RNP-RA/17-0014, Resubmittal of Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles: Difference between revisions

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{{#Wiki_filter:Ernest J. Kapopoulos, Jr.
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( -, DUKE                                                                      H. B. Robinson Steam Electric Plant Unit 2 ENERGYe                                                                      Site Vice President Duke Energy 3581 West Entrance Road Hartsville, SC 29550 0 843 857 1701 F: 843 857 1319 Ernie.Kapopoulos@duke-energy.com Serial: RNP-RA/17-0014 APR 0 3 2017 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 H. 8. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 I RENEWED LICENSE NO. DPR-23 RESUBMITTAL OF REQUEST FOR TECHNICAL SPECIFICATION CHANGE TO CHANGE TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT FREQUENCIES TO SUPPORT 24-MONTH FUEL CYCLES
 
==REFERENCES:==
: 1. Generic Letter 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991 .
: 2. Regulatory Guide 1.52, "Design , Inspection and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants," Revision 2, dated March 1978.
 
==Dear Sir/Madam:==
 
In accordance with 10 CFR 50.90, Duke Energy Progress, LLC (DEP) hereby requests an amendment to the Technical Specifications (TS) for H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP) to support 24-month fuel cycle operations. Specifically, this change requests Nuclear Regulatory Commission (NRC) approval for certain HBRSEP TS Surveillance Requirement frequencies that are specified as "18 months" by revising them to "24 months" in accordance with the guidance of Reference 1. Also, consistent with this guidance, approval is requested for a change to Administrative Controls Section 5.5.11, "Ventilation Filter Testing Program," for changes to the 18-month frequencies that are specified by Reference 2.
The Enclosure provides HBRSEPs evaluation supporting the proposed changes. Attachment 1 provides the existing TS pages marked up to show the proposed changes. Attachment 2 provides revised (clean) TS pages that reflect the proposed change. Attachment 3 provides the marked-up TS Bases pages (for information only). Attachment 4 provides the reprinted TS Bases pages (for information only). Attachment 5 summarizes the formal licensee commitments pending NRC approval of the proposed amendment. Attachment 6 provides detailed GL 91-04 evaluation results. Attachment 7 provides the detailed drift evaluation methods utilized. provides an evaluation of non-calibration surveillance failures.
A previous request for Technical Specifications changes to support a 24 month fuel cycle was submitted by letter dated September 16, 2016, but was withdrawn by DEP letter dated
 
U. S. Nuclear Regulatory Commission Serial: RNP-RA/17-0014 Page 2of2 November 10, 2016. The concerns that led to the withdrawal are described in an NRC letter dated November 21, 2016. The current request addresses the concerns. The letter also requested the submittal of a representative instrument calculation; the calculation will be provided under a separate cover.
Regulatory evaluation (including the significant hazards consideration) and environmental considerations are provided in Sections 5 and 6 of Enclosure 1. Attachment 5 provides a list of regulatory commitments being made as a result of this License Amendment Request (LAR) .
I A copy of this LAR is being sent to the State of South Carolina in accordance with 10 CFR 50.91 requirements.
Please address any comments or questions regarding this matter to Mr. Tony Pilo, Manager -
Nuclear Regulatory Affairs at (843) 857-1409.
I declare under penalty of perjury that the foregoing is true and correct. Executed on fP ?> ftf\ell.- '2017.
Sincerely,
      ~
Ernest J. Kapopoulos, Jr.
Site Vice President EJK/jsk Enclosure
: 1. Evaluation of Proposed Changes Attachments:
: 1. Technical Specifications - Marked-up Pages
: 2. Technical Specifications - Reprinted Pages
: 3. Technical Specification Bases - Marked-up Pages
: 4. Technical Specification Bases - Reprinted Pages
: 5. Summary of Licensee Commitments
: 6. Review of Historical Surveillance Records for lnstumentation
: 7. Detailed Drift Evaluation Methods
: 8. Non-Calibration Surveillance Failure Analysis cc: Regional Administrator, NRC Region II Mr. Dennis J. Galvin NRC Project Manager, NRR NRC Resident Inspector, HBRSEP Ms. S. E. Jenkins, Manager, Infectious and Radioactive Waste Management Section (SC)
A. Gantt, Chief, Bureau of Radiological Health (SC)
Alan Wilson , Attorney General (SC)
 
U. S. Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/17-0014 29 Pages (including cover page)
EVALUATION OF PROPOSED CHANGES
 
==SUBJECT:==
REQUEST FOR TECHNICAL SPECIFICATION CHANGE TO CHANGE TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT FREQUENCIES TO SUPPORT 24-MONTH FUEL CYCLES
: 1.
 
==SUMMARY==
DESCRIPTION
: 2. BACKGROUND
: 3. DETAILED DESCRIPTION OF PROPOSED CHANGES
: 4. TECHNICAL EVALUATION
: 5. REGULATORY EVALUATION 5.1    Significant Hazards Consideration 5.2    Applicable Regulatory Requirements/Criteria 5.3    Precedent 5.4    Conclusion
: 6. ENVIRONMENTAL CONSIDERATION
: 7. REFERENCES
: 1.     
 
==SUMMARY==
DESCRIPTION In accordance with 10 CFR 50.90, Duke Energy Progress, LLC (DEP) proposes to amend the Technical Specifications (TS) to the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP)
Renewed Facility Operating License No. DPR-23 to extend certain 18-month TS Surveillance Requirement (SR) frequencies to 24 months to accommodate a 24-month fuel cycle in accordance with the guidance of Generic Letter (GL) 91-04 (Reference 1). Also, consistent with this guidance, a change is proposed to Administrative Controls Section 5.5.11, "Ventilation Filter Testing Program," to change the 18-month frequencies that are specified by Regulatory Guide 1.52 (Reference 2) to 24 months.
By letter to the NRC dated November 19, 2015, Duke Energy Progress, Inc. submitted a license amendment request to adopt Option B of 10 CFR 50 Appendix J. The amendment will:
* Increase in the existing integrated leak rate test (ILRT) program test interval from 10 to 15 years
* Adopt 10 CFR 50, Appendix J, Option B, as modified by approved exemptions, for the performance-based testing of Types B and C tested components in accordance with the guidance of Technical Specification Task Force (TSTF)-
52, Implement 10 CFR 50, Appendix J, Option B,
* Allow an extension to the 120-month frequency currently permitted by Option B for Type B leakage rate testing,
* Allow an extension from the 60-month frequency currently permitted by Option B to a 75-month frequency for Type C leakage rate testing.
The proposed change would also adopt a more conservative grace interval of 9 months, for Type B and Type C tests in accordance with Nuclear Energy Institute (NEI) Topical Report NEI 94-01 , revision 3-A. The amendment was approved by NRC letter dated October 11, 2016.
Therefore, this submittal does not include a request for exemption from 10 CFR 50, Appendix J as discussed in Attachment 3 of Generic Letter 91-04.
Steam Generator in-service inspections has been evaluated in regard to a 24-month fuel cycle.
Engineering Change 402781 determined the existing inspection interval is compatible with an extended fuel cycle; therefore, no changes or additional considerations are needed.
DEP requests approval of this amendment request by August 30, 2018 to allow sufficient time to complete changes necessary for implementation after the 31st refueling outage for HBRSEP.
Approval by this date will also support scheduling and planning for the refueling outage based on 24-month Surveillance Frequency requirements.
: 2.        BACKGROUND Improved reactor fuels have allowed licensees to increase the duration of the fuel cycle for their facilities. A number of SRs are performed during a refueling outage. The current HBRSEP Technical Specifications (TS) require these SRs to be performed on an 18-month frequency, consistent with the 18-month fuel cycle. To synchronize these requirements with a 24-month
 
fuel cycle, it is necessary to extend the existing 18-month surveillance frequencies to 24 months. This change will allow HBRSEP to take advantage of improved fuel designs which support a 24-month refueling interval.
The Nuclear Regulatory Commission (NRC) has provided generic guidance in GL 91-04 (Reference 1) for license amendment requests for individual plants to modify surveillance intervals to be compatible with a 24-month fuel cycle. GL 91-04 identifies the types of information that must be addressed when proposing extensions of TS SR frequency intervals from 18 months to 24 months. The proposed changes associated with this submittal were evaluated in accordance with that guidance. Section 4 of this Enclosure defines each step outlined by the NRC in Reference 1 and provides a description of the methodology used by HBRSEP to complete the evaluation for the extension of specific TS SR frequencies from 18 months to 24 months.
GL 91-04 also addresses steam generator inspections and interval extensions to the 24 month leak rate testing requirements of 10 CFR 50 Appendix J. As discussed above, HBRSEP has performed an Engineering Change that evaluated steam generator in-service inspections in regard to a 24 month fuel cycle. The evaluation determined that the existing inspection interval is compatible with an extended fuel cycle; therefore, no changes are needed.
Since GL 91-04 was issued, NRC has revised 10 CFR 50 Appendix J to allow licensees to adopt performance based testing requirements (Option B) that allow intervals to exceed the prescriptive 24 month testing requirements (Option A). HBRSEP has requested a change to adopt Option B for Local Leak Rate Test (LLRT) and has received approval of that change by NRC letter dated October 11, 2016. Therefore, HBRSEP does not need an exemption to the 24 month testing requirements of Appendix J Option A.
: 3.      DETAILED DESCRIPTION OF PROPOSED CHANGES To accommodate a 24-month fuel cycle, HBRSEP proposes to extend certain 18-month TS SR frequencies to 24 months. The proposed changes were evaluated in accordance with the guidance provided in GL 91-04 (Reference 1). The SR frequencies HBRSEP proposes to change to 24 months are for the SRs listed below:
TS 3.1.7      Rod Position Indication SR 3.1.7.1        Perform CHANNEL CALIBRATION of the APRI System This was previously SR 3.1.7.4; however it was revised during this project.
TS 3.3.1      RPS Instrumentation SR 3.3.1.10      Perform CHANNEL CALIBRATION Table 3.3.1-1 Items 7.a, 7.b, 8, 9.a, 9.b, 11, 12, 13, 15.a, 17.e SR 3.3.1.11      Perform CHANNEL CALIBRATION Table 3.3.1-1 Items 2.a, 2.b, 3, 4, 17.a, 17.c, 17.d SR 3.3.1.12      Perform CHANNEL CALIBRATION Table 3.3.1-1 Items 5, 6 SR 3.3.1.13      Perform COT Table 3.3.1-1 Items 17.a, 17.b, 17.c, 17.d, 17.e SR 3.3.1.14      Perform TADOT Table 3.3.1-1 Items 1, 10.a, 10.b, 12, 16, 17.b
 
TS 3.3.2  ESFAS Instrumentation SR 3.3.2.3      Perform MASTER RELAY TEST Table 3.3.2-1 Items 1.b, 2.b, 3.a.2, 3.b.2, 4.b, 5.a SR 3.3.2.5      Perform SLAVE RELAY TEST Table 3.3.2-1 Items 1.b, 2.b, 3.a.2, 3.b.2, 4.b, 5.a SR 3.3.2.6      Perform TADOT Table 3.3.2-1 Items 1.a, 2.a, 3.a.1, 3.b.1, 4.a SR 3.3.2.7      Perform CHANNEL CALIBRATION Table 3.3.2-1 Items 1.c, 1.d, 1.e, 1.f, 1.g, 2.c, 3.b.3, 4.c, 4.d, 4.e, 6.a, 6.b TS 3.3.3  PAM Instrumentation SR 3.3.3.2      Perform CHANNEL CALIBRATION Table 3.3.3-1 Items 1-8, 10-21 SR 3.3.3.3      Perform TADOT Table 3.3.3-1 Items 9, 22-24 TS 3.3.4  Remote Shutdown System SR 3.3.4.2      Verify each required control circuit and transfer switch is capable of performing the intended function Table B 3.3.4-1 Items 1.c, 2.b, 3.c, 4.b, 5.a and 5.b SR 3.3.4.3      Perform CHANNEL CALIBRATION for each required instrumentation channel Table B 3.3.4-1 Items 1.a, 2.a, 3.a, 3.b, 3.d, 3.e, 3.f, 4.a, 4.c SR 3.3.4.4      Perform TADOT of the reactor trip breaker open/closed indication Table B 3.3.4-1 Items 1.b, 1.c TS 3.3.5  LOP DG Start Instrumentation SR 3.3.5.1      Perform TADOT SR 3.3.5.2      Perform CHANNEL Calibration with Trip Setpoints as follows:
: a.      Loss of voltage Trip Setpoint of 328 V +/- 10% with a time delay of 1 second (at zero voltage)
: b.      Degraded voltage Trip Setpoint of 430 V +/- 4V with a time delay of 10 +/- 0.5 seconds TS 3.3.6  Containment Ventilation Isolation Instrumentation SR 3.3.6.3      Perform MASTER RELAY TEST Table 3.3.6-1 Item 2 SR 3.3.6.5      Perform SLAVE RELAY TEST Table 3.3.6-1 Item 2 SR 3.3.6.6      Perform TADOT Table 3.3.6-1 Item 1 SR 3.3.6.7      Perform CHANNEL CALIBRATION Table 3.3.6-1 Items 3.a and 3.b TS 3.3.7  CREFS Actuation Instrumentation SR 3.3.7.4      Perform MASTER RELAY CHECK Table 3.3.7-1 Item 1 SR 3.3.7.5      Perform SLAVE RELAY TEST Table 3.3.7-1 Item 1 TS 3.3.8  Auxiliary Feedwater (AFW) System Instrumentation SR 3.3.8.3      Perform TADOT Table 3.3.8-1 Items 3, 4, 5 SR 3.3.8.4      Perform CHANNEL CALIBRATION Table 3.3.8-1 Items 1, 3, 4
 
TS 3.4.1  RCS Pressure, Temperature and Flow DNB Limits SR 3.4.1.4    Verify by precision heat balance that RCS total flow rate is  97.3 x 106 lbm/hr TS 3.4.9  Pressurizer SR 3.4.9.2    Verify capacity of required pressurizer heaters is  125KW SR 3.4.9.3    Verify required pressurizer heaters are capable of being powered from an emergency supply TS 3.4.11 Pressurizer PORV SR 3.4.11.2    Perform a complete cycle of each PORV SR 3.4.11.3    Perform a complete cycle of each solenoid air control valve and check valve on the nitrogen accumulators in PORV control system SR 3.4.11.4    Verify accumulators are capable of operating PORVs through a complete cycle TS 3.4.12 LTOP System SR 3.4.12.7    Perform CHANNEL CALIBRATION for each required PORV actuation channel TS 3.4.14 RCS PIVs SR 3.4.14.1    Verify leakage from each RCS PIV is less than or equal to an equivalent of 5 gpm at an RCS pressure  2235 psig, and verify the margin between the results of the previous leak rate test and the 5 gpm limit has not been reduced by  50% for valves with leakage rate > 1.0 gpm SR 3.4.14.2    Verify RHR System interlock prevents the valves from being opened with a simulated or actual RCS pressure signal > 474 psig TS 3.4.15 RCS Leakage Detection Instrumentation SR 3.4.15.3    Perform CHANNEL CALIBRATION of the required containment sump monitor SR 3.4.15.4    Perform CHANNEL CALIBRATION of the required containment atmosphere radioactivity monitor SR 3.4.15.5    Perform CHANNEL CALIBRATION of the required containment fan cooler condensate flow rate monitor TS 3.4.17 CVCS SR 3.4.17.2    Verify seal injection flow of  6 gpm to each RCP from each Makeup Water Pathway from the RWST TS 3.5.2  ECCS - Operating SR 3.5.2.4    Verify each ECCS automatic valve in the flow path that is locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal SR 3.5.2.5    Verify each ECCS pump starts automatically on an actual or simulated actuation signal SR 3.5.2.6    Verify, by visual inspection, the ECCS train containment sump suction inlet is not restricted by debris and the suction inlet trash strainers show no evidence of structural distress or abnormal corrosion TS 3.6.3  Containment Isolation Valves SR 3.6.3.2    Verify each containment isolation valve and blind flange that is located outside containment and not locked, sealed or otherwise secured and required to be closed during accident conditions SR 3.6.3.5    Verify each automatic containment isolation valve that is not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal SR 3.6.3.6    Verify each 42 inch inboard containment purge valve is blocked to restrict the valve from opening > 70 degrees
 
TS 3.6.6  Containment Spray and Cooling Systems SR 3.6.6.5      Verify each automatic containment spray valve in the flow path that is locked, sealed or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal SR 3.6.6.6      Verify each containment spray pump starts automatically on an actual or simulated actuation signal SR 3.6.6.7      Verify each containment cooling train starts automatically on an actual or simulated actuation signal TS 3.6.7  Spray Additive System SR 3.6.7.4      Verify each spray additive automatic valve in the flow path that is not locked, sealed or otherwise secured in position, actuates to the correct position on an actual or simulated signal TS 3.6.8  Isolation Valve Seal Water System SR 3.6.8.4      Verify each automatic valve in the IVSW System actuates to the correct position on an actual or simulated actuation signal SR 3.6.8.5      Verify the IVSW dedicated nitrogen bottles will pressurize the IVSW tank to  46.2 psig SR 3.6.8.6      Verify total IVSW seal header flow rate is  124 cc/minute TS 3.7.4  AFW System SR 3.7.4.3      Verify each AFW automatic valve that is not locked, sealed or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal SR 3.7.4.4      Verify each AFW pump starts automatically on an actual or simulated actuation signal SR 3.7.4.6      Verify the AFW automatic bus transfer switch associated with discharge valve V2-16A operates automatically on an actual or simulated actuation signal TS 3.7.6  CCW System SR 3.7.6.2      Verify each required CCW pump starts automatically on an actual or simulated LOP DG Start undervoltage signal TS 3.7.7  SWS SR 3.7.7.2      Verify each SWS automatic valve in the flow path that is not locked, sealed or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal SR 3.7.7.3      Verify each SWS pump and SWS booster pump starts automatically on an actual or simulated actuation signal SR 3.7.7.4      Verify the SWS automatic bus transfer switch associated with the Turbine Building loop isolation valve V6-16C operates automatically on an actual or simulated actuation signal TS 3.7.9  CREFS SR 3.7.9.3      Verify each CREFS train actuates on an actual or simulated actuation signal TS 3.7.10 CREATC SR 3.7.10.1    Verify each CREATC WCCU train has the capability to remove the assumed heat load TS 3.7.11 SR 3.7.11.3    Verify the FBACS can maintain a negative pressure with respect to atmospheric pressure
 
TS 3.8.1  AC Sources - Operating SR 3.8.1.10    Verify on an actual or simulated ESF actuation signal each DG auto-starts from standby condition SR 3.8.1.12    Verify each DG operating at a power factor  0.9 operates for  24 hours SR 3.8.1.13    Verify each DG starts and achieves, in  10 seconds, voltage  467 V, and frequency  58.8 Hz, and after steady state conditions are reached, maintains voltage  467 V and  493 V and frequency  58.8 Hz and 61.2 Hz SR 3.8.1.14    Verify actuation of each sequenced load block is within +/- 0.5 seconds of design setpoint for each emergency load sequencer SR 3.8.1.15    Verify on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ESF actuation signal: De-energizing of the emergency buses; load shedding from the emergency buses; and DG auto-starts from standby condition SR 3.8.1.16    Verify automatic transfer capability of the 4.16kV bus 2 and the 480V Emergency bus 1 loads from the Unit auxiliary transformer to the start up transformer SR 3.8.1.8      Verify each DG rejects a load greater than or equal to its associated single largest post-accident load and does not trip on overspeed SR 3.8.1.9      Verify on an actual or simulated loss of offsite power signal: De-energizing of the emergency buses; load shedding from the emergency buses; and DG auto-starts from standby condition TS 3.8.4  DC Sources - Operating SR 3.8.4.2      Verify battery cells, cell plates, and racks show no visual indication of physical damage or abnormal deterioration that could degrade battery performance SR 3.8.4.3      Remove visible terminal corrosion, verify battery cell to cell and terminal connections are clean and tight, and are coated with anti-corrosion material SR 3.8.4.4      Verify each battery charger supplies  300 amps at  125 V for  4 hours SR 3.8.4.5      Verify battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test TS 3.8.9  Distribution Systems - Operating SR 3.8.9.2      Verify capability of the two molded case circuit breakers for AFW Header Discharge Valve to S/G A, V2-16A to trip on overcurrent SR 3.8.9.3      Verify capability of the two molded case circuit breakers for Service Water System Turbine Building Supply Valve (emergency supply), V6-16C to trip on overcurrent TS 3.9.2  Nuclear Instrumentation SR 3.9.2.2      Perform CHANNEL CALIBRATION TS 3.9.3  Containment Penetrations SR 3.9.3.2      Verify each required containment ventilation valve actuates to the isolation position on an actual or simulated signal TS 5.5.11 Ventilation Filter Testing Program SR 5.5.11      Ventilation Filter Testing Program (VFTP) - This program provides controls for implementation of the following required testing of Engineered Safety Feature (ESF) ventilation filter systems at the frequencies specified in Positions C.5 and C.6 of Regulatory Guide 1.52, Revision 2, March 1978, and conducted in general conformance with ANSI N510-1975 or N510-1980
 
TS 5.5.17 Control Room Envelope Habitability Program 5.5.17(d)  Measurement, at designated locations, of the CRE pressure relative to external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREFS, operating at the flow rate required by the VFTP, at a frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the assessment of the CRE boundary.
: 4. TECHNICAL EVALUATION To accommodate a 24-month fuel cycle, HBRSEP proposes to extend certain 18-month TS SR frequencies to 24 months. The proposed TS changes were evaluated in accordance with the guidance provided in GL 91-04 (Reference 1). The proposed TS changes, based on Reference 1, have been divided into two categories. The categories are: (1) changes to surveillance frequencies other than channel calibrations, identified as "Non-Calibration Changes"; and (2) changes involving the channel calibration frequency identified as "Channel Calibration Changes."
4.1    Non-Calibration Changes Reference 1 identifies guidance to evaluate non-calibration changes:
Licensees should evaluate the effect on safety of the change in surveillance intervals to accommodate a 24-month fuel cycle. This evaluation should support a conclusion that the effect on safety is small. Licensees should confirm that historical maintenance and surveillance data support the conclusion.
Evaluation HBRSEP Engineering performed a study to determine if the non-calibration-related historical surveillance performances ensure that the availability and reliability of systems, components, and functions will not be significantly reduced by repetitive or time based failures and that the effect on safety is small. To confirm this conclusion, the study demonstrated that the surveillance test history does not indicate a history of repetitive failures which would go undetected if the current surveillance interval were extended to the proposed surveillance interval. The purpose of surveillance testing is to verify that the tested TS function/feature will perform as assumed in the associated safety analysis. By periodically testing the TS function/feature, the availability of the associated function/feature is confirmed.
HBRSEP Engineering performed an engineering analysis of the historical maintenance records for outage-based Surveillance and non-surveillance Preventative Maintenance (PM) tasks to ascertain if any failure history of any components would preclude lengthening the surveillance frequency for these components to 24 months (maximum 30 months with the allowance of TS SR 3.0.2) vice 18 months. The analysis reviewed five performances of each components surveillance test history. The surveillance test history study is a qualitative review of the surveillance test performances to ensure there is no evidence of any repetitive failures associated with the surveillance requirement which would invalidate the conclusion that the impact on system availability, if any, will be small as a result of the change to a 24-month surveillance interval. The five performances ensure that approximately three 30-month surveillance periods are reviewed to identify any repetitive problems. It has been concluded, based on engineering judgment, that three 30 month periods provide adequate surveillance test history. The aforementioned amount of historical data has been proven to be acceptable by the United States Nuclear Regulatory Commission (USNRC) in previous nuclear plant (i.e., Perry Nuclear Plant, Hatch Nuclear Plant, DC Cook Nuclear Plant and Oconee Nuclear Station) license submittals for surveillance interval extensions.
 
HBRSEP engineers validated for all of the surveillances that there was no evidence of repetitive failures or failures caused by a time-based failure mechanism which would invalidate the conclusion that the impact, if any, on system availability will be small as a result of changing to a 24 month performance interval. An analysis of non-calibration surveillance failures is presented in Attachment 8.
Licensees should confirm that the performance of surveillances at the bounding surveillance interval limit provided to accommodate a 24-month fuel cycle would not invalidate any assumption in the plant licensing basis.
Evaluation:
In order to support the response to this item a search of the UFSAR and docket was performed using the search parameter 18 month. There were a total of 561 instances found in the docket and 6 instances found in the UFSAR. In the majority of cases it was apparent that the instance was a discussion of an 18 month surveillance without any qualifying information. These surveillances will be changed to 24 months with NRC approval. Other cases discussed items such as the Systematic Assessment of Licensee Performance evaluations on an 18 month frequency, data gathered for the previous 18 months, etc. and were judged not to be relevant to this engineering change.
The search did identify three commitments discussed below.
Letter NLS-90-110 describes how Carolina Power & Light (CP&L) will take an exception, to Section 5.2(3) of IEEE 450-1980 which required an annual performance testing of batteries showing signs of degradation. Instead HBRSEP2 invokes Regulatory Guide 1.32, Revision 2, February 1977, "Criteria for Safety Related Electric Power Systems for Nuclear Power Plants," which recommends that: "The battery service test should be performed during refueling operations or at some other outage, with intervals between tests not to exceed 18 months." However, our commitment to RG 1.32 does not appear in UFSAR section 1.8. NRC approval of this LAR will supersede this commitment.
The Bases for Surveillance Requirement 3.7.9.3 states: This SR verifies that each CREFS train starts and operates on an actual or simulated actuation signal. The Frequency of 18 months is consistent with Position C.5 of Regulatory Guide 1.52 (Ref.
4). The 18 month Frequency is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month frequency. RG 1.52, position 5.c states, in part: The in-place DOP test for HEPA filters should conform to Section 10 of ANSI N510-1975 (Ref. 2). HEPA filter sections should be tested in place (1) initially, (2) at least once per 18 months thereafter, and. . . Note, there is no mention of The 18 month frequency is based on the refueling cycle. Our conformance to the RG is documented in UFSAR section 1.8, Conformance to NRC Regulatory Guides. Upon NRC approval of the LAR, the commitment in the UFSAR will be modified.
Surveillance Requirement 3.8.1.8 demonstrates the capability for the diesel generators to reject the largest single load without exceeding the overspeed trip. The Bases for SR 3.8.1.8 states, in part: The 18 month frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 8). However, RG 1.108 has been withdrawn by the NRC. The Federal Register notice of the withdrawal states, in part: The guidance in Regulatory Guide 1.108 has been updated and incorporated into Revision 3 of
 
Regulatory Guide 1.9, Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as Class IE Onsite Electric Power Systems at Nuclear Power Plants, which was issued recently. Since there is no longer a need for Regulatory Guide 1.108, it has been withdrawn. However, the withdrawal of Regulatory Guide 1.108 does not alter any prior or existing licensing commitments based on its use. RG 1.9, Rev. 4, Position C.2 contains a requirement to perform a largest load rejection test, but it specifies a frequency of shutdown/refueling. An appropriate Basis change is provided in this letter.
The core design for the 24-month fuel cycle may result in the removal of Part Length Shield Assemblies (PLSAs) from the reactor core. PLSAs have been used and credited for reduction of fluence at critical reactor vessel weld locations. As discussed in a letter to the NRC dated July 28, 1988, the need for continued use of the PLSAs will be periodically evaluated. Although design work is not complete at this time, it is currently intended that the PLSAs will be removed under the provision to 10 CFR 50.59 for Cycle 32 operation.
There will be no effect of the removal of the PLSAs on the Excore Power Range Nuclear Instrumentation due to the physical location of the detectors relative to the locations of the PLSAs. The Source Range and Intermediate Range Nuclear Instrumentation are located outside of the reactor vessel in an orientation such that they will be affected. The Source Range detectors will see an increase in neutron count rate. Site procedures will be used to adjust setpoints that will be affected by the change in leakage (e.g. High Flux At Shutdown). The Intermediate Range detectors will also see an increase in leakage due to the removal of the PLSA. These are monitored and adjusted using plant procedures during a startup from an outage to maintain the High Flux Trip setpoint in accordance with Technical Specification Surveillance Requirement 3.3.1.11.
This LAR will not invalidate any assumption in the licensing basis.
 
4.2    Channel Calibration Changes Reference 1 identifies seven steps to evaluate channel calibration changes.
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.
Evaluation to Step 1:
This question includes two phrases that are not defined in the GL 91-04. To determine if except on rare occasions equipment has exceeded acceptable limits, those two terms are defined as follows:
Exceeded Acceptable Limits Uncertainty/Setpoint calculations are intended to ensure the analytical limits are not exceeded.
Typically, as-found values are determined in those calculations for each component of an instrument loop. Finding equipment within those as-found values ensure the Total Loop Uncertainty is not exceeded and therefore, the analytical limit was not challenged. Therefore, equipment associated with uncertainty/setpoint calculations will use the calculated as-found tolerances as the acceptable limits for this evaluation.
Additionally, as-found values, which are found to be out-of-tolerance in a conservative direction with respect to Allowable Values, will not be considered to exceed acceptable limits.
Therefore, the functions which have a trip setpoint and Allowable Value, as described in Technical Specification Bases B.3.3.1, will be considered to exceed acceptable limits if it was found outside of the calculated as-found tolerance of the applicable uncertainty calculation in the direction of the Allowable Value.
The Technical Specification functions which have no setpoint or Allowable Value, such as post-accident monitoring (PAM), typically provide the operator with indication to perform manual action specified in the unit Emergency Operating Procedures (ref. TS Bases, page B 3.3-93).
These functions typically have action setpoints associated with them. These action setpoints are determined using the calculated uncertainty values. If components are outside of the calculated uncertainty values, it could have an adverse effect on operator actions. Again, finding components within the calculated as-found tolerances ensures the Total Loop Uncertainty and Total Device Uncertainty have not been exceeded. Therefore, components which have an associated uncertainty calculation will use the calculated as-found values as the acceptable limits.
Functions which have no associated uncertainty calculation will use the calibration tolerance as the acceptable limits or another definition may be specified within the evaluations included in  of this LAR.
 
Except on Rare Occasions As stated in Attachment 6, approximately ten years of surveillance data was reviewed.
Generally, instrumentation that is repeatedly found to exceed its as-found tolerances will require corrective actions. These corrective actions could be to replace the equipment, perform a modification, setpoint change or other actions. Therefore, it is not expected that instrumentation will be continually found to exceed acceptable limits. If instruments were found to exceed acceptable limits on two consecutive occurrences it is indicative of more than rare occasion.
Additionally, instruments that were found to exceed their allowable value on two or more occasions over the review period required additional inspection to determine if the problem was corrected. If the problem was corrected and acceptable limits were no long exceeded, the issue was no longer considered to be a factor in the determination to extend the calibration interval. If the problem was not corrected it was considered to exceed rare occasion. provides the details of how the historical records were reviewed to complete this item. The summary conclusion of that evaluation is that components are typically found within their acceptable limits and only on rare occasions are they exceeded. One exception was concerning the pressure switches associated with Technical Specification 3.3.1, Table 3.3.1-1, Function 15.a, Turbine Trip, Low Auto Stop Oil Pressure. The pressure switches 63/AST-1, 63/AST-2, and 63/AST-3 were found to exceed acceptable limits on more than rare occasions.
As a result, these relays will be replaced before increasing the surveillance interval of SR 3.3.1.10 to accommodate a 24-month fuel cycle. (see Commitments in Attachment 5).
Additionally, Control Room Radiation Monitor R-1 has recently been replaced with a different model. No historical calibration data exist; therefore, it cannot be recommended for extension of the surveillance frequency. This engineering change recommends SR 3.3.7.6 remain at a 18-month frequency. SR 3.3.7.6 has been omitted from the list of affected SR in Section B.5.1 above.
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 assumptions used to determine the rate of instrument drift with time based upon historical plant calibration data.
Evaluation to Step 2:
An Engineering Change was developed specifically to establish the methodology used to collect instrument drift data, scrub the data, test the data for statistical relevance, and perform the mean drift extension. The methodology is based on EPRI TR-103335, which has been accepted by the NRC as an acceptable approach.
As part of this project, instruments that are calibrated every 18 months, but are also subject to a SR Channel Operability Test (COT) and SR Channel Check were not included in the drift analysis. For components which were evaluated for drift, it has been determined 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 and range) and application that performs a safety function.
 
The COT and Channel Check will not change with this project, and will continue to ensure that instruments are capable of performing their intended functions within acceptable limits.
COTs are typically performed quarterly (92 days). The COT does not include transmitters (sensors). The typical COT disconnects the transmitter from the rest of the instrument loop and injects a simulated signal in the instrument loop. Therefore, the transmitters are only calibrated during the 18-month surveillances. COTs are used to ensure operability of safety-related equipment; therefore, it does not verify functionality of components in the instrument loop which do not perform those functions. Specifically, the COT does not typically include verification of indicators, computer inputs, or components used for control, even if they are in the loop the COTs are being performed.
Channel Checks are typically performed on a much more frequent interval than even the COT.
The Channel Checks compare redundant indications to look for variances between channels indicative of drift.
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 and range) and application that performs a safety function.
Provide a list of the channels by TS sections that identifies these instrument applications.
Evaluation to Step 3:
An evaluation has been performed to determine the magnitude of instrument drift has for a bounding calibration interval of 30 months for each instrument type (make, model and range) and application that performs a safety function. The evaluation justifies taking exception for certain instruments based on factors including: channel operability tests performed more frequent, construction of component, history of little to no drift. For components which were evaluated for drift, it has been determined 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 and range) and application that performs a safety function.
The following list, by applicable Technical Specification, identifies the instrument loops that drift analysis has been performed. Not all components in an instrument loop were studied; therefore, this list includes the applicable components.
TS 3.3.1      Function 7 RPS Instrumentation - Pressurizer Pressure Pressurizer Pressure - PT-455 Pressurizer Pressure - PT-456 Pressurizer Pressure - PT-457 TS 3.3.1      Function 8 RPS Instrumentation - High Pressurizer Level Pressurizer Level - LT-459 Pressurizer Level - LT-460 Pressurizer Level - LT-461 TS 3.3.1      Function 9 RPS Instrumentation - Low Reactor Coolant Flow RCS Flow Transmitter - FT-414 RCS Flow Transmitter - FT-415 RCS Flow Transmitter - FT-416
 
RCS Flow Transmitter - FT-424 RCS Flow Transmitter - FT-425 RCS Flow Transmitter - FT-426 RCS Flow Transmitter - FT-434 RCS Flow Transmitter - FT-435 RCS Flow Transmitter - FT-436 TS 3.3.1 Function 11 RPS Instrumentation - RCP Undervoltage 4KV Bus 1 Undervoltage - 272/1(4KV) 4KV Bus 2 Undervoltage - 272/2(4KV) 4KV Bus 4 Undervoltage - 272/4(4KV)
TS 3.3.1 Function 12 RPS Instrumentation - RCP Underfrequency 4KV Bus 1 Underfrequency - 811/1 4KV Bus 2 Underfrequency - 811/2 4KV Bus 4 Underfrequency - 811/4 TS 3.3.1 Function 13 RPS Instrumentation - SG Low-Low Level Steam Generator A Level - LT-474 Steam Generator A Level - LT-475 Steam Generator A Level - LT-476 Steam Generator B Level - LT-484 Steam Generator B Level - LT-485 Steam Generator B Level - LT-486 Steam Generator C Level - LT-494 Steam Generator C Level - LT-495 Steam Generator C Level - LT-496 TS 3.3.1 Function 17.e RPS Instrumentation - Turbine Impulse Pressure (P-7)
Turbine First Stage Pressure - PT-446 Turbine First Stage Pressure - PT-447 TS 3.3.2 Function 1.c ESFAS Instrumentation - SI, High Containment Pressure Containment Pressure - PT-951 Containment Pressure - PT-953 Containment Pressure - PT-955 TS 3.3.2 Function 1.d ESFAS Instrumentation - SI - Low Pressurizer Pressure Pressurizer Pressure - PT-455 Pressurizer Pressure - PT-456 Pressurizer Pressure - PT-457 TS 3.3.2 Function 1.e ESFAS Instrumentation - Safety Injection, High Steam Line Differential Pressure between Steam Header and Steam Lines Main Steam Pressure, Steam Generator A - PT-474, PT-475, PT-476 Main Steam Pressure, Steam Generator B - PT-484, PT-485, PT-486 Main Steam Pressure, Steam Generator C - PT-494, PT-495, PT-496 Main Steam Header Pressure - PT-464 Main Steam Header Pressure - PT-466 Main Steam Header Pressure - PT-468 TS 3.3.2 Function 1.f ESFAS Instrumentation - Safety Injection, High Steam Flow Coincident with Low Tavg Turbine First Stage Pressure - PT-446 Turbine First Stage Pressure - PT-447 Main Steam, Steam Generator A Steam Flow - FT-474 Main Steam, Steam Generator A Steam Flow - FT-475 Main Steam, Steam Generator B Steam Flow - FT-484 Main Steam, Steam Generator B Steam Flow - FT-485
 
Main Steam, Steam Generator C Steam Flow - FT-494 Main Steam, Steam Generator C Steam Flow - FT-495 TS 3.3.2 Function 1.g ESFAS Instrumentation - Safety Injection, High Steam Flow Coincident with Low Steam Line Pressure Turbine First Stage Pressure - PT-446 Turbine First Stage Pressure - PT-447 Main Steam, Steam Generator A Steam Flow - FT-474 Main Steam, Steam Generator A Steam Flow - FT-475 Main Steam, Steam Generator B Steam Flow - FT-484 Main Steam, Steam Generator B Steam Flow - FT-485 Main Steam, Steam Generator C Steam Flow - FT-494 Main Steam, Steam Generator C Steam Flow - FT-495 Main Steam Pressure, Steam Generator A - PT-474 Main Steam Pressure, Steam Generator B - PT-485 Main Steam Pressure, Steam Generator C - PT-496 TS 3.3.2 Function 2.c ESFAS Instrumentation - CV Spray, High-High Containment Pressure Containment Pressure - PT-950 Containment Pressure - PT-951 Containment Pressure - PT-952 Containment Pressure - PT-953 Containment Pressure - PT-954 Containment Pressure - PT-955 TS 3.3.2 Function 3.b(3) ESFAS Instrumentation - Containment Isolation, Phase B, Safety Injection Containment Pressure - PT-950 Containment Pressure - PT-951 Containment Pressure - PT-952 Containment Pressure - PT-953 Containment Pressure - PT-954 Containment Pressure - PT-955 TS 3.3.2 Function 4.c ESFAS Instrumentation - Steam Line Isolation, High-High Containment Pressure Containment Pressure - PT-950 Containment Pressure - PT-951 Containment Pressure - PT-952 Containment Pressure - PT-953 Containment Pressure - PT-954 Containment Pressure - PT-955 TS 3.3.2 Function 4.d ESFAS Instrumentation - Steam Line Isolation, High Steam Flow Coincident with Low Tavg Turbine First Stage Pressure - PT-446 Turbine First Stage Pressure - PT-447 Main Steam, Steam Generator A Steam Flow - FT-474 Main Steam, Steam Generator A Steam Flow - FT-475 Main Steam, Steam Generator B Steam Flow - FT-484 Main Steam, Steam Generator B Steam Flow - FT-485 Main Steam, Steam Generator C Steam Flow - FT-494 Main Steam, Steam Generator C Steam Flow - FT-495
 
TS 3.3.2 Function 4.e ESFAS Instrumentation - Steam Line Isolation, High Steam Flow Coincident with Steam Line Low Pressure Main Steam Pressure, Steam Generator A - PT-474 Main Steam Pressure, Steam Generator B - PT-485 Main Steam Pressure, Steam Generator C - PT-496 Turbine First Stage Pressure - PT-446 Turbine First Stage Pressure - PT-447 Main Steam, Steam Generator A Steam Flow - FT-474 Main Steam, Steam Generator A Steam Flow - FT-475 Main Steam, Steam Generator B Steam Flow - FT-484 Main Steam, Steam Generator B Steam Flow - FT-485 Main Steam, Steam Generator C Steam Flow - FT-494 Main Steam, Steam Generator C Steam Flow - FT-495 TS 3.3.2 Function 5.b ESFAS Instrumentation - Feedwater Isolation, Safety Injection Turbine First Stage Pressure - PT-446 Turbine First Stage Pressure - PT-447 TS 3.3.2 Function 5.b ESFAS instrumentation - Feedwater Isolation, Safety Injection Containment Pressure - PT-950 Containment Pressure - PT-951 Containment Pressure - PT-952 Containment Pressure - PT-953 Containment Pressure - PT-954 Containment Pressure - PT-955 TS 3.3.2 Function 6.a ESFAS Instrumentation - Interlocks, Low Pressurizer Pressure Pressurizer Pressure - PT-455 Pressurizer Pressure - PT-456 Pressurizer Pressure - PT-457 TS 3.3.3 Function 5 PAM Instrumentation - RCS Wide Range Pressure RCS Pressure - PT-501 TS 3.3.3 Function 20 Steam Generator Pressure Main Steam Pressure, Steam Generator A - PT-474, PT-475, PT-476 Main Steam Pressure, Steam Generator B - PT-484, PT-485, PT-486 Main Steam Pressure, Steam Generator C - PT-494, PT-495, PT-496 TS 3.3.5 Loss of Power, Diesel Generator Start Instrumentation Emergency Bus E1, Phase A Degraded Grid - 27/DVA-1 Emergency Bus E1, Phase B Degraded Grid - 27/DVB-1 Emergency Bus E1, Phase C Degraded Grid - 27/DVC-1 Emergency Bus E2, Phase A Degraded Grid - 27/DVA-2 Emergency Bus E2, Phase B Degraded Grid - 27/DVB-2 Emergency Bus E2, Phase C Degraded Grid - 27/DVC-2 TS 3.3.5 Loss of Power, Diesel Generator Start Instrumentation Emergency Bus E1, Loss of Voltage - 271/E1(480V)
Emergency Bus E1, Loss of Voltage - 272/E1(480V)
Emergency Bus E2, Loss of Voltage - 271/E2(480V)
Emergency Bus E2, Loss of Voltage - 272/E2(480V)
 
TS 3.3.6  Function 4 Containment Ventilation Isolation Instrumentation Turbine First Stage Pressure - PT-446 Turbine First Stage Pressure - PT-447 Containment Pressure - PT-950 Containment Pressure - PT-951 Containment Pressure - PT-952 Containment Pressure - PT-953 Containment Pressure - PT-954 Containment Pressure - PT-955 TS 3.3.7 Function 3, CREFS Actuation Instrumentation - Safety Injection Turbine First Stage Pressure - PT-446 Turbine First Stage Pressure - PT-447 Containment Pressure - PT-950 Containment Pressure - PT-951 Containment Pressure - PT-952 Containment Pressure - PT-953 Containment Pressure - PT-954 Containment Pressure - PT-955 TS 3.3.8 Function 2 AFW System Instrumentation - Safety injection Turbine First Stage Pressure - PT-446 Turbine First Stage Pressure - PT-447 Containment Pressure - PT-950 Containment Pressure - PT-951 Containment Pressure - PT-952 Containment Pressure - PT-953 Containment Pressure - PT-954 Containment Pressure - PT-955 TS 3.3.8 Function 3 Auxiliary Feedwater System Instrumentation - Loss of Offsite Power Emergency Bus E1, Loss of Voltage - 271/E1(480V)
Emergency Bus E1, Loss of Voltage - 272/E1(480V)
Emergency Bus E2, Loss of Voltage - 271/E2(480V)
Emergency Bus E2, Loss of Voltage - 272/E2(480V)
TS 3.3.8 Function 4 Auxiliary Feedwater System Instrumentation - RCP Undervoltage 4KV Bus 1 Undervoltage - 271/1(4KV) 4KV Bus 1 Undervoltage - 272/1(4KV) 4KV Bus 4 Undervoltage - 271/4(4KV) 4KV Bus 4 Undervoltage - 272/4(4KV)
TS 3.4.12 PORV Actuation Pressurizer Overpressure - PT-500 Pressurizer Overpressure - PT-501 TS 3.4.14 RCS Pressure Isolation Valves - Verify RHR Interlock RHR-750 Hi Pressure Interlock - PT-403, PC-403
 
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 a 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.
Evaluation to Step 4:
The projected drift values determined by the calculations have been compared to the values used in the corresponding uncertainty/setpoint calculations. The uncertainty/setpoint calculations have been updated to address the comparisons. In no case was revision of a TS Setpoint or Allowable Value required. Also, no safety analysis was required to be revised.
HBRSEP instituted several standards by which the uncertainty/setpoint calculations would be revised:
* Instrumentation calibrated on a more frequent surveillance interval than outage based was exempt from estimating the changes to drift.
* Where margin is required in the calculation, the projected drift values can be used in place of Calibration Tolerance (CAL), Measurement and Test Equipment (M&TE) and drift (DR) to obtain the Total Loop Uncertainty (TLU).
* As-found calibration tolerances would not be revised unless the existing tolerances were no longer conservative with respect to the Allowable Value.
Step 5:
Confirm that the projected instrument errors caused by drift are acceptable for control of plant parameters to affect a safe shutdown with the associated instrumentation.
Evaluation to Step 5:
The projected instrument errors caused by drift are acceptable for control of plant parameters to affect a safe shutdown with the associated instrumentation.
The following functions associated with TS 3.3.4 were considered for drift:
1.a    Source Range Neutron Flux, N-51 or N-52 2.a    Pressurizer Pressure, Loop, PI-607E-1 or PI-607E-2 3.a    RCS Hot Leg Temperature Wide Range Loop A, TI-413A or TI-413B 3.b    RCS Cold Leg Temperature Wide Range Loop A, TI-410A or TI-410B 3.d    SG Pressure, PIC-477 and PIC-487 and PIC-497 3.e    SG Level (Wide Range), (LI-607A-1 or LI-607A-2) and (LI-607B-1 or LI-607B-2) and (LI-607C-1 or LI-607C-2) 3.f    Condensate Storage Tank Level, LI-1454C 4.a    Pressurizer Level, LI-607D-1 or LI-607D-2 4.c    Refuel Water Storage Tank Level, LIC-947 A separate drift analysis is not performed for the Remote Shutdown instruments based upon the design of the Remote Shutdown instruments and equipment history.
 
Not all functions listed above have uncertainty calculation associated with them. Following is a list of calculations that are associated with these functions. These calculations were updated to address extended drift:
* Function 3.a - RNP-I/INST-1064 RCS Hot Leg Temperature Instrumentation Uncertainty and Scaling Calculation
* Function 3.b - RNP-I/INST-1063 RCS Cold Leg Temperature Instrumentation Uncertainty and Scaling Calculation Calculations RNP-I/INST-1015 Condensate Storage Tank Level Uncertainty and RNP-I/INST-1023 Refueling Water Storage Tank Uncertainty and Scaling Calculation are associated with functions 3.f and 4.c respectively. These two calculations are not being updated. All components associated with these calculations are currently calibrated online and can continue to be calibrated online. If a change is made to the calibration frequency of the associated components the Preventative Maintenance Change Request (PMR) will drive the calculation updates.
No accuracy requirements exist for the functions listed for Remote Shutdown. The equipment will retain the existing calibration tolerances. Any out-of-tolerance conditions will be entered into the Corrective Action Program. If equipment experiences drift outside of those tolerances it will be evaluated as part of that program to determine if any actions are needed. Extending the tolerances used or replacement of the equipment are possible actions.
For remote shutdown equipment additional consideration for drift outside of what is evaluated here is not warranted as the evaluation of extended drift would not be compared to any meaningful values. The existing calibration program will continue to evaluate out-of-tolerance conditions, including those resulting from increased drift intervals.
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.
Evaluation to Step 6:
There are no setpoint or tolerance changes required as a result of calculation revisions. As-found and as-left values have been determined to be acceptable to ensure correct operation and operability of the instruments, with one exception mentioned below.
Seven maintenance procedures are impacted by this LAR. LP-022-1-PT, LP-022-2-PT and LP-022-3-PT will be revised to institute a minimum calibration temperature. This is required to address low margin between the Total Loop Uncertainty (TLU) and analytical value within the uncertainty/setpoint calculation. PIC-112, F delta I Calibration is being revised to state in the purpose that calibration of Power Range Indicator NI-303 is required to support operation on a 24-month fuel cycle. LP-001, LP-002 and LP-003 are being revised to require as-found string data being recorded.
 
Evaluation of Impact to EST-047/WCAP-11889/SR 3.4.1.3:
WCAP-11889 RTD Bypass Elimination Licensing Report for H. B. Robinson Unit 2 was prepared to support operation of RNP utilizing the new thermowell mounted Resistance Temperature Detectors (RTDs). The existing RTD bypass system for measurement of RCS temperature was replaced by this newer system.
As part of WCAP-11889, calorimetric flow measurement uncertainty values were provided for the new system. These values were specific to the installation at RNP. The calculated uncertainty values used an existing methodology consistent with that outlined in NUREG/CR-3659, A Mathematical Model for Assessing the Uncertainties of Instrumentation Measurements for Power and Flow of PWR Reactors. The methodology nor basis for the uncertainty values were provided to RNP as part of the WCAP; therefore, RNP typically evaluates impact to the WCAP by qualitative assessment.
Table 3.1-1 of WCAP-11889 lists the uncertainties of each of the inputs to the flow calorimetric.
Those inputs include: Feedwater Temperature, Feedwater Pressure, Feedwater Flow, Steam Pressure, Hot Leg Temperature, Cold Leg Temperature and Pressurizer Pressure. The calculated total uncertainty from all contributions was determined to be 2.3% flow as shown on Table 3.1-3 of the WCAP.
As part of the NRC review process, Westinghouse prepared Addendum 1 to WCAP-11889. The addendum provided answers to NRC questions concerning RTD Bypass Elimination. Question 8 of the addendum specifically discussed additional uncertainties the NRC requested in the calorimetric flow uncertainty. The NRC requested the RCS Cold Leg Flow uncertainties and Feedwater Venturi fouling be included in the calculation. Westinghouse provided Table 1 of the addendum to answer the NRC question.
Table 1 of the addendum stated the uncertainty values associated with the Cold Leg Elbow Tap flow loop. Table 1 also included a new Reactor Coolant system (RCS) flow uncertainty which included the Cold Leg Elbow Tap uncertainties and Venturi fouling. The revised RCS flow uncertainty was stated as 2.6 % flow.
Before addition of the Venturi fouling uncertainty, the RCS flow uncertainty, with the addition of the Cold Leg Elbow Tap, was 2.5% flow Although it is not discussed, reverse calculation determined the Cold Leg Elbow Tap uncertainty of 1.0% flow was statistically applied to the predetermined RCS flow uncertainty by Square Root of the Sum of the Squares (SRSS). The Cold Leg Elbow Tap accounts for 0.2% flow of the overall RCS flow uncertainty. It is not stated in the WCAP or addendum to the WCAP; however, it is believed the indicator and computer input uncertainties are not included in the Cold Leg Elbow Tap uncertainty.
Technical Specification Surveillance Requirement 3.4.1.3, verifies that RCS total flow rate is 97.3 x 106 lbm/hr. Per section 7.3 of OST-020, Shiftly Surveillances, the operators use Reactor Turbine Generator Board (RTGB) RCS flow indications or Emergency Response Facility Information System (ERFIS) to verify this flow rate. This surveillance requirement is performed on a shiftily bases.
Before SR 3.4.1.3 can be verified, SR 3.4.1.4 must be completed within 24 hours of reaching Reactor Thermal Power  90%, after each refueling outage. SR 3.4.1.4 verifies the RCS total flow rate by precision heat balance.
 
EST-047 Reactor Coolant Flow Test satisfies SR 3.4.1.4. EST-047 also establishes the minimum indicated flow reading from the Cold Leg Elbow Tap indications (FI-414, FI-415, FI-416, FI-424, FI-425, FI-426, FI-434, FI-435, FI-436) and associated computer points. OST-020 is updated to include this minimum flow reading, which is used the remainder of that operating cycle to meet SR 3.4.1.3 every twelve hours.
Per Section 5.0 of EST-047, an acceptance criteria for minimum calculated flow of 99.8E+6 lbm/hr is used. This accounts for 2.6% instrument uncertainty above the SR stated value. This allowance is directly from WCAP-11889. Therefore, the uncertainty of the Cold Leg Elbow Tap is accounted for in the acceptance criteria for the precision heat balance calculation of RCS total flow.
Per note 31 of EST-047 Attachment 4, the transmitter, total device uncertainty (TDUXMTR) is included in the calculation of indicator, total loop uncertainty (TLUIND). The values used to calculate TLUIND are obtained from RNP-I/INST-1128, which means they will include drift considering a 30-month calibration interval.
Since the indications of Cold Leg Elbow Taps already take into account uncertainty for the operating cycle, the use of 2.6% flow from WCAP-11889 is an additional conservatism. The 2.6% flow uncertainty value is retained to preserve the values given in WCAP-11889; however, the value could be easily revised to remove the Cold Leg Elbow Tap uncertainty. This would result in an uncertainty value of 2.31% flow + 0.1% flow = 2.4% flow. However, making this change would result in moving away from the values given in the WCAP, which is not preferred.
Based on this evaluation, the uncertainty of the Cold Leg Elbow Taps is already accounted for in the values calculated in EST-047, for use through the operating cycle. The 2.6% flow value given in WCAP-11889 is not affected as a result.
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.
Evaluation to Step 7:
Instruments with TS calibration surveillance frequencies extended to 24 months will be monitored and trended in accordance with station procedures. As-found and as-left calibration data will be recorded for each 24-month calibration activity.
All out of tolerance conditions exceeding notification limits require engineering evaluation and trending per the Duke calibration procedures and are entered in the corrective action program.
The out of tolerance notification limits are conservative compared to the 30 month limits documented in the associated instrument setpoint and uncertainty calculation.
This will identify occurrences of instruments found outside of their allowable value and instruments whose performance is not as assumed in the drift or setpoint analysis. When the as-found conditions are outside the allowable value, an evaluation will be performed in accordance with the station corrective action program to evaluate the effect on plant safety.
 
This evaluation will be conducted to ensure the assumptions in the setpoint calculations continue to be valid. If this evaluation indicates that instrument performance is not consistent with assumptions, corrective actions will be taken in accordance with station corrective action requirements.
GL 91-04 Steam Generator Surveillance Concern The interval for conducting steam generator (SG) in-service inspections (ISIs) is worthy of special consideration in extending the surveillance interval to be compatible with a 24-month fuel cycle.
 
===Response===
GL 91-04 addresses steam generator in-service inspection considerations and intervals that pre-date the current Industry and Regulatory requirements that were adopted for the Steam Generator Program (SGP) as provided in NEI 97-06, Steam Generator Program Guidelines and Improved Technical Specifications. Steam Generator in-service inspections has been evaluated by an Engineering Change in regard to a 24-month fuel cycle. It was concluded that the existing inspection interval is compatible with an extended fuel cycle; therefore, no changes or additional considerations are needed.
GL 91-04 Enclosure 3 GL 91-04 Leak Testing Concern An increase in the testing interval for Type B and C tests will require a request for an exemption from the Appendix J requirements. Licensees desiring an exemption from the 24-month testing interval should provide supporting leak testing data to demonstrate that the requested test interval would not provide unacceptable results.
 
===Response===
RNP is required to perform Type A, B & C testing pursuant to the applicable sections of 10CFR50, Appendix J. The program plan is documented plant procedures.
Currently:
* HBRSEP Type A testing is performed per Option B to Appendix J; which requires that one test (ILRT) is performed at an interval not to exceed 10 years. The last test was performed in the Spring of 2007. The next scheduled test is due in Spring 2017. and includes a Structural Integrity Test (SIT) in conjunction with the ILRT to satisfy license extension commitments.
* HBRSEP Type B & C tests are currently on Option A to Appendix J; which requires that tests be performed during reactor shutdown for refueling, or other convenient intervals, but in no case at intervals greater than 2 years.
On November 19, 2015, HBRSEP submitted a LAR to the NRC to adopt 10CFR50, Appendix J, Option B with a request for approval by November 30, 2016. (Serial Number RNP-RA/15-0090).
On January 20, 2016, the NRC acknowledged our LAR and concluded that there was sufficient information to proceed with a Safety Evaluation.
 
