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#REDIRECT [[PY-CEI-NRR-1284, Application for Amend to License NPF-58,changing Tech Specs 3/4.3.1 Re Reactor Protection Sys instrumentation,3/4.3.6 Re Control Rod Block Instrumentation & 3/4.3.7.6 Re Source Range Monitors]]
| number = ML20070T094
| issue date = 03/28/1991
| title = Application for Amend to License NPF-58,changing Tech Specs 3/4.3.1 Re Reactor Protection Sys instrumentation,3/4.3.6 Re Control Rod Block Instrumentation & 3/4.3.7.6 Re Source Range Monitors
| author name = Lyster M
| author affiliation = CENTERIOR ENERGY
| addressee name =
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000440
| license number =
| contact person =
| document report number = PY-CEI-NRR-1284, NUDOCS 9104030254
| package number = ML20070T095
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS & PERMITS
| page count = 14
| project =
| stage = Request
}}
 
=Text=
{{#Wiki_filter:.
1                      CENTERED 3 ENERGY PERRY NUCLEAR POWER PLANT                  t il  es Michael D. Lyster PE R,    HIO 4 081 (216) 259 3M7 March 28, 1991 PY-CEI/NRR-1284 L U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.            20555 Perry Nuclear Power Plant Docket No. 50-440 Technical Specification Change Request:
Reactor Protection System lustrumentation, Control Rod Block Instrumentation and Source Range Monitors Instramentat_io3 Gentlemen In accordance with 10CFR50.90, enclosed is a request for amendment of Facility Operating License NPF-58 for the Perry Nuclear Power Plant (PNPP) Unit 1. In accordance with the requirements of 10CFR$0.91(b)(1), a copy of this amenament request has been sent to the State of Ohio as indicated t.elow, This amendment request proposes changes to PNPP Technical Specificatione 3/4.3.1, " Reactor Protection System Instrumentation"; 3/4.3.6 " Control Rod Block Instrumentation"; and 3/4.3.7.6, " Source Range Monitori.." Attachinent i provides the Summary, Safety Analysis, No Significant llazards had Environmental Impact Considerations. Attachment 2 is a copy of the marked up Technical Specification pages.
It is requested that these proposed changes be issued prior to our next scheduled manual shutdown for the third refueling outage, currently slated for February 28, 1992.
If you have any questions, please feel free to ca]*.
Sincer+1g Qt          A Michael D. Lyscsr HDLICJFinjc Attachments cc      NRC Project Manager NRC Resident Inspector Office NRC Region III J. Ilarris, State of Ohio opw;cu y es                                                                              i Cae:ama f em: h w o"g                                                                J wae te -
9104030234 910320                                              f a                    t . c.' 9 h }^                        PDR P
ADOCK 05000440 POR                                          hhv' )  ,
                                                                                                                                    }
 
Attachunt (
PV-CE1/NRR-1284 L
                                          ,'    -                                                                                            Page 1 of 13 l
Summary of Proposed Changes In accordance with 10CFR50.9t, the following changes to the Perry Nuclear Pover Plant (PNPP) Technical Specifi<ations 3/4.3.1, " Reactor Protection System Instrumenu.lon 3/4.3.0 "Cco rol Rod Block Instrumento<fon"; and 3/4.3.7.6, " Source Range Monitors,' a.re being proposed. Additional discussion and justification of these items is provided under the " Safety Analysis" section of this letter, which follows the Summary.
