Text

Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements
	ML20268C198
Person / Time
Site:	Perry
Issue date:	09/24/2020
From:	Payne F; Energy Harbor Nuclear Corp
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-20-166
	Download: ML20268C198 (58)
	v • d • e

energy Energy Harbor Nuclear Corp.

~....-.. harbor Perry Nuclear Power Plant 10 Center Road P.O. Box 97 Perry, Ohio 44081 Frank R. Payne 440-280-5382 Site Vice President, Perry Nuclear September 24, 2020 L-20-166 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Application to Revise Technical Specifications to Adopt TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements" Pursuant to 10 CFR 50.90, Energy Harbor Nuclear Corp. is submitting a request for an amendment to the Technical Specifications (TS) for Perry Nuclear Power Plant, Unit No. 1.

Energy Harbor Nuclear Corp. requests adoption of TSTF 582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements." The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

The enclosure provides a description and assessment of the proposed changes.

Attachment 1 provides the existing TS pages marked to show the proposed changes.

Attachment 2 provides revised (clean) TS pages. Attachment 3 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.

Energy Harbor Nuclear Corp. requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested by January 22, 2021. Once approved, the amendment shall be implemented within 90 days.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Manager - Fleet Licensing, at (330) 696-7208.

Perry Nuclear Power Plant L-20-166 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on September 24, 2020.

Since, y, ,_fr--

Frank R Payne

Enclosure:

Evaluation of Proposed Change cc: NRC Region I Administrator NRC Resident Inspector NRR Project Manager Executive Director, Ohio Emergency Management Agency Utility Radiological Safety Board

Evaluation of Proposed Change Page 1 of 9

Subject:

Application to Revise Technical Specifications to Adopt TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements"

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation 2.2 Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis 3.2 Conclusion

4.0 ENVIRONMENTAL CONSIDERATION

5.0 ATTACHMENTS

1. Technical Specification Page Markups

2. Revised Technical Specification Pages (for information only)

3. TS Bases Markups (for information only)

Evaluation of Proposed Change Page 2 of 9

1.0 DESCRIPTION

Energy Harbor Nuclear Corp. requests adoption of TSTF 582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements." The Technical Specifications (TSs) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation Energy Harbor Nuclear Corp. has reviewed the safety evaluation for TSTF-582 provided to the Technical Specifications Task Force in a letter dated August 13, 2020. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-582. Energy Harbor Nuclear Corp. has concluded that the justifications presented in TSTF-582 and the safety evaluation prepared by the NRC staff are applicable to Perry Nuclear Power Plant, Unit No. 1 (PNPP) and justify this amendment for the incorporation of the changes to the PNPP TSs.

Energy Harbor Nuclear Corp. verifies that the required ECCS injection/spray subsystem can be aligned and the pump started using relatively simple evolutions involving the manipulation of a small number of components. These actions can be performed in a short time (less than the minimum Drain Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) from the control room following plant procedures.

2.2 Variations Energy Harbor Nuclear Corp. is proposing the following variations from the TS changes described in TSTF-582 or the applicable parts of the NRC staffs safety evaluation:

2.2.1 The PNPP TS utilize different numbering and titles than the Standard Technical Specifications on which TSTF-582 was based.

Specifically, the numbering in TS 3.3.5.2 differs from what is shown in the TSTF. Additionally, the titles in Table 3.3.5.2-1 differ from what is shown in the TSTF. These differences are administrative and do not affect the applicability of TSTF-582 to the PNPP TS.

2.2.2 The existing wording of SR 3.8.2.1 in the PNPP is different than the wording shown in the TSTF. The final wording of the PNPP TS will match what has been provided by the BWROG for the SR 3.8.2.1 variation and will match the structure of NUREG-1434. This change is administrative and does not affect the applicability of TSTF-582 to the PNPP TS.

Evaluation of Proposed Change Page 3 of 9 2.2.3 The PNPP TS contain an error within SR 3.8.2.1 for TS 3.8.2 AC Sources - Shutdown. In order for this SR to be met, the following SRs must be met: SR 3.8.1.1 through SR 3.8.1.7, SR 3.8.1.9 through 3.1.8.16, SR 3.1.8.18, and SR 3.1.8.19. Additionally, Note 1 of SR 3.8.2.1 lists certain SRs that are not required to be performed in order to meet SR 3.8.2.1. Currently, SR 3.8.1.8 is listed in the note, but it is not a requirement to meet SR 3.8.2.1.

This is a legacy error from the initial conversion to the Improved Standard Technical Specifications. The proposed change would eliminate reference to SR 3.8.1.8 from the note in SR 3.8.2.1. This change is administrative and does not affect the applicability of TSTF-582 to the PNPP TS.

2.2.4 Changes in TSTF-582 were incorporated in the PNPP TS as variations during adoption of TSTF-542 by letter dated December 6, 2017 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML17347A788]. Specifically, Required Action J.2 in Condition J of TS 3.3.6.1 was already removed during adoption of TSTF-542. It was removed because the direction to initiate action to close the RHR shutdown cooling (SDC) isolation valves in Mode 3 is in direct conflict with TS 3.4.9, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, which requires two RHR SDC subsystems to be operable, and if not, to take immediate action to restore an RHR SDC subsystem to operable status (Required Action A.1). Also, Condition E of TS 3.3.5.2 was deleted during the adoption of TSTF-542. It was deleted because the ability to override the HPCS Level 8 isolation is already part of the PNPP emergency operating procedures and is practiced during operator training. SR 3.5.2.8 was revised to assure that the HPCS manual start capability (including the HPCS Level 8 isolation override feature) is tested. Additionally, the associated HPCS functions have been relabeled to account for the deletions of Functions 3.a and 3.e. Therefore, these TSTF-582 changes are not needed.

2.2.5 In the Bases pages for TS 3.3.5.2, TSTF-582 shows the function Reactor Vessel Water Level - Low, Level 3 isolates group 3 valves. For PNPP, this function isolates groups 3 and 4 valves.

2.2.6 TSTF-582, "RPV WIC Enhancements," states:

The ECCS injection/spray subsystem required to be operable by LCO 3.5.2 must be capable of being manually started as defense-in-depth against an unexpected draining event. The changes in TSTF-542 did not assume automatic actuation of the ECCS subsystem. TS 3.5.2, Required Action D.1 requires an additional method of water injection

Evaluation of Proposed Change Page 4 of 9 and that the required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power. However, LCO 3.5.2 does not assume that the onsite electrical power source will start automatically on an ECCS or loss of power signal.

LCO 3.8.2, "AC Sources - Shutdown," requires one offsite circuit and one diesel generator to be operable in Modes 4 and 5. SR 3.8.2.1 lists the TS 3.8.1, "AC Sources -

Operating," SRs that are applicable in Modes 4 and 5. In an oversight in TSTF-542, the TS 3.8.1 SRs that test automatic start and loading of a diesel generator on an ECCS or loss of offsite power signal were not excluded from SR 3.8.2.1.

TSTF-582 revises Technical Specification (TS) 3.8.2, "AC Sources -

Shutdown," Surveillance Requirement (SR) 3.8.2.1, to exclude SRs that verify the ability of the diesel generators to automatically start and load on an ECCS initiation signal or loss of offsite power signal.

