ML060530620

License Amendment Request to Revise Required Action B.1 in the Emergency Core Cooling System Instrumentation Technical Specification to Be Consistent with the Improved Standard Technical Specifications

ML060530620
Person / Time
Site:	Perry
Issue date:	02/10/2006
From:	Pearce L FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PY-CEI/NRR-2930L
Download: ML060530620 (23)

Text

rENOC Perry Nuclear Power Station 10 Center Road FirstEnergy Nuclear Operating Company Perry Ohio 44081 L. W/lam Pearce 440-280-5382 Vice President Fax: 440-280-8029 10 CFR 50.90 February 10, 2006 PY-CIEI/NRR-2930L ATTN: Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555-0001 Perry Nuclear Power Plant Docket No. 50-440

Subject:

License Amendment Request To Revise Required Action B.1 In The Emergency Core Cooling System Instrumentation Technical Specification To Be Consistent With The Improved Standard Technical Specifications Pursuant to 10 CFR 50.90, a license amendment is requested for the Perry Nuclear Power Plant (PNPP). The requested change modifies Technical Specification 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," to correct a PNPP-specific issue and to establish consistency with the improved Standard Technical Specifications (iSTS). Approval of the proposed license amendment is requested by March of 2007. The approval date is proposed to allow for Nuclear Regulatory Commission (NRC) review; the plant does not need this amendment by that date in order to continue safe full power operations. Once approved, the amendment will be implemented within 120 days.

The proposed changes have been reviewed by the Plant Operations Review Committee and Company Nuclear Review Board. The enclosure provides an evaluation of the proposed amendment. There are no regulatory commitments contained in this letter or its enclosure.

If there are any questions or if additional information is required, please contact Mr. Gregory A. Dunn, Manager - FENOC Fleet Licensing, at (330) 315-7243.

I declare under penalty of perury that the foregoing is true and correct. Executed on February _

, 2006

Enclosure:

Evaluation of the Proposed Change Attachments:

1. Proposed Technical Specification Changes (mark-up)

2. Changes to Technical Specification Bases pages, for information (mark-up) cc: NRC Region IlIl

_ZoC)

NRC Project Manager NIRC Resident Inspector State of Ohio

Enclosure PY-CEI/NRR-2930L Page 1 of 5 EVALUATION OF THE PROPOSED CHANGE

Subject:

License Amendment Request To Revise Required Action B.1 In The Emergency Core Cooling System Instrumentation Technical Specification To Be Consistent With The Improved Standard Technical Specifications Contents:

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS 5.1 Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria

1.0 DESCRIPTION

A license amendment is requested for the Peny Nuclear Power Plant (PNPP), in the form of a modification to Technical Specification (TS) 3.3.5.1, "Emergency Core Cooling System (ECCS)

Instrumentation." The proposed change would revise Required Action B.1 to correct a PNPP-specific issue, by establishing consistency with the Boiling Water Reactor (BWRI6) improved Standard Technical Specification (Reference 1).

2.0 PROPOSED CHANGE

Sub-actions B.1.2.1 and B.1.2.2, which were added into PNPP TS 3.3.5.1 during the improved Standard Technical Specification (iSTS) conversion process, are deleted. PNPP Required Action B.1 will then match the iSTS Required Action B.1. As a result, actions with a 1-hour Completion Time will only be required for the Annulus Exhaust Gas Treatment (AEGT) system if a loss of initiation capability in both divisions actually exists for an AEGT initiation Function, as originally intended.

3.0 BACKGROUND

The purpose of Required Action B.1 in the ECCS Instrumentation Specification is to check if a "loss of initiation capability" for a "feature"(') has occurred in both Divisions 1 and 2, whenever more than one instrumentation channel has become inoperable. This is explained in the Bases for Required Action B. 1, and this concept is repeated in a number of places throughout the Instrumentation specifications. However, a portion of the current wording of Required Action B.1 is PNPP-specific, and that portion:

- Includes actions that must be taken even when only a single channel has become inoperable, and a "loss of initiation capability" has not occurred in both divisions,

- Conflicts with the Bases for the Required Action, and

- Could result in an operator misinterpretation.

( The "feature(s)" which must be examined to comply with the loss of initiation capability check in Required Action B.ll are those discussed in the Bases for Specification 3.3.5.1, including the Division 1 and 2 diesel generators; the low-pressure ECCS subsystems, and the AEGT subsystems (see Attachment 2).

Enclosure PY-CEI/NRR-2930L Page 2 of 5 The background of how this PNPP-specific wording was added into Required Action B.1 provides the foundation for Section 4.0 "Technical Analysis."

During the development of the BWR iSTS, the concept of checking for a "loss of initiation capability in both divisions" when more than one instrument channel became inoperable was added into several of the instrumentation specifications.

One of the specifications that adopted such a check was TS 3.3.5.1 "Emergency Core Cooling System ('ECCS) Instrumentation." If a loss of initiation capability for feature(s) such as the low-pressure ECCS occurs in both divisions for a particular monitored Function such as Drywell Pressure-High, the supported feature(s) that would no longer initiate from that Drywell Pressure-High signal are required to be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

At PNPP, during the conversion to iSTS, additional requirements were added into TS 3.3.5.1 to address a PNPP-unique system called the Annulus Exhaust Gas Treatment (AEGT) system. The AEGT Division I and 2 subsystems are provided to reduce, by filtration, radioactive material that may be released due to a loss of coolant accident. The AEGT system function is very similar to the Standby Gas Treatment System (SGTS) used at most BWRs, except that at PNPP, one of the two subsystems of AEGT is in operation at all times, rather than both subsystems being in standby.