(1) A new Surveillance Requirement, 4.3.1.4 is added to the Reactor Protection System (RPS) Instrumentation Technical Specifications as indicated in Attachment 2, pages 1 and 2. The proposed requirement vould state thct the provisions of Technical Specification 4.0.4 are not applicable to the Channel Functional Test and Channel Calibration surveillances for the Intermediate Range Monitors (IRM) for entry into their applicable Operational Conditions (as shovn in Table 4.3.1.1-1) ftom Operational Condition 1, provided the surveillances are performed within 12 hours after such entry. This Specification 4.0.4 exception is necessary since in Operational Condition 1 the IRH detectors are withdrawn from the core, and the IRH Channel Functional Test cannot be performed becau=e the IRH trip functions are bypassed with the reactor mode switch in the Run position (The IRH functions are not required to be operable in Operational Condition 1). Consequently, extended plant operation in Operatiot.al Condition 1 results in the weekly IRH Channel Functional Test surveillance frequency being exceeded since this testing cannot be performed in Operational condition 1 prjor to the plant entering the Operational conditions for which the IRM surveillances are required (e.g., Operational Condition 2, 3 or 4) during a manual controlled plant shutdovn or due *.9 a reactor scram. As a result, currently, in order to avoid a tecnnical violation of Specification 4.0.4 during manual controlled shutdovns, these IRH functions have to be declaced inoperable and the applicable Action Statements entered. This proposed change vill allov for manual controlled shutdovns to be performed without technical violations of Specification 4.0.4, and in combination vith the provisions of the recently revised Specification 4.0.3, vill provide adequate time to perform these surveillances af ter the applicable Operational Condition has been entered both during manual controlled shutdowns and following reactor scrams. This proposed change vill enhance safety by reducing the possibility for unnecessary scrams and safety syste'n challenges by precluding the necessity for technicians having to perform these surveillances under the provisions of the applicable Action Statement, which requires insertion of an IRH trip that produces an RPS half-scram signal during a planned shutdown or reactor scram recovery. Please note that the possibility of the submittal of a Specification 4.0.4 exception such as proposed here was mentioned in a previous Ictter to the NRC dated November 28, 1989 (reference letter PY-CEI/NRR-1099L page 2, footnote),
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Attachment 1 PY-CEI/NRR.1284 L Pe p 2 of 13 I
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(2) Note (c) of Technical Specificat W Table 4.3.1 b l, " Reactor Protection System Instrumentation Surveillance Fequiraeus" is to be deleted as indicated in Attachment 2, pages 3 and 4. 'this note is associated with the IRH and Average Power Range Monitor (APRH) Channel Functional Test
,                                requirements. The note currently states that the Channi! Functional Test must be performed "vithin 24 hours prior to startup, if not prformed                  r vithin the previous 7 days." This proposed change (to delete the note)                l is similar to the change proposed to Surveillance Requirement 4.3.7.6.b.1            ,
for Source Range Monitors discussed in item (6) below. The existing                    )
vording is considered potentially confusing due to the 24-hour clause,                j vhich appet s to require anticipation of the exact time of startup, which              )
is not always possible. The current Channel Functional Test requirements              '
(with a frequency of at least once per seven days) provide equivalent assurarae of the operability of the associated RPS function.                          -
As a result of the proposed deletion of note (c), the associated "S/U" Channel Functional Test surveillance frequency is ao longer required since the surveillance must have been performed within seven days prior to plant startup due to the specified frequency of "at least once pergc)n seven days" ("V") and Technical Specification 4.0.4. Therefore, "S/U is deleted from the Table 4.3.1.1-1 Channel Functional Test column for items 1.a (IRM) and 2.a (APRH) of the Table (see Attachment 2, page 3).
(3) Note (d) Technical Specification Table 4.3.1.1-1 is revised by adding a new sentence as indicated in Attachment 2, page 4.          Note (d) app'ies to the weekly Channel Calibration requirement for the RPS APRM Flov-Biased Simulated Thermal Pover-High ar! Neutron Flux-High functions. This note requires adjustment of the APRH channel gains such that the APRHs conform to the reactor power values calculated by a heat balance during Operational Condition 1 when THERHAL POWER > 25% of RATED THERHAL POVER, if the absolute dif ference is greater then 'l% of RATED THERMAL. POVER.
Per Table 4.3.1.1-1 (page 3/4 3-7), these APRM functions are required to be operable in Operational Condit1on 1. Note (d) vill nov provide an exception to the provisions of Technical Specification 4.0.4 to clarily that entry into operational Condition 1, a subsequent increase to > 25%
RATED THERMAL POVER, a.id a 12 hour time f rame for performance of tfils surveillance after reaching 25% of RATED THERHAL POVER is permitted. In other vords, this proposed change vill clarify that it is acceptable to enter Operational Condition 1 ard further, to establish the plant conditions necessary to provide ecurate results from a heat balance calculation prior to performing this surveillance.