The NRC Safety Evaluation for TSTF-582 (ADAMS Accession No. ML20223A000, dated, 8/13/2020), Section 3.6, "Alternating Current Sources - Shutdown, STS 3.8.2," states:

STS 3.5.2, Reactor Pressure Vessel Water Inventory Control (RPV WIC), does not require automatic ECCS initiation to mitigate a draining event in Modes 4 and 5, and the ECCS initiation signal related to the automatic ECCS initiation is removed from the STS. Because the automatic ECCS initiation and related ECCS initial signal in Modes 4 and 5 are eliminated, the automatic start of the DG on an ECCS initiation signal is not required in Modes 4 and 5.

[T]he NRC staff finds that STS 3.5.2 provides enough time from the onset of the [loss of offsite power] LOOP event for the operator to manually start the DG required to supply power to the water injection equipment to mitigate the draining event in Modes 4 and 5. In addition, STS 3.5.2 does not require the automatic initiation of the ECCS injection/spray subsystem or the additional method of water injection. Therefore, since STS 3.5.2 allows enough time to manually start the DG and the equipment for water injection, the NRC staff finds that the automatic start and loading of the DG are not necessary on a LOOP signal or LOOP concurrent with an ECCS initiation signal to mitigate a draining event in Modes 4 and 5.

Furthermore, the NRC staff notes that other events postulated in Modes 4 and 5 (for example, FHA, waste gas tank rupture) and

Evaluation of Proposed Change Page 5 of 9 during movement of [recently] irradiated fuel assemblies in the

[primary and secondary containment] do not assume a LOOP event or an automatic ECCS initiation.

TSTF-582 did not include all of the TS changes needed to reflect that TS 3.8.2 should not require automatic start and loading of a diesel generator within 10 seconds for Divisions 1 and 2 and within 13 second for Division 3 on an ECCS initiation signal or a loss of offsite power signal.

TS 3.3.8.1, "Loss of Power (LOP) Instrumentation," is applicable in Modes 1, 2, and 3, and when the associated diesel generator is required to be operable by TS 3.8.2. TSTF-582 revised TS 3.8.2 to no longer require automatic start and loading of a diesel generator on a loss of offsite power signal. Consequently, the LOP instrumentation that generates the loss of offsite power signal should not be required to be operable when the diesel generator is required to be operable by TS 3.8.2. The Applicability of LCO 3.3.8.1 is revised to not include the specified condition "When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, 'AC Sources - Shutdown'."

TS SR 3.8.1.7 and SR 3.8.1.15 require that the DG starts from standby or hot conditions, respectively, and achieve required voltage and frequency within 10 seconds for Divisions 1 and 2 and within 13 second for Division 3. The 10 or 13 second start requirements support the assumptions in the design basis LOCA analysis. This capability is not required during a manual diesel generator start to respond to a draining event, which has a minimum Drain Time of one hour. Therefore, SR 3.8.1.7 and SR 3.8.1.15 are added to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.

TS SR 3.8.1.18 states, "Verify for Division 1 and 2 DGs, the sequence time is within +/- 10% of design for each load sequence timer." TSTF-582 retained SR 3.8.1.18 as a test that must be met but not performed. The relay logic schemes that perform a function equivalent to a load sequencer are only used for the automatic start and loading of the diesel generator and are not used during a manual diesel generator start. Therefore, SR 3.8.1.18 is added to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.

The TS 3.8.2 LCO Bases were not updated by TSTF-542 or TSTF-582 to reflect that automatic start and loading of a diesel generator is not required. The LCO 3.8.2 and SR 3.8.2.1 Bases are revised to reflect the TS requirements. This variation provides consistency within the TS after incorporating the TSTF-582 changes to SR 3.8.2.1.

Evaluation of Proposed Change Page 6 of 9

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Energy Harbor Nuclear Corp. requests adoption of TSTF 582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements. The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions that were incorporated into the plant TSs when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." TSTF-582 includes the following changes to the TSs:

1. The TSs are revised to eliminate the requirement for a manual ECCS initiation signal to start the required ECCS injection/spray subsystem, and to instead rely on manual valve alignment and pump start.

2. The Drain Time definition is revised to move the examples of common mode failure mechanisms to the Bases and seismic events are no longer considered a common mode failure mechanism.

3. The Drain Time definition exception from considering the Drain Time for penetration flow paths isolated with manual or automatic valves that are "locked, sealed, or otherwise secured" is revised to apply the exception for manual or automatic valves that are "closed and administratively controlled."

4. The TSs are revised to permit placing an inoperable isolation channel in trip as an alternative to declaring the associated penetration flow path incapable of automatic isolation.

5. A Surveillance Requirement (SR) that requires operating the required Emergency Core Cooling System (ECCS) injection/spray subsystem for at least 10 minutes through the recirculation line, is modified to permit crediting normal operation of the system to satisfy the SR and to permit operation through the test return line.

6. TS 3.8.2, "AC Sources - Shutdown," SR 3.8.2.1, is revised to not require SRs that test the ability of the automatic diesel generator to start in Modes 4 and 5. Automatic ECCS initiation in Modes 4 and 5 was eliminated in TSTF-542. This was an oversight in TSTF-542.

7. The TSs are revised to use wording and to define acronyms in a manner consistent with the remainder of the TS. These changes are made for consistency and have no effect on the application of the TS.

Energy Harbor Nuclear Corp. has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No

Evaluation of Proposed Change Page 7 of 9 The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." Draining of RPV water inventory in Mode 4 (that is, cold shutdown) and Mode 5 (that is, refueling) is not an accident previously evaluated and, therefore, revising the existing TS controls to prevent or mitigate such an event has no effect on any accident previously evaluated. RPV water inventory control in Mode 4 or Mode 5 is not an initiator of any accident previously evaluated. The existing and revised TS controls are not mitigating actions assumed in any accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in 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 change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." The event of concern under the current requirements and the proposed change is an unexpected draining event. The TS have contained requirements related to an unexpected draining event during shutdown for over 40 years and this event does not appear as an analyzed event in the Updated Final Safety Analysis Report (UFSAR) for any plant or in the NRC's Standard Review Plan (NUREG-0800).

Therefore, an unexpected draining event is not a new or different kind of accident not considered in the design and licensing bases that would have been considered a design basis accident in the UFSAR had it been previously identified.

None of the equipment affected by the proposed change has a design function described in the UFSAR to mitigate an unexpected draining event in Modes 4 or 5, although the equipment may be used for that purpose.

Therefore, the proposed amendment will not change the design function of the affected equipment. The proposed change will affect the operation of certain equipment, such as the control of valves credited for preventing a draining event. However, these changes provide adequate protection to prevent or mitigate an unexpected draining event and do not create the possibility of a new or different kind of accident due to credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.

Evaluation of Proposed Change Page 8 of 9 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

The safety basis for the RPV WIC requirements is to protect Safety Limit 2.1.1.3. The proposed change does not affect any specific values that define a safety margin as established in the licensing basis. The proposed change does not affect a design basis or safety limit, or any controlling value for a parameter established in the UFSAR or the license. Therefore, the proposed change does not significantly reduce the margin of safety.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Energy Harbor Nuclear Corp. concludes that the proposed change 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.

3.2 Conclusion 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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion

Evaluation of Proposed Change Page 9 of 9 set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Attachment 1 Technical Specification Page Markups (11 pages follow)

Definitions 1.1 1.1 Definitions (continued)

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except;

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation devices without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; (continued)

PERRY - UNIT 1 1.0-2a Amendment No. 184 - I

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.2-1 for the channel.

AB. One or more channels A.1 Initiate action to place Immediately inoperable.As required by channel in trip.

