View source for L-09-031, Application for Technical Specification Change Regarding Revision of Control Rod Application for Technical Specification Change Regarding Revision of Control

{{Adams
| number = ML090760866
| issue date = 03/11/2009
| title = Application for Technical Specification Change Regarding Revision of Control Rod Application for Technical Specification Change Regarding Revision of Control
| author name = Bezilla M
| author affiliation = FirstEnergy Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000440
| license number = NPF-058
| contact person = 
| case reference number = L-09-031
| document type = Letter type:L, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specification, Amendment
| page count = 30
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:FENOC                                                                                Perry Nuclear Power Station 10 Center Road FirstEnergy Nuclear Operating Company                                                         Perry, Ohio 44081 MarkB. Bezilla                                                                                    440-280-5382 Vice President                                                                               Fax: 440-280-8029 March 11,2009 L-09-031                                                          10 CFR 50.90 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

==SUBJECT:==

Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency and a Clarification of a Frequencv Example In accordance with the provisions of 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) is submitting a request for an amendment to the technical specifications (TS) for the Perry Nuclear Power Plant (PNPP).
The proposed amendment would: (1) revise TS surveillance requirement (SR) frequency in TS 3.1.3, Control Rod OPERABILITY, and (2) revise Example 1.4-3 in Section 1.4 Frequency to clarify the applicability of the 1.25 surveillance test interval extension.
The enclosure provides the evaluation for the proposed amendment.
Approval of the license amendment is requested prior to August 29, 2009, with the amendment to be implemented within 90 days following its effective date.
Regulatory commitments associated with this submittal are included in the attachment. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 761-6071.
I declare under penalty of perjury that the foregoing is true and correct. Executed on March L\,  2009.
Mark B. Bezillal/

March 11, 2009 L-09-031                                                                 10 CFR 50.90 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

==SUBJECT:==

Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency and a Clarification of a Frequency Example In accordance with the provisions of 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) is submitting a request for an amendment to the technical specifications (TS) for the Perry Nuclear Power Plant (PNPP).
The proposed amendment would: (1) revise TS surveillance requirement (SR) frequency in TS 3.1.3, Control Rod OPERABILITY, and (2) revise Example 1.4-3 in Section 1.4 Frequency to clarify the applicability of the 1.25 surveillance test interval extension.
The enclosure provides the evaluation for the proposed amendment.
Approval of the license amendment is requested prior to August 29, 2009, with the amendment to be implemented within 90 days following its effective date.
Regulatory commitments associated with this submittal are included in the attachment. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 761-6071.
I declare under penalty of perjury that the foregoing is true and correct. Executed on March ___, 2009.
Sincerely, Mark B. Bezilla

Perry Nuclear Power Plant L-09-031 Page 2 of 2

==Attachment:==

Regulatory Commitment List

==Enclosure:==

Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency and a Clarification of a Frequency Example cc:    NRC Region III Administrator NRC Resident Inspector NRR Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)
Utility Radiological Safety Board

Attachment L-09-031 Regulatory Commitment List Page 1 of 1 The following list identifies those actions committed to by FirstEnergy Nuclear Operating Company (FENOC) for Perry Nuclear Power Plant in this document. Any other actions discussed in the submittal represent intended or planned actions by FENOC. They are described only as information and are not Regulatory Commitments. Please notify Mr.
Thomas A. Lentz, Manager - Fleet Licensing, at (330) 761-6071 of any questions regarding this document or associated Regulatory Commitments.
Regulatory Commitment                                 Due Date
: 1. FENOC commits to revising Technical                Concurrent with amendment Specification Bases based on TSTF-475,                implementation.
Revision 1 as proposed in Attachment 2 to the Enclosure.

Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency and a Clarification of a Frequency Example
: 1. DESCRIPTION
: 2. ASSESSMENT 2.1   APPLICABILITY OF PUBLISHED SAFETY EVALUATION 2.2   OPTIONAL CHANGES AND VARIATIONS
: 3. REGULATORY ANALYSIS 3.1   NO SIGNIFICANT HAZARDS DETERMINATION 3.2   VERIFICATION AND COMMITMENTS
: 4. ENVIRONMENTAL EVALUATION Attachments:
: 1. Proposed Technical Specification Changes (Mark-Up)
: 2. Proposed Changes to Technical Specifications Bases
: 3. Proposed Technical Specification Changes (Retyped)

Page 2 of 3

==1.0    DESCRIPTION==

The proposed amendment would: (1) revise the Technical Specification (TS)
Surveillance Requirement (SR) 3.1.3.2 frequency in TS 3.1.3, Control Rod OPERABILITY, and (2) revise Example 1.4-3 in Section 1.4, Frequency, to clarify the applicability of the 1.25 surveillance test interval extension.
The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification (STS) change TSTF-475, Revision 1. The Federal Register notice published on November 13, 2007 announced the availability of this TS improvement through the consolidated line item improvement process (CLIIP).
2.0    ASSESSMENT 2.1    Applicability of Published Safety Evaluation FirstEnergy Nuclear Operating Company (FENOC) has reviewed the safety evaluation dated November 5, 2007 as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the background information provided to support TSTF-475, Revision 1. FENOC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Perry Nuclear Power Plant (PNPP), Unit 1 and justify this amendment for the incorporation of the changes to the PNPP TS.
2.2    Optional Changes and Variations TSTF-475, Revision 1 proposes three changes to the STS. The proposed change: (1) revises the TS control rod notch surveillance frequency in TS 3.1.3, (2) clarifies the TS 3.3.1.2 requirement for fully inserting control rods for one or more inoperable SRMs in Mode 5, and (3) revises one example in Section 1.4, Frequency, to clarify the applicability of the 1.25 surveillance test interval extension.
Only two of the changes are proposed for this amendment application. The change to TS 3.3.1.2, which is not included in this amendment application, would have incorporated the word fully into Required Action E.2, Source Range Monitoring Instrumentation, as follows:
Initiate action to fully insert all insertable control rods in core cells containing one or more fuel assemblies.
The word fully is already in PNPP TS 3.3.1.2, Required Action E.2, Source Range Monitoring Instrumentation. Therefore, no change is necessary to incorporate this aspect of TSTF-475 into the PNPP TS.

Page 3 of 3 FENOC is not proposing any other variations or deviations from the TS changes described in the modified TSTF-475, Revision 1 and the NRC staffs model safety evaluation dated November 5, 2007.
FENOC is proposing a variation relative to the proposed TS Bases changes contained in TSTF-475, Revision 1. The TSTF-475 proposed TS Bases discussion for SR 3.1.3.3 (previously identified as SR 3.1.3.4) would remove SR 3.1.4.4 from the listed SRs performed in conjunction with SR 3.1.3.3. Incorporation of this change would be inconsistent with TS SR 3.1.3.3, which includes SR 3.1.4.4 in the Frequency column.

==3.0     REGULATORY ANALYSIS==

3.1     No Significant Hazards Consideration Determination FENOC has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. FENOC has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to PNPP without need for modification despite the deviation described in Section 2.2 of this application and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).
3.2     Verification and Commitments As discussed in the notice of availability published in the Federal Register on November 13, 2007 for this TS improvement, FENOC verifies the applicability of TSTF-475 to PNPP, and commits to revising Technical Specification Bases based on TSTF-475, Revision 1, as proposed in Attachment 2.
These changes are based on TSTF change traveler TSTF-475, Revision 1, which proposes revisions to the STS by: (1) revising the frequency of SR 3.1.3.2, notch testing of fully withdrawn control rod, from 7 days after the control rod is withdrawn and THERMAL POWER is greater than the [Low Power Setpoint] LPSP of [Rod Pattern Control System] RPCS to 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RPCS, and (2) revising Example 1.4-3 in Section 1.4, Frequency, to clarify that the 1.25 surveillance test interval extension in SR 3.0.2 is applicable to time periods discussed in NOTES in the SURVEILLANCE column in addition to the time periods in the FREQUENCY column.
4.0 ENVIRONMENTAL EVALUATION FENOC has reviewed the environmental evaluation included in the model safety evaluation dated November 5, 2007 as part of the CLIIP. FENOC has concluded that the staffs findings presented in that evaluation are applicable to PNPP without need for modification despite the deviation described in Section 2.2 of this application, and the evaluation is hereby incorporated by reference for this application.
Page 1 of 9 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Frequency 1.4 1.4  Frequency EXAMPLES       EXAMPLE 1.4-2              (continued)
                 "Thereafter" lndicates future performances must be established per SR 3.0.2, but only after a specified condition i s ffrst met (Le., the "once" performance i n t h i s example).
I f reactor power decreases to < 25% RTP, the measurement o f both intervals stops. New intervals start upon reactor power reaching 25% RTP.
EXAMPLE 1, 4-3 The interval continues whether or not the unit operation i s
                < 25% RTP between perfownces.
As the Note modifies the required performance o f the Surveillance, i t i s construed to be p a r t o f the "specified Frequency." Should the 7 day interval be exceeded while operation i s < 25% RTP, t h i s Note allows 12 hours after power reaches 2 25% RTP t o perform the Surveillance. The Surveillance i s still consldered to be within the "specffied Frequency. Therefore, i f the Surveillance were not performed within the 7 day (plus the extension allowed by SR 3.0.2) Interval, but operatton was < 25% RTP, 3t would not c o n s t j t u t e a failure of the SR or fai'luret o meet the LCO. Also, no v i o l a t i o n o f SR 3,0.4 occurs when changing MDU, even w i t h the 7 day Frequency not met, provided operation does not exceed 12 hours i t h power 2 25% RTP.
tCORt5W$dl I
PERRY - UNIT 1                                   1.0-27                          Amendment No, 69