More delails on the AEGT system and its instnjmentation are provided in Bases Sections 3.6.4.3 and 3.3.5.1, and in USAR Sections 6.5.3 and 7.3.1.1.9.

In NUREG-1434 "Standard Technical Specifications General Electric Plants, BWR/6," the loss of initiation capability check for the instrumentation that starts the Standby Gas Treatment System is folded into Specification 3.3.6.2, entitled "Secondary Containment Isolation Instrumentation." At PNPP, due to the passive secondary containment design, there was no need for a separate isolation specification, because there are no automatic valves that need to isolate. Therefore, PNPP did not incorporate iSTS 3.3.6.2.

Since that isolation specification also contained the requirements for the ventilation system initiation instruments, at PNPP the requirement to check for a loss of ventilation system initiation capability needed to be relocated into another Specification. The ECCS Instrumentation Specification (TS 3.3.E5.1) was chosen, in Required Action B.1. This Required Action was chosen since the Required Action B.1 Functions 1.a, 2.a, 1.b, and 2.b (Low Water Level 1 and Drywell Pressure-High in Divisions 1 and 2, respectively) also actuate the AEGT subsystems.

Specifically, when the PNPP iSTS markups were prepared, a portion of the required actions from iSTS 3.3.6.2 relative to actuation of the ventilation system were copied into Required Action B.1 of TS 3.3.5.1. A copy of the iSTS 3.3.6.2 pages are included as pages 1 and 2 of Attachment 1, to show the source of the B.1.2.1 and B.1.2.2 words. In iSTS 3.3.6.2, those actions require the ventilation subsystems to either be placed in operation or declared inoperable when a loss of initiation capability has occurred. However, when those actions were transferred into TS 3.3.5.1, the loss of initiation capability requirements were not modified to conform to the format of TS 3.3.5.1. In TS 3.3.5.1, loss of initiation capability checks are self-contained in a single Condition, and there is a sentence in the Completion Time column that requires a check to determine if initiation capability has been lost in both divisions. However, in i.STS 3.3.6.2, the loss of initiation capability check is split into two Conditions (B and C), and the only portion of the requirements that were transferred into PNP*P TS 3.3.5.1 were those from Condition C.

4.0 TECHNICAL ANALYSIS

Relocating the requirements from iSTS 3.3.6.2 without modifying them to conform to the TS 3.3.5.1 loss of initiation capability format resulted in unintended consequences. Even if only one AEGT system initiation channel has become inoperable, and even if the Function is still capable of initiating

Enclosure PY-CEI/NRR-2930L Page 3 of 5 the system (i.e., enough channels remain OPERABLE or are in trip that the Function has NOT been lost), operators are currently forced to take actions that should only be required if the Function has been lost. Specifically, they have to place the associated subsystem in operation or declare it inoperable. Requiring such actions within one hour when a loss of initiation capability has not occurred in both divisions is unnecessary, and conflicts with the Bases, which correctly state that Required Action B.1 is only applicable if redundant initiation capability has been lost.

The proposed change to delete Required Actions B.1.2.1 and B.1.2.2 and their Completion Times will resolve this issue by only requiring a 1-hour action for the AEGT feature if a loss of initiation capability actually exists in both divisions for an ECCS instrumentation Function that actuates AEGT.

The change matches the iSTS wording of TS 3.3.5.1 Required Action B.1. Required Action B.1 will contain the requirements for all the "feature(s)", including the AEGT subsystems. If both divisions of AEGT should lose initiation capability from one of the applicable Functions, both subsystems will be declared inoperable. The Bases will be revised to provide a better explanation of this concept (see the example Bases markups provided in Attachment 2, for information). Bases changes are processed in accordance with the PNPP Bases Control Program.

The proposed revision to delete the sub-actions in B.1.2 will reduce the potential for operator misinterpretations. With the current format of Required Action B. 1, it appears that all the AEGT actions are self-contained within Required Action B.11.2 (sub-actions B.1.2.1 and B.1.2.2), with no AEGT requirements in B.1.1. Also, sub-actions B.1.2.1 and B.1.2.2 appear to provide the operator with an option when a loss of initiation capability situation occurs, of either (1) placing the AEGT subsystems into operation, or (2) declaring the AEGT subsystems inoperable. However, Required Action B. 1.1 is more restrictive than B.1.2 when a loss of initiation capability situation actually exists in both divisions. Required Action B.1.1 requires that if neither division of a feature addressed by this specification (such as AEGT) will initiate on a signal from one of the applicable Functions, then the "supported feature(s)" must be declared inoperable. In such a case, for AEGT, this would require both AEGT divisions to be declared inoperable. Therefore, the appearance of an option to instead place the subsystems into operation (in B.11.2) is misleading.

In a situation where a loss of initiation capability in both divisions has occurred for the AEGT feature, the deletion of sub-actions B.1.2.1 and B.1.2.2 actually has no impact on the currently required Technical Specification actions, because existing Required Action B.1.1 has already directed that both AEGT divisions must be declared inoperable. Deleting sub-actions B.1.2.1 and B.1.2.2 simply removes the requirements that were introduced for situations when channel inoperabilities do NOT result in a loss of initiation capability in both divisions. The wording that remains in Required Action B.1 ensures appropriate actions are taken when such a loss of initiation capability exists, by declarinc the supported systems inoperable, which continues to place the same limit on continued plant operation as currently exists when the plant is in this condition.

