ML070580492

Perry, Unit 1, License Amendment, Issuance of Amendment Revise TS to Change the Frequency of the Mode 5 Intermediate Range Monitoring Instrumentation Channel Functional Test

ML070580492
Person / Time
Site:	Perry
Issue date:	04/27/2007
From:	Wengert T J NRC/NRR/ADRO/DORL/LPLIII-2
To:	Pearce L W FirstEnergy Nuclear Operating Co
Wengert, Thomas
Shared Package
ML070580506	List: ML070580492 ML071210291
References
TAC MD0144
Download: ML070580492 (18)

Text

April 27, 2007Mr. L. W. PearceSite Vice President FirstEnergy Nuclear Operating Company Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - ISSUANCE OFAMENDMENT RE: REVISE TECHNICAL SPECIFICATIONS TO CHANGE THE FREQUENCY OF THE MODE 5 INTERMEDIATE RANGE MONITORING INSTRUMENTATION CHANNEL FUNCTIONAL TEST (TAC NO. MD0144)

Dear Mr. Pearce:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosedAmendment No.141 to Facility Operating License No. NPF-58 for the Perry Nuclear Power Plant, Unit No. 1. This amendment revises the Technical Specifications (TSs) in response to your application dated February 14, 2006, as supplemented by letters dated October 17, 2006, and February 8, 2007.This amendment revises Perry Nuclear Power Plant, Unit No. 1 TS, to change the frequency ofthe Mode 5 Intermediate Range Monitoring Instrumentation CHANNEL FUNCTIONAL TEST contained in TS 3.3.1.1, from 7 days to 31 days. A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in theCommission's next biweekly Federal Register notice.Sincerely,/RA/Thomas J. Wengert, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-440

Enclosures:

1. Amendment No. 141 to NPF-58 2. Safety Evaluationcc w/encls: See next page April 27, 2007Mr. L. W. Pearce Site Vice President FirstEnergy Nuclear Operating Company P.O. Box 97, A290 10 Center Road Perry, Ohio 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - ISSUANCE OFAMENDMENT RE: REVISE TECHNICAL SPECIFICATIONS TO CHANGE THE FREQUENCY OF THE MODE 5 INTERMEDIATE RANGE MONITORING INSTRUMENTATION CHANNEL FUNCTIONAL TEST (TAC NO. MD0144)

Dear Mr. Pearce:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosedAmendment No. 141 to Facility Operating License No. NPF-58 for the Perry Nuclear Power Plant, Unit No. 1. This amendment revises the Technical Specifications (TSs) in response to your application dated February 14, 2006, as supplemented by letters dated October 17, 2006, and February 8, 2007.This amendment revises Perry Nuclear Power Plant, Unit No. 1 TS, to change the frequency ofthe Mode 5 Intermediate Range Monitoring Instrumentation CHANNEL FUNCTIONAL TEST contained in TS 3.3.1.1, from 7 days to 31 days. A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in theCommission's next biweekly Federal Register notice.Sincerely,/RA/Thomas J. Wengert, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-440

Enclosures:

1. Amendment No. 141 to NPF-58 2. Safety EvaluationDISTRIBUTION

PUBLICLPL3-2 R/FRidsNrrPMTWengertRidsNrrDirsItsb RidsOgcRpRidsNrrLAEWhittRidsRgn3MailCenterRidsNrrDorlLpl3-2 RidsAcrsAcnwMailCenterRidsNrrDorlDprGHill (2)