Once approved, the HBRSEP licensing basis for Appendix J will be modified as follows:
* Increase the existing Type A integrated leakage rate test (ILRT) program test interval from 10 years to 15 years in accordance with Nuclear Energy Institute (NEI) Topical Report NEI 94-01,Revision 3-A and the conditions and limitations specified in NEI 94-01,Revision 2-A.
* Adopt 10 CFR 50, Appendix J, Option B, as modified by approved exemptions, for the performance-based testing of Type B components in accordance with the guidance of Technical Specification Task Force (TSTF)-52, Implement 10 CFR 50, Appendix J, Option B. This would allow us to extend Type B tests out to 120 months.
* Adopt an extension of the containment isolation valve leakage testing (Type C) frequency from the 60 months currently permitted by 10 CFR 50, Appendix J, Option B, to a 75-month frequency for Type C leakage rate testing of selected components, in accordance with NEI 94-01, Revision 3-A.
* Adopt a more conservative grace interval of 9 months, for Type A, Type B and Type C tests in accordance with Nuclear Energy Institute (NEI) Topical Report NEI 94-01, Revision 3-A.
The amendment was approved by NRC letter dated October 11, 2016. Therefore, this submittal does not include a request for exemption from 10 CFR 50, Appendix J as discussed in  of Generic Letter 91-04.
: 5. REGULATORY EVALUATION 5.1 Significant Hazards Consideration HBRSEP has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10CFR 50.92, "Issuance of Amendment," as discussed below.
The requested change would affect certain Technical Specification Surveillance Requirement frequencies that are specified as "18 months" by revising them to "24 months" in accordance with the guidance of GL 91-04 (Reference 1).
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed amendment changes the surveillance frequency from 18 months to 24 months for Surveillance Requirements in the Technical Specifications that are normally a function of the refueling interval. Duke Energy's evaluations have shown that the reliability of protective instrumentation and equipment will be preserved for the maximum allowable surveillance interval.
The proposed change does not involve any change to the design or functional requirements of the associated systems. That is, the proposed Technical Specification (TS) change neither degrades the performance of, nor increases the challenges to any safety systems assumed to function in the plant safety analysis. The proposed change will not give rise to any increase in operation power level, fuel operating limits or effluents. The proposed change does not affect any accident precursors since no accidents previously evaluated relate to the frequency of surveillance testing and the revision to the frequency does not introduce any accident initiators. The proposed change does not impact the usefulness of the Surveillance Requirements (SRs) in evaluating the operability of required systems and components or the manner in which the surveillances are performed.
In addition, evaluation of the proposed TS change demonstrates that the availability of equipment and systems required to prevent or mitigate the radiological consequences of an accident is not significantly affected. because of the availability of redundant systems and equipment or the high reliability of the equipment Since the impact on the systems is minimal, it is concluded that the overall impact on the plant safety analysis is negligible.
Furthermore, an historical review of surveillance test results and associated maintenance records indicates there is no evidence of any failure that would invalidate the above conclusions. Therefore, the proposed TS change does not significantly increase the probability or consequences of an accident previously evaluated.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed amendment does not require a change to the plant design nor the mode of plant operation. No new or different equipment is being installed. No installed equipment is being operated in a different manner. As a result, no new failure modes are being introduced. In addition, the proposed change does not impact the usefulness of the SRs in evaluating the operability of required systems and components or the manner in which the surveillances are performed. Furthermore, an historical review of surveillance test results and associated maintenance records indicates there is no evidence of any failure that would invalidate the above conclusions. Therefore, the implementation of the proposed change will not create the possibility for an accident of a new or different type than previously evaluated.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed amendment changes the surveillance frequency from 18 months to 24 months for Surveillance Requirements in the Technical Specifications that are normally a function of the refueling interval. Surveillance Requirement 3.0.2 would allow a maximum surveillance interval of 30 months for these surveillances.
Although the proposed change will result in an increase in the interval between surveillance tests, the impact on system availability is small based on other, more frequent testing that is performed, the existence of redundant systems and equipment or overall system reliability. There is no evidence of any time-dependent failures that would impact the availability of the systems. The proposed change does not significantly impact the condition or performance of structures, systems and components relied upon for accident mitigation. This change does not alter the existing TS allowable values or analytical limits. The existing operating margin between plant conditions and actual plant setpoints is not significantly reduced due to these changes. The assumptions and results in any safety analyses are not significantly impacted. Therefore, the proposed change does not involve a significant reduction in margin of safety.
Based on the above, Duke Energy concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
 
5.2    Applicable Regulatory Requirements/Criteria 10 CFR 50.36, "Technical Specifications," provides the content required in a licensee's TS.
Specifically, 10 CFR 50.36(c)(3) requires that the TS include surveillance requirements. The proposed SR frequency changes continue to support the requirements of 10 CFR 50.36(c)(3) to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits and that the limiting conditions for operation are met.
NRC GL 91-04 provides generic guidance for evaluating a 24-month surveillance test interval for TS SRs. This request for a license amendment provides the HBRSEP, Unit No.
2 specific evaluation of each step outlined in GL 91-04 and provides a description of the methodology used by HBRSEP, Unit No. 2 to complete the evaluation for each specific TS SR being revised. Duke Energy's monitoring program is adequate for assessing the effects of the extended instrument calibration surveillance intervals on future instrument drift.
In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public.
5.3    Precedent This request is similar in format and content to the following submittal:
Oconee Nuclear Station, submittal dated May 6, 2010, Accession No. ML101330499, supplemented by letters dated February 11, 2011, April 28, 2011, July 19, 2011 and September 16, 2011, NRC Safety Evaluation dated April 20, 2012 Accession No. ML12086A289.
5.4    Conclusions HBRSEP has made the determination that this amendment request involves a No Significant Hazards Consideration by applying the standards established by the NRC regulations in 10 CFR 50.92 in Section 5.1 of this Enclosure.
The regulatory requirements and guidance applicable to this LAR are identified in Section 5.2 above.
HBRSEP identified a similar LAR, as indicated in Section 5.3 above, requesting the extension of 18 month SR frequencies to 24 months to support transition to a 24 month fuel cycle. This LAR used the applicable regulatory requirements of Section 5.2 above to provide a basis for NRC review and approval. HBRSEP used the Oconee LAR to the extent practical and applicable for developing this LAR.
: 6.      ENVIRONMENTAL CONSIDERATION HBRSEP has evaluated this license amendment request against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. HBRSEP has determined that this license amendment request meets the criteria for a categorical exclusion as set forth in 10 CFR 51.22(c)(9). This determination is based on the fact the this change is being proposed as an amendment to a license issued pursuant to 10 CFR 50 that changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or that changes an inspection or a surveillance requirement, and the amendment meets the following specific criteria:
(1)      The amendment involves no significant hazard consideration as demonstrated in Section 5.1.
(2)      There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite. The principal barriers to the release of radioactive materials are not modified or affected by this change and no significant increases in the amounts of any effluent that could be released offsite will occur as a result of this change.
(3)      There is no significant increase in individual or cumulative occupational radiation exposure. Because the principal barriers to the release of radioactive materials are not modified or affected by this change, there will be no significant increase in individual or cumulative occupational radiation exposure resulting from this change.
Therefore, no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment pursuant to 10 CFR 51.22(b).
: 7. REFERENCES
: 1. NRC Generic Letter 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991.
: 2. Regulatory Guide 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants,"
Revision 2, dated March 1978.
: 3. EPRI TR-103335-R1, "Guidelines for Instrument Calibration Extension/Reduction Statistical Analysis of Instrument Calibration Data", Final Report, October 1998.
: 4. NRC Status Report dated December 1, 1997, on the Staff review of EPRI Technical Report (TR)-103335, "Guidelines for the Instrument Calibration Extension I Reduction Programs."
: 5. ANSl/ISA-S67.04, Part 1 - 1994, "Setpoints for Nuclear Safety - Related Instrumentation".
: 6. ISA-RP67.04, Part 2 - 1994, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation".
: 7. Duke Energy Procedure EGR-NGGC-0153, Engineering Instrument Setpoints, Revision 12.
 
U. S. Nuclear Regulatory Commission  to Serial: RNP-RA/17-0014 46 Pages (including cover page)
ATTACHMENT 1 MARKED-UP TECHNICAL SPECIFICATION PAGES
 
Rod Position Indication 3.1.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE                            FREQUENCY SR 3.1.7.1  Perform CHANNEL CALIBRATION of the ARPI      18 months System.
24 HBRSEP Unit No. 2                3.1-18                  Amendment No. 241
 
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                FREQUENCY SR 3.3.1.9      ------------------------------NOTE-------------------------------
Verification of setpoint is not required.
Perform TADOT.                                                        92 days SR 3.3.1.10    -------------------------------NOTE------------------------------
This Surveillance shall include verification that the time constants are adjusted to the prescribed values where applicable.
Perform CHANNEL CALIBRATION.                                          18 months SR 3.3.1.11    -------------------------------NOTE------------------------------      24 Neutron detectors are excluded from CHANNEL CALIBRATION.
Perform CHANNEL CALIBRATION.                                          18 months SR 3.3.1.12    -------------------------------NOTE------------------------------
This Surveillance shall include verification that the                  24 electronic dynamic compensation time constants are set at the required values, and verification of RTD                      24 response time constants.
Perform CHANNEL CALIBRATION.                                          18 months SR 3.3.1.13    Perform COT.                                                          18 months (continued) 24 HBRSEP Unit No. 2                                3.3-11                              Amendment No. 176
 
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                FREQUENCY SR 3.3.1.14    ------------------------------NOTE------------------------------
24 Verification of setpoint is not required.
Perform TADOT.                                                      18 months SR 3.3.1.15    ------------------------------NOTE------------------------------    -------NOTE--------
Verification of setpoint is not required.                            Only required
                -------------------------------------------------------------------- when not performed within previous 31 days Perform TADOT.                                                      Prior to reactor startup HBRSEP Unit No. 2                                3.3-12                              Amendment No. 176
 
ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS
-----------------------------------------------------NOTES-------------------------------------------------------------
: 1. Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.
: 2. When a channel or train is placed in an inoperable status solely for the performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours provided the redundant train is OPERABLE.
SURVEILLANCE                                                    FREQUENCY SR 3.3.2.1              Perform CHANNEL CHECK.                                                  12 hours SR 3.3.2.2              Perform ACTUATION LOGIC TEST.                                            31 days on a STAGGERED TEST BASIS 24 SR 3.3.2.3              Perform MASTER RELAY TEST.                                              18 months SR 3.3.2.4              Perform COT.                                                            92 days 24 SR 3.3.2.5              Perform SLAVE RELAY TEST.                                                18 months SR 3.3.2.6              ---------------------------NOTE-----------------------------
Verification of setpoint not required for manual initiation functions.                                                        24 Perform TADOT.                                                          18 months SR 3.3.2.7              Perform CHANNEL CALIBRATION.                                            18 months 24 HBRSEP Unit No. 2                                          3.3-24                                  Amendment No. 176
 
PAM Instrumentation 3.3.3 ACTIONS (continued)
CONDITION                                REQUIRED ACTION                        COMPLETION TIME G. As required by Required                G.1          Initiate action in Immediately Action E.1 and referenced                          accordance with in Table 3.3.3-1.                                  Specification 5.6.6.
SURVEILLANCE REQUIREMENTS
----------------------------------------------------------NOTE-----------------------------------------------------------
SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1; except Functions 9, 22, 23, and 24. SR 3.3.3.3 applies only to Functions 9, 22, 23, and 24.
SURVEILLANCE                                                    FREQUENCY SR 3.3.3.1              Perform CHANNEL CHECK for each required                                  31 days instrumentation channel that is normally energized.
SR 3.3.3.2              ----------------------------NOTE-------------------------------          18 months Neutron detectors are excluded from CHANNEL CALIBRATION.
                          -------------------------------------------------------------------              24 Perform CHANNEL CALIBRATION.
SR 3.3.3.3              ----------------------------NOTE------------------------------          18 months Verification of setpoint not required.
                          ------------------------------------------------------------------                24 Perform TADOT.
HBRSEP Unit No. 2                                          3.3-31                                  Amendment No. 216
 
Remote Shutdown System 3.3.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                FREQUENCY SR 3.3.4.1      Perform CHANNEL CHECK for each required                              31 days instrumentation channel that is normally energized.
SR 3.3.4.2      Verify each required control circuit and transfer                    18 months switch is capable of performing the intended function.
24 SR 3.3.4.3      ----------------------------NOTE---------------------------------
Neutron detectors are excluded from CHANNEL CALIBRATION.                                                              24 Perform CHANNEL CALIBRATION for each required                        18 months instrumentation channel.
SR 3.3.4.4      Perform TADOT of the reactor trip                                    18 months breaker open/closed indication.
24 HBRSEP Unit No. 2                                3.3-34                              Amendment No. 176
 
LOP DG Start Instrumentation 3.3.5 ACTIONS CONTINUED (continued)
CONDITION                              REQUIRED ACTION                      COMPLETION TIME D. Required Action and                D.1          Enter applicable                Immediately associated Completion                          Condition(s) and Time not met.                                  Required Action(s) for the associated DG made inoperable by LOP DG start instrumentation.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                FREQUENCY SR 3.3.5.1      -----------------------------NOTE-----------------------------
Verification of setpoint not required.                                  24 Perform TADOT.                                                    18 months SR 3.3.5.2      Perform CHANNEL CALIBRATION with Trip                              18 months Setpoints as follows:
24
: a.      Loss of voltage Trip Setpoint of 328 V +/- 10%
with a time delay of 1 second (at zero voltage).
: b.      Degraded voltage Trip Setpoint of 430 V +/- 4 V with a time delay of 10 +/- 0.5 seconds.
HBRSEP Unit No. 2                                  3.3-36                              Amendment No. 176
 
Containment Ventilation Isolation Instrumentation 3.3.6 SURVEILLANCE REQUIREMENTS
-------------------------------------------------------NOTE--------------------------------------------------------------
Refer to Table 3.3.6-1 to determine which SRs apply for each Containment Ventilation Isolation Function.
SURVEILLANCE                                                    FREQUENCY SR 3.3.6.1              Perform CHANNEL CHECK.                                                  12 hours SR 3.3.6.2              Perform ACTUATION LOGIC TEST.                                            31 days on a STAGGERED TEST BASIS SR 3.3.6.3              Perform MASTER RELAY TEST.                                              18 months 24 SR 3.3.6.4              Perform COT.                                                            92 days SR 3.3.6.5              Perform SLAVE RELAY TEST.                                                18 months SR 3.3.6.6              ----------------------------NOTE--------------------------------                  24 Verification of setpoint is not required.
                          --------------------------------------------------------------------                          24 Perform TADOT.                                                          18 months SR 3.3.6.7              Perform CHANNEL CALIBRATION.                                            18 months 24 HBRSEP Unit No. 2                                          3.3-38                                  Amendment No. 176
 
CREFS Actuation Instrumentation 3.3.7 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                      FREQUENCY 24 SR 3.3.7.4      Perform MASTER RELAY CHECK.            18 months 24 SR 3.3.7.5      Perform SLAVE RELAY TEST.              18 months SR 3.3.7.6      Perform CHANNEL CALIBRATION.            18 months HBRSEP Unit No. 2                    3.3-42            Amendment No. 176
 
Auxiliary Feedwater (AFW) System Instrumentation 3.3.8 SURVEILLANCE REQUIREMENTS
----------------------------------------------------------NOTE-----------------------------------------------------------
Refer to Table 3.3.8-1 to determine which SRs apply for each AFW Function.
SURVEILLANCE                                                    FREQUENCY SR 3.3.8.1              Perform CHANNEL CHECK.                                                  12 hours SR 3.3.8.2              Perform COT.                                                            92 days SR 3.3.8.3              ----------------------------NOTE--------------------------------
For Function 5, the TADOT shall include injection of a simulated or actual signal to verify channel OPERABILITY.                                                                      24 Perform TADOT.                                                          18 months SR 3.3.8.4              Perform CHANNEL CALIBRATION.                                            18 months 24 HBRSEP Unit No. 2                                          3.3-46                                  Amendment No. 176
 
RCS Pressure, Temperature, and Flow DNB Limits 3.4.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                    FREQUENCY SR 3.4.1.1      Verify pressurizer pressure is greater than or equal to  12 hours the limit specified in the COLR.
SR 3.4.1.2      Verify RCS average temperature is less than or equal    12 hours to the limit specified in the COLR.
SR 3.4.1.3      Verify RCS total flow rate is~ 97.3 x 10 lbm/hr and      12 hours 6
greater than or equal to the limit specified in the COLR.
SR 3.4.1.4      --*-------NOTE---------
Not required to be performed until 24 hours after
                ~ 90% RTP.
Verify by precision heat balance that RCS total flow    18 months rate is ~ 97 .3 x 106 lbm/hr and greater than or equal to the limit specified in the COLR.
24 HBRSEP Unit No. 2                            3.4-2                      Amendment No. 250
 
Pressurizer 3.4.9 CONDITION                      REQUIRED ACTION            COMPLETION TIME D. Required Action and          D.1      Be in MODE 3.          6 hours associated Completion Time of Condition B or C      AND not met.
D.2      Be in MODE 4.          12 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                  FREQUENCY SR 3.4.9.1      Verify pressurizer water level is within limits. 12 hours SR 3.4.9.2      Verify capacity of required pressurizer heaters is 18 months 125 kW.
24 SR 3.4.9.3      Verify required pressurizer heaters are            18 months capable of being powered from an emergency power supply.                                  24 HBRSEP Unit No. 2                          3.4-22                    Amendment No. 176
 
Pressurizer PORVs 3.4.11 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                              FREQUENCY SR 3.4.11.2    ------------------------------NOTE-----------------------------
Not required to be performed until 12 hours after entry into MODE 3.                                                        24 Perform a complete cycle of each PORV.                              18 months SR 3.4.11.3    Perform a complete cycle of each solenoid                          18 months air control valve and check valve on the nitrogen accumulators in PORV control systems.
24 SR 3.4.11.4    Verify accumulators are capable of operating PORVs                  18 months through a complete cycle.
24 HBRSEP Unit No. 2                                3.4-28                            Amendment No. 176
 
LTOP System 3.4.12 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                            FREQUENCY SR 3.4.12.6    ---------------------------- NOTE-----------------------------
Not required to be performed until 12 hours after decreasing RCS cold leg temperature to  350°F.
Perform a COT on each required PORV, excluding                    31 days actuation.
SR 3.4.12.7    Perform CHANNEL CALIBRATION for each required                      18 months PORV actuation channel.
24 HBRSEP Unit No. 2                                3.4-34                            Amendment No. 238
 
RCS PIVs 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                FREQUENCY SR 3.4.14.1    --------------------------------NOTES---------------------------
: 1.      Not required to be performed in MODES 3 and 4.
: 2.      Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation.
: 3.      RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.
Verify leakage from each RCS PIV is less than or                      In accordance with equal to an equivalent of 5 gpm at an RCS pressure                    the Inservice 2235 psig, and verify the margin between the                        Testing Program results of the previous leak rate test and the 5 gpm                  and 18 months limit has not been reduced by  50% for valves with leakage rates > 1.0 gpm.                                              AND        24 Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND (continued)
HBRSEP Unit No. 2                                3.4-39                              Amendment No. 176
 
RCS PIVs 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                  FREQUENCY SR 3.4.14.1 (continued)                                            Within 24 hours following valve actuation due to automatic or manual action or flow through the valve SR 3.4.14.2    Verify RHR System interlock prevents the valves    18 months from being opened with a simulated or actual RCS pressure signal > 474 psig.
24 HBRSEP Unit No. 2                        3.4-40                Amendment No. 176 , 182
 
RCS Leakage Detection Instrumentation 3.4.15 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                  FREQUENCY SR 3.4.15.2    Perform COT of the required containment atmosphere  92 days radioactivity monitor.
SR 3.4.15.3    Perform CHANNEL CALIBRATION of the required        18 months containment sump monitor.
24 SR 3.4.15.4    Perform CHANNEL CALIBRATION of the required        18 months containment atmosphere radioactivity monitor.
24 SR 3.4.15.5    Perform CHANNEL CALIBRATION of the required        18 months containment fan cooler condensate flow rate monitor.                                                  24 HBRSEP Unit No. 2                        3.4-44                    Amendment No. 176
 
CVCS 3.4.17 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                FREQUENCY SR 3.4.17.1    Verify seal injection flow of  6 gpm to each RCP. 12 hours SR 3.4.17.2    Verify seal injection flow of  6 gpm to each RCP  18 months from each Makeup Water Pathway from the RWST.
24 SR 3.4.17.3    For Makeup Water Pathways from the RWST to be      In accordance with OPERABLE, SR 3.5.4.2 is applicable.                SR 3.5.4.2 HBRSEP Unit No. 2                          3.4-51                  Amendment No. 176
 
ECCS - Operating 3.5.2 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                    FREQUENCY SR 3.5.2.3      Verify each ECCS pump's developed head at the test      In accordance with flow point is greater than or equal to the required    the Inservice developed head.                                        Testing Program SR 3.5.2.4      Verify each ECCS automatic valve in the flow path      18 months that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual        24 or simulated actuation signal.
SR 3.5.2.5      Verify each ECCS pump starts automatically on an        18 months actual or simulated actuation signal.
24 SR 3.5.2.6      Verify, by visual inspection, the ECCS containment      18 months sump suction inlet is not restricted by debris and the 24 suction inlet strainers show no evidence of structural distress or abnormal corrosion.
(continued)
HBRSEP Unit No. 2                          3.5-6                        Amendment No. 213
 
Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY SR 3.6.3.2      --------------------------NOTE-----------------------------------
Valves and blind flanges in high radiation areas may be verified by use of administrative controls.
Verify each containment isolation manual valve and                    31 days for blind flange that is located outside containment and                  containment not locked, sealed or otherwise secured and required                  isolation manual to be closed during accident conditions is closed,                    valves (except except for containment isolation valves that are open                  Penetration under administrative controls.                                        Pressurization System valves with a diameter 3/8 inch) and blind flanges AND 24 18 months for Penetration Pressurization System valves with a diameter 3/8 inch SR 3.6.3.3      -----------------------NOTE--------------------------------------
Valves and blind flanges in high radiation areas may be verified by use of administrative means.
Verify each containment isolation manual valve and                    Prior to entering blind flange that is located inside containment and                    MODE 4 from not locked, sealed or otherwise secured and required                  MODE 5 if not to be closed during accident conditions is closed,                    performed within except for containment isolation valves that are open                  the previous under administrative controls.                                        92 days (continued)
HBRSEP Unit No. 2                                3.6-11                              Amendment No. 176
 
Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                      FREQUENCY SR 3.6.3.4      Verify the isolation time of each automatic power        In accordance operated containment isolation valve is within limits. with the Inservice Testing Program SR 3.6.3.5      Verify each automatic containment isolation valve        18 months that is not locked, sealed or otherwise secured in position, actuates to the isolation position on an                24 actual or simulated actuation signal.
SR 3.6.3.6      Verify each 42 inch inboard containment purge valve      18 months is blocked to restrict the valve from opening > 70º.
24 HBRSEP Unit No. 2                            3.6-12                      Amendment No. 176
 
Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                      FREQUENCY SR 3.6.6.2      Operate each containment cooling train fan unit for      31 days 15 minutes.
SR 3.6.6.3      Verify cooling water flow rate to each cooling unit is  31 days 750 gpm.
SR 3.6.6.4      Verify each containment spray pump's developed          In accordance with head at the flow test point is greater than or equal to  the Inservice the required developed head.                            Testing Program SR 3.6.6.5      Verify each automatic containment spray valve in the    18 months flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position          24 on an actual or simulated actuation signal.
SR 3.6.6.6      Verify each containment spray pump starts                18 months automatically on an actual or simulated actuation signal.                                                        24 SR 3.6.6.7      Verify each containment cooling train starts            18 months automatically on an actual or simulated actuation signal.                                                            24 SR 3.6.6.8      Verify each spray nozzle is unobstructed.                Following activities which could result in nozzle blockage HBRSEP Unit No. 2                          3.6-17                    Amendment No. 176 194
 
Spray Additive System 3.6.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                    FREQUENCY SR 3.6.7.1      Verify each spray additive manual, power operated,      31 days and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.
SR 3.6.7.2      Verify spray additive tank solution volume is            184 days 2505 gal.
SR 3.6.7.3      Verify spray additive tank NaOH solution                184 days concentration is  30% by weight.
SR 3.6.7.4      Verify each spray additive automatic valve in the flow  18 months path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an            24 actual or simulated actuation signal.
HBRSEP Unit No. 2                          3.6-19                      Amendment No. 176
 
Isolation Valve Seal Water System 3.6.8 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                        FREQUENCY SR 3.6.8.3      Verify the opening time of each air operated            In accordance with header injection valve is within limits.                the Inservice Testing Program SR 3.6.8.4      Verify each automatic valve in the IVSW System          18 months actuates to the correct position on an actual or simulated actuation signal.                                24 SR 3.6.8.5      Verify the IVSW dedicated nitrogen bottles will        18 months pressurize the IVSW tank to  46.2 psig.
24 SR 3.6.8.6      Verify total IVSW seal header flow rate is              18 months 124 cc/minute                                              24 HBRSEP Unit No. 2                        3.6-21                          Amendment No. 220
 
AFW System 3.7.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                FREQUENCY SR 3.7.4.1      Verify each AFW manual, power operated, and                          31 days automatic valve in each water flow path, and in the steam supply flow path to the steam driven AFW pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.
SR 3.7.4.2      ----------------------------NOTE---------------------------------
Not required to be performed for the steam driven AFW pump until 24 hours after  1000 psig in the steam generator.
Verify the developed head of each AFW pump at the                    31 days on a flow test point is greater than or equal to the required              STAGGERED developed head.                                                      TEST BASIS SR 3.7.4.3      ----------------------------NOTE---------------------------------
Not applicable in MODE 4 when steam generator is being used for heat removal.
Verify each AFW automatic valve that is not locked,                  18 months sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated                              24 actuation signal.
(continued)
HBRSEP Unit No. 2                                3.7-12                              Amendment No. 176
 
AFW System 3.7.4 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                FREQUENCY SR 3.7.4.4      -------------------------NOTES----------------------------------
: 1. Not required to be performed for the steam driven AFW pump until 24 hours after  1000 psig in the steam generator.
: 2. Not applicable in MODE 4 when steam generator is being used for heat removal.
24 Verify each AFW pump starts automatically on an                      18 months actual or simulated actuation signal.
SR 3.7.4.5      --------------------------NOTE------------------------------------
Not required to be performed for the steam driven AFW pump until prior to entering MODE 1.
Verify proper alignment of the required                              Prior to entering AFW flow paths by verifying flow from the                            MODE 2, condensate storage tank to each steam generator.                      whenever unit has been in MODE 5 or 6 for > 30 days SR 3.7.4.6      Verify the AFW automatic bus transfer switch                          18 months associated with discharge valve V2-16A operates automatically on an actual or simulated actuation 24 signal.
HBRSEP Unit No. 2                                3.7-13                              Amendment No. 176
 
CCW System 3.7.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                FREQUENCY SR 3.7.6.1      -------------------------------NOTE-------------------------------
Isolation of CCW flow to individual components does not render the CCW System inoperable.
Verify each required CCW manual, power operated,                      31 days and automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.
SR 3.7.6.2      Verify each required CCW pump starts automatically                    18 months on an actual or simulated LOP DG Start undervoltage signal.                                                                        24 HBRSEP Unit No. 2                                3.7-17                            Amendment No. 176 186
 
SWS 3.7.7 ACTIONS (continued)
CONDITION                              REQUIRED ACTION                        COMPLETION TIME C. Two Turbine Building loop          C.1          Close and deactivate                2 hours isolation valves inoperable.                    one inoperable Turbine Building loop isolation valve.
D. Required Actions and                D.1          Be in MODE 3.                      6 hours associated Completion Times of Conditions A, B,          AND or C not met.
D.2          Be in MODE 5.                      36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.7.7.1        --------------------------NOTE-----------------------------------
Isolation of SWS flow to individual components does not render the SWS inoperable.
Verify each SWS manual, power operated, and                              31 days automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.
SR 3.7.7.2        Verify each SWS automatic valve in the flow path                        18 months that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.                                                  24 (continued)
HBRSEP Unit No. 2                                    3.7-19                                Amendment No. 176
 
SWS 3.7.7 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                  FREQUENCY SR 3.7.7.3      Verify each SWS pump and SWS booster pump            18 months starts automatically on an actual or simulated actuation signal.                                          24 SR 3.7.7.4      Verify the SWS automatic bus transfer switch          18 months associated with Turbine Building loop isolation valve V6-16C operates automatically on an actual or                24 simulated actuation signal.
HBRSEP Unit No. 2                          3.7-20                      Amendment No. 176
 
CREFS 3.7.9 ACTIONS (continued)
CONDITION                        REQUIRED ACTION            COMPLETION TIME H. Required Action and          H.1        Be in MODE 3.            6 hours associated Completion Time of Condition G not      AND met in MODE 1, 2, 3, or 4.
H.2        Be in MODE 5.          36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                      FREQUENCY SR 3.7.9.1      Operate each CREFS train for  15 minutes.              31 days SR 3.7.9.2      Perform required CREFS filter testing in accordance    In accordance with with the Ventilation Filter Testing Program (VFTP). VFTP SR 3.7.9.3      Verify each CREFS train actuates on an actual or        18 months simulated actuation signal.
24 SR 3.7.9.4      Perform required CRE maintenance and testing in        In accordance with accordance with the CRE Habitability Program.          the CRE Habitability Program HBRSEP Unit No. 2                        3.7-24                      Amendment No. 219
 
CREATC 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE                              FREQUENCY SR 3.7.10.1    Verify each CREATC WCCU train has the capability 18 months to remove the assumed heat load.                    24 HBRSEP Unit No. 2                      3.7-27                    Amendment No. 176
 
FBACS 3.7.11 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                FREQUENCY SR 3.7.11.3    ---------------------------NOTE----------------------------------
Not required to be met when the only movement of irradiated fuel is movement of the spent fuel shipping                    24 cask containing irradiated fuel.
Verify the FBACS can maintain a negative pressure                    18 months with respect to atmospheric pressure.
HBRSEP Unit No. 2                                3.7-29                              Amendment No. 176
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                FREQUENCY SR 3.8.1.6      Verify the fuel oil transfer system operates to                        31 days automatically transfer fuel oil from storage tank to the day tank.
SR 3.8.1.7      --------------------------NOTES--------------------------------
All DG starts may be preceded by an engine prelube period.
Verify each DG starts from standby condition and                      184 days achieves in  10 seconds, voltage  467 V and frequency  58.8 Hz, and after steady state conditions are reached, maintains voltage  467 V and  493 V and frequency  58.8 Hz and  61.2 Hz.
SR 3.8.1.8      ---------------------------NOTES-------------------------------
: 1.      This Surveillance shall not be performed in MODE 1 or 2.
: 2.      If performed with the DG synchronized with offsite power, it shall be performed at a power factor  0.9.                                                        24 Verify each DG rejects a load greater than or equal to                18 months its associated single largest post-accident load and does not trip on overspeed.
(continued)
HBRSEP Unit No. 2                                  3.8-6                              Amendment No. 176
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                FREQUENCY SR 3.8.1.9      ----------------------------NOTES------------------------------
: 1.      All DG starts may be preceded by an engine prelube period.
: 2.      This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
: 3.      During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed 24 the load on its bus.
Verify on an actual or simulated loss of offsite power                18 months signal:
: a.      De-energization of emergency buses; b      Load shedding from emergency buses;
: c.      DG auto-starts from standby condition and:
: 1.      energizes permanently connected loads in  10 seconds,
: 2.      energizes auto-connected shutdown loads through automatic load sequencer,
: 3.      maintains steady state voltage 467 V and  493 V,
: 4.      maintains steady state frequency 58.8 Hz and  61.2 Hz, and
: 5.      supplies permanently connected and auto-connected shutdown loads for 5 minutes.
(continued)
HBRSEP Unit No. 2                                  3.8-7                              Amendment No. 176
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                FREQUENCY SR 3.8.1.10    ---------------------------NOTES-------------------------------
1      All DG starts may be preceded by prelube period.
: 2.      This Surveillance shall not be performed in MODE 1 or 2.
: 3.      During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
Verify on an actual or simulated Engineered Safety                    18 months Feature (ESF) actuation signal each DG auto-starts from standby condition and:
24
: a.      In  10 seconds after auto-start achieves voltage  467 V, and after steady state conditions are reached, maintains voltage 467 V and  493 V;
: b.      In  10 seconds after auto-start achieves frequency  58.8 Hz, and after steady state conditions are reached, maintains frequency 58.8 Hz and  61.2 Hz;
: c.      Operates for  5 minutes;
: d.      Permanently connected loads remain energized from the offsite power system; and
: e.      Emergency loads are energized through the automatic load sequencer from the offsite power system.
(continued)
HBRSEP Unit No. 2                                  3.8-8                              Amendment No. 176
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY SR 3.8.1.11    Verify each DG's automatic trips are bypassed except engine overspeed.                                                24 months SR 3.8.1.12    ---------------------------NOTES--------------------------------
: 1.      Momentary transients outside the load and power factor ranges do not invalidate this test.
: 2.      This Surveillance shall not be performed in MODE 1 or 2.
: 3.      During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.                                                24 Verify each DG operating at a power factor  0.9                        18 months operates for  24 hours:
: a.      For  1.75 hours loaded  2650 kW and 2750 kW; and
: b.      For the remaining hours of the test loaded 2400 kW and  2500 kW.
(continued)
HBRSEP Unit No. 2                                  3.8-9                                Amendment No. 208
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY SR 3.8.1.13    -------------------------------NOTES----------------------------
: 1.      This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated  2 hours loaded  2400 kW and 2500 kW.
Momentary transients outside of load range do not invalidate this test.
: 2.      All DG starts may be preceded by an engine prelube period.
Verify each DG starts and achieves, in  10 seconds,                    18 months voltage  467 V, and frequency  58.8 Hz, and after steady state conditions are reached, maintains voltage  467 V and  493 V and frequency  58.8 Hz                        24 and  61.2 Hz.
SR 3.8.1.14    -----------------------------NOTE--------------------------------
This Surveillance shall not be performed in MODE 1, 2, 3, or 4.                                                                  24 Verify actuation of each sequenced load block is                        18 months within +/- 0.5 seconds of design setpoint for each emergency load sequencer.
(continued)
HBRSEP Unit No. 2                                3.8-10                                Amendment No. 176
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY SR 3.8.1.15    ---------------------------NOTES--------------------------------
: 1. All DG starts may be preceded by an engine prelube period.
: 2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
: 3. During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
Verify on an actual or simulated loss of offsite power                  18 months signal in conjunction with an actual or simulated ESF actuation signal:
: a. De-energization of emergency buses;                                        24
: b. Load shedding from emergency buses; and
: c. DG auto-starts from standby condition and:
: 1. energizes permanently connected loads in 10 seconds,
: 2. energizes auto-connected emergency loads through load sequencer,
: 3. achieves steady state voltage  467 V and 493 V,
: 4. achieves steady state frequency  58.8 Hz and 61.2 Hz, and (continued)
HBRSEP Unit No. 2                                3.8-11                                Amendment No. 176
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.8.1.15 (continued)
: 5. supplies permanently connected and auto connected emergency loads for  5 minutes.
SR 3.8.1.16    -------------------------NOTE------------------------------------
: 1. This Surveillance shall not be performed in MODE 1 or 2.
: 2. SR 3.8.1.16 is not required to be met if 4.160 kV bus 2 and 480 V Emergency Bus 1 power supply is from the start up transformer.
                ---------------------------------------------------------------------      24 Verify automatic transfer capability of the 4.160kV bus                18 months 2 and the 480V Emergency bus 1 loads from the Unit auxiliary transformer to the start up transformer.
SR 3.8.1.17    ------------------------NOTE-------------------------------------
All DG starts may be preceded by an engine prelube period.
Verify when started simultaneously from standby                        10 years condition, each DG achieves, in  10 seconds, voltage 467 V and frequency  58.8 Hz, and after steady state conditions are reached, maintains voltage 467 V and  493 V and frequency  58.8 Hz and 61.2 Hz.
HBRSEP Unit No. 2                                3.8-12                                Amendment No. 176
 
DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                              FREQUENCY SR 3.8.4.2      Verify battery cells, cell plates, and racks show no                18 months visual indication of physical damage or abnormal deterioration that could degrade battery performance.                    24 SR 3.8.4.3      Remove visible terminal corrosion, verify battery cell to            18 months cell and terminal connections are clean and tight, and are coated with anti-corrosion material.                                  24 SR 3.8.4.4      Verify each battery charger supplies  300 amps at                  18 months 125 V for  4 hours.
24 SR 3.8.4.5      -----------------------NOTES----------------------------------
: 1.      The modified performance discharge test in SR 3.8.4.6 may be performed in lieu of the service test in SR 3.8.4.5.
: 2.      This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
Verify battery capacity is adequate to supply, and                  18 months maintain in OPERABLE status, the required emergency loads for the design duty cycle when                          24 subjected to a battery service test.
(continued)
HBRSEP Unit No. 2                                3.8-20                            Amendment No. 206
 
Distribution Systems-Operating 3.8.9 ACTIONS (continued)
CONDITION                              REQUIRED ACTION                        COMPLETION TIME G. Two trains with inoperable          G.1          Enter LCO 3.0.3.                    Immediately distribution subsystems that result in a loss of safety function.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.8.9.1        ---------------------------NOTE----------------------------------
Actual voltage measurement is not required for the AC vital buses supplied from the constant voltage transformers.
Verify correct breaker alignments and voltage to AC,                    7 days DC, and AC instrument bus electrical power distribution subsystems.
SR 3.8.9.2        Verify capability of the two molded case circuit                        18 months breakers for AFW Header Discharge Valve to S/G                                24 "A", V2-16A to trip on overcurrent.
SR 3.8.9.3        Verify capability of the two molded case circuit                        18 months breakers for Service Water System Turbine Building                          24 Supply Valve (emergency supply), V6-16C to trip on overcurrent.
HBRSEP Unit No. 2                                    3.8-34                                Amendment No. 176
 
Nuclear Instrumentation 3.9.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.9.2.1      Perform CHANNEL CHECK.                                                  12 hours SR 3.9.2.2      ----------------------NOTE--------------------------------------
Neutron detectors are excluded from CHANNEL CALIBRATION.                                                                  24 Perform CHANNEL CALIBRATION.                                            18 months HBRSEP Unit No. 2                                3.9-3a                      Amendment No. 176,180,190
 
Containment Penetrations 3.9.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                    FREQUENCY SR 3.9.3.1      Verify each required containment penetration is in the  7 days required status.
SR 3.9.3.2      Verify each required containment ventilation valve      18 months actuates to the isolation position on an actual or simulated actuation signal.                                    24 HBRSEP Unit No. 2                          3.9-5                      Amendment No. 176
 
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.10      Secondary Water Chemistry Program (continued)
: b. Procedures used to measure the critical parameters;
: c. Requirements for the documentation and review of sample results;
: d. Procedures which identify the administrative events and corrective actions required to return the secondary chemistry to its normal control band following an out of control band condition; and
: e. Identification of the authority responsible for the interpretation of the sample results.
5.5.11      Ventilation Filter Testing Program (VFTP)
This program provides controls for implementation of the following required testing of Engineered Safety Feature (ESF) ventilation filter systems at the frequencies specified in Positions C.5 and C.6 of Regulatory Guide 1.52, Revision 2, March 1978, and conducted in general conformance with ANSI N510-1975 or N510-1980.
: a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows the specified penetration and except that the            system bypass leakage when tested in accordance with the referenced testing specified at        standard at the system flowrate specified below.
a frequency of 18          ESF months is required      Ventilation      Penetration at a frequency of        System            /Bypass              Flowrate            Reference Std 24 months, Control Room          <0.05%          3300 - 4150 ACFM        Regulatory Guide Emergency                                                      1.52, Revision 2, March 1978, C.5.a, C.5.c, C.5.d (using ANSI N510-1980)
Spent Fuel            <1%            11070- 13530 CFM        ANSI N510-1975 Building Containment          <1%            31500- 38500 CFM        ANSI N510-1975 Purge (continued)
HBRSEP                                          5.0-15                      Amendment No. 214
 
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.17      Control Room Envelope Habitability Program (continued)
: a. The definition of the CRE and the CRE boundary.
: b. Requirements for maintaining the CRE boundary in its design condition, including configuration control and preventive maintenance.
: c. Requirements for: (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.
The following exception is taken to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:
: 1.      Unfiltered air inleakage testing shall include the ability to deviate from the test methodology of ASTM-E741. These exceptions shall be documented in the test report.
: d. Measurement, at designated locations, of the CRE pressure relative to external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREFS, operating at the flow rate required by the VFTP, at a frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the assessment of the CRE boundary.                  24
: e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.
The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. For hazardous chemicals, inleakage rates shall be less than assumed in the licensing bases.
: f. The provisions of SR 3.0.2 are applicable to the frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.
HBRSEP                                          5.0-22a                      Amendment No. 219
 
U. S. Nuclear Regulatory Commission  to Serial: RNP-RA/17-0014 46 Pages (including cover page)
ATTACHMENT 2 REPRINTED TECHNICAL SPECIFICATION PAGES
 
Rod Position Indication 3.1.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE                        FREQUENCY SR 3.1.7.1      Perform CHANNEL CALIBRATION of the ARPI  24 months System.
HBRSEP Unit No. 2                    3.1-18              Amendment No.
 
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                FREQUENCY SR 3.3.1.9      ------------------------------NOTE-------------------------------
Verification of setpoint is not required.
Perform TADOT.                                                        92 days SR 3.3.1.10    -------------------------------NOTE------------------------------
This Surveillance shall include verification that the time constants are adjusted to the prescribed values where applicable.
Perform CHANNEL CALIBRATION.                                          24 months SR 3.3.1.11    -------------------------------NOTE------------------------------
Neutron detectors are excluded from CHANNEL CALIBRATION.
Perform CHANNEL CALIBRATION.                                          24 months SR 3.3.1.12    -------------------------------NOTE------------------------------
This Surveillance shall include verification that the electronic dynamic compensation time constants are set at the required values, and verification of RTD response time constants.
Perform CHANNEL CALIBRATION.                                          24 months SR 3.3.1.13    Perform COT.                                                          24 months (continued)
HBRSEP Unit No. 2                                3.3-11                              Amendment No.
 
RPS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                FREQUENCY SR 3.3.1.14    ------------------------------NOTE------------------------------
Verification of setpoint is not required.
Perform TADOT.                                                        24 months SR 3.3.1.15    ------------------------------NOTE------------------------------      -------NOTE--------
Verification of setpoint is not required.                            Only required
                --------------------------------------------------------------------  when not performed within previous 31 days Perform TADOT.                                                        Prior to reactor startup HBRSEP Unit No. 2                                3.3-12                              Amendment No.
 
ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS
-----------------------------------------------------NOTES-------------------------------------------------------------
: 1. Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.
: 2. When a channel or train is placed in an inoperable status solely for the performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours provided the redundant train is OPERABLE.
SURVEILLANCE                                                      FREQUENCY SR 3.3.2.1              Perform CHANNEL CHECK.                                                    12 hours SR 3.3.2.2              Perform ACTUATION LOGIC TEST.                                              31 days on a STAGGERED TEST BASIS SR 3.3.2.3              Perform MASTER RELAY TEST.                                                24 months SR 3.3.2.4              Perform COT.                                                              92 days SR 3.3.2.5              Perform SLAVE RELAY TEST.                                                  24 months SR 3.3.2.6              ---------------------------NOTE-----------------------------
Verification of setpoint not required for manual initiation functions.
Perform TADOT.                                                            24 months SR 3.3.2.7              Perform CHANNEL CALIBRATION.                                              24 months HBRSEP Unit No. 2                                          3.3-24                                Amendment No.
 
PAM Instrumentation 3.3.3 ACTIONS (continued)
CONDITION                                REQUIRED ACTION                          COMPLETION TIME G. As required by Required                G.1          Initiate action in Immediately Action E.1 and referenced                            accordance with in Table 3.3.3-1.                                    Specification 5.6.6.
SURVEILLANCE REQUIREMENTS
----------------------------------------------------------NOTE-----------------------------------------------------------
SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1; except Functions 9, 22, 23, and 24. SR 3.3.3.3 applies only to Functions 9, 22, 23, and 24.
SURVEILLANCE                                                      FREQUENCY SR 3.3.3.1              Perform CHANNEL CHECK for each required                                    31 days instrumentation channel that is normally energized.
SR 3.3.3.2              ----------------------------NOTE-------------------------------            24 months Neutron detectors are excluded from CHANNEL CALIBRATION.
Perform CHANNEL CALIBRATION.
SR 3.3.3.3              ----------------------------NOTE------------------------------            24 months Verification of setpoint not required.
Perform TADOT.
HBRSEP Unit No. 2                                          3.3-31                                Amendment No.
 
Remote Shutdown System 3.3.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.3.4.1      Perform CHANNEL CHECK for each required                                31 days instrumentation channel that is normally energized.
SR 3.3.4.2      Verify each required control circuit and transfer                      24 months switch is capable of performing the intended function.
SR 3.3.4.3      ----------------------------NOTE---------------------------------
Neutron detectors are excluded from CHANNEL CALIBRATION.
Perform CHANNEL CALIBRATION for each required                          24 months instrumentation channel.
SR 3.3.4.4      Perform TADOT of the reactor trip                                      24 months breaker open/closed indication.
HBRSEP Unit No. 2                                3.3-34                              Amendment No.
 
LOP DG Start Instrumentation 3.3.5 ACTIONS CONTINUED (continued)
CONDITION                              REQUIRED ACTION                      COMPLETION TIME D. Required Action and                D.1          Enter applicable                Immediately associated Completion                          Condition(s) and Time not met.                                  Required Action(s) for the associated DG made inoperable by LOP DG start instrumentation.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                FREQUENCY SR 3.3.5.1      -----------------------------NOTE-----------------------------
Verification of setpoint not required.
Perform TADOT.                                                    24 months SR 3.3.5.2      Perform CHANNEL CALIBRATION with Trip                              24 months Setpoints as follows:
: a.      Loss of voltage Trip Setpoint of 328 V +/- 10%
with a time delay of 1 second (at zero voltage).
: b.      Degraded voltage Trip Setpoint of 430 V +/- 4 V with a time delay of 10 +/- 0.5 seconds.
HBRSEP Unit No. 2                                  3.3-36                            Amendment No.
 
Containment Ventilation Isolation Instrumentation 3.3.6 SURVEILLANCE REQUIREMENTS
-------------------------------------------------------NOTE--------------------------------------------------------------
Refer to Table 3.3.6-1 to determine which SRs apply for each Containment Ventilation Isolation Function.
SURVEILLANCE                                                      FREQUENCY SR 3.3.6.1              Perform CHANNEL CHECK.                                                    12 hours SR 3.3.6.2              Perform ACTUATION LOGIC TEST.                                              31 days on a STAGGERED TEST BASIS SR 3.3.6.3              Perform MASTER RELAY TEST.                                                24 months SR 3.3.6.4              Perform COT.                                                              92 days SR 3.3.6.5              Perform SLAVE RELAY TEST.                                                  24 months SR 3.3.6.6              ----------------------------NOTE--------------------------------
Verification of setpoint is not required.
Perform TADOT.                                                            24 months SR 3.3.6.7              Perform CHANNEL CALIBRATION.                                              24 months HBRSEP Unit No. 2                                          3.3-38                                Amendment No.
 
CREFS Actuation Instrumentation 3.3.7 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                      FREQUENCY SR 3.3.7.4      Perform MASTER RELAY CHECK.            24 months SR 3.3.7.5      Perform SLAVE RELAY TEST.              24 months SR 3.3.7.6      Perform CHANNEL CALIBRATION.            18 months HBRSEP Unit No. 2                    3.3-42            Amendment No.
 
Auxiliary Feedwater (AFW) System Instrumentation 3.3.8 SURVEILLANCE REQUIREMENTS
----------------------------------------------------------NOTE-----------------------------------------------------------
Refer to Table 3.3.8-1 to determine which SRs apply for each AFW Function.
SURVEILLANCE                                                      FREQUENCY SR 3.3.8.1              Perform CHANNEL CHECK.                                                    12 hours SR 3.3.8.2              Perform COT.                                                              92 days SR 3.3.8.3              ----------------------------NOTE--------------------------------
For Function 5, the TADOT shall include injection of a simulated or actual signal to verify channel OPERABILITY.
Perform TADOT.                                                            24 months SR 3.3.8.4              Perform CHANNEL CALIBRATION.                                              24 months HBRSEP Unit No. 2                                          3.3-46                                Amendment No.
 
RCS Pressure, Temperature, and Flow DNB Limits 3.4.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                FREQUENCY SR 3.4.1.1      Verify pressurizer pressure is greater than or equal to                12 hours the limit specified in the COLR.
SR 3.4.1.2      Verify RCS average temperature is less than or equal                  12 hours to the limit specified in the COLR.
SR 3.4.1.3      Verify RCS total flow rate is  97.3 x 106 lbm/hr and                  12 hours greater than or equal to the limit specified in the COLR.
SR 3.4.1.4      ---------------------------NOTE---------------------------------
Not required to be performed until 24 hours after 90% RTP.
Verify by precision heat balance that RCS total flow                  24 months rate is  97.3 x 106 lbm/hr and greater than or equal to the limit specified in the COLR.
HBRSEP Unit No. 2                                  3.4-2                              Amendment No.
 
Pressurizer 3.4.9 CONDITION                      REQUIRED ACTION            COMPLETION TIME D. Required Action and          D.1      Be in MODE 3.          6 hours associated Completion Time of Condition B or C      AND not met.
D.2      Be in MODE 4.          12 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                  FREQUENCY SR 3.4.9.1      Verify pressurizer water level is within limits. 12 hours SR 3.4.9.2      Verify capacity of required pressurizer heaters is 24 months 125 kW.
SR 3.4.9.3      Verify required pressurizer heaters are            24 months capable of being powered from an emergency power supply.
HBRSEP Unit No. 2                          3.4-22                  Amendment No.
 
Pressurizer PORVs 3.4.11 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                FREQUENCY SR 3.4.11.2    ------------------------------NOTE-----------------------------
Not required to be performed until 12 hours after entry into MODE 3.
Perform a complete cycle of each PORV.                                24 months SR 3.4.11.3    Perform a complete cycle of each solenoid                            24 months air control valve and check valve on the nitrogen accumulators in PORV control systems.
SR 3.4.11.4    Verify accumulators are capable of operating PORVs                    24 months through a complete cycle.
HBRSEP Unit No. 2                                3.4-28                            Amendment No.
 
LTOP System 3.4.12 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                              FREQUENCY SR 3.4.12.6    ---------------------------- NOTE-----------------------------
Not required to be performed until 12 hours after decreasing RCS cold leg temperature to  350&deg;F.
Perform a COT on each required PORV, excluding                      31 days actuation.
SR 3.4.12.7    Perform CHANNEL CALIBRATION for each required                        24 months PORV actuation channel.
HBRSEP Unit No. 2                                  3.4-34                          Amendment No.
 
RCS PIVs 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.4.14.1    --------------------------------NOTES---------------------------
: 1.      Not required to be performed in MODES 3 and 4.
: 2.      Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation.
: 3.      RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.
Verify leakage from each RCS PIV is less than or                      In accordance with equal to an equivalent of 5 gpm at an RCS pressure                    the Inservice 2235 psig, and verify the margin between the                        Testing Program results of the previous leak rate test and the 5 gpm                  and 24 months limit has not been reduced by  50% for valves with leakage rates > 1.0 gpm.                                              AND Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND (continued)
HBRSEP Unit No. 2                                3.4-39                              Amendment No.
 
RCS PIVs 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                  FREQUENCY SR 3.4.14.1 (continued)                                              Within 24 hours following valve actuation due to automatic or manual action or flow through the valve SR 3.4.14.2    Verify RHR System interlock prevents the valves from 24 months being opened with a simulated or actual RCS pressure signal > 474 psig.
HBRSEP Unit No. 2                        3.4-40                    Amendment No.
 
RCS Leakage Detection Instrumentation 3.4.15 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                  FREQUENCY SR 3.4.15.2    Perform COT of the required containment atmosphere  92 days radioactivity monitor.
SR 3.4.15.3    Perform CHANNEL CALIBRATION of the required        24 months containment sump monitor.
SR 3.4.15.4    Perform CHANNEL CALIBRATION of the required        24 months containment atmosphere radioactivity monitor.
SR 3.4.15.5    Perform CHANNEL CALIBRATION of the required        24 months containment fan cooler condensate flow rate monitor.
HBRSEP Unit No. 2                        3.4-44                  Amendment No.
 
CVCS 3.4.17 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                    FREQUENCY SR 3.4.17.1    Verify seal injection flow of  6 gpm to each RCP. 12 hours SR 3.4.17.2    Verify seal injection flow of  6 gpm to each RCP    24 months from each Makeup Water Pathway from the RWST.
SR 3.4.17.3    For Makeup Water Pathways from the RWST to be        In accordance with OPERABLE, SR 3.5.4.2 is applicable.                  SR 3.5.4.2 HBRSEP Unit No. 2                          3.4-51                  Amendment No.
 
ECCS - Operating 3.5.2 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                      FREQUENCY SR 3.5.2.3      Verify each ECCS pump's developed head at the test      In accordance with flow point is greater than or equal to the required      the Inservice developed head.                                          Testing Program SR 3.5.2.4      Verify each ECCS automatic valve in the flow path        24 months that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
SR 3.5.2.5      Verify each ECCS pump starts automatically on an        24 months actual or simulated actuation signal.
SR 3.5.2.6      Verify, by visual inspection, the ECCS containment      24 months sump suction inlet is not restricted by debris and the suction inlet strainers show no evidence of structural distress or abnormal corrosion.
(continued)
HBRSEP Unit No. 2                          3.5-6                      Amendment No.
 
Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY SR 3.6.3.2      --------------------------NOTE-----------------------------------
Valves and blind flanges in high radiation areas may be verified by use of administrative controls.
Verify each containment isolation manual valve and                      31 days for blind flange that is located outside containment and                    containment not locked, sealed or otherwise secured and required                    isolation manual to be closed during accident conditions is closed,                      valves (except except for containment isolation valves that are open                  Penetration under administrative controls.                                          Pressurization System valves with a diameter 3/8 inch) and blind flanges AND 24 months for Penetration Pressurization System valves with a diameter 3/8 inch SR 3.6.3.3      -----------------------NOTE--------------------------------------
Valves and blind flanges in high radiation areas may be verified by use of administrative means.
Verify each containment isolation manual valve and                      Prior to entering blind flange that is located inside containment and                    MODE 4 from not locked, sealed or otherwise secured and required                    MODE 5 if not to be closed during accident conditions is closed,                      performed within except for containment isolation valves that are open                  the previous under administrative controls.                                          92 days (continued)
HBRSEP Unit No. 2                                3.6-11                              Amendment No.
 
Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                      FREQUENCY SR 3.6.3.4      Verify the isolation time of each automatic power        In accordance operated containment isolation valve is within limits. with the Inservice Testing Program SR 3.6.3.5      Verify each automatic containment isolation valve        24 months that is not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.
SR 3.6.3.6      Verify each 42 inch inboard containment purge valve      24 months is blocked to restrict the valve from opening > 70&#xba;.
HBRSEP Unit No. 2                            3.6-12                  Amendment No.
 
Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                        FREQUENCY SR 3.6.6.2      Operate each containment cooling train fan unit for      31 days 15 minutes.
SR 3.6.6.3      Verify cooling water flow rate to each cooling unit is    31 days 750 gpm.
SR 3.6.6.4      Verify each containment spray pump's developed            In accordance with head at the flow test point is greater than or equal to  the Inservice the required developed head.                              Testing Program SR 3.6.6.5      Verify each automatic containment spray valve in the      24 months flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
SR 3.6.6.6      Verify each containment spray pump starts                24 months automatically on an actual or simulated actuation signal.
SR 3.6.6.7      Verify each containment cooling train starts              24 months automatically on an actual or simulated actuation signal.
SR 3.6.6.8      Verify each spray nozzle is unobstructed.                Following activities which could result in nozzle blockage HBRSEP Unit No. 2                          3.6-17                      Amendment No.
 
Spray Additive System 3.6.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                      FREQUENCY SR 3.6.7.1      Verify each spray additive manual, power operated,        31 days and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.
SR 3.6.7.2      Verify spray additive tank solution volume is            184 days 2505 gal.
SR 3.6.7.3      Verify spray additive tank NaOH solution                  184 days concentration is  30% by weight.
SR 3.6.7.4      Verify each spray additive automatic valve in the flow    24 months path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
HBRSEP Unit No. 2                          3.6-19                      Amendment No.
 
Isolation Valve Seal Water System 3.6.8 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                        FREQUENCY SR 3.6.8.3      Verify the opening time of each air operated            In accordance with header injection valve is within limits.                the Inservice Testing Program SR 3.6.8.4      Verify each automatic valve in the IVSW System          24 months actuates to the correct position on an actual or simulated actuation signal.
SR 3.6.8.5      Verify the IVSW dedicated nitrogen bottles will        24 months pressurize the IVSW tank to  46.2 psig.
SR 3.6.8.6      Verify total IVSW seal header flow rate is              24 months 124 cc/minute HBRSEP Unit No. 2                        3.6-21                      Amendment No.
 
AFW System 3.7.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                FREQUENCY SR 3.7.4.1      Verify each AFW manual, power operated, and                            31 days automatic valve in each water flow path, and in the steam supply flow path to the steam driven AFW pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.
SR 3.7.4.2      ----------------------------NOTE---------------------------------
Not required to be performed for the steam driven AFW pump until 24 hours after  1000 psig in the steam generator.
Verify the developed head of each AFW pump at the                      31 days on a flow test point is greater than or equal to the required              STAGGERED developed head.                                                        TEST BASIS SR 3.7.4.3      ----------------------------NOTE---------------------------------
Not applicable in MODE 4 when steam generator is being used for heat removal.
Verify each AFW automatic valve that is not locked,                    24 months sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
(continued)
HBRSEP Unit No. 2                                3.7-12                            Amendment No.
 
AFW System 3.7.4 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY SR 3.7.4.4      -------------------------NOTES----------------------------------
: 1. Not required to be performed for the steam driven AFW pump until 24 hours after  1000 psig in the steam generator.
: 2. Not applicable in MODE 4 when steam generator is being used for heat removal.
Verify each AFW pump starts automatically on an                        24 months actual or simulated actuation signal.
SR 3.7.4.5      --------------------------NOTE------------------------------------
Not required to be performed for the steam driven AFW pump until prior to entering MODE 1.
Verify proper alignment of the required                                Prior to entering AFW flow paths by verifying flow from the                              MODE 2, condensate storage tank to each steam generator.                        whenever unit has been in MODE 5 or 6 for > 30 days SR 3.7.4.6      Verify the AFW automatic bus transfer switch                            24 months associated with discharge valve V2-16A operates automatically on an actual or simulated actuation signal.
HBRSEP Unit No. 2                                3.7-13                              Amendment No.
 
CCW System 3.7.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.7.6.1      -------------------------------NOTE-------------------------------
Isolation of CCW flow to individual components does not render the CCW System inoperable.
Verify each required CCW manual, power operated,                        31 days and automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.
SR 3.7.6.2      Verify each required CCW pump starts automatically                    24 months on an actual or simulated LOP DG Start undervoltage signal.
HBRSEP Unit No. 2                                3.7-17                                Amendment No.
 
SWS 3.7.7 ACTIONS (continued)
CONDITION                                REQUIRED ACTION                        COMPLETION TIME C. Two Turbine Building loop            C.1          Close and deactivate              2 hours isolation valves inoperable.                      one inoperable Turbine Building loop isolation valve.
D. Required Actions and                D.1          Be in MODE 3.                      6 hours associated Completion Times of Conditions A, B,            AND or C not met.
D.2          Be in MODE 5.                      36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.7.7.1        --------------------------NOTE-----------------------------------
Isolation of SWS flow to individual components does not render the SWS inoperable.
Verify each SWS manual, power operated, and                              31 days automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.
SR 3.7.7.2        Verify each SWS automatic valve in the flow path that                    24 months is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
(continued)
HBRSEP Unit No. 2                                    3.7-19                              Amendment No.
 
SWS 3.7.7 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                    FREQUENCY SR 3.7.7.3      Verify each SWS pump and SWS booster pump              24 months starts automatically on an actual or simulated actuation signal.
SR 3.7.7.4      Verify the SWS automatic bus transfer switch            24 months associated with Turbine Building loop isolation valve V6-16C operates automatically on an actual or simulated actuation signal.
HBRSEP Unit No. 2                          3.7-20                      Amendment No.
 
CREFS 3.7.9 ACTIONS (continued)
CONDITION                        REQUIRED ACTION            COMPLETION TIME H. Required Action and          H.1        Be in MODE 3.          6 hours associated Completion Time of Condition G not      AND met in MODE 1, 2, 3, or 4.
H.2        Be in MODE 5.          36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                    FREQUENCY SR 3.7.9.1      Operate each CREFS train for  15 minutes.            31 days SR 3.7.9.2      Perform required CREFS filter testing in accordance    In accordance with with the Ventilation Filter Testing Program (VFTP). VFTP SR 3.7.9.3      Verify each CREFS train actuates on an actual or      24 months simulated actuation signal.
SR 3.7.9.4      Perform required CRE maintenance and testing in        In accordance with accordance with the CRE Habitability Program.          the CRE Habitability Program HBRSEP Unit No. 2                        3.7-24                    Amendment No.
 
CREATC 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                FREQUENCY SR 3.7.10.1    Verify each CREATC WCCU train has the capability  24 months to remove the assumed heat load.
HBRSEP Unit No. 2                      3.7-27                    Amendment No.
 
