ML042660109

License Amendment Request Pursuant to 10 CFR 50.90: Application for Technical Specification Improvement to Eliminate Requirements for the Hydrogen Recombiners and the Hydrogen Analyzers Using the Consolidated Line Item

ML042660109
Person / Time
Site:	Perry
Issue date:	09/10/2004
From:	Myers L FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
FY-CEI/NRR-2739L
Download: ML042660109 (26)

Text

,.FENOC FirstEnergy Nuclear Operating Company 76 South Main Street Akron, Ohio 44308 Low W. Myers 330-384-3733 Chief Operating Officer Fax: 330-384-3799 September 10, 2004 PY-CEI/NRR-2739L United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Perry Nuclear Power Plant Docket No. 50-440 License Amendment Request Pursuant to 10 CFR 50.90: Application for Technical Specification Improvement to Eliminate Requirements for the Hydrogen Recombiners and the Hydrogen Analyzers Using the Consolidated Line Item Improvement Process Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, Nuclear Regulatory Commission (NRC) review and approval of a license amendment for the Perry Nuclear Power Plant (PNPP) is requested. The proposed amendment will delete the Technical Specification requirements related to hydrogen recombiners and hydrogen analyzers. The proposed Technical Specification changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this Technical Specification improvement was announced in the Federal Register on September 25, 2003 (68 FR 55416) as part of the Consolidated Line Item Improvement Process (CLIIP).

It is requested that the proposed license amendment be approved by May 1, 2005, with the amendment being implemented 90 days following the effective date of the amendment.

If you have any questions or require additional information, please contact Mr. Henry L. Hegrat, Supervisor - Licensing, at (330) 315-6944.

Very truly yours, Attachments:

1. Notarized FirstEnergy Nuclear Operating Company Affidavit

2.

Description and Assessment of the Proposed Change

3.

Marked-up Technical Specification Pages

4.

Marked-up Technical Specification Bases and Technical Specification Table of Contents Pages (For Information Only)

5. Commitments cc:

NRC Project Manager NRC Resident Inspector NRC Region IlIl State of Ohio

Attachment I PY-CEI/NRR-2739L Page 1 of I I, Lew W. Myers, hereby affirm that (1) I am Chief Operating Officer, of the FirstEnergy Nuclear Operating Company, (2) I am duly authorized to execute and file this certification as the duly authorized agent for the FirstEnergy Nuclear Operating Company, and (3) the statements set forth herein are true and correct to the best of my knowledge, information and belief.

afirs Subscribed to and affirmed before me, the

/°4.... day of _______________

I.

1*

- 

razz r s

, A,- -

JANE E. MOTT Notary Public, State of Ohio My Commission Expires Feb. 20, 2005 (Recorded In Lake County)

PY-CEI/NRR-2739L Page 1 of 3 DESCRIPTION AND ASSESSMENT 1.0 Introduction The proposed license amendment deletes Technical Specification (TS) 3.6.3.1, "Primary Containment Hydrogen Recombiners", and references to the Primary Containment and Drywell H2 Concentration Analyzer and Monitor (hydrogen monitor) in TS 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation." The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.

The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003 (68 FR 55416) as part of the Consolidated Line Item Improvement Process (CLIIP).

2.0 Description of Proposed Amendment Consistent with the NRC-approved Revision 1 of TSTF-447, the proposed TS change deletes the "Primary Containment and Drywell H2 Concentration Analyzer and Monitor" and its associated surveillances contained in TS 3.3.3.1 "Post Accident Monitoring (PAM) Instrumentation", and deletes TS 3.6.3.1 "Primary Containment Hydrogen Recombiners." TS pages, annotated with the proposed changes, are contained in. With the exception of the plant shutdown requirements, the hydrogen monitor and hydrogen recombiner operational and testing requirements that are being deleted from the TS will be relocated to the Perry Nuclear Power Plant (PNPP)

Operational Requirements Manual (ORM). The plant shutdown requirements will be deleted since the hydrogen monitors and recombiners are no longer required for accident mitigation, nor are required to be located within the TS. Hydrogen monitor and recombiner functionality will be maintained through the ORM controls and the PNPP 10 CFR 50.65 (Maintenance Rule) program. Changes to the ORM are made under the requirements of 10 CFR 50.59.

As described in NRC-approved Revision 1 of TSTF-447, the changes to the TSs results in changes to various TS Bases sections. The TS Bases changes will be submitted with a future TS Bases update in accordance with TS 5.5.11, 7Technical Specifications (TS) Bases Control Program." For informational purposes, the TS Bases and the TS Table of Content pages, annotated with the proposed changes, are contained in.