 
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Attachmont 1 PY-CEI/NRR-1284 L
                          '
* Page 3 of 13 (4) The. current-Control Rod Block Instrumentation Surveillance Requirement
                                        -4.3.6 is renumbered as 4.3.6.1 and a new Surveillance Requirement 4.3.6.2 is added as indicated in Attachment 2, page 5. Similar to proposed change (1) of this submittal, Surveillance Requirement 4.3.6.2 vill state that the provisions of Technical Specification 4.0.4 are not applicable to the Channel Functional Test and Channel Calibration surveillances for the IRMs and Source Range Monitors (SRM) for entry into their applicable Operation 1 Conditions (as shown in Table 4.3.6 1) from Operational Condition 1, provided the surveillances are performed within 12 hours after such entry. This provision is also necessary for the reasons
                                          =tatan in propoaed change (1) above. Specifically, this provision addresses IRH ar.d SRM surveillances that become applicable during plant shutdown.i following extended operation in operational Condition 1, and vnich cannot he periormed at povar
;                              (5) The channel calibration frequency for-the SRM control rod block functions specified on Technical Specification Table 4.3.6-1 is changed from at least onco per 184 days ("SA") to at least r ee per 18 months ("R") as indicated in Attachment 2, page 6. These proposed changes are consistent with Technical Specification 3/4.2.7.6 for Source Range Monitoring Instrumentation and with Technical Specification 3/4.3.7.5 for Accident Monitoring SRM Instrumentatio_n.= There is no specific design basis which requires there SRH control rod block functions to be. calibrated more often than the corresponding source range monitoring functions. Also, no credit is taken for these SRH control rod blocks in any of PNPP's Chapter 15 design basis analyses. Although current Channel Functional Test procedures at FNPP (performed at least once per seven days while in applicable modes) already include provisions for verifieraion of proper setpoints for- tino functions and ensure prompt correction of out-of-calibration setpoints, this change request proposes an addition to
                                        -Surveillance Requirement-4.3.6, Table 4.3.6-1, to add the performance of this trip setpoint verification to the' Technical Specifications for the-upscale-and dr.Tscale SRM Rod Bhek Setpoints during veekly SRM Channel Functional Tests (riorence Attaument 2, page 6). As with all other
                                        -Technical' Specification surveillances, a calibration of the Rod Block Channel vould be required if any of these.setpoint verifications are
!                                          found outside the allovable values given in the Technical Sp2cifications.
j Note that a similar change was previously approvedLfor the IRH control l
rod block functions by Amendment No. 31.to the PNPP Operating License (reference Technical Specif.ication Chenge Request letter o
PY-CEI/NRR-0732L, dated November 19,-1987, Supplemental Information letter PY-CEI/NRR-1099L, dated November 28, 1989 and Amendment 31, l
including Safety Evaluation, dated July.18, 1990).
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Attaeb%nt 3 PY-CEI/ar.R-1284 L Page 4 of 13 9
(6) Surveillance Requirement 4.3.7.6.b.1 is revised for clarification in a manner similar to that proposed for note (c) of Technical Specification-Table 4.3.1.1-1 discussed in item (2) above (see-Attachment 2, page 7).
This sorveillance currently requires that the SRMs be demonstrated operable by the performance of a channel Functional Test "vitFin 24 hours prior to moving the reactor mode switch from the Shutdown position, if not performed within the previous 7 days." The propossd frequency states "vithin 7 days prior to moving the reactor mode switch from the Shutdown position." As dascribed in item 2 above, the current wording is
:                                                considered pote dially confusing due to the 24-hour clause which appears to requ W anticipation of the exact time of moving the reactor mode suitd.- from the Shutdown position, which is not always possible. The nu posed change provides equivals t assurance that the SRM is operable, vr!1e remvving the source of possible confusion.
(7) A new tc.tnote (footnote #) associated with the SRH Channel Calibrations in Surveillance Requirement 4.3.7.6.a.2, and with the SRH Channel Functional Tests in Surveillance Requirement 4.3.7.6.b.2 is added as indicated in Attachment 1, pages 7 and 8. The proposed wording of footnote # states that the provisions of Technical Specification 4.0.4 are not applicable to the Channel Functional Test and Channel Calibration surveillances for the Source Range Monitors for entry into their applicable Operational-Conditions (Operational Condition 2*, 3 and 4) from Operational Condition 1, provided the surveillances are performed-vithin 12 hoves after such entry. These proposed changes are similar to items (1) and (4) above and are also necessary-to address SRH g                                                surveillances which become applicable during plant shutdowns following
!                                                extended operation in Operational Condition 1, and cannot be performed at power.
Safety- Arialysis/ Justification for Proposed Changes The-proposed changes can be grouped into one of three general categories                                (1)
;                                  incorporate statements of exception to Technical Specification 4.0.4 (items 1, 3,-4 and 7), (2) clarify startup surveillance. requirements (items 2 and 6),
and (3)-revise SRH Control Rod Block Channel Calibration frequency (item 5).
These general categories are discussec separately below.
l                              '
Incorporate Stetements of Exception to Technical Specification 4.0.4 (item 1,-
!.                                3,-4 and 7)
As. described above,-this Technical Specification Change Request proposes to incorporate statements of exception to the provisions of Technical Specification 4.0.4 for the IRM.RPS functions in Technical Specification 3/4.3.1, the IRH and SRH Control Rod Block functions in Technical l                                Specification 3/4.3.6 and the SRH functions in Technical Specification l                                3/4.3.7.6. These proposed exceptions to Technical Specification 4.0.4 vill only be applicable during plant thutdowns followina extended operation in Operational Condition 1.