Required Action A.1 and referenced in OR Table 3.3.5.2-1.

AB.2.1 Declare associated Immediately penetration flow path(s) incapable of automatic isolation.

AND AB.2.2 Initiate action to cCalculate Immediately DRAIN TIME.

C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.5.2-1.

(continued)

PERRY - UNIT 1 3.3-43a Amendment No. 184

RPV Water Inventory Control Instrumentation 3.3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. As required by Required D.1 Declare HPCS system 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and inoperable.

referenced in Table 3.3.5.2-1. OR D.2 Align the HPCS pump 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months suction to the suppression pool.

E. As required by Required E.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and OPERABLE status.

referenced in Table 3.3.5.2-1.

F. Required Action and F.1 Declare associated ECCS Immediately associated Completion injection/spray subsystem Time of Condition C, D, inoperable.

or E not met.

PERRY - UNIT 1 3.3-43b Amendment No. 184

RPV Water Inventory Control Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.3 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.3-43c Amendment No. 184 - I

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 12)

RPV Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

1. Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core Spray (LPCS) Subsystems

a. Reactor Vessel 4, 5 1(a) C SR 3.3.5.2.1 482.7 psig Pressure - Low SR 3.3.5.2.2 and (LPCS Injection Valve 607.7 psig Permissive)

b. LPCS Pump Discharge 4, 5 1(a) E SR 3.3.5.2.1 1200 gpm Flow - Low (Bypass) SR 3.3.5.2.2

c. Reactor Vessel 4, 5 1(a) C SR 3.3.5.2.1 490.0 psig Pressure - Low SR 3.3.5.2.2 and (LPCI Injection Valve 537.1 psig Permissive)

d. LPCI Pump A Discharge 4, 5 1(a) E SR 3.3.5.2.1 1450 gpm Flow - Low (Bypass) SR 3.3.5.2.2

e. Manual Initiation 4, 5 1(a) E SR 3.3.5.2.3 NA

2. LPCI B and LPCI C Subsystems

a. Reactor Vessel 4, 5 1 per C SR 3.3.5.2.1 490.0 psig Pressure - Low (LPCI subsystem SR 3.3.5.2.2 and Injection Valve (a) 537.1 psig Permissive) for LPCI B; and 490.0 psig and 537.1 psig for LPCI C

b. LPCI Pump B and LPCI 4, 5 1 per pump E SR 3.3.5.2.1 1450 gpm Pump C Discharge (a) SR 3.3.5.2.2 Flow - Low (Bypass)

c. Manual Initiation 4, 5 1(a) E SR 3.3.5.2.3 NA (continued)

(a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control.

PERRY - UNIT 1 3.3-43d Amendment No. 184

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 2 of 2)

RPV Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

3. High Pressure Core Spray (HPCS) System

a. Condensate Storage Tank 4(b), 5(b) 2(a) D SR 3.3.5.2.1 90,300 Level - Low SR 3.3.5.2.2 gallons

b. HPCS Pump Discharge 4, 5 1(a) E SR 3.3.5.2.1 120 psig Pressure - High (Bypass) SR 3.3.5.2.2

c. HPCS System Flow 4, 5 1(a) E SR 3.3.5.2.1 600 gpm Rate - Low (Bypass) SR 3.3.5.2.2

14. RHR System Isolation

a. Reactor Vessel Water (ac) 2 in one trip B SR 3.3.5.2.1 177.1 inches Level - Low, Level 3 system SR 3.3.5.2.2

25. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water (ac) 2 in one trip B SR 3.3.5.2.1 127.6 inches Level - Low Low, Level 2 system SR 3.3.5.2.2 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control.

(b) When HPCS is OPERABLE for compliance with LCO 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control, and aligned to the condensate storage tank.

(ac) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

PERRY - UNIT 1 3.3-43e Amendment No. 184

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, When the associated diesel generator (DG) is required to be OPERABLE by LCO 3.8.2, AC Sources - Shutdown.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable.

B. Required Action and B.1 Declare associated DG Immediately associated Completion inoperable.

Time not met.

PERRY - UNIT 1 3.3-74 Amendment No. 69

ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS - Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of eight safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.

ACTIONS

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

LCO 3.0.4.b is not applicable to High Pressure Core Spray (HPCS).

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray subsystem ECCS injection/spray inoperable. subsystem to OPERABLE status.

B. High Pressure Core B.1 Verify by administrative 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Spray (HPCS) System means RCIC System is inoperable. OPERABLE when RCIC is required to be OPERABLE.

AND B.2 Restore HPCS System to 14 days OPERABLE status.

(continued)

PERRY - UNIT 1 3.5-1 Amendment No. 184

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify, for a required High Pressure Core Spray In accordance (HPCS) System, the: with the Surveillance

a. Suppression pool water level is 16 ft 6 in; or Frequency Control Program

b. Condensate storage tank water volume is 249,700 gal.

SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance subsystem, the piping is filled with water from the with the pump discharge valve to the injection valve. Surveillance Frequency Control Program SR 3.5.2.5 Verify, for the required ECCS injection/spray In accordance subsystem, each manual, power operated, and with the automatic valve in the flow path, that is not locked, Surveillance sealed, or otherwise secured in position, is in the Frequency correct position. Control Program (continued)

PERRY - UNIT 1 3.5-8 Amendment No. 184

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.56 ---------------------------NOTES--------------------------------

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray In accordance subsystem through the recirculation line for with the 10 minutes. Surveillance Frequency Control Program SR 3.5.2.67 Verify each valve credited for automatically isolating In accordance a penetration flow path actuates to the isolation with the position on an actual or simulated isolation signal. Surveillance Frequency Control Program SR 3.5.2.78 ----------------------------NOTE---------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCSLPCI or LPCS In accordance injection/spray subsystem actuates on a manual with the injection signal, or the required HPCS subsystem Surveillance can be manually operated. Frequency Control Program PERRY - UNIT 1 3.5-9 Amendment No. 184

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 ------------------------------NOTES-----------------------------

1. The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.89, SR 3.8.1.4, and through SR 3.8.1.16,. - - -

SR 3.8.1.18, and - SR 3.8.1.19.

2. SR 3.8.1.12 and SR 3.8.1.19 are not required to be met when the associated ECCS subsystem(s) are not required to be OPERABLE per LCO 3.5.2, ECCS - Shutdown.

In accordance with applicable The following SRs are applicable Ffor AC sources SRs required to be OPERABLE, the following SRs are applicable:

SR 3.8.1.1 SR 3.8.1.7 SR 3.8.1.14 SR 3.8.1.2 SR 3.8.1.9 SR 3.8.1.15 SR 3.8.1.3 SR 3.8.1.10 SR 3.8.1.16 SR 3.8.1.4 SR 3.8.1.11 SR 3.8.1.18 SR 3.8.1.5 SR 3.8.1.12 SR 3.8.1.19 SR 3.8.1.6 SR 3.8.1.13 PERRY - UNIT 1 3.8-20 Amendment No. 184

Attachment 2 Revised Technical Specification Pages (for information only)

(9 pages follow)

For Information Only Definitions 1.1 1.1 Definitions (continued)

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure, for all penetration flow paths below the TAF except;

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation devices without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; (continued)

PERRY - UNIT 1 1.0-2a Amendment No. 184

For Information Only RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Initiate action to place Immediately inoperable. channel in trip.

OR A.2.1 Declare associated Immediately penetration flow path(s) incapable of automatic isolation.