As noted above, the proposed change deletes Required Action B.1.2. Instead of deleting B.1.2, rewording Required Action B.1 was considered, to allow the option of simply placing both AEGT subsystems into operation when a loss of initiation capability occurs in both divisions. However, this alternative approach was not chosen, since the PNPP AEGT design does not include automatic restart of the heaters for the charcoal beds following a loss of power, unless a Loss of Coolant Accident (LOCA) signal is provided to the system. Since the loss of initiation capability check required by Required Action B.1 is looking for a loss of a LOCA signal from one of the Functions such as Low Water Level I or Drywell Pressure-High, the check has to assume the LOCA signal would not work. Therefore, for the check, it is assumed the heaters would not restart. The heaters are currently considered to be necessary for AEGT system OPERABILITY.

Enclosure PY-CEI/NRR-2930L Page 4 of 5 5.0 REGULATORY SAFETY ANALYSIS 5.1 Significant Hazards Consideration The proposed amendment is requesting Nuclear Regulatory Commission review and approval of changes to the Perry Nuclear Power Plant (PNPP) Technical Specifications (TS), addressing a PNPP-specific issue by revising the TS requirements to match the improved Standard Technical Specification (iSTS) requirements. The change revises TS Required Action B.1 for TS 3.3.5.1 "Emergency Core Cooling System (ECCS)

Instrumentation." Required Action B. 1 is a "loss of initiation capability" check. Therefore, sub-actions B.1.2.1 and B.1.2.2 are deleted so 1-hour actions are only required for the Annulus Exhaust Gas Treatment (AEGT) system if a "loss of initiation capability" actually exists for one or both of the Functions which actuate the AEGT subsystems.

An evaluation has been performed to determine whether or not a significant hazard is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

There are no physical modifications being made to any plant system or component.

The only change is to a Required Action within the Technical Specifications. The revised Technical Specification requirements do not impact initiators of previously evaluated accidents or transients.

The specification being revised is associated with a system used to mitigate the consequences of accidents. The change does not affect how the AEGT system is controlled, operated, or tested. The intent of Required Action B.1 for the ECCS Instrumentation, specifically, a loss of initiation capability check, is maintained by the changes being proposed. The wording of Required Action B.1 ensures appropriate actions are taken when a loss of initiation capability exists, by declaring the supported systems inoperable. This action is consistent with the current requirements.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

There are no physical modifications being made to any plant system or component, and the proposed change introduces no new method of operation of the plant, or its systems or components. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed change does not involve a significant reduction in a margin of safety.

The change to the ECCS Instrumentation Required Action continues to ensure that a check is performed to determine if one or more of the ECCS Instrumentation Functions has lost its capability to actuate the Division I and 2 low-pressure ECCS, the AEGT subsystems, and the associated diesel generators. It continues to direct appropriate actions if such a loss of initiation capability is found. Therefore, the necessary function

Enclosure PY-CEI/NRR-2930L Page 5 of 5 of the Technical Specification requirements is maintained, and the proposed changes do not involve a significant reduction in a margin of safety.

Based upon the above, it is concluded that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria These changes are consistent with the BWR/6 iSTS format and intent. There are no regulations or Regulatory Guides directly applicable to the wording of these Required Actions. There are no known industry precedents, since the need for correction of the PNPP Technical Specifications is due to the PNPP-specific nature of the existing requirements. Proposed Bases markups are provided in Attachment 2, for information.

In conclusion, based on the considerations discussed in 5.1 and 5.2 above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

The proposed Technical Specification change was evaluated against the criteria of 1 OCFR51.22 for environmental considerations. The proposed change does not significantly increase individual or cumulative occupational radiation exposures, does not significantly change the types or significantly increase the amounts of effluents that may be released off-site and, as discussed above, does not involve a significant hazards consideration. Based on the foregoing, it has been concluded that the proposed Technical Specification change meets the criteria given in IOCFR51.22(c)(9) for categorical exclusion from the requirement for an Environmental Impact Statement.

7.0 REFERENCES

1. NUREG-1434 "Standard Technical Specifications General Electric Plants, BWRI6, Revisions 0 and 3.0

2. USAR Section 6.5.3 "Fission Product Control Systems"

3. USAR Section 7.3.1.1.9 "Annulus Exhaust Gas Treatment System (AEGTS)"

4. Letter to NRC dated December 16, 1993 (PY-CEI/NRR-1732L) "License Amendment Request:

Conversion to Technical Specifications Based on NUREG-1434 "Improved BWR-6 Technical Specifications" Revision 0" PY-CEI/NRR-2930L Page 1 of 10 Secondary Containment Isolation Instrumentation 3.3.6.2 3.3 INSTRUMENTATION 3.3.6.2 Secondary Containment Isolation Instrumentation LCO 3.3.6.2 The secondary containment isolation instrumentation for each Function in hQ9E'-

Table 3.3..2sh le )E

.A ---

5 APPLICABILITY:

According to Tablto.~d, re-rt Arrest Go v Sew ACTIONS Separate Condition entry is allowed for each channel.