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Attachment 1 PY-CEI/NRR-1284 L Page 5 of 13 As described above in items 1 and 4,  this Technical Specification Change Request proposes to add a Specification 4.0.4 exception for the IRH functions in the kPS and Control Rod Block Instrumentation Specifications.      As stated in PNPP's Updated Safety Analysis Report (USAR) Section 7.6.1.4.1 and 7.2.1.1.b the IRM system consists of eight detectors. The IRM is a five-decade, ten-range instrument, and the trip setpoint of 120 divisions of scale is active in each of the ten ranges. Thus, as the IRH is " ranged up" to accommodate increases in reactor power, the trip setpoint is also ranged up.
The IRMs also provide neutron monitoring overlap with both the APRM and the SRM systems. After the IRMs have been verified to overlap the APRMs during reactor startups, the IRMs are withdravn from the reactor core in order to prolong their life. Vhen the reactor mode svitch has been placed in the Run position (Operational Condition 1), the IRM scram and control rod block functions are automatically bypassed since adequate protection and monitoring is provided by the APRM functions.
Per Technical Specification 3/4.3.1, Table 4.3<l.1-1, the IRH Neutron Flux-High and Inoperative RPS functions are required to be operable in Operational Conditions 2, 3, 4 and 5. Per Technical Specification 3/4.3.6, Table 4.3.6-1, the IRM Detector-not-full-in, Upscale, Inoperative, and Downscale control rod block functions are currently required to be operable in Operational Conditions 2 and 5. During plant operation in Operational Condition 1 (with the reactor mode svitch in the Run position), a Channel Functional Test cannot be performed since the IRM trips are automatically bypassed with the reactor mode switch in the Run position. Further, a Channel Calibration requires the performance of a Channel Functional Test. As a result, the IRH surveillance frequency is exceeded during extended operation in Operational Condition 1.
Technical Specification 4.0.4 prohibits entry into an Operational Conditiun unless the surveillance requirement (s) associated with the Technical Specification has been performed within the applicable surveillan< interval.
As a result, Technical Specification 4.0.4 would imply that the teactor mode switch cannot be placed in the Startup/ Hot Standby (Operational Condition 2),
Hot Shutdown (0p Con 3) or Cold Shutdown (0p Con 4) position after extended operatioa in Operational Condition 1 until the IRM curveillances have been performed. As previously stated however, these surveillances cannot be performed until after the reactor mode switch is taken out of the Run position. Therefore, it is proposed that an exception to the provisions of Technical Specification 4.0.4 be added for the IRMs to allow entry into the plant conditions required to complete this testing. Additionally, it is proposed that a limit be placed on this exception to require these surveillances to be performed within 12 hours after entering these applicable Operational Conditions.
 
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Attachmant 1 PY-CEI/NRR-1284 L Page 6 of 13 4
These proposed changes are justified on the basis that, since the reactor vill already be in a shutdown condition (as a result of a scram) or in the process of a contrelled shutdown, and since the APRM RPS (scram) functions vould continue to be operable (since the APRM surveillances can be maintained current in op Con 1) adequate scram protection is available during the short period of time needed to perform the IRH surveillance 3. The 4.0.4 exception vould apply only during such reactor shutdowns, and not to reactor startups.
In addition, the IRH control rod block functions are provided only to ensure that adequate neutron monitoring is available during control rod movements and no credit is taken in PNPP's USAR Chapter 15 safety analyses for the IRH control rod block function. Again, the APRMs are adequate to perform this monitoring function during the short period of time needed to perform the IRH surveillances in Operational Condition 2.      Also, the IRH's are not necessarily incapable of performing their functions during a controlled shutdown just because the surveillances are overdue. The channel check, which can be quickly performed on the IRH channels prior to performance of the functionals/ calibrations, provides some confidence that the IRH's are functional. During Operational Condition 3 and 4, the control rods vould already be inserted and the Reactor Mode Switch-Shutdown Mode function ptuvides a control rod block to prevent control rod withdrawal.
Because the IRH Surveillances cannot be completed in Operational Condition 1, Technical Specifications would require all the IRH Channels to be declared inoperable upon entry into an applicable Operational Condition for which these surveillance requirements apply (i.e., Operational Condition 2 during normal manual shutdovns, and Operational Condition 3 for reactor scrams), if sustained power operations have occurred which extended beyond the surveillance interval due date (7 days for Channel Functional Tests and 18 months for Channel Calibrations). Due to this "inoperability," the Action Statement for Technical Specification 3.3.1 requires that one RPS trip system be placed in the tripped condition (half-scram condition) within 1 hour after entering Operational Condition 2 (or Operational Condition 3).      Likewise, the Action Statement for Technical Specification 3.3.6 requires one of the IRH Channels to be placed in the tripped condition within 1 hour after entoring Operational Condition 2. This results in the generation of a control rod block and, since the same IRH logic serves both the rod block and scram functions, it also results in the RPS logic being placed in a half-scram condition. Requiring the performance of IRH Channel Functional Test and Channel Calibration surveillances under the above plant conditions results in a significant increase in the probability for unnecessary reactor scrams and l      safety system challenges. Also, although Perry Plant operators and technicians take all appropriate actions to avoid a plant scram during performance of the above surveillances, the burden placed on plant operators and technicians to avoid such consequences is, under the circumstances, unnecessary and avoidable.