AND A.2.2 Initiate action to calculate Immediately DRAIN TIME.

PERRY - UNIT 1 3.3-43a Amendment No. 184

For Information Only RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE MODES OR REQUIRED OTHER CHANNELS SPECIFIED PER ALLOWABLE FUNCTION CONDITIONS FUNCTION VALUE

1. RHR System Isolation

a. Reactor Vessel Water (a) 2 in one trip 177.1 Level - Low, Level 3 system inches

2. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water (a) 2 in one trip 127.6 Level - Low Low, Level 2 system inches (a) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

PERRY - UNIT 1 3.3-43c Amendment No. 184

LOP Instrumentation For Information Only 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3 ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable.

B. Required Action and B.1 Declare associated DG Immediately associated Completion inoperable.

Time not met.

PERRY - UNIT 1 3.3-74 Amendment No. 69

For Information Only ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS - Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of eight safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.

ACTIONS

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

LCO 3.0.4.b is not applicable to High Pressure Core Spray (HPCS).

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray subsystem ECCS injection/spray inoperable. subsystem to OPERABLE status.

B. HPCS System B.1 Verify by administrative 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. means RCIC System is OPERABLE when RCIC is required to be OPERABLE.

AND B.2 Restore HPCS System to 14 days OPERABLE status.

(continued)

PERRY - UNIT 1 3.5-1 Amendment No. 184

For Information Only RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify, for a required High Pressure Core Spray In accordance (HPCS) System, the: with the Surveillance

a. Suppression pool water level is 16 ft 6 in; or Frequency Control Program

b. Condensate storage tank water volume is 249,700 gal.

SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance subsystem, the piping is filled with water from the with the pump discharge valve to the injection valve. Surveillance Frequency Control Program (continued)

PERRY - UNIT 1 3.5-8 Amendment No. 184

For Information Only RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5 ---------------------------NOTES--------------------------------

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray In accordance subsystem for 10 minutes. with the Surveillance Frequency Control Program SR 3.5.2.6 Verify each valve credited for automatically isolating In accordance a penetration flow path actuates to the isolation with the position on an actual or simulated isolation signal. Surveillance Frequency Control Program SR 3.5.2.7 ----------------------------NOTE---------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem In accordance can be manually operated. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.5-9 Amendment No. 184

For Information Only AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 ------------------------------NOTE------------------------------

The following SRs are not required to be performed:

SR 3.8.1.3, SR 3.8.1.9, SR 3.8.1.4, and SR 3.8.1.16.

The following SRs are applicable for AC sources In accordance required to be OPERABLE: with applicable SRs SR 3.8.1.1 SR 3.8.1.14 SR 3.8.1.2 SR 3.8.1.9 SR 3.8.1.3 SR 3.8.1.10 SR 3.8.1.16 SR 3.8.1.4 SR 3.8.1.5 SR 3.8.1.6 PERRY - UNIT 1 3.8-20 Amendment No. 184

Attachment 3 TS Bases Markups (for information only)

(25 pages follow)

For Information Only RPV Water Inventory Control Instrumentation B 3.3.5.2 B 3.3 INSTRUMENTATION B 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF.

If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

Technical Specifications are required by 10 CFR 50.36 to include limiting safety system settings (LSSS) for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a safety action is initiated to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur. The actual settings for the automatic isolation channels are the same as those established for the same functions in MODES 1, 2, and 3 in LCO 3.3.5.1, Emergency Core Cooling System (ECCS)

Instrumentation, or LCO 3.3.6.1, Primary Containment and Drywell Isolation Instrumentation.

With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses.

RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur. Under the definition of DRAIN TIME, some penetration flow paths may be excluded from the DRAIN TIME calculation if they will be isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation.

(continued)

PERRY - UNIT 1 B 3.3-123a -

Revision No. 12 I

For Information Only RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES BACKGROUND The purpose of the RPV Water Inventory Control Instrumentation is to (continued) support the requirements of LCO 3.5.2, Reactor Pressure Vessel (RPV)

Water Inventory Control, and the definition of DRAIN TIME. There are functions that are required for manual initiation or operation of the ECCS injection/spray subsystem required to be OPERABLE by LCO 3.5.2 and other functions that support automatic isolation of Residual Heat Removal subsystem and Reactor Water Cleanup system penetration flow path(s) on low RPV water level.

The RPV Water Inventory Control Instrumentation supports operation of low pressure core spray (LPCS), low pressure coolant injection (LPCI),

and high pressure core spray (HPCS). The equipment involved with each of these systems is described in the Bases for LCO 3.5.2.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not required SAFETY to mitigate any events or accidents evaluated in the safety analyses.

ANALYSES, LCO, RPV water inventory control is required in MODES 4 and 5 to protect and APPLICABILITY Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not considered postulated in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is postulated considered in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one ECCS injection/spray subsystem can be manually initiated to maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety.

Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Permissive and interlock setpoints are generally considered as nominal values without regard to measurement accuracy. The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed as follows on a Function by Function basis.

(continued)

PERRY - UNIT 1 B 3.3-123b Revision No. 12

For Information Only RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE Low Pressure Core Spray and Low Pressure Coolant Injection Systems SAFETY ANALYSES, LCO, 1.a, 1.c, 2.a. Reactor Vessel Pressure - Low (Injection Valve Permissive) and APPLICABILITY (continued) Low reactor vessel pressure signals are used as permissives for the low pressure ECCS subsystems. This ensures that, prior to opening the injection valves of the low pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems maximum design pressure. While it is assured during MODES 4 and 5 that the reactor vessel pressure will be below the ECCS maximum design pressure, the Reactor Vessel Pressure - Low signals are assumed to be operable and capable of permitting initiation of the ECCS.

The Reactor Vessel Pressure - Low (Injection Valve Permissive) signals are initiated from one pressure transmitter for each low pressure ECCS system that senses the reactor pressure.

The Allowable Value is low enough to prevent overpressuring the equipment in the low pressure ECCS.

One channel of Reactor Vessel Pressure - Low (Injection Valve Permissive) Function per associated low pressure ECCS subsystem is required to be OPERABLE in MODES 4 and 5, since these channels support the manual initiation Function. In addition, the channels are only required when the associated ECCS subsystem is required to be OPERABLE by LCO 3.5.2.

1.b, 1.d, 2.b. Low Pressure Coolant Injection and Low Pressure Core Spray Pump Discharge Flow - Low (Bypass)

The minimum flow instruments are provided to protect the associated low pressure ECCS pump from overheating when the pump is operating and the associated injection valve is not fully open. The minimum flow valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump.

One flow transmitter per ECCS pump is used to detect the associated subsystems flow rates. The logic is arranged such that each transmitter causes its associated minimum flow valve to open. The logic will close the minimum flow valve once the closure setpoint is exceeded. The LPCI minimum flow valves are time delayed such that the valves will not open for 8 seconds after the transmitters and associated trip units detect low flow. The time delay is provided to limit reactor vessel inventory loss during the startup of the Residual Heat Removal (RHR) shutdown cooling mode (for RHR A and RHR B).

(continued)

PERRY - UNIT 1 B 3.3-123c Revision No. 12

For Information Only RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE 1.b, 1.d, 2.b. Low Pressure Coolant Injection and Low Pressure Core SAFETY Spray Pump Discharge Flow - Low (Bypass) (continued)

ANALYSES, LCO, and APPLICABILITY The Pump Discharge Flow - Low (Bypass) Allowable Values are high enough to ensure that the pump flow rate is sufficient to protect the pump, yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core.