3.0

Background

The background for this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, and the documentation associated with the 10 CFR 50.44 rulemaking, (Refer to Section 10.0.)

PY-CEI/NRR-2739L Page 2 of 3 4.0 Regulatory Requirements and Guidance The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, and the documentation associated with the 10 CFR 50.44 rulemaking. (Refer to Section 10.0.)

5.0 Technical Analysis The PNPP staff has reviewed the NRC's Safety Evaluation (SE) published on September 25, 2003 (68 FR 55416) as part of the CLIIP Notice of Availability. The PNPP staffs review also included the information provided to support TSTF-447. The PNPP staff has concluded that the technical bases presented in the TSTF proposal and the NRC SE are applicable to the PNPP and support this amendment for the incorporation of the changes to the PNPP's TS.

Though the hydrogen recombiner and hydrogen monitor requirements are being deleted from the TS, the requirements (other than the plant shutdowns) are being relocated to the ORM. Hence, controls associated with the use and testing of the equipment will be maintained. As described in the TS Bases, one of the functions of the hydrogen recombiners is to serve as an alternate hydrogen control system for the hydrogen igniters and the hydrogen mixing compressors. The relocation of the hydrogen recombiner requirements to the ORM will maintain this function.

6.0 Regulatory Analysis A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003, TSTF-447, and the documentation associated with the 10 CFR 50.44 rulemaking.

6.1 Verification As discussed in the model SE published in the Federal Register on September 25, 2003 (68 FR 55416) for this TS improvement, the PNPP staff has made the following verifications:

1. The PNPP staff has verified that hydrogen monitors, capable of diagnosing beyond design-basis accidents, are installed.

The PNPP staffs verification did not include review of Generic Safety Issue-189 (GI-1 89), "Susceptibility of Ice Condenser and Mark ill Containments to Early Failure from Hydrogen Combustion During a Severe Accident." GI-189 is an issue that was identified during the 10 CFR 50.44 rulemaking. As stated in the Federal Register notice forthe final 10 CFR 50.44 rule (68 FR 54123):..

"GI-189 resolution is proceeding independently from this rulemaking."

As of the date of this license amendment request, GI-189 is not yet resolved.

PY-CEI/NRR-2739L Page 3 of 3 Therefore, the evaluation of the GI-189 resolution, with respect to the PNPP hydrogen monitors, would occur upon completion of the resolution of GI-189.

2. The PNPP staff commits to maintaining a hydrogen monitoring system capable of diagnosing beyond design-basis accidents. Refer to Attachment 5 for a description of the regulatory commitment.

3. PNPP does not have an inerted containment, so verification of the capability of an oxygen monitor is not required.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION The PNPP staff has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416) as part of the CLIIP.

The PNPP staff has concluded that the proposed determination presented in the Federal Register Notice is applicable to PNPP and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

8.0 ENVIRONMENTAL EVALUATION The PNPP staff has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416) as part of the CLIIP. The PNPP staff has concluded that the NRC staffs findings presented in that evaluation are applicable to PNPP and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. The PNPP staff is not proposing variations or deviations from the Technical Specification changes described in TSTF-447, Revision I or the NRC staffs model SE published on September 25, 2003 (68 FR 55416).

10.0 REFERENCES

1. Federal Register Notice: Notice of Availability~of Model Application Conceming Technical Specification Improvement To Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003 (68 FR 55416).

2. Federal Register Notice: Combustible Gas Control in Containment, published September 16, 2003 (68 FR 54123).

3. Letter from A. R. Pietrangelo (Nuclear Energy Institute) to Dr. W. D. Beckner (Nuclear Regulatory Commission) dated May 12, 2003, subject: Forwarding of TSTF (TSTF-447, Revision 1).

4. GSI-189, "Susceptibility of Ice Condenser and Mark III Containments to Early Failure from Hydrogen Combustion During a Severe Accident."

PY-CEI/NRR-2739L Page 1 of 8 MARKED-UP TECHNICAL SPECIFICATION PAGES REFLECTING THE PROPOSED AMENDMENT

/

PY-CEIINRR-2739L Page 2 of 8 PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE.

APPLICABILITY:

MODES I and 2.

ACTIONS

^_

o

---

NO ES ------------------------------------

1. LCO 3.0.4 is not applicable.

2.

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable.

status.

B. Required Action and B.1 Initiate action to Immediately associated Completion prepare and submit a Time of Condition A Special Report.

not met.