The proposed exceptions to Technical Specification 4.0.4, along with the proposed 12 hour time period provided for completion of the overduc IRH Channel Functional Test and Channel Calibration surveillances vill provide a significant scram reduction benefit by reducing the possibility for l
unnecessary scram and safety system challenges folloving mode changes.
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Attachmsnt 1 PY-CEI/NRR-1284 L Page 7 of 13 As described above in items 4 and 7, this Technical Specification Change Request proposes to add a Specification 4.0.4 exception for the SRM functions in the Control Rod Block and Source Range Monitor Instrumentation Specification's.
The SRM system consists of four detectors, one in each quadrant of the reactor core. As described in Technical Specification Bases 3/4.3.7.6 the SRMs provide neutron flux monitoring capability during reactor startup and lov flux level operations. Per Technical Specification 3/4.3.7.6 the SRMs are required to be operable in Operational Conditions 3 and 4 and in Operational Condition 2* (Operational Condition 2 vith the IRMs on range 2 or below). Per Technical Specification 3/4.3.6, Table 4.3.6-1, the SRM Detector-not-full-in, Upscale, Inoperative and Downscale control rod block functions are currently required to be operable in Operational condition 2** (Operational condition 2 with IRMs on range 2 or below), and in Operational Condition 5.
Similar to the IRH control rod block function discussed above, the S withdrawnfromthecoreandarebypassedwhentheplantisatpower.gM'sare            Since the SRH's are automatically bypassed and the detectors are fully withdrawn to prolong their life, the surveillances for the SRMs are prevented from being maintained current during extended operation in Operrtional Condition 1.
Therefore, it is proposed to add a statement of exception to the provisions of Technical Specification 4.0.4 for the SRMs to formally allov either the reactor mode switch to be placed in the Shutdovn (0p Con 3) position (manual scram), or a controlled plant shutdown to be performed, by permitting entry into Operational Condition 2 (with the IRH's on Range 2 or below), Op Con 3 or Op Con 4. Without the applicable SRM surveillances being current due to extended operation in Operational Condition 1. Additionally, it is proposed that a limit be placed on this exception to require tnese surveillances to be performed on the SRMs within 12 hours after entering their applicable Operational Conditions.
i 1 As identified by note (a) of Technical Specification Table 3.3.6-1, the SRM Detector-not-full-in control rod block function is automatically bypassed if the detector count rate is greater than 100 counts per second (eps) or the IRM channels are on range 3 or higher; as identified by note (b) of Table 3.3.6-1, the SRM Upscale and Inoperative control rod block functions are automatically l      bypassed when the IRM channels are on range 8 or higher; and as identified by
!      note (c) of Table 3.3.6-1, the SRM Downscale control rod block function is automatically bypassed when the IRH channels are on range 3 or higher.
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  .                                                                                                1 Attachment 1.
PY-CEI/NRR-1284 L Page 8 of 13 The proposed exceptions-to Specification 4.0.4, together with the proposed 12    j hour time limit, vill provide adequate time for reactor power to be reduced sufficiently.to allov the SRMs-to be fully inserted, unbypassed, and the surveillances comp]sted. The 4.0.4 exception would apply only during reactor shutdowns and not to reactor startups. Similar to the IRM control rod block functions discussed above, the SRM control rod block functions are provided only to ensure that adequate neutron monitoring capability exists during control rod movements and no credit is taken in PNPP's USAR Chapter 15 safety analyses for-their function.      Also, similar to the IRH's above, the SRH's are not necessarily incapable of functioning just because the surveillances are overdue. The channel ; heck, which can be quickly performed on the SRM            i channels prior to perfo.mance of the functionals/ calibrations, provides some    ;
confidence that the SRM's are iunct10nel. During Operational Condition _3 and 4, the control rods vould already be ially inserted and the Keactor Mode Switch-Shutdown Mode function provides a control rod block to prevent control rod withdrawal.
As described in item 3 above, the Technicel Specification change request also proposes to add an exception to the provisions of Technical Specification 4.0.4 for the APRM Flov-Biased Simulated Thermal Pover-High and Neutron Flux-High functions of the RPS [ Technical Specification Table 4.3.1.1-1, note (d)). This proposed exception vill be applicable to the APRM gain adjustment only during plant startups.