Each channel of Pump Discharge Flow - Low (Bypass) Function (one LPCS channel and three LPCI channels) is only required to be OPERABLE in MODES 4 and 5 when the associated LPCS or LPCI pump is required to be OPERABLE by LCO 3.5.2 to ensure the pumps are capable of injecting into the Reactor Pressure Vessel when manually initiated.

1.e, 2.c. Manual Initiation The Manual Initiation push button channels introduce signals into the appropriate ECCS logic to provide manual initiation capability and are redundant to the automatic protective instrumentation. There is one push button for each of the two Divisions of low pressure ECCS (i.e., Division 1 ECCS, LPCS and LPCI A; Division 2 ECCS, LPCI B and LPCI C).

The Manual Initiation Function is not assumed in any accident or transient analyses in the USAR. However, the Function is retained for overall redundancy and diversity of the low pressure ECCS function as required by the NRC in the plant licensing basis.

There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the push buttons.

Each channel of the Manual Initiation Function (one channel per Division) is only required to be OPERABLE when the associated ECCS is required to be OPERABLE by LCO 3.5.2.

High Pressure Core Spray System 3.a. Condensate Storage Tank Level - Low Low level in the CST indicates the unavailability of an adequate supply of makeup water from this normal source. Normally the suction valve between HPCS and the CST is open and, upon receiving a HPCS initiation signal, water for HPCS injection would be taken from the CST.

However, if the water level in the CST falls below a preselected level, first the suppression pool suction valve automatically opens, and then the (continued)

PERRY - UNIT 1 B 3.3-123d Revision No. 12

RPV Water Inventory Control Instrumentation For Information Only B 3.3.5.2 BASES APPLICABLE 3.a. Condensate Storage Tank Level - Low (continued)

SAFETY ANALYSES, LCO, CST suction valve automatically closes. This ensures that an adequate and APPLICABILITY supply of makeup water is available to the HPCS pump. To prevent losing suction to the pump, the suction valves are interlocked so that the suppression pool suction valve must be open before the CST suction valve automatically closes.

Condensate Storage Tank Level - Low signals are initiated from two level transmitters. The logic is arranged such that either transmitter and associated trip unit can cause the suppression pool suction valve to open and the CST suction valve to close. The Condensate Storage Tank Level

- Low Function Allowable Value of 90,300 gallons (elevation 626 ft. 8 inches) is high enough to ensure adequate pump suction head while water is being taken from the CST.

Two channels of the Condensate Storage Tank Level - Low Function are only required to be OPERABLE when HPCS is required to be OPERABLE to ensure that no single instrument failure can preclude HPCS swap to the suppression pool source. The Function is required to be OPERABLE only when HPCS is required to be OPERABLE to fulfill the requirements of LCO 3.5.2, HPCS is aligned to the CST, and the CST water level is not within the limits of SR 3.5.2.3 and the suppression pool water level is within the limits of SR 3.5.2.3. With CST water level within limits, a sufficient supply of water exists for injection to minimize the consequences of a vessel draindown event.

3.b, 3.c. HPCS Pump Discharge Pressure - High (Bypass) and HPCS System Flow Rate - Low (Bypass)

The minimum flow instruments are provided to protect the HPCS pump from overheating when the pump is operating and the associated injection valve is not fully open. The minimum flow valve is opened when low flow and high pump discharge pressure are sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump or the discharge pressure is low (indicating the HPCS pump is not operating).

One flow transmitter is used to detect the HPCS Systems flow rate. The logic is arranged such that the transmitter causes the minimum flow valve to open, provided the HPCS pump discharge pressure, sensed by another transmitter, is high enough (indicating the pump is operating).

The logic will close the minimum flow valve once the closure setpoint is exceeded. (The valve will also close upon HPCS pump discharge pressure decreasing below the setpoint.)

(continued)

PERRY - UNIT 1 B 3.3-123e Revision No. 12

For Information Only RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE 3.b, 3.c. HPCS Pump Discharge Pressure - High (Bypass) and HPCS SAFETY System Flow Rate - Low (Bypass) (continued)

ANALYSES, LCO, and APPLICABILITY The HPCS System Flow Rate - Low (Bypass) and HPCS Pump Discharge Pressure - High (Bypass) Allowable Value is high enough to ensure that pump flow rate is sufficient to protect the pump, yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core. The HPCS Pump Discharge Pressure - High (Bypass) Allowable Value is set high enough to ensure that the valve will not be open when the pump is not operating.

One channel of each Function is required to be OPERABLE when HPCS is required to be OPERABLE by LCO 3.5.2 in MODES 4 and 5.

RHR System Isolation 14.a. Reactor Vessel Water Level - Low, Level 3 The definition of DRAIN TIME allows crediting the closing of penetration flow paths that are capable of being automatically isolated by RPV water level isolation instrumentation prior to the RPV water level being equal to the TAF.

The Reactor Vessel Water Level - Low, Level 3 Function is only required to be OPERABLE when automatic isolation of the associated RHR penetration flow path is credited in calculating DRAIN TIME.

The Reactor Vessel Water Level - Low, Level 3 Function associated with RHR Shutdown Cooling System isolation is not directly assumed in any transient or accident analysis, since bounding analyses are performed for large breaks such as MSLBs. The RHR Shutdown Cooling System isolation on Level 3 supports actions to ensure that the RPV water level does not drop below the top of the active fuel during a vessel draindown event through the 1E12-F008 and 1E12-F009 valves caused by a leak (e.g., pipe break or inadvertent valve opening) in the RHR Shutdown Cooling System.

Reactor Vessel Water Level - Low, Level 3 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low, Level 3 Function are available, only two channels of the Reactor Vessel Water Level - Low, Level 3 Function are required to be OPERABLE in MODES 4 and 5 (both channels must input into the same trip system).

(continued)

PERRY - UNIT 1 B 3.3-123f -

Revision No. 12 I

For Information Only RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE 14.a. Reactor Vessel Water Level - Low, Level 3 (continued)

SAFETY ANALYSES, LCO, The Reactor Vessel Water Level - Low, Level 3 Allowable Value was and APPLICABILITY chosen to be the same as the RPS Reactor Vessel Water Level - Low, Level 3 Allowable Value (LCO 3.3.1.1), since the capability to cool the fuel may be threatened.

This Function isolates the Group 3 and 4 valves.

Reactor Water Cleanup (RWCU) System Isolation 25.a. Reactor Vessel Water Level - Low Low, Level 2 The definition of DRAIN TIME allows crediting the closing of penetration flow paths that are capable of being automatically isolated by RPV water level isolation instrumentation prior to the RPV water level being equal to the TAF. The Reactor Vessel Water Level - Low Low, Level 2 Function associated with RWCU System isolation may be credited for automatic isolation of penetration flow paths associated with the RWCU System.

Low RPV water level indicates the capability to cool the fuel may be threatened. Should RPV water level decrease too far, fuel damage could result. Therefore, isolation of some reactor vessel interfaces occurs to isolate the potential sources of a break.

Reactor Vessel Water Level - Low Low, Level 2 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low Low, Level 2 Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low Low, Level 2 Allowable Value was chosen to be the same as the ECCS Reactor Vessel Water Level - Low Low, Level 2 Allowable Value (LCO 3.3.5.1), since the capability to cool the fuel may be threatened.

The Reactor Vessel Water Level - Low Low, Level 2 Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.

