Text

Issuance of Amendment Concerning Adoption of TSTF-425, Relocate Surveillance Frequencies to Licensee Control (CAC No. MF3720) (L-14-106)
	ML15307A349
Person / Time
Site:	Perry
Issue date:	02/23/2016
From:	Kimberly Green; Plant Licensing Branch III
To:	Hamilton D; FirstEnergy Nuclear Operating Co
	Green K, NRR/DORL/LPLIII-1
References
	CAC MF3720, L-14-106
	Download: ML15307A349 (165)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 23, 2016 Mr. David B. Hamilton Site Vice President FirstEnergy Nuclear Operating Company Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - ISSUANCE OF AMENDMENT CONCERNING ADOPTION OF TSTF-425, "RELOCATE SURVEILLANCE FREQUENCIES TO LICENSEE CONTROL" (CAC NO. MF3720) (L-14-106)

Dear Mr. Hamilton:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 171 to Facility Operating License No. NPF-58 for Perry Nuclear Power Plant, Unit No. 1. The amendment consists of changes to the technical specifications (TSs) in response to your application dated March 25, 2014, as supplemented by letters dated October 7, 2014, and August 24, 2015.

The amendment modifies the TSs by relocating specific surveillance frequencies to a licensee-controlled program. The proposed changes are consistent with the NRG-approved Technical Specifications Task Force (TSTF) Traveler, TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative Sb."

D. Hamilton A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Kimberly J. Green, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosures:

1. Amendment No. 171 to NPF-58

2. Safety Evaluation cc w/encls: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION, LLC OHIO EDISON COMPANY DOCKET NO. 50-440 PERRY NUCLEAR POWER PLANT, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 171 License No. NPF-58

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for license filed by FirstEnergy Nuclear Operating Company, et al. (the licensee, FENOC), dated March 25, 2014, as supplemented by letters dated October 7, 2014, and August 24, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-58 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 171, are hereby incorporated into the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of its issuance and shall be implemented within 120 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

()JO.~/-

David J. wlona, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-58 and Technical Specifications Date of Issuance: February 23, 2016