Per Technical Specification 3/4.3.1, Table 4.3.1.1-1, the APRM Flow-Biased Simulated Thermal Pover-High and Neutron Flux-High RPS functions are only required to be operable in Operational Condition 1. One of the surveillances required to demonstrate operability of these APRM functions is the adjustment i                  of the APRM gains such that the APRMs conform to the reactor power values calculated by a heat balance during Operational Condition 1 when reactor power is > 25% of-RATED THERMAL POVER. At low reactor power levels.-heat balance calculations.are susceptible to inaccuracies due to lov values of feedvater flov and various feedvater heater configurations.      As.a result,'the current surveillance provides an allowance-to delay the APRM gain adjustments until reactor p'ver is > 25% of RATED THERHAL POVER.      However, since= Technical Specific t ton 4.074 prohibits mode changes unless all. surveillance requirer ..s have been performed vithin the applicabic surveillance intervals,-
this sus elllance should be clarified to clearly state that Operational Condition 1 may be entered prior to performing'this surveillance. Therefore, it.is proposed to incorporate a statement of exception to Technical Specification 4.0.4 to. formal]r provide the allowance to enter Operational Condition 1. . Additionally, it.is proposed to require the APRM gains to be adjusted within 12 hours after reaching 25% of RATED THERMAL POVER (whereas
                  - there is no current time limit).
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Attachment 1 PY-CEI/NRR-1204 L Page 9 of 13 Please note that the changes proposed in items 1, 3, 4 and 7 of the above Summary are consistent with the solution suggested by the NRC staff in Generic Litter (GL) 87-09 for similar conflicts. In GL 87-09, the NRC staff recognized that conf'icts could arise when Surveillance Requirements can only be cv.?pleted after ei. cry into a mode or specified condition for which the Surveillanct Requirements apply (the very situation addressed above). In addition, the NPC staff recognized that a second conflict could arise because, upon entry into the applicable mode or condition, the requirements of Specification 4.0.3 w v not be met because the Surveillance Requiremt ts may not have been perfornel within the allovable surveillance interval (again, the very situation addressed above). In such cases, the staff recognized that an exception to Specification 4.0.4 vould be appropriate. According to the Generic Letter, the e.tception to Specification 4.0.4, in conjunction with the changes recommended in GL 87-09 for Specification 4.0.3 (i.e. , the delay of up to 24 houro in Specification 4.0.3 for the applicability of Action Requirements) would provide an appropriate time limit for the completion of those Su:veillance Requirements that become applicable as a consequence of allovance of any exception to Specification 4.0.4.
Although the changes recommended by GL 87-09 for Specification 4.0.3 vere granted for PNPP Technical Specifications by Amendment 30, dated May 24, 1990, it is not clear that PNPP is able to implement the above solution proposed by GL 87-09 because of the current lack of a specification 4.0.4 exception to t; i IRM and SRM Channel Functional Test and Channel Calibration Surveillance Requirements, and for the APRM Channel Calibration requirement (gain adjustment).
Note also, that although approval of Specification 4.0.4 exceptions in conjunction with Specification 4.0.3 (as currently amended per GL 87-09) would provide an appropriate solution, a specific 12-hour time limit is being pror 'ed for each Specification 4.0.4 exception (rather than the 24 hour time lim ' provided by the Generic Letter) solely to maintain consistency with the Bk:-6 Technical Specification Improvement Program and with similar Amendment Requests proposed by other BVR-6 licensees (reference proposed operating license amendment by Illinois Power for the Clinton Power Station dated August 31, 1990). Due to the safety benefits and scram avoidance aspects that the proposed changes provide, it is appropriate to process these changes and have them approved by the NRC in advance of the Technical Specification Improvement
      -effort. It is requested that this change package be issued prior to our next scheduled manual shutdown for the third refueling outage, currently slated for February 28, 1992.
Clarification of Startup Surveillence Requirements (items 2 and 6)
The current PNPP Technical Specification 3/4.3.1, Table 4.3.1.1-1, Note (c),
requires a Channel Fenetional Test of the APRM Neutron Flux-High, Setdovn and IRH Neutron Flux-High functions to be performed within 24 hours prior to startup, if not performed within the previous seven days. Additionally, Technical Specification 3/4.3.7.6.b.1 requires a Channel Functional Test of the SRMs to be performed within 24 hours prior to moving the reactor mode switch from the Shutdown position, if not performed within the previous seven days.
 
Attachment 1 PY-CEI/NRR-1284 L 3                            ,                                                                      Page 10 of 13 This. Technical Specification Change Request proposes to delete the apparent.
requirement to perform the above described Channel Functional Test within 24 hours prior to startup. The requirement to perform these tests within seven days prior to startup would be retained. The current wording is cons 4.dered
,                                  potentially confusing and the proposed changes are provided for clarification.