CONDITION IREQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Place channelin t t2(osS-~4-<vo

• Ctw.'1" C,

it oax t'

}

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Function 2 ND 24 hours for Functions other than Function 2 B. One or more auto c

Functions wit seconda ontainment isolaf capability not m

tained.

I{

B.1 Restore secondary containment isolation capability.

C. Required Action and associated Completion Time of Condition A or B not met.

C.1.1 Isolate the associated penetration flow path(.

OR 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> eLA.C bulks 5 f

& "loss 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

,+:.MS C2,.[ &,

C2.-Se

-yFP tQ-) hue

+

"P "5+e 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

>id1+/-

i.

a C.1.2 Declare associated secondary containment isolation valves inoperable.

AND A

(ERES 3.3.6.2-1 Rev. 3.0, 03/31/04 PY-CEI/NRR-2930L Page 2 of 10 Secondary Containment Isolation Instrumentation 3.3.6.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

-
-

a,'k tS; p rW 0 A~t

• C.2.1 I

.\\~~e j; 2ir

/

X toss5-of-Ca-+

F in pa4sta IO OR C.2.2 Place the associated standby gas treatment (SGT) subsystem(s) in operation.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 1 hour Declare associated SGT subsystem inoperable.

"lossP -rS

°3.:?

.-. t II N-

' Io ~~-- of - ~,c vv I -4, EJ SURVEILLANCE REQUIREMENTS NOTES------

1.

Refer to Table 3.3.6.2-1 to determine which SRs apply for each Secondary Containment Isolation Function.

2.

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 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, provided the associated Function maintains secondary containment isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.2.1 Perform CHANNEL CHECK.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.3.6.2.2 Perform CHANNEL FUNCTIONAL TEST.

[92] days SR 3.3.6.2.3

[Calibrate the trip unit.

[92] days]

SR 3.3.6.2.4 Perform CHANNEL CALIBRATION.

[18] months SR 3.3.6.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST.

.[18] months

\\\\BWR,'6 STS

3.3.6.2-2 Rev. 3.0, 03/31/04 PY-CEI/NRR-2930L Page 3 of 10 ECCS Instrumentation 3.3.5.1 3.3 INSTRUMENTATION 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation LCO 3.3.5.1 APPLICABILITY:

The ECCS instrumentation for each Function in Table 3.3.5.1-1 shall be OPERABLE.

According to Table 3.3.5.1-1.

ACTIONS Se-rteCodtin-nt--salow o e-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 3.3.5.1-1 for the channel.

B. As required by Required Action A. 1 and referenced in Table 3.3.5.1-1.

(

Nlo cl&rt So-i:

th4s rc-3,j.5,(

5

'5 B AW - ST S 6-1 BWR/

T B.1

---

NOTES----

1. Only applicable in MODES 1, 2, and 3.

2. Only applicable for Functions 1.a, 1.b, 2.a and 2.b.

Declare supported feature(s) inoperable when its redundant feature ECCS initiation capability is inoperable.

AND 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of initiation capability for feature(s) in both divisions Rev. 3.0, 03/31/04 3.3.5.1-1 PY-CEI/N RR-2930L Page 4 of 10 ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION I

REQUIRED ACTION COMPLETION TIME 4-W

!9 Ckt &0v C9 Y\\ +

e.)C tea B.2

---

NOTES-----

1. Only applicable in MODES 1, 2, and 3.

2. Only applicable for Functions 3.a and 3.b.

'C I Declare High Pressure Core Spray (HPCS) System inoperable.

AND B.3 Place channel in trip.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of HPCS initiation capability 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

• 1-C. As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

C.1

---

NOTES----

1. Only applicable in MODES 1, 2, and 3.

2. Only applicable for Functions 1.c, 1.d, 2.c, and 2.d.

Declare supported feature(s) inoperable when its redundant feature ECCS initiation capability is inoperable.

AND C.2 Restore channel to OPERABLE status.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of initiation capability for feature(s) in both divisions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> BWR/6 ST 3.3.5.1-2 RRev. 3.0, 03/31/04.

PY-CEI/U RR-2930L Page 5 of 10 ECCS Instrumentation 3.3.5.1 3.3 INSTRUMENTATION 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation LCO 3.3.5.1 APPLICABILITY:

The ECCS instrumentation for each Function in Table 3.3.5.1-1 shall be OPERABLE.

According to Table 3.3.5.1-1.

ACTIONS NOTE-------------------------------------

Separate Condition entry is allowed for each channel.

CONDITION

=

REQUIRED ACTION COMPLETION TIME A. ine or more channels inoperable.

A.1 Enter the Condition referenced in Table 3.3.5.1-1 for the channel.

Immediately (continued)

PERRY -- UNIT 1 3 3 ~ 2~m n m n o 1

3. 3-32

-Amendment No. III PY-CE-I/NRR-2930L Page 6 of 10 ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION J

REQUIRED ACTION ICOMPLETION TIME, B. As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

B. 1, NOTES--------

1. Only applicable in MODES 1, 2, and 3.

2. Only applicable for Functions I.a, L.b, 2.a and 2.b.

Declare supported feature(s) inoperable when its redundant feature ECCS initiation capability is inoperable.

CND B.1.2.1 Place the associated annulus exhaust gas treatment (AEGT) subsystem in operation.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of initiation capability for feature(s) in both divisions A,

OR

-eglare associated AEGT subsystem inoperable.