FBACS 3.7.11 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY SR 3.7.11.3    ---------------------------NOTE----------------------------------
Not required to be met when the only movement of irradiated fuel is movement of the spent fuel shipping cask containing irradiated fuel.
Verify the FBACS can maintain a negative pressure                      24 months with respect to atmospheric pressure.
HBRSEP Unit No. 2                                3.7-29                              Amendment No.
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY SR 3.8.1.6      Verify the fuel oil transfer system operates to                        31 days automatically transfer fuel oil from storage tank to the day tank.
SR 3.8.1.7      --------------------------NOTES--------------------------------
All DG starts may be preceded by an engine prelube period.
Verify each DG starts from standby condition and                        184 days achieves in  10 seconds, voltage  467 V and frequency  58.8 Hz, and after steady state conditions are reached, maintains voltage  467 V and  493 V and frequency  58.8 Hz and  61.2 Hz.
SR 3.8.1.8      ---------------------------NOTES-------------------------------
: 1.      This Surveillance shall not be performed in MODE 1 or 2.
: 2.      If performed with the DG synchronized with offsite power, it shall be performed at a power factor  0.9.
Verify each DG rejects a load greater than or equal to                  24 months its associated single largest post-accident load and does not trip on overspeed.
(continued)
HBRSEP Unit No. 2                                  3.8-6                              Amendment No.
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY SR 3.8.1.9      ----------------------------NOTES------------------------------
: 1.      All DG starts may be preceded by an engine prelube period.
: 2.      This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
: 3.      During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
Verify on an actual or simulated loss of offsite power                  24 months signal:
: a.      De-energization of emergency buses; b      Load shedding from emergency buses;
: c.      DG auto-starts from standby condition and:
: 1.      energizes permanently connected loads in  10 seconds,
: 2.      energizes auto-connected shutdown loads through automatic load sequencer,
: 3.      maintains steady state voltage 467 V and  493 V,
: 4.      maintains steady state frequency 58.8 Hz and  61.2 Hz, and
: 5.      supplies permanently connected and auto-connected shutdown loads for 5 minutes.
(continued)
HBRSEP Unit No. 2                                  3.8-7                              Amendment No.
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY SR 3.8.1.10    ---------------------------NOTES-------------------------------
1      All DG starts may be preceded by prelube period.
: 2.      This Surveillance shall not be performed in MODE 1 or 2.
: 3.      During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
Verify on an actual or simulated Engineered Safety                      24 months Feature (ESF) actuation signal each DG auto-starts from standby condition and:
: a.      In  10 seconds after auto-start achieves voltage  467 V, and after steady state conditions are reached, maintains voltage 467 V and  493 V;
: b.      In  10 seconds after auto-start achieves frequency  58.8 Hz, and after steady state conditions are reached, maintains frequency 58.8 Hz and  61.2 Hz;
: c.      Operates for  5 minutes;
: d.      Permanently connected loads remain energized from the offsite power system; and
: e.      Emergency loads are energized through the automatic load sequencer from the offsite power system.
(continued)
HBRSEP Unit No. 2                                  3.8-8                              Amendment No.
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY SR 3.8.1.11    Verify each DG's automatic trips are bypassed except engine overspeed.                                                24 months SR 3.8.1.12    ---------------------------NOTES--------------------------------
: 1.      Momentary transients outside the load and power factor ranges do not invalidate this test.
: 2.      This Surveillance shall not be performed in MODE 1 or 2.
: 3.      During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
Verify each DG operating at a power factor  0.9                        24 months operates for  24 hours:
: a.      For  1.75 hours loaded  2650 kW and 2750 kW; and
: b.      For the remaining hours of the test loaded 2400 kW and  2500 kW.
(continued)
HBRSEP Unit No. 2                                  3.8-9                              Amendment No.
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY SR 3.8.1.13    -------------------------------NOTES----------------------------
: 1.      This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated  2 hours loaded  2400 kW and 2500 kW.
Momentary transients outside of load range do not invalidate this test.
: 2.      All DG starts may be preceded by an engine prelube period.
Verify each DG starts and achieves, in  10 seconds,                    24 months voltage  467 V, and frequency  58.8 Hz, and after steady state conditions are reached, maintains voltage 467 V and  493 V and frequency  58.8 Hz and 61.2 Hz.
SR 3.8.1.14    -----------------------------NOTE--------------------------------
This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
Verify actuation of each sequenced load block is within                  24 months
                +/- 0.5 seconds of design setpoint for each emergency load sequencer.
(continued)
HBRSEP Unit No. 2                                  3.8-10                              Amendment No.
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY SR 3.8.1.15    ---------------------------NOTES--------------------------------
: 1. All DG starts may be preceded by an engine prelube period.
: 2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
: 3. During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
Verify on an actual or simulated loss of offsite power                  24 months signal in conjunction with an actual or simulated ESF actuation signal:
: a. De-energization of emergency buses;
: b. Load shedding from emergency buses; and
: c. DG auto-starts from standby condition and:
: 1. energizes permanently connected loads in 10 seconds,
: 2. energizes auto-connected emergency loads through load sequencer,
: 3. achieves steady state voltage  467 V and 493 V,
: 4. achieves steady state frequency  58.8 Hz and 61.2 Hz, and (continued)
HBRSEP Unit No. 2                                3.8-11                              Amendment No.
 
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.8.1.15 (continued)
: 5. supplies permanently connected and auto connected emergency loads for  5 minutes.
SR 3.8.1.16    -------------------------NOTE------------------------------------
: 1. This Surveillance shall not be performed in MODE 1 or 2.
: 2. SR 3.8.1.16 is not required to be met if 4.160 kV bus 2 and 480 V Emergency Bus 1 power supply is from the start up transformer.
Verify automatic transfer capability of the 4.160kV bus                  24 months 2 and the 480V Emergency bus 1 loads from the Unit auxiliary transformer to the start up transformer.
SR 3.8.1.17    ------------------------NOTE-------------------------------------
All DG starts may be preceded by an engine prelube period.
Verify when started simultaneously from standby                          10 years condition, each DG achieves, in  10 seconds, voltage 467 V and frequency  58.8 Hz, and after steady state conditions are reached, maintains voltage 467 V and  493 V and frequency  58.8 Hz and 61.2 Hz.
HBRSEP Unit No. 2                                3.8-12                              Amendment No.
 
DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                FREQUENCY SR 3.8.4.2      Verify battery cells, cell plates, and racks show no                  24 months visual indication of physical damage or abnormal deterioration that could degrade battery performance.
SR 3.8.4.3      Remove visible terminal corrosion, verify battery cell to            24 months cell and terminal connections are clean and tight, and are coated with anti-corrosion material.
SR 3.8.4.4      Verify each battery charger supplies  300 amps at                    24 months 125 V for  4 hours.
SR 3.8.4.5      -----------------------NOTES----------------------------------
: 1.      The modified performance discharge test in SR 3.8.4.6 may be performed in lieu of the service test in SR 3.8.4.5.
: 2.      This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
Verify battery capacity is adequate to supply, and                    24 months maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test.
(continued)
HBRSEP Unit No. 2                                3.8-20                            Amendment No.
 
Distribution Systems-Operating 3.8.9 ACTIONS (continued)
CONDITION                                REQUIRED ACTION                          COMPLETION TIME G. Two trains with inoperable            G.1          Enter LCO 3.0.3.                    Immediately distribution subsystems that result in a loss of safety function.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.8.9.1          ---------------------------NOTE----------------------------------
Actual voltage measurement is not required for the AC vital buses supplied from the constant voltage transformers.
Verify correct breaker alignments and voltage to AC,                    7 days DC, and AC instrument bus electrical power distribution subsystems.
SR 3.8.9.2          Verify capability of the two molded case circuit                        24 months breakers for AFW Header Discharge Valve to S/G "A", V2-16A to trip on overcurrent.
SR 3.8.9.3          Verify capability of the two molded case circuit                        24 months breakers for Service Water System Turbine Building Supply Valve (emergency supply), V6-16C to trip on overcurrent.
HBRSEP Unit No. 2                                    3.8-34                              Amendment No.
 
Nuclear Instrumentation 3.9.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.9.2.1      Perform CHANNEL CHECK.                                                  12 hours SR 3.9.2.2      ----------------------NOTE--------------------------------------
Neutron detectors are excluded from CHANNEL CALIBRATION.
Perform CHANNEL CALIBRATION.                                            24 months HBRSEP Unit No. 2                                3.9-3a                              Amendment No.
 
Containment Penetrations 3.9.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                    FREQUENCY SR 3.9.3.1      Verify each required containment penetration is in the  7 days required status.
SR 3.9.3.2      Verify each required containment ventilation valve      24 months actuates to the isolation position on an actual or simulated actuation signal.
HBRSEP Unit No. 2                          3.9-5                    Amendment No.
 
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.10      Secondary Water Chemistry Program (continued)
: b. Procedures used to measure the critical parameters;
: c. Requirements for the documentation and review of sample results;
: d. Procedures which identify the administrative events and corrective actions required to return the secondary chemistry to its normal control band following an out of control band condition; and
: e. Identification of the authority responsible for the interpretation of the sample results.
5.5.11      Ventilation Filter Testing Program (VFTP)
This program provides controls for implementation of the following required testing of Engineered Safety Feature (ESF) ventilation filter systems at the frequencies specified in Positions C.5 and C.6 of Regulatory Guide 1.52, Revision 2, March 1978, except that the testing specified at a frequency of 18 months is required at a frequency of 24 months, and conducted in general conformance with ANSI N510-1975 or N510-1980.
: a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows the specified penetration and system bypass leakage when tested in accordance with the referenced standard at the system flowrate specified below.
ESF Ventilation      Penetration System            /Bypass              Flowrate            Reference Std Control Room          <0.05%          3300 - 4150 ACFM        Regulatory Guide Emergency                                                      1.52, Revision 2, March 1978, C.5.a, C.5.c, C.5.d (using ANSI N510-1980)
Spent Fuel            <1%            11070- 13530 CFM        ANSI N510-1975 Building Containment          <1%            31500- 38500 CFM        ANSI N510-1975 Purge (continued)
HBRSEP                                          5.0-15                  Amendment No.
 
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.17      Control Room Envelope Habitability Program (continued)
: a. The definition of the CRE and the CRE boundary.
: b. Requirements for maintaining the CRE boundary in its design condition, including configuration control and preventive maintenance.
: c. Requirements for: (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.
The following exception is taken to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:
: 1.      Unfiltered air inleakage testing shall include the ability to deviate from the test methodology of ASTM-E741. These exceptions shall be documented in the test report.
: d. Measurement, at designated locations, of the CRE pressure relative to external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREFS, operating at the flow rate required by the VFTP, at a frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the assessment of the CRE boundary.
: e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.
The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. For hazardous chemicals, inleakage rates shall be less than assumed in the licensing bases.
: f. The provisions of SR 3.0.2 are applicable to the frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.
HBRSEP                                          5.0-22a                  Amendment No.
 
U. S. Nuclear Regulatory Commission  to Serial: RNP-RA/17-0014 58 Pages (including cover page)
ATTACHMENT 3 MARKED-UP TECHNICAL SPECIFICATION BASES PAGES
 
Rod Position Indication B 3.1.7 BASES ACTIONS          until power has been reduced to  50%, at which time the (continued)      Required Action C.2 would be met.
With one demand position indicator per bank inoperable, the rod positions can be determined by the ARPI System. Since normal power operation does not require excessive movement of rods, verification by administrative means that the rod position indicators are OPERABLE, that the position of each rod in the affected bank(s) is within 7.5 inches of the average of the individual rod positions in the affected bank(s), for bank positions < 200 steps and that the position of each rod in the affected bank(s) is within 15 inches of the bank demand position for bank positions 200 steps within the allowed Completion Time of once every 8 hours is adequate.
C.2 Reduction of THERMAL POWER to  50% RTP puts the core into a condition where rod position is not significantly affecting core peaking factors. The allowed Completion Time of 8 hours provides an acceptable period of time to verify the rod positions per Required Actions C.1.1 and C.1.2 or reduce power to  50% RTP.
D.1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours. The allowed Completion Time is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.
24 SURVEILLANCE      SR 3.1.7.1 REQUIREMENTS A CHANNEL CALIBRATION of the ARPI System is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to the measured parameter with the necessary range and accuracy. The 18 month Frequency is based on the need to perform this Surveillance under conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
24 (continued)
HBRSEP Unit No. 2                        B 3.1-47                              Revision No. 66
 
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE      SR 3.3.1.8 (continued)
REQUIREMENTS testing required by this surveillance must be performed prior to the expiration of the 4 hour limit. Four hours is a reasonable time to complete the required testing or place the unit in a MODE where this surveillance is no longer required. This test ensures that the NIS source, intermediate, and power range low channels are OPERABLE prior to taking the reactor critical and after reducing power into the applicable MODE (< P-10 or < P-
: 6) for periods > 4 hours.
SR 3.3.1.9 SR 3.3.1.9 is the performance of a TADOT and is performed every 92 days, as justified in Reference 7.
The SR is modified by a Note that excludes verification of setpoints from the TADOT. Since this SR applies to RCP undervoltage and underfrequency relays, setpoint verification requires elaborate bench calibration and is accomplished during the CHANNEL CALIBRATION.
24 SR 3.3.1.10 A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology (Ref. 8). The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 8).
The Frequency of 18 months is based on the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology (Ref. 8).
24 24 (continued)
HBRSEP Unit No. 2                          B 3.3-52                            Revision No. 0
 
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE      SR 3.3.1.10 (continued)
REQUIREMENTS SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. This Note applies to those Functions equipped with electronic dynamic compensation. Not all Functions to which SR 3.3.1.10 is applicable are equipped with electronic dynamic compensation.
SR 3.3.1.11                              24 SR 3.3.1.11 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10, every 18 months. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux map performed above 15% RTP. The CHANNEL CALIBRATION for the source range and intermediate range neutron detectors consists of obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data. This Surveillance is not required for the NIS 24      power range detectors for entry into MODE 2 or 1, and is not required for the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors. The 18 month Frequency is based on industry operating experience, considering instrument reliability and operating history data. Operating experience has shown these components usually pass the Surveillance when performed on the 18 month Frequency.
24 SR 3.3.1.12 24 SR 3.3.1.12 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10, every 18 months. For Table 3.3.1-1 Functions 5 and 6, the CHANNEL CALIBRATION shall include a narrow range RTD cross calibration. This SR is modified by a Note stating that this test shall include verification of the electronic dynamic compensation time constants and the RTD response time constants. The RCS (continued)
HBRSEP Unit No. 2                        B 3.3-53                              Revision No. 0
 
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE      SR 3.3.1.12 (continued)
REQUIREMENTS narrow range temperature sensors response time shall be  a 4.0 second lag time constant.
24 The Frequency is justified by the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.
SR 3.3.1.13 SR 3.3.1.13 is the performance of a COT of RPS interlocks every 24    18 months.
The Frequency is based on the known reliability of the interlocks and the multichannel redundancy available, and has been shown to be acceptable through operating experience.
24 SR 3.3.1.14 SR 3.3.1.14 is the performance of a TADOT of the Manual Reactor Trip, RCP Breaker Position, and the SI Input from ESFAS and the P-7 interlock. This TADOT is performed every 18 months. The test shall independently verify the OPERABILITY of the undervoltage and shunt trip mechanisms for the Manual Reactor Trip Function for the Reactor Trip Breakers and the undervoltage trip mechanism for the Reactor Trip Bypass Breakers.
The test shall also independently verify the OPERABILITY of the low power reactor trip block from the Power Range Neutron Flux (P-10) interlock and turbine first stage pressure. The TADOT verifies that when either the Turbine Impulse Pressure inputs or the Power Range Neutron Flux (P-10) interlock engage, reactor trips that are blocked by P-7 are enabled.
The Frequency is based on the known reliability of the Functions and the multichannel redundancy available, and has been shown to be acceptable through operating experience.
(continued)
HBRSEP Unit No. 2                        B 3.3-54                              Revision No. 0
 
ESFAS Instrumentation B 3.3.2 BASES BACKGROUND        ESFAS Automatic Initiation Logic (continued) completed, the system will send actuation signals via master and slave relays to those components whose aggregate Function best serves to alleviate the condition and restore the unit to a safe condition. Examples are given in the Applicable Safety Analyses, LCO, and Applicability sections of this Bases.
The actuation of ESF components is accomplished through master and slave relays. The ESFAS relay logic energizes the master relays appropriate for the condition of the unit. Each master relay then energizes one or more slave relays, which then cause actuation of the end devices. The master relays are routinely tested for continuity after performance of the ACTUATION LOGIC TEST. Each master and slave relay is tested at a Frequency of 18 months by initiation of the Function.
24 APPLICABLE        Each of the analyzed accidents can be detected by one or SAFETY            more ESFAS Functions. One of the ESFAS Functions is the ANALYSES, LCO,    primary actuation signal for that accident. An ESFAS and APPLICABILITY Function may be the primary actuation signal for more than one type of accident. An ESFAS Function may also be a secondary, or backup, actuation signal for one or more other accidents. For example, Pressurizer Pressure - Low is a primary actuation signal for small loss of coolant accidents (LOCAs) and a backup actuation signal for steam line breaks (SLBs) outside containment. Functions such as manual initiation, not specifically credited in the accident safety analysis, are qualitatively credited in the safety analysis and the NRC staff approved licensing basis for the unit. These Functions may provide protection for conditions that do not require dynamic transient analysis to demonstrate Function performance. These Functions may also serve as backups to Functions that were credited in the accident analysis (Ref. 3).
The LCO requires all instrumentation performing an ESFAS Function to be OPERABLE. Failure of any instrument renders the affected channel(s) inoperable and reduces the reliability of the affected Functions.
(continued)
HBRSEP Unit No. 2                        B 3.3-59                              Revision No. 0
 
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE      SR 3.3.2.1 (continued)
REQUIREMENTS instrumentation continues to operate properly between each CHANNEL CALIBRATION.
Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and reliability. 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.
The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
SR 3.3.2.2 SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST. The ESF relay logic is tested every 31 days on a STAGGERED TEST BASIS.
The train being tested is placed in the test condition. All possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is tested for continuity. This verifies that the logic modules are OPERABLE and that there is an intact voltage signal path to the master relay coils. The Frequency of every 31 days on a STAGGERED TEST BASIS is adequate. It is based on industry operating experience, considering instrument reliability and operating history data.
SR 3.3.2.3 SR 3.3.2.3 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay. The master relay is actuated by either a manual or automatic initiation of the function being tested. Contact operation is verified either by a continuity check of the circuit containing the master relay or proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 18 months. The 18 month Frequency is adequate, based on 24 24 (continued)
HBRSEP Unit No. 2                        B 3.3-87                                Revision No. 0
 
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE      SR 3.3.2.3 (continued)
REQUIREMENTS industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing.
SR 3.3.2.4 SR 3.3.2.4 is the performance of a COT.
A COT is performed on each required channel to ensure the entire channel, with the exception of the transmitter sensing device, will perform the intended Function. Setpoints must be found within the Allowable Values specified in Table 3.3.2-1.
The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 9). The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology (Ref. 9).
The "as found" and "as left" values must also be recorded and reviewed for consistency with the assumptions of the surveillance interval extension analysis in WCAP-10271-P-A (Ref. 8) when applicable.
The Frequency of 92 days is justified in Reference 8.
SR 3.3.2.5 SR 3.3.2.5 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified either by a continuity check of the circuit containing the slave relay, or by verification of proper operation of the end device during supported equipment simulated or actual automatic actuation test. This test is performed every 18 months. The 18 month Frequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing.
24              24 (continued)
HBRSEP Unit No. 2                        B 3.3-88                                Revision No. 0
 
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE      SR 3.3.2.6                                          24 REQUIREMENTS (continued)      SR 3.3.2.6 is the performance of a TADOT. This test is a check of Manual Actuation Functions. It is performed every 18 months. Each Manual Actuation Function is tested up to, and including, the master relay coils. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.). The Frequency is adequate, based on industry operating experience and is consistent with the typical refueling cycle.
The SR is modified by a Note that excludes verification of setpoints during the TADOT for manual initiation Functions. The manual initiation Functions have no associated setpoints.
SR 3.3.2.7                                                24 SR 3.3.2.7 is the performance of a CHANNEL CALIBRATION.
A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology (Ref. 9). The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology.        24                                    24 The Frequency of 18 months is based on the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology.
REFERENCES        1.        UFSAR, Chapter 6.
: 2.        UFSAR, Chapter 7.
: 3.        UFSAR, Chapter 15.
: 4.        UFSAR, Section 3.1.
(continued)
HBRSEP Unit No. 2                          B 3.3-89                            Revision No. 0
 
PAM Instrumentation B 3.3.3 BASES SURVEILLANCE      SR 3.3.3.1 (continued)
REQUIREMENTS should be compared to similar unit instruments located throughout the unit.
Channel deviation criteria are determined by the unit 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. If the channels are within the criteria, it is an indication that the channels are OPERABLE.
As specified in the SR, a CHANNEL CHECK is only required for those channels that are normally energized.
The Frequency of 31 days is based on operating experience that demonstrates that channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
24 SR 3.3.3.2 A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. This SR is modified by a Note that excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, "Reactor Protection System (RPS)
Instrumentation." The Frequency is based on operating experience and consistency with the typical industry refueling cycle.
SR 3.3.3.3 SR 3.3.3.3 is the performance of a TADOT of containment isolation valve position indication, PORV position (primary) indication, PORV block valve position (primary) indication, and safety valve position (primary) indication. This TADOT is performed every 18 months. The test shall independently 24 (continued)
HBRSEP Unit No. 2                        B 3.3-107                                Revision No. 0
 
Remote Shutdown System B 3.3.4 BASES SURVEILLANCE      SR 3.3.4.2 REQUIREMENTS (continued)      SR 3.3.4.2 verifies each required Remote Shutdown System control circuit and transfer switch performs the intended function. This verification is performed from the remote shutdown panel and locally, as appropriate.
Operation of the equipment from the remote shutdown panel is not necessary. The Surveillance can be satisfied by performance of  24a continuity check. This will ensure that if the control room becomes inaccessible, the unit can be placed and maintained in MODE 3 from the remote shutdown panel and the local control stations. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. (However, this Surveillance is not required to be performed only during a unit outage.) Operating experience demonstrates that remote shutdown control channels usually pass the Surveillance test when performed at the 18 month Frequency.
24 SR 3.3.4.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
The Frequency of 18 months is based upon operating experience and consistency with the typical industry refueling cycle.
24 SR 3.3.4.4                                                24 SR 3.3.4.4 is the performance of a TADOT every 18 months. This test should verify the OPERABILITY of the reactor trip breakers (RTBs) open and closed indication on the remote shutdown panel, by actuating the RTBs. The Frequency is based upon operating experience and consistency with the typical industry refueling outage.
REFERENCES        1.      UFSAR, Section 7.4.1.
HBRSEP Unit No. 2                      B 3.3-113                              Revision No. 0
 
LOP DG Start Instrumentation B 3.3.5 BASES ACTIONS          B.1 (continued)
The specified Completion Time and time allowed for tripping one channel are reasonable considering the Function remains fully OPERABLE on every bus and the low probability of an event occurring during these intervals.
C.1 Condition C applies when more than one degraded voltage channel on a single bus is inoperable.
Required Action C.1 requires restoring all but one channel on each bus to OPERABLE status. The 1 hour Completion Time should allow ample time to repair most failures and takes into account the low probability of an event requiring an LOP start occurring during this interval.
D.1 Condition D applies to each of the LOP DG start Functions when the Required Action and associated Completion Time for Condition A, B, or C are not met.
In these circumstances the Conditions specified in LCO 3.8.1, "AC Sources - Operating," or LCO 3.8.2, "AC Sources - Shutdown," for the DG made inoperable by failure of the LOP DG start instrumentation are required to be entered immediately. The actions of those LCOs provide for adequate compensatory actions to assure unit safety.
SURVEILLANCE      SR 3.3.5.1 REQUIREMENTS SR 3.3.5.1 is the performance of a TADOT. This test is performed every 24        18 months. The test checks trip devices that provide actuation signals directly, bypassing the analog process control equipment. The Frequency is based on the known reliability of the relays and controls and the multichannel redundancy available, and has been shown to be acceptable through operating experience.
(continued)
HBRSEP Unit No. 2                      B 3.3-119                              Revision No. 0
 
LOP DG Start Instrumentation B 3.3.5 BASES SURVEILLANCE      SR 3.3.5.1 (continued)
REQUIREMENTS The SR is modified by a Note that excludes verification of the setpoint from the TADOT. Setpoint verification is accomplished during the CHANNEL CALIBRATION.
SR 3.3.5.2 SR 3.3.5.2 is the performance of a CHANNEL CALIBRATION.
The setpoints, as well as the response to a loss of voltage and a degraded voltage test, should include a single point verification that the trip occurs within the required time delay, as shown in Reference 1.
24 A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
24      24 The Frequency of 18 months is based on operating experience and consistency with the typical industry refueling cycle and is justified by the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.
REFERENCES        1.      UFSAR, Section 8.3.
: 2.      Calculation RNP-E-8.002, AC Auxiliary Electrical Distribution System Voltage/Load Flow/Fault Current Study
: 3.      UFSAR, Chapter 15.
: 4.      EGR-NGGC-0153, Engineering Instrument Setpoints
: 5.      RNP-I/INST-1010, Emergency Bus - Degraded Grid Voltage Relay HBRSEP Unit No. 2                        B 3.3-120                            Revision No. 55
 
Containment Ventilation Isolation Instrumentation B 3.3.6 BASES SURVEILLANCE      SR 3.3.6.3 (continued)
REQUIREMENTS The master relay is actuated by either a manual or automatic initiation of the function being tested. Contact operation is verified either by a continuity check of the circuit containing the master relay or proper 24 operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 18 months.
The 18 month Frequency is adequate, based on industry operating 24  experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing.
SR 3.3.6.4 A COT is performed every 92 days on each required channel to ensure the entire channel will perform the intended Function. The Frequency is based on the staff recommendation for increasing the availability of radiation monitors according to NUREG-1366 (Ref. 2). This test verifies the capability of the radiation monitor instrumentation to initiate Containment Ventilation System isolation. The setpoint should be left consistent with the calibration procedure tolerance.
24 SR 3.3.6.5                        24 SR 3.3.6.5 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified either by a continuity check of the circuit containing the slave relay, or by verification of proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 18 months. The 18 month Frequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing.
SR 3.3.6.6 SR 3.3.6.6 is the performance of a TADOT. This test is a check of the Manual Actuation Functions and is performed (continued)
HBRSEP Unit No. 2                        B 3.3-126                              Revision No. 0
 
Containment Ventilation Isolation Instrumentation B 3.3.6 BASES (continued)
SURVEILLANCE      SR 3.3.6.6 (continued)          24 REQUIREMENTS every 18 months. Each Manual Actuation Function is tested up to, and including, the master relay coils. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.).
The test also includes trip devices that provide actuation signals directly to the relay logic, bypassing the analog process control equipment. The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Functions tested have no setpoints associated with them.
The Frequency is based on the known reliability of the Function and the redundancy available, and has been shown to be acceptable through operating experience.
24 SR 3.3.6.7 A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
The Frequency is based on operating experience and is consistent with the typical industry refueling cycle.
REFERENCES        1.      Deleted.
: 2.      NUREG-1366, "Improvements to Technical Specification Surveillance Requirements," December, 1992.
HBRSEP Unit No. 2                        B 3.3-127                            Revision No. 31
 
CREFS Actuation Instrumentation B 3.3.7 BASES SURVEILLANCE      SR 3.3.7.1 (continued)
REQUIREMENTS The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
SR 3.3.7.2 A COT is performed once every 92 days on the required radiation monitor channel to ensure the entire channel will perform the intended function.
This test verifies the capability of the instrumentation to provide actuation of both CREFS trains. The setpoint should be left consistent with the unit specific calibration procedure tolerance. The Frequency is based on the known reliability of the monitoring equipment and has been shown to be acceptable through operating experience.
SR 3.3.7.3 SR 3.3.7.3 is the performance of an ACTUATION LOGIC TEST. The train being tested is placed in the test condition. All possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is tested for continuity. This verifies that the logic modules are OPERABLE and there is an intact voltage signal path to the master relay coils. This test is performed every 31 days on a STAGGERED TEST BASIS. The Frequency is justified in WCAP-10271-P-A, Supplement 2, Rev. 1 (Ref. 1).
SR 3.3.7.4 SR 3.3.7.4 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay. The master relay is actuated by either a manual or automatic initiation of the function being tested. Contact operation is verified either by a continuity check of the circuit containing the master relay or proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 18 24 (continued)
HBRSEP Unit No. 2                        B 3.3-132                              Revision No. 0
 
CREFS Actuation Instrumentation B 3.3.7 BASES SURVEILLANCE      SR 3.3.7.4 (continued)
REQUIREMENTS months. The 18 month Frequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing.
24 SR 3.3.7.5 SR 3.3.7.5 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified either by a continuity check of the circuit containing the slave relay, or by verification of proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 18 months. The 18 month Frequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing.
24 24 SR 3.3.7.6 A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
The Frequency is based on operating experience and is consistent with the typical industry refueling cycle.
REFERENCES        1.      WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.
HBRSEP Unit No. 2                        B 3.3-133                              Revision No. 0
 
Auxiliary Feedwater (AFW) System Instrumentation B 3.3.8 BASES SURVEILLANCE      SR 3.3.8.1 (continued)
REQUIREMENTS that the sensor or the signal processing equipment has drifted outside its limit.
The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
SR 3.3.8.2 SR 3.3.8.2 is the performance of a COT. A COT is performed on each required channel to ensure the entire channel, with the exception of the transmitter sensing device, will perform the intended Function. Setpoints must be found within the tolerances and Allowable Values specified in Table 3.3.8-1.
The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 4). The setpoint must be left set consistent with the assumptions of the setpoint methodology (Ref. 4).
The "as found" and "as left" values must also be recorded and reviewed for consistency with the assumptions of the surveillance interval extension analysis in Reference 3 when applicable.
The Frequency of 92 days is justified in Reference 3.
SR 3.3.8.3                                                    24 SR 3.3.8.3 is the performance of a TADOT. This test is a check of AFW automatic pump start on loss of offsite power, undervoltage RCP, and trip of all MFW pumps Functions. It is performed every 18 months. Each applicable Actuation Function is tested up to, and including, the end device start circuitry. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.). As noted, this SR requires the injection of a simulated or actual signal for the Trip of Main Feedwater (continued)
HBRSEP Unit No. 2                        B 3.3-143                              Revision No. 0
 
Auxiliary Feedwater (AFW) System Instrumentation B 3.3.8 BASES SURVEILLANCE      SR 3.3.8.3 (continued)
REQUIREMENTS Pumps Function. The injection of the signal should be as close to the sensor as practical. The Frequency is adequate, based on industry operating experience and is consistent with the typical refueling cycle.
SR 3.3.8.4                                              24 SR 3.3.8.4 is the performance of a CHANNEL CALIBRATION. A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology (Ref. 4). The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 4).                                          24 24 The Frequency of 18 months is based on the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology (Ref. 4).
REFERENCES        1.        UFSAR, Section 7.3.1
: 2.        UFSAR, Section 3.1
: 3.        WCAP-10271-P-A, Supplement 2, Rev. 1., June 1990
: 4.        EGR-NGGC-0153, Engineering Instrument Setpoints HBRSEP Unit No. 2                        B 3.3-144                          Revision No. 55
 
RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 BASES SURVEILLANCE      SR 3.4.1.3 (continued)
REQUIREMENTS sufficient to regularly assess potential degradation and to verify operation within safety analysis assumptions.
SR 3.4.1.4                                    24 Measurement of RCS total flow rate by performance of a precision calorimetric heat balance once every 18 months allows the installed RCS flow instrumentation to be calibrated and verifies the actual RCS flow rate is greater than or equal to the minimum required RCS flow rate.
24 The Frequency of 18 months reflects the importance of verifying flow after a refueling outage when the core has been altered, which may have caused an alteration of flow resistance.
This SR is modified by a Note that allows entry into MODE 1, without having performed the SR, and placement of the unit in the best condition for performing the SR. The Note states that the SR is not required to be performed until 24 hours after $ 90% RTP. This exception is appropriate since the heat balance requires the plant to be at a minimum of 90% RTP to obtain the stated RCS flow accuracies. The Surveillance shall be performed within 24 hours after reaching 90% RTP.
REFERENCES        1.      UFSAR, Chapter 15.
: 2.      UFSAR, Section 4.4.2.
HBRSEP Unit No. 2                          B 3.4-5                              Revision No. 0
 
Pressurizer B 3.4.9 BASES SURVEILLANCE      SR 3.4.9.1 (continued)
REQUIREMENTS limit to provide a minimum space for a steam bubble. The Surveillance is performed by observing the indicated level. The Frequency of 12 hours corresponds to verifying the parameter each shift. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess level for any deviation and verify that operation is within safety analyses assumptions. Alarms are also available for early detection of abnormal level indications.
SR 3.4.9.2 The SR is satisfied when the power supplies are demonstrated to be capable of producing the minimum power and the associated pressurizer heaters are verified to be at their design rating. This may be done by testing the power supply output and heater current, or by performing an electrical check on heater element continuity and resistance. The Frequency of 18 months is considered adequate to detect heater degradation and has been shown by operating experience to be acceptable.
24 SR 3.4.9.3                            24 This Surveillance demonstrates that the heaters can be manually transferred from the normal to the emergency power supply and energized. The Frequency of 18 months is based on a typical fuel cycle and is consistent with similar verifications of emergency power supplies.
REFERENCES        1.      UFSAR, Chapter 15.
: 2.      NUREG-0737, November 1980.
HBRSEP Unit No. 2                        B 3.4-48                                Revision No. 0
 
Pressurizer PORVs B 3.4.11 BASES
 
SURVEILLANCE      SR 3.4.11.1 REQUIREMENTS Block valve cycling verifies that the valve(s) can be opened and closed if needed. The basis for the Frequency of 92 days is the ASME Code, Section XI (Ref. 3). If the block valve is closed to isolate a PORV that is capable of being manually cycled, the OPERABILITY of the block valve is of importance, because opening the block valve is necessary to permit the PORV to be used for manual control of reactor pressure. If the block valve is closed to isolate an inoperable PORV that is incapable of being manually cycled, the maximum Completion Time to restore the PORV and open the block valve is 72 hours, which is well within the allowable limits (25%) to extend the block valve Frequency of 92 days. Furthermore, these test requirements would be completed by the reopening of a recently closed block valve upon restoration of the PORV to OPERABLE status.
The Note modifies this SR by stating that it is not required to be met with the block valve closed, in accordance with the Required Action of this LCO.
SR 3.4.11.2 SR 3.4.11.2 requires a complete cycle of each PORV. Operating a PORV through one complete cycle ensures that the PORV can be manually actuated. Testing the PORVs in MODE 3 is required in order to simulate the temperature and pressure environmental effects on PORVs.
In the HBRSEP Unit No. 2 PORV design, testing in MODE 4 or MODE 5 is not considered to be a representative test for assessing PORV performance under normal plant operating conditions. The Frequency of 24      18 months is based on a typical refueling cycle and industry accepted practice.
The Note provides guidance to perform this SR within 12 hours of entering MODE 3. This allows adequate time to establish proper plant conditions and ensures the SR is performed in a timely manner.
(continued)
HBRSEP Unit No. 2                        B 3.4-59                                Revision No. 0
 
Pressurizer PORVs B 3.4.11 BASES
 
SURVEILLANCE      SR 3.4.11.3                                          24 REQUIREMENTS (continued)      Operating the solenoid air control valves and check valves on the nitrogen accumulators ensures the PORV control system actuates properly when called upon. The Frequency of 18 months is based on a typical refueling cycle and the Frequency of the other Surveillances used to demonstrate PORV OPERABILITY.
SR 3.4.11.4 The Surveillance demonstrates that the accumulators are capable of supplying sufficient nitrogen to operate the PORVs if they are needed for RCS pressure control, and normal nitrogen and the backup instrument air systems are not available. Backup instrument air is supplied when the accumulator reaches its low pressure setpoint. This SR must be performed by isolating the normal air and nitrogen supplies from the PORVs. The Frequency of 18 months is based on a typical refueling cycle and industry accepted practice.
REFERENCES        1.      UFSAR, Section 15.6.            24
: 2.      Generic Letter 90-06, "Resolution of Generic Issue 70, `Power-Operated Relief Valve and Block Valve Reliability,' and Generic Issue 94, `Additional Low-Temperature Overpressure Protection for Light-Water Reactors,' Pursuant to 10 CFR 50.54(f)," dated June 25, 1990.
: 3.      ASME, Boiler and Pressure Vessel Code, Section XI.
HBRSEP Unit No. 2                        B 3.4-60                              Revision No. 0
 
LTOP System B 3.4.12 BASES SURVEILLANCE      SR 3.4.12.6 (continued)
REQUIREMENTS To provide operators flexibility during MODE 4 transition activities a note has been added indicating that this SR is not required to be performed until 12 hours after decreasing RCS cold leg temperature to  350&deg;F. The 12 hour FREQUENCY considers the unlikelihood of a low temperature overpressure event during this time. The COT is required to be performed within 12 hours after entering the LTOP MODES when the PORV lift setpoint is reduced to the LTOP setting. The 31 day FREQUENCY considers experience with equipment reliability.
SR 3.4.12.7                                24 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every 18 months to adjust the whole channel so that it responds and the valve opens within the required range and accuracy to known input.
REFERENCES        1.      10 CFR 50, Appendix G.
: 2.      Generic Letter 88-11.
: 3.      UFSAR, Chapter 5.
: 4.      Letter, RNP-RA/96-0141, CP&L (R. M. Krich) to NRC, "Request for Technical Specifications Change, Conversion to Improved Standard Technical Specifications Consistent with NUREG-1431,
                          `Standard Technical Specifications-Westinghouse Plants,'
Revision 1," August 30, 1996, Enclosure 5.
: 5.      Letter, NG-77-1215, CP&L (B. J. Furr) to NRC (R. W. Reid),
                          "Reactor Vessel Overpressurization Protection," October 31, 1977.
: 6.      Letter, NG-77-1426, CP&L (E. E. Utley) to NRC (R. W. Reid),
                          "Response to Overpressure Protection System Questions,"
December 15, 1977.
(continued)
HBRSEP Unit No. 2                        B 3.4-74                            Revision No. 64
 
RCS PIVs B 3.4.14 BASES SURVEILLANCE      SR 3.4.14.1 (continued)
REQUIREMENTS To satisfy ALARA requirements, leakage may be measured indirectly (as from the performance of pressure indicators) if accomplished in accordance with approved procedures and supported by computations showing that the method is capable of demonstrating valve compliance with the leakage criteria. Leakage rates > 1.0 gpm and  5.0 gpm are considered unacceptable if the latest measured rate exceeds the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the 5.0 gpm limit by  50%.
Leakage rates > 5.0 gpm are considered to be unacceptable.
More than one valve may be tested in parallel. The combined leakage must be within the limits of this SR. In addition, the minimum differential pressure when performing the SR shall not be < 150 psid. For two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.
24 Testing is to be performed every 18 months, a typical refueling cycle.
Testing must also be performed once prior to entering MODE 2 whenever the unit has been in MODE 5 for at least 7 days if leakage testing has not been performed in the previous 9 months. The 18 month Frequency is consistent with the frequency allowed by the American Society of Mechanical Engineers (ASME) Code, Section XI (Ref. 6).
n addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PIVs disturbed in the performance of this Surveillance should also be tested unless it has been established per Note 3 that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours after the valve has been reseated if in MODES 1 or 2, or prior to entry into MODE 2 if not in MODES 1 or 2 at the end of the 24 hour period. Within 24 hours is a reasonable and practical time limit for performing this test after opening or reseating a valve.
(continued)
HBRSEP Unit No. 2                        B 3.4-87                              Revision No. 0
 
RCS PIVs B 3.4.14 BASES SURVEILLANCE      SR 3.4.14.1 (continued)
REQUIREMENTS The leakage limit is to be met at the RCS pressure associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures.
Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complementary to the Frequency of prior to entry into MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months. In addition, this Surveillance is not required to be performed on the RHR System when the RHR System is aligned to the RCS in the shutdown cooling mode of operation. PIVs contained in the RHR shutdown cooling flow path must be leakage rate tested after RHR is secured and stable unit conditions and the necessary differential pressures are established.
SR 3.4.14.2                                                          24 Verifying that the RHR interlock is OPERABLE ensures that RCS pressure will not pressurize the RHR system beyond 125% of its design pressure of 600 psig. The interlock setpoint prevents the valves from being opened and is set so the actual RCS pressure must be < 474 psig to open the valves. This setpoint ensures the RHR design pressure will not be exceeded and the RHR relief valves will not lift. The 18 month Frequency is based on the need to perform the Surveillance under conditions that apply during a plant outage. The 18 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.
24 REFERENCES        1.      10 CFR 50.2.
: 2.      10 CFR 50.55a(c).
: 3.      UFSAR, Section 3.1.
: 4.      WASH-1400 (NUREG-75/014), Appendix V, October 1975.
(continued)
HBRSEP Unit No. 2                        B 3.4-88                            Revision No. 0, 7 Amendment No. 182
 
RCS Leakage Detection Instrumentation B 3.4.15 BASES SURVEILLANCE      SR 3.4.15.3, SR 3.4.15.4, and SR 3.4.15.5 REQUIREMENTS (continued)      These SRs require the performance of a CHANNEL CALIBRATION for each of the required RCS leakage detection instrumentation channels.
The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 18 months is a typical refueling cycle and considers channel reliability.            24 Again, operating experience has proven that this Frequency is acceptable.
REFERENCES        1.      UFSAR, Section 3.1.
: 2.      UFSAR, Section 5.2.
HBRSEP Unit No. 2                        B 3.4-97                              Revision No. 39
 
CVCS B 3.4.17 BASES ACTIONS          F.1 and F.3 (continued) required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE      SR 3.4.17.1 REQUIREMENTS Verification of seal injection to the RCP seals ensures that adequate cooling to the RCP seals is maintained. Verification of seal injection flow is accomplished by direct measurement of seal injection flow or by other means as defined in procedures. A 12 hour Frequency is considered reasonable in view of other administrative controls and the existence of plant alarms that will ensure that an undetected loss of seal injection for more than a short time is unlikely.
SR 3.4.17.2                                24 Verification of seal injection flow to the RCP seals via the Makeup Water Pathways ensures that adequate cooling to the RCP seals can be maintained from the RWST. An 18 month Frequency is considered reasonable considering the unlikely failure mechanisms associated with passive piping and operation of the two valves.
Verification of OPERABILITY of the Makeup Water Pathways from the RWST is also satisfied by SR 3.5.4.2, which verifies an adequate inventory of makeup water.
REFERENCES        1.      UFSAR Paragraph 9.3.4.
: 2.      CP&L Letter to NRC, 'Submittal of Independent Plant Examination (IPE)," dated August 31, 1992.
HBRSEP Unit No. 2                        B 3.4-109                              Revision No. 0
 
ECCS - Operating B 3.5.2 BASES SURVEILLANCE      SR 3.5.2.4 and SR 3.5.2.5 (continued)          24 REQUIREMENTS simulated SI signal and that each ECCS pump starts on receipt of an actual or simulated SI signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for unplanned plant transients if the Surveillances were performed with the reactor at power. The 24        18 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.
The actuation logic is tested as part of ESF Actuation System testing, and equipment performance is monitored as part of the Inservice Testing Program.
24 SR 3.5.2.6 Periodic inspections of the containment sump suction inlet ensure that it is unrestricted and stays in proper operating condition. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage, on the need to have access to the location, and because of the potential for an unplanned transient if the Surveillance were performed with the reactor at power. This Frequency has been found to be sufficient to detect abnormal degradation and is confirmed by operating experience.
SR 3.5.2.7 Verification of proper valve position ensures the proper flow path is established for the LHSI system following operation in RHR mode. The Frequency of 31 days is commensurate with the accessibility and radiation levels involved in performing the surveillance (Ref. 6).
SR 3.5.2.8 Verification of proper valve position ensures the proper flow path is established for the LHSI system following operation in RHR mode. The Frequency of 92 days is based on (continued)
HBRSEP Unit No. 2                        B 3.5-19                              Revision No. 0
 
Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE      SR 3.6.3.1 (continued)
REQUIREMENTS safety related considerations (equipment or personnel) to support plant operations and maintenance activities within containment. Examples of this may include operating the valves to reduce activity to increase stay times, eliminate the need for respiratory protective equipment, reduce ambient temperatures during hot months, to increase the effectiveness of workers and to minimize occupational effects of necessary, non-routine activities in containment, or for Surveillances that require the valves to be open. The valves are capable of closing in the environment following a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The 31 day Frequency is consistent with other containment isolation valve requirements discussed in SR 3.6.3.3. Since it is not operationally necessary, it is desirable to preclude the 42 inch valves and 6 inch valves from being open at the same time. A Note to this SR restricts the 6 inch and 42 inch valves from being open simultaneously.
SR 3.6.3.2 This SR requires verification that each containment isolation manual valve and blind flange located outside containment and not locked, sealed or otherwise secured and required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits.
This SR does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown, that those containment isolation valves outside containment and capable of being mispositioned are in the correct position. Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day Frequency is applicable to containment isolation valves (except Penetration Pressurization System valves with a diameter  3/8 inch) and blind flanges. The 18 month Frequency is applicable to Penetration Pressurization System valves with a diameter  3/8 inch. These Frequencies are based on engineering judgment and were chosen to provide added assurance of the correct positions. The 18 month Frequency for Penetration Pressurization System valves  3/8 inch in diameter is considered acceptable based on the low                    24 24 (continued)
HBRSEP Unit No. 2                        B 3.6-22                              Revision No. 37
 
Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE      SR 3.6.3.3 (continued)
REQUIREMENTS administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, and 4, for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small.
SR 3.6.3.4 Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses.
The isolation time and Frequency of this SR are in accordance with the Inservice Testing (IST) Program. In addition to the IST program testing frequency, the 42 inch purge supply and exhaust valves will be tested prior to use if not tested within the previous quarter. Otherwise, the 42 inch purge supply and exhaust valves are not cycled quarterly only for testing purposes.
SR 3.6.3.5                              24 Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass this Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
24 (continued)
HBRSEP Unit No. 2                        B 3.6-24                              Revision No. 37
 
Containment Isolation Valves B 3.6.3 BASES
 
SURVEILLANCE      SR 3.6.3.6 REQUIREMENTS (continued)      Verifying that each 42 inch inboard containment purge valve is blocked to restrict opening to  70&#xba; is required to ensure that the valves can close under DBA conditions within the times assumed in the analyses of References 1 and 2. If a LOCA occurs, the purge valves must close to maintain containment leakage within the values assumed in the accident analysis. At other times when purge valves are required to be capable of closing (e.g., during movement of irradiated fuel assemblies),
pressurization concerns are not present, thus the purge valves can be fully open. The 18 month Frequency is appropriate because the blocking devices are typically removed only during a refueling outage.
REFERENCES        1.      UFSAR, Chapter 15.
: 2.      UFSAR, Section 6.2.
24
: 3.      Standard Review Plan 6.2.4.
HBRSEP Unit No. 2                        B 3.6-25                              Revision No. 37
 
Containment Spray and Cooling Systems B 3.6.6 BASES SURVEILLANCE      SR 3.6.6.3 (continued)
REQUIREMENTS train redundancy available, and the low probability of a significant degradation of flow occurring between surveillances.
SR 3.6.6.4 Verifying each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential pressure are normal tests of centrifugal pump performance required by Section XI of the ASME Code (Ref. 5). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on recirculation flow. This test confirms pump performance is consistent with the pump design curve and is indicative of overall performance, by setting the pump head and measuring the test flow. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of the SR is in accordance with the Inservice Testing Program.
SR 3.6.6.5 and SR 3.6.6.6                              24 These SRs require verification that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated actuation of a containment High - High pressure signal. SR 3.6.6.5 is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. SR 3.6.6.6 must be performed with the isolation valves in the spray supply lines at the containment and spray additive tank locked closed. The 18 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillances when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.                                  24 (continued)
HBRSEP Unit No. 2                        B 3.6-41                              Revision No. 0
 
Containment Spray and Cooling Systems B 3.6.6 BASES SURVEILLANCE      SR 3.6.6.7                  24 REQUIREMENTS (continued)      This SR requires verification that each containment cooling train actuates upon receipt of an actual or simulated safety injection signal. The 18 month Frequency is based on engineering judgment and has been shown to be acceptable through operating experience. See SR 3.6.6.5 and SR 3.6.6.6, above, for further discussion of the basis for the 18 month Frequency.
24 SR 3.6.6.8 With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and provides assurance that spray coverage of the containment during an accident is not degraded. Performance is required following activities which could result in nozzle blockage. Such activities may include: (1) a major configuration change; or (2) a loss of foreign material control such that the final condition of the system cannot be assured. The frequency is considered adequate due to the passive design of the nozzles, the stainless steel construction of the piping and nozzles, and the use of foreign material exclusion controls during system opening.
REFERENCES        1.      UFSAR, Section 3.1.
: 2.      10 CFR 50, Appendix K.
: 3.      UFSAR, Section 6.2.
: 4.      UFSAR, Section 9.4.
: 5.      ASME, Boiler and Pressure Vessel Code, Section XI.
HBRSEP Unit No. 2                        B 3.6-42                              Revision No. 22
 
Spray Additive System B 3.6.7 BASES SURVEILLANCE      SR 3.6.7.2 REQUIREMENTS (continued)      To provide effective iodine removal, the containment spray must be an alkaline solution. Since the RWST contents are normally acidic, the volume of the spray additive tank must provide a sufficient volume of spray additive to adjust pH for all water injected. This SR is performed to verify the availability of sufficient NaOH solution in the Spray Additive System. The 184 day Frequency was developed based on the low probability of an undetected change in tank volume occurring during the SR interval (the tank is isolated during normal unit operations). Tank level is also indicated and alarmed in the control room, so that there is high confidence that a substantial change in level would be detected.
SR 3.6.7.3 This SR provides verification of the NaOH concentration in the spray additive tank and is sufficient to ensure that the spray solution being injected into containment is at the correct pH level. The 184 day Frequency is sufficient to ensure that the concentration level of NaOH in the spray additive tank remains above the limit. This is based on the low likelihood of an uncontrolled change in concentration (the tank is normally isolated) and the probability that any substantial variance in tank volume will be detected.
SR 3.6.7.4 This SR provides verification that each automatic valve in the Spray Additive System flow path actuates to its correct position. This 24 Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls.
The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 24    18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
(continued)
HBRSEP Unit No. 2                          B 3.6-47                              Revision No. 0
 
IVSW System B 3.6.8 BASES SURVEILLANCE      SR 3.6.8.3 (continued)
REQUIREMENTS Program, and previous operating experience has shown that these valves usually pass the required test when performed.
SR 3.6.8.4                                                    24 This SR ensures that automatic header injection valves actuate to the correct position on a simulated or actual signal. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable.
24 SR 3.6.8.5 This SR ensures the capability of the dedicated nitrogen bottles to pressurize the IVSW system independent of the Plant Nitrogen System.
The 18 month Frequency is based on the need to perform this 24    Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
SR 3.6.8.6                                    24 Integrity of the IVSW seal boundary is important in providing assurance that the design leakage value required for the system to perform its sealing function is not exceeded. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
(continued)
HBRSEP Unit No. 2                        B 3.6-53                            Revision No. 0
 
AFW System B 3.7.4 BASES SURVEILLANCE      SR 3.7.4.2 (continued)
REQUIREMENTS (only required at 3 month intervals) satisfies this requirement. The 31 day Frequency on a STAGGERED TEST BASIS results in testing each pump once every 3 months, as required by Reference 4.
This SR is modified by a Note indicating that the SR should be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test.
SR 3.7.4.3 This SR verifies that AFW can be delivered to the appropriate steam generator in the event of any accident or transient that generates an AFW actuation signal, by demonstrating 24            that each automatic valve in the flow path actuates to its correct position on an actual or simulated actuation signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The 18 month Frequency is acceptable based on operating experience and the design reliability of the equipment.
24 This SR is modified by a Note that states the SR is not required in MODE 4 when AFW is being used for heat removal. In MODE 4, the required AFW train is already aligned and operating.
SR 3.7.4.4 This SR verifies that the AFW pumps will start in the event of any accident or transient that generates an AFW actuation (continued)
HBRSEP Unit No. 2                        B 3.7-29                              Revision No. 19
 
AFW System B 3.7.4 BASES SURVEILLANCE      SR 3.7.4.4 (continued)                              24 REQUIREMENTS signal by demonstrating that each AFW pump starts automatically on an actual or simulated actuation signal in MODES 1, 2, and 3. In MODE 4, the autostart function is not required. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
This SR is modified by two Notes. Note 1 indicates that the SR be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test.
Note 2 states that the SR is not required in MODE 4. In MODE 4, the heat removal requirements would be less providing more time for operator action to manually start the required AFW pump.
SR 3.7.4.5 This SR verifies proper AFW System alignment and flow path OPERABILITY from the CST to each SG following extended outages to determine that no misalignment of valves has occurred. The SR is performed prior to entering MODE 2 after more than 30 days in MODE 5 or 6. OPERABILITY of AFW flow paths must be verified before sufficient core heat is generated that would require the operation of the AFW System during a subsequent shutdown. The Frequency is reasonable, based on engineering judgment and other administrative controls that ensure that flow paths remain OPERABLE.
This SR is modified by a Note that allows entry into and operation in MODE 3 and MODE 2 prior to performing the SR for the steam driven AFW pump. This is necessary because sufficient decay heat is not available following an extended outage. The unit must be at a point of adding minimum core heat in order to provide sufficient steam to operate the steam driven AFW pump to verify water flow.
(continued)
HBRSEP Unit No. 2                        B 3.7-30                              Revision No. 0
 
AFW System B 3.7.4 BASES SURVEILLANCE      SR 3.7.4.6 REQUIREMENTS (continued)      This SR verifies that the automatic bus transfer switch associated with the "swing" motor driven AFW flow path discharge valve V2-16A will function properly to automatically transfer the power source from the aligned emergency power source to the other emergency power source upon loss of power to the aligned emergency power source. The Surveillance consists of two tests to assure that the switch will perform in either direction. One test is performed with the automatic bus transfer switch aligned to one emergency power source initially, and the test is repeated with the switch initially aligned to the other emergency power source.
Periodic testing of the switch is necessary to demonstrate OPERABILITY.
Operating experience has shown that this component usually passes the Surveillance when performed at the 18 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
 
REFERENCES        1.      UFSAR, Section 10.4.8.                24
: 2.      UFSAR, Section 15.2.8.
: 3.      UFSAR, Section 15.2.7.
: 2.      ASME, Boiler and Pressure Vessel Code, Section XI.
HBRSEP Unit No. 2                          B 3.7-31                            Revision No. 19
 
CCW System B 3.7.6 BASES ACTIONS          B.1 and B.2 (continued) allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE      SR 3.7.6.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the CCW flow to individual components may render those components inoperable but does not affect the OPERABILITY of the CCW System.
Verifying the correct alignment for manual, power operated, and automatic valves in the required CCW flow path provides assurance that the proper flow paths exist for CCW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.
The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.
SR 3.7.6.2 24 This SR verifies proper automatic operation of the required CCW pumps on an actual or simulated LOP DG start undervoltage signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the Surveillance when performed at (continued)
HBRSEP Unit No. 2                        B 3.7-39                          Revision No. 0, 14 Amendment 186
 
CCW System B 3.7.6 BASES                          24 SURVEILLANCE      SR 3.7.6.2 (continued)
REQUIREMENTS the 18 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
REFERENCES        1.        UFSAR, Section 9.2.2.
HBRSEP Unit No. 2                        B 3.7-40                        Revision No. 0
 
SWS B 3.7.7 BASES                                    24 SURVEILLANCE      SR 3.7.7.2 (continued)
REQUIREMENTS controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 24    18 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
SR 3.7.7.3 24 This SR verifies proper automatic operation of the SWS pumps and SWS booster pumps on an actual or simulated actuation signal. The SWS is a normally operating system that cannot be fully actuated as part of normal testing during normal operation. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
24 SR 3.7.7.4 This SR verifies that the automatic bus transfer switch associated with turbine building service water isolation valve V6-16C, will function properly to automatically transfer the power source from the aligned emergency power source to the other emergency power source upon loss of power to the aligned emergency power source. The surveillance consists of two tests to assure that the switch will perform in either direction. One test is performed with the automatic bus transfer switch aligned to one emergency power source initially, and the test is repeated with the switch initially aligned to the other emergency power source.
Periodic testing of the switch is necessary to demonstrate OPERABILITY.
Operating experience has shown that this component usually passes the Surveillance when performed at the 18 month Frequency.
24 (continued)
HBRSEP Unit No. 2                          B 3.7-46                              Revision No. 0
 
CREFS B 3.7.9 BASES SURVEILLANCE      SR 3.7.9.3                                                      24 REQUIREMENTS (continued)      This SR verifies that each CREFS train starts and operates on an actual or simulated actuation signal. The Frequency of 18 months is consistent with Position C.5 of Regulatory Guide 1.52 (Ref. 4). The 18 month Frequency is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency.
SR 3.7.9.4 This SR verifies the integrity of the CRE boundary. The CRE Habitability Program specifies administrative controls for temporary breaches to the boundary, preventative maintenance requirements to ensure the boundary is maintained, and leak test surveillance requirements. The details and frequencies for these requirements are specified in the CRE Habitability Program.
REFERENCES        1.      UFSAR, Section 6.4.
: 2.      UFSAR Section 6.4.2.3.
: 3.      UFSAR, Chapter 15.
: 4.      Regulatory Guide 1.52, Rev. 2, March 1978.
HBRSEP Unit No. 2                      B 3.7-58a                            Revision No. 48
 
CREATC B 3.7.10 BASES ACTIONS          F.1 and F.2 (continued)
In MODE 1, 2, 3, or 4, if both inoperable WCCU trains cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE      SR 3.7.10.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the heat load assumed in the control room. This SR consists of a combination of testing and calculations. The 18 month Frequency is appropriate since significant degradation of the WCCUs is slow and is not expected over this time period.
REFERENCES        1.      UFSAR, Section 6.4.                                24 HBRSEP Unit No. 2                        B 3.7-62                              Revision No. 0
 
FBACS B 3.7.11 BASES (continued)
SURVEILLANCE      SR 3.7.11.1 REQUIREMENTS The FBACS should be checked periodically to ensure that it functions properly. As the environmental and normal operating conditions on this system are not severe, testing once every month provides an adequate check on this system.
Monthly heater operation dries out any moisture accumulated in the charcoal from humidity in the ambient air. Systems with heaters must be operated for  10 continuous hours with the heaters operating in the automatic mode under humidistat control to maintain the relative humidity at the inlet of the charcoal bed  70%. The 31 day Frequency is based on the known reliability of the equipment.
SR 3.7.11.2 This SR verifies that the required FBACS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).
Specific test frequencies and additional information are discussed in detail in the VFTP.
SR 3.7.11.3                24 This SR verifies the integrity of the fuel building enclosure. The ability of the fuel building to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the FBACS. The FBACS is designed to maintain a slight negative pressure in the fuel building, to prevent unfiltered LEAKAGE.
The Frequency of 18 months is consistent with the guidance provided in NUREG-0800, Section 6.5.1 (Ref. 5).            with the refueling interval.
ISTS SR 3.7.13.4 is modified by a Note. This Note provides clarification that the Surveillance is not applicable when the only movement of irradiated fuel is movement of a spent fuel shipping cask containing irradiated fuel. This Note is necessary to permit the shipping cask to be removed from the fuel handling building. When the side walls are opened to (continued)
HBRSEP Unit No. 2                        B 3.7-65                              Revision No. 0
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.8 (continued)
REQUIREMENTS response characteristics and capability to reject the largest single load without exceeding the overspeed trip.
For this unit, the single load for each DG is a safety injection pump rated at 380 Brake Horsepower. This Surveillance may be accomplished by:
: a.      Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus; or
: b.      Tripping its associated single largest post-accident load with the 24        DG solely supplying the bus.
The 18 month Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 8).            1.9 revision 3 This SR is modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. In order to ensure that the DG is tested under load conditions that are as close to design basis conditions as possible, Note 2 requires that, if synchronized to offsite power, testing must be performed using a power factor  0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG would experience.
SR 3.8.1.9 This Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.
The DG autostart time of 10 seconds is derived from requirements of the accident analysis to respond to a design (continued)
HBRSEP Unit No. 2                          B 3.8-16                                Revision No. 0
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.9 (continued)
REQUIREMENTS basis large break LOCA. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability is achieved.
The requirement to verify the connection and power supply of permanent and auto connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, emergency Core Cooling Systems (ECCS) injection valves are not required to be stroked open, or high pressure injection systems are not capable of being operated at full flow, or residual heat removal (RHR) systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG systems to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
24 The Frequency of 18 months takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by three Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus.
This reduces exposure of the DG to undue risk of damage that might render it inoperable.
(continued)
HBRSEP Unit No. 2                        B 3.8-17                              Revision No. 0
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.10 REQUIREMENTS (continued)      This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (10 seconds) from the design basis actuation signal (LOCA signal) and operates for  5 minutes. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application. This period may extend beyond the 10 second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR, HBRSEP Unit No. 2 will monitor and trend the actual time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.10.d and SR 3.8.1.10.e ensure that permanently connected loads and emergency loads are energized from the offsite electrical power system on an ESF signal without loss of offsite power.
The requirement to verify the connection of permanent and autoconnected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, ECCS injection valves are not required to be stroked open, or high pressure injection systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
24 The Frequency of 18 months takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with the expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the (continued)
HBRSEP Unit No. 2                        B 3.8-18                                Revision No. 30
 