The existing wording of the "24-hour" portion of these items vould appear to require anticipation of the exact time of a startup (or mode svitch position change) so as to implement that part of the current note.- This is not always-possible, since plant startup (or the change in mode switch position) could be-delayed for more than 24 hours after test completion. As long as the delay after test completion is less than seven days, the surveillance frequency has still been satisfied even though more than 24 hours have passed. As can be seen, the 24-hour clause serves no useful purpose. Incorporation of the proposed changes vould prevent confusion while providing-the same degree of confidence that the associated instrumentation is operable.
Additionally, the "S/U" annotation associated with Table 4.3.1.1-1, note (c),
for these surveillances that are performed at least once per seven days is not needed and should be deleted. Since-Technical Specification 4.0.4 prohibits entry into an Operational Condition unless the Surveillance Requirement (s) associated with the_ Technical Specification has been performed within the applicable suru 111ance interval, the "S/U" annotation is redundant to the "V" requirement to perform the Channel Functional Test at least once per seven days. Therefore, it is proposed to delete the "S/U" annotation for the above IR:1 and APRM Channel Functional Tests. These proposed changes are considered justified since they vill make the Technical Specifications easier to implement with no reduction in the effectiveness of ensuring the operability of-these functions.
Revision of SRM Control Rod Block Channel Calibration Frequency (item 5)
Technical Specifications 3/4.3.7.5 (Accident Monitoring Instrumentation) and 3/4.3.7.6 (Source Range Monitors) currently require the SRMs to be calibrated at least once per 18 months. -However, Technical Specification 3/4.3.6 currently requires the SRH Upscale and Downscale control rod block functions to be calibrated at least once per 184 days ("SA"). This proposed change seeks to make the calibration requirements for the SRHs consistent throughout these Technical Specifications by changing the SRM Channel-Calibration Surveillance frequency for-Control Rod Block Instrumentation (Table 4.3.6-1)  -
from at least once per 184 days ("SA") to at least once per 18 months _("R").
There is no significant difference between the instrumentation used for the accident moattoring function (Spec 3/4.3.7.5) and the source range monitoring function (3/4.3.7.6) versus that used for the control rod block trips (3/4.3.6) since, at the channel level, the instrumentation is the same.
Accordingly, there is no specific design basis that requires these trip channels to be calibrated more often for-the control rod block function than for.the accident monitoring / source range monitoring function. (From a drift allowance standpoint, the' difference between the trip setpoint and the
                                -allowable value is the same (2/125 of scale) for all these functions). Also, no credit is taken for these SRM control rod blocks in any of PNPP's Chapter
                        . _ _                        _ __ _                  _ ~ - . . _ . . . _ _                  _
 
    - ~.-.-.-.-. - _ - . - . - - - - . - -                                                                - . - . - . . - --
Attachment 1 PY-CEI/NP.R-1284 L
* Page 11 of 13 15 design basis analyses. PNPP procedures which control performance of the weekly Channel Functional testing of these SRM functions currently require verification of proper channel operation and include verification of the control rod block upscale and downscale trip setpoints for these functions.
This setpoint verification vill be added to the Technical Specifications as a requirement in the weekly SRM Channel Functional Test contained in Table 4.3.6-1, consistent with similar changes approved for the IRH Channel Functional Tests by Amendment 31. As with all other Technical Specification surveillances, a calibration of the Rod Block Channel vould be required if any
                      - of these setpoint verifications are found outside the allowable values given in the Technical Specifications. As a result, there is adequate assurance that requiring the Channel Calibrations to be performed on an 18-month frequency is adequate to ensure that control rod blocks vill be initiated when intended.
Additionally, the SRM Channel Calibrations cannot be maintained current during extended operation in Operational Condition 1 since the definition of CHANNEL CALIBRATION requires the performance of a Channel Functional Test. As previously stated, Channel Functional Testing of the SRMs cannot be performed while in Operational Condition 1 because-the trips from these instruments are bypassed-with the reactor mode switch in the Run position. The proposed changes vill resolve this conflict by changing this calibration frequency to 18 months. This frequency is consistent with the current operating cycles of PNPP, and therefote, this proposed frequency vill allow the Channel Calibration surveillances to remain current throughout an operating cycle.
Significant Hazards Consideration The standards used to arrive at a determination that a request for amendment involves no significant hazards considerations are included in the Commission's Regulations, 10CFR50.92, which state that the operation of the facility in accordance with the proposed amendment vould not (1) involve a-significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any.previously evaluated, or (3) involve a significant reduction in a margin of safety.