RidsNrrDeEicbHGarg, NRRRidsNrrDssSbwbPackage Accession Number: ML070580506Amendment Accession Number: ML070580492 TS Accession Number: ML071210291*- with edits**- NLO with editsNRR-058OFFICELPL3-2/PMLPL3-2/LAITSB/BCSRXB/BC (A)EICB/BCOGCLPL3-2/BCNAMETWengert:mwEWhittTKobetz*SMirandaAHoweJBiggins**RGibbsDATE4 27/07 4/27/07 4/10/07 4/6/07 4/3/07 4/19/07 4/27/07OFFICIAL RECORD COPY Perry Nuclear Power Plant, Unit No. 1 cc:David W. Jenkins, AttorneyFirstEnergy CorporationMail Stop A-GO-1876 South Main StreetAkron, OH 44308Resident Inspector's OfficeU.S. Nuclear Regulatory CommissionP.O. Box 331Perry, OH 44081-0331Regional Administrator, Region IIIU.S. Nuclear Regulatory CommissionSuite 2102443 Warrenville RoadLisle, IL 60532-4531Sue HiattOCRE Interim Representative8275 MunsonMentor, OH 44060Manager, Site Regulatory ComplianceFirstEnergy Nuclear Operating CompanyPerry Nuclear Power PlantMail Stop A-PY-A210P.O. Box 97, 10 Center RoadPerry, OH 44081-0097Mayor, Village of North PerryNorth Perry Village Hall4449 Lockwood RoadNorth Perry Village, OH 44081Donna Owens, DirectorOhio Department of CommerceDivision of Industrial ComplianceBureau of Operations & Maintenance6606 Tussing RoadP.O. Box 4009Reynoldsburg, OH 43068-9009Carol O'Claire, Chief, Radiological BranchOhio Emergency Management Agency2855 West Dublin Granville RoadColumbus, OH 43235-7150Mayor, Village of PerryP.O. Box 100Perry, OH 44081-0100 Dennis ClumRadiological Assistance Section SupervisorBureau of Radiation ProtectionOhio Department of HealthP.O. Box 118Columbus, OH 43266-0118Zack A. Clayton DERROhio Environmental Protection AgencyATTN: Mr. Zack A. ClaytonP.O. Box 1049Columbus, OH 43266-0149ChairmanPerry Township Board of Trustees3750 Center Road, Box 65Perry, OH 44081Daniel Z. FisherTransportation DepartmentPublic Utilities Commission180 East Broad StreetColumbus, OH 43215-3793 James H. LashSenior Vice President of Operations and Chief Operating OfficerFirstEnergy Nuclear Operating CompanyMail Stop A-GO-1476 South Main StreetAkron, OH 44308Director, Fleet Regulatory AffairsFirstEnergy Nuclear Operating CompanyMail Stop A-GO-276 South Main StreetAkron, OH 44308Joseph J. HaganPresident and Chief Nuclear OfficerFirstEnergy Nuclear Operating CompanyMail Stop A-GO-1976 South Main StreetAkron, OH 44308 Perry Nuclear Power Plant, Unit No. 1 cc:

Danny L. Pace Senior Vice President, Fleet EngineeringFirstEnergy Nuclear Operating CompanyMail Stop A-GO-1476 South Main StreetAkron, OH 44308Jeannie M. RinckelVice President, Fleet OversightFirstEnergy Nuclear Operating CompanyMail Stop A-GO-1476 South Main StreetAkron, OH 44308Manager, Fleet LicensingFirstEnergy Nuclear Operating CompanyMail Stop A-GO-276 South Main StreetAkron, OH 44308Richard AndersonVice President, Nuclear SupportFirstEnergy Nuclear Operating CompanyMail Stop A-GO-1476 South Main StreetAkron, OH 44308 FIRSTENERGY NUCLEAR OPERATING COMPANYFIRSTENERGY NUCLEAR GENERATION CORP.OHIO EDISON COMPANYDOCKET NO. 50-440PERRY NUCLEAR POWER PLANT, UNIT NO. 1AMENDMENT TO FACILITY OPERATING LICENSEAmendment No.141License No. NPF-581.The U.S. Nuclear Regulatory Commission (the Commission) has found that:A.The application for license filed by FirstEnergy Nuclear Operating Company,et al., (the licensee) dated February 14, 2006, as supplemented by letters datedOctober 17, 2006, and February 8, 2007, complies with the standards andrequirements of the Atomic Energy Act of 1954, as amended (the Act), and theCommission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of thepublic, and (ii) that such activities will be conducted in compliance with theCommission's regulations;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment, and paragraph 2.C.(2) of FacilityOperating License No. NPF-58 is hereby amended to read as follows: (2)Technical SpecificationsThe Technical Specifications contained in Appendix A and the EnvironmentalProtection Plan contained in Appendix B, as revised through Amendment No. 141 are hereby incorporated into this license. FENOC shall operate thefacility in accordance with the Technical Specifications and the EnvironmentalProtection Plan.3.This license amendment is effective as of its date of its issuance and shall beimplemented within 90 days of the date of issuance.FOR THE NUCLEAR REGULATORY COMMISSION/RA/Russell A. Gibbs, ChiefPlant Licensing Branch III-2Division of Operating Reactor LicensingOffice of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating LicenseDate of Issuance: April 27, 2007 ATTACHMENT TO LICENSE AMENDMENT NO. 141 FACILITY OPERATING LICENSE NO. NPF-58DOCKET NO. 50-440Replace the following pages of the Facility Operating License and Appendix A TechnicalSpecifications with the attached revised pages. The revised pages are identified byamendment number and contain marginal lines indicating the areas of change. Remove InsertLicense Page 4License Page 43.3-63.3-63.3-73.3-7 renewal. Such sale and leaseback transactions are subject to the representationsand conditions set forth in the above mentioned application of January 23, 1987,as supplemented on March 3, 1987, as well as the letter of the Director of theOffice of Nuclear Reactor Regulation dated March 16, 1987, consenting to suchtransactions. Specifically, a lessor and anyone else who may acquire an interestunder these transactions are prohibited from exercising directly or indirectly anycontrol over the licenses of PNPP Unit 1. For purposes of this condition thelimitations of 10 CFR 50.81, as now in effect and as may be subsequentlyamended, are fully applicable to the lessor and any successor in interest to thatlessor as long as the license for PNPP Unit 1 remains in effect; these financialtransactions shall have no effect on the license for the Perry Nuclear facilitythroughout the term of the license. (b)Further, the licensees are also required to notify the NRC in writing prior to anychange in: (i) the terms or conditions of any lease agreements executed as part ofthese transactions; (ii) the PNPP Operating Agreement; (iii) the existing propertyinsurance coverage for PNPP Unit 1; and (iv) any action by a lessor or others thatmay have an adverse effect on the safe operation of the facility.C.This license shall be deemed to contain and is subject to the conditions specified inthe Commission's regulations set forth in 10 CFR Chapter I and is subject to allapplicable provisions of the Act and to the rules, regulations, and orders of theCommission now and hereafter in effect; and is subject to the additional conditionsspecified or incorporated below:(1)Maximum Power LevelFENOC is authorized to operate the facility at reactor core power levels not inexcess of 3758 megawatts thermal (100% power) in accordance with the conditionsspecified herein.(2)Technical SpecificationsThe Technical Specifications contained in Appendix A and the EnvironmentalProtection Plan contained in Appendix B, as revised through Amendment No. 141,are hereby incorporated into the license. FENOC shall operate the facility inaccordance with the Technical Specifications and the Environmental Protection Plan.(3)Antitrust Conditionsa. FirstEnergy Nuclear Generation Corp. and Ohio Edison CompanyAmendment No. 141 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 141 TO FACILITY OPERATING LICENSE NO. NPF-58FIRSTENERGY NUCLEAR OPERATING COMPANYFIRSTENERGY NUCLEAR GENERATION CORP.OHIO EDISON COMPANYPERRY NUCLEAR POWER PLANT, UNIT NO. 1DOCKET NO. 50-44