I (continued)

I PERRYr - UNIT I 3.3-33 Amendment No. 69

Attachment I PY-CEI/1\\RR-2930L Page 7 of 10 ECCS Instrumentation 3.3.5.1 ArTTAInIc CONDITION I

REQUIRED ACTTON I COMPLETION TIME

_ I B. l'continued)

B.2

---

NOTES--------

1. Only applicable in MODES 1, 2, and 3.

2. Only applicable for Functions 3.a and 3.b.

Declare High Pressure Core Spray (HPCS)

System inoperable.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of HPCS initiation capability 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND B.3 Place trip.

channel in C. As; required by Required Action A.1 and referenced in Table 3.3.5.1-1.

C.1

---

NOTES--------

1. Only applicable in MODES 1, 2, and 3.

2. Only applicable for Functions 1.c, 1.d, 1.e, 2.c, and 2.d.

Declare supported feature(s) inoperable when its redundant feature ECCS initiation capability is inoperable.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of initiation capability for feature(s) in both divisions (continued)

AND PERRsY - UN~IT i 3.3-34 Amendment No. 69

Atta,,hment 1 PY-('EI/NRR-2930L Page 8 of 10 ECCS Instrumentation 3.3.5-.1 ACTIONS (continuedl CONDITION REQUIRED ACTION COMPLETION TIME G. As required by G.1 NOTE

Required Action A.I Only applicable for and referenced in Functions 4.b, 4.d, Table 3.3.5.1-1.

4.e, 5.b, and 5.d.

Declare ADS valves 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from inoperable.

discovery of loss of ADS initiation capability in both trip systems AND G.2 Restore channel to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from OPERABLE status.

discovery of inoperable channel concurrent with HPCS or RCIC inoperable AND 8 days H'f.

Pequired associate lime of C C:, D, E, met.

Action and ed Completion Condition B, F, or G not H.l Declare associated supported feature(s) inoperable.

Immediate y I.-

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AAX s) r' r

T akfh 24-PERRY 13.3-37 PY-CEI/NRR-2930L Page 9 of 10 ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 1 of 5)

Emergency Core Cooling System Instrumentation APPLICABLE CONDmONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

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

a. Reactor Vessel W Level - Low Low L Level 1

b. Drywell Pressure-c LPCI Pump A Start - Time Delay Relay 1,2,3, 4(a),5(a) 1.2,3

-High 1,2,3, 4(a),2(a) 1,2,3

.d.

Reactor Vessel Pressure - Low (LPCS Injection Valve Permissive) 4(a),5 (a)

e. ReactorVessel Pressure-Low (LPCI Injecticn Valve Permissive) 1.2,3 I

I 1

I I

B SR SR SR SR SR B

SR SR SR SR SR C

SR SR SR C

SR SR SR SR SR B

SR SR SR SR SR C

SR SR SR SR SR B

SR SR SR SR SR E

SR SR SR SR SR 3.3.5.1.1

> 14.3 inches 3.3.5.1.42 eod 3.3.5.1.3 3.3.5.1.5 3.3.5.1. 6 3.3.5.1.1 s 1.88 psig 3.3.5.1.2 3.3.5.1.3 3.3.5.1.5 4

3.3.5.1.6 3.3.5.1.2

5. 25 3.3.5.1.4 seconds 3.3.5.1.6 3.3.5.1.1 2 482.7 psig 3.3.5.1.2 and 3.3.5.1.3 s 607.7 psig 3.3.5.1.5 3.3.5.1.6 3.3.5.1.1 2 482.7 psig 3.3.5.1.2 and 3.3.5.1.3 s 607.7 psig 3.3.5.1.5 3.3.5.1.6 3.3.5.1.1 2 490.0 psig 3.3.5.1.2 and 3.3.5.1.3 s 537.1 psig 3.3.5.1.5 3.3.5.1.6 3.3.5.1.1 a 490.0 psig l

3.3.5.1.2 and 3.3.5.1.3 s537.1 psig 3.3.5.1.5 3.3.5.1.6

.3.3.5.1.1 2 1200 gpm 3.3.5.1.2 3.3.5.1.3 3.3.5.1.5 3.3.5.1.6 4(a), 5(a)

LPCS Pump Discharge Flow - Low (Bypass) 1,2,3, 4(a),5(a)

(continued)

(a) When associated subsystem(s) are required to be OPERABLE.

(b)

Also required to Initiate the associated diesel generator and AEGT subsystem.

PERRY -

4I.&

3 PEIMY - UNI

.3-39 hn~xbc -t No.093 PY-CEI/NRR-2930L Page 10 of 10 ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 2 of 5)

Emergency Core Cooling System Instrumentation APPLICABLE CONDMONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE CONDmONS FUNCTION ACTION A.1 REQUIREMENTS VALUE FUNCTION

1.

Low Pressure Coolant Injection-A (LPCI) and Low Pre.sure Core Spray (LPCtS) Subsystems (continued)

g. LPCI Pump A Discharge Flow - Low (Bypass)

h. Manual Initiation 1.2.3.

4(a),5(a) 1.2,3, 1

1 E

SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 C

SR 3.3.5.1.6 2 1450 gpm NA 1.2.3.

1C T.

1,2,3,51aC i SR 3.3.5.1.4 SR 3.3.5.1.6

d.