ATTACHMENT TO LICENSE AMENDMENT NO. 171 FACILITY OPERATING LICENSE NO. NPF-58 DOCKET NO. 50-440 Replace the following pages of the Facility Operating License and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT License NPF-58 License NPF-58 TSs TSs REMOVE INSERT REMOVE INSERT REMOVE INSERT REMOVE INSERT 1.0-6 1.0-6 3.3-69 3.3-69 3.6-26 3.6-26 3.8-9 3.8-9 3.1-10 3.1-10 3.3-72 3.3-72 3.6-30 3.6-30 3.8-10 3.8-10 3.1-13 3.1-13 3.3-75 3.3-75 3.6-33 3.6-33 3.8-11 3.8-11 3.1-17 3.1-17 3.3-79 3.3-79 3.6-35 3.6-35 3.8-12 3.8-12 3.1-19 3.1-19 3.4-4 3.4-4 3.6-38 3.6-38 3.8-13 3.8-13 3.1-21 3.1-21 3.4-6 3.4-6 3.6-39 3.6-39 3.8-14 3.8-14 3.1-22 3.1-22 3.4-7 3.4-7 3.6-41 3.6-41 3.8-15 3.8-15 3.1-25 3.1-25 3.4-8 3.4-8 3.6-43 3.6-43 3.8-23 3.8-23 3.2-1 3.2-1 3.4-9 3.4-9 3.6-47 3.6-47 3.8-25 3.8-25 3.2-2 3.2-2 3.4-11 3.4-11 3.6-48 3.6-48 3.8-26 3.8-26 3.2-3 3.2-3 3.4-13 3.4-13 3.6-50 3.6-50 3.8-27 3.8-27 3.3-3 3.3-3 3.4-18 3.4-18 3.6-52 3.6-52 3.8-33 3.8-33 3.3-4 3.3-4 3.4-20 3.4-20 3.6-55 3.6-55 3.8-34 3.8-34 3.3-5 3.3-5 3.4-23 3.4-23 3.6-58 3.6-58 3.8-37 3.8-37 3.3-6 3.3-6 3.4-25 3.4-25 3.6-60 3.6-60 3.8-39 3.8-39 3.3-12 3.3-12 3.4-27 3.4-27 3.6-60a 3.6-60a 3.9-1 3.9-1 3.3-13 3.3-13 3.4-29 3.4-29 3.6-64 3.6-64 3.9-2 3.9-2 3.3-14b 3.3-14b 3.4-32 3.4-32 3.6-67 3.6-67 3.9-3 3.9-3 3.3-14c 3.5-4 3.5-4 3.6-69 3.6-69 3.9-4 3.9-4 3.3-16 3.3-16 3.5-5 3.5-5 3.6-70 3.6-70 3.9-7 3.9-7 3.3-17 3.3-17 3.5-7 3.5-7 3.6-72 3.6-72 3.9-8 3.9-8 3.3-22 3.3-22 3.5-8 3.5-8 3.7-2 3.7-2 3.9-9 3.9-9 3.3-24 3.3-24 3.5-9 3.5-9 3.7-3 3.7-3 3.9-12 3.9-12 3.3-25 3.3-25 3.5-11 3.5-11 3.7-6 3.7-6 3.9-15 3.9-15 3.3-27 3.3-27 3.5-12 3.5-12 3.7-7 3.7-7 3.10-5 3.10-5 3.3-28 3.3-28 3.6-7 3.6-7 3.7-10 3.7-10 3.10-8 3.10-8 3.3-30 3.3-30 3.6-8 3.6-8 3.7-12 3.7-12 3.10-11 3.10-11 3.3-31 3.3-31 3.6-15 3.6-15 3.7-13 3.7-13 3.10-12 3.10-12 3.3-38 3.3-38 3.6-16 3.6-16 3.7-14 3.7-14 3.10-14 3.10-14 3.3-38a 3.6-17 3.6-17 3.7-15 3.7-15 3.10-15 3.10-15 3.3-46 3.3-46 3.6-19 3.6-19 3.7-18 3.7-18 3.10-17 3.10-17 3.3-53 3.3-53 3.6-20 3.6-20 3.7-20 3.7-20 3.10-21 3.10-21 3.3.53a 3.3.53a 3.6-21 3.6-21 3.8-5 3.8-5 3.10-22 3.10-22 3.3-62 3.3-62 3.6-23 3.6-23 3.8-6 3.8-6 5.0-15c 5.0-15c 3.3-66 3.3-66 3.6-25 3.6-25 3.8-7 3.8-7 5.0-15d 3.8-8 3.8-8

renewal. Such sale and leaseback transactions are subject to the representations and conditions set forth in the above mentioned application of January 23, 1987, as supplemented on March 3, 1987, as well as the letter of the Director of the Office of Nuclear Reactor Regulation dated March 16, 1987, consenting to such transactions. Specifically, a lessor and anyone else who may acquire an interest under these transactions are prohibited from exercising directly or indirectly any control over the licenses of PNPP Unit 1. For purposes of this condition the limitations of 10 CFR 50.81, as now in effect and as may be subsequently amended, are fully applicable to the lessor and any successor in interest to that lessor as long as the license for PNPP Unit 1 remains in effect; these financial transactions shall have no effect on the license for the Perry Nuclear facility throughout the term of the license.