This Function isolates the Group 7 valves.

(continued)

PERRY - UNIT 1 B 3.3-123g Revision No. 12

For Information Only RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES (continued)

ACTIONS A Note has been provided to modify the ACTIONS related to RPV Water Inventory Control instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPV Water Inventory Control instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable RPV Water Inventory Control instrumentation channel.

A.1 Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.2-1. The applicable Condition referenced in the Table is Function dependent. Each time a channel is discovered inoperable, Condition A is entered for that channel and provides for transfer to the appropriate subsequent Condition.

AB.1, A.2.1, and AB.2.2 RHR System Isolation, Reactor Vessel Water Level - Low Level 3, and Reactor Water Cleanup System, Reactor Vessel Water Level - Low Low, Level 2 functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME. If the instrumentation is inoperable, Required Action AB.1 directs immediate action to place the channel in trip. With the inoperable channel in the tripped condition, the remaining channel will isolate the penetration flow path on low water level. If both channels are inoperable and placed in trip, the penetration flow path will be isolated. Alternatively, Required Action A.2.1 requires an immediate declaration that the associated penetration flow path(s) to be immediately declared are incapable of automatic isolation. Required Action AB.2.2 directs initiating action to calculateion of DRAIN TIME. The calculation cannot credit automatic isolation of the affected penetration flow paths.

(continued)

PERRY - UNIT 1 B 3.3-123h Revision No. 12

For Information Only RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES ACTIONS C.1 (continued)

Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual initiation functions. If this permissive is inoperable, manual initiation of ECCS is prohibited. Therefore, the permissive must be placed in the trip condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . With the permissive in the trip condition, manual initiation may be performed. Prior to placing the permissive in the tripped condition, the operator can take manual control of the pump and the injection valve to inject water into the RPV.

The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is intended to allow the operator time to evaluate any discovered inoperabilities and to place the channel in trip.

D.1 and D.2 Required Actions D.1 and D.2 are intended to ensure that appropriate actions are taken if multiple, inoperable channels within the same Function result in a loss of automatic suction swap for the HPCS system from the condensate storage tank to the suppression pool. The HPCS system must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or the HPCS pump suction must be aligned to the suppression pool, since, if aligned, the function is already performed.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes the risk of HPCS being needed without an adequate water source while allowing time for restoration or alignment of HPCS pump suction to the suppression pool.

E.1 If an LPCI or LPCS Discharge Flow - Flow bypass function or HPCS System Discharge Pressure - High or Flow Rate - Low bypass function is inoperable, there is a risk that the associated ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open. In this condition, the operator can take manual control of the pump and the injection valve to ensure the pump does not overheat. If a manual initiation function is inoperable, the ECCS subsystem pumps can be started manually and the valves can be opened manually, but this is not the preferred condition.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time was chosen to allow time for the operator to evaluate and repair any discovered inoperabilities. The Completion Time is appropriate given the ability to manually start the ECCS pumps and open the injection valves and to manually ensure the pumps do not overheat.

(continued)

PERRY - UNIT 1 B 3.3-123i Revision No. 12

For Information Only RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES (continued)

ACTIONS F.1 (continued)

With the Required Action and associated Completion Time of Conditions C, D, or E not met, the associated ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.

SURVEILLANCE The following SRs apply to As noted in the beginning of the SRs, the SRs REQUIREMENTS for each RPV Water Inventory Control Instrument Function are found in the SRs column of Table 3.3.5.2-1.

SR 3.3.5.2.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK guarantees that undetected outright channel failure is limited; thus, it is key to verifying that the instrumentation continues to operate properly between each CHANNEL FUNCTIONAL TEST.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO.

SR 3.3.5.2.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required contact(s) of a channel relay may be (continued)

PERRY - UNIT 1 B 3.3-123j Revision No. 12

For Information Only RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES SURVEILLANCE SR 3.3.5.2.2 (continued)

REQUIREMENTS performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.2.3 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.5.2 overlaps this Surveillance to complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. Information Notice 84-81, Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup, November 1984.

2. Information Notice 86-74, Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves, August 1986.

3. Generic Letter 92-04, Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f), August 1992.

4. NRC Bulletin 93-03, Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs, May 1993.

5. Information Notice 94-52, Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1, July 1994.

PERRY - UNIT 1 B 3.3-123k Revision No. 12

For Information Only LOP Instrumentation B 3.3.8.1 BASES APPLICABLE The specific Applicable Safety Analyses, LCO, and Applicability SAFETY discussions are listed below on a Function by Function basis.

ANALYSES, LCO, and APPLICABILITY 4.16 kV Emergency Bus Undervoltage (continued) 1.a, 1.b. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage)

Loss of voltage on a 4.16 kV emergency bus indicates that offsite power may be completely lost to the respective emergency bus and is unable to supply sufficient power for proper operation of the applicable equipment.

Therefore, the power supply to the bus is transferred from offsite power to DG power when the voltage on the bus drops below the Loss of Voltage Function Allowable Values (loss of voltage with a short time delay). This ensures that adequate power will be available to the required equipment.

The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure power is available to the required equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that power is available to the required equipment.

Two channels of 4.16 kV Emergency Bus Undervoltage (Loss of Voltage)

Function per associated emergency bus are required to be OPERABLE in MODES 1, 2, and 3 and also when the associated DG is required to be OPERABLE by LCO 3.8.2 AC Sources-Shutdown, to ensure that no single instrument failure can preclude the DG function. A channel is defined as a voltage sensing coil. Refer to LCO 3.8.1, "AC Sources -

Operating," and LCO 3.8.2 for Applicability Bases for the DGs.

1.c, 1.d, 1.e. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

A reduced voltage condition on a 4.16 kV emergency bus indicates that while offsite power may not be completely lost to the respective emergency bus, power may be insufficient for starting large motors without risking damage to the motors that could disable the ECCS function. Therefore, power supply to the bus is transferred from offsite power to onsite DG power when the voltage on the bus (continued)

PERRY - UNIT 1 B 3.3-214 Revision No. 12

LOP Instrumentation For Information Only B 3.3.8.1 BASES APPLICABLE 1.c, 1.d, 1.e. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

SAFETY (continued)

ANALYSES, LCO, and APPLICABILITY drops below the Degraded Voltage Function Allowable Values (degraded voltage with a time delay). This ensures that adequate power will be available to the required equipment.

The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that sufficient power is available to the required equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that sufficient power is available to the required equipment.

Two channels of 4.16 kV Emergency Bus Undervoltage (Degraded Voltage) Function per associated emergency bus are required to be OPERABLE in MODES 1, 2, and 3 and also when the associated DG is required to be OPERABLE by LCO 3.8.2 to ensure that no single instrument failure can preclude the DG function. A channel is defined as a voltage sensing coil. Refer to LCO 3.8.1 and LCO 3.8.2 for Applicability Bases for the DGs.

ACTIONS A Note has been provided to modify the ACTIONS related to LOP instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable LOP instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable LOP instrumentation channel.

A.1 With one or more channels of a Function inoperable, the Function may not be capable of performing the intended function. Therefore, only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore the inoperable channel to OPERABLE status.

If the inoperable (continued)

PERRY - UNIT 1 B 3.3-215 Revision No. 12

LOP Instrumentation For Information Only B 3.3.8.1 BASES ACTIONS A.1 (continued) channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action A.1. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue.

