbine Control Valve Fast Closure Trip Oil Pressure-Low Functions are not bypassed when THERMAL POWER is 2 38% RTP.

SR 3.3.1.1.17 Calibrate flow reference transmitters.

24 months SR 3.3.1.1.18

• -------------NOTES----

1. Neutron detectors are excluded.

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

3. For Function 6.. "n equals 4 channels for the purpose of determining the STAGGERED TEST BASIS Frequency.

Verify the RPS RESPONSE TIME is Within limits.

24 months on a STAGGERED TEST BASIS PERRY -

UNIT I 3.3-6 Amendment No. 11 PY-CEI/NRR-2627L Page 2-of 2 RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 1 of 3)

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

1.

Intermediate Range Monitors

a.

Neutron Flux-2 3

H SR 3.3.1.1.1 s 12Z/125 High SR 3.3.1.1.4 divisions of SR 3.3.1.1.6 full scale SR 3.3.1.1.7 SR 3.3.1.1.13 5(a) 33 SR 3.3.1.1.1 122/1 25 QSR 3.3.1.1.5; Iq divisions of SR 3.3 3

full scale 3.3.111

b.

Inop.2 3

H SR 33.1.1.4.

5(a) 3 1

NA

2.

Average Power Range Monitors

a.

Neutron Flux-2 3

H SR 3.3.1.1.1 s 20 RTP High, Setdown SR 3.3.1.1.4 SR 3.3.1.1.7 SR 3.3.1.1.8 SR 3.3.1.1.11 SR 3.3.1.1.15

b.

Flow Biased 1

3 a

SR 3.3.1.1.1 s 0.628 W +

Simulated SR 3.3.1.1.2 63.8% RTP Thermal Power-SR 3.3.1.1.3 and s 113%

High SR 3.3.1.1.8 RTPb SR 3.3.1.1.9 SR 3.3.1.1.11 SR 3.3.1.1.14 SR 3.3.1.1.15 SR 3.3.1.1.17 SR 3.3.1.1.18 (continued)

(a) With any control rod withdrawn fro= a -core cell containing one or more fuel assenblies.

(b)

Allowable Value is s 0.628 U 4 43.5X RTP when reset for single loop operation per LCO 3.4.1, "Recirculation Loops Operating."

PERRY - UNIT 1 3.3-7 Amendment No. 1 12 PY-CEI/NRR-2764L Page 1 of 2 RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE SR 3.3.1.1.16 (continued)

REQUIREMENTS If any bypass channel setpoint is nonconservative (i.e.

the Functions are bypassed at Ž 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, this SR is met and the channel is considered OPERABLE.

The Frequency of 24 months is based on engineering judgment and reliability of the components.

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.

RPS RESPONSE TIME tests are conducted on a 24 month STAGGERED TEST BASIS. Note 2 requires STAGGERED TEST BASIS Frequency to be determined based on 4 channels per trip system. in lieu of the 8 channels specified in Table 3.3.1.1-1 for the MSIV-Closure Function. This Frequency is based on the logic interrelationships of the various channels required to produce an RPS scram signal.

Therefore. staggered testing results in response time verification of these devices every 24 months. This Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience, which shows that random failures of instrumentation components causing serious time degradation, but not channel failure,

,,are infrequent.

I SH PERRY - UNIT 1 B 3.3-31 Revision No. 3 PY-CEI/NRR-2764L Page 2 of 2 INSERT I SR 3.3.1.1.19 A CHANNEL FUNCTIONAL TEST is performed on each channel to ensure that the entire channel will perform the intended Function. A Frequency of 31 days provides an acceptable level of system average availability over the Frequency and is based upon operating experience and the reliability of this instrumentation.

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9 6.2.3 Intermediate Range Monitors Control Rod Block Instrumentation OPERATIONAL REQUIREMENT:

The Intermediate Range Monitors (IRM) control rod block instrumentation channels shown in Table 6.2.3-1 shall be OPERABLE with their setpoints set consistent with the Allowable Values shown in the Table 6.2.3-2.

APPLICABILITY:

TABLE 6.2.3-1 IRM APPLICABILITY MINIMUM OPERABLE CHANNELS APPLICABLE TRIP FUNCTION PER TRIP FUNCTION""

MODES

1.

Detector not 6

2,5 full in

2.