Reactor Vessel 1.2.3 1 per C

Pressure - Low (LPCI subsystem Injection Valve P'ermissive) 0 A.--

D e

Pr'xr &.

c,(a) 5(a) 1 per B

subsystem t~

~

~

b so, A

^~.A SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1,5 SR 3.3.5.1.6

> 490.0 psig and s 537.1 psig for LPCI B.

and k 490.0 psig and s 537.1 psig for LPCI C k 490.0 psig and s 537.1 psig for LPCI B; and 2 490.0 psig and s 537.1 psig for LPCI C I

I SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 I

I I

I (continued)

(a) When associated subsystem(s) are required to be OPERABLE.

C

iequorequired to initiate the associated diesel enerator and AEGT su POW - lNIT 1 3.3-40 1Amrii t l. 93 PY-CEIVNRR-2930L CS Instrumentation Page 1 of 7 EGG Intruenttio BASES U

Lui"J i

A V

BACKGROUND Diesel Generators (continued) standby conditions (rated voltage and speed. with the OG output breaker open). The DGs will only energize their respective Engineered Safety Feature (ESF) buses if a loss of offsite power occurs. (Refer to Bases for LCO 3.3.8.1.)

=AEGI h

c<9 S t

The AEGT subsystems may be initiated by either automatic or manual means. Automatic initiation occurs for conditions of X 44 1xt 5

9a~5Q--

Reactor Vessel Water Level -Low Low Low. Level 1 or Drywell Pressure-High. Each of these diverse variables is monitored by two redundant transmitters per AEGT-subsystem which are.

r i-,'tA g-z v r in turn, connected to two trip units.

The outputs of the four divisionalized trip units (two trip units from each of i -

-t -;

the two variables) are connected to relays whose contacts are arranged in a one-out-of-two taken twice logic. The AEGT subsystems receive their initiation signals from the associated Divisions' ECCS logic (i.e.. Division 1 AEGT subsystem receives an initiation signal from Division 1 ECCS (LPCS and LPCI A). and Division 2 AEGT subsystem receives an initiation signal from Division 2 ECCS (LPCI B and LPCI C)).

The AEGT subsystems can also be started manually from the control room. The AEGT initiation logic is reset by resetting the associated ECCS initiation logic.

APPLICABLE SAFETY ANALYSES LCO. and APPLICABILITY The actions of the ECCS are explicitly assumed in the safety analyses of References 1. 2. and 3. The ECCS is initiated to preserve the integrity of the fuel cladding by limiting the post LOCA peak cladding temperature to less than the 10 CFR 50.46 limits.

ECCS instrumentation satisfies Criterion 3 of the NRC Policy Statement. Certain instrumentation Functions are retained for other reasons and are described below in the individual Functions discussion.

The OPERABILITY of the ECCS upon the OPERABILITY of the channel Functions specified instrumentation is dependent individual instrumentation in Table 3.3.5.1-1.

Each (continued)

PERRY - UNIT 1 E, 3.3-94 Revision No. 0 PY-CEI/NFRR-2930L Page 2 of 7 ECCS Instrumentation B 3.3.5.1 WOR

@3RDiwi BASES APPLICABLE SAFETY ANALYSES.

isron

-,4 Low Pressure Core Sorav and Low Pressure Coolant Iniection Systems LULl, CIU APPLICABILITY l a. 2.a Reactor Vessel Water Level-Low Low Low. Level 1 v (continued)

A F&zrs~

Low reactor pressure vessel (RPV) water level indicates that the capability to cool the fuel may be threatened.

Should RPV wa ter level decrease too far, fuel damage could result.

The low Pressure ECCS and associated OGs are initiated at Level 1 to ensure tnat core spray and flooding functions are available to prevent or minimize fuel damage.

The Reactor Vessel Water Level-Low Low Low, Level 1 is one of the Functions assumed to be OPERABLE and capable of initiating the ECCS during the transients analyzed in References 1 and 3. In addition, the Reactor Vessel Water Level-Low Low Low, Level 1 Function is assumed in the analysis of the DBA LOCA (Ref. 2). The core cooling function of the ECCS, along with the scram action of the Reactor Protection System (RPS), ensures that the fuel peak claddingtl 0

fino remains below the limits of 10 CFR 50.4 r&A-&it S+tev I

215 i_

-;g+at at Le.ve-1 A-

+

Reactor Vessel Water Level-Low Low Low, Leve signals are a

initiated from four level transmitters that sense the difference between the pressure due to a constant column of

.3 water (reference leg) and the pressure due to the actual i t rG, water level (variable leg) in the vessel. The Reactor c b Vessel Water Level-Low Low Low, Level 1 Allowable Value is chosen to allow time for the low pressure core flooding ej systems to activate and provide adequate cooling.

h or*)

Stya aezk2. z%

,S&iss D'10.

+L.a

-',J.

Z.wiZ,'t MLS~ <A-t tW -x-~

s)

Two channels of Reactor Vessel Water Level-Low Low Low, Level 1 Function per associated Division are only required &i.tO K to be OPERABLE when the associated ECCS. DG. or AEGT subysIm is rFequi red to De UILKAEbL.

to ensure, that no a

i instrument failure can preclude ECCS initiation.

Gois (Two channels input to LPCS and LPCI A. while the other two channels input to LPCI B and LPCI C.)