Frequency 1.4 1.4 Frequency EXAMPLES       EXAMPLE 1.4-3 (continued)
Once the u n i t reaches 25% RTP, 12 hours would be allowed f o r I f the Survei 1lance were not ompletingwthe erformed                  t h j 1lance.
i t h i nSurvei     hour i@erVtiJp there would then be t a l lure t o perrorinsalhver I lance wqthin the specified Frequency, and the provisions o f SI? 3.0.3 would apply.
EXAMPLE 1.4-4 SURVEILLANCE REQUIREMENTS SURVEILLANCE                         FREQUENCY Verify leakage rates are w i t h i n l i m i t s .      24 hours Example 1.4-4 specifies t h a t the requirements o f t h i s Surveillance do not have t o be met u n t i l the u n i t i s in MODE 1. The interval measurement f o r the Frequency o f t h i s Surveillance continues a t a l l times, as described i n Example 1.4-1. However, the Note constitutes an "otherwise stated" exception t o the A p p l i c a b i l i t y o f this Surveillance.
R Therefore. i f the Surveillance were not erformed within the 24 hour (plus the extension allowed by S 3.0.2) i n t e r v a l ,
but the u n i t was not i n MODE 1, there would be no failure o f the SR nor f a i l u r e t o meet the LCO. Therefore, no v i o l a t i o n o f SR 3.0.4 occurs when changing MODES, even with the d
24 hour Fre uency exceeded, provided t h e MODE change was not made i n t o DE 1. Prior t o entering MOD 1 (assuming again that the 24 hour Frequency were not met), SR 3.0.4 would re u i r e satisfying the SR, except as provided by SR 3 . 0 . 3 1
an LCO 3.0.4.
1.0-28                      Amendment No. 131

Control Rod OPERABILITY
                                                                                                                               ' 1 1 2 3 . 1 REACTIVITY CONTROL SYSTEMS 3.1.3             Control Rod OPERABILITY LCO 3.1.3                                  Each control rod shall be OPERABLE.
APPLICABILITY:                            MODES 1 and 2.
ACTIONS
 - - - - - - - - - - - - - - - - - - - - _ _ _ c _ _ _ _ _ _ _ _ _ _ _ _ _      NOTE-------------------------------------
Separate Condition entry i s allowed for each control rod.
CONDITION                                             REQUIRE0 ACTION                    COMPLETION TIME A.         One withdrawn control                               - - - - - - - - - - - - NOTE-------------
rod stuck.                                         A stuck rod may be bypassed in the Rod Action Control System (RACS) i n accordance with SR 3.3.2.1.9 i f required to allow continued operation.
A. 1            Verify stuck control             Inpnedi ately rod separation c r i t e r i a are met.
A.2             Disarm the associated           2 hours control rod drive (CRD)     .
AND (continued)
PERRY - UNIT 1                                                                3.1-7                              Amendment No. 120