C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable.

status.

(continued)

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PERRY - UNIT 1 3.3-20 Amendment No. 69

I PY-CEI/NRR-2739L Page 3 of 8 PAM Instrumentation 3.3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Enter the Condition Immediately associated Completion referenced in Time of Condition C Table 3.3.3.1-1 for not met.

the channel.

E. As required by E.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Required Action D.1 and referenced in Table 3.3.3.1-1.

F. As required by F.1 Initiate action to Immediately Required Action D.1 prepare ard submit a and referenced in Special Report.

Table 3.3.3.1-1:

PERRY - UNIT 1 3.3-?i PRmUnUNmanIT 11 - co PY-CEI/NRR-2739L Page 4 of 8 PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.1.1

---

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

Applic~a~ble ~ifotfo Function in Table 3.3.3.1-1 except Fu Perform CHANNEL CHECK.

31 days SR 3.3.3.1.2 -NOTE------------------

Onlya able for Function 10 in Table pP r C E C R

tPerform.CHANNEL CALBAr3 A

SR 3.3.3.1.3 -NOTE---------

Pefomlicab Neach Function in months 3.3.3.1-1 exce n~lction 10.

Perform CHANNEL CALIBRATION.

24 months PERRY - UNIT 1 3.3-22 Amendment No. 115 PY-CEIlNRR-2739L-'

Page 5 of 8 PAM Instrumentation 3.3.3.1 Table 3.3.3.1-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITIONS REFERENCED FROM REQUIRED REQUIRED FUNCTION CHANNELS ACTION D.1

1. Reactor Steam Dome Pressure

2. Reactor Vessel Water Level-Uide Range

3. Reactor Vessel Water Level-Fuet Zone

4. Suppression Pool Water Level

5. Suppression Pool Sector Water Teaperature

6. Drywell Pressure

7. Drywell Air Temperature B. Primary Contairmnent/Drywelt Area Gross Gamma Radiation Monitors

9. Penetration Flow Path, PCIV Position 2

2 2

2 2

2 2

2 per penet[,~

f lo w pa th aWM&

E E

E E

E E

E F

E nt_^_.,

r^_*_tAAAAAv __

r_._.AI 2 u riirr :tirt DflO *'r.uit ii I

roncentratlen Analymer endHfri-toi-

11. Primary Containrment Pressure

12. Primary Contarinent Air Teirperature 2

2 E

E ta) Not required for isolation valves whose associated penetration flow path is isolated.

Cb) Only one position indication.channel is required for penetration flow paths with only control room indication charnel.

Cc) Monitoring each of eight sectors.

one installed PERRY - UNIT 1 3.3-23 Amendment No. 85 PY-CEI/NRR-2739L-.-

Page 6 of 8 SPMU System 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify upper containment pool water level 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is:

a. 2 22 ft 9 inches abbve the reactor pressure' vessel (RPV) flange.

OR

b. 2 22 ft 5 inches above the RPV flange, and suppression pool water level 2 17 ft 11.7 inches.

SR 3.6.2.4.2 Verify upper containment pool water 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> temperature.is s 1100F.

SR 3.6.2.4.3 Verify each SPMU subsystem manual, power 31 days operated, and automatic valve that is not locked, sealed, or otherwise secured in position is in the correct position.

SR 3.6.2.4.4 Verify all required upper containment 31 days pool gates are in the stored position or are otherwise removed from the upper containment pool.

SR 3.6.2.4.5

---

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

Actual makeup to the suppression pool may be excluded.

Verify each SPMU subsystem automatic 24 months valve actuates to the correct-osit an actual or simulated au initiation signal.

I 36-43 (J ~r & SGE' $

,S.&

s6) 5

3.6-4 16)

PERRY - UNIT 1 PY-CEI/NRR-2739L Page 7 of 8 Primary Containment Hydrogen Recombiners 3.6.3.1 3.6 SYSTEMS 3.6.3.1 Containment Hydrogen Recombiners LCO 3.6.3.1 Two primary OPERABLE.

containment hydrogen recombiners shall be APPLICABILITY:

1 and 2.

I A. One primary containment hydrogen recombiner inoperable.

30 days B. Two primary containment hydrogen recombiners inoperable.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND B.2 Restore one primary containment hydrogen recombiner to OPERABLE status.

7 days C.

quired Action and ssociated Completion Time not met.