Alternately, if it is not desired to place the channel in trip (e.g., as in the case where placing the channel in trip would result in a DG initiation),

Condition B must be entered and its Required Action taken.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

B.1 If the Required Action and associated Completion Time is not met, the associated Function may not be capable of performing the intended function. Therefore, the associated DG(s) are declared inoperable immediately. This requires entry into applicable Conditions and Required Actions of LCO 3.8.1 and LCO 3.8.2, which provides appropriate actions for the inoperable DG(s).

SURVEILLANCE As noted at the beginning of the SRs, the SRs for each LOP REQUIREMENTS Instrumentation Function are located in the SRs column of Table 3.3.8.1-1.

The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provided the associated Function maintains DG initiation capability. Upon completion of the Surveillance, or expiration of the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken.

(continued)

PERRY - UNIT 1 B 3.3-216 Revision No. 1

For Information Only LOP Instrumentation B 3.3.8.1 BASES SURVEILLANCE SR 3.3.8.1.3 REQUIREMENTS (continued) A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.8.1.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic upon the receipt of actuation signals. The system functional testing performed in LCO 3.8.1 and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety functions.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. USAR, Section 8.3.1.1.2.9.a.2.

2. USAR, Section 5.2.

3. USAR, Section 6.3.

4. USAR, Chapter 15.

PERRY - UNIT 1 B 3.3-218 Revision No. 11

For Information Only RPV Water Inventory Control B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF.

If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not required SAFETY to mitigate any events or accidents evaluated in the safety analyses.

ANALYSES RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material to the environment should an unexpected draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulatedconsidered in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is considered in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (an event that creates a drain path through multiple vessel penetrations located below top of active fuel, such as e.g., seismic event, loss of normal power, or a single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can maintain adequate reactor vessel water level.

Operating experience has shown RPV water inventory to be significant to public health and safety (Ref. 1, 2, 3, 4, and 5). Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO The RPV water level must be controlled in MODES 4 and 5 to ensure that if an unexpected draining event should occur, the reactor coolant water level remains above the top of the active irradiated fuel as required by Safety Limit 2.1.1.3.

(continued)

PERRY - UNIT 1 B 3.5-15 Revision No. 12

For Information Only RPV Water Inventory Control B 3.5.2 BASES LCO The Limiting Condition for Operation (LCO) requires the DRAIN TIME of (continued) RPV water inventory to the TAF to be 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A DRAIN TIME of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate unexpected draining of reactor coolant. An event that could cause loss of RPV water inventory and result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

One ECCS injection/spray subsystem is required to be OPERABLE and capable of being manually aligned and started from the control room to provide defense-in-depth should an unexpected draining event occur.

OPERABILITY of the ECCS injection/spray subsystem includes any necessary valves, instrumentation, or controls needed to manually align and start the subsystem from the control room. A ECCS injection/spray subsystem is defined as either one of the three Low Pressure Coolant Injection (LPCI) subsystems, one Low Pressure Core Spray (LPCS)

System, or one High Pressure Core Spray (HPCS) System. The LPCI subsystems and the LPCS System consist of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV.

The HPCS System consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or condensate storage tank (CST) to the RPV.

The LCO is modified by a Note which allows a required LPCI subsystem (A or B) to be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned (remote or local) to the LPCI mode and is not otherwise inoperable. Alignment and operation for decay heat removal includes when the required RHR pump is not operating or when the system is realigned from or to the RHR shutdown cooling mode. This allowance is necessary since the RHR System may be required to operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. Because of the restrictions on DRAIN TIME, sufficient time will be available following an unexpected draining event to manually align and initiate LPCI subsystem operation to maintain RPV water inventory prior to the RPV water level reaching the TAF.

APPLICABILITY RPV water inventory control is required in MODES 4 and 5.

Requirements on water inventory control in other MODES are contained in LCOs in Section 3.3, Instrumentation, and other LCOs in Section 3.5, ECCS, RPV Water Inventory Control, and RCIC System, and RPV Water Inventory Control. RPV water inventory control is required to protect Safety Limit 2.1.1.3 which is applicable whenever irradiated fuel is in the reactor vessel.

(continued)

PERRY - UNIT 1 B 3.5-16 Revision No. 12

For Information Only RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 (continued)

REQUIREMENTS The definition of DRAIN TIME states that realistic cross-sectional areas and drain rates are used in the calculation. A realistic drain rate may be determined using a single, step-wise, or integrated calculation considering the changing RPV water level during a draining event. For a Control Rod RPV penetration flow path with the Control Rod Drive Mechanism removed and not replaced with a blank flange, the realistic cross-sectional area is based on the control rod blade seated in the control rod guide tube. If the control rod blade will be raised from the penetration to adjust or verify seating of the blade, the exposed cross-sectional area of the RPV penetration flow path is used.

The definition of DRAIN TIME excludes from the calculation those penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlledlocked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths. A blank flange or other bolted device must be connected with a sufficient number of bolts to prevent draining in the event of an Operating Basis Earthquake. Normal or expected - I leakage from closed systems or past isolation devices is permitted.

Determination that a system is intact and closed or isolated must consider the status of branch lines and ongoing plant maintenance and testing activities.

The Residual Heat Removal (RHR) Shutdown Cooling System is only considered an intact closed system when misalignment issues (Reference 6) have been precluded by functional valve interlocks or by isolation devices, such that redirection of RPV water out of an RHR subsystem is precluded. Further, RHR Shutdown Cooling System is only considered an intact closed system if its controls have not been transferred to Remote Shutdown, which disables the interlocks and isolation signals.

The exclusion of a single penetration flow paths, or multiple penetration flow paths susceptible to a common mode failure, from the determination of DRAIN TIME mustshould consider the potential effects of a single operator error or initiating event on items supporting temporary alterations in support of maintenance maintenance and testing (rigging, scaffolding, temporary shielding, piping plugs, snubber removal, freeze seals, etc.). If reasonable controls are implemented to prevent If failure of such temporary alterations from items could result and would causinge a draining event from a closed system, or between the RPV and the isolation device, the effect of the temporary alterations on DRAIN TIME need not be considered. Reasonable controls include, but are not limited to, the penetration flow path may not be excluded from the DRAIN TIME calculation.controls consistent with the guidance in NUMARC 93-01, PERRY - UNIT 1 B 3.5-20 -

Revision No. 12 I

For Information Only RPV Water Inventory Control B 3.5.2 Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4, NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, or commitments to NUREG-0612, Control of Heavy Loads at Nuclear Power Plants.

(continued)

PERRY - UNIT 1 B 3.5-20 Revision No. 12

RPV Water Inventory Control For Information Only B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 (continued)

REQUIREMENTS Surveillance Requirement 3.0.1 requires SRs to be met between performances. Therefore, any changes in plant conditions that would change the DRAIN TIME requires that a new DRAIN TIME be determined.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.2 and SR 3.5.2.3 The minimum water level of 16 ft 6 in required for the suppression pool is periodically verified to ensure that the suppression pool will provide adequate net positive suction head (NPSH) for the ECCS pump, recirculation volume, and vortex prevention. With the suppression pool water level less than the required limit, the required ECCS injection/spray subsystem is inoperable unless aligned to an OPERABLE CST.