Control Rod OPERABILITY 3.1.3 ACTIONS CONDITION            REQUIRED        ACTION            COMPLETION TIME A.  (continued)           A.3                        3.2       24 hours from for       discovery o f each withdrawn                  Cond-ition A OPERABLE control rod.           concurrent w i t h THERM1 POWER greater than or equal t o the 1ow power setpoint (LPSP) o f the Rod Pattern Control AND                                  System (RPCS).
A.4  Perform SR 3.1.1.1.             72 hours B. Two or more withdrawn B.l  Be i n MODE 3.                  12 hours control rods stuck.
C. One or more control    c.1  - - _ - - - - -NOTE---------
rods inoperable f o r      Inoperable control reasons other than         rods may be bypassed Condition A or B.          i n RACS i n accordance with SR 3.3.2.1.9. i f required. t o a1 low insertion o f inoperabl e control rod and continued operation, Fully insert                    3 hours inoperable control rod.
C.2  Disarm the associated           4 hours CRD .
(continued)
PERRY - UNIT 1                 3.1-8                             Amendment No. 1 20

Control Rod OPERABILITY 3.1.3 D. 1 Restore cornpli&nc-d t h  4 hours BPMS .
OR D.2  Restore control rod t o   4 hours Two or more inoperable           OPERABLE status.
control rods not i n compl iance with banked pos i t i on w i t hdraw1%
sequence (BPWSJ and not separated by twu or more OPERABtE control rods.
E. Required Action and         E.1  Be i n MODE 3.
a ssoci a t ed Compl et iun Time o f Condition A.
C, or D not met.
Nine or more cantm3 rods i noperabl e,.
PERRY  - UNIT 1                        3.1-9                      Amendment No. 112

Control Koa   UYLKH~Z~LIII 3.1.3 SURYEICLANCE REQUIREM,ENTS SURVE I lLAElCE                                 FREQUENCY 24 hours Insert each                   w i thdrawn control rod   31 days a t least one no c SR 3.1,3@
d     Verify each control rad scram time frum f u l l y wjthdrann t o notch positton 13 i s L 7 seconds.
In accordance w#t h S R 3.1.4*1, SR 3.1-4,2, SR J,Z,4.3, and SR 3.1.4.4 (continued)
PERRY - UNIT  1                             3.1-10                       Amendment No. 69

PERRY - 3.1-11 Amendment No, 69 Table 3.1.4-1 Control Rod Scram Times (a)  Maximum scram time from fully withdrawn position, based on de-energization o f scram p i l o t valve solenoids as time zero-(b)   Scram times as a functlon of reactor steam dome pressure when < 950 PSig are within established l i m i t s .
(c)   For intermediate reactor steam dome pressures, the scram time criteria are deterrained by 1 inear interpol ation.
PERRY  - UNIT  1                           3.1-14                   Amendment No. 69 Page 1 of 7 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS BASES (PROVIDED FOR INFORMATION)

Control Rod OPERABILITY B 3.1.3 BASES LCO (cont inued) satisf contro control r   the intended reactivity control r e uirements, s t r i c t 8
over the number and distribution o inoperable rods i s required t o satisfy the assumptions o f the DBA and     transient analyses.
APPCICABI L IN     I n MODES 1 and 2. the control rods are assumed t o function durin a DBA or transient and are therefore required t o be O P E d L E i n these MODES. In MODES 3 and 4, control rods are not able t o be withdrawn since the reactor mode switch i s in Shutdown and a control rod block i s ap lied. This provides E
adequate requirements f o r control rod PERABILITY during these conditions. Control rod r e uirements i n PKIDE 5 are 1
located i n LCO 3.9.5."Control Ro OPERABl[LITY-Refueling. ''
ACTIONS            The ACTIONS table i s modified by a Note indicating that a separate Condition entry i s allowed f o r each control rod.
This i s acceptable, since the Required Actions for each z
Condition provide appropriate compensator actions for each inoperable control rod. Complying with t e Required Actions may    a1low f o r continued operation, and subsequent inoperable control rods are governed by subsequent Condition entry and application o f associated Required Actions.
A . 1 , A.2. A.3, and A.4 A control rod i s considered stuck i f i t w i l l not insert (using a71 available insertion methods) by either CRD drive water o r scram pressure. With a f u l l y inserted control rod stuck. no actions are required as long as the control-rod remains f u l l y inserted. The Required Actions are modified b a Note that allows a stuck control rod t o be bypassed i n K
t e Rod Action Control System (RACS) t o allow cont-inued o e r a t i on. SR 3 3.2.1.9-provides addi t ional requi rements den  control rods are bypassed i n RACS t o ensure compliance with the CRDA analysis. With one withdrawn control rod stuck. the local scram reactivity rate assumptions may not be met i f the stuck control rod separation c r i t e r i a are not met. Therefore. verification that the separation c r i t e r i a (continued)