PERRY - UNIT I 3.6-44 Amendment No. 69 PY-CEI/NRR-2739L Page 8 of 8 Primary Containment Hydrogen Recombiners 3.6.3.1 SURVEILLX CE REQUIREMENTS SURVEILLANCE FREQUED Y SR 3.6.3.1.1 erform a system functional test for each 24 nths imary containment hydrogen recombiner.

SR 3.6.3.1.2 Visua X examine each primary contain t 24 months hydrogen ecombiner enclosure and ve fy there is n evidence of abnormal conditions.

SR 3.6.3.1.3 perform a resista e to g un test for 24 months each heater phase.v I

PERRY - UNIT 1 3.6-45 Amendment No. 115 PY-CEI/NRR-2739L Page Iof12 MARKED-UP TECHNICAL SPECIFICATION BASES AND TECHNICAL SPECIFICATION TABLE OF CONTENTS PAGES REFLECTING THE PROPOSED AMENDMENT (For Information Only)

PY-CEIINRR-2739L Page 2 of 12 TABLE OF CONTENTS (continued)

B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.1 ECCS-Operating.

B 3.5-1 B 3.5.2 ECCS-Shutdown.

B 3.5-15 B 3.5.3 RCIC System.

B 3.5-21 3.6 CONTAINMENT SYSTEMS 3.6.1.1 Primary Containment-Operating............................

3.6-1 3.6.1.2 Primary Containment Air Locks............................. 3.6-3 3.6.1.3 Primary Containment Isolation Valves (PCIVs)..............

3.6-9 3.6.1.4 Primary Containment Pressure.............................. 3.6-20 3.6.1.5 Primary Containment Air Temperature.......................

3.6-21 3.6.1.6 Low-Low Set (LLS) Valves..................................

3.6-22 3.6.1.7 Residual Heat Removal (RHR) Containment Spray System.3.6-24 3.6.1.8 Feedwater Leakage Control System CFWLCS).................. 3.6-26 3.6.1.9 Main Steam Shutoff Valves.....................

3.6-27 3.6.1.10 Primary Containment-Shutdown..................... ;

3.6-29 3.6.1.11 Containment Vacuum Breakers.....................

. 3.6-31 3.6.1.12 Containment Humidity Control..

3.6-34 3.6.2.1 Suppression Pool Average Temperature......................

3.6-36 3.6.2.2 Suppression Pool Water Level..............................

3.6-39 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling................................................ 3.6-40 3.6.2.4 Suppression Pool Makeup (SPMU) System.-

4 3.6.3.1 Pe l Containment H

_ydroe R...

.............3.6 1

3.6.3.2 Primary Containment and Drywell Hydrogen.

Igniters.............................................. 3.6-46 3.6.3.3 Combustible Gas Mixing System............................. 3.6-49 3.6.4.1 Secondary Containment..................................... 3.6-51 3.6.4.2 Secondary Containment Isolation Valves (SCIVs)............

3.6-53 3.6.4.3 Annulus Exhaust Gas Treatment (AEGT) System...............

3.6-56 3.6.5.1 Drywell..............................................

3.6-59 3.6.5.2 Drywell Air Lock.......................................... 3.6-61 3.6.5.3 Drywell Isolation Valves..................................

3.6-65 3.6.5.4 Drywell Pressure.......................................... 3.6-69 3.6.5.5 Drywell Air Temperature................................... 3.6-70 3.6.5.6 Drywell Vacuum Relief System.............................. 3.6-71 B 3.6 CONTAINMENT SYSTEMS B 3.6.1.1 Primary Containment-Operating........................ B 3.6-1 B 3.6.1.2 Primary Containment Air Locks......................... B 3.6-7 B 3.6.1.3 Primary Containment Isolation Valves (PCIVs).......... B 3.6-17 B 3.6.1.4 Primary Containment Pressure.......................... B 3.6-33 B 3.6.1.5 Primary Containment Air Temperature................... B 3.6-36 B 3.6.1.6 Low-Low Set (LLS) Valves.............................. B 3.6-39 (continued)

PERRY - UNIT 1 iv Revision No. 2 PY-CEI/NRR-2739L Page 3 of 12 TABLE OF CONTENTS 3.6 CONTAINMENT SYSTEMS (continued) 3.6.1.7 Residual Heat Removal (RHR) Containment Spray System.......................................

B 3.6-43 3.6.1.8 Feedwater Leakage Control System (FWLCS).............. B 3.6-48 3.6.1.9 Main Steam Shutoff Valves............................. B 3.6-51 3.6.1.10 Primary Containment-Shutdown............................. B 3.6-55 3.6.1.11 Containment Vacuum Breakers............................... B 3.6-59 3.6.1.12 Containment Humidity Control..............................