AC Sources - Operating B 3.8.1 BASES                                        10 SURVEILLANCE      SR 3.8.1.1 (continued)
REQUIREMENTS 24          18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by three Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus.
This reduces exposure of the DG to undue risk of damage that might render it inoperable.
SR 3.8.1.11 This Surveillance demonstrates that DG noncritical protective functions (e.g., high coolant water temperature) are bypassed. A manual switch is provided which bypasses the non-critical trips. The noncritical trips are normally bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG. This SR is satisfied by simulating a trip signal to each of the non-critical trip devices and observing the DG does not receive a trip signal.
The 24 month Frequency is based on engineering judgment and is intended to be consistent with DG maintenance interval. The equipment being tested is a manually-operated switch. Therefore, Frequency was concluded to be acceptable from a reliability standpoint.
(continued)
HBRSEP Unit No. 2                          B 3.8-19                              Revision No. 30
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.12                        24 REQUIREMENTS This SR requires demonstration once per 18 months that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours,  1.75 hours of which is at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG start shall be a manually initiated start followed by manual syncronization with other power sources.
Additionally, the DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.
In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed using a power factor of  0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG would experience.
The load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The 18 month Frequency takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
24 This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test.
Similarly, momentary power factor transients above the power factor limit will not invalidate the test. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.
Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus.
(continued)
HBRSEP Unit No. 2                        B 3.8-20                              Revision No. 30
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.12 (continued)
REQUIREMENTS This reduces exposure of the DG to undue risk of damage that might render it inoperable.
SR 3.8.1.13 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within 10 seconds. The 10 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application. This period may extend beyond the 10 second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR, HBRSEP Unit No. 2 will monitor and trend the actual time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 18 month Frequency is based on engineering judgment and is intended to be consistent with expected fuel cycle lengths.
24 This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The load band is provided to avoid routine overloading of the DG. Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The requirement that the diesel has operated for at least 2 hours at full load conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.
(continued)
HBRSEP Unit No. 2                        B 3.8-21                                Revision No. 0
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.14 REQUIREMENTS (continued)      Under accident and loss of offsite power conditions, loads are sequentially connected to the bus by the automatic load sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The
                  +/- 0.5 seconds load sequence time setpoint tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses. 24 The Frequency of 18 months takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.
SR 3.8.1.15 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.
This Surveillance demonstrates the DG operation, as discussed in the Bases for SR 3.8.1.9, during a loss of offsite power actuation test signal in conjunction with an ESF actuation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The Frequency of 18 months takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length of 18 months.
24            24 (continued)
HBRSEP Unit No. 2                        B 3.8-22                            Revision No. 0
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.15 (continued)
REQUIREMENTS This SR is modified by three Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations for DGs. The reason for Note 2 is that the performance of the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus.
This reduces exposure of the DG to undue risk of damage that might render it inoperable.
SR 3.8.1.16 Transfer of the 4.160 kV bus 2 power supply from the auxiliary transformer to the start up transformer demonstrates the OPERABILITY of the offsite circuit network to power the shutdown loads. In lieu of actually initiating a circuit transfer, testing that adequately shows the capability of the transfer is acceptable. This transfer testing may include any sequence of sequential, overlapping, or total steps so that the entire transfer sequence is verified. The 18 month Frequency is based on engineering judgement taking into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle length.                  24 This SR is modified by two Notes. The reason for Note 1 is that, during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. As stated in Note 2, automatic transfer capability to the SUT is not required to be met when the associated 4.160 kV bus and Emergency Bus are powered from the SUT. This is acceptable since the automatic transfer capability function has been satisfied in this condition.
(continued)
HBRSEP Unit No. 2                          B 3.8-23                                Revision No. 0
 
DC Sources - Operating B 3.8.4 ACTIONS            B.1 and B.2 (continued) required unit conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE      SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery (or battery cell) and maintain the battery (or a battery cell) in a fully charged state. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the initial voltages assumed in the battery sizing calculations and permit a single battery cell to be jumpered out.
The 7 day Frequency is consistent with manufacturer recommendations and IEEE-450 (Ref. 5).
SR 3.8.4.2 Visual inspection of the battery cells, cell plates, and battery racks provides an indication of physical damage or abnormal deterioration that 24 could potentially degrade battery performance.
The 18 month frequency is based on engineering judgment and operational experience and is sufficient to detect battery and rack degradation on a long term basis.
SR 3.8.4.3 Visual inspection of intercell, intertier, and terminal connections provide an indication of physical damage or abnormal deterioration that could indicate degraded battery condition. The anticorrosion material is used to help ensure good electrical connections and to reduce terminal deterioration. The visual inspection for corrosion is not intended to require removal of and inspection under each (continued)
HBRSEP Unit No. 2                        B 3.8-42                                Revision No. 0
 
DC Sources - Operating B 3.8.4 SURVEILLANCE      SR 3.8.4.3 (continued)
REQUIREMENTS terminal connection. The removal of visible corrosion is a preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR provided visible corrosion is removed during performance of SR 3.8.4.3.
The 18 month frequency is based on engineering judgment taking into consideration the likelihood of a change in component or system status.
24 SR 3.8.4.4 This SR requires that each battery charger be capable of supplying 300 amps and 125 V for  4 hours. These current and voltage requirements are based on the design capacity of the chargers. The battery charger supply is based on normal DC loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state. The minimum required amperes and duration ensures that these requirements can be satisfied.
The Surveillance Frequency is acceptable, given the other administrative controls existing to ensure adequate charger performance during these 24      18 month intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.
SR 3.8.4.5 A battery service test is a special test of battery capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length should correspond to the design duty cycle requirements.
This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test.
(continued)
HBRSEP Unit No. 2                        B 3.8-43                                Revision No. 29
 
Distribution Systems - Operating B 3.8.9 BASES                                    24 SURVEILLANCE      SR 3.8.9.2 and SR 3.8.9.3 REQUIREMENTS (continued)      The two breakers associated with each ABT will trip on over current as required to prevent fault from affecting both trains of the AC Distribution System. The 18 month Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions desirable for performing the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency.
Therefore the Frequency was concluded to be acceptable from a 24 reliability standpoint.
REFERENCES        1.        UFSAR, Chapter 6.
: 2.        UFSAR, Chapter 15.
: 3.        SER for HBRSEP Unit No. 2 Amendment 123, dated Sept. 5, 1989
: 4.        Regulatory Guide 1.93, December 1974.
HBRSEP Unit No. 2                          B 3.8-76                            Revision No. 0
 
Nuclear Instrumentation B 3.9.2 BASES SURVEILLANCE      SR 3.9.2.1 REQUIREMENTS SR 3.9.2.1 is the performance of a CHANNEL CHECK, which is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that the two indication channels should be consistent with core conditions. Changes in fuel loading and core geometry can result in significant differences between source range channels, but each channel should be consistent with its local conditions.
The Frequency of 12 hours is consistent with the CHANNEL CHECK Frequency specified similarly for the same instruments in LCO 3.3.1.
SR 3.9.2.2 SR 3.9.2.2 is the performance of a CHANNEL CALIBRATION every 24        18 months. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the source range neutron flux monitors consists of obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data. The CHANNEL CALIBRATION for the PAM source range neutron flux monitors only applies to the portion of the channel applicable to providing visual indication of neutron count rate in the Control Room. The 24        18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage. Operating experience has shown these components usually pass the Surveillance when performed at the 18 month Frequency.
24 REFERENCES        1.      UFSAR, Section 3.1.
: 2.      UFSAR, Section 15.4.6.
HBRSEP Unit No. 2                        B 3.9-7a                  Revision No. 5, 16, 17, 18 Amendment No. 180, 190
 
Containment Penetrations B 3.9.3 BASES SURVEILLANCE      SR 3.9.3.1 (continued)
REQUIREMENTS Accident involving handling recently irradiated fuel that releases fission product radioactivity within the containment will not result in a significant release of fission product radioactivity to the environment.
SR 3.9.3.2 24 This Surveillance demonstrates that each containment ventilation valve actuates to its isolation position on manual initiation or on an actual or simulated high radiation signal. The 18 month Frequency maintains consistency with other similar instrumentation and valve testing requirements. In LCO 3.3.6, the Containment Ventilation Isolation instrumentation requires a CHANNEL CHECK every 12 hours and a COT every 92 days to ensure the channel OPERABILITY during refueling operations. Every 18 months a CHANNEL CALIBRATION is performed.
The system actuation response time is demonstrated every 18 months, 24  during refueling, on a STAGGERED TEST BASIS. SR 3.6.3.5 24 demonstrates that the isolation time of each valve is in accordance with the Inservice Testing Program requirements. These Surveillances performed during MODE 6 will ensure that the valves are capable of closing after a postulated fuel handling accident involving handling recently irradiated fuel to limit a release of fission product radioactivity from the containment.
REFERENCES        1.      UFSAR, Section 15.7.4.
HBRSEP Unit No. 2                        B 3.9-12                              Revision No. 22
 
U. S. Nuclear Regulatory Commission  to Serial: RNP-RA/17-0014 58 Pages (including cover page)
ATTACHMENT 4 REPRINTED TECHNICAL SPECIFICATIONS BASES PAGES
 
Rod Position Indication B 3.1.7 BASES ACTIONS          until power has been reduced to  50%, at which time the (continued)      Required Action C.2 would be met.
With one demand position indicator per bank inoperable, the rod positions can be determined by the ARPI System. Since normal power operation does not require excessive movement of rods, verification by administrative means that the rod position indicators are OPERABLE, that the position of each rod in the affected bank(s) is within 7.5 inches of the average of the individual rod positions in the affected bank(s), for bank positions < 200 steps and that the position of each rod in the affected bank(s) is within 15 inches of the bank demand position for bank positions 200 steps within the allowed Completion Time of once every 8 hours is adequate.
C.2 Reduction of THERMAL POWER to  50% RTP puts the core into a condition where rod position is not significantly affecting core peaking factors. The allowed Completion Time of 8 hours provides an acceptable period of time to verify the rod positions per Required Actions C.1.1 and C.1.2 or reduce power to  50% RTP.
D.1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours. The allowed Completion Time is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE      SR 3.1.7.1 REQUIREMENTS A CHANNEL CALIBRATION of the ARPI System is performed every 24 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to the measured parameter with the necessary range and accuracy. The 24 month Frequency is based on the need to perform this Surveillance under conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
(continued)
HBRSEP Unit No. 2                        B 3.1-47                                  Revision No.
 
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE      SR 3.3.1.8 (continued)
REQUIREMENTS testing required by this surveillance must be performed prior to the expiration of the 4 hour limit. Four hours is a reasonable time to complete the required testing or place the unit in a MODE where this surveillance is no longer required. This test ensures that the NIS source, intermediate, and power range low channels are OPERABLE prior to taking the reactor critical and after reducing power into the applicable MODE (< P-10 or < P-
: 6) for periods > 4 hours.
SR 3.3.1.9 SR 3.3.1.9 is the performance of a TADOT and is performed every 92 days, as justified in Reference 7.
The SR is modified by a Note that excludes verification of setpoints from the TADOT. Since this SR applies to RCP undervoltage and underfrequency relays, setpoint verification requires elaborate bench calibration and is accomplished during the CHANNEL CALIBRATION.
SR 3.3.1.10 A CHANNEL CALIBRATION is performed every 24 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology (Ref. 8). The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 8).
The Frequency of 24 months is based on the assumption of an 24 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology (Ref. 8).
(continued)
HBRSEP Unit No. 2                          B 3.3-52                              Revision No.
 
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE      SR 3.3.1.10 (continued)
REQUIREMENTS SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. This Note applies to those Functions equipped with electronic dynamic compensation. Not all Functions to which SR 3.3.1.10 is applicable are equipped with electronic dynamic compensation.
SR 3.3.1.11 SR 3.3.1.11 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10, every 24 months. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux map performed above 15% RTP. The CHANNEL CALIBRATION for the source range and intermediate range neutron detectors consists of obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data. This Surveillance is not required for the NIS power range detectors for entry into MODE 2 or 1, and is not required for the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors. The 24 month Frequency is based on industry operating experience, considering instrument reliability and operating history data. Operating experience has shown these components usually pass the Surveillance when performed on the 24 month Frequency.
SR 3.3.1.12 SR 3.3.1.12 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10, every 24 months. For Table 3.3.1-1 Functions 5 and 6, the CHANNEL CALIBRATION shall include a narrow range RTD cross calibration. This SR is modified by a Note stating that this test shall include verification of the electronic dynamic compensation time constants and the RTD response time constants. The RCS (continued)
HBRSEP Unit No. 2                        B 3.3-53                                Revision No.
 
RPS Instrumentation B 3.3.1 BASES SURVEILLANCE      SR 3.3.1.12 (continued)
REQUIREMENTS narrow range temperature sensors response time shall be  a 4.0 second lag time constant.
The Frequency is justified by the assumption of a 24 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.
SR 3.3.1.13 SR 3.3.1.13 is the performance of a COT of RPS interlocks every 24 months.
The Frequency is based on the known reliability of the interlocks and the multichannel redundancy available, and has been shown to be acceptable through operating experience.
SR 3.3.1.14 SR 3.3.1.14 is the performance of a TADOT of the Manual Reactor Trip, RCP Breaker Position, and the SI Input from ESFAS and the P-7 interlock. This TADOT is performed every 24 months. The test shall independently verify the OPERABILITY of the undervoltage and shunt trip mechanisms for the Manual Reactor Trip Function for the Reactor Trip Breakers and the undervoltage trip mechanism for the Reactor Trip Bypass Breakers.
The test shall also independently verify the OPERABILITY of the low power reactor trip block from the Power Range Neutron Flux (P-10) interlock and turbine first stage pressure. The TADOT verifies that when either the Turbine Impulse Pressure inputs or the Power Range Neutron Flux (P-10) interlock engage, reactor trips that are blocked by P-7 are enabled.
The Frequency is based on the known reliability of the Functions and the multichannel redundancy available, and has been shown to be acceptable through operating experience.
(continued)
HBRSEP Unit No. 2                        B 3.3-54                                Revision No.
 
ESFAS Instrumentation B 3.3.2 BASES BACKGROUND        ESFAS Automatic Initiation Logic (continued) completed, the system will send actuation signals via master and slave relays to those components whose aggregate Function best serves to alleviate the condition and restore the unit to a safe condition. Examples are given in the Applicable Safety Analyses, LCO, and Applicability sections of this Bases.
The actuation of ESF components is accomplished through master and slave relays. The ESFAS relay logic energizes the master relays appropriate for the condition of the unit. Each master relay then energizes one or more slave relays, which then cause actuation of the end devices. The master relays are routinely tested for continuity after performance of the ACTUATION LOGIC TEST. Each master and slave relay is tested at a Frequency of 24 months by initiation of the Function.
APPLICABLE        Each of the analyzed accidents can be detected by one or SAFETY            more ESFAS Functions. One of the ESFAS Functions is the ANALYSES, LCO,    primary actuation signal for that accident. An ESFAS and APPLICABILITY Function may be the primary actuation signal for more than one type of accident. An ESFAS Function may also be a secondary, or backup, actuation signal for one or more other accidents. For example, Pressurizer Pressure - Low is a primary actuation signal for small loss of coolant accidents (LOCAs) and a backup actuation signal for steam line breaks (SLBs) outside containment. Functions such as manual initiation, not specifically credited in the accident safety analysis, are qualitatively credited in the safety analysis and the NRC staff approved licensing basis for the unit. These Functions may provide protection for conditions that do not require dynamic transient analysis to demonstrate Function performance. These Functions may also serve as backups to Functions that were credited in the accident analysis (Ref. 3).
The LCO requires all instrumentation performing an ESFAS Function to be OPERABLE. Failure of any instrument renders the affected channel(s) inoperable and reduces the reliability of the affected Functions.
(continued)
HBRSEP Unit No. 2                        B 3.3-59                                Revision No.
 
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE      SR 3.3.2.1 (continued)
REQUIREMENTS instrumentation continues to operate properly between each CHANNEL CALIBRATION.
Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and reliability. 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.
The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
SR 3.3.2.2 SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST. The ESF relay logic is tested every 31 days on a STAGGERED TEST BASIS.
The train being tested is placed in the test condition. All possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is tested for continuity. This verifies that the logic modules are OPERABLE and that there is an intact voltage signal path to the master relay coils. The Frequency of every 31 days on a STAGGERED TEST BASIS is adequate. It is based on industry operating experience, considering instrument reliability and operating history data.
SR 3.3.2.3 SR 3.3.2.3 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay. The master relay is actuated by either a manual or automatic initiation of the function being tested. Contact operation is verified either by a continuity check of the circuit containing the master relay or proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 24 months. The 24 month Frequency is adequate, based on (continued)
HBRSEP Unit No. 2                        B 3.3-87                                  Revision No.
 
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE      SR 3.3.2.3 (continued)
REQUIREMENTS industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing.
SR 3.3.2.4 SR 3.3.2.4 is the performance of a COT.
A COT is performed on each required channel to ensure the entire channel, with the exception of the transmitter sensing device, will perform the intended Function. Setpoints must be found within the Allowable Values specified in Table 3.3.2-1.
The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 9). The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology (Ref. 9).
The "as found" and "as left" values must also be recorded and reviewed for consistency with the assumptions of the surveillance interval extension analysis in WCAP-10271-P-A (Ref. 8) when applicable.
The Frequency of 92 days is justified in Reference 8.
SR 3.3.2.5 SR 3.3.2.5 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified either by a continuity check of the circuit containing the slave relay, or by verification of proper operation of the end device during supported equipment simulated or actual automatic actuation test. This test is performed every 24 months. The 24 month Frequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing.
(continued)
HBRSEP Unit No. 2                        B 3.3-88                                  Revision No.
 
ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE      SR 3.3.2.6 REQUIREMENTS (continued)      SR 3.3.2.6 is the performance of a TADOT. This test is a check of Manual Actuation Functions. It is performed every 24 months. Each Manual Actuation Function is tested up to, and including, the master relay coils. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.). The Frequency is adequate, based on industry operating experience and is consistent with the typical refueling cycle.
The SR is modified by a Note that excludes verification of setpoints during the TADOT for manual initiation Functions. The manual initiation Functions have no associated setpoints.
SR 3.3.2.7 SR 3.3.2.7 is the performance of a CHANNEL CALIBRATION.
A CHANNEL CALIBRATION is performed every 24 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology (Ref. 9). The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology.
The Frequency of 24 months is based on the assumption of an 24 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology.
REFERENCES        1.        UFSAR, Chapter 6.
: 2.        UFSAR, Chapter 7.
: 3.        UFSAR, Chapter 15.
: 4.        UFSAR, Section 3.1.
(continued)
HBRSEP Unit No. 2                          B 3.3-89                              Revision No.
 
PAM Instrumentation B 3.3.3 BASES SURVEILLANCE      SR 3.3.3.1 (continued)
REQUIREMENTS should be compared to similar unit instruments located throughout the unit.
Channel deviation criteria are determined by the unit 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. If the channels are within the criteria, it is an indication that the channels are OPERABLE.
As specified in the SR, a CHANNEL CHECK is only required for those channels that are normally energized.
The Frequency of 31 days is based on operating experience that demonstrates that channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
SR 3.3.3.2 A CHANNEL CALIBRATION is performed every 24 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. This SR is modified by a Note that excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, "Reactor Protection System (RPS)
Instrumentation." The Frequency is based on operating experience and consistency with the typical industry refueling cycle.
SR 3.3.3.3 SR 3.3.3.3 is the performance of a TADOT of containment isolation valve position indication, PORV position (primary) indication, PORV block valve position (primary) indication, and safety valve position (primary) indication. This TADOT is performed every 24 months. The test shall independently (continued)
HBRSEP Unit No. 2                        B 3.3-107                                  Revision No.
 
Remote Shutdown System B 3.3.4 BASES SURVEILLANCE      SR 3.3.4.2 REQUIREMENTS (continued)      SR 3.3.4.2 verifies each required Remote Shutdown System control circuit and transfer switch performs the intended function. This verification is performed from the remote shutdown panel and locally, as appropriate.
Operation of the equipment from the remote shutdown panel is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the unit can be placed and maintained in MODE 3 from the remote shutdown panel and the local control stations. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. (However, this Surveillance is not required to be performed only during a unit outage.) Operating experience demonstrates that remote shutdown control channels usually pass the Surveillance test when performed at the 24 month Frequency.
SR 3.3.4.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
The Frequency of 24 months is based upon operating experience and consistency with the typical industry refueling cycle.
SR 3.3.4.4 SR 3.3.4.4 is the performance of a TADOT every 24 months. This test should verify the OPERABILITY of the reactor trip breakers (RTBs) open and closed indication on the remote shutdown panel, by actuating the RTBs. The Frequency is based upon operating experience and consistency with the typical industry refueling outage.
REFERENCES        1.      UFSAR, Section 7.4.1.
HBRSEP Unit No. 2                      B 3.3-113                                Revision No.
 
LOP DG Start Instrumentation B 3.3.5 BASES ACTIONS          B.1 (continued)
The specified Completion Time and time allowed for tripping one channel are reasonable considering the Function remains fully OPERABLE on every bus and the low probability of an event occurring during these intervals.
C.1 Condition C applies when more than one degraded voltage channel on a single bus is inoperable.
Required Action C.1 requires restoring all but one channel on each bus to OPERABLE status. The 1 hour Completion Time should allow ample time to repair most failures and takes into account the low probability of an event requiring an LOP start occurring during this interval.
D.1 Condition D applies to each of the LOP DG start Functions when the Required Action and associated Completion Time for Condition A, B, or C are not met.
In these circumstances the Conditions specified in LCO 3.8.1, "AC Sources - Operating," or LCO 3.8.2, "AC Sources - Shutdown," for the DG made inoperable by failure of the LOP DG start instrumentation are required to be entered immediately. The actions of those LCOs provide for adequate compensatory actions to assure unit safety.
SURVEILLANCE      SR 3.3.5.1 REQUIREMENTS SR 3.3.5.1 is the performance of a TADOT. This test is performed every 24 months. The test checks trip devices that provide actuation signals directly, bypassing the analog process control equipment. The Frequency is based on the known reliability of the relays and controls and the multichannel redundancy available, and has been shown to be acceptable through operating experience.
(continued)
HBRSEP Unit No. 2                      B 3.3-119                                Revision No.
 
LOP DG Start Instrumentation B 3.3.5 BASES SURVEILLANCE      SR 3.3.5.1 (continued)
REQUIREMENTS The SR is modified by a Note that excludes verification of the setpoint from the TADOT. Setpoint verification is accomplished during the CHANNEL CALIBRATION.
SR 3.3.5.2 SR 3.3.5.2 is the performance of a CHANNEL CALIBRATION.
The setpoints, as well as the response to a loss of voltage and a degraded voltage test, should include a single point verification that the trip occurs within the required time delay, as shown in Reference 1.
A CHANNEL CALIBRATION is performed every 24 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
The Frequency of 24 months is based on operating experience and consistency with the typical industry refueling cycle and is justified by the assumption of an 24 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.
REFERENCES        1.      UFSAR, Section 8.3.
: 2.      Calculation RNP-E-8.002, AC Auxiliary Electrical Distribution System Voltage/Load Flow/Fault Current Study
: 3.      UFSAR, Chapter 15.
: 4.      EGR-NGGC-0153, Engineering Instrument Setpoints
: 5.      RNP-I/INST-1010, Emergency Bus - Degraded Grid Voltage Relay HBRSEP Unit No. 2                        B 3.3-120                                Revision No.
 
Containment Ventilation Isolation Instrumentation B 3.3.6 BASES SURVEILLANCE      SR 3.3.6.3 (continued)
REQUIREMENTS The master relay is actuated by either a manual or automatic initiation of the function being tested. Contact operation is verified either by a continuity check of the circuit containing the master relay or proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 24 months.
The 24 month Frequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing.
SR 3.3.6.4 A COT is performed every 92 days on each required channel to ensure the entire channel will perform the intended Function. The Frequency is based on the staff recommendation for increasing the availability of radiation monitors according to NUREG-1366 (Ref. 2). This test verifies the capability of the radiation monitor instrumentation to initiate Containment Ventilation System isolation. The setpoint should be left consistent with the calibration procedure tolerance.
SR 3.3.6.5 SR 3.3.6.5 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified either by a continuity check of the circuit containing the slave relay, or by verification of proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 24 months. The 24 month Frequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing.
SR 3.3.6.6 SR 3.3.6.6 is the performance of a TADOT. This test is a check of the Manual Actuation Functions and is performed (continued)
HBRSEP Unit No. 2                        B 3.3-126                                Revision No.
 
Containment Ventilation Isolation Instrumentation B 3.3.6 BASES (continued)
SURVEILLANCE      SR 3.3.6.6 (continued)
REQUIREMENTS Every 24 months. Each Manual Actuation Function is tested up to, and including, the master relay coils. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.).
The test also includes trip devices that provide actuation signals directly to the relay logic, bypassing the analog process control equipment. The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Functions tested have no setpoints associated with them.
The Frequency is based on the known reliability of the Function and the redundancy available, and has been shown to be acceptable through operating experience.
SR 3.3.6.7 A CHANNEL CALIBRATION is performed every 24 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
The Frequency is based on operating experience and is consistent with the typical industry refueling cycle.
REFERENCES        1.      Deleted.
: 2.      NUREG-1366, "Improvements to Technical Specification Surveillance Requirements," December, 1992.
HBRSEP Unit No. 2                        B 3.3-127                                Revision No.
 
CREFS Actuation Instrumentation B 3.3.7 BASES SURVEILLANCE      SR 3.3.7.1 (continued)
REQUIREMENTS The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
SR 3.3.7.2 A COT is performed once every 92 days on the required radiation monitor channel to ensure the entire channel will perform the intended function.
This test verifies the capability of the instrumentation to provide actuation of both CREFS trains. The setpoint should be left consistent with the unit specific calibration procedure tolerance. The Frequency is based on the known reliability of the monitoring equipment and has been shown to be acceptable through operating experience.
SR 3.3.7.3 SR 3.3.7.3 is the performance of an ACTUATION LOGIC TEST. The train being tested is placed in the test condition. All possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is tested for continuity. This verifies that the logic modules are OPERABLE and there is an intact voltage signal path to the master relay coils. This test is performed every 31 days on a STAGGERED TEST BASIS. The Frequency is justified in WCAP-10271-P-A, Supplement 2, Rev. 1 (Ref. 1).
SR 3.3.7.4 SR 3.3.7.4 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay. The master relay is actuated by either a manual or automatic initiation of the function being tested. Contact operation is verified either by a continuity check of the circuit containing the master relay or proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 24 (continued)
HBRSEP Unit No. 2                        B 3.3-132                                Revision No.
 
CREFS Actuation Instrumentation B 3.3.7 BASES SURVEILLANCE      SR 3.3.7.4 (continued)
REQUIREMENTS months. The 24 month Frequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing.
SR 3.3.7.5 SR 3.3.7.5 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified either by a continuity check of the circuit containing the slave relay, or by verification of proper operation of the end device during the supported equipment simulated or actual automatic actuation test. This test is performed every 24 months. The 24 month Frequency is adequate, based on industry operating experience, and is consistent with the typical refueling cycle, which provides the plant conditions necessary for testing.
SR 3.3.7.6 A CHANNEL CALIBRATION is performed every 18 months. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.
The Frequency is based on operating experience.
REFERENCES        1.      WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.
HBRSEP Unit No. 2                        B 3.3-133                                Revision No.
 
Auxiliary Feedwater (AFW) System Instrumentation B 3.3.8 BASES SURVEILLANCE      SR 3.3.8.1 (continued)
REQUIREMENTS that the sensor or the signal processing equipment has drifted outside its limit.
The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.
SR 3.3.8.2 SR 3.3.8.2 is the performance of a COT. A COT is performed on each required channel to ensure the entire channel, with the exception of the transmitter sensing device, will perform the intended Function. Setpoints must be found within the tolerances and Allowable Values specified in Table 3.3.8-1.
The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 4). The setpoint must be left set consistent with the assumptions of the setpoint methodology (Ref. 4).
The "as found" and "as left" values must also be recorded and reviewed for consistency with the assumptions of the surveillance interval extension analysis in Reference 3 when applicable.
The Frequency of 92 days is justified in Reference 3.
SR 3.3.8.3 SR 3.3.8.3 is the performance of a TADOT. This test is a check of AFW automatic pump start on loss of offsite power, undervoltage RCP, and trip of all MFW pumps Functions. It is performed every 24 months. Each applicable Actuation Function is tested up to, and including, the end device start circuitry. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.). As noted, this SR requires the injection of a simulated or actual signal for the Trip of Main Feedwater (continued)
HBRSEP Unit No. 2                        B 3.3-143                                Revision No.
 
Auxiliary Feedwater (AFW) System Instrumentation B 3.3.8 BASES SURVEILLANCE      SR 3.3.8.3 (continued)
REQUIREMENTS Pumps Function. The injection of the signal should be as close to the sensor as practical. The Frequency is adequate, based on industry operating experience and is consistent with the typical refueling cycle.
SR 3.3.8.4 SR 3.3.8.4 is the performance of a CHANNEL CALIBRATION. A CHANNEL CALIBRATION is performed every 24 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology (Ref. 4). The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology (Ref. 4).
The Frequency of 24 months is based on the assumption of an 24 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology (Ref. 4).
REFERENCES        1.        UFSAR, Section 7.3.1
: 2.        UFSAR, Section 3.1
: 3.        WCAP-10271-P-A, Supplement 2, Rev. 1., June 1990
: 4.        EGR-NGGC-0153, Engineering Instrument Setpoints HBRSEP Unit No. 2                        B 3.3-144                              Revision No.
 
RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 BASES SURVEILLANCE      SR 3.4.1.3 (continued)
REQUIREMENTS sufficient to regularly assess potential degradation and to verify operation within safety analysis assumptions.
SR 3.4.1.4 Measurement of RCS total flow rate by performance of a precision calorimetric heat balance once every 24 months allows the installed RCS flow instrumentation to be calibrated and verifies the actual RCS flow rate is greater than or equal to the minimum required RCS flow rate.
The Frequency of 24 months reflects the importance of verifying flow after a refueling outage when the core has been altered, which may have caused an alteration of flow resistance.
This SR is modified by a Note that allows entry into MODE 1, without having performed the SR, and placement of the unit in the best condition for performing the SR. The Note states that the SR is not required to be performed until 24 hours after $ 90% RTP. This exception is appropriate since the heat balance requires the plant to be at a minimum of 90% RTP to obtain the stated RCS flow accuracies. The Surveillance shall be performed within 24 hours after reaching 90% RTP.
REFERENCES        1.      UFSAR, Chapter 15.
: 2.      UFSAR, Section 4.4.2.
HBRSEP Unit No. 2                          B 3.4-5                                Revision No.
 
Pressurizer B 3.4.9 BASES SURVEILLANCE      SR 3.4.9.1 (continued)
REQUIREMENTS limit to provide a minimum space for a steam bubble. The Surveillance is performed by observing the indicated level. The Frequency of 12 hours corresponds to verifying the parameter each shift. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess level for any deviation and verify that operation is within safety analyses assumptions. Alarms are also available for early detection of abnormal level indications.
SR 3.4.9.2 The SR is satisfied when the power supplies are demonstrated to be capable of producing the minimum power and the associated pressurizer heaters are verified to be at their design rating. This may be done by testing the power supply output and heater current, or by performing an electrical check on heater element continuity and resistance. The Frequency of 24 months is considered adequate to detect heater degradation and has been shown by operating experience to be acceptable.
SR 3.4.9.3 This Surveillance demonstrates that the heaters can be manually transferred from the normal to the emergency power supply and energized. The Frequency of 24 months is based on a typical fuel cycle and is consistent with similar verifications of emergency power supplies.
REFERENCES        1.      UFSAR, Chapter 15.
: 2.      NUREG-0737, November 1980.
HBRSEP Unit No. 2                        B 3.4-48                                  Revision No.
 
Pressurizer PORVs B 3.4.11 BASES
 
SURVEILLANCE      SR 3.4.11.1 REQUIREMENTS Block valve cycling verifies that the valve(s) can be opened and closed if needed. The basis for the Frequency of 92 days is the ASME Code, Section XI (Ref. 3). If the block valve is closed to isolate a PORV that is capable of being manually cycled, the OPERABILITY of the block valve is of importance, because opening the block valve is necessary to permit the PORV to be used for manual control of reactor pressure. If the block valve is closed to isolate an inoperable PORV that is incapable of being manually cycled, the maximum Completion Time to restore the PORV and open the block valve is 72 hours, which is well within the allowable limits (25%) to extend the block valve Frequency of 92 days. Furthermore, these test requirements would be completed by the reopening of a recently closed block valve upon restoration of the PORV to OPERABLE status.
The Note modifies this SR by stating that it is not required to be met with the block valve closed, in accordance with the Required Action of this LCO.
SR 3.4.11.2 SR 3.4.11.2 requires a complete cycle of each PORV. Operating a PORV through one complete cycle ensures that the PORV can be manually actuated. Testing the PORVs in MODE 3 is required in order to simulate the temperature and pressure environmental effects on PORVs.
In the HBRSEP Unit No. 2 PORV design, testing in MODE 4 or MODE 5 is not considered to be a representative test for assessing PORV performance under normal plant operating conditions. The Frequency of 24 months is based on a typical refueling cycle and industry accepted practice.
The Note provides guidance to perform this SR within 12 hours of entering MODE 3. This allows adequate time to establish proper plant conditions and ensures the SR is performed in a timely manner.
(continued)
HBRSEP Unit No. 2                        B 3.4-59                                Revision No.
 
Pressurizer PORVs B 3.4.11 BASES
 
SURVEILLANCE      SR 3.4.11.3 REQUIREMENTS (continued)      Operating the solenoid air control valves and check valves on the nitrogen accumulators ensures the PORV control system actuates properly when called upon. The Frequency of 24 months is based on a typical refueling cycle and the Frequency of the other Surveillances used to demonstrate PORV OPERABILITY.
SR 3.4.11.4 The Surveillance demonstrates that the accumulators are capable of supplying sufficient nitrogen to operate the PORVs if they are needed for RCS pressure control, and normal nitrogen and the backup instrument air systems are not available. Backup instrument air is supplied when the accumulator reaches its low pressure setpoint. This SR must be performed by isolating the normal air and nitrogen supplies from the PORVs. The Frequency of 24 months is based on a typical refueling cycle and industry accepted practice.
REFERENCES        1.      UFSAR, Section 15.6.
: 2.      Generic Letter 90-06, "Resolution of Generic Issue 70, `Power-Operated Relief Valve and Block Valve Reliability,' and Generic Issue 94, `Additional Low-Temperature Overpressure Protection for Light-Water Reactors,' Pursuant to 10 CFR 50.54(f)," dated June 25, 1990.
: 3.      ASME, Boiler and Pressure Vessel Code, Section XI.
HBRSEP Unit No. 2                        B 3.4-60                                Revision No.
 
LTOP System B 3.4.12 BASES SURVEILLANCE      SR 3.4.12.6 (continued)
REQUIREMENTS To provide operators flexibility during MODE 4 transition activities a note has been added indicating that this SR is not required to be performed until 12 hours after decreasing RCS cold leg temperature to  350&deg;F. The 12 hour FREQUENCY considers the unlikelihood of a low temperature overpressure event during this time. The COT is required to be performed within 12 hours after entering the LTOP MODES when the PORV lift setpoint is reduced to the LTOP setting. The 31 day FREQUENCY considers experience with equipment reliability.
SR 3.4.12.7 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every 24 months to adjust the whole channel so that it responds and the valve opens within the required range and accuracy to known input.
REFERENCES        1.      10 CFR 50, Appendix G.
: 2.      Generic Letter 88-11.
: 3.      UFSAR, Chapter 5.
: 4.      Letter, RNP-RA/96-0141, CP&L (R. M. Krich) to NRC, "Request for Technical Specifications Change, Conversion to Improved Standard Technical Specifications Consistent with NUREG-1431,
                          `Standard Technical Specifications-Westinghouse Plants,'
Revision 1," August 30, 1996, Enclosure 5.
: 5.      Letter, NG-77-1215, CP&L (B. J. Furr) to NRC (R. W. Reid),
                          "Reactor Vessel Overpressurization Protection," October 31, 1977.
: 6.      Letter, NG-77-1426, CP&L (E. E. Utley) to NRC (R. W. Reid),
                          "Response to Overpressure Protection System Questions,"
December 15, 1977.
(continued)
HBRSEP Unit No. 2                        B 3.4-74                                Revision No.
 
RCS PIVs B 3.4.14 BASES SURVEILLANCE      SR 3.4.14.1 (continued)
REQUIREMENTS To satisfy ALARA requirements, leakage may be measured indirectly (as from the performance of pressure indicators) if accomplished in accordance with approved procedures and supported by computations showing that the method is capable of demonstrating valve compliance with the leakage criteria. Leakage rates > 1.0 gpm and  5.0 gpm are considered unacceptable if the latest measured rate exceeds the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the 5.0 gpm limit by  50%.
Leakage rates > 5.0 gpm are considered to be unacceptable.
More than one valve may be tested in parallel. The combined leakage must be within the limits of this SR. In addition, the minimum differential pressure when performing the SR shall not be < 150 psid. For two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.
Testing is to be performed every 24 months, a typical refueling cycle.
Testing must also be performed once prior to entering MODE 2 whenever the unit has been in MODE 5 for at least 7 days if leakage testing has not been performed in the previous 9 months.
n addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PIVs disturbed in the performance of this Surveillance should also be tested unless it has been established per Note 3 that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours after the valve has been reseated if in MODES 1 or 2, or prior to entry into MODE 2 if not in MODES 1 or 2 at the end of the 24 hour period. Within 24 hours is a reasonable and practical time limit for performing this test after opening or reseating a valve.
(continued)
HBRSEP Unit No. 2                        B 3.4-87                                Revision No.
 
RCS PIVs B 3.4.14 BASES SURVEILLANCE      SR 3.4.14.1 (continued)
REQUIREMENTS The leakage limit is to be met at the RCS pressure associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures.
Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complementary to the Frequency of prior to entry into MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months. In addition, this Surveillance is not required to be performed on the RHR System when the RHR System is aligned to the RCS in the shutdown cooling mode of operation. PIVs contained in the RHR shutdown cooling flow path must be leakage rate tested after RHR is secured and stable unit conditions and the necessary differential pressures are established.
SR 3.4.14.2 Verifying that the RHR interlock is OPERABLE ensures that RCS pressure will not pressurize the RHR system beyond 125% of its design pressure of 600 psig. The interlock setpoint prevents the valves from being opened and is set so the actual RCS pressure must be < 474 psig to open the valves. This setpoint ensures the RHR design pressure will not be exceeded and the RHR relief valves will not lift. The 24 month Frequency is based on the need to perform the Surveillance under conditions that apply during a plant outage. The 24 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.
REFERENCES        1.      10 CFR 50.2.
: 2.      10 CFR 50.55a(c).
: 3.      UFSAR, Section 3.1.
: 4.      WASH-1400 (NUREG-75/014), Appendix V, October 1975.
(continued)
HBRSEP Unit No. 2                        B 3.4-88                                Revision No.
 
RCS Leakage Detection Instrumentation B 3.4.15 BASES SURVEILLANCE      SR 3.4.15.3, SR 3.4.15.4, and SR 3.4.15.5 REQUIREMENTS (continued)      These SRs require the performance of a CHANNEL CALIBRATION for each of the required RCS leakage detection instrumentation channels.
The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 24 months is a typical refueling cycle and considers channel reliability.
Again, operating experience has proven that this Frequency is acceptable.
REFERENCES        1.      UFSAR, Section 3.1.
: 2.      UFSAR, Section 5.2.
HBRSEP Unit No. 2                        B 3.4-97                                Revision No.
 
CVCS B 3.4.17 BASES ACTIONS          F.1 and F.3 (continued) required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE      SR 3.4.17.1 REQUIREMENTS Verification of seal injection to the RCP seals ensures that adequate cooling to the RCP seals is maintained. Verification of seal injection flow is accomplished by direct measurement of seal injection flow or by other means as defined in procedures. A 12 hour Frequency is considered reasonable in view of other administrative controls and the existence of plant alarms that will ensure that an undetected loss of seal injection for more than a short time is unlikely.
SR 3.4.17.2 Verification of seal injection flow to the RCP seals via the Makeup Water Pathways ensures that adequate cooling to the RCP seals can be maintained from the RWST. An 24 month Frequency is considered reasonable considering the unlikely failure mechanisms associated with passive piping and operation of the two valves.
Verification of OPERABILITY of the Makeup Water Pathways from the RWST is also satisfied by SR 3.5.4.2, which verifies an adequate inventory of makeup water.
REFERENCES        1.      UFSAR Paragraph 9.3.4.
: 2.      CP&L Letter to NRC, 'Submittal of Independent Plant Examination (IPE)," dated August 31, 1992.
HBRSEP Unit No. 2                        B 3.4-109                                Revision No.
 
ECCS - Operating B 3.5.2 BASES SURVEILLANCE      SR 3.5.2.4 and SR 3.5.2.5 (continued)
REQUIREMENTS simulated SI signal and that each ECCS pump starts on receipt of an actual or simulated SI signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 24 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for unplanned plant transients if the Surveillances were performed with the reactor at power. The 24 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.
The actuation logic is tested as part of ESF Actuation System testing, and equipment performance is monitored as part of the Inservice Testing Program.
SR 3.5.2.6 Periodic inspections of the containment sump suction inlet ensure that it is unrestricted and stays in proper operating condition. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage, on the need to have access to the location, and because of the potential for an unplanned transient if the Surveillance were performed with the reactor at power. This Frequency has been found to be sufficient to detect abnormal degradation and is confirmed by operating experience.
SR 3.5.2.7 Verification of proper valve position ensures the proper flow path is established for the LHSI system following operation in RHR mode. The Frequency of 31 days is commensurate with the accessibility and radiation levels involved in performing the surveillance (Ref. 6).
SR 3.5.2.8 Verification of proper valve position ensures the proper flow path is established for the LHSI system following operation in RHR mode. The Frequency of 92 days is based on (continued)
HBRSEP Unit No. 2                        B 3.5-19                                Revision No.
 
Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE      SR 3.6.3.1 (continued)
REQUIREMENTS safety related considerations (equipment or personnel) to support plant operations and maintenance activities within containment. Examples of this may include operating the valves to reduce activity to increase stay times, eliminate the need for respiratory protective equipment, reduce ambient temperatures during hot months, to increase the effectiveness of workers and to minimize occupational effects of necessary, non-routine activities in containment, or for Surveillances that require the valves to be open. The valves are capable of closing in the environment following a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The 31 day Frequency is consistent with other containment isolation valve requirements discussed in SR 3.6.3.3. Since it is not operationally necessary, it is desirable to preclude the 42 inch valves and 6 inch valves from being open at the same time. A Note to this SR restricts the 6 inch and 42 inch valves from being open simultaneously.
SR 3.6.3.2 This SR requires verification that each containment isolation manual valve and blind flange located outside containment and not locked, sealed or otherwise secured and required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits.
This SR does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown, that those containment isolation valves outside containment and capable of being mispositioned are in the correct position. Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day Frequency is applicable to containment isolation valves (except Penetration Pressurization System valves with a diameter  3/8 inch) and blind flanges. The 24 month Frequency is applicable to Penetration Pressurization System valves with a diameter  3/8 inch. These Frequencies are based on engineering judgment and were chosen to provide added assurance of the correct positions. The 24 month Frequency for Penetration Pressurization System valves  3/8 inch in diameter is considered acceptable based on the low (continued)
HBRSEP Unit No. 2                        B 3.6-22                                Revision No.
 
Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE      SR 3.6.3.3 (continued)
REQUIREMENTS administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, and 4, for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small.
SR 3.6.3.4 Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses.
The isolation time and Frequency of this SR are in accordance with the Inservice Testing (IST) Program. In addition to the IST program testing frequency, the 42 inch purge supply and exhaust valves will be tested prior to use if not tested within the previous quarter. Otherwise, the 42 inch purge supply and exhaust valves are not cycled quarterly only for testing purposes.
SR 3.6.3.5 Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass this Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
(continued)
HBRSEP Unit No. 2                        B 3.6-24                                  Revision No.
 
Containment Isolation Valves B 3.6.3 BASES
 
SURVEILLANCE      SR 3.6.3.6 REQUIREMENTS (continued)      Verifying that each 42 inch inboard containment purge valve is blocked to restrict opening to  70&#xba; is required to ensure that the valves can close under DBA conditions within the times assumed in the analyses of References 1 and 2. If a LOCA occurs, the purge valves must close to maintain containment leakage within the values assumed in the accident analysis. At other times when purge valves are required to be capable of closing (e.g., during movement of irradiated fuel assemblies),
pressurization concerns are not present, thus the purge valves can be fully open. The 24 month Frequency is appropriate because the blocking devices are typically removed only during a refueling outage.
REFERENCES        1.      UFSAR, Chapter 15.
: 2.      UFSAR, Section 6.2.
: 3.      Standard Review Plan 6.2.4.
HBRSEP Unit No. 2                        B 3.6-25                                Revision No.
 
Containment Spray and Cooling Systems B 3.6.6 BASES SURVEILLANCE      SR 3.6.6.3 (continued)
REQUIREMENTS train redundancy available, and the low probability of a significant degradation of flow occurring between surveillances.
SR 3.6.6.4 Verifying each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential pressure are normal tests of centrifugal pump performance required by Section XI of the ASME Code (Ref. 5). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on recirculation flow. This test confirms pump performance is consistent with the pump design curve and is indicative of overall performance, by setting the pump head and measuring the test flow. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of the SR is in accordance with the Inservice Testing Program.
SR 3.6.6.5 and SR 3.6.6.6 These SRs require verification that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated actuation of a containment High - High pressure signal. SR 3.6.6.5 is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. SR 3.6.6.6 must be performed with the isolation valves in the spray supply lines at the containment and spray additive tank locked closed. The 24 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillances when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
(continued)
HBRSEP Unit No. 2                        B 3.6-41                                Revision No.
 
Containment Spray and Cooling Systems B 3.6.6 BASES SURVEILLANCE      SR 3.6.6.7 REQUIREMENTS (continued)      This SR requires verification that each containment cooling train actuates upon receipt of an actual or simulated safety injection signal. The 24 month Frequency is based on engineering judgment and has been shown to be acceptable through operating experience. See SR 3.6.6.5 and SR 3.6.6.6, above, for further discussion of the basis for the 24 month Frequency.
SR 3.6.6.8 With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and provides assurance that spray coverage of the containment during an accident is not degraded. Performance is required following activities which could result in nozzle blockage. Such activities may include: (1) a major configuration change; or (2) a loss of foreign material control such that the final condition of the system cannot be assured. The frequency is considered adequate due to the passive design of the nozzles, the stainless steel construction of the piping and nozzles, and the use of foreign material exclusion controls during system opening.
REFERENCES        1.      UFSAR, Section 3.1.
: 2.      10 CFR 50, Appendix K.
: 3.      UFSAR, Section 6.2.
: 4.      UFSAR, Section 9.4.
: 5.      ASME, Boiler and Pressure Vessel Code, Section XI.
HBRSEP Unit No. 2                        B 3.6-42                                Revision No.
 
Spray Additive System B 3.6.7 BASES SURVEILLANCE      SR 3.6.7.2 REQUIREMENTS (continued)      To provide effective iodine removal, the containment spray must be an alkaline solution. Since the RWST contents are normally acidic, the volume of the spray additive tank must provide a sufficient volume of spray additive to adjust pH for all water injected. This SR is performed to verify the availability of sufficient NaOH solution in the Spray Additive System. The 184 day Frequency was developed based on the low probability of an undetected change in tank volume occurring during the SR interval (the tank is isolated during normal unit operations). Tank level is also indicated and alarmed in the control room, so that there is high confidence that a substantial change in level would be detected.
SR 3.6.7.3 This SR provides verification of the NaOH concentration in the spray additive tank and is sufficient to ensure that the spray solution being injected into containment is at the correct pH level. The 184 day Frequency is sufficient to ensure that the concentration level of NaOH in the spray additive tank remains above the limit. This is based on the low likelihood of an uncontrolled change in concentration (the tank is normally isolated) and the probability that any substantial variance in tank volume will be detected.
SR 3.6.7.4 This SR provides verification that each automatic valve in the Spray Additive System flow path actuates to its correct position. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
(continued)
HBRSEP Unit No. 2                          B 3.6-47                                Revision No.
 
IVSW System B 3.6.8 BASES SURVEILLANCE      SR 3.6.8.3 (continued)
REQUIREMENTS Program, and previous operating experience has shown that these valves usually pass the required test when performed.
SR 3.6.8.4 This SR ensures that automatic header injection valves actuate to the correct position on a simulated or actual signal. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable.
SR 3.6.8.5 This SR ensures the capability of the dedicated nitrogen bottles to pressurize the IVSW system independent of the Plant Nitrogen System.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
SR 3.6.8.6 Integrity of the IVSW seal boundary is important in providing assurance that the design leakage value required for the system to perform its sealing function is not exceeded. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
(continued)
HBRSEP Unit No. 2                        B 3.6-53                              Revision No.
 
AFW System B 3.7.4 BASES SURVEILLANCE      SR 3.7.4.2 (continued)
REQUIREMENTS (only required at 3 month intervals) satisfies this requirement. The 31 day Frequency on a STAGGERED TEST BASIS results in testing each pump once every 3 months, as required by Reference 4.
This SR is modified by a Note indicating that the SR should be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test.
SR 3.7.4.3 This SR verifies that AFW can be delivered to the appropriate steam generator in the event of any accident or transient that generates an AFW actuation signal, by demonstrating that each automatic valve in the flow path actuates to its correct position on an actual or simulated actuation signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The 24 month Frequency is acceptable based on operating experience and the design reliability of the equipment.
This SR is modified by a Note that states the SR is not required in MODE 4 when AFW is being used for heat removal. In MODE 4, the required AFW train is already aligned and operating.
SR 3.7.4.4 This SR verifies that the AFW pumps will start in the event of any accident or transient that generates an AFW actuation (continued)
HBRSEP Unit No. 2                        B 3.7-29                                  Revision No.
 
AFW System B 3.7.4 BASES SURVEILLANCE      SR 3.7.4.4 (continued)
REQUIREMENTS signal by demonstrating that each AFW pump starts automatically on an actual or simulated actuation signal in MODES 1, 2, and 3. In MODE 4, the autostart function is not required. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
This SR is modified by two Notes. Note 1 indicates that the SR be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test.
Note 2 states that the SR is not required in MODE 4. In MODE 4, the heat removal requirements would be less providing more time for operator action to manually start the required AFW pump.
SR 3.7.4.5 This SR verifies proper AFW System alignment and flow path OPERABILITY from the CST to each SG following extended outages to determine that no misalignment of valves has occurred. The SR is performed prior to entering MODE 2 after more than 30 days in MODE 5 or 6. OPERABILITY of AFW flow paths must be verified before sufficient core heat is generated that would require the operation of the AFW System during a subsequent shutdown. The Frequency is reasonable, based on engineering judgment and other administrative controls that ensure that flow paths remain OPERABLE.
This SR is modified by a Note that allows entry into and operation in MODE 3 and MODE 2 prior to performing the SR for the steam driven AFW pump. This is necessary because sufficient decay heat is not available following an extended outage. The unit must be at a point of adding minimum core heat in order to provide sufficient steam to operate the steam driven AFW pump to verify water flow.
(continued)
HBRSEP Unit No. 2                        B 3.7-30                                Revision No.
 
AFW System B 3.7.4 BASES SURVEILLANCE      SR 3.7.4.6 REQUIREMENTS (continued)      This SR verifies that the automatic bus transfer switch associated with the "swing" motor driven AFW flow path discharge valve V2-16A will function properly to automatically transfer the power source from the aligned emergency power source to the other emergency power source upon loss of power to the aligned emergency power source. The Surveillance consists of two tests to assure that the switch will perform in either direction. One test is performed with the automatic bus transfer switch aligned to one emergency power source initially, and the test is repeated with the switch initially aligned to the other emergency power source.
Periodic testing of the switch is necessary to demonstrate OPERABILITY.
Operating experience has shown that this component usually passes the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
 
REFERENCES        1.      UFSAR, Section 10.4.8.
: 2.      UFSAR, Section 15.2.8.
: 3.      UFSAR, Section 15.2.7.
: 2.      ASME, Boiler and Pressure Vessel Code, Section XI.
HBRSEP Unit No. 2                          B 3.7-31                                Revision No.
 
CCW System B 3.7.6 BASES ACTIONS          B.1 and B.2 (continued) allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE      SR 3.7.6.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the CCW flow to individual components may render those components inoperable but does not affect the OPERABILITY of the CCW System.
Verifying the correct alignment for manual, power operated, and automatic valves in the required CCW flow path provides assurance that the proper flow paths exist for CCW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.
The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.
SR 3.7.6.2 This SR verifies proper automatic operation of the required CCW pumps on an actual or simulated LOP DG start undervoltage signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the Surveillance when performed at (continued)
HBRSEP Unit No. 2                        B 3.7-39                                  Revision No.
 
CCW System B 3.7.6 BASES SURVEILLANCE      SR 3.7.6.2 (continued)
REQUIREMENTS the 24 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
REFERENCES        1.        UFSAR, Section 9.2.2.
HBRSEP Unit No. 2                        B 3.7-40                          Revision No.
 
SWS B 3.7.7 BASES SURVEILLANCE      SR 3.7.7.2 (continued)
REQUIREMENTS controls. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
SR 3.7.7.3 This SR verifies proper automatic operation of the SWS pumps and SWS booster pumps on an actual or simulated actuation signal. The SWS is a normally operating system that cannot be fully actuated as part of normal testing during normal operation. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
SR 3.7.7.4 This SR verifies that the automatic bus transfer switch associated with turbine building service water isolation valve V6-16C, will function properly to automatically transfer the power source from the aligned emergency power source to the other emergency power source upon loss of power to the aligned emergency power source. The surveillance consists of two tests to assure that the switch will perform in either direction. One test is performed with the automatic bus transfer switch aligned to one emergency power source initially, and the test is repeated with the switch initially aligned to the other emergency power source.
Periodic testing of the switch is necessary to demonstrate OPERABILITY.
Operating experience has shown that this component usually passes the Surveillance when performed at the 24 month Frequency.
(continued)
HBRSEP Unit No. 2                          B 3.7-46                                Revision No.
 
CREFS B 3.7.9 BASES SURVEILLANCE      SR 3.7.9.3 REQUIREMENTS (continued)      This SR verifies that each CREFS train starts and operates on an actual or simulated actuation signal. The 24 month Frequency is based on the refueling cycle.
SR 3.7.9.4 This SR verifies the integrity of the CRE boundary. The CRE Habitability Program specifies administrative controls for temporary breaches to the boundary, preventative maintenance requirements to ensure the boundary is maintained, and leak test surveillance requirements. The details and frequencies for these requirements are specified in the CRE Habitability Program.
REFERENCES        1.      UFSAR, Section 6.4.
: 2.      UFSAR Section 6.4.2.3.
: 3.      UFSAR, Chapter 15.
: 4.      Regulatory Guide 1.52, Rev. 2, March 1978.
HBRSEP Unit No. 2                      B 3.7-58a                              Revision No.
 
CREATC B 3.7.10 BASES ACTIONS          F.1 and F.2 (continued)
In MODE 1, 2, 3, or 4, if both inoperable WCCU trains cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE      SR 3.7.10.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the heat load assumed in the control room. This SR consists of a combination of testing and calculations. The 24 month Frequency is appropriate since significant degradation of the WCCUs is slow and is not expected over this time period.
REFERENCES        1.      UFSAR, Section 6.4.
HBRSEP Unit No. 2                        B 3.7-62                                Revision No.
 
FBACS B 3.7.11 BASES (continued)
SURVEILLANCE      SR 3.7.11.1 REQUIREMENTS The FBACS should be checked periodically to ensure that it functions properly. As the environmental and normal operating conditions on this system are not severe, testing once every month provides an adequate check on this system.
Monthly heater operation dries out any moisture accumulated in the charcoal from humidity in the ambient air. Systems with heaters must be operated for  10 continuous hours with the heaters operating in the automatic mode under humidistat control to maintain the relative humidity at the inlet of the charcoal bed  70%. The 31 day Frequency is based on the known reliability of the equipment.
SR 3.7.11.2 This SR verifies that the required FBACS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).
Specific test frequencies and additional information are discussed in detail in the VFTP.
SR 3.7.11.3 This SR verifies the integrity of the fuel building enclosure. The ability of the fuel building to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the FBACS. The FBACS is designed to maintain a slight negative pressure in the fuel building, to prevent unfiltered LEAKAGE.
The Frequency of 24 months is consistent with the refueling interval.
ISTS SR 3.7.13.4 is modified by a Note. This Note provides clarification that the Surveillance is not applicable when the only movement of irradiated fuel is movement of a spent fuel shipping cask containing irradiated fuel. This Note is necessary to permit the shipping cask to be removed from the fuel handling building. When the side walls are opened to (continued)
HBRSEP Unit No. 2                        B 3.7-65                                Revision No.
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.8 (continued)
REQUIREMENTS response characteristics and capability to reject the largest single load without exceeding the overspeed trip.
For this unit, the single load for each DG is a safety injection pump rated at 380 Brake Horsepower. This Surveillance may be accomplished by:
: a.      Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus; or
: b.      Tripping its associated single largest post-accident load with the DG solely supplying the bus.
The 24 month Frequency is consistent with the recommendation of Regulatory Guide 1.9 revision 3.
This SR is modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. In order to ensure that the DG is tested under load conditions that are as close to design basis conditions as possible, Note 2 requires that, if synchronized to offsite power, testing must be performed using a power factor  0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG would experience.
SR 3.8.1.9 This Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.
The DG autostart time of 10 seconds is derived from requirements of the accident analysis to respond to a design (continued)
HBRSEP Unit No. 2                        B 3.8-16                                  Revision No.
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.9 (continued)
REQUIREMENTS basis large break LOCA. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability is achieved.
The requirement to verify the connection and power supply of permanent and auto connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, emergency Core Cooling Systems (ECCS) injection valves are not required to be stroked open, or high pressure injection systems are not capable of being operated at full flow, or residual heat removal (RHR) systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG systems to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The Frequency of 24 months takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by three Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus.
This reduces exposure of the DG to undue risk of damage that might render it inoperable.
(continued)
HBRSEP Unit No. 2                        B 3.8-17                                Revision No.
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.10 REQUIREMENTS (continued)      This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (10 seconds) from the design basis actuation signal (LOCA signal) and operates for  5 minutes. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application. This period may extend beyond the 10 second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR, HBRSEP Unit No. 2 will monitor and trend the actual time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.10.d and SR 3.8.1.10.e ensure that permanently connected loads and emergency loads are energized from the offsite electrical power system on an ESF signal without loss of offsite power.
The requirement to verify the connection of permanent and autoconnected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, ECCS injection valves are not required to be stroked open, or high pressure injection systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The Frequency of 24 months takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with the expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the (continued)
HBRSEP Unit No. 2                        B 3.8-18                                  Revision No.
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.10 (continued)
REQUIREMENTS 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by three Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus.
This reduces exposure of the DG to undue risk of damage that might render it inoperable.
SR 3.8.1.11 This Surveillance demonstrates that DG noncritical protective functions (e.g., high coolant water temperature) are bypassed. A manual switch is provided which bypasses the non-critical trips. The noncritical trips are normally bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG. This SR is satisfied by simulating a trip signal to each of the non-critical trip devices and observing the DG does not receive a trip signal.
The 24 month Frequency is based on engineering judgment and is intended to be consistent with DG maintenance interval. The equipment being tested is a manually-operated switch. Therefore, Frequency was concluded to be acceptable from a reliability standpoint.
(continued)
HBRSEP Unit No. 2                          B 3.8-19                                  Revision No.
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.12 REQUIREMENTS This SR requires demonstration once per 24 months that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours,  1.75 hours of which is at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG start shall be a manually initiated start followed by manual syncronization with other power sources.
Additionally, the DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.
In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed using a power factor of  0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG would experience.
The load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The 24 month Frequency takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test.
Similarly, momentary power factor transients above the power factor limit will not invalidate the test. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.
Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus.
(continued)
HBRSEP Unit No. 2                        B 3.8-20                                Revision No.
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.12 (continued)
REQUIREMENTS This reduces exposure of the DG to undue risk of damage that might render it inoperable.
SR 3.8.1.13 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within 10 seconds. The 10 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application. This period may extend beyond the 10 second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR, HBRSEP Unit No. 2 will monitor and trend the actual time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 24 month Frequency is based on engineering judgment and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The load band is provided to avoid routine overloading of the DG. Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The requirement that the diesel has operated for at least 2 hours at full load conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.
(continued)
HBRSEP Unit No. 2                        B 3.8-21                                  Revision No.
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.14 REQUIREMENTS (continued)      Under accident and loss of offsite power conditions, loads are sequentially connected to the bus by the automatic load sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The
                  +/- 0.5 seconds load sequence time setpoint tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses.
The Frequency of 24 months takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.
SR 3.8.1.15 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.
This Surveillance demonstrates the DG operation, as discussed in the Bases for SR 3.8.1.9, during a loss of offsite power actuation test signal in conjunction with an ESF actuation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The Frequency of 24 months takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length of 24 months.
(continued)
HBRSEP Unit No. 2                        B 3.8-22                                Revision No.
 