Control Rod OPERABILITY 8 3.1.3 BASES ACTIONS       A . l . A.2, A.3. and A.4   (continued) are met must be performed immediately. The stuck control rod separation criteria are that the stuck control rod ma not occupy a location adjacent t o a 'slow" control rod. {he description o f "slow" control rods i s provided i n LCO 3.1.4 "Control Rod Scram Times". I n addition, the control rod must be disarmed within 2 hours. The allowed Completion Time o f 2 hours i s acceptable, considerin the reactor can 3
still be shut dorm. assuming no additiona control rods f a i l t o insert. and provides a reasonable amount of time t o 4
perform the Re uired Action i n an orderly manner. Isolating the control r from scram prevents damage t o the CRDM. The control rod can be (cont inued1 PERRY - UNIT 1                    B 3.1-15a                    Revision No. 4

Control Rod OPERABILITY B 3.1.3 BASES ACTIONS        A . 1 . A.2. A.3. and A.4     (continued) isolated from scram by isolating the hydraulic control u n i t from scram and normal drive and withdraw pressure. yet still maintain cooling water t o the CRD. A control rod can be hydraulically disarmed by closing the drive water and exhaust water isolation valves. Electrically. the control rod can be disarmed by dlsconnecting power from a l l four directional control valve solenoids.
Monitoring o f the insertion capability for each withdrawn_
control r d must a l s o H r f o r m e d within 24 hours. A    7 3
SR 3.1.3.2 Eerforflperiodic tests o f the control rod( insert% caDa i l i t y o f withdrawn control rods.
Testing each withdrawn control rod ensures that a. generic problem does not exist. The allowed Completion Time of 24 hours provides a reasonable t i m e t o test the control rods, considering the potential fur a need t o reduce power t o perform the tests. Required Action A.2 has a modifjed t i m e zero Completion Time. The 24 hour Completion Time for t h i s Required Action starts when the withdrawn control rod i s discovered t o be stuck and THERMAL POWER i s greater than P
the actual low Ower set i n t (LPSP) o f the rod pattern
                                            !?
control fer (RPC , since he notch insertions may not be co a t i b l e with the r e uirements o f rod pattern control (LE                        2 3.1.6) and the RP (LCO 3.3.2.1, Control Rod Block Instrumentation 1.
To allow continued operation with a withdrawn control rod stuck. an evaluation of adequate SDM i s also required within 72 hours. Should a DBA or transient require a shutdown. t o preserve the single failure c r i t e r i o n an additional control rod would have t o be assumed t o have failed t o insert when s
required. Therefore. the ori inal SM demonstration may not be v a l i d . The SOM must there ore be evaluated (by measurement or analysis) with the stuck control rod a t i t s stuck position and the highest worth OPERABLE control rod assumed t o be fully withdrawn.
The allowed Completion Time o f 72 hours t o v e r i f y SDM i s adequate, considering that with a single control rod stuck In a withdrawn position, the remaining OPERABLE control rods are capable o f providing the re uired scram and shutdown reactivitl                          d
                              . Failure t o reach DE 4 i s on1 likely ifan 51 additiona control rod adjacent t o the stuc control rod (continuedl PERRY - UNIT 1                      B 3.1-16                         Revision No. 4