When the suppression pool level is < 16 ft 6 in, the HPCS System is considered OPERABLE only if it can take suction from the CST and the CST water level is sufficient to provide the required NPSH for the HPCS pump. Therefore, a verification that either the suppression pool water level is 16 ft 6 in or the HPCS System is aligned to take suction from the CST and the CST contains 249,700 gallons of water ensures that the HPCS System can supply makeup water to the RPV.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.4 The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the required ECCS injection/spray subsystems full of water ensures that the ECCS subsystem will perform properly. This may also prevent a water hammer following an ECCS actuationinitiation signal. One acceptable method of ensuring that the lines are full is to vent at the high points.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

PERRY - UNIT 1 B 3.5-20a Revision No. 12

For Information Only RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.5 REQUIREMENTS (continued) Verifying the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow path provides assurance that the proper flow paths will be available for ECCS operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.56 Verifying that the required ECCS injection/spray subsystem can be manually aligned, and the pump started and operated for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. This SR is modified by two Notes. Note 1 states that tTesting the ECCS injection/spray subsystem may be done through the test return recirculation line is necessary to avoid overfilling the refueling cavity. Note 2 states that credit for meeting the SR may be taken for normal system operation that satisfies the SR, such as using the RHR mode of LPCI for 10 minutes. The minimum operating time of 10 minutes was based on engineering judgement.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.67 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

PERRY - UNIT 1 B 3.5-20b Revision No. 12

For Information Only RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.78 REQUIREMENTS (continued) The required ECCS subsystem is required to have a manual start capability. This Surveillance verifies that a manual initiation signal will cause the required LPCI subsystem or LPCS System can be manually aligned and started from the control room, including any necessary valve alignment, instrumentation, or controls, to transfer water from the suppression pool or CST to the RPV to start and operate as designed, including pump startup and actuation of all automatic valves to their required positions. The HPCS system is verified to start manually from a standby configuration, and includes the ability to override the RPV Level 8 injection valve isolation.

The Surveillance is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES 1. Information Notice 84-81, Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup, November 1984.

2. Information Notice 86-74, Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves, August 1986.

3. Generic Letter 92-04, Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f), August 1992.

4. NRC Bulletin 93-03, Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs, May 1993.

5. Information Notice 94-52, Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1, July 1994.

6. General Electric Service Information Letter No. 388, RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6, February 1983.

PERRY - UNIT 1 B 3.5-20c Revision No. 12

For Information Only AC Sources - Shutdown B 3.8.2 BASES LCO powered from offsite power. An OPERABLE DG, associated with a (continued) Division 1 or Division 2 Distribution System Engineered Safety Feature (ESF) bus required OPERABLE by LCO 3.8.8, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit. Similarly, when the high pressure core spray (HPCS) system is required to be OPERABLE, a separate offsite circuit to the Division 3 Class 1E onsite electrical power distribution subsystem, or an OPERABLE Division 3 DG, ensure an additional source of power for the HPCS. This additional source for Division 3 is not necessarily required to be connected to be OPERABLE. Either the circuit required by LCO Item a, or a circuit required to meet LCO Item c may be connected, with the second source available for connection. Together, OPERABILITY of the required offsite circuit(s) and the ability to manually start a DG(s) ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents involving handling of recently irradiated fuel). Automatic initiation of the required DG during shutdown conditions is specified in LCO 3.3.8.1, LOP Instrumentation.

The qualified offsite circuit(s) must be capable of maintaining rated frequency and voltage while connected to their respective ESF bus(es),

and accepting required loads during an accident. Qualified offsite circuits are those that are described in the USAR and are part of the licensing basis for the plant. One offsite circuit consists of the Unit 1 startup transformer through the Unit 1 interbus transformer, to the Class 1E 4.16 kV ESF buses through source feeder breakers for each required division. A second acceptable offsite circuit consists of the Unit 2 startup transformer through the Unit 2 interbus transformer, to the Class 1E 4.16 kV ESF buses through source feeder breakers for each required division. Additional path(s) are available, as described in the USAR and the AC Sources - Operating Bases.

The required DG must be capable of being manually startedstarting, accelerating to rated speed and voltage, and connecting to its respective ESF bus on detection of bus undervoltage, and accepting required loads.

This sequence must be accomplished within 10 seconds for Division 1 and 2 and 13 seconds for Division 3. Each DG must also be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as: DG in standby with the engine hot and DG in standby (continued)

PERRY - UNIT 1 B 3.8-36 -

Revision No. 12 I

AC Sources - Shutdown For Information Only B 3.8.2 BASES LCO with the engine at ambient conditions. Additional DG capabilities must be (continued) demonstrated to meet required Surveillances, e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode.

Proper sequencing of loads, including tripping of nonessential loads, is a required function for DG OPERABILITY. In addition, proper load sequence operation is an integral part of offsite circuit and DG OPERABILITY since its inoperability impacts the ability to start and maintain energized loads required OPERABLE by LCO 3.8.8. It is acceptable for divisions to be cross tied during shutdown conditions, permitting a single offsite power circuit to supply all required AC electrical power distribution subsystems.

As described in Applicable Safety Analyses, in the event of an accident during shutdown, the TS are designed to maintain the plant in a condition such that, even with a single failure, the plant will not be in immediate difficulty.

APPLICABILITY The AC sources required to be OPERABLE in MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the primary containment or fuel handling building provide assurance that:

a. Systems that provide core cooling are available;

b. Systems used to mitigate a fuel handling accident involving handling of recently irradiated fuel are available (due to radioactive decay, handling of fuel only requires OPERABILITY of the AC Sources when the fuel being handled is recently irradiated, i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months );

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, and 3 are covered in LCO 3.8.1.

(continued)

PERRY - UNIT 1 B 3.8-37 Revision No. 12

AC Sources - Shutdown For Information Only B 3.8.2 BASES (continued)

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.8 is not required to be met since only one offsite circuit is required to be OPERABLE. SR 3.8.1.7, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.1.15, SR 3.8.1.18, and SR 3.8.1.19 are not required to be met because DG start and load within a specified time and response on an offsite power or ECCS initiation signal is not required.

SR 3.8.1.17 is not required to be met because the required OPERABLE DG(s) is not required to undergo periods of being synchronized to the offsite circuit. SR 3.8.1.20 is not required to be met because starting independence is not required with the DG(s) that is not required to be OPERABLE. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

This SR is modified by atwo Notes which precludes . The reason for Note 1 is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of SRs, and preclude de-energizing a required 4160 V ESF bus or disconnecting a required offsite circuit during performance of Surveillances. With limited AC sources available, a single event could compromise both the required circuit and the DG. It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG is required to be OPERABLE.

Hence the NOTE provides an exception to SR 3.0.1 during the period when only one diesel generator is OPERABLE.

Note 2 states that SRs 3.8.1.12 and 3.8.1.19 are not required to be met when the associated ECCS subsystem(s) are not required to be OPERABLE. These SRs demonstrate the DG response to an ECCS signal (either alone or in conjunction with a loss of offsite power signal).

This is consistent with the ECCS instrumentation requirements that do not require ECCS signals when the associated ECCS system is not required to be OPERABLE per LCO 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control.

REFERENCES None.

PERRY - UNIT 1 B 3.8-40 -

Revision No. 12 I

v t e Letter Sequence Request
EPID:L-2020-LLA-0211, TSTF-582 (Approved, Closed)
Initiation Request Acceptance Supplement Administration Questions Answers Results Approval Other:
MONTHYEAR2020-09-24 [Table View]

L-20-166, Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements

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SUBJECT:

Enclosure:

Subject:

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL CONSIDERATION

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

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L-20-166, Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements

Text

SUBJECT:

Enclosure:

Subject:

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL CONSIDERATION

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

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