Upscale 6

2,5

3.

Inoperative 6

2,5

4.

Downscalelb) 6 2,5 (a)

When a channel is placed in an inoperable status solely for performance of required testing, entry into the associated 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 that the associated Function maintains trip, isolation, or initiation capability.

(b) This function is automatically bypassed when the IRM channels are on range 1.

The provisions of Technical Specification SR 3.0.4 are not applicable to the CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION Test Requirements for the Intermediate Range Monitors for entry into MODE 2 from MODE 1 provided the Test Requirements are performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after such entry.

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9 6.2.3 Intermediate Range Monitors Control Rod Block Instrumentation (Cont.)

ACTION:

a.

With a control rod block instrumentation channel trip setpoint less conservative than the value shown in the Allowable Value column of Table 6.2.3-2, declare the channel inoperable.

b.

With the number of OPERABLE channels:

1.

One less than required by the Minimum OPERABLE Channels Per Trip Function requirement, restore the inoperable channel to OPERABLE status within 7 days or place the inoperable channel in the tripped condition within the next hour.

2.

Two or more less than required by the Minimum OPERABLE Channels Per Trip Funcition requirement, place at least one inoperable channel in the tripped condition or initiate a rod block within one hour.

TABLE 6.2.3-2 IRM INSTRUMENTATION SETPOINTS TRIP FUNCTION TRIP SETPOINT ALLOWABLE VALUE

1.

Detector not full in 1N/A N/A

2.

Upscale 5 108/125 full scale

< 110/125 full-scale

3.

Inoperative N/A N/A 4.

Downscale 4 5/125 full scale 2 3/125 full scale Heqd !.A PY-CEI/NRR-2764L Page 3 of 4 A,

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9 6.2.3 Intermediate Range Monitors Control Rod Block Instrumentation (Cont.)

TESTING REQUIREMENTS:

6.2.3.1 Perform a CHANNEL FUNCTIONAL TEST within 7 days prior to startup for the following trip functions:

a.

Detector not full in

b. Upscale C.

Inoperative

d. Downscale 6.2.3.2 Perform a CHANNEL FUNCTIONAL TEST ery \\days or the following trip functions:

a. Detector not full in f apo r -

b.-

Upscale1 l-

c. Inoperative CAf b"

d.

Downscale1 l)

(1) -

Trip setpoints are verified during weekly CHANNEL FDICTIONAL TESTS.

6.2.3.3 Perform a CHANNEL CALIBRATION 22 every 24 months for the following trip functions:

a.

N/A

b.

Upscale C.

N/A

d.

Downscale (2) - Neutron detectors may be excluded from CHANNEL CALIBRATION.

BASES:

The control rod block functions are provided consistent with the requirements of Technical Specifications 3.3.2.1, Control Rod Block Instrumentation and 3.2, Power Distribution Limits.

The trip logic is arranged so that a trip in any one of the inputs will result in a control rod block.

Operation with a trip set less conservative than its Trip Setpoint but within its specified Allowable Value is acceptable on the basis that the difference between each Trip Setpoint and the Allowable Value is an allowance for instrument drift specifically allocated for each trip in the safety analyses.

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9 6.2.3 Intermediate Range Monitors Control Rod Block Instrumentation (Cont.)

The Trip Functions identified in Table 6;2.3-1 are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required testing, entry into associated 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 Trip Function maintains control rod block capability.

Upon completion of the testing, 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 ACTIONs taken.

This Note is based on the reliability analysis assumption that 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is the average time required to perform channel testing.

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 /> allowance does not significantly reduce the probability that the control rod block will occur when necessary.

'Fi-.y PY-CEI/NRR-2764L Page 1 of 1 Commitments The following table identifies the actions that are considered to be regulatory commitments. Any other actions discussed in this document represent intended or planned actions, are described for the NRC's information, and are not regulatory commitments. Please notify the Manager - Regulatory Affairs at the Perry Nuclear Power Plant (PNPP) of any questions regarding this document or any associated regulatory commitments.

Commitments

1. Revise the Operational Requirements Manual (ORM) 6.2.3.2 CHANNEL FUNCTIONAL TEST frequency from performance every 7 days to every 31 days.

The revision will include updating any supporting design bases documents, as appropriate. The ORM revision will be made effective on the date the proposed Technical Specification change will become effective.