01.0 INTRODUCTION

By letter to the Nuclear Regulatory Commission (NRC, the Commission) dated February 14,2006 (Agencywide Documents Access and Management System (ADAMS) AccessionNo. ML060540393) as supplemented by letters dated October 17, 2006 (ADAMS AccessionNo. ML062970446) and February 8, 2007 (ADAMS Accession No. ML070470263), FirstEnergyNuclear Operating Company, et al. (FENOC, the licensee) requested changes to the technicalspecifications (TSs) for the Perry Nuclear Power Plant, Unit No. 1 (PNPP). The October 17,2006, and February 8, 2007, supplements contained clarifying information and did not changethe NRC staff's initial proposed finding of no significant hazards consideration. The proposedchanges would revise the frequency of the Mode 5 Intermediate Range Monitoring (IRM)Instrumentation CHANNEL FUNCTIONAL TEST from 7 days to 31 days. Specifically, theproposed changes would modify:1.1TS 3.3.1.1, "Reactor Protection System (RPS) Instrumentation"A new Surveillance Requirement (SR) has been added, SR 3.3.1.1.19, requiring the channelfunctional test to be performed every 31 days.1.2TS Table 3.3.1.1-1 (page 1 of 3), "Reactor Protection System Instrumentation"The SR for functions 1a and 1b have been changed from SR 3.3.1.1.5 to SR 3.3.1.1.19, whicheffectively increases the surveillance test interval for the Mode 5 channel functional test from 7days to 31 days.

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR), Paragraph 50.36(c)(3), "SurveillanceRequirements," defines SRs as requirements relating to test, calibration, or inspection to assurethat the necessary quality of systems and components is maintained, that facility operation willbe within safety limits, and that the limiting conditions for operation will be met. Also, 10 CFRPart 50, Appendix A, General Design Criterion 21, "Protection system reliability and testability,"requires in part that the protection system be designed for high functional reliability andinservice testability such that

?(1) no single failure results in loss of protection function, and(2) removal from service of any component or channel does not result in loss of the requiredminimum redundancy unless the acceptable reliability of operation of the protection system canbe otherwise demonstrated." The licensee's evaluation was based on an analysis of instrument component drift performancewith reference to Generic Letter (GL) 91-04, "Changes in Technical Specification SurveillanceIntervals to Accommodate a 24-Month Fuel Cycle," and not on a component reliability analysisas in previous channel functional test evaluations. The licensee's amendment request wasbased on a traditional engineering analysis instead of the guidance in Regulatory Guide (RG)1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-informed Decisions onPlant-Specific Changes to the Licensing Basis," and RG 1.177, "An Approach for Plant-SpecificRisk Informed Decision Making: Technical Specifications."