B 3.6-65 3.6.2.1 Suppression Pool Average Temperature B 3.6-70 3.6.2.2 Suppression Pool Water Level........................

B 3.6-75 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling.............................

B 3.6-79 "'

3.6.2.4 Suppression Pool Makeup CSPMU) System...

B 3.6-83(ips 3.6.3.1 flcchmbinPr.

3.6.3.2 Primary Containment and Drywell Hydrogen Igniters:....................................

B 3.6-95 3.6.3.3 Combustible Gas Mixing System.......................... B 3.6-101 3.6.4.1 Secondary Containment................................. B 3.6-106 3.6.4.2 Secondary Containment Isolation Valves (SCIVs)........ B 3.6-111 3.6.4.3 Annulus Exhaust Gas Treatment (AEGT) System........... B 3.6-118 3.6.5.1 Drywell....................................

B 3.6-123 3.6.5.2 Drywell Air Lock.................................... B 3.6-128 3.6.5.3 Drywell Isolation Valves.............................. B 3.6-136 3.6.5.4 Drywell Pressure.................................... B 3.6-145 3.6.5.5 Drywell Air Temperature............................... B 3.6-148 3.6.5.6 Drywell Vacuum Relief System.......................... B 3.6-151 f--J 3.7 PLANT SYSTEMS 3.7.1 Emergency Service Water (ESW) System-Divisions 1 and 2.

3.7.2 Emergency Service Water (ESW) System-Division 3.

3.7.3 Control Room Emergency Recirculation (CRER) System 3.7.4 Control Room Heating, Ventilation, and Air Conditioning (HVAC) System.

3.7.5 Main Condenser Offgas.

3.7.6 Main Turbine Bypass System.

3.7.7 Fuel Pool Water Level.

3.7.8 Fuel Handling Building.

3.7.9 Fuel Handling Building Ventilation Exhaust System.

3.7.10 Emergency Closed Cooling Water (ECCW) System.

B 3.7 PLANT SYSTEMS B 3.7.1 Emergency Service Water (ESW) System-Divisions 1 and 2..................................... B B 3.7.2 Emergency Service Water (ESW) System-Division 3

........... B B 3.7.3 Control Room Emergency Recirculation (CRER) System........ B 3.7-1 3.7-3 3.7-4 3.7-8 3.7-11 3.7-13 3.7-14 3.7-15 3.7-16 3.7-19 3.7-1 3.7-7 3.7-10 PERRY - UNIT 1 v

Revision No. 2 PY-CEI/NRR-2739L Page 4 of 12 PAM Instrumentation B 3.3.3.1 BASES LCO

9. Penetration Flow Path. Primary Containment Isolation Valve (PCIV) Position (continued) enetration flow n his not needed to determine status.

Ther Vvt.r e -p6osition1'.1dictmi

valves in an isolated enetration is not required to be0PERABL A

9

10.

_P4 azContanmo AndrynvwP1l Hvyrloen ConCent-ati-

)

-Analyzer ad kom te-

/

Iimary containment and drywell hydrogen concentration (an ers and monitors are Category I i ruments provided to de t high hydrogen concentratio onditions that represent otential for containm breach.; This variable is also impo nt in verifying t adequacy of mitigating actions.\\

The primary containme drywell hydrogen concentration analyzers and monitors nstrumentation consists of two completely redundan ydroge alyzers each with control room recorders.

ch analyzer sales from four redundant sample lines:

e from above the s ession pool, one from the space beeen the reactor vessel e and drywell dome.

one from e top of the drywell area, and o from the top of the me of the containment vessel. Each an zer has the pability to measure a range of 0-10 percent rogen entration.

1IS-P1imrvContainment Pressure Primary containment pressure is a Category I variable provided to verify RCS and containment integrity and to verify the effectiveness of ECCS actions taken to prevent containment breach. Two wide -range primary containment pressure signals are transmitted from separate pressure transmitters and are continuously recorded and displayed on two control room recorders. These recorders are the primary indication used by the operator during an accident.

Therefore, the PAM Specification deals specifically with this portion of the instrument channel.

(continued)

PERRY - UNIT 1 B 3.3-57 Revision No. 1 PY-CEI/NRR-2739L Page 5 of 12 PAM Instrumentation B 3.3.3.1 BASES ACTIONS F.1 (continued)

NRC should discuss the alternate means used, describe the degree to which the alternate means are equivalent to the installed PAM channels. justify the areas in which they are not equivalent. and provide a schedule for restoring the normal PAM channels.