CEI has reviewed the proposed amendment with respect to these three factors and has determined that the proposed changes do not involve a significant hazard because (1) The proposed changes do not involve a significant increase in the 4                                          probability or consequences of a' accident previously evaluated. The proposed changes do not involve a physical change or addition to any plant component or system which could cause the probability of an accident to increase. _The proposed' changes do not result in any change to the plant design or-its operating modes. Therefore, these
                                          . proposed changes cannot increase the probability of any accident previously evaluated.
 
Attachment 1 pY-CEI/NRR-1284 L Page 12 of 13 l
The proposed addition of Surveillance Requirements 4.3.1.4 and 4.3.6.2, together with the incorporation of the proposed additional text for Surveillance Requirements 4.3.7.6.a and 4.3.7.6.b, provide for performance of the associated IRH and SRM surveillances during plant shutdowns following extended operation in Operational Condition 1. These surveillances cannot be performed with the unit in Operational Condition 1. The proposed changes merely provide the formal means to avoid violation of Technical Specification 4.0.4 and provide adequate time to perform these surveillances without causing the possibility of unnecessary plant scrams, challenges to safety systems, and unnecessary procedural complications / stress on plant personnel while completing these surveillances under the provisions of Action Statements. The 12-hour time allowance fot performance of the IRH Channel Functional Test and Channel Calibration Surveillances after entering lover modes of operation from Operational Condition 1 vill help avoid unnecessary scrams during controlled plant shutdowns and/or mode changes by significantly reducing (and in most cases eliminating) the time that the half scram signal is inserted into the RPS logic after entry into lover modes of operation and would eliminate unnecessary manipulations of plant equipment in order to perform the IRH Surveillances at the same time that a portion of the RPS system is in the tripped position. Adequate scram protection and neutron monitoring capability are provided by the APRMs during the short time period needed to perform these surveillances. Upon entry into Operational Conditions 3 or 4, the control rod block provided by the mode switch provides adequate protection pending surveillance completion.
The proposed change to provide a formal Specification 4.0.4 exception to allov entry into Operational Condition 1 before the APRH gain surveillance has been performed provides adequate time for plant conditions to be achieved that vill result in an accurate heat balance calculation. The APRM Flow-Biased Simulated Thermal Power-High function still provides adequate scram protection during the short time period needed to achieve 25% of RATED THERHAL POWER and perform these APRM gain adjustments after entering Operational condition 1.
The proposed deletion of the 24-hour clause and the "S/U" notation from the Channel Functional Test requirement for the neutron monitors eliminates the possible confusion caused by the current wording without reducing the effectiveness of these surveillances.
The Technical Specifications, when revised as proposed, vill continue to require, as they currently do, that these Channel Functional Tests be performed within seven days prior to entering the conditions for which these instruments are required.
 
Attachmsnt 1
                        .                                                                PY-CEI/NRR-1284 L Page 13 of 13 The proposed change to the Channel Calibration frequency for the SRM control rod block functions vill not result in any significant
                                      -hange-in the availability of this rod block function, and it is consistent with the current channel calibration frequency requirement for ensuring that source range neutron monitoring capability is available to the operators during control rod movements at low power conditions, and/or post-accident conditions.
No clodit is taken for the SRM control rod block function in PNPP's USAR Chapter 15 safety analyses, and since the setpoint is checked during each shutdovn in which an applicable Operational Condition for SRMs is entered, they-vill be fully functional for any subsequent startup.
Based upon the above, these proposed changes cannot increase the probability or the consequences of any accident previously evaluated.
1 (2) The proposed changes do not create the possibility of a new or                            ;
different kind of accident from any accident previously evaluated                  l because the proposed change does not involve a change in the design of any plant system or component nor does it involve a change in the operation of any plant system or component. As a result, no new failure modes are introduced.
(3) The proposed changes do not result in a significant reduction in the margin of safety, because'as discussed in (1) above, the proposed changes still provide adequate assurance that each of the applicable safety functions are capable of being effected when required, including reactor scram protection, control rod block, and neutron monitoring.
Based upon.the above considerations, CEI concludes that these proposed changes do not involve significant hazards considerations.
Environmental Consideration The Cleveland Electric Illuminating l Company has reviewed the proposed
                -Technical Specification change against_the criteria of 10CFR51.22 for environmental considerations. As shovn-above,-the proposed change does not-H                involve a significant hazards consideration, nor increase'the types and l                amounts of effluents that may be released offsite,-nor significantly increase
;                individual.or cumulative occupational radiation exposures.- Based.on the foregoing, CEI concludes that the proposed Technical Specification change meets _the criteria given in 10CFR51.22(c)(9)-for a categorical exclusion from-
_the requirement for an Environmental Impact Statement.
NJC/ CODED /4329
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