Refer to LCO 3.5.1 and LCO 3.5.2. "ECCS-Shutdown," for Applicability Bases for the low Dressure ECSsubsystems: LCO 3.8.1, "AC ounces-Uperating" and LCU73.8.2, "AC Sources-Shutdown," for Applicability Bases for the DGs: and LCO 3.6.4.3.

"Annulus Lxhaust Gas Treatment (AEGT) System," for Applicability Bases for AEGT System.

11;

11

(continued)

PERRD

-_ MITT 1 VIIA V4 4

B 3. 3/-°5/

Revision No. 3 PY-CEI/NRR-2930L ECCS Instrumentation Page 3 of 7 B 3.3.5.1 BASE:S 2 7 2 io g E, APPLICABLE 1.b. 2.b.

Drywell Pressure-High j SAFETY ANALYSES.

A LCO. and High pressure in the drywell could indicate a break in the APPLICABILITY reactor coolant pressure boundary (RCPB).

The low pressure.

(continued ECCS and associated DGs are initiated upon receipt of the

/ ll5y l

Press'ure-=-gl function in order to minimize the possibility of fuel damage. The Drywell Pressure-High Function is assumed in the analysis of the DBA LOCA (Ref.

2).

The core cooling function of the ECCS along with the scram action of the RPS. ensures that the fuel peak cladding tmea e mal elow the limits-of 10 CFR 50.46.47ka AL essure signals ar Tia ted from tour Aressure ransmiters that sense drywell pressure.

The llowable Value was selected to be as low as possible and be

":3 indicative of a LOCA inside primary containment. Negative

\\

barometric fluctuations are accounted for in the Allowable 6-- Fw -ovCS Value.

AL ba 2,^ '

The Drywell Pressure-High Function is required to be OPERABLE when the associated ECCS. DGs or AEGT subsystems Wifi;G%_

a'er e,

are required to be OPERABLE in conjunction witn times when the primary containment is required to be OPERABLE.

Thus.

'5 c

AfCr Sfour channels of the LPCS and LPCI Drywell Pressure-High

\\

aktt1 X 5'ws4 Function are required to be OPERABLE in MODES 1. 2. and 3 to ensure that no single instrument failure can preclude EGGS auks o/

-Lu_

>Spy i initiation.

(Two channels input to LPCS and LPCI A. while art' eok. 2t\\

S the other two channels input to LPCI B and LPCI C.)

In MODES 4 and 5. the Drywel] Pressure-High Function is not I

4/

required since there is insufficient energy in the reactor l

Ž".-

tS4 to-pressurize the primary containment to Drywell Pressure-High setpoint.

t x'd Refer to LCO 3.5.1 for Applicability Bases for the low 5 ressure FCCS substems; LCO 3.8.1 for Applicability Bases and 4.3 for Applicability Bases for the 1.c. 2.c.

Low Pressure Coolant Injection Pump A and Pump B Start-Time Delay Relay The purpose of this time delay is to stagger the start of the two ECCS pumps that are in each of Divisions 1 and 2.

thus limiting the starting transients on the 4.16 kV emergency buses.

This Function is only necessary when power is being supplied from the standby power sources (DG).

(continued)

PERRY - UNIT 1 13 3.3-97 P1Revision No. 3

Attachmrrent 2 PY-CEI/NRR-2930L ECCS Instrumentation Page4of7 B 3.3.5.1 BASES APPLICABLE 4.f. 5.e.

Manual Initiation (continued)

SAFETY ANALYSES.

LCO, and There is no Allowable Value for this Function since the APPLICABILITY channel is mechanically actuated based solely on the position of the push buttons. Four channels of the Manual Initiation Function (two channels per ADS trip system) are only required to be OPERABLE when the ADS is required to be OPERABLE. Refer to LCO 3.5.1 for ADS Applicability Bases.

ACTIONS A Note has been provided to modify the ACTIONS related to ECCS 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 ECCS instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable ECCS instrumentation channel.

A.1 Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.1-1.

The applicable Condition specified in the table is Function dependent.

Each time a channel is discovered to be inoperable.

Condition A is entered for that channel and provides for transfer to the appropriate subsequent Condition.

B.1. B.2. and B.3 Required Actions B.1 and B.2 are intended to ensure that appropriate actions are taken if multiple, inoperable.

untripped channels within the same Function (or in some cases, within the same monitored parameter) result in redundant automatic initiation qapabilit 4,eing lost for the feature(s). Required Action B.1' eaturd3kould be those that are initiated by Functions 1.a. l.b, 2.a. and 2.b (e.g., low pressure ECCf.

The Required Action B.2 feature

,,__-:;;__ _ __ _ * ~~(,-_.----___continued

( sra,.k or J-;~rt) 5Uor Q

Ct.z.~ ^+Jr)

J4S; wt

• 4re 7*ats~u_

re-S IN t r,

c- "&e, PERRY - UNIT 1 B 3.3-110 evision No. 1 K;kru&A k\\

ff G A

)

p PY-CEI/NRR-2930L ECCS Instrumentation Page5of7 B 3.3.5.1 BASES

[

7 ACTIONS B.1, B.2, and-B,3 (continued) r would be HPC.:

or Required Action B.1. redundant automatic initi-l;ion capability is lost if either (a) one or more Function L.a channels and one or more Function 2.a channel are inoperable and untripped, or (b) one or more Function 1.b channels and one or more Function 2.b channels are inop le and untripped.