The special report shall be submitted in accordance with 10 CFR 50.4 within 14 days of entering Condition F.

SURVEILLANCE The following SRs apply to each PAM instrumentation Function REQUIREMENTS in Table 3.3.3.1-1. except as noted below.

SR 3.3.3.1.1 i

For all Functions cxcejt the Primiiarly Cod mIad DJrwel

{ Hyrogn Coecnr~tin Aalyzr ld 1101ibor. performance of t

h HANNEL CHECK once ever 31 days ensures that a gross n

Tisaxr'bfii-SnOt occurred, A CHANNk8Fz-is normally a comparison of the parametereu-i-i.. ed on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value.

Significant deviations between instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious.

CHANNEL CHECK will detect gross channel -failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

The Primary Containment and Drywell Gross Gamma Radiation Monitors should be compared to similar plant instruments located throughout the plant.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties.

including isolation, indication, and readability. If a channel is outside the criteria. it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.

(continued)

PERRY - UNIT 1 B 3.3-61 Revision No. 1 PY-CEI/NRR-2739L Page 6 of 12 PAM Instrumentation B 3.3.3.1 BASES SURVEILLANCE SR 3.3.3.1.1 (continued)

REQUIREMENTS The Frequency of 31 days is based upon plant operating experience with regard to channel OPERABILITY and drift.

which demonstrates that failure of more than one channel of a given function in any 31 day interval is rare. The CHANNEL CHECK supplements less formal. but more frequent.