Control Rod OPERABILITY B 3.1.3 BASES ACTIONS A . 1 . A.2. A.3. and A.4        (continued) 9 also f a i l s t o insert durin a required scram. Even with the postulated additional sing e failure o f an adjacent control rod t o insert, sufficient reactivity control remains t o reach and maintain MODE 3 conditions (Ref. 7).
With two or more withdrawn control rods stuck, the plant should be brought t o WDE 3 within 12 hours. Isolating the control rod from scram prevents damage t o the CRDM. The occurrence o f more than one control rod stuck a t a withdrawn s i t i o n increases the probabi 1i t y that the reactor cannot shut down i f required. Insertion o f a l l insertable control rods eliminates the possibilit .of an additional f a i l u r e o f a control rod t o insert. Tie allowed Completion Time of 12 hours i s reasonable, based on operating experience, t o reach MODE 3 from f u l l power conditions i n an orderly manner and without challenging plant systems.
C.l and C.2 With one or more control rods inoperable for reasons other than being stuck i n the withdrawn position, operation may continue, provided the control rods are f u l l y inserted within 3 hours and disarmed (electrically or hydraulically) a control rod ensures the w i t h i n 4 hours.
Inserting shutdown and scram capabi i t i e s are not adversely affected.
The control rod i s disarmed t o prevent inadvertent withdrawal during subsequent o erations. The control rods E
can be hydraulically disarmed y closing the drive water and exhaust water isolation valves. Electrically, the control 7                 R rods can be disarmed b disconnecting ower from a l l four directional control va ve solenoids. i t h a control rod not coupled t o i t s associated drive mechanism, i n s e r t the control rod drive mechanism t o accomplish recoup1ing.
i Verify recouplin by withdrawing the control rod and observing any i n icated response o f the nuclear instrumentation and demonstrating that the control rod drive w i l l not go t o the overtravel position. Required Action C.1 z
i s modified b a Note that allows control rods t o be 1
bypassed i n t e RACS i f r e uired t o allow insertion of the ino erable control rods an continued operation.
SR g.3.2.1.9 provides additional requirements when the control rods are bypassed t o ensure compliance with the CRDA analysis.
(continuedl

Control Rod OPERABILITY B 3.1.3 SASES  (continued)
SURVEILLANCE        SR 3.1.3.1 REQUIREMENTS The position o f each control rod must be determined, t o ensure adequate information on control rod position i s available t o the operator f o r determining control rod OPERABILITY andecontrol 1ing rod patterns. Control rod osition may be determined by the use o f at least one gPERA6i-E position indicator, by moving control rods t o a position with an OPERABLE indicator, or by the use o f other appropriate methods. The 24 hour Frequency o f t h i s SR i s based on operating experience related t o expected changes i n control rod position and the availability o f control rod position indications i n the control r m .
SR 3.1.3.21ki;6&$R fll.Y&J Control rod insertion capabilit i s demonstrated b T                    T inserting each p a r t i a l l y or f u l y withdrawn contro rod a t least one notch and observing that the control rod moves.
The control rod may then be returned t o i t s original position. Observation o f changes i n indicated control rod position provides evidence that the control rod osition indication i s OPERABLE. This ensures the contro rod i s not stuck and i s free t o insert on a scram signal. When plant P
rocedures permit, these SRs may also be met by rod scram.
h e s e Surveillances are not required when THEWL POWER i s less than or equal t o the actual LPSP o f the RPC since the notch insertions may not be cmatible with the reauirements e w @ i e d e relawd t o t h d c h a m e d i n CRD d r f o r d c e an&he
                                                  'awn control rods are t i? Frequenck based on the Dotential - m e rrxxhctim ntwco~dd;imfJ Furthermore. the atins exDerience related to'changes in CRD performance'. A t any t h e , ifa e
control rod i s imnovable. a determination o f t h a t control rod's t r i p a b i l i t y (OPERABILITY) must be made and appropria e action taken.
SR 3     .1  .3 .w Verifying the scram time for each control rod t o notch position 13 i s s 7 seconds provides reasonable assurance that the control rod will insert when required during a DBA or transient, thereby completing i t s shutdown function.
                                  +!j (continued)
              ~ZnformatM?
PERRY - UNIT 1                               B 3.1-19                        Revision No. 3