AC Sources - Operating B 3.8.1 BASES SURVEILLANCE      SR 3.8.1.15 (continued)
REQUIREMENTS This SR is modified by three Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations for DGs. The reason for Note 2 is that the performance of the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. Note 3 to this SR permits removal of the bypass for protective trips after the DG has properly assumed its loads on the bus.
This reduces exposure of the DG to undue risk of damage that might render it inoperable.
SR 3.8.1.16 Transfer of the 4.160 kV bus 2 power supply from the auxiliary transformer to the start up transformer demonstrates the OPERABILITY of the offsite circuit network to power the shutdown loads. In lieu of actually initiating a circuit transfer, testing that adequately shows the capability of the transfer is acceptable. This transfer testing may include any sequence of sequential, overlapping, or total steps so that the entire transfer sequence is verified. The 24 month Frequency is based on engineering judgement taking into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle length.
This SR is modified by two Notes. The reason for Note 1 is that, during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. As stated in Note 2, automatic transfer capability to the SUT is not required to be met when the associated 4.160 kV bus and Emergency Bus are powered from the SUT. This is acceptable since the automatic transfer capability function has been satisfied in this condition.
(continued)
HBRSEP Unit No. 2                          B 3.8-23                                  Revision No.
 
DC Sources - Operating B 3.8.4 ACTIONS          B.1 and B.2 (continued) required unit conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE      SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery (or battery cell) and maintain the battery (or a battery cell) in a fully charged state. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the initial voltages assumed in the battery sizing calculations and permit a single battery cell to be jumpered out.
The 7 day Frequency is consistent with manufacturer recommendations and IEEE-450 (Ref. 5).
SR 3.8.4.2 Visual inspection of the battery cells, cell plates, and battery racks provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance.
The 24 month frequency is based on engineering judgment and operational experience and is sufficient to detect battery and rack degradation on a long term basis.
SR 3.8.4.3 Visual inspection of intercell, intertier, and terminal connections provide an indication of physical damage or abnormal deterioration that could indicate degraded battery condition. The anticorrosion material is used to help ensure good electrical connections and to reduce terminal deterioration. The visual inspection for corrosion is not intended to require removal of and inspection under each (continued)
HBRSEP Unit No. 2                        B 3.8-42                                  Revision No.
 
DC Sources - Operating B 3.8.4 SURVEILLANCE      SR 3.8.4.3 (continued)
REQUIREMENTS terminal connection. The removal of visible corrosion is a preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR provided visible corrosion is removed during performance of SR 3.8.4.3.
The 24 month frequency is based on engineering judgment taking into consideration the likelihood of a change in component or system status.
SR 3.8.4.4 This SR requires that each battery charger be capable of supplying 300 amps and 125 V for  4 hours. These current and voltage requirements are based on the design capacity of the chargers. The battery charger supply is based on normal DC loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state. The minimum required amperes and duration ensures that these requirements can be satisfied.
The Surveillance Frequency is acceptable, given the other administrative controls existing to ensure adequate charger performance during these 24 month intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.
SR 3.8.4.5 A battery service test is a special test of battery capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length should correspond to the design duty cycle requirements.
This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test.
(continued)
HBRSEP Unit No. 2                        B 3.8-43                                  Revision No.
 
Distribution Systems - Operating B 3.8.9 BASES SURVEILLANCE      SR 3.8.9.2 and SR 3.8.9.3 REQUIREMENTS (continued)      The two breakers associated with each ABT will trip on over current as required to prevent fault from affecting both trains of the AC Distribution System. The 24 month Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions desirable for performing the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency.
Therefore the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES        1.        UFSAR, Chapter 6.
: 2.        UFSAR, Chapter 15.
: 3.        SER for HBRSEP Unit No. 2 Amendment 123, dated Sept. 5, 1989
: 4.        Regulatory Guide 1.93, December 1974.
HBRSEP Unit No. 2                        B 3.8-76                                Revision No.
 
Nuclear Instrumentation B 3.9.2 BASES SURVEILLANCE      SR 3.9.2.1 REQUIREMENTS SR 3.9.2.1 is the performance of a CHANNEL CHECK, which is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that the two indication channels should be consistent with core conditions. Changes in fuel loading and core geometry can result in significant differences between source range channels, but each channel should be consistent with its local conditions.
The Frequency of 12 hours is consistent with the CHANNEL CHECK Frequency specified similarly for the same instruments in LCO 3.3.1.
SR 3.9.2.2 SR 3.9.2.2 is the performance of a CHANNEL CALIBRATION every 24 months. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the source range neutron flux monitors consists of obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data. The CHANNEL CALIBRATION for the PAM source range neutron flux monitors only applies to the portion of the channel applicable to providing visual indication of neutron count rate in the Control Room. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage. Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency.
REFERENCES        1.      UFSAR, Section 3.1.
: 2.      UFSAR, Section 15.4.6.
HBRSEP Unit No. 2                        B 3.9-7a                                Revision No.
 
Containment Penetrations B 3.9.3 BASES SURVEILLANCE      SR 3.9.3.1 (continued)
REQUIREMENTS Accident involving handling recently irradiated fuel that releases fission product radioactivity within the containment will not result in a significant release of fission product radioactivity to the environment.
SR 3.9.3.2 This Surveillance demonstrates that each containment ventilation valve actuates to its isolation position on manual initiation or on an actual or simulated high radiation signal. The 24 month Frequency maintains consistency with other similar instrumentation and valve testing requirements. In LCO 3.3.6, the Containment Ventilation Isolation instrumentation requires a CHANNEL CHECK every 12 hours and a COT every 92 days to ensure the channel OPERABILITY during refueling operations. Every 24 months a CHANNEL CALIBRATION is performed.
The system actuation response time is demonstrated every 24 months, during refueling, on a STAGGERED TEST BASIS. SR 3.6.3.5 demonstrates that the isolation time of each valve is in accordance with the Inservice Testing Program requirements. These Surveillances performed during MODE 6 will ensure that the valves are capable of closing after a postulated fuel handling accident involving handling recently irradiated fuel to limit a release of fission product radioactivity from the containment.
REFERENCES        1.      UFSAR, Section 15.7.4.
HBRSEP Unit No. 2                        B 3.9-12                                  Revision No.
 
U. S. Nuclear Regulatory Commission  to Serial: RNP-RA/17-0014 1 Page ATTACHMENT 5
 
==SUMMARY==
OF LICENSEE COMMITMENTS The following commitment table identifies those actions committed to by Duke Energy Progress, LLC (DEP) in this submittal. Other actions discussed in the submittal represent intended or planned actions by DEP. They are described to the Nuclear Regulatory Commission (NRC) for the NRC's information and are not regulatory commitments.
Commitment                                      Completion Date 1      Ensure that the pressure switches 63/AST-1, 63/AST-2, and            Upon 63/AST-3 are replaced before increasing the surveillance interval    implementation of SR 3.3.1.10 to accommodate a 24-month fuel cycle. The              of the license pressure switches were found to exceed acceptable limits on          amendment more than rare occasions. It is recommended that these relays be replaced before increasing the surveillance interval of SR 3.3.1.10 to accommodate a 24-month fuel cycle.
2      The ongoing out of tolerance program will monitor future as-          Upon found/as-left results for three 24 month cycles to ensure the        implementation assumptions in the setpoint calculations continue to be valid.        of the license amendment 3      The Bases for Surveillance Requirement 3.7.9.3 states, in part:      Upon This SR verifies that each CREFS train starts and operates on        implementation an actual or simulated actuation signal. The Frequency of 18          of the license months is consistent with Position C.5 of Regulatory Guide 1.52      amendment (Ref. 4). RG 1.52, position 5.c states, in part: The in-place DOP test for HEPA filters should conform to Section 10 of ANSI N510-1975 (Ref. 2). HEPA filter sections should be tested in place (I) initially, (2) at least once per 18 months thereafter, and. . . Our conformance to the RG is documented in UFSAR section 1.8, Conformance to NRC Regulatory Guides. Upon NRC approval of the LAR, the commitment to Regulatory Guide 1.52 in the UFSAR will be modified as appropriate.
 
U. S. Nuclear Regulatory Commission  to Serial: RNP-RA/17-0014 32 Pages (including cover page)
ATTACHMENT 6 REVIEW OF HISTORICAL SURVEILLANCE RECORDS FOR INSTRUMENTATION
 
==Background:==
 
Robinson Nuclear Plant (RNP) is studying the ability to perform an instrument calibration extension to support a 24-Month Fuel Cycle. Nuclear Regulatory Commission (NRC) Generic Letter (GL) 91-04 Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle provides the NRC guidance, which RNP must use, to evaluate the issue of instrumentation errors caused by drift. This evaluation is used as justification to increase the surveillance intervals to accommodate a 24-month fuel cycle. , Action 1 of GL 91-04 directs the licensee to 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.
 
==Purpose:==
This document will evaluate Technical Specification, Surveillance Requirements associated with instrument calibrations. Additionally this is limited to Surveillance Requirements associated with refueling outages and/or 18-month frequency. The evaluation will review all associated issues found during these surveillances.
Method of Calibration Identifications:
Historical records were obtained for approximately the last ten years. All historical calibration data for that time period can be obtained from the Records Management System (RMS). That amount of data will include calibrations back to 2005 or refueling outage 23. The research for this data was performed before refueling outage 29; therefore, it will include six refueling outages. Per Section 4.1 of Oconee Nuclear Station (ONS) calculation OSC-9904, their review included five outages of data; therefore, RNP will include more data points for each surveillance than ONS. Some reviews will include calibrations performed during refueling outage 29; however, this is the exception. Review of refueling outage 29 data is completely random.
A complete list of SR impacted by a transition to a 24-month fuel cycle is included in Section B.5.1 of this engineering change. That list was filtered manually for SR which could be impacted by instrument drift. Following is a list of those SRs:
3.1.7.1          (Previously 3.1.7.4) - Rod Position Indication 3.3.1.10(7.a)    Pressurizer Pressure, Low 3.3.1.10(7.b)    Pressurizer Pressure, High 3.3.1.10(8)      Pressurizer Water Level, High 3.3.1.10(9.a)    Reactor Coolant Flow, Low 3.3.1.10(9.b)    Reactor Coolant Flow, Low 3.3.1.10(11)    RCP Undervoltage 3.3.1.10(12)    RCP Underfrequency 3.3.1.10(13)    SG Water Level, Low-Low 3.3.1.10(15.a)  Turbine Trip, Low Auto Stop Oil Pressure 3.3.1.10(17.e)  Turbine Impulse Pressure, P-7 Input 3.3.1.11(2.a)    Power Range Neutron Flux, High 3.3.1.11(2.b)    Power range Neutron Flux, Low 3.3.1.11(3)      Intermediate Range Neutron Flux 3.3.1.11(4)      Source Range Neutron Flux 3.3.1.12(5)      Over Temperature, Delta T 3.3.1.12(6)      Over Power, Delta T
 
3.3.1.13(17.b) Low Power Reactor Trips Block, P-7 3.3.1.13(17.e) Turbine Impulse Pressure, P-7 Input 3.3.2.7(1.c)  Containment Pressure, High SI 3.3.2.7(1.d)  Pressurizer Pressure, Low SI 3.3.2.7(1.e)  Steam Line High Differential Pressure Between Steam Header and Steam Lines 3.3.2.7(1.f)  High Steam Flow in Two Steam Lines with Tavg, Low 3.3.2.7(1.g)  High Steam Flow in Two Steam Lines with Steam Line Pressure, Low 3.3.2.7(2.c)  Containment Pressure, High-High Containment Spray 3.3.2.7(3.b.3) Containment Pressure, High-High Phase B Isolation 3.3.2.7(4.c)  Containment Pressure, High-High Steam Line Isolation 3.3.2.7(4.d)  High Steam Flow in Two Steam Lines with Tavg, Low 3.3.2.7(4.e)  High Steam Flow in Two Steam Lines with Steam Line Pressure, Low 3.3.2.7(6.a)  Pressurizer Pressure, Low SI Interlock 3.3.2.7(6.b)  Tavg, Low SI Interlock 3.3.3.2(1)    Power Range Neutron Flux 3.3.3.2(2)    Source Range Neutron Flux 3.3.3.2(3)    RCS Hot Leg Temperature 3.3.3.2(4)    RCS Cold Leg Temperature 3.3.3.2(5)    RCS Pressure, Wide Range 3.3.3.2(6)    RWST Level 3.3.3.2(7)    Containment Sump Level, Wide Range 3.3.3.2(8)    Containment Pressure, Wide Range 3.3.3.2(10)    Containment Area Radiation (High Range) 3.3.3.2(12)    Pressurizer Level 3.3.3.2(13)    SG Level, Narrow Range 3.3.3.2(14)    Condensate Storage Level 3.3.3.2(15)    Core Exit Temperature - Quadrant 1 3.3.3.2(16)    Core Exit Temperature - Quadrant 2 3.3.3.2(17)    Core Exit Temperature - Quadrant 3 3.3.3.2(18)    Core Exit Temperature - Quadrant 4 3.3.3.2(19)    Aux Feedwater Flow 3.3.3.2(20)    Steam Generator Pressure 3.3.3.2(21)    Containment Spray Additive Tank Level 3.3.4.3(1.a)  Source Range Neutron Flux 3.3.4.3(2.a)  Pressurizer Pressure 3.3.4.3(3.a)  RCS Hot Leg Temperature 3.3.4.3(3.b)  RCS Cold Leg Temperature 3.3.4.3(3.d)  SG Pressure 3.3.4.3(3.e)  SG Level, Wide Range 3.3.4.3(3.f)  Condensate Storage Tank Level 3.3.4.3(4.a)  Pressurizer Level 3.3.4.3(4.c)  RWST Water Level 3.3.5.2(a)    E1/E2 Loss of Voltage Trip Setpoint 3.3.5.2(b)    E1/E2 Degraded Grid Voltage Trip Setpoint 3.3.6.7(3.a)  Containment Radiation, Gaseous 3.3.6.7(3.b)  Containment Radiation, Particulate 3.3.7.6(2)    Control Room Radiation Monitor 3.3.8.4(1)    Auxiliary Feedwater Start - SG Water Level, Low-Low 3.3.8.4(3)    Auxiliary Feedwater Start - E1/E2 Loss of Voltage 3.3.8.4(4)    Auxiliary Feedwater Start - RCP Undervoltage 3.4.1.4        Verify by precision heat balance that RCS total flow rate is  97.3x106 lbm/hr 3.4.12.7      PORV Actuation - Low Temperature, Over Pressure (LTOP)
 
3.4.14.2          Verify RHR System Interlock Prevents Values from Being Opened, RCS > 474 psig 3.4.15.3          Containment Sump Monitor 3.4.15.4          Containment Atmosphere Radioactivity Monitor 3.4.15.5          Containment Fan Cooler Condensate Flow Rate Monitor 3.8.1.14          Verify Actuation of Sequenced Loads (ESFAS Timers) 3.9.2.2          Nuclear instrumentation The population of equipment associated with each of these functions was obtained from review of drawings, vendor technical manuals, calculations and calibration procedures. The population is limited to only those components which are associated with performance of the function and can have drift associated with them. For example, loop power supplies were not included in the review. The identified components are listed in each of the evaluations below.
Using EDB and Records Management System (RMS) a list of all applicable 18-month surveillances was compiled. This typically is a completed work order; however, in some cases the information was recorded by calibration procedure number and not the work order number it was performed under. All reviewed material is referenced in the evaluations below.
Evaluation of Issues:
Issues were identified by review of the completed work orders and/or records. If the record noted a problem with a component or that it was found out-of-tolerance, the calibration data sheet was reviewed to determine if acceptable limits were exceeded.
Once all reviews were complete for a TS function it was determined if the criteria for rare occasion was exceeded.
Several functions utilize common equipment. In these cases, the function is listed along with the applicable components, followed by the next function. The common evaluation is presented after all of the functions are listed. In cases where this occurs it may appear an evaluation is missing.
The terms acceptable limits and rare occasion are defined in Enclosure 1 as follows:
Exceeded Acceptable Limits Uncertainty/Setpoint calculations are intended to ensure the analytical limits, are not exceeded. Typically, as-found values are determined in those calculations for each component of an instrument loop. Finding equipment within those as-found values ensure the Total Loop Uncertainty is not exceeded and therefore, the analytical limit was not challenged. Therefore, equipment associated with uncertainty/setpoint calculations will use the calculated as-found values as the acceptable limits for this evaluation.
Additionally, as-found values, which are found to be out-of-tolerance in a conservative direction with respect to Allowable Values, will not be considered to exceed acceptable limits.
Therefore, the functions which have a trip setpoint and Allowable Value, as described in Technical Specification Bases B.3.3.1, will be considered to exceed acceptable limits if it was found outside of the calculated as-found tolerance of the applicable uncertainty calculation, in the direction of the Allowable Value.
 
The Technical Specification functions which have no setpoint or Allowable Value, such as post-accident monitoring (PAM), typically provide the operator with indication to perform manual action specified in the unit Emergency Operating Procedures (ref. TS Bases, page B 3.3-93). These functions typically have action setpoints associated with them. These action setpoints are determined using the calculated uncertainty values. If components are outside of the calculated uncertainty values, it could have an adverse effect on operator actions. Again, finding components within the calculated as-found values ensure the Total Loop Uncertainty and Total Device Uncertainty have not been exceeded. Therefore, components which have an associated uncertainty calculation will use the calculated as-found values as the acceptable limits.
Functions which have no associated uncertainty calculation will use the calibration tolerance as the acceptable limits or another definition may be specified within the evaluations include in this document.
Except on Rare Occasions Approximately ten years of surveillance data was reviewed. Generally, instrumentation that is repeatedly found to exceed its as-found tolerances will require corrective actions. These corrective actions could be to replace the equipment, perform a modification, setpoint change or other actions. Therefore, it is not expected that instrumentation will be continually found to exceed acceptable limits. If instruments were found to exceed acceptable limits on two consecutive occurrences it is indicative of more than rare occasion.
Additionally, instruments that were found to exceed their allowable value on two or more occasions over the review period required additional inspection to determine if the problem was corrected. If the problem was corrected and acceptable limits were no long exceeded, the issue was no longer considered to be a factor in the determination to extend the calibration interval. If the problem was not corrected it was considered to exceed rare occasion.
Review:
Generic Evaluation of RTDs and Thermocouples: This evaluation is applicable to the following Surveillance Requirements and components:
SR 3.3.1.12 Items 5 and 6 - (TE-412D, TE-412C, TE-412B1, TE-411D1, TE-412B2, TE-411D2, TE-412B3, TE-411D3, TE-422D, TE-422C, TE-422B1, TE-421D1, TE-422B2, TE-421D2, TE-422B3, TE-421D3, TE-432D, TE-432C, TE-432B1, TE-431D1TE-432B2, TE-431D2, TE-432B3, TE-431D3) This includes spare RTDs.
SR 3.3.2.7 Items 1.f, 4.d, 6.b - The same RTDs as listed above.
SR 3.3.3.2 Item 3 - TE-413-1, TE-413-2, TE-423, TE-433 SR 3.3.3.2 Item 4 - TE-410, TE-420, TE-430 SR 3.3.3.2 Items 15, 16, 17, 18 - TE-523, TE-524, TE-525, TE-526, TE-527, TE-528
 
These RTDs provide temperature compensation for the termination of thermocouples inside the Reference Junction Boxes, located in the Containment Vessel. The Core Exit Temperature is measured by thermocouples.
Following is a list of the applicable thermocouples, which includes spares and/or failed thermocouples:
Train A - TE-472A, TE-472B, TE-473A, TE-473B, TE-474A, TE-474B, TE-475A, TE-475B, TE-476A, TE-476B, TE-477A, TE-477B, TE-478A, TE-478B, TE-479A, TE-479B, TE-480A, TE-480B, TE-481A, TE-481B, TE-482A, TE-482B, TE-483A, TE-483B, TE-484A, TE-484B, TE-485A, TE-485B, TE-486A, TE-486B, TE-487A, TE-487B, TE-488A, TE-488B, TE-490A, TE-490B, TE-491A, TE-491B, TE-492A, TE-492B, TE-493A, TE-493B, TE-494A, TE-494B, TE-495A, TE-495B, TE-496A, TE-496B Train B - TE-497A, TE-497B, TE-498A, TE-498B, TE-499A, TE-499B, TE-500A, TE-500B, TE-501A, TE-501B, TE-502A, TE-502B, TE-503A, TE-503B, TE-504A, TE-504B, TE-505A, TE-505B, TE-506A, TE-506B, TE-507A, TE-507B, TE-508A, TE-508B, TE-509A, TE-509B, TE-510A, TE-510B, TE-512A, TE-512B, TE-513A, TE-513B, TE-514A, TE-514B, TE-515A, TE-515B, TE-516A, TE-516B, TE-517A, TE-517B, TE-518A, TE-518B, TE-519A, TE-519B, TE-520A, TE-520B, TE-521A, TE-521B, TE-522A, TE-522B SR 3.3.4.3 Items 3.a and 3.b - TE-413-1 and TE-410 Information from the previous five performances of EST-052 Operational Alignment of Process Temperature Instrumentation were reviewed (Ref. RMS Records 3698867, 3988506, 4423393, 4895020, 5307508). Based on the reviewed data, one adjustment was required in 2007 to the low-level amplifier for RCS Loop #3, Hot Leg RTD #2. No other adjustments have been required since that time. The data from 2005 could not be obtained in RMS; however, data from the 2002 and 2004 performances (Ref. RMS Record 91331, 3089427) were also reviewed. No adjustments were required during those performances.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle. The remainder of the instrument loops, which these devices are a part of, are evaluated in the applicable SR evaluations below.
SR 3.1.7.1 (Previously 3.1.7.4) - Rod Position Indication: This surveillance requirement performs the channel calibration of the Rod Position Indication System (RPI). The components applicable to this SR are numerous. All components calibrated in performance of LP-551 are considered applicable to this function.
Review of LP-551 determined no as-found data is taken. This function does not require the same historical surveillance review as the typical as-found/as-left evaluation since SR 3.1.4.1 verifies the individual rod positions within alignment limits every 12 hours. OST-020 performs this verification every shift.
Since a more frequent surveillance requirement would have identified the rod positions being outside of the TS limits, an increase in the calibration interval would not result in the failure being unidentified for a longer time period.
The historical review of LP-551 was performed just to ensure no issues were discovered that would not have been discovered by the more frequent surveillance.
 
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00553028, 00788240, 01057720, 01443883, 02031929, 02005029, 13306102 SR 3.3.1.10 Item 7.a - Pressurizer Pressure, Low: Three pressure transmitters (PT-455, PT-456, PT-457) and associated rack equipment (PM-455A, PC-455C, PM-456A, PC-456C, PM-457A, PC-457C) provide this trip function to the RPS.
SR 3.3.1.10 Item 7.b - Pressurizer Pressure, High: Three pressure transmitters (PT-455, PT-456, PT-457) and associated rack equipment (PC-455A, PC-456A, PC-457A) provide this trip function to the RPS.
SR 3.3.2.7 Item 1.d - Pressurizer Pressure, Low SI: Three pressure transmitter (PT-455, PT-456, PT-457) and associated rack equipment (PC-455E, PC-456D, PC-457D) provide this actuation function to the ESFAS.
SR 3.3.2.7 Item 6.a - Pressurizer Pressure, Low SI Interlock: Three pressure transmitter (PT-455, PT-456, PT-457) and associated rack equipment (PC-455B, PC-456B, PC-457B) provide this actuation function to the ESFAS.
PT-455 was found to be out-of-tolerance high at the highest calibration point of the transmitter on one occasion. This would only have the potential to affect the high pressurizer pressure, reactor trip, since all other calibration points were found in tolerance. This would have resulted in actuation below the setpoint; therefore, the Allowable Value would not have been exceeded.
PT-456 was found out-of-tolerance high at all but the lowest calibration point. Since the points were found high with respect to the desired as-found values it would only have the potential to affect decreasing setpoints. Low Pressurizer Pressure Reactor Trip and Low Pressurizer Pressure SI are the potentially impacted safety functions. Since the same component performs both of these functions, it will be considered one occurrence to exceed acceptable limits.
No issues were identified concerning the rack components that perform these functions.
SR 3.3.1.10 includes a note associated with verification of time constants. This note is concerning the time response of Lead/Lag controllers. Item 7.a - Pressurizer Pressure, Low includes a Lead/Lag controller; therefore, this test is applicable to that function. All Lead/Lag controllers are calibrated every 18-months by procedure PIC-605 Hagan Lead/Lag Controller (Response Test Only). The components associated with this function are PM-455A, PM-456A and PM-457A. Review of the previous performances of PIC-605 for the applicable components did not identify any issues.
Therefore, one occurrence of a pressurizer pressure transmitter exceeding its TS Allowable Value for SR 3.3.2.7 Item 1.d and 6.a was found. This does not exceed rare occasion; therefore, based on this review surveillance testing of these functions are found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 01457543, 01069838, 00787640, 02288725, 02015634, 00543300, 01765909, 00548509, 00629802, 00788415, 00827459, 01052774, 01097414, 01438904, 01465078, 01751681, 01749793, 01983205, 02001043, 02206269, 02291831
 
SR 3.3.1.10 Item 8 - Pressurizer Water Level, High: Three differential pressure transmitters (LT-459, LT-460, LT-461) and associated rack equipment (LC-459A, LC-460A, LC-461) provide this trip function to the RPS.
In 2010, comparator LC-459A was found out-of-tolerance high at the reactor trip setpoint; however, it was within the as-found tolerance given in Section 9.3 of RNP-I/INST-1038. This out-of-tolerance did not exceed acceptable limits.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00536827, 00781611, 01063276, 01450567, 01759248, 02009577, 02284972, 00539072, 00783715, 01065583, 01452828, 01762124, 02010531, 02288320, 00540631, 00785864, 01067596, 01455392, 01764616, 02013339, 02282800, 00629807, 00827464, 01097412, 01465083, 01751680, 01983204, 02251980 SR 3.3.1.10 Item 9.a and 9.b - Reactor Coolant Flow, Low: Nine differential pressure transmitters (FT-414, FT-415, FT-416, FT-424, FT-425, FT-426, FT-434, FT-435, FT-436) and associated rack equipment (FC-414, FC-415, FC-416, FC-424, FC-425, FC-426, FC-434, FC-435, FC-436) provide these trip functions to the RPS. There are three transmitters per RCS Loop.
In 2007, FT-436 was found out-of-tolerance, low at its lowest calibration point. That point is equivalent to no flow in the Loop 3 of the RCS. This point would not have prevented the component from performing its safety function. Per Section 8 of RNP-I/INST-1128 the TS, trip setpoint is 94.26% of flow span or
((SQRT(4 VDC)*94.68% flow) / 120% flow)2 + 1 VDC = 3.47 VDC The transmitter was within tolerance at the calibration points above and below this setpoint, therefore, it was also within its TS Allowable Value.
In 2010, FT-416 was found out-of-tolerance at the three upper calibration points. Comparing the as-found values from the calibration to those listed in Section 9 of RNP-I/INST-1128 determined the transmitter was within the calculated as-found values at all but the highest calibration point. As stated previously, the TS, trip setpoint is 3.47 VDC. The transmitter was within the calculated tolerance at the calibration points above and below the setpoint.
Therefore, it did not exceed its TS Allowable Value.
In 2010, FT-415 was found out-of-tolerance, high at all five calibration points. This represents a shift in the non-conservative direction which exceeds the TS Allowable Value. The transmitter was replaced.
In 2012, FT-415 was again found out-of-tolerance, high at the three highest calibration points.
This out-of-tolerance condition exceeded the TS Allowable Value.
Review of the two most recent calibrations did not result in any out-of-tolerance conditions of these transmitters. A total of 63 calibrations were reviewed for this function. Two occurrences of equipment exceeding the TS Allowable Value were found on the same component in consecutive cycles. FT-415 was replaced after the first identification of a problem. That would mean the second out-of-tolerance was the first calibration of a new transmitter after operating a cycle. Although this is not desired, it is not unexpected for new equipment to drift after it is subjected to the environment it operates within (i.e. pressures, temperatures, voltages, etc.).
 
Additionally, since these occurrences were on different pieces of equipment they would not be considered repetitive and as stated above there have been no additional out-of-tolerances in the following calibrations.
These occurrences would not be considered to exceed rare occasion based on the evaluation given above.
In 2009, comparator FC-435 was found out-of-tolerance high and chattering at the trip setpoint.
The component was within the as-found value listed in Section 9.3 of RNP-I/INST-1128. The component was found chattering; however a review of the attached MMM-006 out-of-tolerance review sheet determined the component was still capable of performing its design function; therefore, this issue did not exceed acceptable limits.
In 2013, comparator FC-416 was found out-of-tolerance high on its reset action. The reset action was still well above the trip function (approximately 40 mVDC); therefore, it would not have affected the design function of the component to send a logic signal to the RPS.
In 2015, comparator FC-425 was found out-of-tolerance on its reset action. The reset action was still well above the trip function (approximately 37 mVDC); therefore, it would not have affected the design function of the component to send a logic signal to the RPS.
Based on this review surveillance testing of these functions are found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00540348, 00785362, 01067274, 01455037, 01763525, 02130964, 02288321, 00419063, 00629806, 00827463, 01097417, 01465082, 01751685, 01983203, 02221998 SR 3.3.1.10 Item 11 - RCP Undervoltage: Three undervoltage relays (272/1, 272/2, 272/4) are associated with this trip function to the RPS. One is located on each applicable 4KV bus (Bus 1, 2, 4).
SR 3.3.8.4 Item 4 - Auxiliary Feedwater Start - RCP Undervoltage: Four undervoltage relays (271/1, 271/4, 272/1, 272/4) are associated with this function. Two are located on each applicable 4KV bus. This function is a two-out-of-two logic on both 4KV bus. All four relays must actuate to perform this function.
No as-found data was recorded for relays 272/2 and 272/1 during the replacement is 2012; therefore, those calibrations are not included in this evaluation. This is acceptable since all other data for these relays have resulted in acceptable calibrations.
No issues were identified for these functions. Based on this review surveillance testing of these functions are found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00537761, 00783070, 01064410, 01451770, 01761719, 02010395, 02285283 SR 3.3.1.10 Item 12 - RCP Underfrequency: Three underfrequency relays (811/1, 811/2, 811/4) are associated with this trip function to the RPS. One is located in each of the applicable 4KV bus (Bus 1, 2, 4).
In 2007, 811/1 failed during calibration. The as-found values met the TS Allowable Value. The relay failed during as-left measurements. Since the as-found readings were within the TS Allowable Values it met the acceptable limits. The failure does constitute a failure that would
 
not have been identified by other surveillances; however, the relay did function properly during the as-found readings. The relay was replaced during this outage.
In 2008, 811/1 and 811/2 were found in tolerance at the trip setpoint; however, both were outside of tolerance with respect to the difference in the minimum and maximum voltages the tests are performed at. This is not a requirement of the TS. This portion of the test ensures proper operation of the relays with respect to the relays design. Since the relays functioned within the TS Allowable Values, this is not considered a failure.
In 2013, 811/1 was found out-of-tolerance high during calibration at the 40 VAC test point. This is in the conservative direction with respect to the setpoint and TS Allowable Value; therefore, this is not considered a failure.
Of the above described issues, only the failure of 811/1 in 2007 is considered to NOT meet the acceptable limits. Since there was only one failure in 18 calibrations it is considered rare.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00537440, 00782776, 01064106, 01451315, 01760445, 02010241 SR 3.3.1.10 Item 13 - SG Water Level, Low-Low: Nine differential pressure transmitters (LT-474, LT-475, LT-476, LT-484, LT-485, LT-486, LT-494, LT-495, LT-496) and associated rack equipment (LC-474A, LC-475A, LC-476A, LC-484A, LC-485A, LC-486A, LC-494A, LC-495A, LC-496A) provide this trip function to the RPS. There are three transmitters per SG.
SR 3.3.8.4 Item 1 - Auxiliary Feedwater Start - SG Water Level, Low-Low: Nine differential pressure transmitters (LT-474, LT-475, LT-476, LT-484, LT-485, LT-486, LT-494, LT-495, LT-496) and associated rack equipment (LC-474A, LC-475A, LC-476A, LC-484A, LC-485A, LC-486A, LC-494A, LC-495A, LC-496A) provide this actuation signal to the Auxiliary Feedwater System. There are three transmitters per SG. Two-out-of-three logic is required to actuate the system.
There were no issues identified for these functions. Based on this review surveillance testing of these functions are found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00540349, 00785364, 01067275, 01455038, 01763526, 02012892, 02282801, 00444382, 00656216, 00857768, 01129330, 01499675, 01783397, 02009521, 02271879, 00444381, 00656215, 00857767, 01129335, 01499674, 01783396, 02009520, 02242520, 00444380, 00656217, 00857766, 01129334, 01499676, 01783398, 02009965, 02219369
 
SR 3.3.1.10 Item 15.a - Turbine Trip, Low Auto Stop Oil Pressure: Three pressure switches provide this trip function to the RPS (63/AST-1, 63/AST-2, 63/AST-3). Three occurrences of a Turbine Auto Stop Trip Pressure Switch exceeding the Allowable Value were reviewed. All three were discovered during different outages over a seven year period. Each occurrence was associated with a different switch; therefore, there was no consecutive occurrences that would indicate a repetitive problem.
Based on the number of problems this would be considered to exceed rare occasions. These pressure switches will be recommended for replacement before operation on a 24-month fuel cycle. Nuclear Task Management (NMT) 01953869, assignment 06 is tracking that this action be incorporated into the LAR, as a commitment.
Ref. WO 01060395, 01756593, 02287383, 00534564, 00780301, 01446499, 02025663 SR 3.3.2.7 Item 1.c - Containment Pressure, High SI: Three pressure transmitters (PT-951, PT-953, PT-955) and associated rack equipment (PC-951B, PC-953B, PC-955B) provide this actuation function to the ESFAS.
SR 3.3.2.7 Item 2.c - Containment Pressure, High-High Containment Spray: Six pressure transmitters (PT-950, PT-951, PT-952, PT-953, PT-954, PT-955) and associated rack equipment (PC-950, PC-951A, PC-952, PC-953A, PC-954, PC-955A) provide this actuation function to the ESFAS.
SR 3.3.2.7 Item 3.b.3 - Containment Pressure, High-High Phase B Isolation: Six pressure transmitters (PT-950, PT-951, PT-952, PT-953, PT-954, PT-955) and associated rack equipment (PC-950, PC-951A, PC-952, PC-953A, PC-954, PC-955A) provide this actuation function to the ESFAS.
SR 3.3.2.7 Item 4.c - Containment Pressure, High-High Steam Line Isolation: Six pressure transmitters (PT-950, PT-951, PT-952, PT-953, PT-954, PT-955) and associated rack equipment (PC-950, PC-951A, PC-952, PC-953A, PC-954, PC-955A)provide this actuation function to the ESFAS.
No issues were identified that required review. Based on this review surveillance testing of these functions are found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00543001, 00786487, 01069478, 01457321, 01765558, 02015295, 02281298, 00584103, 00782652, 01039087, 01486150, 01800610, 02035604, 02281769, 00584105, 00782654, 01039083, 01486152, 01800612, 02035608, 02281771, 00584104, 00782653, 01039082, 01486151, 01800611, 02035606, 02281770, 00584100, 00782649, 01039084, 01486147, 01800607, 02035595, 02281766, 00584102, 00782651, 01039086, 01486149, 01800609, 02035602, 02281768, 00584101, 00782650, 01039085, 01486148, 01800608, 02035599, 02281767 SR 3.3.2.7 Item 1.e - Steam Line High Differential Pressure Between Steam Header and Steam Lines: This function provides an actuation signal to the ESFAS to initiate a SI. The function is a two-out-of-three logic on any Steam Line. The function consist of the following components: PT-464, PM-464B, PT-466, PM-466B, PT-468, PM-468B, PT-474, PT-475, PT-476, PT-484, PT-485, PT-486, PT-494, PT-495, PT-496, PC-474B, PC-475, PC-476, PC-484, PC-485B, PC-486, PC-494, PC-495, PC-496B).
 
All components calibrations were reviewed. No issues were identified.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00544737, 00789018, 01072350, 01459358, 01767950, 02016809, 02294665, 00455124, 00666901, 00869279, 01146806, 01517724, 01795546, 02020578, 02285206, 00541896, 00786343, 01062357, 01424873, 01710198, 01951582, 02075037, 02282671, 00540351, 00785366, 01062358, 01424872, 01710197, 01951581, 02151938 SR 3.3.5.2(a) - E1/E2 Loss of Voltage Trip Setpoint: Four undervoltage relays (271/E1(480V), 271/E2(480V), 272/E1(480V), 272/E2(480V)) provide this function. Two undervoltage relays monitor the voltage of each of the two, 480V Emergency Bus. This is a one-out-of-two logic scheme. Since there is no TS Allowable Value for this function, the review will use the tolerance specified in the TS Surveillance Requirement as the acceptable limit.
SR 3.3.8.4 Item 3 - Auxiliary Feedwater Start - E1/E2 Loss of Voltage: Four undervoltage relays (271/E1(480V), 271/E2(480V), 272/E1(480V), 272/E2(480V)) provide this function. Two undervoltage relays monitor the voltage of each of the two, 480V Emergency Bus. This is a one-out-of-two logic scheme. Since there is no TS Allowable Value for this function, the review will use the tolerance specified in the TS Surveillance Requirement as the acceptable limit.
In 2010, both relays of the E2 bus were found out-of-tolerance high (time setting); however, they are found at approximately 0.81 seconds which is below the Surveillance Requirement specified time of  1 second. Since the SR specified value was met there was no loss of safety function.
Based on this review surveillance testing of these functions are found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00565263, 00788298, 01045608, 01621396, 01432316, 01749502, 02029807, 02066084, 13325112, 00565264, 00788299, 01045609, 01727296, 01800382, 02080996, 13325111 SR 3.3.5.2(b) - E1/E2 Degraded Grid Voltage Trip Setpoint: Six undervoltage relays (27/DVA-1, 27/DVB-1, 27/DVC-1, 27/DVA-2, 27/DVB-2, 27/DVC-2) provide this function. Three undervoltage relays monitor the voltage of each of the two, 480V Emergency Bus. This is a two-out-of-three logic scheme. Since there is no TS Allowable Value for this function, the review will use the tolerance specified in the TS Surveillance Requirement as the acceptable limit.
No issues were identified that required review.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00539155, 00783990, 01065989, 01453156, 01779454, 01762574, 02012088, 00534885, 00780402, 01060941, 01446936, 01779455, 01756875, 02007609 SR 3.4.12.7 - PORV Actuation - Low Temperature, Over Pressure (LTOP): Two pressure transmitters (PT-500, PT-501) provide input to this function along with the associated rack equipment (PC-502, TM-502, TC-502, QM-502, PC-503, TM-503, QM-503, TC-503). Input is also provided from each of the three cold leg, wide range temperature loops.
 
Those loops consist of the following calibrated components: TM-410, TM-420, TM-430 (low level amplifiers). The low level amplifiers are calibrated as part SR 3.3.3.2 Item 5; however, they will be evaluated here. The as-found values listed in RNP-I/INST-1127 will be used as the acceptable limits for review of this function.
No issued were identified in regards to the pressure transmitters.
In 2007, TM-502 was found failed. No as-found readings could be obtained. The plant was in Mode 1 at the time. The LTOP System is required in Modes 4, 5, or 6 (with head on vessel).
This failure would not have been identified by other means; however, it was not required to be operable at the time. Since this is the only failure of this component or the same component in another loop it is considered to NOT exceed acceptable limits except on rare occasion.
In 2013, QM-502 was found out-of-tolerance, high at one calibration point; however, it was within the calculated as-found values listed in section 6.12 of RNP-I/INST-1127; therefore, it did not exceed acceptable limits.
No issues were identified in regards to the low level amplifiers of the cold leg, wide range temperature loops.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00629803, 00827460, 01097413, 01465079, 01751682, 01983206, 02224327, 01047001, 00827462, 01097416, 01465081, 01751684, 01983202, 02262626, 00544736, 00788246, 01047001, 01433217, 01745128, 01996785, 02285899 SR 3.3.1.12 Item 5 and 6 - Over Temperature, Delta T and Over Power, Delta T: Twelve Low Level Amplifiers/RTDs (TM-412, TM-412H1, TM-412H2, TM-412H3, TM-422, TM-422H1, TM-422H2, TM-422H3, TM-432, TM-432H1, TM-432H2, TM-432H3) and associated rack equipment (TM-412N, TM-412K, TM-412J, TM-412E, NM-412F, NM-412C, TM-412F, TC-412C, TM-422N, TM-422K, TM-422J, TM-422E, TM-422F, NM-422F, NM-422C, TC-422C, TM-432N, TM-432K, TM-432J, TM-432E, TM-432F, NM-432F, NM-432C, TC-432C, TM-412M, TM-412L, TM-412G, NC-412B, TM-412V, TC-412B, TM-422M, TM-422L, TM-422G, NC-422B, TM-422V, TC-422B, TM-432M, TM-432L, TM-432G, NC-432B, TM-432V, TC-432B) provide these trip functions to the RPS. Four low level amplifiers are in each of three protection channels, corresponding to the three RCS loops. Inputs are also provided to the instrument loops from other protection channels: Pressurizer pressure transmitters (PT-455, PT-456 and PT-457) provide an input signal to the corresponding temperature protection loop and upper and lower flux signals are provided to each temperature protection channel from the Nuclear Instrument System. Review of the components that provide the pressurizer pressure and nuclear instrument signals to the temperature protection channels are documented in other portions of this evaluation. The evaluation of PT-455, PT-456 and PT-457 are included in the evaluation of SR 3.3.1.10 Item 7.a - Pressurizer Pressure, Low. The upper and lower flux input signals are evaluated in the SR 3.3.1.11 Items 2.a, 2.b, 17.c and 17.d.
Each low level amplifier measures resistance from its associated RTD. Evaluation of RTDs was performed generically and will not be repeated here; however, that evaluation determined extension of RTD calibrations was acceptable.
The instrument loops associated with this function have a Channel Operability Test (COT) performed every 92 days per SR 3.3.1.7. Those COTs are performed by procedure MST-003
 
Tavg and Delta-T Protection Channel Testing. Review of MST-003 determined the Allowable Values of 2.96% and 3.17% of Delta-T span for the complete instrument loop is verified.
During each refueling outage the Channel Calibration for SR 3.3.1.12 is performed by loop calibration procedures LP-001 Overpower, Overtemperature Delta-T Protection Channel I, LP-002 Overpower, Overtemperature Delta-T Protection Channel II, LP-003 Overpower, Overtemperature Delta-T Protection Channel III. Those loop calibration procedures check the calibration of and make adjustment to the individual components before performance of the string verifications. No as-found string verification is performed before adjustments are made.
Based on the way these loop calibration procedures are performed, it is not possible to evaluate the instrument loops for these functions against the Allowable Value. Also, evaluation of the individual modules would not be a valid determination of acceptability to extend the calibration interval since they can only be evaluated against the individual tolerance, which in most cases is the standard tolerances listed in plant procedures. The individual component tolerances do not relate to the Allowable Value or stated tolerances from the equipment vendors.
Therefore, these functions are acceptable for extension of the calibration interval based on verification of operability during the 92 day, COT. This is different than the evaluation method used on other instrument loops; however, no other evaluation method is available at this time which would provide clear evidence of acceptability.
As an enhancement to the existing channel calibration, LP-001, LP-002 and LP-003 will be revised to include a string verification before individual components are calibrated and adjusted. This will provide a more definitive answer to operability between the time of the last COT and performance of the Channel Calibration. LP-001, LP-002 and LP-003 have been added to Section C and the ADL of this engineering change to make this enhancement.
The Low Level Amplifiers are also calibrated using LP-001, LP-002 and LP-003. Verification of those components is not performed during the string verification. Each low level amplifier is calibrated using standard tolerances of plant procedures. These tolerances will be used as the acceptable limits for this evaluation. Review of the low level amplifier calibrations did not identify any out-of-tolerance issues.
SR 3.3.1.12 includes a note associated with verification of time constants. This note is concerning the time response of Lead/Lag controllers and RTD time response. Items 5 and 6 includes Lead/Lag controllers and RTDs; therefore, this test is applicable to those functions.
All Lead/Lag controllers time response are verified every 18-months by procedure PIC-605 Hagan Lead/Lag Controller (Response Test Only). The components associated with this function are TM-412L, TM-412E, TM-422L, TM-422E, TM-432L, TM-432E. PIC-605 was reviewed for issues associated with these components. The tolerances provide in PIC-605 will be used as the acceptable limits since they ensure the TS allowable values are not exceeded.
In 2005, TM-412L, TM-422L and TM-432L were found out-of-tolerance. Since this is a penalty to the Overpower Delta T setpoint any as-found value below the lower tolerance is considered a non-conservative value and exceeds acceptable limits for this evaluation. TM-412L and TM-422L were out-of-tolerance high; therefore, they did not exceed acceptable limits. TM-432L was out-of-tolerance low and exceeded acceptable limits.
In 2007, TM-432L was found out-of-tolerance low; therefore, it exceeded acceptable limits.
 
In 2008, TM-432L was found out-of-tolerance high. Based on the discussion above, this does not exceed acceptable limits; however, it was noted as the third consecutive out-of-tolerance condition for this component.
The three out-of-tolerance conditions evaluated above exceeds acceptable limits on more than rare occasion. Review of corrective maintenance for component TM-432L identified this component was replaced with a newer model in 2010 (Ref. WO 01621188). This replacement was part of an ongoing project to replace all obsolete Hagan modules with NUS modules. Since that replacement there have been no issues identified.
Based on the corrective maintenance and three consecutive, satisfactory calibrations since that time, this function is found to be acceptable for extension of calibration frequency to support a 24-month fuel cycle.
Response time testing of RTDs is performed by procedure EST-124 Response Time Testing of Reactor Coolant System RTDs (Refueling Interval). Review of the completed procedures did not identify any issues.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00548509, 00788415, 01052774, 01438904, 01749793, 02001043, 02291831, 00537760, 00783069, 01064409, 01451769, 01761718, 02010396, 02284969, 00539518, 00784264, 01066473, 01454567, 01763046, 02012155, 02286878, 00540632, 00785863, 01067598, 01455394, 01836659, 02013340, 02284970 Ref. RMS Record 3335301, 3698868, 3985603, 4356836, 4825860, 5710680, 5274750 SR 3.4.14.2 - Verify RHR System Interlock Prevents Values from Being Opened, RCS >
474 psig: One pressure transmitter (PT-403) and one rack component (PC-403) provide this interlock to the controls of value RHR-750. Any calibration out-of-tolerance conditions identified will be compared to the as-found/as-left values of Section 9 of RNP-I/INST-1126 to determine if acceptable limits were exceeded.
No issues were identified that required additional review. Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00534562, 00780303, 01060397, 01756592, 02007178, 02288995, 00534563, 00780302, 01060396, 01446497, 01446498, 01756594, 02007179 SR 3.4.15.5 - Containment Fan Cooler Condensate Flow Rate Monitor: Four differential pressure transmitters (LT-701, LT-702, LT-703, LT-704) and four indicator/relays (LI-701, LI-702, LI-703, LI-704) provide indication for this function. There are no TS setpoints or Allowable Values; therefore, the calibration tolerance will be used for the acceptable limits criteria.
In 2005, LT-702 and LT-703 were found out-of-tolerance high with respect to setpoint. This would have resulted in higher level reading than compared to actual level; however, the transmitters were still capable of responding to an increase in level.
 
In 2008 all four pressure transmitter were found out-of-tolerance low with respect to setpoint.
This would have resulted in a lower level reading than compared to actual level; however, the transmitters were still capable of responding to an increase in level.
In 2010 all four pressure transmitter were found out-of-tolerance high with respect to setpoint.
This would have resulted in a higher level reading than compared to actual level; however, the transmitters were still capable of responding to an increase in level.
In 2013, LT-703 and LT-704 were found out-of-tolerance low with respect to setpoint. This would have resulted in a lower level reading than compared to actual level; however, the transmitters were still capable of responding to an increase in level.
In 2015, LT-703 was found out-of-tolerance high with respect to setpoint. This would have resulted in a higher level reading than compared to actual level; however, the transmitter was still capable of responding to an increase in level.
In 2012, LI-704 was found out-of-tolerance at the High-High level alarm setpoint; however, the alarm was still functional on an increase in level.
Based on review of Technical Specification Bases B 3.4.15 this system is used to detect RCS leakage. Although the level transmitters were found out-of-tolerance on multiple occasions the calibration uses typical tolerances, not calculated tolerances. Also, there is no accuracy requirement for this function. The capability of the system to provide alarm function on an increase in standpipe level determines operability of the system. Once the high level alarm is received, the operators use the instruments as a flow rate monitor. The rate of raise in level determines the rate of water being collected. Even if the system is out-of-tolerance, the alarm will at some point be received. After that point the rate of increase would still be mostly linear.
The exception to this is if the components are out-of-tolerance in a non-linear fashion by a significant amount..
The out-of-tolerances reviewed here did exhibite non-linearity; however the magnitude was not substantial.
Although not required by Technical Specifications, operability of the level system is verified monthly by performance of OST-901. That procedure ensures level in each standpipe increases when expected. Also, based on performance of the 18-month surveillances, there have been no occurrences of the equipment failing to provide an indication of an increase in level; therefore, the system would have still provided the required alarm in response to increased level in the standpipes. The level would have been slightly in error; however, the amount of error would not have resulted in a misidentification of the sources, based on the fact the worst out-of-tolerance reading was less than 0.08 VDC or 0.4 feet.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00534575, 00780314, 01060411, 01446515, 01756601, 02007195, 02295991, 00653826, 00854952, 01125876, 01495922, 01778542, 02006642, 02281890
 
Note for Evaluation of SR 3.3.3.2 and 3.3.4.3: No Allowable Values are noted in the Technical Specifications for PAM Instrumentation and Remote Shutdown Instrumentation.
These functions provide the Control Room operators with indications to determine if systems used to mitigate an accident are functioning properly or to safety shutdown the plant from outside the Control Room. EOP/AOP procedures use these indications to determine when actions are required by the operators. These action levels are based on operator readings of the applicable indicators. Since the total loop uncertainties calculated in the associated uncertainty calculations are used to determine these actions levels, those will be used as the acceptable limits for the following evaluations, where available. Where an uncertainty calculation does not exist for the function, other means will be defined in the applicable evaluation for acceptable limits.
Specific to SR 3.3.3.2, recorders were not included in the evaluation. The TS requirement is for the required number of channels to be operable. The indicators were evaluated for these functions, since they will always be available as long as the instrument loop has power. The recorders require an additional power source to operate. Also, digital recorders are not typically subject to time dependent drift and do not have the capability to be adjusted.
SR 3.3.3.2 Item 3 - RCS Hot Leg Temperature: This function is performed by three RTDs (TE-413-1, TE-413-2, TE-423, TE-433), associated rack equipment (TM-413, TY-413, TM-577, TM-578) and indications (TI-413C, TI-423, TI-433). Evaluation of RTDs was performed generically and will not be repeated here.
SR 3.3.4.3 Item 3.a - RCS Hot Leg Temperature: This function is performed by one RTD (TE-413-1), associated rack equipment (TM-413, TY-413) and indications (TI-413B). Evaluation of RTDs was performed generically and will not be repeated here.
In 2009, two indicators were found out-of-tolerance low are one calibration point (TI-413A and TI-413B. This is in respect to the tolerances specified in RNP-I/INST-1064. The worst out-of-tolerance was approximately 20 degrees F from the indicated value at the 175 degrees calibration point. The indicators were within tolerance at all other calibration points.
In 2010, two indicators were found out-of-tolerance low (TI-413B and TI-413C). TI-413B had been replaced in 2009, following issues identified in the previous calibration. This appears to be a significant amount of drift and is most likely attributed to settling of the new indicator.
Although that cannot be confirmed it also is not evident of a repeat issue. TI-413C was within the calculation tolerance in RNP-I/INST-1064.
TI-413B was found out-of-tolerance on two occasions. The indicator was replaced between the two issues; therefore, corrective actions were performed. The second out-of-tolerance conditions was the first following replacement. Three calibration have taken place since that time with no identified issues. Therefore, replacement of the indicator fixed the problem.
TM-577 and TM-578 are calibrated during performance of MST-050 and MST-050-1 (previously EST-148). Review of performance of those procedures was performed as part of the SR 3.3.3.2 Items 15 through 18 - Core Exit Temperature review. That review did not identify any issues associated with these functions.
Based on this review surveillance testing of these functions are found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00629805, 00827462, 01097416, 01465081, 01751684, 01983202, 02262626
 
SR 3.3.3.2 Item 4 - RCS Cold Leg Temperature: This function is performed by three RTDs (TE-410, TE-420, TE-430), associated rack equipment (TM-410, TM-420, TM-430, TM-410B) and indications (TI-410C, TI-420, TI-430). Evaluation of RTDs was performed generically and will not be repeated here.
SR 3.3.4.3 Item 3.b - RCS Cold Leg Temperature: This function is performed by one RTD (TE-410), associated rack equipment (TM-410, TY-410) and indications (TI-410A, TI-410B).
Evaluation of RTDs was performed generically and will not be repeated here.
In 2006, repeater module TY-410 was found out-of-tolerance low; however, it was within the calculation tolerance of RNP-I/INST-1063. The component met acceptable limits.
Based on this review surveillance testing of these functions are found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00629805, 00827462, 01097416, 01465081, 01751684, 01983202, 02262626 SR 3.3.3.2 Item 5 - RCS Pressure, Wide Range: Two pressure transmitters (PT-402, PT-501),
associated rack equipment (PM-501) and indications (PI-402, PI-501) provide this function.
Calculations RNP-I/INST-1065 and RNP-I/INST-1127 apply to this function.
No issues were identified. Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00534562, 00780303, 01060397, 01446497, 01756592, 02007178, 02288995, 00544736, 00788246, 01047001, 01433217, 01745128, 01996785, 02285899, 00629803, 00827460, 01097413, 01465079, 01751682, 01983206, 02224327, 00661939, 00697775, 00898700, 01279354, 01560287, 01839005, 02052855 SR 3.3.3.2 Item 6 - RWST Level: Two differential pressure transmitters (LT-948, LT-969) and associated indications (LI-948, LI-969) provide this function. Although this is an 18-month surveillance, the transmitters are currently calibrated yearly. There are no plans to extend these calibration intervals; however, they could be at a later time. This evaluation will use the yearly data to determine if extension for a 24-month fuel cycle is acceptable.
In 2009, LT-948 was found out-of-tolerance at the highest calibration point; however, compared to the calculation as-found values listed in RNP-I/INST-1023, the transmitter was within the acceptable limits.
No other issues were identified. Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00658802, 00713183, 00791249, 00861663, 00976260, 01052382, 01135631, 01320407, 01414056, 01506546, 01874213, 01927494, 02069672, 02224382, 13381496, 00658801, 00712510, 00791248, 00861662, 00976259, 01052380, 01135629, 01320405, 01414058, 01506549, 01599447, 01769015, 01927492, 02069673, 02224383, 13381494, 00611611, 00809437, 01076443, 01439920, 01727387, 01964097, 02154568, 00516933, 00726300, 00976255, 01320397, 01599441, 01867644, 02105251 SR 3.3.3.2 Item 7 - Containment Sump Level, Wide Range: Two level transmitters (LT-801, LT-802) and associated indication (LI-801, LI-802) provide this function.
 
SR 3.4.15.3 Containment Sump Monitor: Two level transmitters (LT-801, LT-802) and associated indication (LI-801, LI-802) provide this function.
The level transmitters are not calibrated based on design of the components. They are functionally tested.
In 2008, LI-801 failed when it was being returned to service. The indicator met all as-found readings. The indicator was swinging over the scale when returned to service. This problem would have been identified during normal, monthly channel checks per SR 3.3.3.1.
In 2010, LI-801 was found out-of-tolerance when testing the lower and upper limits; however, the indicator was in tolerance during the five point calibration. The indicator was still capable of providing indication of CV sump level. This issue was with the loop test function, not a calibration problem.
Based on this review surveillance testing of these functions are found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00548508, 00788244, 01052773, 01438905, 01749792, 02001044 SR 3.3.3.2 Item 8 - Containment Pressure, Wide Range: Two pressure transmitters (PT-956, PT-957) and associated indications ( PI-956, PI-957) provide this function.
In 2007, PT-957 was found out-of-tolerance; however, based on the as-found values calculated in RNP-I/INST-1057, the transmitter was within tolerance.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00545500, 00788251, 01047521, 01433990, 01746044, 01998238 SR 3.3.3.2 Item 12 - Pressurizer Level: Three differential pressure transmitters (LT-459, LT-460, LT-461), associated rack equipment (LM-459, LM-460, LM-461) and indications (LI-459A, LI-460, LI-461) provide this function.
The level transmitters are evaluated in the SR 3.3.1.10 Item 8 evaluation, within this document.
No issues were identified for those components. This review is for the rack equipment and indications.
No issues were found that required additional review. Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00540631, 00785864, 01067596, 01455392, 01764616, 02013339, 02282800, 00539072, 00783715, 01065583, 01452828, 01762124, 02010531, 02288320, 00629807, 00827464, 01097412, 01465083, 01751680, 01983204, 02251980
 
SR 3.3.4.3 Item 4.a - Pressurizer Level: One differential pressure transmitter (LT-607D) and indications (LI-607D-1 and LI-607D-2) provide this function.
In 2005, LT-607D was found out-of-tolerance. However, no tolerance was indicated on the calibration data sheet. MMM-006 states a tolerance of 0.5% for transmitters. For LT-607D this would result in a tolerance of 0.02VDC. All as-found values were within the MMM-006 standard tolerance; therefore, this will not be considered to exceed acceptable limits.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00540630, 00785865, 01067597, 01455393, 01764615, 02013338, 02285901 SR 3.3.3.2 Item 13 - SG Level, Narrow Range: Nine differential pressure transmitters (LT-474, LT-475, LT-476, LT-484, LT-485, LT-486, LT-494, LT-495, LT-496) associated rack equipment (LM-474, LM-475, LM-476, LM-484, LM-485, LM-486, LM-494, LM-495, LM-496) and indications (LI-474, LI-475, LI-476, LI-484, LI-485, LI-486, LI-494, LI-495, LI-496) provide this function. There are three transmitters associated with each of three steam generators. The Technical Specifications require two per steam generator.
The transmitters have already been reviewed by the evaluation of SR 3.3.1.10 Item 13. No issues were identified for the transmitters. The review will be for the rack equipment and indications.
In 2012, LI-476 was found out-of-tolerance. The as-found also exceeded the calculated values of RNP-I/INST-1070. This exceeded acceptable limits.
No other issues were identified; therefore, the one issue with LI-476 did not exceed rare occasions.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00444381, 00656215, 00857767, 01129335, 01499674, 01783396, 02009520, 02242520, 00444382, 00656216, 00857768, 01129330, 01499675, 01783397, 02009521, 02271879, 00444380, 00656217, 00857766, 01129334, 01499676, 01783398, 02009965, 02219369 SR 3.3.3.2 Item 14 - Condensate Storage Level: Two differential pressure transmitters (LT-1454A, LT-1454B) and the associated indicators (LI-1454A, LI-1454B) provide this function.
In 2009, LI-1454A was found out-of-tolerance at one of the five calibration points; however, the as-found is within the calculated values of RNP-I/INST-1015. This does not represent equipment exceeding acceptable limits.
In December of 2012, LT-1454A and LT-1454B were found to have a deviation of >5%. Work Orders 01856817, 01862167 replaced these transmitters. Because of these replacements as-found values were not obtained. This is acceptable for this evaluation since the issues were identified by more frequent surveillances. Extending the 18-month surveillance would not have resulted in these components exceeding acceptable limits for an extended period. Also noted:
WO 01605051 does not have calibration data for these transmitters since they were replaced.
 