norma opertional use of those g

~~~~~~displays associatedwt trSmnts~~~

hsLO fZ{ 3.

3 t 7-O 3331. n SR.3.3.3.1.3.

For all Functions xccnpt the Primary Containmcnt and Dryell

"---5____^Hydrogon Conccntrathio Analyst and Monitor a CHANNEL

'---'----1L NLLIN spef d every 24 months, or approximat at every refuel chek of the instrument loop including the sensor. The test verifies that the channel responds to the measured parameter with the necessary range and accuracy. The CHANNEL CALIBRATION for the Penetration Flow Path, PCIV Position consists of the Position Indicator Test (PIT), which is conducted in accordance with the ASME inservice inspection and testing program. The CHANNEL CALIBRATION for primary Containment/Drywell Area Gross Gamma Radiation Monitors shall consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/hr and a one oint calibration check of the detector below 10 R/hr wit an instaliegii pslgamsource. The Frsbf5i ae on RteatgeplAmailvd it nc h

~the typical industry refueling yls

( Fsrthe Primary Containment and Drywifll Hrogen A

Conc ration Analyzer and Monitor tg M NEL CALIBRAT ON is perfo every 92 days. Th alibration is perf ed using sample otan in

a. One volume per ogen. balance nitrogen.

b. Four volu rcent hy balance nitrogen.

This equency is based on operating nce.

REFERENCES

1.

Regulatory Guide 1.97, "Instrumentation for Light-Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," Revision 2, December 1980.

2.

USAR, Table 7.1-4.

PERRY - UNIT 1 B 3.3-62 Revision No. 3 PY-CEIUNRR-2739L Page 7 of 12 SPMU System B 3.6.2.4 BASES (continued)

REFERENCES

1. USAR. Section 6.2.

2. USAR. Chapter 15.

PERRY - UNIT 1 Revision No. 1 PY-CEI/NRR-2739L Page 8 of 12 Primary Containment Hydrogen Recombiners B 3.6.3.1 B 6 CONTAINMENT SYSTEMS B 3.6.

1 Primary Containment Hydrogen Recombiners BASES

/7 BACKGROUNID The primary containment hydrogen re ombiner eliminates the tential breach of primary contai ment due to a hydrogen oxgen reaction and is part of cobustible gas control req *red by 10 CFR 50.44. "Stan rds for Combustible Gas Contr I in Light-Water-Cooled actors" (Ref. 1). and GDC 41. "Containment Atmospher Cleanup" (Ref. 2).

The primary ontainment hydrogen ecombiner is required to reduce th hydrogen concentr tion in the primary containment following a loss of coolan accident (LOCA).

• The primary containment drogen reco iner accomplishes this by.

recombining h rogen and oxygen to form water vapor.

The vapor remains i the pri ary containment, thus eliminating any discharge to the e vironment.

The primary containment hydrogen recombin i manually operated, since flammability limits would not bleached until several days after a Design Basis Accide (DBA).

Two 100% capacity inde endent primary containment hydrogen recombiner subsy tems a e provided.

Each consists of a power supply a control located in the control complex and a recombiner cated in p imary containment. The recombiners ye no moving arts.

Recombination is accomplishedby heating a hdrogen air mixture > 11500F.

,The result g water vapor an discharge gases are cooled prior to Oscharge from the u ft.

Air flows through the unit at 100 cfm, with natural crculation in the unit providirn the motive force.

A s~hgle recombiner is capable of mai taining the hydrogen conce tration in primary contai'ment below the 4.0 volume p rcent Cv/o) flammability limi.

Two recombiners are provide to meet the requirement for edundancy and independence.

Ea recombiner is powered fr m a separate Engineered Safety Fea re bus.

ant Emergency Instructions direct tha the hydrogen concentration in primary containment be m nitored following a DBA and that the primary containment hyd gen recombiner

/ be manually activated to prevent the primar containment atmosphere from reaching a bulk hydrogen c tion of 4.0 v/o.

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PERRY - UNIT 1 B 3.6-90 Revision No. I PY-CEI/NRR-2739L Page 9 of 12

.Primary Containment Hydrogen Reombiners Pt :R h;.14 BASES (continued)

APPLICABLE The primary containment hydrogen recombiner provides the AFETY ANALYSES capability of controlling the bulk hydroge concentration in primary containment to less than the lower flammable concentration of 4.0 v/o following a DB This control would prevent a primary containment wi hydrogen burn, thus ensuring that pressure and temperatur conditions assumed in the analysis are not exceeded. The miting DBA relative to hydrogen generation is a LOCA.

Hydrogen may accumulate in primary containment following a LOCA as a result of:

a.

A metal steam reaction be een the zirconium fuel rod cladding and the reactor oolant; or Radiolytic decompositio of water in the "Reactor Coolant System.

To e luate the potential for hydrogen accumulation in primar containment foll ing a LOCA. the hydrogen generat n as a functio of time following the initiation of the acci nt is calcula ed. Assumptions recommended by Reference are used maximize the amount of hydrogen calculated.

The calculatio c rms that when the mitigating systems are actuated in ordance with plant procedures, the peak hydrogen concent tion in the primary containment remains

< 4.0 v/o (Ref.

)

The primary co ainm t hydrogen recombiners satisfy Criterion 3 o the NR olicy Statement.

LCO Two indepen ent primary c\\ tainment hydrogen recombiners must be OP RABLE.

This ens res operation of at least one primary c ntainment hydrogen ecombiner in the event of a worst cape single active fail e.

Operati n with at least one prim ry containment hydrogen recomb, ner subsystem ensures that he post LOCA hydrogen conceytration can be prevented fro exceeding the flaability limit.

APPLICABILITY I MODES 1 and 2. the two primary conta n ent hydrogen

-rcombiners are required to control the hSd4rogen-

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I PERRY - UNIT 1 B 3.6-91 Revision No. 1 PY-CEI/NRR-2739L Page 10 of 12

.Pr-imary Containment Hydrogen Recombiners

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3.6.3.1

\\%

BASES

\\ APPLICABILITY (continued) concentration within primary containment bel wits flammability limit of 4.0 v/o following a CA, assuming a worst case single failure.