BASES SURVEILLANCE                  (continued)
REQUIREMENTS i n conjunction with the control rod SR 3.1.4.1. SR 3.1.4.2, SR 3.1.4.3, SYSTEM FUNCTIONAL TEST i n LCO 3.3.1.1. "Reactor Protection System (Rps)
InstrumentatJon." and the functional testing o f SDV vent and drain valves i n LCO 3.1.8. "Scram Discharge Volume W I V )
Vent and Drain Valves." overlap this Surveillance t o provide complete testing o f the assunred safety function. The associated Frequencies are acceptable, considering the more frequent testing erformed t o demonstrate other aspects of control rod OPERA[1ILIiv and operati ty e y i e n c e . which shows scram times do not slgnlficant y c ange over an operating cycle.
Coupling verification i s performed t o ensure the control rod is connected to the CRDM and will perform i t s internled function when necessary. The Survei 11 ance requi res verifying that a control rod does not go t o the withdrawn overtravel positi            i t i s f u l l y withdrawn. The ture rovides a positlve check on the overtravel posf ti P
coupling i n t pity, since on y an uncoupled CRD can reach 7
the overtrave position. The verification i s required t o be performed anytime a control rod i s withdrawn t o the "full out" position (notch,posltion 48) or prior t o declaring the control rod OPERABtEafter work on the control rod or CRD System that could affect coupling. This includes control rods inserted one notch and then returned t o the "full out" position durtng the performance o f SR 3.1.3.2. Until the control rod reaches the " f u l l out" position where coupling can be verified, the nuclear Instrumentation i s observed for 7 7 any indicated response duri withdrawal. This Frequency 1s acceptable, consideri the ow probability that a control rod will become uncoup ed when it is not k i n g moved and operati ng experi m e re1ated t o uncoupl ing events       .
PERRY - UNIT 1                    8 3.1-20                             Revision No. 1 Page 1 of 7 PROPOSED TECHNICAL SPECIFICATION CHANGES (RETYPED)

Frequency 1.4 1.4 Frequency EXAMPLES       EXAMPLE 1.4-2                     (continued)
               "Thereafter" indicates f u t u r e performances must be established per SR 3.0.2, but only a f t e r a specified condition i s f i r s t met ( i . e . , t h e "once" performance i n t h i s example). I f reactor power decreases t o < 25% RTP, the measurement o f both i n t e r v a l s s t o s. New i n t e r v a l s s t a r t upon reactor power reaching 25% RP.                          4!
EXAMPLE 1.4-3 SURVEILLANCE REOUIREMENTS SURV E I LLANCE                                  FREQUENCY Perform channel adjustment.                                                7 days The i n t e r v a l continues whether o r not t h e u n i t operation i s 25% RTP between performances.
                                                                              +
As t h e Note modifies the required erformance o f the Frequency." Should t h e 7 day i n t e r v a l be exceeded while Surveillance, operation i s c i25%             t i sRTP,  construed    t o be t h i s Note   allows     o hours p a r t 12 t h e "specified after
               !ower reaches 2 25% RTP t o perform t h e Surveillance. The u r v e i l l a n c e i s s t i l l considered t o be w i t h i n t h e "specified Fre uency . Therefore, i f t h e Survei 17 ance were not
                                  'I 9ormed iw SR 3.0.2) per                   n ti tehr ivna lt ,h ebut 7 day    (plus twas operation            < 25% RTP,allowed h e extension not c o n s t i t u t e a f a i l u r e o f t h e SR o r f a i l u r e t o meet the i t would by LCO. Also, no v i o l a t i o n o f SR 3.0.4 occurs when changing MODES, even w i t h the 7 day Frequency not met, provided operation does not exceed 12 hours (plus t h e extension allowed by SR 3.0.2) w i t h power 225% RTP.
(continued)
PERRY - UNIT 1

Frequency 1.4 1.4 Frequency EXAMPLES       EXAMPLE 1.4-3              (continued)
Once t h e u n i t reaches 25% RTP, 12 hours would be allowed for completing the Surveillance. I f the Surveillance were not performed w i t h i n t h i s 12 hour i n t e r v a l (plus the extension allowed by SR 3.0.2). there would then be a f a i l u r e t o perform a Survei 7 1ance w i t h i n the speci f ied Frequency, and t h e provisions o f SR 3.0.3 would apply.
EXAMPLE 1.4-4 SURVEILLANCE REQUIREMENTS SURVEILLANCE                          FREQUENCY Only required t o be met i n MODE 1.
V e r i f y leakage rates are w i t h i n l i m i t s . 24 hours Example 1.4-4 specifies t h a t t h e requirements o f t h i s Surveillance do not have t o be met u n t i l t h e u n i t i s i n MODE 1. The i n t e r v a l measurement f o r t h e Frequency o f t h i s Surveillance continues a t a l l times, as described i n Example 1.4-1. However, the Note constitutes an "otherwise stated" exception t o the A p p l i c a b i l i t y o f t h i s Surveillance.
g Therefore, i f the Surveillance were not erformed w i t h i n t h e 24 hour (plus the extension allowed by S 3.0.2) i n t e r v a l ,
but the u n i t was not i n MODE 1. there would be no f a i l u r e of t h e SR nor f a i l u r e t o meet the LCO. Therefore, no v i o l a t i o n o f SR 3.0.4 occurs when changing MODES, even w i t h t h e 8
24 hour Fre uency exceeded, provided t h e MODE change was not made i n t o M DE 1. P r i o r t o entering MODE 1 (assuming again t h a t the 24 hour Frequency were not met), SR 3.0.4 would r e u i r e s a t i s f y i n g t h e SR-, except as provided by SR 3.0.3 an LCO 3.0.4.
PERRY - UNIT 1                                1.0-28                       Amendment No.