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00519681, 00728953, 00978930, 01325393, 01605051, 01870201, 02101352, 13313822, 01856817, 01862167 SR 3.3.3.2 Items 15 through 18 - Core Exit Temperature: This function is comprised of two independent trains. Each train consist of thermocouples located at various locations internal to the reactor, near the top of the fuel assemblies, three RTDs at the reference junction box, computer processor and display. Following is the list of components associated with this function:
Train A - TE-472A, TE-472B, TE-473A, TE-473B, TE-474A, TE-474B, TE-475A, TE-475B, TE-476A, TE-476B, TE-477A, TE-477B, TE-478A, TE-478B, TE-479A, TE-479B, TE-480A, TE-480B, TE-481A, TE-481B, TE-482A, TE-482B, TE-483A, TE-483B, TE-484A, TE-484B, TE-485A, TE-485B, TE-486A, TE-486B, TE-487A, TE-487B, TE-488A, TE-488B, TE-490A, TE-490B, TE-491A, TE-491B, TE-492A, TE-492B, TE-493A, TE-493B, TE-494A, TE-494B, TE-495A, TE-495B, TE-496A, TE-496B, TE-523, TE-524, TE-525, TM-577, TI-579 Train B - TE-497A, TE-497B, TE-498A, TE-498B, TE-499A, TE-499B, TE-500A, TE-500B, TE-501A, TE-501B, TE-502A, TE-502B, TE-503A, TE-503B, TE-504A, TE-504B, TE-505A, TE-505B, TE-506A, TE-506B, TE-507A, TE-507B, TE-508A, TE-508B, TE-509A, TE-509B, TE-510A, TE-510B, TE-512A, TE-512B, TE-513A, TE-513B, TE-514A, TE-514B, TE-515A, TE-515B, TE-516A, TE-516B, TE-517A, TE-517B, TE-518A, TE-518B, TE-519A, TE-519B, TE-520A, TE-520B, TE-521A, TE-521B, TE-522A, TE-522B, TE-526, TE-527, TE-528, TM-578, TI-580 Channel calibration is now performed by procedure MST-050 and MST-050-1; however, this historical review will look at data from previously performed procedure EST-148. Attachments 10.5 and 10.6 of EST-148 performed channel calibration of the components associated with this surveillance requirement. MST-050 and MST-050-1 were performed during the 2015 calibration. Attachments 23 and 24 of MST-050 and MST-050-1 are the applicable portions of the procedures for this review.
No issues were identified from this review. Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. RMS Record 3361917 (Train A, 2005), 3361921 (Train B 2005)
Ref. WO 01071082 (Both Trains 2008), 0145850401 (Both Trains 2010), 0176753501 (Both Trains 2012), 0201655501 (Both Trains 2013), 1341003701 (Train B 2015), 0227571001 (Train A 2015)
SR 3.3.3.2 Item 19 - Aux Feedwater Flow: Six differential pressure transmitters (FT-1425A, FT-1425B, FT-1425C, FT-1426A, FT-1426B, FT-1426C), associated square root extractor modules (FY-1425A, FY-1425B, FY-1425C, FY-1426A, FY-1426B, FY-1426C) and indications (FI-1425A, FI-1425B, FI-1425C, FI-1426A, FI-1426B, FI-1426C) provide this function.
In 2013, FT-1426A was found out-of-tolerance; however, based on RNP-I/INST-1055 the calculated as-found tolerance is 1.23% or 0.0492 VDC. All of the calibration points were found within the calculated tolerance; therefore, this is not considered an issue for this evaluation.
 
In 2013, FT-1426B was found out-of-tolerance; however, based on RNP-I/INST-1055 the calculated as-found tolerance is 1.23% or 0.0492 VDC. All of the calibration points were found within the calculated tolerance; therefore, this is not considered an issue for this evaluation.
In 2012, FT-1426C was found out-of-tolerance at the highest calibration point; however, based on RNP-I/INST-1055 the calculated as-found tolerance is 1.23% or 0.0492 VDC. All of the calibration points were found within the calculated tolerance; therefore, this is not considered an issue for this evaluation.
In 2013, FT-1426C was found out-of-tolerance; however, based on RNP-I/INST-1055 the calculated as-found tolerance is 1.23% or 0.0492 VDC. All of the calibration points were found within the calculated tolerance; therefore, this is not considered an issue for this evaluation.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00508331, 00721417, 00970158, 01312078, 01591130, 01862593, 02079258, 00508333, 00721419, 00970156, 01312079, 01591132, 01862595, 02079260, 00508332, 00721418, 00970157, 01312080, 01591131, 01862594, 02079259, 00510929, 00723794, 00973416, 01316349, 01595547, 01865480, 02083264, 00510931, 00723796, 00973415, 01316351, 01595549, 01865482, 02083266, 00510930, 00723795, 00973414, 01316350, 01595548, 01865480, 01865481, 02083265 SR 3.3.3.2 Item 20 - Steam Generator Pressure: Nine pressure transmitters (PT-474, PT-475, PT-476, PT-484, PT-485, PT-486, PT-494, PT-495, PT-496), associated rack equipment (PM-474A, PM-475A, PM-476A, PM-484A, PM-485A, PM-486A, PM-494A, PM-495A, PM-496A) and indications (PI-474, PI-475, PI-476, PI-484, PI-485, PI-486, PI-494, PI-495, PI-496) provide this indication function.
The following components have been evaluated in SR 3.3.2.7 Item 1.e evaluation. Those evaluations are applicable to this function; therefore, no additional evaluation is needed: PT-474, PT-475, PT-476, PT-484, PT-485, PT-486, PT-494, PT-495, PT-496.
In 2005, PI-474 was found out-of-tolerance. It also exceeded the calculated as-found values from RNP-I/INST-1043. This is considered to exceeded acceptable limits. The issue with PI-474 was the only issue that exceeded acceptable limits. This does not exceeded rare occasions.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00544737, 00789018, 01072350, 01459358, 01767950, 02016809, 02294665, 00455124, 00666901, 00869279, 01146806, 01517724, 01795546, 02020578, 02285206, 00541896, 00786343, 01062357, 01424873, 01710198, 01951582, 02075037, 02282671, 00540351, 00785366, 01062358, 01424872, 01710197, 01951581, 02151938 SR 3.3.3.2 Item 21 - Containment Spray Additive Tank Level: Two differential pressure transmitters (LT-970, LT-949) and indications (LI-970, LI-949) provide this indication function.
No issues were identified for the available work order records. It should be noted that 2009 was the last performance of this calibration. The frequency of calibration was incorrectly changed to
 
approximately 8 years (NCR 02031851). However, the data that was reviewed showed the components had no previous issues. In addition, the components were calibrated in 2016, for the first time in approximately seven years and were found in tolerance.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00550502, 00755766, 01009151, 01370208, 11903824 SR 3.3.4.3 Item 2.a - Pressurizer Pressure: One pressure transmitter (PT-607E) and indications (PI-607E-1, PI-607E-2) provide this indication function.
The calibration data sheet for PI-607E-2 does not contain tolerances. No calculation exist for this indicator. The calibration tolerances of PI-607E-1 will be used to determine acceptable limits.
In 2008, PI-607E-2 was found out-of-tolerance high at all points. This will be considered to exceed acceptable limits.
In 2013, PI-607E-2 was found out-of-tolerance high at all points. This will be considered to exceed acceptable limits There were two issues identified for indicator PI-607E-2. The indicator was still capable of indicating Pressurizer Pressure; however, in both cases the reading would have been elevated.
Even though there were issues with PI-607E-2, it is being recommended to extend the calibration interval to support a 24-month fuel cycle. Per TS Bases, only one indication is required; therefore, no case existed were both indications exceeded acceptable limits.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00540899, 00786110, 01068832, 01455755, 01764723, 02013725, 02284419 SR 3.3.4.3 Item 4.c - RWST Water Level: One differential pressure indicator/controller (LIC-947) provides this indication function.
No issues were identified. Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00623736, 00821902, 01090917, 01457328, 01780284, 01745013, 01977945, 02156782, 13374986 SR .3.4.3 Item 3.f - Condensate Storage Tank Level: One differential pressure transmitter (LT-1454C) and indication (LI-1454C) provide this indication function.
No issues were identified. Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00519681, 00728953, 00978930, 01325393, 01605051, 01870201, 02101352, 13313822
 
SR 3.3.4.3 Item 3.d - SG Pressure: Three pressure indicator/controllers (PIC-477, PIC-487, PIC-497) provide this indication function. Procedure PIC-840 performs calibration of these components along with other components applicable to operation of the Main Steam Relief Values. The portion of the calibration that is applicable to this SR is calibration of the steam line pressure pointers In 2005, the WO notes state that all indicators were found unsatisfactory; however, a review of the calibration data sheets determined PIC-477 was found out-of-tolerance at one calibration point, in one direction only. The as-found was 5 psi above the tolerance. The calibration data sheet uses a standard tolerance of +/- 2% of span, not a calculated tolerance.
The issue discussed above is the only identified issue with these components. The out-of-tolerance with PIC-477 did exceed what has been defined as acceptable limits; however, there was only one issue. Based on this it was only an issue on rare occasion.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00534580, 00780316, 01060413, 01446511, 01756610, 02007194, 02291830 SR 3.3.4.3 Item 3.e - SG Level, Wide Range: Three differential pressure transmitters (LT-607A, LT-607B, LT-607C) and indications (LI-607A-1, LI-607A-2, LI-607B-1, LI-607B-2, LI-607C-1, LI-607C-2) provide this indication function.
No tolerance is listed on the calibration data sheets for these components. No calculation exists for these components. MMM-006 provides maintenance personnel with standard tolerances to use when none are specified. Per MMM-006, the tolerance for the transmitters is +/- 0.5% of span and for indicators the tolerance is +/- 2% span; therefore, this will be used as the acceptable limits for this review.
In 2012, LI-607B-2 was found failed. The indicator was replaced. This issues would have been identified during performance of OST-918 to support SR 3.3.4.1 (31 days); therefore, extending this surveillance interval to support a 24-month fuel cycle would not result in an increase time which the component would have been failed.
In 2015, WO 02285900 did not have calibration data sheets for LI-607A-1, LI-607B-1 or LI-607C-1. The WO completion notes do not make reference to the indicators. The WO package does have the SC code for each of these indicators, which means satisfactory completion.
Also, no mention of adjustments is made in the WO. With no evidence contrary to satisfactory completion, these calibration are considered to meet acceptable limits.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00537166, 00782644, 01063673, 01450688, 01760236, 02009963, 02285900
 
SR 3.3.7.6 - Item 2 - Control Room Radiation Monitor: Radiation Monitor R-1 and associated equipment was replaced during refueling outage 29 in 2015; therefore, no meaningful conclusion can be drawn from an historical surveillance review.
Based on the equipment being newly installed, a determination of the acceptability for operation at 24-months between calibrations could not be determined. It is recommended to leave this SR as an 18-month frequency. This function will be the only one affected by leaving SR 3.3.7.6 at an 18-month frequency.
SR 3.8.1.14 - Verify Actuation of Sequenced Loads (ESFAS Timers): Twenty-four time delay relays (2-SIB1, 2-SIA, 2-RHRA, 2-SWA, 2-SWB, 2-HVH-1, 2-HVH-2, 2-AFA, 2-CCPB, 2-BR1, 2-17B, 2-SID1, 2-SIB2, 2-SIC, 2-RHRB, 2-SWC, 2-SWD, 2-HVH-3, 2-HVH-4, 2-AFB, 2-CCPC, 2-BR2, 2-27B, 2-SID2) sequence loads onto one of two emergency buses during a Safety Injection or Station Blackout.
OST-407 Verification of Component Response to Blackout Sequence verifies the actuation time of 2-CCPB and 2-CCPC. No issues were identified for these relays.
OST-163 Safety Injection Test and Emergency Diesel Generator Auto Start on Loss of Power and Safety Injection (Refueling) verifies the actuation time of 2-SIB1, 2-SIA, 2-RHRA, 2-SWA, 2-SWB, 2-HVH-1, 2-HVH-2, 2-AFA, 2-BR1, 2-17B, 2-SID1, 2-SIB2, 2-SIC, 2-RHRB, 2-SWC, 2-SWD, 2-HVH-3, 2-HVH-4, 2-AFB, 2-BR2, 2-27B, 2-SID2. No issues were identified for these relays.
PIC-018 Time Delay Relay Calibration Safeguards Train B and PIC-020 Time Delay Relay Calibration Safeguards Train A perform individual calibrations on each relay every other refueling outage (approximately 36-months +/- 25%). Four out-of-tolerances were identified from this review. All out-of-tolerance conditions occurred in 2007 (Ref. WO 00846967, 00756178). These out-of-tolerances were associated with relays 2-17B, 2-SID1, 2-27B and 2-SID2. These were the only out-of-tolerances identified.
Assuming the four out-of-tolerance conditions exceeded acceptable limits, this is not considered to exceed rare occasions. The basis for this conclusion is these were not repetitive findings and were not associated with the same relays. Also, based on the number of successful tests, which required no adjustment, these components are considered highly reliable.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. RMS Record 3364717, 3674890, 3990628, 4405866, 4887125, 5309388, 5736258, 3373022, 3676567, 3991958, 4415922, 4893877, 5342868, 5734889 Ref. WO 00545036, 00774940, 02047249, 00766990, 01414238, 02047251, 13338234, 00846967, 00756178
 
SR 3.4.1.4 - Verify by precision heat balance that RCS total flow rate is  97.3x106 lbm/hr:
This SR will performed within 24 hours of the plant reaching  90 reactor thermal power, following a refueling outage. All instrumentation used for this surveillance have recently been calibrated. There is no evaluation required for extension of this SR.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
SR 3.3.6.7 Items 3.a and 3.b - Containment Radiation, Gaseous and Particulate: Radiation monitors R-11 and R-12 provide signals to the Containment Ventilation Isolation logic.
SR 3.4.15.4 - Containment Atmosphere Radioactivity Monitor: Radiation monitors R-11 and R-12 provide alarm and indication functions.
Procedures RST-010 and RST-011 previously performed calibration of these radiation monitors.
Those procedures have now been superseded by CP-RST-911 and CP-RST-912 respectively.
The calibration procedures check the signal into the rate meter. All other components associated with this function (i.e. comparators) are digital, which is not associated with time dependent drift. The acceptance criteria for this SR will be the as-found data meets the acceptance criteria of the procedure.
In 2005, R-11 was found out-of-tolerance. This is considered to exceed acceptable limits.
Two issues with R-11 in 2005 and 2015 are the only identified problems with this function.
Although there are two occurrences of exceeding acceptable limits, it will not be considered to exceed rare occasion since the two issues were approximately nine years apart.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. RMS Record 3209789, 3490052, 3850944, 4190946, 4561508, 5213247, 5667211, 5667212, 3407751, 3694603, 4071594, 4298757, 4732062, 5667213 SR 3.3.2.7 Items 1.f and 4.d - High Steam Flow in Two Steam Lines with Low Tavg and SR 3.3.2.7 Item 6.b - Low Tavg Interlock: The following components provide this function:
PT-446, PM-446B, PM-474C, FC-474, FC-484, PM-494C, FC-494, FT-474, FT-484, FT-494 PT-447, PM-447B, PM-475B, FC-475, FC-485, PM-495B, FC-495, FT-475, FT-485, FT-495 TM-412H1, TM-412H2, TM-412H3, TM-412, TM-412N, TM-412K, TC-412E TM-422H1, TM-422H2, TM-422H3, TM-422, TM-422N, TM-422K, TC-422E TM-432H1, TM-432H2, TM-432H3, TM-432, TM-432N, TM-432K, TC-432E RTD Low Level Amplifiers associated with these functions are evaluated in the SR 3.3.1.12 Item 5 and 6 - Over Temperature, Delta T and Over Power, Delta T. No issues were identified for the low level amplifiers.
Steam Flow Transmitters are zero shifted for static pressure when starting the plant from each refueling outage. This zero shift takes place soon after the calibration is performed. To account for this zero shift in the as-found values, the zero shift from the previous outage is subtracted from each as-found value. See Attachment R of this engineering change for supporting data.
The zero shift is performed at the lower span.
 
Since it is performed soon after the calibration, drift and other errors are assumed to be negligible over the entire span and the shift is linear over the span. Based on this assumption, the zero shift is subtracted from all calibration points, not just the lower span.
After the zero shift was applied to the as-found values only one transmitter out-of-tolerance condition was identified. In 2014, FT-484 was found out-of-tolerance high at its highest calibration point. This would be considered a shift in the conservative direction; however, since it is the only out-of-tolerance condition identified it will be considered to exceed acceptable limits, for conservatism.
In 2008, PM-447B was found out-of-tolerance low. This summator provides the Channel IV, First Stage Pressure signal for comparison with Channel IV Steam Flow signals. It also exceeded the as-found values of RNP-I/INST-1045. This component being out-of-tolerance low would represent lower power levels to compare to steam flow. This would be a conservative condition.
In 2013, PM-447B was found out-of-tolerance low. This summator provides the Channel IV, First Stage Pressure signal for comparison with Channel IV Steam Flow signals. It also exceeded the as-found values of RNP-I/INST-1045. This component being out-of-tolerance low would represent lower power levels to compare to steam flow. This would be a conservative condition.
In 2009, PM-494C was found out-of-tolerance low. This summator provides the Channel III, SG C Steam Flow signal for comparison with Channel III First Stage Pressure signal. It exceeded the as-found values of RNP-I/INST-1045 at the highest point only; therefore, it will be considered to exceed acceptable limits.
In 2005, TM-412N was found out-of-tolerance high. This summator provides a signal representing the average of Loop #1, Hot Leg RTDs. No uncertainty calculation existed at the time of this out-of-tolerance to determine the as-found value. In 2014, calculation RNP-I/INST-1154 was issued. That calculation determined as-found values for this Hagan module in Section 6.3. Based on the as-found values calculated in RNP-I/INST-1154, the module did not exceed the calculated as-found.
One transmitter out-of-tolerance condition was classified to exceed acceptable limits. It should be noted this was a conservative classification and is not the standard which all of the components will be gauged. This was the only issue and is not considered to exceed rare occasion.
One rack component was identified to exceed acceptable limits. This was the only occurrence and does not exceed rare occasion.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00539895, 00785242, 01066866, 01454702, 01763331, 02012523, 02286946, 00566755, 00788414, 01072751, 01459686, 01768657, 02017886, 02285282, 00455125, 00666900, 00869280, 01146807, 01517725, 01795547, 01976117, 02203147, 00455126, 00666902, 00869281, 01146805, 01517726, 01795545, 01990881, 02020579, 02208181, 00496100, 00704103, 00904212, 01288502, 01568931, 01846258, 02060159, 02276620, 00499691, 00708661, 00954364, 01295004, 01574910, 01851294, 02066030, 02278730,
 
00491897, 00701435, 00901886, 01284936, 01565606, 01842950, 02057303, 02285506, 00499899, 00708972, 00954682, 01575522, 01851758, 02088514, 00537760, 00783069, 01064409, 01451769, 01761718, 02010396, 02284969, 00539518, 00784264, 01066473, 01454567, 01763046, 02012155, 02286878, 00540632, 00785863, 01067598, 01455394, 01836659, 02013340, 02284970, 00534579, 00780307, 01060412, 01446510, 01756609, 02007188, 13312895 SR 3.3.2.7 Items 1.g and 4.e - High Steam Flow in Two Steam Lines with Low Steam Line Pressure: The following components provide this function:
PT-446, PM-446B, PM-474C, FC-474, FC-484, PM-494C, FC-494, FT-474, FT-484, FT-494 PT-447, PM-447B, PM-475B, FC-475, FC-485, PM-495B, FC-495, FT-475, FT-485, FT-495 PT-474, PT-485, PT-496, PC-474A, PC-485A, PC-496A The following components have been evaluated in SR 3.3.2.7 Item 1.f and 4.d evaluation.
Those evaluations are applicable to these functions; therefore, no additional evaluation is needed: PT-446, PM-446B, PM-474C, FC-474, FC-484, PM-494C, FC-494, FT-474, FT-484, FT-494, PT-447, PM-447B, PM-475B, FC-475, FC-485, PM-495B, FC-495, FT-475, FT-485, FT-495.
The following components have been evaluated in SR 3.3.2.7 Item 1.e evaluation. Those evaluations are applicable to these functions; therefore, no additional evaluation is needed: PT-474, PT-485, PT-496.
No issues were identified for the remainder of components evaluated. Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00455124, 00666901, 00869279, 01146806, 01517724, 01795546, 02020578, 02285206, 00541896, 00786343, 01062357, 01424873, 01710198, 01951582, 02075037, 02282671, 00540351, 00785366, 01062358, 01424872, 01710197, 01951581, 02151938 SR 3.3.1.10 and 3.3.1.13 Item 17.e - Turbine Impulse Pressure, P-7 Input: Two pressure transmitters (PT-446, PT-447) and associated rack components (PC-446A, PC-447E) provide this interlock function to the P-7 logic.
PT-446 and PT-447 have already been evaluated in the SR 3.3.2.7 Items 1.f and 4.d evaluation.
No issues were identified with those transmitters.
No issues were identified with the comparators. Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref WO 00455125, 00666900, 00869280, 01146807, 01517725, 01795547, 01976117, 02203147, 00455126, 00666902, 00869281, 01146805, 01517726, 01795545, 01990881, 02020579, 02208181
 
SR 3.3.3.2 Item 10 - Containment Area Radiation (High Range): Radiation Monitors R-32A and R-32B provide this indication function. These radiation monitors are calibrated per procedure RST-020.
All records were reviewed. No issues were identified during performance of the procedure.
Based on this review surveillance testing of this function is found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. RMS Record 3343692, 3343693, 3654557, 3654559, 3966004, 3966008, 4348594, 4348595, 4895120, 4895122, 5343945, 5727998 SR 3.3.1.11 Item 4 - Source Range Neutron Flux: Two channels of source range, neutron flux monitors (N-31, N-32) provide this reactor trip signal to the RPS. Rack components (NM-101, NM-102, NM-103, NM-104, NM-105) and comparator module (NC-101) in each monitor actuate the trip output function. Performance of calibration procedures LP-702 and LP-703 satisfy this Surveillance Requirement.
SR 3.9.2.2 - Nuclear Instrumentation - Source Range (Mode 6): Two channels of source range, neutron flux monitors (N-31, N-32) provide this indication function. Count rate monitor NI-101 provides the indication function in each monitor, along with NI-31B and NI-32B.
Performance of calibration procedures LP-702 and LP-703 satisfy this Surveillance Requirement.
In 2015, NI-101 and NI-31B indications, associated with NI-31, was found out-of-tolerance low.
This would have resulted in non-conservative readings of source range flux. This was a result of NM-104 having failed. The component had to be replaced. This would have also resulted in the signal to NC-101 being out-of-tolerance. This is not the result of drift; however, it will be considered to exceed acceptable limits.
In 2007, NI-32B indication, associated with NI-32, was found out-of-tolerance high. This would result in a conservative reading for source range flux and does not exceed acceptable limits.
There was one identified occurrence of exceeding acceptable limits; therefore, this does not exceed rare occasion.
Based on this review surveillance testing of these functions are found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00547708, 00993584, 01051901, 01436593, 01748708, 01999570, 02254864, 02267574, 00993672, 01051900, 01436592, 01748707, 01999569, 02265657 SR 3.3.3.2 Item 1 and 2 - Power Range and Source Range Neutron Flux: Two channels of gamma-metrics, neutron flux monitors (N-51, N-52) provide this indication function. The following components are associated with providing this function: NM-51A, NM-51B, NM-51C, NM-52A, NM-52B, NM-52C, NI-52A, NI-52B, NI-51A, NI-51B.
 
SR 3.3.4.3 Item 1.a - Source Range Neutron Flux: Two channels of source range, gamma-metrics, neutron flux monitors (N-51, N-52) provide this indication function. The following components are associated with providing this function: NM-51A, NM-51B, NM-51C, NM-52A, NM-52B, NM-52C, NI-52, NI-51.
In 2006, NI-51 was found out-of-tolerance low. The Technical Review of Calibration Data, included in the work order, determined the out-of-tolerance condition was conservative. Also, the out-of-tolerance error was small enough that it would not have affected the operators ability to verify that the reactor is shutdown. Therefore, this will not be considered to exceed acceptable limits.
In 2012, NI-51 was found out-of-tolerance. The Technical Review of Calibration Data, included in the work order, determined the out-of-tolerance condition would not have been discernable to the operators on a logarithmic scale. Therefore, this will not be considered to exceed acceptable limits.
Based on this review surveillance testing of these functions are found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00740884, 00756171, 01009603, 01370771, 01647327, 01904255, 02157092, 00814482, 00814600, 01009602, 01370770, 01647326, 01904254, 02167189 SR 3.3.1.11 Item 2.a - Power Range Neutron Flux, High: Four channels of power range, neutron flux monitors (N-41, N-42, N-43, N-44) and internal components of each monitor (NM310, NC306) provide this trip function to the RPS System.
SR 3.3.1.11 Item 2.b - Power Range Neutron Flux, Low: Four channels of power range, neutron flux monitors (N-41, N-42, N-43, N-44) and internal components of each monitor (NM310, NC305) provide this trip function to the RPS System.
SR 3.3.1.11&13 Item 17.c - Power Range Neutron Flux, P-8: Four channels of power range, neutron flux monitors (N-41, N-42, N-43, N-44) and internal components of each monitor (NM310, NC304) provide this interlock function to the RPS System.
SR 3.3.1.11&13 Item 17.d - Power Range Neutron Flux, P-10: Four channels of power range, neutron flux monitors (N-41, N-42, N-43, N-44) and internal components of each monitor (NM310, NC308) provide this interlock function to the RPS System.
Additionally, low and high flux signals are developed and used in the Overtemperature and Overpower reactor trips (Table 3.3.1-1, functions 5 and 6). The following additional, internal components of each monitor provide this signal to those functions: NM306 and NM307.
NM310 of each monitor is adjusted every 24-hours for SR 3.3.1.2; therefore, it is not calibrated to a specific tolerance during channel calibrations; therefore, it is not reviewed.
In 2005, NC306 of N-41 was found out-of-tolerance high. The calibration data sheet uses the as-left values for as-found which is conservative. Calculation RNP-I/INST-1049 states the calculated as-found tolerance is +/-2.91% Span. Based on the calculated as-found values, the component was in tolerance; therefore, this is not considered to exceed acceptable limits.
 
In 2007, NC308 of N-41 reset was found out-of-tolerance low. The calibration data sheet uses the as-left values for as-found which is conservative. Calculation RNP-I/INST-1049 states the calculated as-found tolerance is +/-3.21% Span. Based on the calculated as-found values, the component was in tolerance; therefore, this is not considered to exceed acceptable limits.
In 2007, NC306 of N-41 was found out-of-tolerance high. The calibration data sheet uses the as-left values for as-found which is conservative. Calculation RNP-I/INST-1049 states the calculated as-found tolerance is +/-2.91% Span. Based on the calculated as-found values, the component was in tolerance; therefore, this is not considered to exceed acceptable limits.
In 2008, NC306 of N-41 was found out-of-tolerance high. The calibration data sheet uses the as-left values for as-found which is conservative. Calculation RNP-I/INST-1049 states the calculated as-found tolerance is +/-2.91% Span. Based on the calculated as-found values, the component was in tolerance; therefore, this is not considered to exceed acceptable limits.
In 2008, NM306 of N-41 was found out-of-tolerance. The Technical Review of Calibration Data, attachment to the completed work order, determined this issue was within the allowable value given in TS and uncertainty calculations. Therefore, this is not considered to exceed acceptable limits.
In 2009, NM307 of N-42 was found out-of-tolerance. The Technical Review of Calibration Data, attachment to the completed work order, determined this issue was within the allowable value given in TS. Therefore, this is not considered to exceed acceptable limits.
In 2006, NC306 reset of N-43 was found out-of-tolerance high. This does not affect the trip function; therefore, this is not considered to exceed acceptable limits.
In 2007, NC306 of N-42 was found out-of-tolerance high. The calibration data sheet uses the as-left values for as-found which is conservative. Calculation RNP-I/INST-1049 states the calculated as-found tolerance is +/-2.91% Span. Based on the calculated as-found values, the component was in tolerance; therefore, this is not considered to exceed acceptable limits.
In 2009, NC305 of N-43 was found out-of-tolerance low on the action and reset function. The reset function has no impact on the TS function. The trip function was out-of-tolerance in a conservative manner; therefore, it did not exceed acceptable limits.
In 2013, NC306 of N-44 was found out-of-tolerance low. This trip function was out-of-tolerance in a conservative manner; therefore, it did not exceed acceptable limits.
No issues were identified that exceeded acceptable limits. Based on this review surveillance testing of these functions are found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00516931, 00726298, 00976253, 01320395, 01599439, 01867642, 02086047, 00550994, 00756168, 01009600, 01370768, 01647329, 01904256, 02167883, 00820503, 00820508, 01052373, 01414050, 01942939, 02167882, 00624149, 00822511, 01091379, 01458054, 01745609, 01978137, 02192995
 
SR 3.3.1.13 Item 17.b - Lower Power Reactor Trips Block, P-7: This interlock is derived in the relay logic cabinets. The signals that provide an input to this function have already been evaluated for SR 3.3.1.11 Item 17d and Item 17.e. No additional evaluation is required for this function.
SR 3.3.1.11&13 Item 17.a - Intermediate Range Neutron Flux, P-6: Two channels of intermediate range, neutron flux monitors (N-35, N-36) and internal components of each monitor (NM201, NC205) provide this interlock function to the RPS System.
SR 3.3.1.11 Item 3 - Intermediate Range Neutron Flux: Two channels of intermediate range, neutron flux monitors (N-35, N-36) and internal components of each monitor (NM201, NC206) provide this trip function to the RPS System.
No issues were identified that required additional evaluation. Based on this review surveillance testing of these functions are found to be acceptable to be extended to accommodate a 24-month fuel cycle.
Ref. WO 00413740, 00623738, 01001474, 01090915, 01457324, 01745010, 01977942, 02229305, 01001475, 01090916, 01457325, 01745011, 01977943, 02229306
 
U. S. Nuclear Regulatory Commission  to Serial: RNP-RA/17-0014 58 Pages (including cover page)
ATTACHMENT 7 DETAILED DRIFT EVALUATION METHODS
 
Problem Statement H.B. Robinson Steam Electric Plant Unit No. 2 (HBRSEP) is studying the ability to perform an instrument calibration extension to support a 24 Month Fuel Cycle. NRC Generic Letter 91-04 Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle provides the NRC guidance which HBRSEP must use to evaluate the issue of instrumentation errors caused by drift, in order to justify an increase in surveillance intervals to accommodate a 24-month fuel cycle.
This Engineering Evaluation will present the HBRSEP methodology, guidance, and detail required to perform a drift analysis using the historical As-Found / As-Left instrument calibration data in order to address and confirm the applicable requirements of GL 91-04 are met and support Instrument Setpoints per EGR-NGGC-0153.
References
: 1. Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle (Generic Letter 91-04), dated April 2, 1991
: 2. EPRI Technical Report TR-103335-R1, October 1998, Guidelines for Instrument Calibration Extension/Reduction - Revision 1 Statistical Analysis of Instrument Calibration Data.
: 3. EPRI Report 3002002556, Final Report, January 2014, Guidelines for Instrument Calibration Extension/Reduction - Revision 2 Statistical Analysis of Instrument Calibration Data.
: 4. EGR-NGGC-0153, Engineering Instrument Setpoints, Revision 12
: 5. AD-EG-ALL-1117, Design Analyses and Calculations, Revision 1
: 6. EGR-NGGC-0028, Engineering Evaluation, Revision 3
: 7. ASTM E178-08, Standard Practice for Dealing with Outlying Observations
: 8. OSC-9719, Duke Energy - Oconee Nuclear Station Instrument Drift Analysis Methodology In Support Of 24 Month Surveillance Interval, Revision 1
: 9. Beggs, William J. Statistics for Nuclear Engineers and Scientists, Part 1: Basic Statistical Inference, DOE Research and Development Report No. WAP-TM-1292, February 1981.
: 10. EGR-NGGC-0009, Engineering Change Product Selection and Initiation, Revision 8
: 11. NUREG-1475, Applying Statistics, Revision 1.
: 12. ANSI N15.15-1974, Assessment of the Assumption of Normality (Employing Individual Observed Values)
: 13. EPRI TR-1009603, Final Report, July 2005, Instrument Drift Study - Sizewell B Nuclear Generating Station
: 14. EPRI TR-1003695, Final Report, December 2004, Equipment Condition Assessment Volume 1:Application of On-Line Monitoring Technology Solution or Conclusion This Engineering Evaluation clarifies the methodology, guidance, and detail required to perform a drift analysis using the historical As-Found / As-Left instrument calibration data in order to address and confirm the applicable requirements of GL 91-04 are met for HBRSEP. Any changes to plant design function or methods of performing or controlling a design function, such as revisions to calculations, instrumentation tolerances, or procedures, found to be necessary by applying this methodology will be controlled via a separate and appropriate Engineering Change Product in accordance with existing procedures.
 
Bounding Technical Requirements Per EGR-NGGC-0153 Engineering Instrument Setpoints Section 9.4.2, Reference 2.29 contains detailed guidelines for analysis of instrument drift based on calibration history.
Reference 2.29 refers to EPRI Technical Report TR-103335-R1, October 1998, Guidelines for Instrument Calibration Extension/Reduction - Revision 1: Statistical Analysis of Instrument Calibration Data. EPRI TR-103335-R1 was revised by EPRI and taken to Revision 2 during January, 2014. A new report number was assigned and is 3002002556. Revision 2 incorporates experience gained since 1994 and also addresses key regulatory issues that have surfaced since the previous revision were issued. Furthermore, this document builds on the knowledge gained from related Electric Power Research Institute (EPRI) studies pertaining to the nature of instrument drift. This evaluation will review Revision 2 to ensure that the methodology documented below benefits from the lessons learned provided within Revision 2 and remains a conservative approach for use with the EGR-NGGC-0153 methodology.
This Engineering Evaluation will provide engineering guidance on use of the detailed guidelines contained in the EPRI Technical Report 103335, as endorsed by EGR-NGGC-0153. Therefore, the methodology is considered within the existing Bounding Technical Requirements. This Engineering Evaluation only documents the methodology. Any changes to plant design function or methods of performing or controlling a design function, such as revisions to calculations, instrumentation tolerances, or procedures, found to be necessary by applying this methodology will be controlled via a separate and appropriate Engineering Change Product in accordance with EGR-NGGC-0009 (Reference 10) or its successor.
Based upon the methodology being able to be applied to calculations for safety related component as found configurations, it is determined to be a Safety Related Engineering Evaluation. The reviews and approvals will be in accordance with EGR-NGGC-0028  requirements for a Non-PSA, SR, EVAL Impact Item 4.
Evaluation The basis for HBRSEP methodology, guidance, and detail that follows will be the Duke Energy Oconee Nuclear Station Methodology (Reference 8). By using this document, HBRSEP gains the insight and lessons learned from our fleet station that has already implemented a 24 Month Fuel Cycle. The methodology is updated to reflect current industry lessons learned from EPRI Report 3002002556 and for HBRSEP specific calibration practices and documentation.
 
Table Of Contents
 
==1.0 BACKGROUND==
 
2.0 OBJECTIVE/PURPOSE 3.0 DRIFT ANALYSIS SCOPE 3.1 Limited Scope 3.2 Included Devices 3.3 Relation to QA Condition/Nuclear Safety 4.0 DRIFT STUDY METHODOLOGY and DISCUSSION 4.1 Assumptions 4.2 Methodology 4.3 As-Found As-Left (AFAL) Calibration Drift Analysis 4.4 Data Collection 4.5 Data Grouping 4.6 Populating the Spreadsheet and Initial AFAL (RAW) Data Review 4.7 Outlier Review 4.8 Normality Testing 4.9 Time-Dependency Analysis 4.10 Drift Bias Determination 4.11 Time Dependent Analyzed Drift (AD) 4.12 Shelf Life Of Analysis Results 5.0 INSTRUCTIONS FOR PREPARING THE DRIFT CALCULATION/ANALYSIS 5.1 Performing a Drift Calculation/Analysis 5.2 Populating the Spreadsheet 5.3 Calculating Initial Statistics 5.4 Review Raw Data for Failures, Deficiencies and Errors 5.5 Testing For and Removal of Outliers 5.6 Normality Testing 5.7 Time-Dependency Evaluation 5.8 Drift Bias Determination 5.9 Calculate the Tolerance Interval/Analyzed Drift (AD) 5.10 As Found Tolerance 5.11 Ongoing Instrument Loop/Component Calibration As-Found/As-Left Evaluation Program 6.0 CALCULATION/ANALYSIS 6.1 Calculation/Analysis Content 6.2 Drift Analysis Details 6.3 Comparison of Analyzed Drift (AD) with Uncertainty Calculation Limits and Procedure Acceptance Criteria 7.0 DEFINITIONS 8.0 ATTACHMENTS Attachment 1 - Comments from Excel Services
 
==1.0  BACKGROUND==
 
NRC Generic Letter 91-04, Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle, dated April 2, 1991, provides the NRC guidance which H.B. Robinson Steam Electric Plant Unit No. 2 (HBRSEP) must use to evaluate the issue of instrumentation errors caused by drift, in order to justify an increase in surveillance intervals to accommodate a 24-month fuel cycle.
The NRC indicates that operating experience and available vendor data can provide insights on the increase in instrument errors that could occur with an increased calibration interval. The NRC continues these insights, with a program to monitor and assess the long-term effects of instrument drift, can provide the basis for increasing the refueling outage related calibration intervals for instruments that perform safety functions.1  to NRC Generic Letter 91-04 provides a summary of the seven issues that should be addressed:2 1.1 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. The surveillance and maintenance history for instrument channels should demonstrate that most problems affecting instrument operability are found as a result of surveillance tests other than the instrument calibration. If the calibration data show that instrument drift is beyond acceptable limits on other than rare occasions, the calibration interval should not be increased because instrument drift would pose a greater safety problem in the future.
1.2 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. The surveillance and maintenance history for instrument channels should demonstrate that most problems affecting instrument operability are found as a result of surveillance tests other than the instrument calibration. If the calibration data show that instrument drift is beyond acceptable limits on other than rare occasions, the calibration interval should not be increased because instrument drift would pose a greater safety problem in the future.
1.3 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. The surveillance and maintenance history for instrument channels should demonstrate that most problems affecting instrument operability are found as a result of surveillance tests other than the instrument calibration. If the calibration data show that instrument drift is beyond acceptable limits on other than rare occasions, the calibration interval should not be increased because instrument drift would pose a greater safety problem in the future.
1 Generic Letter 91-04, Enclosure 2, Discussion 2
Generic Letter 91-04, Enclosure 2, Justification for Increased Calibration Intervals
 
1.4 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. The surveillance and maintenance history for instrument channels should demonstrate that most problems affecting instrument operability are found as a result of surveillance tests other than the instrument calibration. If the calibration data show that instrument drift is beyond acceptable limits on other than rare occasions, the calibration interval should not be increased because instrument drift would pose a greater safety problem in the future.
1.5 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. The surveillance and maintenance history for instrument channels should demonstrate that most problems affecting instrument operability are found as a result of surveillance tests other than the instrument calibration. If the calibration data show that instrument drift is beyond acceptable limits on other than rare occasions, the calibration interval should not be increased because instrument drift would pose a greater safety problem in the future.
1.6 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. The surveillance and maintenance history for instrument channels should demonstrate that most problems affecting instrument operability are found as a result of surveillance tests other than the instrument calibration. If the calibration data show that instrument drift is beyond acceptable limits on other than rare occasions, the calibration interval should not be increased because instrument drift would pose a greater safety problem in the future.
1.7 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. The surveillance and maintenance history for instrument channels should demonstrate that most problems affecting instrument operability are found as a result of surveillance tests other than the instrument calibration. If the calibration data show that instrument drift is beyond acceptable limits on other than rare occasions, the calibration interval should not be increased because instrument drift would pose a greater safety problem in the future.
1.8 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 assumptions used to determine the rate of instrument drift with time based upon historical plant calibration data.
The licensee should have a body of as-found and as-left calibration data that permits the determination of the rate of instrument drift with time over the calibration interval.
This data should allow the determination of instrument drift for those instruments that perform safety functions.
 
1.9 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.
The magnitude of the instrument drift error that occurs over a longer interval is an important consideration to justify an extension of the calibration interval for instruments that perform safety functions. Licensees need to identify the applications where the calibration interval for these instruments depends upon the length of the fuel cycle and could be as long as 30 months (the extension limit for this calibration interval). Licensees should determine the projected value of the instrument drift error that could occur over a 30-month interval for each of these applications.
1.10 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 a 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.
Licensees should ensure that the projected value of instrument drift for an increased calibration interval is consistent with the values of drift errors used in determining safety system setpoints. These setpoints ensure that the consequences of accidents and anticipated transients are bounded within the assumptions of the safety analysis.
If the allowance for instrument drift that was used to establish trip setpoints for safety systems would be exceeded, licensees should establish new trip setpoints for safety systems. Instrument Society of America (ISA) Standard, ISA-S67.04-1982, Setpoints for Nuclear Safety-Related Instrumentation Used in Nuclear Power Plants, provides a methodology for evaluating instrument drift. The NRC endorsed this standard in Regulatory Guide 1.105, Instrument Setpoints for Safety-Related Systems. If a new setpoint must be used to ensure that safety actions will be initiated consistent with the assumptions of the safety analysis, this will require a TS revision to reflect a new trip setpoint value. If the combination of instrument drift errors and current trip setpoints is not consistent with existing safety analysis assumptions, licensees should perform a new safety analysis to confirm that safety limits will not be exceeded with the increased drift associated with longer calibration intervals.
[NOTE: Reg Guide 1.105, Rev. 3 (December, 1999) endorsed Part 1 of ISA S67.04-1994. Also, part II Methodologies for the Determination of Setpoints for the Nuclear Safety-Related Instrumentation, of ISA-S67.04-1994 was not addressed by this regulatory guide3].
3 Regulatory Guide 1.105, Revision 3, B. Discussion & C. Regulatory Position
 
1.11 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.
Licensees should determine the effect of instrument errors on control systems used to effect a safe shutdown. Licensees must confirm that the instrument errors caused by drift will not affect the capability to achieve a safe plant shutdown.
1.12 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.
Licensees should take care to avoid errors or oversights when establishing acceptance criteria for plant surveillance procedures that are derived from the assumptions of the safety analysis and the results of the methodology for determining setpoints. The NRC staff experience is that licensees have encountered problems when asked to confirm that instrument drift and other errors and assumptions of the safety and setpoint analyses are consistent with the acceptance criteria included in plant surveillance procedures. This review should include channel checks, channel functional tests, and the calibrations of channels for which surveillance intervals are being increased.
1.13 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.
Finally, licensees should have a program to monitor calibration results and the effect on instrument drift that will accompany the increase in calibration intervals. The program should ensure that existing procedures provide data for evaluating the effects of increased calibration intervals. The data should confirm that the estimated errors for instrument drift with increased calibration intervals are within the limits projected.
In summary, licensees can provide a justification for increased surveillance intervals for instrument channel calibration by addressing each of the items noted herein.
 
2.0    OBJECTIVE/PURPOSE The purpose of this document is to establish the Duke Energy methodology, guidance and detail required to perform a drift analysis using the historical As-Found / As-Left instrument calibration data in order to address and confirm the applicable requirements of GL 91-04 are met.
The calibration data is collected from RNP surveillance and maintenance procedure records obtained from the RNP Records Management System (RMS). This methodology will be used as a means of characterizing the performance of an instrument loop, component, or group of components as follows:
2.1 Quantifying loop and/or component drift characteristics within defined probability limits to gain an understanding of the expected behavior for the loop and/or component by evaluating past performance. (GL 91-04 Item 2) 2.2 Estimating loop and/or component drift to review for integration into existing instrument uncertainty calculations if necessary. (GL 91-04 Item 4) 2.3 Establishing a technical basis for extending calibration and surveillance intervals (18 to 24 months) using historical calibration data. The required time interval for which the drift study data must be computed is the required calibration interval plus 25%, or 24 months + (0.25 x 24 = 6) months for a total interval of 30 months. Provide a list of the channels by TS section that identifies the instrument applications to be extended using the methodology of this EC EVAL. (GL 91-04 Item 3) 2.4 Evaluating extended calibration intervals (18 to 24 months) in support of longer fuel cycles. (GL 91-04 Item 3) 2.5 As an analysis aid for reliability centered maintenance practices (e.g., optimizing calibration frequency, 18 to 24 months) 3.0    DRIFT ANALYSIS SCOPE 3.1      Limited Scope The scope of this design guide is limited to the calculation of the expected performance for a component, group of components or loop, utilizing past calibration data.
Duke Energy Progresss Procedure EGR-NGGC-0153 Engineering Instrument Setpoints, provides guidance to determine instrument or loop accuracies. For the topic of drift, EGR-NGGC-0153 refers the user to EPRI TR-103335-R1 for detailed guidelines for analysis of instrument drift based upon calibration history.
The detailed guidelines within EPRI TR-103335-R1 can be used as the methodology for the creation of calculations in accordance with Duke Energy Procedure, AD-EG-ALL-1117 Design Analyses and Calculations. The conclusions and analyzed drift value outputs from the drift calculations, performed using the EPRI detailed guidelines, will be utilized, as required, to update the associated instrument uncertainty calculations.
 
The analysis techniques described below are based on determining a statistically derived value of drift by analyzing the instrument loop and/or component as-found and as-left calibration measurement values recorded in calibration or surveillance testing of the instrument loop and/or component. This analysis methodology is termed as-found as-left analysis (AFAL analysis).
The scope of the instrument applications analyzed is limited to those instrument loops and/or components that perform Safety Functions, including those which provide the capability for Safe Shutdown and which are currently subject to the RNP Tech. Spec. required 18-month calibration interval. However, non-Tech Spec, non-Safety Related instruments may be used for additional drift data if necessary. These instruments would meet the same make/model/input/output requirements as the Tech Spec instruments analyzed.
The existing RNP Instrument Setpoint/Uncertainty calculations will be reviewed to ensure the drift values determined in the AFAL analysis are bounding with respect to the uncertainty terms developed in the RNP Instrument Setpoint/Uncertainty calculations. This will be documented in a future Engineering Change.
3.2 Included Devices A drift analysis may be performed on all regularly calibrated devices where as-found and as-left data is recorded. The scope of this methodology includes, but is not limited to, the following list of devices:
3.2.1 Transmitters (Differential Pressure, Flow, Level, Pressure, Temperature, etc.)
3.2.2 Bistables (Trip Units, Alarm Units, etc.)
3.2.3 Indicators (Analog, Digital) 3.2.4 Switches (Differential Pressure, Flow, Level, Pressure, Temperature, etc.)
3.2.5 Signal Conditioners/Converters (Summers, E/P Converters, Square Root Converters, etc.)
3.2.6 Recorders (Differential Pressure, Flow, Level, Pressure, Temperature, etc.)
3.2.7 Monitors & Modules (Radiation, Neutron, Pre-Amplifiers, Buffer Amplifiers, etc.)
3.2.8 Relays (Time Delay, Undervoltage, Overvoltage, etc.)
3.3 Relation to QA Condition/Nuclear Safety This Engineering Evaluation is designated as Safety Related since it can provide the guidance for performing a Drift Analysis for Safety Related Quality Classification A instrumentation.
Based upon the methodology being able to be applied to calculations for safety related component as found configurations, it is determined to be a Safety Related Engineering Evaluation. The reviews and approvals will be in accordance with EGR-NGGC-0028 Attachment 1 requirements for a Non-PSA, SR, EVAL Impact Item 4. The following Reviews are required: Design Verifier, Other (Mod-Qual Engr Impact Review), REG-0010 Exempt, and Supervisor (Design Engineering Manager).
 
4.0 DRIFT STUDY METHODOLOGY and DISCUSSION 4.1  Assumptions Each Drift Analysis calculation makes the following three assumptions which are then proven or disproven in the statistical analysis. The analysis results are applied to the final Analyzed Drift term.
4.1.1    The AFAL drift sample data is assumed to be Normal and is analyzed for Normality through a series of steps. The data is checked through standard statistical means for determination of normality. This topic is discussed in detail in section 4.8.
4.1.2    The AFAL drift sample data is also assumed to be zero centered (the mean is zero based). See section 4.10 for a detailed discussion of how the mean is analyzed (drift bias determination).
4.1.3    Moderate time dependency in the AFAL drift sample data is assumed as a standard approach. Various techniques described in section 4.9 are then used to support or refute this assumption.
4.2  Methodology This guide will provide the methodology necessary for the analysis of As-Found and As-Left calibration data as a means of characterizing the performance of an instrument loop and/or component. The data will be used to determine the rate of instrument drift with time based on historical plant calibration data per the guidance contained within NRC Generic Letter 91-04.
The methodology defined herein will follow the methodology presented in the Electric Power Research Institute (EPRI) TR-103335 through Revision 2 (References 2 & 3). By letter dated December 1, 1997, from T.H. Essig, NRC, to R.W. James, EPRI (Reference 3), the NRC staff issued a status report documenting its concerns with TR-103335 Rev. 0.
The EPRI report was reissued as TR-103335-R1 in October, 1998, and Revision 2 as Final Report 3002002556 in January 2014. From Appendix E in Revision 2:
Revision 1 of the TR was issued in October 1998 to incorporate experience gained since the original issue and too address key regulatory issues. Revision 1 was not submitted to the US NRC for review, but has been referenced by some licensees with their LAR submittals. The following are excerpts or paraphrases from the US NRC Status Report on the Staff review of EPRI Technical Report (TR)-103335, Guidelines for Instrument Calibration Extension /Reduction Programs. These excerpts are followed by the evaluation of how the concerns were addressed in Revisions 1and 2 of the TR.
The NRC has not issued a formal review of TR-103335 Revision 1 or Revision 2.
Refer to the EPRI documents for a more detailed description of the AFAL method than presented here. Only such modifications, as are necessary to accommodate RNP plant specific issues and the NRC issues addressed in the above referenced Status Report, will be incorporated into the industry accepted methodology. Duke Procedure EGR-NGGC-0153, applicable to legacy Progress Energy plants, endorses TR-103335 Revision 1. Lessons learned incorporated into the EPRI Revision 2 report will be reviewed and incorporated into this methodology when determined to be a conservative approach or more developed method than presented in Revision 1.
 
Fuel cycle extension efforts require an analysis of plant-specific instrument performance to demonstrate that the longer calibration interval will not result in larger than expected drift. The analysis techniques described herein are based on determining a statistically derived value of drift by analyzing the as-found and as-left measurements recorded during calibration or surveillance of the instruments. The details of this statistical analysis are given in this section.
4.3 As-Found As-Left (AFAL) Calibration Drift Analysis 4.3.1  Although TR-103335 discusses alternate variations by which to analyze drift, the AFAL Calibration Analysis has been selected for use in this review. The following information can be obtained by evaluating the AFAL data for an instrument or group of instruments:
4.3.1.1      The typical loop and/or component drift between calibrations (random in nature).
4.3.1.2      Any tendency for the loop and/or component to drift in a particular direction (bias).
4.3.1.3      Any tendencies for the loop and/or component drift to increase in magnitude over time.
4.3.1.4      Confirmation that the setting or calibration tolerance is appropriate for the loop and/or component.
4.3.2  General Features of AFAL Drift Analysis 4.3.2.1      Methodology evaluates historical calibration data only: Data is obtained from instrument loop and/or component calibration and maintenance records.
4.3.2.2      Present and future performance is based on statistical analysis of past performance.
4.3.2.3      Data can be analyzed starting from instrument installation up to the present or only the more recent data can be evaluated.
4.3.2.4      Since only historical data is evaluated, the method is not intended as a tool to identify individual faulty instruments. It can be used to demonstrate that a particular instrument, model, or application is performing well or poorly.
4.3.2.5      A similar class of instruments, i.e., same make, model, application, is to be evaluated.
4.3.2.6      The methodology is less suitable for evaluating the drift of a single instrument loop and/or component due to statistical analysis penalties that occur with smaller sample sizes.
4.3.2.7      The methodology is based on Robinson surveillance procedure calibration data and is thus traceable to calibration standards.
4.3.2.8      The methodology determines plant-specific drift for a particular instrument loop and/or component that can be compared to the Robinson Instrument Setpoint/Uncertainty calculations.
The value of drift represents the plant specific performance of this loop and/or component.
 
4.3.2.9  The methodology is designed to support the analysis of longer calibration intervals for 18 to 24-month fuel cycle extensions and is consistent with the NRC expectations described in Reference 1.
4.3.3 Random Behavior 4.3.3.1  If the AFAL calibration data indicates that the instrument loop and/or component randomly drifts around its setting without a tendency to drift in a particular direction, the drift is referred to as random drift.
4.3.3.2  Per EPRI TR-103335 (References 2 & 3) in terms of AFAL analysis, the standard deviation of the AFAL drift data is used to compute the random portion of the instrument loop and/or component drift.
4.3.4 Bias Behavior 4.3.4.1  If the instrument loop and/or component consistently drifts in one direction, the drift is said to have a bias.
4.3.4.2  Per EPRI TR-103335 (References 2 & 3), in terms of AFAL analysis, the mean, or average value of the AFAL drift data, is used to compute the bias portion of the instrument loop and/or component performance. In an ideal case with no bias, the mean would have a value of zero, indicating that there was no tendency for the instrument to drift preferentially in one direction. However, if the instrument does drift preferentially in one direction, the mean of the AFAL analysis will be non-zero.
This deviation from a zero mean value shall be treated as a bias if statistically significant. See section 4.10, Drift Bias Determination for further guidance and discussion.
4.3.5 Analyzed Drift (AD) 4.3.5.1  Once the statistical tests are applied and the AFAL sample population passes specified testing, the Analyzed Drift term (AD18month) for the existing Technical Specification interval is calculated as: the +/- random term combined arithmetically with the bias term, but only if the bias term is determined to be significant, see examples in section 4.10.
4.3.5.2  The extended or 30-month Analyzed Drift term (AD30month) will then be extrapolated from the AD18month term as discussed in section 4.11.
 
4.3.6 Error and Uncertainty Content in AFAL Data 4.3.6.1    The As-Found versus the As-Left data includes several sources of uncertainty over and above loop and/or component drift. Each of the following sources of error can contribute to the magnitude of the AFAL value:
: 1. True drift representing a change, time-dependent or otherwise, in loop and/or component output over the time period between any two consecutive calibrations.
: 2. Accuracy errors present between any two consecutive calibrations.
: 3. Measurement and test equipment error between any two consecutive calibrations.
: 4. Personnel-induced or human-related variation or error between any two consecutive calibrations.
: 5. Normal temperature effects due to a difference in ambient temperature between any two consecutive calibrations.
: 6. Environmental effects on component performance, e.g.,
radiation, humidity, vibration, etc., between any two consecutive calibrations that cause a shift in component output.
: 7. Misapplication, improper installation, or other operating effects that affect component calibration between any two consecutive calibrations.
: 8. Instrument shifts associated with system operational changes (Shutdown, cooldown, depressurization).
4.3.7 Potential Effects of AFAL Data Analysis 4.3.7.1    Many of the items listed in Step 4.3.6 are not expected to have a significant effect on the measured As-Found and As-Left settings. Because of the many independent parameters contributing to the possible variance in calibration data, they will all be considered together and termed the instrument loop or component's Analyzed Drift (AD) uncertainty. This approach has the following potential effects on an analysis of the loop and/or component's calibration data:
: 1. The calculated variation may exceed any assumptions or manufacturer predictions regarding drift. Attempts to validate manufacturer's performance claims should consider the possible contributors to the calculated drift.
: 2. The magnitude of the calculated variation that includes all of the above sources of uncertainty may mask any true time-dependent drift. In other words, the analysis of AFAL data might not reveal any time dependency. This does not mean that time-dependent drift does not exist, only that it could be so small that it is negligible in the cumulative effects of component uncertainty, when all of the above sources of uncertainty are combined.
: 3. The AFAL drift value could possibly be used in place of more than just the drift term in the channel uncertainty calculation.
4.4 Data Collection 4.4.1 Sources of Data 4.4.1.1    Instrument Surveillance procedures and Calibration procedures (PMs) 4.4.1.2    Corrective Maintenance, Nuclear Station Modifications, and PM Replacements 4.4.2 How Much Data To Collect 4.4.2.1    The goal is to collect sufficient data for the instrument loop and/or component to make a statistically valid pool. As has been done at other utilities, a minimum of 30 drift values should be attained before the drift analysis can be performed without additional justification.
4.4.2.2    Table 4.2 provides the Tolerance Interval Factor (TIF) for various sample pool sizes. It should be noted that the smaller the pool the larger the TIF. A tolerance interval factor is a statement of confidence that a certain proportion of the total population is contained within a defined set of bounds. For example, a 95%/95% TIF indicates a 95% level of confidence that 95% of the population is contained within the stated interval. Generally, sample sizes of greater than 30 are acceptable. AFAL analysis performed with a smaller sample size must have justification provided within the analysis documentation.
4.4.2.3    The total population of instrument loop and/or components - all makes, models, and applications - that will be analyzed must be known.
4.4.2.4    For each selected loop and/or component in the sample, enough historic calibration data should be provided to ensure that the loop and/or component's performance over time is understood.
4.4.2.5    Specific justification in the drift study is required to document the sampling plan.
4.4.3 Documentation associated with Robinson PM Work Orders is available through the Passport Applications Menu. The completed instrument calibration procedures that contain the data recorded during the instrument calibrations can be located by WO number by accessing the EDB Portal. Digitized records date back to approximately 2000. Before 2000, searches within Microfiche would be necessary.
 