For Divisions 1 and 2. sinee each inoperab-c channel would have Required Act o B.1 a

(refer to ACTIONiS Note). e n

chae w o

quire the affected portion of the a--ociat-d Division of loW,-'-- - -

prcurcs CC

---

-G and AEGT S"-tem to be declared ft° a,

-inopcrabl. Howev.- --- clannels 3 oth Divisionstare rinopera rpe Andg er pe tre

{ t7_

a concurrently for th hnen-i oh iiin;ti-<p-pcrit#

5

'SAKS. I4rUtL r lt\\ in the ff t d portions oth Divisions of ECC I

?oi. ;s DG and AEGT declaredkinoperable Cr~ +

CIA bppItcit^S

'.For Required Action redundant autom ic initiation

'j+W^ Jo 6u "apab'ls lost if two Function 3.a or two Function 3.

channel'y re inoperable and untripped in the same trip system;[ 11 this situation (loss of redundant automatic initiatSfn capability), the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance of Required Action B.3 is not approprie and the feature(s) associated with the inoperable. unt rp d channels must be declared inoperable within 1 hour17fl noted (Note 1 to Required Action B.1 and Required Ec~on B.2). the two Required Actions are only applicable in MODES 1, 2, and 3. In MODES Pv CieAx FQ-+p2_ 4 and 5. the specific initiation time of the ECCS is not assumed and the probability of a LOCA is lower. Although a of{

44-.Q--

total loss of initiation capability for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed OA by Required Action B.3 during MODES 4 and 5, additional

{

-(5r controls are imposed in ORM 6.2.9. Notes are also provided (Note 2 to Required Action B.1 and Required Action B.2) to

° U 3 )12) delineate which Required Action is applicable for each Function that requires entry into Condition B if an K

. 1?

re3 J associated channel is inoperable. This ensures that the pro er loss of initiation capability check is performed.

e

~ ~

continued)

PERRY --

UNIT 1 B 3.3-111 Revision No. 4

Clean Version of the Bases Mark-ups on paaes B 3.3-110 & B 3.3-111 Attacii/ent 2 PY-CE I/N RR-2930L Page 6 of 7 pg. B 3.3-110 B.l, B.2, and 12.3 L~

Required Actions B.1 and B.2 are intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the same Function (or in some cases, within the same monitored parameter) result in redundant automatic initiation capability being lost for the feature(s). Required Action B.1 "features" would be those that are initiated by Functions l.a, l.b, 2.a, and 2.b (e.g.,

Division 1 and 2 diesel generators, low pressure ECCS, or the AEGTT subsystems); B.1 features do not include those separately addressed with their own Instrumentation Specification (e.g., RHR Containment Spray Instrumentation). The Required Action B.2 feature pg. B 3.3-111 would be HPCS.

For Required Aclion B.1, redundant automatic initiation capability is lost for a feature if either (a) one or more of its Function l.a channels and one or more of its Function 2.a channels are inoperable and untripped, or (b) one or more of its Function l.b channels and one or more of its Function 2.b channels are inoperable and untripped.

Since Required Action B.1 is only applicable if channels supporting both Divisions of a feature are inoperable and untripped, the affected portions of both Divisions of ECCS, DG and AEGT are declared inoperable concurrently (within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery).

For Required Action B.2, redundant automatic initiation capability is lost if two Function 3.a or two Function 3.b channels are inoperable and untripped in the same trip system.

In this situation (loss of redundant automatic initiation capability), the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance of Required Action B.3 is not appropriate and the feature(s) associated with the inoperable, untripped channels must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

As noted (Note 1 to Required Action B.1 and Required Action B.2), the two Required Actions are only applicable in MODES 1, 2, and 3. In MODES 4 and 5, the specific initiation time of the ECCS is not assumed and the probability of a LOCA is lower.

Although a total loss of initiation capability for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed by Required Action B.3 during MODES 4 and 5, additional controls are imposed in ORM 6.2.9. Notes are also provided (Note 2 to Required Action B.1 and Required Action B.2) to delineate which Required Action is applicable for each Function that requires entry into Condition B if an associated channel is inoperable.

This ensures that the proper loss of initiation capability check is performed.

'i PY-CEI/NRR-2930L Page 7 of 7 ECCS Instrumentation B 3.3.5.1 LIU L

UP L j L \\ L LA BASES

I1N, AL ACTIONS B.1. B.2. and B-3 (continued)

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

For Required Action B.1, the Com letion Time only begins upon discovery that a redundarq ature in both Divisions (e.g.. any Division 1 ECCS aq A ision 2 ECC ) cannot be automatically initiated due t operable. un ripped channels within the same monitored parameter as described in aragraph above. For Required Action.2, the KComp ie only begins upon dis y that the HPCS

'IV.

vA System cannot be aut oma iated due to two inoperable, untripped channels for the associated Function

^

LfD.

As *thin the same trip system. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable

>Nior

4. -

4 because it minimizes risk while allowing time for restoration or tripping of channels.

Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been shown to be acceptable (Ref. 4) to permit restoration of any inoperable channel to OPERABLE status. If the inoperable 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 B.3.

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 inoperable channel in trip would result in an initiation). Condition H must be entered and its Required Action taken.

(continued)

PERRY - UNIT 1 B 3.3-112 Revision No. 1