3.0 TECHNICAL EVALUATION

3.1BackgroundThe primary purpose of the surveillance testing is to assure that the components in a standbysystem (safety system) will be operable when needed. The risk contribution associated with thesurveillance test interval (STI) is mainly due to the possibility that the component will fail betweenconsecutive tests. Testing these components detects failures that may have occurred since thelast surveillance, thus limiting the risk due to undetected failures. However, increasing the timebetween surveillance tests may also have some benefits. Increased STIs may reduce test-induced transients, test-caused failures, equipment wear, and reduce resource requirements fortesting. The disadvantage is that the time that a component will be subject to failure (the faultexposure time) increases with an increased STI. Previous generic studies, including NEDC-30851P-A, "Technical Specification ImprovementAnalysis for BWR Reactor Protection System," evaluated the relaxation of STIs for boiling waterreactor (BWR) reactor protection system (RPS) instrumentation, including analog transmitter tripunits and channel-functional-test-related instrumentation. The current 3-month surveillanceinterval for channel functional testing is based on topical reports submitted by General ElectricCo. (GE), of which NEDC-30851P-A is representative. These reports presented an approachusing reliability analysis to identify improvements in testing intervals and allowable outage times(AOTs) for the RPS and related instrumentation. As part of the NEDC-30851P-A evaluation,sensitivity studies were performed on RPS trip system fault trees. GE found that for eachinitiating event the RPS unavailability was relatively insensitive to the change in componentfailure rates. The impact on RPS failure frequency was also found to be negligible. In the safety evaluation reports (SERs) for NEDC-30851P-A dated July 15, 1987, andJanuary 24, 1988, the NRC staff also concluded that uncertainties in component failure rates do not significantly affect RPS unavailability. The NRC staff also concluded that the estimatedincrease in RPS's unavailability due to the proposed TS changes would not result in a significantnet change in the core damage frequency. Therefore, the NRC staff found a quarterly functionaltest interval to be acceptable. However, the RPS IRM functions were not explicitly modeled inNEDC-30851P-A. Consequently, NEDC-30851P-A did not propose changes to the existingfunctional test frequency of the RPS IRM function. 3.2Evaluation of TS Changes to Test FrequencyThe licensee evaluated the proposed TS changes in accordance with the guidance provided inGL 91-04. In accordance with GL 91-04, the licensee should provide the following information,to provide an acceptable basis for increasing the calibration interval for instruments that areused to perform safety functions: (1)Confirm that instrument drift as determined by as-found and as-left calibration datafrom surveillance and maintenance records has not, except on rare occasions,exceeded acceptable limits for a calibration interval.(2)Confirm that the values of drift for each instrument types (make, model, and range)and applications have been determined with a high probability and a high degree ofconfidence. Provide a summary of the methodology and assumptions used todetermine the rate of instrument drift with time based upon historical plant calibrationdata.(3)Confirm that the magnitude of instrument drift has been determined with a highprobability and a high degree of confidence for a bounding calibration interval of30 months for each instrument type (make, model number, and range) andapplication that performs a safety function. Provide a list of the channels by TSsection that identifies these instrument applications.(4) Confirm that a comparison of the projected instrument drift errors has been madewith the values of drift used in the setpoint analysis. If this results in revised setpointsto accommodate larger drift errors, provide the proposed TS changes to update tripsetpoints. If the drift errors result in a revised safety analysis to support existingsetpoints, provide a summary of the updated analysis conclusions to confirm thatsafety limits and safety analysis assumptions are not exceeded.(5)Confirm that the projected instrument errors caused by drift are acceptable for controlof plant parameters to effect a safe shutdown with the associated instrumentation.(6)Confirm that all conditions and assumptions of the setpoint and safety analyses havebeen checked and are appropriately reflected in the acceptance criteria of plantsurveillance procedures for channel checks, channel functional tests, and channelcalibrations.(7)Provide a summary description of the program for monitoring and assessing theeffects of increased calibration surveillance intervals of instrument drift and its effecton safety.The licensee has performed a safety assessment of the proposed changes to the STI inaccordance with the GL 91-04 guidance given above. This assessment entailed reviewing thehistorical maintenance and surveillance test data at the bounding STI limit, performing anevaluation to ensure that a 31-day interval for the functional test would not invalidate anyassumptions in the plant licensing basis and the determination that the effect of the STIextension is small. The licensee performed analysis of the drift for IRM instrumentation anddetermined that the drift is less than the value assumed in the PNPP calculation. Therefore,there was no change to the plant surveillance procedures. Also, the licensee did not requestany TS changes associated with instrument