4.4.3.1 In the Passport Applications Menu, select EDB Portal.
4.4.3.2 An EDB Portal Filter will launch. State the Tag Number for which you are searching information and select search 4.4.3.3 EDB Portal: Equipment Results will display. Check the box to the left of Details for the row of the tag number you are interested in, check the box to the left of History for historical data, and select the PM W/O tab, and rows of historical PM Work Orders will appear, if applicable. Select the RMS hyperlink to view the digitized record from the Record Management System. This method can be followed to research other critical information such as CM W/O for Corrective Maintenance Work Orders, PMR/STR for Preventative Maintenance Change Requests, NCR for Corrective Action Program items, EC for Engineering Changes, etc.
 
4.5    Data Grouping 4.5.1 Grouping Calibration Data 4.5.1.1  The analysis goal for Robinson Nuclear is to combine the Technical Specification functionally equivalent loops and/or components which are normally calibrated using the same or similar procedure(s) into a single statistical group for the drift analysis.
For example, the following table identifies RNP procedures that could be evaluated for a single statistical group,:
Procedure  Title LP-027      STEAM GENERATOR #1 NARROW RANGE (N/R) LEVEL CHANNEL 476 LP-028      STEAM GENERATOR #2 NARROW RANGE (N/R) LEVEL CHANNEL 486 LP-029      STEAM GENERATOR #3 NARROW RANGE (N/R) LEVEL CHANNEL 496 LP-030      STEAM GENERATOR #1 NARROW RANGE (N/R) LEVEL CHANNEL 474 LP-031      STEAM GENERATOR # 2 NARROW RANGE (N/R) LEVEL CHANNEL 484 LP-032      STEAM GENERATOR #3 NARROW RANGE (N/R) LEVEL CHANNEL 494 LP-033      STEAM GENERATOR #1 NARROW RANGE (N/R) LEVEL CHANNEL 475 LP-034      STEAM GENERATOR #2 NARROW RANGE (N/R) LEVEL CHANNEL 485 LP-035      STEAM GENERATOR #3 NARROW RANGE (N/R) LEVEL CHANNEL 495
 
4.5.1.2    Example of Groupings 4.5.1.2.1    All devices of same manufacturer, model and range, covered by the same Surveillance Test.
4.5.1.2.2    All transmitters used to monitor a specific parameter e.g. pressurizer level (assuming that all transmitters are the same manufacturer, model and range).
4.5.1.2.3    All transmitters of a specific manufacturer, model that have similar spans and performance requirements.
4.5.1.2.4    All control room indicators of a specific manufacturer and model.
4.5.2 Rationale for Grouping Loop and/or Components into a Larger Sample.
4.5.2.1    A single Robinson Nuclear unit loop and/or component analysis may result in too few data points to make statistically meaningful performance predictions.
4.5.2.2    Smaller sample sizes associated with a single loop and/or component may unduly penalize performance predictions by applying a larger Tolerance Interval Factor to account for the smaller data set. Larger sample sizes results in greater confidence and assurance of representative data that in turn reduces the uncertainty factor.
4.5.2.3    Larger groupings of loop and/or components into a sample set for a single population ultimately allows the user to state the RNP-specific performance for a particular make, model and Tech. Spec. function of component.
4.5.2.4    An analysis of smaller sample sizes is more likely to be influenced by non-representative variations of a single loop and/or component (outliers).
4.5.2.5    Grouping similar components together, rather than analyzing them separately, is more efficient and minimizes the number of separate calculations that must be maintained.
4.5.3 Combining Loops and/or Components into a Single Group 4.5.3.1    From EPRI TR-103335 (References 2 & 3), section 5.3, when grouping instruments together into a sample set for a single population, try to answer the following questions:
: 1. Are the grouped instruments of the same make and model?
: 2. Do the grouped instruments receive the same type of signal?
: 3. Do the grouped instruments have similar operating characteristics?
: 4. Do the grouped instruments have similar operating spans?
: 5. Do the grouped instruments have the same calibration
 
check points?
: 6. Are the grouped instruments exposed to similar operating environments?
: 7. Are the grouped instruments calibrated in the same manner?
: 8. Is there a reasonable analysis goal that warrants grouping the instruments together?
4.5.3.2 Standard statistics texts provide methods that can be used to determine if data from similar types of components can be pooled into a single group. If different groups of instruments have essentially equal variances and means at the desired statistical level, the data for the groups can be pooled to form a single group. EPRI TR-103335 says that instruments of a single make and model such as signal isolators or control room indicators could be pooled into a single group for analysis. However, sensors of the same make and model but with different spans could not always be combined into a single group. Based on studies performed by EPRI, most AFAL analyses will have near-zero means. Consequently, two groups of instruments really only need to have near-equal variances to pass a data pooling test. For example, it might be possible to find a group of pressure transmitters that have the same variance as the control room indicators. But, that does not mean that the transmitters and indicators should be combined into a single group. See Section 5.3 of EPRI TR-103335 (References 2 & 3), for considerations when combining instruments into a single group.
4.5.3.3 A t-Test (two samples assuming unequal variances) , as described in Section B.11.1 of Reference 3, may be performed on the proposed components to be grouped. The t-Test returns the probability associated with a Student's t-Test to determine whether the means from two samples are significantly different. The t-Test is performed using the "t-Test: Two-Sample Assuming Unequal Variances" within an Excel spreadsheet with the Hypothesized Mean Difference set to 0, and the level of significance (Alpha) set to 0.05. If the returned t Stat value is less than the returned t Critical two-tail value, the two means are essentially equal.
4.5.3.4 The F-distribution test, as described in Section B.11.2 of Reference 3, may be used to test the equality of two sample variances. The F statistic is the ratio of the larger to smaller variances of the two samples. The critical value of F can be determined using the Excel FINV function with the probability equal to 0.025, degrees of freedom 1 equal to the number of the samples minus 1 in the group with the larger variance, and the degrees of freedom 2 equal to the number of samples minus 1 in the group with the smaller variance. If the calculated F statistic is less than or equal to the critical value of F, the two variances are essentially equal.
 
4.6 Populating the Spreadsheet and Initial AFAL (RAW) Data Review Once the Raw data is combined (as required) and in the correct format (see Section 5.2, Populating the Spreadsheet and Section 5.3, Calculating Initial Statistics), initial data review using Outlier testing can be useful in the initial processing of the raw data to help to identify failures, deficiencies and data errors that require correction or removal. For any values that show up as outliers, analyze the raw data to determine if the data is erroneous. If data failures, deficiencies or errors exist, filter the data into the final data set and re-perform the analysis. Repeat the careful data examination until all erroneous data has been removed. Justification for removal of the erroneous data must be documented in the Calculation/Analysis.
The number of data points, the average and the sample standard deviation shall be determined for each calibration point, see Section 6 of EPRI TR-103335 (References 2 & 3).
Data Cleanup 4.6.1    An initial review of the data is necessary to eliminate any points that are invalid with respect to a statistical analysis. That is, an outside influence affected the recorded value. This can include any of the following (examples taken from EPRI-103335):
4.6.1.1      Data Transcription Errors - Calibration data can be recorded incorrectly on the original calibration data sheet.
4.6.1.2      Calibration Errors - Improper setting of a device at the time of calibration would indicate larger than normal drift during the subsequent calibration.
4.6.1.3      Measuring & Test Equipment (M&TE) Errors - Improperly selected or miscalibrated test equipment could indicate drift, when little or no drift was actually present.
4.6.1.4      Scaling or Setpoint Changes - Changes in scaling or setpoints can appear in the data as larger than actual drift points unless the change is detected during the data entry or screening process.
4.6.1.5      Failed Instruments - Calibrations are occasionally performed to verify proper operation due to erratic indications, spurious alarms, etc. These calibrations may be indicative of component failure (not drift), which would introduce errors that are not representative of the device performance during routine conditions.
4.6.1.6      Design or Application Deficiencies - An analysis of calibration data may indicate a particular component that always tends to drift significantly more than all other similar components installed in the plant. In this case, the component may need an evaluation for the possibility of a design, application, or installation problem, or malfunction, or poor device performance. Including this particular component in the same population as the other similar components may skew the drift analysis results.
 
4.7 Outlier Review 4.7.1  Detection of Outliers 4.7.1.1  ASTM Standard E178-08 provides several methods for determining the presence of outliers. This methodology utilizes the Critical Values for t-Test. The t-Test utilizes the values listed in Table 4.1 with an upper significance level of 2.5% to compare a given data point against. Note that the critical value of t increases as the sample size increases. This signifies that as the sample size grows, it is more likely that the sample is truly representative of the population. The t-Test assumes that the data is normally distributed.
Since we are most often interested in outliers that may exist on either side of the mean, the desired significance must be divided by two when applying the table values. Thus, for a desired 95% probability that the data point is contained within the normal population, the required significance level would be (1-0.95)/2 = 0.025 or 2.5%, and for a desired 99% probability level, the required significance level would be (1-0.99)/2 =
0.005 or 0.5%.
4.7.1.2  t-Test Outlier Detection Equation This test compares an individual measurement to the sample statistics and calculates a parameter, t, known as the extreme studentized deviate. This parameter is calculated as follows:
Where:
T    =    Calculated value of extreme studentized deviate that is compared to the critical value of t for the sample size xi  =    nth value of AFAL drift analysis,
                              =    AFAL drift sample mean and s    =    AFAL drift sample standard deviation.
4.7.1.3  The calculated t-value is then compared to the critical t-value.
If the calculated t-value exceeds the critical t-value, then that AFAL drift data point is a candidate for removal from the sample as an outlier. The critical t-value is based on the significance level and sample size from ASTM E178. Examples of the Critical t-values are shown below (Table 4.1).
4.7.1.4  This methodology will use critical t-values based on an upper 2.5% significance level. Identifying outliers at a 2.5%
significance level will ensure that the resultant tolerance interval is determined at greater than a 95/95 confidence level.
4.7.1.5  The AFAL drift data points whose calculated t-values exceed the critical t value are candidates for removal from the sample as outliers. No more than one AFAL drift data point should be removed from the sample based solely on the t-Test.
 
Outlier candidates should be reviewed on a case by case basis and every effort made to determine the cause of the outlier status. Refer to section 4.6 for examples of failures, deficiencies and data errors that may require correction or removal. For example, a transcription error could be the cause for failing the t-Test. In this case the data point should be retained, the transcription error should be corrected and the sample statistics should be recalculated. The first step in the Drift Analysis is to confirm that the instruments meet acceptable limits. Therefore, most potential outliers will have been identified early in the study and; thus, identifying them at this point in the study should be rare. It is imperative that no data point be removed unless it has been clearly demonstrated as an outlier. The responsibility for removing outliers from an AFAL drift sample lies with the analyst but an attitude of valid until demonstrated invalid should be maintained at all times. After the outliers have been identified and reviewed, the most egregious outlier candidate(s) should be reviewed for removal; however, only one outlier may be excluded for purely statistical reasons. Once this outlier(s) has been removed, the remaining data set is the Final Data Set.
4.7.2 Data Cleanup and Outliers Data Cleanup as listed in Section 4.6 is not considered removal of outliers. Outlier testing is used in this case to identify calibration procedure discrepancies, measurement and test equipment discrepancies or design deficiencies, instrument failures or other discrepancies.
After the data cleanup, certain other data points can still appear as outliers when the outlier analysis is performed. These "unique outliers" are not consistent with the other data collected; and could be judged as erroneous points, which tend to skew the representation of the distribution of the data. If there are many identified outliers, the data should be reviewed in more detail to determine if a single instrument or unusual situation is influencing the results. Outliers should be removed from the analysis only after confirming that they are truly not representative of the instruments normal performance. The basis for removal shall be documented with the analysis. Only one outlier is allowed to be removed per calibration point analyzed in the calculation.
 
Table 4.1 Critical t values Upper 2.5%          Upper 0.5%
Sample Size  Significance Level  Significance Level 15                2.549                2.806 16                2.585                2.852 17                2.62                2.894 18                2.651                2.932 19                2.681                2.968 20                2.709                3.001 21                2.733                3.031 22                2.758                3.06 23                2.781                3.087 30              2.908                3.236 40              3.036                3.381 50              3.128                3.483 60              3.199                3.56 75              3.282                3.648 100              3.383                3.754 125              3.457                3.831 147              3.509                3.883 Note: Table 4.1 adapted from ASTM Standard E178-08. Additional values for T can be found in Table 1 of ASTM Standard E 178-08 or Table T-20 of NUREG-1475.
 
4.8 Normality Testing 4.8.1 The AFAL drift sample data is analyzed for Normality through a series of steps. The data is checked through standard statistical means for determination of the normality of the data set. The W or D-Prime test is the preferred tests for Normality depending on sample size, as discussed below. If these tests do not confirm that the data is normally distributed, then visual examinations are used with a coverage analysis to determine if a normal distribution is conservative with respect to the data. The coverage analysis consists of a histogram and a bin-by-bin comparison of actual data to expectations for a normal distribution.
4.8.2 There are many statistical methods for determining if a given sample population represents a normal distribution. The most common are described in TR-103335 (References 2 & 3). The methods to be used in this analysis to determine if a sample population is consistent with a normal distribution are the D-Prime Test for sample sizes greater than 50 and the W Test for sample sizes of 50 or less. Coverage Analysis will be used on those sample populations that cannot be shown to be consistent with a normal distribution, but are conservative to model as normally distributed. Both methods are discussed below.
 
Table 4.2 Tolerance Interval Factors for Normal Distributions 95/95 Percent          99/95 Percent Sample Size Tolerance Factor Tolerance Factor 10                3.38                  4.27 11                3.26                  4.05 12                3.16                  3.87 13                3.08                  3.73 14                3.01                  3.61 15                2.95                  3.51 16                2.90                  3.42 17                2.86                  3.35 18                2.82                  3.28 19                2.78                  3.22 20                2.75                  3.17 30                2.55                  2.84 40                2.45                  2.68 50                2.38                  2.58 75                2.29                  2.43 100                2.23                  2.36 150                2.18                  2.27 200                2.14                  2.22 300                2.11                  2.17 400                2.08                  2.14 Table 4.2 adapted from EPRI TR 3002002556 Table B-4.
Note: Use of the NUREG-1475 values are also acceptable for analysis.
4.8.3.1 W Test for Normality (Sample < 50)
Note: The W test is endorsed by ANSI N15.15-1974, Assessment of the Assumption of Normality (Employing Individual Observed Values) to evaluate the assumption of a normal distribution for sample sizes less than or equal to 50.
The general procedure for conducting the W test is as follows:
: 1)  Order the sample data (xn) in ascending order from smallest to largest value. Where x1 = the smallest value and xn = largest value.
: 2)  Compute the total sum of squares about the mean, S2, for the sample data.
 
2 n
n xi S 2 =  xi2  i =1 i =1            n 2
Note that S equals (n-1) times the variance of the sample data, or S 2 = (n  1) x s 2 Thus, it is usually straightforward to calculate the variance and multiply by (n-1). The term can be calculated from either the ordered or unordered sample data.
: 3) Calculate the quantity, b, for the sample data.
b =  [an i +1 x( xn i +1  xi )]
Where k = n/2 if n is even or k = (n  1)/2 if n is odd. The values for coefficient ai are tabulated in ANSI N15.15-1974 (Reference 12), for sample sizes up to 50.
: 4) Calculate the test statistic, W, for the sample data.
b2 W= 2 S
The test statistic (W) is compared to the corresponding critical value in Table 4.3 at the desired level of confidence, which in this case is 5%. If the calculated value of W is less than the critical value of W, the assumption of normality would be rejected at the stated significance level. If the calculated value of W is larger than the critical value of W, there is no evidence to reject the assumption of normality.
See Table 4.3 (from ANSI N15.15-1974, table 2) for values of One -
Tailed Percentage Points of W Test for Normality.
 
Table 4.3 One -Tailed Percentage Points of W Test for Normality P                                  P n        1%        5%              n          1%        5%
3      0.753      0.767          27        0.894      0.923 4      0.687      0.748          28        0.896      0.924 5      0.686      0.762          29        0.898      0.926 6      0.713      0.788          30        0.900      0.927 7      0.730      0.803          31        0.902      0.929 8      0.749      0.818          32        0.904      0.930 9      0.764      0.829          33        0.906      0.931 10      0.781      0.842          34        0.908      0.933 11      0.792      0.850          35        0.910      0.934 12      0.805      0.859          36        0.912      0.935 13      0.814      0.866          37        0.914      0.936 14      0.825      0.874          38        0.916      0.938 15      0.835      0.881          39        0.917      0.939 16      0.844      0.887          40        0.919      0.940 17      0.851      0.892          41        0.920      0.941 18      0.858      0.897          42        0.922      0.942 19      0.863      0.901          43        0.923      0.943 20      0.868      0.905          44        0.924      0.944 21      0.873      0.908          45        0.926      0.945 22      0.878      0.911          46        0.927      0.945 23      0.881      0.914          47        0.928      0.946 24      0.884      0.916          48        0.929      0.947 25      0.888      0.918          49        0.929      0.947 26      0.891      0.920          50        0.930      0.947
 
4.8.3.2 The D-Prime Test (Sample > 50)
The D-Prime test is endorsed by ANSI N15.15-1974, Assessment of the Assumption of Normality (Employing Individual Observed Values) to evaluate the assumption of a normal distribution for sample sizes greater than 50. The general procedure for conducting the D-Prime test is as follows:
: 1. Order the sample data in ascending order from smallest to largest value.
: 2. Compute the total sum of squares about the mean, S2, for the sample data as follows:
S 2 =  xi 2  1 n
x ( x )i 2
2 Note that S equals (n-1) times the variance of the sample data, or S 2 = (n  1) x s 2 Thus, it is usually straightforward to calculate the variance and multiply by (n-1). The term can be calculated from either the ordered or unordered sample data.
: 3. Calculate the quantity T as follows: where i = 1 to n.
n + 1 T =  i            x xi 2
where i = 1 to n.
: 4. The test statistic is calculated by:
T D' =
S
: 5. Compare the calculated value of D ' with the D ' percentage points of the distribution of this test. The D ' test is two-sided, which effectively means that the calculated D ' must be bounded by the two-sided percentage points at the stated level of significance. ANSI N15.15 provides percentage points for several levels of significance. Table 4.4 (from N15.15, table 5), provides the percentage points for the 5% significance level. For the given sample size, the calculated value of D ' must lie within the two values provided in Table 4.4 in order to accept the hypothesis of normality.
 
Table 4.4 D-Prime Percentage Points for the 5% Significance Level n          0.025        0.975 50          95.6        101.3 60        126.3        133.1 70        159.6        167.7 80        195.6        204.8 90        233.9        244.3 100        274.4          286 200        783.6        806.9 300          1445        1480 400          2230        2276 500          3120        3179 600          4106        4176 800          6331        6425 4.8.3.3    Coverage Analysis If the D-Prime or W normality tests show that the sample data is inconsistent with a normal distribution (to a 5% significance level),
TR-103335 (References 2 & 3), recommends Coverage Analysis.
Coverage Analysis entails, at a minimum, 95.45% of the AFAL drift data to be bounded by an assumed normal distribution (i.e.,
tolerance limits =  +/- 2). A plot of the data and the assumed normal curve should be evaluated to determine whether the assumed normal distribution effectively bounds the actual data. As can be seen the example Coverage Analysis Plot shown below (Figure 4-1), the AFAL data is more center-peaked than is a normal distribution.
: 1. A coverage analysis is discussed for cases in which the hypothesis test rejects the assumption of normality, but the assumption of normality may still be a conservative representation of the data. The coverage analysis involves the use of a histogram of the data set, overlaid with the equivalent probability distribution curve for the normal distribution, based on the data sample's mean and standard deviation. Visual examination of the plot is used, and the kurtosis is analyzed to determine if the distribution of the data is near normal or conservatively modeled as normal. If the data is near normal/conservatively modeled as normal, then a normal distribution model which adequately covers the set of drift data as observed is derived. This normal distribution will be used as the model for the drift of the component or loop. Otherwise, the data is treated as non-normally distributed, and cannot be combined with other random terms via SRSS.
: 2. Sample counting is used to determine an acceptable normal distribution. The standard deviation of the group is computed.
The number of samples within two standard deviations of the mean is computed. The count is divided by the total number of samples in the group to determine a percentage.
: 3. If the percentage of data within the two standard deviations tolerance is at least 95.45%, the existing standard deviation is acceptable to be used for the encompassing normal distribution model. However, if the percentage is less than 95.45%, the standard deviation of the model will be enlarged, such that the required percentage within +/- two standard deviations is greater than or equal to 95.45%. The required multiplier for the standard deviation in order to provide this coverage is termed the Normality Adjustment Factor (NAF). If no adjustment is required, the NAF is equal to one (1).
: 4. The coverage analysis and histogram should be established with a 12 bin approach unless inappropriate for the application. If an adjustment is required to the standard deviation to provide a normal distribution that adequately covers the data set, then the required multiplier to the standard deviation (NAF) is determined iteratively in the coverage analysis. This multiplier produces a normal distribution model for the drift, which shows adequate data population from the Final Data Set within the +/- 2 bands of the model.
Figure 4-1 Coverage Analysis Plot
 
4.9  Time-Dependency Analysis The loop and/or component drift calculated in the previous sections represented a predicted performance limit without any consideration of whether the drift may vary with time between calibrations or with component age. This section discusses the importance of understanding the time-related performance and the impact of any time-dependency on an analysis.
4.9.1      A clear time-dependency of drift data would greatly simplify the confirmation of the 24-month cycle drift values. It would be a simple matter of increasing the 18-month cycle drift values by a factor appropriate for a 24-month cycle. However, as TR-103335 (References 2 & 3) states, time-dependent behavior is not usually detectable by an AFAL analysis for the following reasons:
4.9.1.1    Drift tends to fluctuate randomly with many calibrations remaining within the specified as-left tolerance.
4.9.1.2    Instruments do not exhibit strong time-dependent behavior such that an increasing standard deviation with time might be observed.
4.9.1.3    Calibrations are usually performed at specified intervals with only a few months spread between calibration frequencies.
In these cases, it will be difficult to identify a clear time-dependent behavior. Note that the Robinson Nuclear loop and/or component calibrations of interest are currently on an 18-month interval.
As discussed in the NRC Status report, that time dependency of drift for a sample or population is understood to be time dependent [sic] of the uncertainty statistic describing the sample or population; e.g., the standard deviation of drift.4 If the time dependency tests are NOT definitive they can be used to support an engineering judgment about the degree of time dependency e.g., moderately time dependent, etc.
(see discussion and methodology in section 4.11, Time Dependent Analyzed Drift).
4.9.2      Limitations of Time Dependency Analyses EPRI TR-103335 Section 9, Reference 2 & 3, presents drift analyses for numerous components at several nuclear plants as part of the project. The data evaluated did not demonstrate any significant time-dependent or age-dependent trends. Time dependency may have existed in all of the cases analyzed, but was insignificant in comparison to other uncertainty contributors. Because time dependency cannot be completely ruled out, there should be an ongoing evaluation to verify that component drift continues to meet expectations whenever calibration intervals are extended (reference section 5.11).
4 EPRI TR 3002002556, Final Report January 2014, Appendix E, Item 4.2, Section 2
 
4.9.3 Based on the discussion in 4.9.1 and 4.9.2 above, this methodology assumes moderate time dependency in the AFAL data as a standard approach. Various techniques as described in the remainder of this section are then used to support or refute this assumption.
The primary Duke Energy method of validating moderate time dependency will be scatter and binning analysis.
Refer to section 4.11 for the development of the extended interval Analyzed Drift terms (random and bias).
4.9.3.1      Scatter (Drift Interval) Plot A drift interval plot is an XY scatter plot that shows the Final Data Set plotted against the time interval between tests for the data points. This plot method relies upon the human eye to discriminate the plot for any trend in the data to exhibit a time dependency. A prediction line can be added to this plot which shows a "least squares" fit of the data over time. This can provide visual evidence of an increasing or decreasing mean over time, considering all drift data. An increasing standard deviation is indicated by a trend towards increasing "scatter" over the increased calibration intervals. See Reference 11.
4.9.3.2      Standard Deviations and Means at Different Calibration Intervals (Binning Analysis)
Another method to establish time dependency, is to perform a drift interval plot (XY scatter plot) that shows the adjusted or final drift data plotted against the time interval between tests for the data points (reference section 4.9.3.2 above).
: 1. The data that is available will be placed in interval bins. The intervals that will normally be used will coincide with Technical Specification calibration intervals plus the allowed tolerance as follows:
: a. 0 to 1.25 months (covers most weekly and monthly calibrations)
: b.  >1.25 to 3.75 months (covers most quarterly calibrations)
: c.  >3.75 to 7.50 months (covers most semi-annual calibrations)
: d.  >7.50 to 15.0 months (covers most annual calibrations)
: e.  >15.0 to 25.0 months (covers most old refuel cycle calibrations)
: f.  >25.0 to 30.0 months (covers most extended refuel cycle calibrations)
: g.  >30.0 months covers missed and forced outage refueling cycle calibrations.
: 2. Different bin splits may be used, but a standard breakup of data across the board is recommended.
: 3. For each bin, where there is data, the mean (average), standard deviation, average time interval and data count will be computed. To determine if time dependency does or does not exist, the data needs to be distributed across multiple bins, with a sufficient population of data in each of two or more bins to consider the statistical results for those bins to be valid. Normally the minimum expected distribution that would allow evaluation is defined below:
: a. For each bin, where there is data, the mean (average), standard deviation, average time interval and data count will be computed.
: b. A bin will be considered valid in the final analysis if it holds more than five data points and more than ten percent of the total data count.
: c. For further evaluation, at least two valid time bins must exist. All valid time bins must be included in further analysis.
The mean and standard deviations of the valid bins are plotted versus average time interval on a diagram. This diagram can give a good visual indication of whether or not the mean or standard deviation of a data set is increasing significantly over time interval between calibrations.
NOTE: If multiple valid bins do NOT exist for a given data set, there is not enough diversity in the calibration intervals analyzed to make meaningful conclusions about time dependency from the existing data. The single bin data set will be established as moderately time dependent for the purposes of extrapolation of the drift value.
4.9.3.3 When multiple valid bins exist, and the bins show an increase in standard deviation over time, then for the random portion of drift, the critical value of the F-distribution is compared to the ratio of the smallest and largest variances of the evaluated bins. If the ratio of variances exceeds the critical value, the drift uncertainty should be considered as strongly time dependent. If the ratio of variances does not exceed the critical value, the drift uncertainty may be considered as moderately time dependent.
4.9.3.4 Regression Analyses and Plots As discussed in the NRC Status Report (Reference 3 Appendix E), Evaluation item 4.4.4, all the regression analysis methods presented in EPRI TR-103335, (Reference 2 and 3) are deemed unacceptable for estimating instrument drift, but the methods will be described and the plots may be included in the drift
 
analysis as a tool to support an engineering judgment about the degree of time dependency. A standard regression analysis within an Excel spreadsheet can plot the drift data versus time, with a prediction line showing the trend. It can also provide Analysis of Variance (ANOVA) table printouts, which contain information required for various numerical tests to determine level of dependency between two parameters (time and drift value). Note that regression analyses are only to be performed if multiple valid bins are determined from the binning analysis.
Regression Analyses are to be performed on the Final Data Set drift values and on the Absolute Value of the Final Data Set drift values. The Final Data Set drift values show trends for the mean of the data set, and the Absolute Values show trends for the standard deviation over time.
4.9.3.5 Regression Plots The following are descriptions of the two plots generated by these regressions.
: 1. Drift Regression - an XY scatter plot that fits a line through the final drift data plotted against the time interval between tests for the data points using the "least squares" method to predict values for the given data set. The predicted line is plotted through the actual data for use in predicting drift over time.
: 2. Absolute Value Drift Regression - an XY scatter plot that fits a line through the Absolute Value of the final drift data plotted against the time interval between tests for the data points using the "least squares" method to predict values for the given data set. The predicted line is plotted through the actual data for use in predicting drift, in either direction, over time.
4.9.3.6 Regression Time Dependency Analytical Tests Typical spreadsheet software includes capabilities to include ANOVA tables with regression analyses. ANOVA tables give various statistical information, which can allow certain numerical tests to be employed to search for time dependency of the drift data. For each of the two regressions (drift regression and absolute value drift regression), the following ANOVA parameters are used to determine if time dependency of the drift data is evident.
All tests listed should be evaluated, and if time dependency is indicated by any of the tests, the data should be considered as strongly time dependent. If the prediction line of the regression plot shows a significant slope, without crossing zero in the study period, which would indicate an increase in drift error over time.
: 1. R Squared Test - The R Squared value, printed out in the ANOVA table, is a relatively good indicator of time dependency. If the value is greater than 0.09 (thereby indicating the R value greater than 0.3), then it appears that the data does closely conform to a linear function, and therefore, should be considered strongly time dependent.
: 2. P Value Test - A P Value for X Variable 1 (as indicated by the ANOVA table for an EXCEL spreadsheet) less than 0.05 is indicative of strong time dependency. It should be noted that per TR-103335, the P test is not independent of the F test.
: 3. Significance of F Test - An ANOVA table F value greater than the critical F-table value would indicate a time dependency. In an EXCEL spreadsheet, the FINV function can be used to return critical values from the F distribution. To return the critical value of F, use the significance level (in this case 0.05 or 5.0%) as the probability argument to FINV, 1 as the numerator degrees of freedom, and the data count minus two as the denominator. If the F value in the ANOVA table exceeds the critical value of F, then the drift is considered time dependent.
: 4. For each of these tests, if time dependency is indicated, the plots should be observed to determine the reasonableness of the result. The tests above generally assess the possibility that the function of drift is linear over time, not necessarily that the function is significantly increasing over time. Time dependency can be indicated even when the plot shows the drift to remain approximately the same or decrease over time. Generally, a decreasing drift over time is not expected for instrumentation, nor is a case where the drift function crosses zero. Under these conditions, the extrapolation of the drift term would normally be established assuming moderate time dependency, if extrapolation of the results is required beyond the analyzed time intervals between calibrations.
: 5. Regardless of the results of the analytical regression tests, if the plots tend to indicate significant increases in either the mean or standard deviation over time, those parameters should be judged to be strongly time dependent. Otherwise, for conservatism, the data will always be considered to be moderately time dependent if extrapolation of the data is necessary, to accommodate the uncertainty involved in the extrapolation process, since no data has generally been taken at time intervals as large as those proposed.
 
4.9.3.7  Age-Dependent Drift Considerations Age-dependency is the tendency for a component's drift to increase in magnitude as the component ages. This can be assessed by plotting the As-Found value for each calibration minus the previous calibration As-Left value of each component over the period of time for which data is available. Random fluctuations around zero may obscure any age-dependent drift trends. By plotting the absolute values of the As-Found versus As-Left calibration data, the tendency for the magnitude of drift to increase with time can be assessed. This analysis is generally not performed as a part of a standard drift study, but can be used when establishing maintenance practices.
4.10 Drift Bias Determination From EPRI TR-103335 (References 2 & 3), in terms of AFAL analysis, the mean, or average value, of the drift result is usually taken as the bias portion of the instrument performance. In an ideal case with no bias, the mean would have a value of zero, indicating that there was no tendency for the instrument to drift preferentially in one direction. This is based on an assumption that instrument drift is zero centered and a normal distribution. However, if the instrument does drift preferentially in one direction, the mean of the AFAL analysis will be non-zero.
If significant, this deviation from a zero mean value should be treated as a bias.
The maximum value of the non-biased mean can be determined for a particular sample based on the standard deviation and the normal deviate, t (at 95%
confidence, see Table 4.5, below) for a particular sample size. When the absolute value of the calculated mean for the given sample exceeds the maximum values in Table 4.5 for the sample size and the calculated standard deviation, the mean is conservatively treated as a bias to the drift term, otherwise it is considered negligible in determining the Analyzed Drift for the 18 month calibration interval.
The mean (bias term) must be combined properly with the standard deviation (random term) to determine AD18months. The standard deviation (random term) is given as a plus and minus value, so the mean (bias term) must be added arithmetically to the random term in the appropriate direction, but should not be subtracted from the random term in the opposite direction. Refer to the example 4.10.1 on next page.
 
Table 4.5 Maximum Value of Non-Biased Mean Normal Deviate (t)            Maximum Value of Non-Biased Mean (x crit ) For Given STDEV (s)
Sample Size (n) @ 0.025 for 95%      s    s        s        s      s          s          s      s    s Confidence      0.10% 0.25%    0.50%      0.75%      1%      1.50%          2%    2.50%  3%
5          2.571        0.115  0.287    0.575      0.862    1.150      1.725        2.300    2.874 3.449 10        2.228        0.070  0.176    0.352      0.528    0.705      1.057        1.409    1.761 2.114 15        2.131        0.055  0.138    0.275      0.413    0.550      0.825        1.100    1.376 1.651 20        2.086        0.047  0.117    0.233      0.350    0.466      0.700        0.933    1.166 1.399 25        2.060        0.041  0.103    0.206      0.309    0.412      0.618        0.824    1.030 1.236 30        2.042        0.037  0.093    0.186      0.280    0.373      0.559        0.746    0.932 1.118 40        2.021        0.032  0.080    0.160      0.240    0.320      0.479        0.639    0.799 0.959 60        2.000        0.026  0.065    0.129      0.194    0.258      0.387        0.516    0.645 0.775 120        1.980        0.018  0.045    0.090      0.136    0.181      0.271        0.361    0.452 0.542
> 120        1.960                                Values Computed Per Equation Below
 
The maximum values of non-biased mean (xcrit) for a given standard deviation (s) and sample size (n) is calculated using the following formula (Reference 9):
Where; xcrit =    Maximum value of non-biased mean for a given s and n, expressed in %
t    =    Normal Deviate for a t-distribution at 0.025 for 95% confidence interval s    =    Standard Deviation of the sample pool n    =    Sample pool size Normal Deviate (t) values above from Reference 9, Table V, t-Distribution.
Examples of determining and applying bias to the analyzed drift term:
4.10.1    Transmitter Group With a Biased Mean A group of flow transmitters are calculated to have a standard deviation of 1.150%, mean of -0.355% with a count of 47. From Table 4.5, the maximum value that a negligible mean could be is +/-
0.258%. Therefore, the mean value is significant, and must be considered. The analyzed drift (AD) term for a 95%/95% tolerance interval for the existing 18 month calibration interval is calculated as AD18months = -0.355% +/- 1.150% x 2.401 (Tolerance Interval Factor interpolated from Table 4.2 at the 95/95 percent Tolerance Factor for 47 samples) or AD18months = -0.355% +/- 2.761%. For conservatism, the AD18months term for the positive direction is not reduced by the bias value where as the negative direction is summed with the bias value, so AD18months = +2.761%, -3.116%.
4.10.2    Transmitter Group With a Non-Biased Mean A group of transmitters is calculated to have a standard deviation of 1.150%, mean of 0.100% with a count of 47. From Table 4.5, the maximum value that a negligible mean could be is +/- 0.258% which is conservatively based on a count of 60 data points. Alternately, using the xcrit equation, t=2.013 Xcrit = 2.013 X 1.15/(47)^0.5 = 0.338%
This means that 0.100% is less than either of the critical values.
Therefore, the mean value is insignificant, and can be neglected. The analyzed drift term for a 95%/95% tolerance interval level is shown as AD18months = +/-1.150% x 2.401 (Tolerance Interval Factor from Table 4.2 interpolated for 47 samples) or AD18months = +/-2.761%
 
4.11 Time Dependent Analyzed Drift (AD)
Instrument uncertainty calculations at RNP follow the guidance of EGR-NGGC-0153 (Reference 4). If a manufacturer does not specify a drift term for their instrument, EGR-NGGC-0153 provides guidance and discussions of drift terms in Section 9.4.2, Drift. In addition, if required, in lieu of utilizing published vendor specifications or in the absence of published specifications, determination of drift can be established based on historical calibration data.
Thus, verification that the AD values determined in the drift analysis are consistent with the drift values used in the existing instrument uncertainty calculations. This is also confirmation that the EGR-NGGC-0153 guidance to extend or establish instrument drift will conservatively account for the time-dependency of AFAL Drift Analysis results.
Extrapolation of the random term of the drift will be performed as discussed below depending on whether the AD has a moderate or strong time dependency.
4.11.1      Time Dependent Random Term The random portion of the Analyzed Drift is calculated by multiplying the standard deviation of the Final Data Set by the Tolerance Interval Factor (TIF) for the sample size and by the Normality Adjustment Factor (NAF), if required from the Coverage Analysis, and then extrapolating the final result for time dependency.
Obtain the appropriate Tolerance Interval Factor for the size of the sample set from Table 4.2 using the 95/95 Percent column.
The following equation will be used to determine the random value:
AD RANDOM = s x TIF 95 / 95 x NAF Where:
s        -  Standard Deviation of the Final Data Set or of the longest-interval, valid time bin from the binning analysis (see note)
TIF95/95 -    95%/95% Tolerance Interval factor from Table 4.2 NAF      -  Normality Adjustment Factor from Coverage Analysis (to ensure coverage is  95.45%)
Note: For conservatism, the larger standard deviation drift value of either the Final Data Set or the longest-interval, valid time bin from the binning analysis is used as a starting point for the drift extrapolation.
 
As discussed in EPRI TR-103335, section 9.5 (References 2 and 3),
if the sample random portion of the Analyzed Drift (Standard Deviation) is verified as moderately time-dependent using one of the methods in section 4.9, the drift uncertainty for the extended calibration interval is extrapolated by square root of the average one cycle data calibration interval and the ratio to the extended calibration interval.
CIE ADERANDOM = ADRANDOM x CIO Where:
ADERANDOM -      random drift term for the extended calibration interval (30 months)
ADRANDOM -      random drift term calculated from the observed data CIE        -    extended calibration interval (surveillance interval
                                    + 25%) or 30 months CIO        -    averaged calibration time interval within the longest-interval, valid time bin from the binning analysis (see note)
Note: For those cases where no time dependency is apparent from the drift analysis, it is also acceptable to use the maximum observed time interval from the longest-interval, valid time bin from the binning analysis, as a starting point in the extrapolation, as opposed to the average observed time interval. This can be used to reduce over-conservatisms in determining an extrapolated analyzed drift value.
If the sample random portion of the Analyzed Drift is determined to be strongly time-dependent per section 4.9, the following conservative equation is used.
CIE ADERANDOM = ADRANDOM x CIO Where:
CIE -  extended calibration interval (surveillance interval + 25%)
or 30 months CIO - averaged calibration time interval within the longest-interval, valid time bin from the binning analysis If the drift bias (bias of the mean) of the Final Data Set is determined to be significant per the criteria in Section 4.10, a bias term will be determined.
 
Extrapolation of the bias term will be performed as discussed below.
4.11.2    Time Dependent Bias Term The bias portion of the Analyzed Drift is equal to the mean (m) of the Final Data Set.
The bias portion of the Analyzed Drift (ADBIAS) if determined to be significant, (per section 4.10) will always be treated as being strongly time-dependent, so the bias portion (ADEBIAS) will be extrapolated in a linear fashion:
CIE ADEBIAS = ADBIAS x CIO Where:
ADEBIAS      -    bias drift term for the extended calibration interval ADBIAS      -    bias drift term determined from Section 0 CIE        -    extended calibration interval (surveillance interval +
25%) or 30 months CIO        -    averaged calibration time interval within the longest-interval, valid time bin from the binning analysis 4.11.3    Total extended interval Analyzed Drift Term (ADE)
The extended drift associated with the applicable instrument loops will be determined in other document(s). The following is presented for information only.
ADE = +/- ADERANDOM +/- ADEBIAS Note that ADEBIAS shall added algebraically to the positive or negative (not both) portion of ADERANDOM, depending on the sign of ADEBIAS.
Switches and bistables are affected by a bias in the opposite direction of a transmitter, for example. So ADEBIAS will require careful application to assure conservatism.
4.12 Shelf Life Of Analysis Results 4.12.1    As discussed in EPRI TR-103335 (References 2 & 3), any analysis result based on the performance of existing loops and/or components has a shelf life. In this case, the term shelf life is used to describe a period of time extending from the present into the future during which the analysis results are considered valid. Predictions for future performance are based upon our knowledge of past calibration performance. This approach assumes that changes in performance will occur slowly or not at all over time. For example, if evaluation of the last ten years of data shows the loop and/or component drift is
 
stable with no observable trend, there is little reason to expect a dramatic change in performance during the next year. However, it is also difficult to claim that an analysis completed today is still a valid indicator of performance ten years from now. For this reason, the analysis results should be re-verified periodically.
4.12.2      Depending on the type of loop and/or component, the analysis results are also dependent on the method of calibration, the loop and/or component span, and the M&TE accuracy. Any of the following program or loop and/or component changes should be evaluated to determine if they affect the analysis results:
4.12.2.1    Changes to M&TE accuracy 4.12.2.2    Changes to the loop and/or component (e.g. span, environment, manufacturer, model, etc.)
4.12.2.3    Calibration procedure changes that alter the calibration methodology 5.0 INSTRUCTIONS FOR PREPARING THE DRIFT CALCULATION/ANALYSIS 5.1  Performing a Drift Calculation/Analysis The Drift Calculation/Analysis should be performed in accordance with the methodology described above and the requirements of EGR-NGGC-0153 and AD-EG-ALL-1117 (References 4 and 5). The Drift Calculation/Analysis will be performed using Microsoft&#xa9; Office Excel spreadsheets for display and calculation.
 
Figure 5.1 Flow Chart of Drift Statistical Analysis
 
5.2 Populating the Spreadsheet The initial step in any As-Found/As-Left (AFAL) Drift Analysis is the gathering of the as-found/as-left data from completed plant calibration procedures and other maintenance activities on the subject devices. As-found and as-left values are defined as follows:
As-found is the condition in which a channel, or portion of a channel, is found after a period of operation and prior to any calibration.
As-left is the condition in which a channel, or portion of a channel, is left after a calibration or surveillance check.
5.2.1    Example of Data Formatting The EPRI TR (References 2 and 3), focuses on device calibrations.
However, RNP normally has access to a mixture of loop and device calibrations. Therefore, the RNP AFAL Drift Analysis will utilize the loop or device calibration data that has the best sample data for which to draw conclusions from. Every effort will be made to lump like instrument loops together; however, the likely effect of using loop rather than device AFAL data is smaller sample sizes. All data from the Technical Specification Surveillance procedures performed during the intervals of interest will be entered into the spreadsheets if available. As-Found or As-Left data which was unable to be located will be noted.
5.2.2    Initial AFAL (Raw) Data Confirmation Prior to any statistical analysis of the data, the raw data is subject to the following constraint; that it has not, except on rare occasions, exceeded acceptable limits. These limits associated with the initial screening are based on engineering judgement, but are generally considered to be calibration As Found Tolerances and / or Allowable Values. Violations of these limits are detected and documented within the calibration records.
Instruments that do not pass this simple constraint are not candidates for AFAL Drift Analysis. They would already show up as out of tolerance on the data sheets and be subject to additional scrutiny immediately. In other words, an instrument that has difficulty remaining within acceptable limits through an 18 month refueling cycle cannot be expected to remain within acceptable limits through an extended refueling cycle with any level of confidence. This constraint also helps verify that data collected represents normal instrument drift that has not been degraded by including instrument failures, which have the potential of skew the results significantly.
The raw drift (DRAW) will be calculated from the AFAL data as follows:
DRAWn = {AFn  ALn1}/span Where: DRAWn = Instrument Drift between n and n1 calibrations AFn      = As-found data for calibration n AL(n  1) = As-left data for calibrations n1 Span      = Instrument calibrated span Note: Calibrated span might be replaced with engineering units or other unit if appropriate for the application.
 
5.2.3  AFAL Drift Analysis Prior to calculating the initial statistics, an effort should be made to group as many instrument loops or devices together as possible. These loops should include the same make and model series instruments, should be exposed to the similar environmental conditions and should be calibrated on the similar frequencies.
The pattern of statistical analysis in this methodology will follow the pattern laid out in TR-103335 (References 2 & 3), as shown in Figure 5.1, the Flow Chart of Drift Statistical Analysis Process.
5.3 Calculating Initial Statistics The initial statistics involve the mean, median and standard deviation of the drift sample population. The drift data determined for comparison with the loop acceptable limit (Section 5.10) will be the same data to be used in the calculation of the initial statistics. This data should be formatted in a consistent manner for all loop/devices using an Excel spreadsheet. Consistent formatting will make reviewing the statistical analysis across loops/functions/devices easier and more reliable. The format used in the TR-103335 (References 2 & 3), shown below, meets these requirements with the following additions. This format should include the date, status (As-Found/As-Left), Instrument Procedure number and all RNP tag numbers for the loop in question. (Illustrative example shown here)
 
Figure 5.2 Examples of Raw AF / AL Historical Data Calibration Points (2)
WO        Calibration          0%          25%        50%    75%    100%
Number        Date (1)    Vdc:  1.000      2.000      3.000  4.000  5.000 AL:      0.997      2.009      2.991  3.975    4.956 1768569      5/4/2008 AF:      0.998      1.998      2.998  3.995    4.991 AL:      1.003      1.997      2.998  4.001    4.998 1670441    11/28/2006 AF:      1.003      1.997      2.998  4.001    4.998 AL:      1.001      2.002      3.012  3.995    4.993 1643667      4/16/2005 AF:      1.001      2.002      3.012  3.995    4.993 Loop or Device Tag AL:      1.002      2.002      3.003  4.002    5.004 Functional          1610280      12/1/2003 description                                    AF:      1.002      2.002      3.003  4.002    5.004 AL:      0.996      2.007      3.002  4.002    4.990 1578814      4/2/2002 AF:      0.996      2.007      3.002  4.002    4.990 AL:      0.992      2.002      2.988  3.963    4.957 1547273      12/5/2000 AF:      1.003      1.994      3.013  3.997    4.997 AL:      1.000      2.004      2.982  4.000    4.988 1518392      6/10/1999 AF:      1.000      2.004      2.982  4.000    4.988 Raw AFAL values shown above are in engineering units (volts).
If hysteresis is checked, then columns shall be added for the 75% values back to 0%.
Table notes for Figure 5.2 & 5.3:
: 1) Date the calibration was performed.
: 2) The calibration points are shown in Volts. If calibration points are noted to have changed during WO review, ensure noted and data captured.
: 3) Calibration interval (months) = (As-Found Date - As-Left Date)/30.44.
: 4) If the calibration points and AFAL drift values are in "% of Span", AFAL drift values = (AFn - ALn-1)/span x 100%.
 
Figure 5.3 Example of Calculated Drift Data from Raw Data Above Calibration    0%        25%        50%      75%  100%
Interval (3) % Span    % Span    % Span    % Span  % Span 17.2      -0.15%    0.30%    -0.18%    -0.65%  -1.05%
19.4        0.05%    -0.12%    -0.35%    0.15%  0.12%
16.5      -0.03%    0.00%      0.22%    -0.17%  -0.27%
20.0        0.15%    -0.13%      0.03%    0.00%  0.35%
15.9      -0.20%    -0.05%      0.15%    -0.92%  -0.78%
17.9      -0.10%    -0.22%    -0.67%    0.12%  -0.27%
Refer to Figure 5.2 for applicable notes.
 
Figure 5.4 Example Formatting of Initial Statistics Calibration Point =              0%            25%              50%                75%          100%
n=              48              48              48                48              48 Mean =          -0.06%          -0.08%          -0.13%            -0.28%        -0.19%
Median =          -0.03%          -0.09%          -0.15%            -0.10%        -0.12%
Standard Deviation =            0.26%          0.23%            0.28%              0.43%          0.49%
Maximum Value =            -0.65%          -0.50%          -0.67%            -1.08%        -1.05%
Minimum Value =              0.23%          0.30%            0.22%              0.15%          0.37%
Calculated T Value =          2.252          1.810            1.935              1.858          1.762 Critical T Value =          3.111          3.111            3.111              3.111          3.111 Not-Outlier    Not-Outlier      Not-Outlier      Not-Outlier    Not-Outlier Notes for the calibration points in Table 5.4:
: 1) n = number of AFAL data points per calibration point.
: 2) Sample Mean, Median and Standard Deviation in % of span
: 3) Maximum AFAL value in % of span
: 4) Minimum AFAL value in % of span
: 5) Calculated T value using the Maximum or Minimum value with the largest deviation from 0.
: 6) Critical T value from Section 4.7.3 at 0.025 upper significance level.
From the raw drift data, the mean, median and standard deviation of the sample should be determined. The example data above assumes a standard five point calibration. However, it should be recognized that many loops will consist of only a single data point per calibration (e.g., pressure switches, bistables, etc.) up to a 9 point calibration. These will require a different format but they are evaluated in the same manner as the standard 5 point calibration.
The sample mean value () for any group of like instrument loops is calculated as the sum of all calculated drift values for all intervals (i.e., all Dns) divided by the number of calculated drift values. The sample mean is determined using the following formula.
D  n
                                =  n n
Where: n = number of drift terms.
 
Excels AVERAGE function may be used to calculate the mean value () of a sample population.
The median is the middle number in an ordered set of numbers. If there are an odd number of observations, it is the middle number. If there is an even number of observations, the median is the average of the two middle observations. A simple comparison of the sample mean to the sample median can often identify the presence of outliers or non-symmetry in the data. Excels MEDIAN function may be used to calculate the median value of a sample population.
The sample standard deviation value () for any group of like instrument loops is calculated using the following formula.
(D    )
2 n
                                      =    n (n  1)
Where: n = number of drift terms.
Excels STDEV.S function may be used to calculate the standard deviation value () of a sample population.
Initially, a mean, median and standard deviation of the drift sample population should be calculated at each calibration point. Robinson Nuclear typically utilizes a 9-point check at 0%, 25%, 50%, 75%, 100%, 75%, 50%, 25%, 0% of span.
From EPRI TR-103335 (References 2 & 3), the basis for the recommendation that each calibration check point be evaluated separately in an AFAL analysis is that drift trends will be observed across the instrument span, if the calibration check points are retained separately in the analysis. If the calibration data for the various check points is instead pooled into a single data set, these drift trends across the span will be missed.
If the instrument being evaluated is used to control the plant in an operating range, the instrument should be evaluated using the calibration data point(s) nearest its operating point, the closest calibration data point or the worst case calibration data point.
5.4      Review Raw Data for Failures, Deficiencies and Errors Review raw data for failures, deficiencies and data errors that may require correction or removal, as discussed in section 4.6. Preliminary Outlier testing may be useful in identifying possible failures, deficiencies or data errors.
5.5      Testing For and Removal of Outliers Perform Outlier testing on final data set as described in section 4.7.1. After the outliers have been identified and reviewed, the most egregious outlier candidate should be removed and sample statistics recalculated. As discussed, only one outlier should be excluded for purely statistical reasons. Removal of erroneous data as described in section 4.7.2 will be justified in the Drift Analysis/Calculation.
 
5.6 Normality Testing Perform Normality Testing as described in Section 4.8. The Normality tests which may be utilized are:
5.6.1  The W-Test for Normality if < 50 data points are available.
5.6.2  The D-Prime Test if >50 data points are available.
5.6.3  Coverage Analysis If the D-Prime or W-Tests show that the sample data is inconsistent with a normal distribution (to a 5% significance level), TR-103335 (References 2 & 3), recommends a Coverage Analysis. Perform the coverage analysis as described in Section 4.8.3.3. This is an EPRI TR-103335 specific concept. Coverage Analysis entails, at a minimum, that 95.45%
of the AFAL drift data will be bounded by an assumed normal distribution (i.e., tolerance limits =  +/- 2).
Visual examination of the plot is used to determine if the distribution of the data is near normal, or if a normal distribution model for the data would adequately cover the data within the 2 sigma limits. Another measure of the conservatism in the use of a normal distribution as a model is the kurtosis of the data. Kurtosis characterizes the relative peakedness or flatness of the distribution compared to the normal distribution, and is readily calculated within statistical and spreadsheet programs. As shown in References 2 and 3, a positive kurtosis indicates a relatively high peaked distribution, and a negative kurtosis indicates a relatively flat distribution, with respect to the normal distribution.
If the data is near normal or is more peaked than a normal distribution (positive kurtosis), then a normal distribution model is derived, which adequately covers the set of drift data, as observed. This normal distribution is used as the model for the drift of the device. As discussed in section 4.8.3.3, the Tolerance Interval Factor will be increased by the Normality Adjustment Factor to ensure that at least 95.45% of all of the sample data will be enveloped.
A plot of the data and the assumed normal curve should be evaluated to determine whether the assumed normal distribution effectively bounds the actual data.
As can be seen in the example plot of Figure 4-1, the AFAL data is more center-peaked than is a normal distribution and has a positive kurtosis; therefore it can be conservatively modeled as normally distributed 5.7 Time-Dependency Evaluation A Time Dependency analysis will be performed using the methods described in Section 4.9.3. These include: time binning, regression analysis, and statistical tests.
 
5.8  Drift Bias Determination Perform a Drift Bias determination as described in Section 0 using the maximum value of non-biased mean as described in Section 0.
5.9  Calculate the Tolerance Interval/Analyzed Drift (AD)
Using the methods discussed in Section 4.11, calculate the analyzed drift term using the random and bias terms following sections 5.9.1 and 5.9.2 as discussed below. Discuss the evaluation, the conclusions and results.
5.9.1  Bias Term Calculate and extrapolate the Bias Term of the Final Data Set (ADEBIAS) as required, for the extended calibration interval as described in Section 4.11.2.
5.9.2  Random Term Calculate and extrapolate the Random Term of the Final Data Set (ADERANDOM) as required, for the extended calibration interval as described in Section 4.11.1.
5.9.3  Final Analyzed Drift (ADE)
Combine the Bias and Random terms as required, for the extended calibration interval (30 months) as described in Section 4.11.3.
5.9.4  Compare the Final Analyzed Drift term (ADE) with the loop/component uncertainty calculation.
5.10 As Found Tolerance The following discussion is included for information only. New As Found Tolerances are derived outside the drift analysis to monitor drift, and provide a value for evaluation in the event that a setpoint requires adjustment. An ideal AFT would be one that includes all the errors present at the time of calibration.
The AFT for each instrument loop will determined in accordance with EGR-NGGC-0153 (or revised equivalent). The drift analysis is independent of the final selected methology for As Found Tolerance.
The AFT for each instrument loop will determined in accordance with EGR-NGGC-0153 (or revised equivalent). Section 5.10 is in the evaluation for information purposes only. The drift analysis is independent of the final selected methology for As Found Tolerance.
AFT should be calculated in units of calibrated instrument span.
5.10.1 Acceptable Limit Failure Rates An instrument loop AFAL data point will be deemed to have failed the initial constraint (see section 1.1) when the AFAL data point for that instrument loop is greater than its loop or device AFT (LAFT, AFT). As required, failures of the Acceptable Limit as defined in Section 5.10.3 should be investigated on a case by case basis in consultation with the appropriate System Engineers. Failed or erroneous instrument data will not be used in the AFAL data analysis. See examples of erroneous data in section 4.6. In some instances, RNP conservatively uses only an as-left
 
tolerance for both the as-found and as-left tolerance, as a single allowable tolerance. The as-left tolerance is used to trigger an out of tolerance review by the system engineer. In these cases, the RNP Instrument Uncertainty calculations should be reviewed to validate if the out of tolerance data truly exceeded the as-found limit.
The initial constraint requirement is that the instrument has not, except on rare occasions, exceeded acceptable limits. TR-103335 (References 2 &
: 3) gives no definition of rare. Duke Energy will allow a maximum of 5%
AFAL data point Acceptable Limit failures to be considered as rare, that is 95% of the AFAL data will NOT fail the Acceptable Limit test. This implies that no more than 2 out of 40 data points will fail the Acceptable Limit test. This level of confidence is consistent with industry standards in regard to instrumentation performance.
5.11 Ongoing Instrument Loop/Component Calibration As-Found/As-Left Evaluation Program Robinson Nuclear has in place a continuing calibration surveillance procedure review program which verifies that loop/component As-Found calibration values do not exceed acceptable limits as defined in applicable Instrument Uncertainty Calculations, except on rare occasions.
Once the 24-month Tech Spec Surveillance Requirement intervals have been approved and implemented, this calibration surveillance procedure review program will continue to verify that future loop/component As-Found calibration values do not exceed the Acceptable Limits determined in the Drift Evaluations and associated Instrument Uncertainty Calculations as revised to reflect a 30 month calibration frequency, except on rare occasions.
 
6.0 CALCULATION/ANALYSIS The Drift Calculation/Analysis should be performed in accordance with the methodology described above and the requirements of AD-EG-ALL-1117, (Reference 5) and EGR-NGGC-0153 (Reference 4). The following items are to be addressed in the calculation.
6.1    Calculation/Analysis Content (Reference AD-EG-ALL-1117 for discussion of 6.1.1 - 6.1.6 topics) 6.1.1    Statement of Problem/Purpose 6.1.1.1        Purpose 6.1.1.2        Analyzed Instrument Loop Function 6.1.1.3        24 Month Cycle Extension Requirements 6.1.1.4        Instrument Locations and Installation Dates 6.1.2    Relation To QA Condition/Nuclear Safety 6.1.3    Design Calculation Method 6.1.4    FSAR/Technical Specification Applicability 6.1.5    References 6.1.6    Assumptions/Design Input 6.1.6.1        Assumptions 6.1.6.2        Design Input/Bases 6.1.7  Drift Analysis 6.1.7.1        Instrument Block Diagram 6.1.7.2        As-Found/As-Left Data Evaluation/Outlier Evaluation 6.1.7.3        Normality Tests/Bias Evaluation/Tolerance Intervals 6.1.7.4        Drift Data Time Dependency / Find Analyzed Drift Value 6.1.7.5        Comparison Of Final Analyzed Drift Value with Existing Uncertainty Calculation Limits 6.1.8  Conclusions/Results 6.1.8.1        Justification of NRC GL 91-04 Issues.
6.1.8.2        Final Disposition 6.2    Drift Analysis Details 6.2.1  Describe, at a minimum, that the objective of the calculation is to document the drift analysis results for the loop and/or component group.
6.2.2  Provide a list for the group of all pertinent instrument information (e.g. Tag Numbers, Manufacturer, Model Numbers, ranges and calibration spans).
6.2.3  Describe any limitations on the application of the results. For example, if the analysis only applies to a certain transmitter range code.
 
6.2.4 The method of solution will describe, at a minimum, a summary of the methodology used to perform the drift analysis outlined by this Drift Methodology. Exceptions taken to this methodology will be identified, including basis and references for exceptions.
6.2.5 The actual calculation/analysis will provide:
6.2.5.1      A listing of data which was removed, and the justification for doing so.
6.2.5.2      A narrative discussion of the specific activities performed for this calculation.
6.2.5.3      Input data with Initial Statistics and Tests:
A.        Input data with notes on removal and validity, B.        Computation of drift data and calibration time intervals, C.        Outlier summary, including Final Data Set and basic statistical summaries, D.        W Test or D-Prime Test Results (as applicable),
E.        Coverage analysis, including histogram, percentages in the required sigma bands, and Normality Adjustment Factor (if applicable),
F.        Scatter Plot with prediction line and equation (if applicable),
G.        Binning Analysis Summaries for Bins and Plots (if applicable),
H.        Regression (if applicable),
I.        Derivation of the projected 30-month drift values.
6.2.5.4      Results and conclusions, including:
A.        Manufacturer and model number analyzed, B.        Bias and random Analyzed Drift values, as applicable, C.        Applicable drift time interval for application, D.        Normality conclusion, E.        Statement of time dependency observed, as applicable, F.        Limitations on the use of this value in application to uncertainty calculations, as applicable, G.        Limitations on the application of the results to similar instruments, as applicable.
 