In MODE 3. both the hydrogen productio rate and the total hydrogen production after a LOCA woul be less than that calculated for the DBA LOCA. Also. ecause of the limited time in this MODE. the probability f an accident requiring the primary containment hydrogen r combiners is low.

Therefore, the primary containme hydrogen recombiners are not required in MODE 3.

In MODES 4 and 5. the probabi ity and consequences of a LOCA are low due to the pressure nd temperature limitations in these MODES. Therefore. ti) primary containment hydrogen recombiners are not requi ad in these MODES.

ACTIONS WitX one primary co ainment hydrogen recombiner inoperable.

the operable pri ry containment hydrogen recombiner must bre ored to OP LE status within 30 days.

In this Conditi n. the r aining OPERABLE primary containment hydrogen recomb er is adequate to perform the hydrogen control f cti.

However. the overall reliability is reduced be u a single failure in the OPERABLE recombiner could result n reduced hydrogen control capability. The 30 day Comp on Time is based on the low probability of the occurr ce a LOCA that would generate hydrogen in amounts c able exceeding the flammability limit, the amount o time ava lable after the event for operator action to prevynt hydrogen ccumulation exceeding this limit, and the lo probability o failure of the OPERABLE primary conta'nment hydrogen r combiner.

Re fired Action A.1 has Fen modified by a Note stating that theprovisions of LCO 3.0.

are not applicable.

As a rsult a MODE change is al wed when one recombiner is noperable. This allowance i provided because of the low probability of the occurrence Mf a LOCA that would generate

, hydrogen in amounts capable of ceeding the flammability limit, the low probability of the failure of the OPERABLE 7

recombiner, and the amount of timeTavailable after a postulated LOCA for operator action o prevent exceeding the flammability limit.

.continued)

II PERRY - UNIT 1 B 3.6-92 Revision No. 1 PY-CEIINRR-2739L Pageli1 of 1 eobnr Primary Contalrnment Aiydrogen Recombiners B 3.6.3.1 BASES CTIONS (continued)

B.1 and B.2 With two primary containment hydrogen ecombiners inoperable, the ability to perform the hydrogen control function via alternate capabilities,ust be verified by administrative means within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />./ The alternate hydrogen control capabilities are provided/by one division of the hydrogen igniters. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> C mpletion Time allows a reasonable period of time to verj fy that a loss of hydrogen control function does not exis The verification may be performed as an administrativ check by examining logs or other information to determi the availability of the alternate hydrogen control stem.

It does not mean to perform the Surveillances eeded to demonstrate OPERABILITY of the alternate hydrogen control system. If the ability to erform the hydrogen con rol function is maintained.

ntinued operation is ermitted with two hydrogen re ombiners inoperable/for up to 7 days. Seven days is a rea nable time to allow two hydrogen recombiners to be minop able because tie hydrogen control function is mainta ned and becagse of the low probability of the occurre ce of a LOVA that would generate hydrogen in the amounts pable o exceeding the flammability limit.

C.1 If any Requi, Action and associated Completion Time cannot be met, the Slant must be brought to a MODE in which the LCO does not apply.

o achieve this status, the plant must be brought to at lea MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The allowed CompletioA Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is reasonable. based on operatin experience, to reach MODE 3 from full power conditi ns in an orde y manner and without challenging plant ystems.

SURVEILLA REQUIREME

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NCE SR /3.6.3.1.1 P rformance of a system functinal test for each primary

/ ontainment hydrogen recombiner sures that the recombiners are OPERABLE and can attain and s tam the temperature necessary for hydrogen recombinatio5.

In particular. this SR requires verification that the mi mum heater sheath temperature increases to z 1225OF in S hours and that it is maintained a 1225 and < 14500F for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to check the capability of the recombiner to properly ction.

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S PERRY - UNIT 1 B 3.6-93 Revi sion No. 1 PY-CEI/NRR-2739L Page 12 of 12 Primary Containment Hydrogen Recombiners B 3..3.1 BASES i RVEILLANCE SR 3.6.3.1.1 (continued)

REQUIREMENTS The 24 month Frequency is based on operating perience, and is consistent with a typical industry refuelTng cycle.

SR 3.6.3.1.2 This SR ensures that there are no physi a problems (e.g..

loose wiring or structural connectiona. deposits of foreign materials, etc.) that could affect p mary containment hydrogen recombiner operation. Sin e the recombiners are mechanically passive, they are not subject to mechanical failure. The only credible failues involve loss of power, blockage of the internal flow pah, missile imp act, etc. A visual inspection is sufficien to determine abnormal conditions that could cause s ch failures.

e 24 month Frequency is b sed on operating experience, and consistent with a typi 1 industry refueling cycle.

SR 3.6:3.1.3 This R requires perf rmance of a resistance to ground test of ea heater phase to ensure that there are no detectable ground in any hea r phase. This is accomplished by verifyi that th resistance to ground for any heater phase is 2 10. 0 ohms ollowing the performance of SR 3.6.3.1.1.

The 24 mon F quency is based on operating experience, and is consiste v th a typical industry refueling cycle.

REFERENCES

1. 10 CF 50 4.

2. 10 FR 50. A endix A. GDC 41.

3.

gulatory Gui 1.7. Revision 2.

4.

AR, Section 6.2.

PERRY - UNIT 1 B 3.6-94 Revision No. 3

PY-CEI/NRR-2739L 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. The PNPP staff commits to maintaining a hydrogen monitoring system capable of diagnosing beyond design-basis accidents. The administrative controls for the hydrogen monitoring system, with the exception of the plant shutdown requirements, will be incorporated into the Operational Requirements Manual. This regulatory commitment will be implemented within 90 days of the effective date of the amendment.