setpoints or allowable values in this amendmentrequest. Therefore, the NRC staff has not reviewed the instrument setpoint methodology for PNPP in this safety evaluation.As discussed above, STI extension requests are usually risk-informed, performance-basedsubmittals. However, the IRMs are used only during startup/shutdown and refueling mode and,therefore, are not included in the risk model. On that basis, the NRC staff agreed to review thelicensee's engineering analysis to demonstrate that the failure of IRMs will not be safetysignificant. The NRC staff was concerned with the number of failures identified in the licensee's submittal and, consequently, requested the licensee to justify these failures. The licensee, intheir letter of October 17, 2006, identified that there were 21 component failures in addition to 13S4 switch failures.The licensee further stated that an S4 switch failure does not affect the operability of the IRMfunction, since the S4 switch is used only during testing. During a conference call on December 6, 2006, the NRC staff asked the licensee to separate these failures and identify onlythose failures identified by the Mode 5 surveillance testing. The licensee, during the conferencecall of December 6, 2006, informed the NRC staff that only 4 failures were associated with Mode5 channel functional tests. The NRC staff requested the licensee to justify these failures with 95 percent statisticalconfidence that the failures of an IRM will not result in the loss of the functional requirements ofthe system. The licensee, by letter dated February 8, 2007, informed the NRC staff that astatistical analysis using a Poisson distribution was performed, and that the analysis indicatedthat there is greater than 95 percent confidence that the probability of experiencing no more thenone failure per 31 days (proposed surveillance test interval) is 95 percent. The licensee hasfurther determined that, with only one channel failure, the required number of IRM channels forboth trip systems will be available and therefore, the IRM function will be operable, butdegraded.The licensee has also identified that in the unlikely event that an IRM high-flux trip function losestrip capability in such a manner as to be undetectable, the average power range monitor (APRM)high flux (setdown) trip function is redundant to the IRM high flux trip. Also, TS Section 3.3.1.1,SR 3.3.1.1.6 requires that source range monitors (SRMs) and IRMs be determined to overlapduring each startup and SR 3.3.1.1.7 requires that IRMs and APRMs be determined to overlapduring each controlled shutdown. Therefore, inoperable IRMs will be detected before neutronflux exceeds the range of the SRMs and before a controlled shutdown by the APRMs. Based onthis, the risk in Mode 2 is minimal.In Mode 5, the IRMs provide core neutron monitoring and protection against an unexpectedreactivity excursion which could be caused by a control rod removal or withdrawal. The PNPPUpdated Safety Analysis Report (USAR) Section 15.4.1.1, "Control Rod Removal Error DuringRefueling", describes that, through plant design features (control rod blocks and refuelinginterlocks) and procedural controls, the event is prevented. The USAR section indicates thatmultiple failures are needed in order for the reactivity excursion to occur. The probability of thiscombined with an IRM failure is considered unlikely.Based on the above discussion, the licensee has demonstrated that the PNPP IRMs haveoperated reliably and, in the event of IRM failures, backups are available to the operator to takenecessary corrective actions. Failure of IRMs have not been shown to result in any increase insafety significance. On the basis of its review, the NRC staff concludes that the proposed methodologies to extendsurveillance intervals for certain safety-related instrumentation components are consistent withthe guidance in GL 91-04. Specifically, the licensee has demonstrated that the effect ofextending the STI to 31 days for channel functional testing of IRM instrumentation in Mode 5 is negligible, and the system will continue to perform within assumed limits during the longer STI. Therefore, the NRC staff finds that the STI extension for channel functional testing isacceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Ohio State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

This amendment changes a surveillance requirement with respect to use of a facility componentlocated within the restricted area as defined in 10 CFR Part 20. The NRC staff has determinedthat the amendment involves no significant increase in the amounts, and no significant change inthe types, of any effluent that may be released offsite and that there is no significant increase inindividual or cumulative occupational radiation exposure. The Commission has previouslyissued a proposed finding that this amendment involves no significant hazards consideration andthere has been no public comment on such finding (71 FR 15484; March 28, 2006). Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement orenvironmental assessment need be prepared in connection with the issuance of thisamendment.

6.0 CONCLUSION

The NRC staff has concluded, based on the considerations discussed above, that: (1) there isreasonable assurance that the health and safety of the public will not be endangered byoperation in the proposed manner, (2) such activities will be conducted in compliance with theCommission's regulations, and (3) the issuance of this amendment will not be inimical to thecommon defense and security or to the health and safety of the public.Principal Contributor: H. Garg, NRR Date: April 27, 2007