ACTIONS                                                           --
CONDITION               REQUIRED ACTION                   COMPLETION TIME
                            ~~~
A.  (continued)              A.3  Perform SR 3.1.3.2              24 hours from f o r each withdrawn           discovery o f         t OPERABLE control rod.          Condition A concurrent w i t h THERMAL POWER greater than or equal t o the low power setpoint (LPSP) o f the Rod
                             -AND                                  Pattern Control System (RPCS).
A.4  Perform SR 3.1.1.1.
72 hours                ,
B. Two o r more withdrawn   B.1  Be i n MODE 3.                  12 hours               ,
control rods stuck.
C. One o r more control     c.1  - - - - - - - - NOTE---------
rods inoperable f o r         Inoperable control reasons other than            rods may be bypassed Condition A o r B.            i n RACS i n accordance w i t h SR 3.3.2.1.9, i f required, t o allow insertion o f inoperable control rod and continued opera t ion.
Fully insert                   3 hours inoperabl e control rod.
c.2  Disarm t h e associated        4 hours CRD .
(cont inued 1 PERRY - UNIT 1                    3.1-8                          Amendment No.        I

Control Rod OPERABILITY 3.1.3 Not required t o be performed u n t i l 31 days a f t e r the control rod i s withdrawn and THERMAL POWER i s greater than t h e LPSP o f t h e RPCS.
I n s e r t each withdrawn control rod a t l e a s t       31 days one notch.
SR 3.1.3.3    V e r i f y each control rod scram time from               I n accordance f u l l y withdrawn t o notch p o s i t i o n 13 i s       with I 7 seconds.                                               SR 3.1.4.1.
SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 (cont inued1 PERRY - UNIT 1                          3.1-10                          Amendment No.

Control Rod OPEM8ILITY 1 1 7 3.1.3 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                FREQUENCY SR 3.1.3.4     V e r i f y each control rod does not go t o the    Each time t h e withdrawn overtravel position.                      control rod i s withdrawn t o
                                                                    " f u l l out" position Prior t o declaring control rod OPERABLE after work on control rod o r CRD System t h a t could a f f e c t coup1 ing PERRY - UNIT 1                           3.1-11                  Amendment No.

Control Rod Scram Times 3.1.4 Table 3.1.4-1 Control Rod Scram Times
- - - - - - - - - - - - - - - - - - _ _ - - - - - - - - - - - - - - - - -N O T E S - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
: 1. OPERABLE control rods w i t h scram times not w i t h i n t h e l i m i t s o f t h i s Table a r e considered "slow."
Enter a p l i c a b l e Conditions and Required Actions o f LCO 3.1.3, "Control 2.
i Rod OPE ABILITY," f o r control rods w i t h scram times > 7 seconds t o notch p o s i t i o n 13, These control rods are inoperable, i n accordance w i t h SR 3.1.3.3, and are not considered "slow."
- - - - - - - - - - - - - - - - - - - - _ _ _ _ _ _ _ c _ _ _ _ _ _ _ _ _ _ _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
SCRAM TIMES(a) ( b )
(seconds 1 REACTOR                                                        REACTOR STEAM DOME PRESSURE(c)                                    STEAM DOME PRESSURE ( C )
NOTCH          POSITION                                   950 p s i g                                                  1050 p s i g
( a > Maximum scram time from f u l l y withdrawn p o s i t i o n , based on de-energization o f scram p i l o t valve solenoids as time zero.
(b)         Scram times as a function o f reactor steam dome pressure when < 950 p s i g are w i t h i n established l i m i t s .
(c)         For intermediate reactor steam dome pressures, the scram time c r i t e r i a are determined by l i n e a r i n t e r p o l a t i o n .}}