6.3 Comparison of Analyzed Drift (AD) with Uncertainty Calculation Limits and Procedure Acceptance Criteria 6.3.1 To apply the results of the drift analyses to a specific loop or device, the associated setpoint/uncertainty calculation will need to be evaluated and revised as necessary in accordance with AD-EG-ALL-1117 and EGR-NGGC-0153.. All required changes will be tracked via the appropriate Engineering Change Product in accordance with EGR-NGGC-0009 (Reference 10) or its successor.
6.3.2 The results of the drift analysis shall be compared to Calibration Test and Channel Functional Test As-Found tolerance limits and Channel Check limits to determine if any changes are required. All required changes will be tracked via the appropriate Engineering Change Product in accordance with EGR-NGGC-0009 (Reference 10) or its successor.
 
7.0 DEFINITIONS (Note: Definitions that can be found in EGR-NGGC-0153 are not repeated here.)
Acceptable Limit - An ideal component or loop acceptable limit includes all the errors present at the time of calibration. See section 5.10 discussion.
AFAL - As-found minus as-left value. The change between the as-found measurement recorded during a calibration and the as-left measurement recorded from the previous calibration.
Calibration Span - The actual input/output signal range for which the instrumentation is calibrated, typically specified by the calibration procedure. In many cases the process sensor has an input calibration span, which differs from the actual instrument loop process output range.
Confidence Interval - An interval that contains a population parameter (e.g., mean) to a given probability. (Reference 3).
EPRI - Electric Power Research Institute Kurtosis - A characterization of the relative peakedness or flatness of a distribution compared to a normal distribution. A positive kurtosis indicates a relatively peaked distribution and a negative kurtosis indicates a relatively flat distribution. (Reference 3).
RNP - H.B. Robinson Steam Electric Plant Unit No. 2 Shelf Life - As discussed in section 4.11.3, the term shelf life is used to describe a period of time extending from the present into the future during which the drift analysis results are considered valid. (Reference 3).
 
8.0 ATTACHMENTS Not Provided.
 
U. S. Nuclear Regulatory Commission  to Serial: RNP-RA/17-0014 63 Pages (including cover page)
ATTACHMENT 8 NON-CALIBRATION SURVEILLANCE FAILURE ANALYSIS
 
Non-Calibration Changes For the non-calibration 18-month surveillances, GL 91-04 requires the following information to support conversion to a 24-month frequency:
: 1) Licensees should evaluate the effect on safety of the change in surveillance intervals to accommodate a 24-month fuel cycle. This evaluation should support a conclusion that the effect on safety is small.
: 2) Licensees should confirm that historical maintenance and surveillance data do not invalidate this conclusion.
: 3) Licensees should confirm that the performance of surveillances at the bounding surveillance interval limit provided to accommodate a 24-month fuel cycle would not invalidate any assumption in the plant licensing basis.
In consideration of these confirmations, GL 91-04 provides that licensees need not quantify the effect of the change in surveillance intervals on the availability of individual systems or components.
The following non-calibration TS SRs are proposed for revision to a 24-month frequency. The associated qualitative evaluation is provided for each of these changes, which concludes that the effect on plant safety is small, that the change does not invalidate any assumption in the plant licensing basis, and that the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. These conclusions have been validated by a review of the surveillance test history at HBSEP as summarized below for each SR.
 
TS 3.3.1 Reactor Protection System (RPS) Instrumentation Table 3.3.1-1, Function 1: Manual Reactor Trip SR 3.3.1.14      Perform TADOT. Note: Verification of setpoint is not required.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
A review of the applicable HBRSEP surveillance history demonstrated only one (1) failure in the procedures and preventive maintenance tasks required to satisfy this SR, and that failure would not have impacted the safety function.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
Table 3.3.1-1, Function 10.a: Reactor Coolant Pump (RCP) Breaker Position - Single Loop Table 3.3.1-1, Function 10.b: Reactor Coolant Pump (RCP) Breaker Position - Two Loops Table 3.3.1-1, Function 12: Underfrequency RCPs SR 3.3.1.14      Perform TADOT. Note: Verification of setpoint is not required.
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis.
 
Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
A review of the applicable HBRSEP surveillance history demonstrated no failures in the procedures and preventive maintenance tasks required to satisfy this SR.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
Table 3.3.1-1, Function 16: Safety Injection (SI) Input from Engineered Safety Feature Actuation System (ESFAS)
SR 3.3.1.14      Perform TADOT. Note: Verification of setpoint is not required.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
The test procedure and preventive maintenance task implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedure and preventive maintenance task required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function.
Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested satisfactorily. Replaced relay in charger and functionally tested satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
 
Table 3.3.1-1, Function 17.b: Reactor Protection System Interlocks - Low Power Reactor Trips Block, P-7 SR 3.3.1.14      Perform TADOT. Note: Verification of setpoint is not required.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
A review of the applicable HBRSEP surveillance history demonstrated three (3) failures in the procedures and preventive maintenance tasks required to satisfy this SR, all of which were event driven. For the first of these, the replacement of relay LC-484B1-X(A) during the refueling outage with the incorrect model contributed directly to the As Found condition. In the second case, the replacement of relay PC-457A-X(A) during the refueling outage and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. In the third case, the replacement of relays NC-43R-X(B) and 1/N-33A-Y(B) earlier during the refueling outage and the subsequent mis-alignment of the relay contacts during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.3.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation Table 3.3.2-1, Function 1.b: Safety Injection - Automatic Actuation Logic and Actuation Relays Table 3.3.2-1, Function 3.a.2: Containment Isolation - Phase A Isolation - Automatic Actuation Logic and Actuation Relays Table 3.3.2-1, Function 5.a: Feedwater Isolation - Automatic Actuation Logic and Actuation Relays SR 3.3.2.3      Perform MASTER RELAY TEST.
SR 3.3.2.5      Perform SLAVE RELAY TEST.
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
 
grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
      "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
The test procedures and preventive maintenance tasks implementing these Surveillance Requirements are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedures and preventive maintenance tasks required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function.
Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
 
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
Table 3.3.2-1, Function 2.b: Containment Spray - Automatic Actuation Logic and Actuation Relays Table 3.3.2-1, Function 3.b.2: Containment Isolation - Phase B Isolation - Automatic Actuation Logic and Actuation Relays Table 3.3.2-1, Function 4.b: Steam Line Isolation - Automatic Actuation Logic and Actuation Relays SR 3.3.2.3        Perform MASTER RELAY TEST.
SR 3.3.2.5        Perform SLAVE RELAY TEST.
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety
 
Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
The test procedure and preventive maintenance task implementing these Surveillance Requirements are large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated one (1) failure in the procedure and preventive maintenance task required to satisfy these SRs. This was an event driven failure, in that relay SB2 was replaced and improperly installed during unrelated activities which contributed directly to the As Found condition. Therefore, this failure will have no impact on an extension to a 24 month surveillance interval.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
Table 3.3.2-1, Function 1.a: Safety Injection - Manual Initiation Table 3.3.2-1, Function 3.a.1: Containment Isolation - Phase A Isolation - Manual Initiation SR 3.3.2.6      Perform TADOT. Note: Verification of setpoint is not required.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
The test procedure and preventive maintenance task implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedure and preventive maintenance task required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent
 
incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval.
Ten (10) of the failures would not have impacted the safety function. Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker.
 
One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
Table 3.3.2-1, Function 2.a: Containment Spray - Manual Initiation Table 3.3.2-1, Function 3.b.1: Containment Isolation - Phase B Isolation - Manual Initiation SR 3.3.2.6      Perform TADOT. Note: Verification of setpoint is not required.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
The test procedure and preventive maintenance task implementing this Surveillance Requirement are large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated one (1) failure in the procedure and preventive maintenance task required to satisfy this SR. This was an event driven failure, in that relay SB2 was replaced and improperly installed during unrelated activities which contributed directly to the As Found condition. Therefore, this failure will have no impact on an extension to a 24 month surveillance interval.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
Table 3.3.2-1, Function 4.a: Steam Line Isolation - Manual Initiation SR 3.3.2.6      Perform TADOT. Note: Verification of setpoint is not required.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace
 
period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable.
This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
A review of the applicable HBRSEP surveillance history demonstrated only two (2) failures in the procedure and preventive maintenance task required to satisfy this SR, and these failures would not have impacted the safety function.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.3.3 Post Accident Monitoring (PAM) Instrumentation Table 3.3.3-1, Function 9: Containment Isolation Valve Position SR 3.3.3.3      Perform TADOT. Note: Verification of setpoint is not required.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
The test procedure and preventive maintenance task implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedure and preventive maintenance task required to satisfy this SR.
 
Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function.
Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
 
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
Table 3.3.3-1, Function 22: PORV Position (Primary)
SR 3.3.3.3        Perform TADOT. Note: Verification of setpoint is not required.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
      "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
A review of the applicable HBRSEP surveillance history demonstrated two (2) failures in the procedure and preventive maintenance task required to satisfy this SR. One (1) of the failures would not have impacted the safety function. One (1) unique failure was observed, and it is described below.
: a. Check valve OPP-9 did not seat and piping continually vented during OST-930. This is a failure to meet SR 3.4.11.3. OPP-9 replaced and retested the check valve via Work Order 10769614.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There is a total of one failure of the NUPRO Co Model SS-8C-C5-10-557 (1/2") Check Valve. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
 
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
Table 3.3.3-1, Function 23: PORV Block Valve Position (Primary)
SR 3.3.3.3      Perform TADOT. Note: Verification of setpoint is not required.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
A review of the applicable HBRSEP surveillance history demonstrated only one (1) failure in the procedure and preventive maintenance task required to satisfy this SR. The failure was event driven, in that the valve maintenance performed during the refueling outage contributed directly to the As Found condition. Therefore, this failure will have no impact on an extension to a 24 month surveillance interval.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
Table 3.3.3-1, Function 24: Safety Valve Position (Primary)
SR 3.3.3.3      Perform TADOT. Note: Verification of setpoint is not required.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
 
      "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
A review of the applicable HBRSEP surveillance history demonstrated one (1) failure in the procedure and preventive maintenance task required to satisfy this SR. This failure was a unique failure, and it is described below.
: a. During the performance of MST-052, the acoustics monitor for RC-551C indicated high noise causing the alarm to be in constantly. VE-551C and the Pre-amp for VM-551C were replaced under Work Order 10764133.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There is a total of one failure of the Unholtz-Dickie Model FCA-2TR acoustic monitor and one failure of the Babcock and Wilcox Model 2273AM20 accelerometer. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only one (1) failure is identified as unique, and it is not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.3.4 Remote Shutdown System Bases Table B 3.3.4-1, Function 2.b: Reactor Coolant System (RCS) Pressure Control -
Pressurizer Heater Controls Bases Table B 3.3.4-1, Function 4.b: RCS Inventory Control - Charging Pump Controls SR 3.3.4.2      Verify each required control circuit and transfer switch is capable of performing the intended function.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
 
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
A review of the applicable HBRSEP surveillance history demonstrated one (1) failure in the procedure and preventive maintenance task required to satisfy this SR. The one failure was event driven. In this case, the setpoint change completed in December 2004 contributed directly to the As Found condition. Therefore, this failure will have no impact on an extension to a 24 month surveillance interval.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
Bases Table B 3.3.4-1, Function 3.c: Decay Heat Removal via Steam Generators (SGs) -
Motor Driven AFW Pump Controls Bases Table B 3.3.4-1, Function 5.a: Support Functions - Component Cooling Water Pump Controls Bases Table B 3.3.4-1, Function 5.b: Support Functions - Service Water Pump Controls SR 3.3.4.2      Verify each required control circuit and transfer switch is capable of performing the intended function.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
A review of the applicable HBRSEP surveillance history demonstrated five (5) failures in the procedure and preventive maintenance task required to satisfy this SR. One failures was event driven. The replacement of relay 24-1-DBS prior to the refueling outage and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, this failure will have no impact on an extension to a 24 month surveillance interval. The other four (4) failures would not have impacted the safety function.
 
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation SR 3.3.5.1        Perform TADOT. Note: Verification of setpoint is not required.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
      "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
A review of the applicable HBRSEP surveillance history demonstrated five (5) failures in the procedures and preventive maintenance tasks required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, a procedural error did not provide proper alignment of plant equipment needed to perform the surveillance procedure. As a result, the procedure required revision to align the plant equipment to the desired configuration. In the second case, testing earlier in the procedure via the use of a different procedure (SPP-025) contributed directly to the undervoltage condition which caused the unexpected breaker trip immediately upon closure of the breaker. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. One (1) of the failures would not have impacted the safety function. Two (2) unique failures were observed, and they are described below.
: a. On 10/16/2013, breaker 52/18B tripped open immediately when closed. Found the trip signal from the degraded trip relays present due to a loose keyswitch. Tightened key switch and verified that Degraded Voltage trip was defeated. Similar issue found when closing breaker 52/22A. Found KAZ microswitch contact closed causing the trip signal to be locked in. Completed testing section with the KAZ trip disabled. Work Request 11600872 written to address breaker 52/22A tripping. Work Order 13303714 written for corrective action. Work Order 13303714 completion comments state: "Removed wiring for KAZ trip at terminal strip 3, terminals 1 and 4. Connected DMM across wires lifted and read a short. Tapping on switches led to intermittent open and short readings when the right hand switch was tested. Replaced KAZ switch with new one from warehouse. Checked all switches per PM-402 as a guide. KAZ switches were all satisfactorily. Installed new KAZ fuses from warehouse. FME closeout all satisfactorily.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker.
 
One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
: b. On 2/18/2012, breaker 52/16B would not close from RTGB. Issue worked in conjuction with Work Order 1799932-01 to troubleshoot 52/16B failure to close. Work Order 1799932-01 measured voltages to ground and across terminals per supervision direction. It was found that the negative fuse side of the 1/16B contact (Gemco remote switch on RTGB) had positive voltages indicative of a shorted condition without breaker attempting to close. Racked breaker to test and tried to close locally (at switchgear) and breaker was trip free. Inspected secondary disconnects and noted a gross mis-alignment although no contacts appeared shorted together and all appeared to be made up properly. Removed breaker and cycled on test stand 2 to 3 times electrically with all satisfactorily results. Measured cell secondary contact voltages with breaker removed and fuses installed. Noted voltage on terminal 12 when there should not have been any. Removed fuses and ohmed panel "BA" terminals. Appears Gemco Switch 1/16B remote close contact on RTGB is closed when it should be open. Installed breaker in cubicle and verified proper engagement of secondary diconnects and racked breaker to connect all satisfactorily. Place local/remote switch on mimic bus panel and installed fuses. Closed breaker from mimic bus panel control switch all satisfactorily.
Recommenced MST-025 at Step 8.5.1.2 and performed all satisfactorily to Step 8.9.21.
Work Order 1534437 replaced defective Gemco switch. Non-Conformance Report 518122 written to document the Gemco Switch failure. Non-Conformance Report documents that the current condition of the switch will not allow the procedure to be successfully completed as breaker 52/16B will re-close immediately upon tripping.
Non-Conformance Report also references a 2008 Condition Report (00270624) in which an investigation of numerous failures of the RTGB Gemco switches was performed revealing a root cause of inadequate maintenance on the switches. As a result, HBRSEP has undergone a massive replacement strategy of the spring return to center Gemco switches on the RTGB as denoted in CR270624 which was scheduled for completion in RFO27. The failure of the Gemco switch at the RTGB impacted the ability of the Operator to CLOSE breaker 52/16B in preparation to perform the 272/E-2 Undervoltage Test in which the breaker is first closed and then tripped open during the actual undervoltage condition in Step 8.5.3.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There is a total of one failure of the Westinghouse Model 10051C74H02Y Gemco Switch. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only two (2) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
 
TS 3.3.6 Containment Ventilation Isolation Instrumentation Table 3.3.6-1, Function 2: Automatic Actuation Logic and Actuation Relays SR 3.3.6.3      Perform MASTER RELAY TEST.
SR 3.3.6.5      Perform SLAVE RELAY TEST.
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
The test procedure and preventive maintenance task implementing these Surveillance Requirements are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedure and preventive maintenance task required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function.
Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187.
 
No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
Table 3.3.6-1, Function 1: Manual Initiation SR 3.3.6.6        Perform TADOT. Note: Verification of setpoint is not required.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final
 
Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
      "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
The test procedures and preventive maintenance tasks implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated sixteen (16) failures in the procedures and preventive maintenance tasks required to satisfy this SR. Three (3) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. In the third case, relay SB2 was replaced and improperly installed during unrelated activities which contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function. Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room."
 
Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily. Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.3.8 Auxiliary Feedwater (AFW) System Instrumentation Table 3.3.8-1, Function 3: Automatic Actuation Logic and Actuation Relays SR 3.3.8.3        Perform TADOT.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more
 
frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
The test procedures and preventive maintenance tasks implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedures and preventive maintenance tasks required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function.
Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF."
 
The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues.
Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
Table 3.3.8-1, Function 4: Undervoltage Reactor Coolant Pump SR 3.3.8.3        Perform TADOT.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
      "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
A review of the applicable HBRSEP surveillance history demonstrated only one (1) failure in the procedure and preventive maintenance task required to satisfy this SR, and that failure would not have impacted the safety function.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency.
 
Based on the history of system performance, the impact of this change on safety, if any, is small.
Table 3.3.8-1, Function 5: Trip of all Main Feedwater Pumps SR 3.3.8.3      Perform TADOT. Note: For Function 5, the TADOT shall include injection of a simulated or actual signal to verify channel OPERABILITY.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. All of the actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the HBRSEP Updated Final Safety Analysis Report (UFSAR). As such, these functions are designed to be highly reliable. This is acknowledged in the August 2, 1993 NRC Safety Evaluation Report relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance intervals from 18 to 24 months:
    "Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis. Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the Logic System Functional Test interval represents no significant change in the overall safety system unavailability."
A review of the applicable HBRSEP surveillance history demonstrated no failures in the procedure and preventive maintenance task required to satisfy this SR.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.4.9 Pressurizer SR 3.4.9.2      Verify capacity of required pressurizer heaters is  125 kW.
SR 3.4.9.3      Verify required pressurizer heaters are capable of being powered from an emergency power supply.
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
grace period. SR 3.4.9.2 is satisfied when the power supplies are demonstrated to be capable of producing the minimum power and the associated pressurizer heaters are verified to be at their design rating. This may be done by testing the power supply output and heater current, or by performing an electrical check on heater element continuity and resistance. SR 3.4.9.3 demonstrates that the heaters can be manually transferred from the normal to the emergency power supply and energized.
The test procedure and preventive maintenance task implementing these Surveillance Requirements are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedure and preventive maintenance task required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable.
 
In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function. Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015.
 
No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.4.11 Pressurizer Power Operated Relief Valves (PORVs)
SR 3.4.11.2      Perform a complete cycle of each PORV. Note: Not required to be performed until 12 hours after entry into MODE 3.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR requires a complete cycle of each PORV. Operating a PORV through one complete cycle ensures that the PORV can be manually actuated.
A review of the applicable HBRSEP surveillance history demonstrated no failures in the procedure and preventive maintenance task required to satisfy this SR.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.4.11.3      Perform a complete cycle of each solenoid air control valve and check valve on the nitrogen accumulators in PORV control systems.
SR 3.4.11.4      Verify accumulators are capable of operating PORVs through a complete cycle.
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
grace period. SR 3.4.11.3 operates the solenoid air control valves and check valves on the nitrogen accumulators, ensuring that the PORV control system actuates properly when called upon. SR 3.4.11.4 demonstrates that the accumulators are capable of supplying sufficient nitrogen to operate the PORVs if they are needed for RCS pressure control, and normal nitrogen and the backup instrument air systems are not available.
A review of the applicable HBRSEP surveillance history demonstrated two (2) failures in the procedure and preventive maintenance task required to satisfy these SRs. One (1) of the failures would not have impacted the safety function. One (1) unique failure was observed, and it is described below.
: a. Check valve OPP-9 did not seat and piping continually vented during OST-930. This is a failure to meet SR 3.4.11.3. OPP-9 replaced and retested the check valve via Work Order 10769614.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There is a total of one failure of the NUPRO Co Model SS-8C-C5-10-557 (1/2") Check Valve. No time based mechanisms are apparent.
 
Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only one (1) failure is identified as unique, and it is not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.4.14 RCS Pressure Isolation Valves (PIVs)
SR 3.4.14.1      Verify leakage from each RCS PIV is less than or equal to an equivalent of 5 gpm at an RCS pressure  2235 psig, and verify the margin between the results of the previous leak rate test and the 5 gpm limit has not been reduced by  50% for valves with leakage rates > 1.0 gpm - Notes: 1. Not required to be performed in MODES 3 and 4. 2. Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation. 3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided - RCS PIVs (Frequency is In accordance with the Inservice Testing Program and 18 months AND Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND Within 24 hours following valve actuation due to automatic or manual action or flow through the valve)
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 and Required Action A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve.
A review of the applicable HBRSEP surveillance history demonstrated two (2) failures in the procedure and preventive maintenance task required to satisfy this SR. One of the failures was event driven, in that the error made in the testing configuration contributed directly to the As Found condition. Therefore, this failure will have no impact on an extension to a 24 month surveillance interval. The other failure would not have impacted the safety function.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.4.17 Chemical and Volume Control System (CVCS)
SR 3.4.17.2      Verify seal injection flow of  6 gpm to each RCP from each Makeup Water Pathway from the RWST.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR verifies seal injection flow to the RCP seals via the Makeup Water Pathways, ensuring that adequate cooling to the RCP seals can be maintained from the RWST.
 
A review of the applicable HBRSEP surveillance history demonstrated no failures in the procedure and preventive maintenance task required to satisfy this SR.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.5.2 Emergency Core Cooling Systems (ECCS) - Operating SR 3.5.2.4      Verify each ECCS automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
SR 3.5.2.5      Verify each ECCS pump starts automatically on an actual or simulated actuation signal.
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
grace period. SR 3.5.2.4 and SR 3.5.2.5 demonstrate that each automatic ECCS valve actuates to the required position on an actual or simulated SI signal and that each ECCS pump starts on receipt of an actual or simulated SI signal. The actuation logic is tested as part of ESF Actuation System testing, and equipment performance is monitored as part of the Inservice Testing Program.
The test procedure and preventive maintenance task implementing these Surveillance Requirements are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedure and preventive maintenance task required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function.
Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent.
 
Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.5.2.6        Verify, by visual inspection, the ECCS train containment sump suction inlet is not restricted by debris and the suction inlet trash strainers show no evidence of structural distress or abnormal corrosion.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. Periodic inspections of the containment sump suction inlet ensure that it is unrestricted and stays in proper operating condition.
 
A review of the applicable HBRSEP surveillance history demonstrated only two (2) failures in the procedure and preventive maintenance task required to satisfy this SR, and neither failure would not have impacted the safety function.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.6.3 Containment Isolation Valves SR 3.6.3.2      Verify each containment isolation manual valve and blind flange that is located outside containment and not locked, sealed or otherwise secured and required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.
Note: Valves and blind flanges in high radiation areas may be verified by use of administrative controls.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR requires verification that each containment isolation manual valve and blind flange located outside containment and not locked, sealed or otherwise secured and required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown, that those containment isolation valves outside containment and capable of being mispositioned are in the correct position.
A review of the applicable HBRSEP surveillance history demonstrated three (3) failures in the procedure and preventive maintenance task required to satisfy this SR, and all of them were event driven. For the first two of these, a procedure error existed to check position of an item that does not exist in the plant. In the third case, valve PP-262A was damaged during unrelated activities which contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.6.3.5      Verify each automatic containment isolation valve that is not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal.
The test procedure and preventive maintenance task implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedure and preventive maintenance task required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance.
 
As a result, the procedure acceptance criteria was not able to be confirmed as acceptable.
In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function. Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker.
 
One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.6.3.6      Verify each 42 inch inboard containment purge valve is blocked to restrict the valve from opening > 70&#xba;.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. Verifying that each 42 inch inboard containment purge valve is blocked to restrict opening to  70&#xba; is required to ensure that the valves can close under DBA conditions within the times assumed in the analyses in the UFSAR. If a LOCA occurs, the purge valves must close to maintain containment leakage within the values assumed in the accident analysis. At other times when purge valves are required to be capable of closing (e.g., during movement of irradiated fuel assemblies), pressurization concerns are not present, thus the purge valves can be fully open.
A review of the applicable HBRSEP surveillance history demonstrated no failures in the procedure and preventive maintenance task required to satisfy this SR.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.6.6 Containment Spray and Cooling Systems SR 3.6.6.5      Verify each automatic containment spray valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
SR 3.6.6.6      Verify each containment spray pump starts automatically on an actual or simulated actuation signal.
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
grace period. These SRs require verification that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated actuation of a containment High - High pressure signal. SR 3.6.6.5 is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls.
The test procedure and preventive maintenance task implementing these Surveillance Requirements are large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated one (1) failure in the procedure and preventive maintenance task required to satisfy these SRs.
 
This was an event driven failure, in that relay SB2 was replaced and improperly installed during unrelated activities which contributed directly to the As Found condition. Therefore, this failure will have no impact on an extension to a 24 month surveillance interval.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.6.6.7          Verify each containment cooling train starts automatically on an actual or simulated actuation signal.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR requires verification that each containment cooling train actuates upon receipt of an actual or simulated safety injection signal.
The test procedure and preventive maintenance task implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedure and preventive maintenance task required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function.
Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.6.7 Spray Additive System SR 3.6.7.4        Verify each spray additive automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR provides verification that each automatic valve in the Spray Additive System flow path actuates to its correct position.
The test procedure and preventive maintenance task implementing this Surveillance Requirement are large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated one (1) failure in the procedure and preventive maintenance task required to satisfy this SR.
 
This was an event driven failure, in that relay SB2 was replaced and improperly installed during unrelated activities which contributed directly to the As Found condition. Therefore, this failure will have no impact on an extension to a 24 month surveillance interval.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.6.8 Isolation Valve Seal Water (IVSW) System SR 3.6.8.4        Verify each automatic valve in the IVSW System actuates to the correct position on an actual or simulated actuation signal.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR ensures that automatic header injection valves actuate to the correct position on a simulated or actual signal.
The test procedure and preventive maintenance task implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedure and preventive maintenance task required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function.
Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.6.8.5        Verify the IVSW dedicated nitrogen bottles will pressurize the IVSW tank to 46.2 psig.
SR 3.6.8.6        Verify total IVSW seal header flow rate is  124 cc/minute.
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
grace period. SR 3.6.8.5 ensures the capability of the dedicated nitrogen bottles to pressurize the IVSW system independent of the Plant Nitrogen System. SR 3.6.8.6 verifies integrity of the IVSW seal boundary to provide assurance that the design leakage value required for the system to perform its sealing function is not exceeded.
The test procedure and preventive maintenance task implementing these Surveillance Requirements are large and test a number of components. A review of the applicable HBRSEP surveillance history demonstrated ten (10) failures in the procedure and preventive maintenance task required to satisfy these SRs.
 
Three (3) of the failures were event driven, in that the valve maintenance contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Six (6) of the failures would not have impacted the safety function. One (1) unique failure was observed, and it is described below.
: a. On 4/1/2014, the as-found leakrate of WD-1786/1787 was higher than measurable by the test equipment. Two leaks were identified. Work Request 11620885 / Work Order 13367226 / Action Request 00676803 covers the leak between the valve body and valve bonnet of WD-1787. While the leak rate was not measureable, the Action Request concludes that the OST-933 acceptance criteria was exceeded. WD-1787 underwent maintenance in RFO-28 and had passed post maintenance testing. Work Request 11620880 / Work Order 13367227 / Action Request 00676802 covers a leaking fitting between WD-1787 and WD-1786. Per the Action Request, the fitting was leaking at 10 dpm or 0.5 cc/min. Per Action Request 00676802, the leak of the fitting would not have caused the header flow rate to exceed the OST-933 or TS limits.
However, Per Action Request 00676803, the valve leak would have exceeded the OST-933 limits.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There is a total of one failure of the ITT Engineer Model 1XA32R (1") 002 Isolation Valve. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only one (1) failure is identified as a unique failure, and it is not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.7.4 Auxiliary Feedwater (AFW) System SR 3.7.4.3        Verify each AFW automatic valve that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal. Note: Not applicable in MODE 4 when steam generator is being used for heat removal.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR verifies that AFW can be delivered to the appropriate steam generator in the event of any accident or transient that generates an AFW actuation signal, by demonstrating that each automatic valve in the flow path actuates to its correct position on an actual or simulated actuation signal.
The test procedures and preventive maintenance tasks implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated sixteen (16) failures in the procedures and preventive maintenance tasks required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable.
 
In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Eleven (11) of the failures would not have impacted the safety function. Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015.
 
No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.7.4.4        Verify each AFW pump starts automatically on an actual or simulated actuation signal - Notes: 1. Not required to be performed for the steam driven AFW pump until 24 hours after  1000 psig in the steam generator. 2.
Not applicable in MODE 4 when steam generator is being used for heat removal.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR verifies that the AFW pumps will start in the event of any accident or transient that generates an AFW actuation signal by demonstrating that each AFW pump starts automatically on an actual or simulated actuation signal in MODES 1, 2, and 3. In MODE 4, the autostart function is not required.
The test procedures and preventive maintenance tasks implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated sixteen (16) failures in the procedures and preventive maintenance tasks required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Eleven (11) of the failures would not have impacted the safety function. Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187.
 
No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF".
Measured continuity between B to W, R to G, and O to U. All readings were OPEN.
Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily. Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times -
no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.7.4.6        Verify the AFW automatic bus transfer switch associated with discharge valve V2-16A operates automatically on an actual or simulated actuation signal.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR verifies that the automatic bus transfer switch associated with the "swing" motor driven AFW flow path discharge valve V2-16A will function properly to automatically
 
transfer the power source from the aligned emergency power source to the other emergency power source upon loss of power to the aligned emergency power source. The Surveillance consists of two tests to assure that the switch will perform in either direction.
One test is performed with the automatic bus transfer switch aligned to one emergency power source initially, and the test is repeated with the switch initially aligned to the other emergency power source. Periodic testing of the switch is necessary to demonstrate OPERABILITY.
A review of the applicable HBRSEP surveillance history demonstrated no failures in the procedure and preventive maintenance task required to satisfy this SR.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.7.6 Component Cooling Water (CCW) System SR 3.7.6.2      Verify each required CCW pump starts automatically on an actual or simulated LOP DG Start undervoltage signal.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR verifies proper automatic operation of the required CCW pumps on an actual or simulated LOP DG start undervoltage signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation.
A review of the applicable HBRSEP surveillance history demonstrated no failures in the procedure and preventive maintenance task required to satisfy this SR.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.7.7 Service Water System (SWS)
SR 3.7.7.2      Verify each SWS automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
SR 3.7.7.4      Verify the SWS automatic bus transfer switch associated with Turbine Building loop isolation valve V6-16C operates automatically on an actual or simulated actuation signal.
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
grace period. SR 3.7.7.2 verifies proper automatic operation of the SWS valves on an actual or simulated actuation signal. The SWS is a normally operating system that cannot be fully actuated as part of normal testing. SR 3.7.7.4 verifies that the automatic bus transfer switch associated with turbine building service water isolation valve V6-16C, will function properly to automatically transfer the power source from the aligned emergency power source to the other emergency power source upon loss of power to the aligned emergency power source. The surveillance consists of two tests to assure that the switch will perform in either direction. One test is performed with the automatic bus transfer switch aligned to one emergency power source initially, and the test is repeated with the switch initially aligned to the other emergency power source.
 
A review of the applicable HBRSEP surveillance history demonstrated five (5) failures in the procedure and preventive maintenance task required to satisfy these SRs. One (1) of the failures would not have affected the safety function. The other four (4) failures were event driven. In the first two cases, the failures were caused from a configuration (Main Steam master clearance and EH clearance orders) resulting from unrelated activities which contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. For other two cases, the failures were caused from the rework of the valves under the same set of activities for the valves, and the problem was detected via post maintenance testing. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.7.7.3        Verify each SWS pump and SWS booster pump starts automatically on an actual or simulated actuation signal.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR verifies proper automatic operation of the SWS pumps and SWS booster pumps on an actual or simulated actuation signal. The SWS is a normally operating system that cannot be fully actuated as part of normal testing during normal operation.
The test procedures and preventive maintenance tasks implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedures and preventive maintenance tasks required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function.
Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent.
 
Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems.
Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.7.9 Control Room Emergency Filtration System (CREFS)
SR 3.7.9.2        Perform required CREFS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace
 
period. This SR verifies that the required CREFS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal.
A review of the applicable HBRSEP surveillance history demonstrated no failures in the procedures and preventive maintenance tasks required to satisfy this SR.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.7.9.3      Verify each CREFS train actuates on an actual or simulated actuation signal.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR verifies that each CREFS train starts and operates on an actual or simulated actuation signal.
The test procedure and preventive maintenance task implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedure and preventive maintenance task required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function.
Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues.
Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.7.10 Control Room Emergency Air Temperature Control (CREATC)
SR 3.7.10.1      Perform required CREFS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR verifies that the heat removal capability of the system is sufficient to remove the heat load assumed in the control room. This SR consists of a combination of testing and calculations.
A review of the applicable HBRSEP surveillance history demonstrated no failures in the procedures and preventive maintenance tasks required to satisfy this SR.
 
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.7.11 Fuel Building Air Cleanup System (FBACS)
SR 3.7.11.2      Perform required FBACS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
SR 3.7.11.3      Verify the FBACS can maintain a negative pressure with respect to atmospheric pressure - Note: Not required to be met when the only movement of irradiated fuel is movement of the spent fuel shipping cask containing irradiated fuel.
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
grace period. SR 3.7.11.2 verifies that the required FBACS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). SR 3.7.11.3 verifies the integrity of the fuel building enclosure.
The ability of the fuel building to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the FBACS. The FBACS is designed to maintain a slight negative pressure in the fuel building, to prevent unfiltered LEAKAGE.
A review of the applicable HBRSEP surveillance history demonstrated only one (1) failure in the procedure and preventive maintenance task required to satisfy these SRs, and that failure would not have impacted the safety function.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.8.1 AC Sources - Operating SR 3.8.1.8      Verify each DG rejects a load greater than or equal to its associated single largest post-accident load and does not trip on overspeed. Notes: 1. This Surveillance shall not be performed in MODE 1 or 2. 2. If performed with the DG synchronized with offsite power, it shall be performed at a power factor 0.9.
SR 3.8.1.10      Verify on an actual or simulated Engineered Safety Feature (ESF) actuation signal each DG auto-starts from standby condition and: a. In  10 seconds after auto-start achieves voltage  467 V, and after steady state conditions are reached, maintains voltage  467 V and  493 V; b. In  10 seconds after auto-start achieves frequency  58.8 Hz, and after steady state conditions are reached, maintains frequency  58.8 Hz and  61.2 Hz; c. Operates for  5 minutes; d. Permanently connected loads remain energized from the offsite power system; and e. Emergency loads are energized through the automatic load sequencer from the offsite power system. Notes: 1. All DG starts may be preceded by prelube period. 2. This Surveillance shall not be performed in MODE 1 or 2. 3. During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
 
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
grace period. Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. SR 3.8.1.8 demonstrates the DG load response characteristics and capability to reject the largest single load without exceeding the overspeed trip.
SR 3.8.1.10 demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (10 seconds) from the design basis actuation signal (LOCA signal) and operates for  5 minutes. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application. This period may extend beyond the 10 second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR, HBRSEP Unit No. 2 monitors and trends the actual time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 5 minute period provides sufficient time to demonstrate stability.
SR 3.8.1.10.d and SR 3.8.1.10.e ensure that permanently connected loads and emergency loads are energized from the offsite electrical power system on an ESF signal without loss of offsite power.
The test procedure and preventive maintenance task implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedure and preventive maintenance task required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function.
Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent.
 
Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
    "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF."
The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.8.1.9        Verify on an actual or simulated loss of offsite power signal: a. De-energization of emergency buses; b. Load shedding from emergency buses;
: c. DG auto-starts from standby condition and: 1. energizes permanently connected loads in  10 seconds, 2. energizes auto-connected shutdown loads through automatic load sequencer, 3. maintains steady state voltage 467 V and  493 V, 4. maintains steady state frequency  58.8 Hz and 61.2 Hz, and 5. supplies permanently connected and auto-connected shutdown loads for  5 minutes - Notes: 1. All DG starts may be preceded by an engine prelube period. 2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
: 3. During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
SR 3.8.1.15      Verify on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ESF actuation signal: a. De-energization of emergency buses; b. Load shedding from emergency buses; and c. DG auto-starts from standby condition and: 1. energizes permanently connected loads in  10 seconds, 2. energizes auto-connected emergency loads through load sequencer, 3. achieves steady state voltage  467 V and  493 V, 4. achieves steady state frequency  58.8 Hz and  61.2 Hz, and 5.
supplies permanently connected and auto connected emergency loads for 5 minutes - Notes: 1. All DG starts may be preceded by an engine prelube period. 2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4. 3.
During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
grace period. SR 3.8.1.9 demonstrates the as designed operation of the standby power sources during loss of the offsite source.
This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.
SR 3.8.1.15 demonstrates the DG operation during a loss of offsite power actuation test signal in conjunction with an ESF actuation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable.
The test procedures and preventive maintenance tasks implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated twenty (20) failures in the procedures and preventive maintenance tasks required to satisfy this SR. Four (4) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. In the third case, procedural error did not provide proper alignment of plant equipment needed to perform the surveillance procedure. As a result, the procedure required revision to align the plant equipment to the desired configuration. In the fourth case, testing earlier in the procedure via the use of a different procedure (SPP-025) contributed directly to the undervoltage condition which caused the unexpected breaker trip immediately upon closure of the breaker. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Eleven (11) of the failures would not have impacted the safety function. Five (5) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected. Notes in the procedure state:
  "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room." Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily.
Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
: d. On 10/16/2013, breaker 52/18B tripped open immediately when closed. Found the trip signal from the degraded trip relays present due to a loose keyswitch. Tightened key switch and verified that Degraded Voltage trip was defeated.
 
Similar issue found when closing breaker 52/22A. Found KAZ microswitch contact closed causing the trip signal to be locked in. Completed testing section with the KAZ trip disabled. Work Request 11600872 written to address breaker 52/22A tripping.
Work Order 13303714 written for corrective action. Work Order 13303714 completion comments state: "Removed wiring for KAZ trip at terminal strip 3, terminals 1 and 4.
Connected DMM across wires lifted and read a short. Tapping on switches led to intermittent open and short readings when the right hand switch was tested. Replaced KAZ switch with new one from warehouse. Checked all switches per PM-402 as a guide. KAZ switches were all satisfactorily. Installed new KAZ fuses from warehouse.
FME closeout all satisfactorily.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
: e. On 2/18/2012, breaker 52/16B would not close from RTGB. Issue worked in conjuction with Work Order 1799932-01 to troubleshoot 52/16B failure to close. Work Order 1799932-01 measured voltages to ground and across terminals per supervision direction. It was found that the negative fuse side of the 1/16B contact (Gemco remote switch on RTGB) had positive voltages indicative of a shorted condition without breaker attempting to close. Racked breaker to test and tried to close locally (at switchgear) and breaker was trip free. Inspected secondary disconnects and noted a gross mis-alignment although no contacts appeared shorted together and all appeared to be made up properly. Removed breaker and cycled on test stand 2 to 3 times electrically with all satisfactorily results. Measured cell secondary contact voltages with breaker removed and fuses installed. Noted voltage on terminal 12 when there should not have been any. Removed fuses and ohmed panel "BA" terminals. Appears Gemco Switch 1/16B remote close contact on RTGB is closed when it should be open. Installed breaker in cubicle and verified proper engagement of secondary diconnects and racked breaker to connect all satisfactorily. Place local/remote switch on mimic bus panel and installed fuses. Closed breaker from mimic bus panel control switch all satisfactorily.
Recommenced MST-025 at Step 8.5.1.2 and performed all satisfactorily to Step 8.9.21.
Work Order 1534437 replaced defective Gemco switch. Non-Conformance Report 518122 written to document the Gemco Switch failure. Non-Conformance Report documents that the current condition of the switch will not allow the procedure to be successfully completed as breaker 52/16B will re-close immediately upon tripping.
Non-Conformance Report also references a 2008 Condition Report (00270624) in which an investigation of numerous failures of the RTGB Gemco switches was performed revealing a root cause of inadequate maintenance on the switches. As a result, HBRSEP has undergone a massive replacement strategy of the spring return to center Gemco switches on the RTGB as denoted in CR270624 which was scheduled for completion in RFO27. The failure of the Gemco switch at the RTGB impacted the ability of the Operator to CLOSE breaker 52/16B in preparation to perform the 272/E-2 Undervoltage Test in which the breaker is first closed and then tripped open during the actual undervoltage condition in Step 8.5.3.
 
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There is a total of one failure of the Westinghouse Model 10051C74H02Y Gemco Switch. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only five (5) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.8.1.12      Verify each DG operating at a power factor  0.9 operates for  24 hours:
: a. For  1.75 hours loaded  2650 kW and  2750 kW; and b. For the remaining hours of the test loaded  2400 kW and  2500 kW - Notes:
: 1. Momentary transients outside the load and power factor ranges do not invalidate this test. 2. This Surveillance shall not be performed in MODE 1 or
: 2. 3. During periods when a diesel generator is being operated for testing purposes, its protective trips need not be bypassed after the diesel generator has properly assumed the load on its bus.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR requires demonstration once per 18 months that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours,  1.75 hours of which is at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG start shall be a manually initiated start followed by manual syncronization with other power sources. Additionally, the DG starts for this Surveillance can be performed either from standby or hot conditions.
The test procedures and preventive maintenance tasks implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedures and preventive maintenance tasks required to satisfy this SR. One (1) failure was event driven, in that the M&TE recorder was improperly configured for the test, which contributed directly to the As Found condition. Therefore, this failure will have no impact on an extension to a 24 month surveillance interval. Twelve (12) of the failures would not have impacted the safety function. Two (2) unique failures were observed, and they are described below.
: a. On 5/15/2015, per CAS description for Work Request 11671548, "EDG 'A' output breaker 52/17B tripped during OST-410. While performing section 8.3, 2750 KW load test, EDG 'A' had been at 2700 KW for approximately 10 minutes of the load test. All recorded parameters of the load test were in normal required bands of the OST. These are recorded every ten minutes in the OST attachment and the operator was in the process of recording when the EDG output breaker opened. No switches were being manipulated. ERFIS shows EDG 'A' voltage at a constant 480V with a sudden spike at 0004 and breaker opening. Current max on ERFIS was approximately 3450 amps, which is less than the 4000 max amps provided by the OST. EDG 'A' KW on ERFIS remained below the max of 2750. Locally at the EDG 'A' generator control panel voltage was at 490 volts, current at 3600 amps, and 2700 KW.
 
All readings were normal and in the required band. Overcurrent flag 51V-A-ADG dropped at the EDG 'A' generator control panel. I&C investigated the 52/17B breaker cubicle and did not notice any abnormalities." Work Order 13522379-01 replaced the relay, and OST-410 was then completed satisfactorily. The failed overcurrent protection relay inhibits the DG from delivering the power as required.
A unique failures review was performed for this failure, to determine whether the failure is repetitive. There is a total of one failure of the Asea Brown Boveri Model COV-8 Relay. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
: b. On 10/12/2005, Fuel Oil Transfer Pump B failed while running in support of the B EDG during performance of OST-411 (24 hour load test). Work Order 769405 was referenced for corrective action. Work Order 769405 removed and replaced the B Fuel Oil Transfer Pump Motor. Action Request 00172281 was written to evaluate the failure.
Evaluation of the failed motor indicated the motor failed due to insulation breakdown of the motor windings from environmental conditions due to a lack of periodic motor replacement.
Action Request 00172281 considers this failure to be a functional failure based on the failure of the B EDG fuel oil transfer pump to supply fuel to the EDG day tank which did not allow the completion of the 24 hour load test. Therefore, the EDG would not be able to perform its required safety function. The motors have been placed on a new replacement frequency of every four years to preclude any additional future failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. No similar failures are identified; therefore, the failure is not repetitive in nature. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only two (2) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.8.1.13      Verify each DG starts and achieves, in  10 seconds, voltage  467 V, and frequency  58.8 Hz, and after steady state conditions are reached, maintains voltage  467 V and  493 V and frequency  58.8 Hz and  61.2 Hz - Notes: 1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated  2 hours loaded  2400 kW and  2500 kW. Momentary transients outside of load range do not invalidate this test. 2. All DG starts may be preceded by an engine prelube period.
 
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within 10 seconds. The 10 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA.
Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not damped out by load application. This period may extend beyond the 10 second acceptance criteria and could be a cause for failing the SR. In lieu of a time constraint in the SR, HBRSEP Unit No. 2 monitors and trends the actual time to reach steady state operation as a means of assuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable.
The test procedures and preventive maintenance tasks implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated twenty-four (24) failures in the procedures and preventive maintenance tasks required to satisfy this SR. Two (2) failures were event driven. For the first case, the M&TE recorder was improperly configured for the test, which contributed directly to the As Found condition. For the second case, the improper setup of the chart recorder used in the initial performance of the test contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval.
Two (2) of the failures would have been detected by other, more frequent testing.
Eighteen (18) of the failures would not have impacted the safety function. Two (2) unique failures were observed, and they are described below.
: a. On 5/15/2015, per CAS description for Work Request 11671548, "EDG 'A' output breaker 52/17B tripped during OST-410. While performing section 8.3, 2750 KW load test, EDG 'A' had been at 2700 KW for approximately 10 minutes of the load test. All recorded parameters of the load test were in normal required bands of the OST. These are recorded every ten minutes in the OST attachment and the operator was in the process of recording when the EDG output breaker opened. No switches were being manipulated. ERFIS shows EDG 'A' voltage at a constant 480V with a sudden spike at 0004 and breaker opening. Current max on ERFIS was approximately 3450 amps, which is less than the 4000 max amps provided by the OST. EDG 'A' KW on ERFIS remained below the max of 2750. Locally at the EDG 'A' generator control panel voltage was at 490 volts, current at 3600 amps, and 2700 KW. All readings were normal and in the required band. Overcurrent flag 51V-A-ADG dropped at the EDG 'A' generator control panel. I&C investigated the 52/17B breaker cubicle and did not notice any abnormalities." Work Order 13522379-01 replaced the relay, and OST-410 was then completed satisfactorily. The failed overcurrent protection relay inhibits the DG from delivering the power as required.
A unique failures review was performed for this failure, to determine whether the failure is repetitive. There is a total of one failure of the Asea Brown Boveri Model COV-8 Relay. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
: b. On 10/12/2005, Fuel Oil Transfer Pump B failed while running in support of the B EDG during performance of OST-411 (24 hour load test). Work Order 769405 was referenced for corrective action. Work Order 769405 removed and replaced the B Fuel Oil Transfer Pump Motor. Action Request 00172281 was written to evaluate the failure.
Evaluation of the failed motor indicated the motor failed due to insulation breakdown of the motor windings from environmental conditions due to a lack of periodic motor replacement. Action Request 00172281 considers this failure to be a functional failure based on the failure of the B EDG fuel oil transfer pump to supply fuel to the EDG day tank which did not allow the completion of the 24 hour load test. Therefore, the EDG would not be able to perform its required safety function. The motors have been placed on a new replacement frequency of every four years to preclude any additional future failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. No similar failures are identified; therefore, the failure is not repetitive in nature. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only two (2) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.8.1.16        Verify automatic transfer capability of the 4.160kV bus 2 and the 480V Emergency bus 1 loads from the Unit auxiliary transformer to the start up transformer - Notes: 1. This Surveillance shall not be performed in MODE 1 or 2. 2. SR 3.8.1.16 is not required to be met if 4.160 kV bus 2 and 480 V Emergency Bus 1 power supply is from the start up transformer.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. Transfer of the 4.160 kV bus 2 power supply from the auxiliary transformer to the start up transformer demonstrates the OPERABILITY of the offsite circuit network to power the shutdown loads. In lieu of actually initiating a circuit transfer, testing that adequately shows the capability of the transfer is acceptable.
A review of the applicable HBRSEP surveillance history demonstrated two (2) failures in the procedures and preventive maintenance tasks required to satisfy this SR. One (1) failure was event driven, in that an incorrect (voltage versus current) relay was installed during this outage, which directly contributed to the failure of the MST procedure.
Therefore, this failure will have no impact on an extension to a 24 month surveillance interval. The other failure would not have impacted the safety function.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
 
TS 3.8.4 DC Sources - Operating SR 3.8.4.3      Remove visible terminal corrosion, verify battery cell to cell and terminal connections are clean and tight, and are coated with anti-corrosion material.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. Visual inspection of intercell, intertier, and terminal connections provide an indication of physical damage or abnormal deterioration that could indicate degraded battery condition. The anticorrosion material is used to help ensure good electrical connections and to reduce terminal deterioration. The visual inspection for corrosion is not intended to require removal of and inspection under each terminal connection. The removal of visible corrosion is a preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR provided visible corrosion is removed during performance of SR 3.8.4.3.
A review of the applicable HBRSEP surveillance history demonstrated only one (1) failure in the procedures and preventive maintenance tasks required to satisfy this SR, and that failure would not have impacted the safety function.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.8.4.4      Verify each battery charger supplies  300 amps at  125 V for  4 hours.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR requires that each battery charger be capable of supplying 300 amps and 125 V for  4 hours. These current and voltage requirements are based on the design capacity of the chargers. The battery charger supply is based on normal DC loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state. The minimum required amperes and duration ensures that these requirements can be satisfied.
A review of the applicable HBRSEP surveillance history demonstrated only two (2) failures in the procedures and preventive maintenance tasks required to satisfy this SR, and neither of these failures would have impacted the safety function.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
SR 3.8.4.5      Verify battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test - Notes: 1.The modified performance discharge test in SR 3.8.4.6 may be performed in lieu of the service test in SR 3.8.4.5. 2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. A battery service test is a special test of battery capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system.
 
A review of the applicable HBRSEP surveillance history demonstrated five (5) failures in the procedures and preventive maintenance tasks required to satisfy this SR. Two (2) failures were event driven, in that the failure of the test equipment used in the initial performance of the test contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. The other three (3) failures would not have impacted the safety function.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.8.9 Distribution Systems - Operating SR 3.8.9.2      Verify capability of the two molded case circuit breakers for AFW Header Discharge Valve to S/G "A", V2-16A to trip on overcurrent.
SR 3.8.9.3      Verify capability of the two molded case circuit breakers for Service Water System Turbine Building Supply Valve (emergency supply), V6-16C to trip on overcurrent.
The surveillance test intervals of these SRs are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25%
grace period. These Surveillances verify that the two breakers associated with each ABT will trip on over current as required to prevent the fault from affecting both trains of the AC Distribution System.
A review of the applicable HBRSEP surveillance history demonstrated three (3) failures in the procedure and preventive maintenance task required to satisfy these SRs, and none of these failures would have impacted the safety function.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.9.3 Containment Penetrations SR 3.9.3.2      Verify each required containment ventilation valve actuates to the isolation position on an actual or simulated actuation signal.
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This Surveillance demonstrates that each containment ventilation valve actuates to its isolation position on manual initiation or on an actual or simulated high radiation signal.
The test procedure and preventive maintenance task implementing this Surveillance Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated fifteen (15) failures in the procedure and preventive maintenance task required to satisfy this SR. Two (2) of the failures were event driven. For the first of these, the test equipment (chart recorder) being utilized to document the test results failed during the procedure performance. As a result, the procedure acceptance criteria was not able to be confirmed as acceptable. In the second case, the replacement of relay CA23X during RO-29 (in 2014) and the subsequent incorrect wiring of the relay during replacement contributed directly to the As Found condition. Therefore, these failures will have no impact on an extension to a 24 month surveillance interval. Ten (10) of the failures would not have impacted the safety function.
Three (3) unique failures were observed, and they are described below.
: a. On 5/3/2007, CB-1 on Battery Charger A-1 failed to trip when power was removed from charger. Work Order 1056863 written to address issue. Work Order states that Relay K-6 is suspected to be the problem. Fuses F-14 and F-15 were checked and found to be satisfactory. Replaced the K-6 relay. Post Maintenance Test (PMT) of the battery charger breaker was performed on the same Work Order.
: b. On 10/29/2008, input breaker CB1 on Battery Charger B-1 failed to trip on loss of AC Voltage. Work Request 10356292 initiated to document finding. Work Order 11440102 completion comments state: "Obtained new K-6 relay from stock and bench tested all satisfactorily. Replaced relay in charger and functionally tested all satisfactorily."
A unique failures review was performed for these failures, to determine whether these failures are repetitive. There are a total of two failures related to the Ametek Model 85-CC3000 Battery Chargers. One failure occurred in Battery Charger A-1 in 2007 and one failure occurred in Battery Charger B-1 in 2008. Both failures involved the replacement of the K-6 relay. Both battery chargers were replaced in 2013 via Engineering Change 000028016 and Engineering Change 0000280187. No time based mechanisms are apparent. Therefore, these failures are unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failures are unique and do not occur on a repetitive basis and are not associated with a time-based failure mechanism. Therefore, the failures will have no impact on an extension to a 24 month surveillance interval.
: c. On 6/20/2015, when placing the PZR HTR BACK-UP GROUP "A" switch to ON, the RTGB ON indication did not illuminate as expected.
Notes in the procedure state: "52/2C did not close from RTGB. Work Request 11676262 submitted. 52/2C closed from local control station in Rod Control Room."
Work Order 13535588 was written to address corrective action. Work Order completion comments state: "Removed control power fuses for 52/2C. Lifted cable C2131G at Aux Panel "AF". Measured continuity between B to W, R to G, and O to U. All readings were OPEN. Relanded cable C2131G and reinstalled fuses. Racked 52/2C to test, cycled breaker all satisfactorily. Removed fuses, verified circuit at remote switch station from RTGB to breaker - all satisfactory. Checked breaker alarm switches - all satisfactory. Opened back-up "A" heater breakers, racked 52/2C in and had Ops cycle breaker three times - no problems. Found wiring discrepancies in local HTR control box; indicating lights are energized in Remote and drawing B-190628 sht. 131 shows they should be OFF." The Correct Only Evaluation (COE) of Non-Conformance Report 00755112 states that although the breaker did not close from the RTGB, it would close when operated from the local position. The COE goes on to state that no issues were found during troubleshooting and the breaker was cycled several times from the RTGB with no issues. Non-Conformance Report 00755505 documents a similar condition in 2013 (RFO-28) on this same breaker. Non-Conformance Report 00755505 concluded that although there was a repeat failure of the breaker in both RFO-28 and RFO-29, they were not identical failures.
A unique failures review was performed for this failure, to determine whether this failure is repetitive. There are a total of two failures related to the Westinghouse Model DB-50 breaker. One failure was due to a failed KAZ microswitch in Breaker 52/18B in 2013 and one failure was Breaker 52/2C not closing as expected from the RTGB in 2015. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
 
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only three (3) failures are identified as unique failures, and they are not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
TS 3.9.7 Containment Purge Filter System SR 3.9.7.3        Perform required Containment Purge Filter System filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
The surveillance test interval of this SR is being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period. This SR verifies that the required Containment Purge Filter System filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).
A review of the applicable HBRSEP surveillance history demonstrated one (1) failure in the procedure and preventive maintenance task required to satisfy this SR. This failure was categorized as unique, and it is described below.
: a. On 2/2/2012, testing was unsatisfactory due to failed carbon sample radioiodine analysis test (84.956% efficiency versus an acceptance criteria of 90%). Per the visual inspection checklist, several cells were found degraded due to moisture. Carbon replacement was performed under Work Order 12031819 and the retest was completed satisfactorily.
A unique failures review was performed for this failure, to determine whether the failure is repetitive. No similar failures are identified; therefore, the failure is not repetitive in nature. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only one (1) failure is identified as unique, and it is not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small. (See also justification for Technical Specification 5.5.11.)
TS 5.5.11 Ventilation Filter Testing Program (VFTP)
While this specified frequency of testing filter ventilation systems does not explicitly state "18 months," TS Section 5.5.11 requires testing frequencies in accordance with RG 1.52 (Reference 2), which does reference explicit "18-month" test intervals for various performance characteristics. With this change, these performance tests are being increased from once every 18 months to once every 24 months, for a maximum interval of 30 months including the 25% grace period.
 
This exception to the RG 1.52 interval is explicitly addressed in the change to TS 5.5.11.
Furthermore, this revision to the HBRSEP commitment to RG 1.52 will be reflected in a revision to the UFSAR and provided in accordance with 10CFR50.71(e). The first paragraph within TS 5.5.11 is revised to state (inserted text shown underlined):
This program provides controls for implementation of the following required testing of Engineered Safety Feature (ESF) ventilation filter systems at the frequencies specified in Positions C.5 and C.6 of Regulatory Guide 1.52, Revision 2, March 1978, except that the testing specified at a frequency of 18 months is required at a frequency of 24 months, and conducted in general conformance with ANSI N510-1975 or N510-1980.
In addition to the 24-month testing, ventilation filter (HEPA and charcoal) testing will continue to be performed in accordance with the other frequencies specified in RG 1.52:
(1) on initial installation and (2) following painting, fire, or chemical release in any ventilation zone communicating with the system. Additionally, RG 1.52 requires a sample of the charcoal adsorber be removed and tested after each 720 hours of system operation and an in-place charcoal test be performed following removal of these samples if the integrity of the adsorber section was affected. This proposed amendment request will not change the commitment to perform these required tests.
The test procedures and preventive maintenance tasks implementing this Technical Specification Requirement are very large and test a wide range of equipment. A review of the applicable HBRSEP surveillance history demonstrated seven (7) failures in the procedures and preventive maintenance tasks required to satisfy this SR. Six (6) of the failures would not have impacted the safety function. One (1) unique failure was observed, and it is described below.
: a. On 2/2/2012, testing was unsatisfactory due to a failed carbon sample radioiodine analysis test (84.956% efficiency versus an acceptance criteria of 90%). Per the visual inspection checklist, several cells were found degraded due to moisture. Carbon replacement was performed under Work Order 12031819 and the retest was completed satisfactorily.
A unique failures review was performed for this failure, to determine whether the failure is repetitive. No similar failures are identified; therefore, the failure is not repetitive in nature. No time based mechanisms are apparent. Therefore, this failure is unique and any subsequent failure would not result in a significant impact on system/component availability.
The identified failure is unique and does not occur on a repetitive basis and is not associated with a time-based failure mechanism. Therefore, the failure will have no impact on an extension to a 24 month surveillance interval.
Only one (1) failure is identified as unique, and it is not indicative of repetitive time based failure mechanisms. As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.
 
TS 5.5.17 Control Room Envelope Habitability Program
[Note that only item (d) of this program description is affected, so only that element is listed.]
A Control Room Envelope (CRE) Habitability Program shall be implemented to ensure that, with an OPERABLE Control Room Emergency Filtration System, CRE occupants can control the nuclear power unit safely following a radiological event, hazardous chemical release, or a smoke challenge. The program shall include the following elements:
: d. Measurement, at designated locations, of the CRE pressure relative to external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREFS, operating at the flow rate required by the VFTP, at a frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the assessment of the CRE boundary.
The surveillance test interval of this requirement is being increased from once every 18 months on a STAGGERED TEST BASIS to once every 24 months on a STAGGERED TEST BASIS, for a maximum interval of 30 months on a STAGGERED TEST BASIS, including the 25% grace period.
A review of the applicable HBRSEP surveillance history demonstrated no failures in the procedures and preventive maintenance tasks required to satisfy this SR.
As such, the impact, if any, on system availability is minimal from the proposed change to a 24-month STAGGERED TEST BASIS testing frequency. Based on the history of system performance, the impact of this change on safety, if any, is small.}}

Latest revision as of 11:42, 9 January 2025

Resubmittal of Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles
ML17093A787
Person / Time
Site: Robinson 
Issue date: 04/03/2017
From: Kapopoulos E
Duke Energy Progress
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/17-0014
Download: ML17093A787 (393)
v • d • e


Text

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