(b) Further, the licensees are also required to notify the NRC in writing prior to any change in: (i) the terms or conditions of any lease agreements executed as part of these transactions; (ii) the PNPP Operating Agreement; (iii) the existing property insurance coverage for PNPP Unit 1; and (iv) any action by a lessor or others that may have an adverse effect on the safe operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now and hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level FENOC is authorized to operate the facility at reactor core power levels not in excess of 3758 megawatts thermal (100% power) in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 171 are hereby incorporated into the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Antitrust Conditions

a. FirstEnergy Nuclear Generation, LLC and Ohio Edison Company Amendment No. 171

Definitions 1.1 1.1 Definitions (continued)

SHUTDOWN MARGIN (SOM) SOM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that:

a. The reactor is*xenon free.

b. The moderator temperature is ~ 68°F.

corresponding to the most reactive state: and

c. All control rods are fully inserted except for the single control rod of highest reactivity worth. which is assumed to be fully withdrawn.

With control rods not capable of being fully inserted. the reactivity worth of these control rods must be accounted for in the determination of SOM.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

TURBINE BYPASS SYSTEM The TURBINE BYPASS SYSTEM RESPONSE TIME consists RESPONSE TIME of two components:

a. The time from initial movement of the main turbine stop valve or control valve until 80%

of the turbine bypass capacity is established:

and

b. The time from initial movement of the main turbine stop valve or control valve until initial movement of the turbine bypass valve.

The response time may be measured by means of any series of sequential. overlapping. or total steps so that the entire response time is measured.

PERRY - UNIT 1 1. 0-6 Amendment No. 171

Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Determine the position of each control rod. In accordance with the Surveillance Frequency Control Program SR 3.1.3. 2 -------------------NOTE--------------------

Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RPCS.

Insert each withdrawn control rod at least In accordance one notch. with the Surveillance Frequency Control Program SR 3.1. 3. 3 Verify each control rod scram time from In accordance fully withdrawn to notch position 13 is with

~ 7 seconds. SR 3.1.4.1.

SR 3.1.4.2.

SR 3.1.4.3. and SR 3.1.4.4 (continued)

PERRY - UNIT 1 3.1-10 Amendment No.171

Control Rod Scram Times 3.1.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.4. 2 Verify. for a representative sample. each In accordance tested control rod scram time is within the with the limits of Table 3.1.4-1 with reactor steam Surveillance dome pressure ~ 950 psig. Frequency Control Program SR 3.1.4.3 Verify each affected control rod scram time Prior to is within the limits of Table 3.1.4-1 with declaring any reactor steam dome pressure. control rod OPERABLE after work on control rod or CRD System that could affect scram time SR 3.1.4.4 Verify each affected control rod scram time Prior to is within the limits of Table 3.1.4-1 with exceeding 40%

reactor steam dome pressure ~ 950 psig. RTP after fuel movement within the affected core cell AND Prior to exceeding 40% RTP after work on control rod or CRD System that could affect scram time PERRY - UNIT 1 3.1-13 Amendment No.171

Control Rod Scram Accumulators 3.1.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2 Declare the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months associated control rod inoperable.

D. Required Action and D.l --------NOTE---------

associated Completion Not applicable if all Time of Required inoperable control Action B.l or C.l not rod scram met. accumulators are associated with fully inserted control rods, Place the reactor Immediately mode switch in the shutdown position.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify each control rod scram accumulator In accordance pressure is ~ 1520 psig. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.1-17 Amendment No . 171

Control Rod Pattern 3.1.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Nine or more OPERABLE B.l --------NOTE---------

control rods not in Affected control rods compliance with BPWS. may be bypassed in RACS in accordance with SR 3.3.2.1.9 for insertion only.

Suspend withdrawal of Immediately control rods.

AND B.2 Place the reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months mode switch in the shutdown position.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.l Verify all OPERABLE control rods comply In accordance with BPWS. with the Survei 11 ance Frequency Control Program PERRY - UN IT I 3. 1-19 ~endment No . 171

SLC System 3.1. 7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3 .1. 7 .1 Verify available volume of borax-boric acid In accordance solution is within the limits of Figure with the 3.1.7-1. Surveillance Frequency Control Program SR 3.1. 7.2 Verify temperature of borax-boric acid In accordance solution is ~ 70°F. with the Surveillance Frequency Control Program SR 3.1. 7.3 Verify temperature of pump suction piping In accordance is ~ 70°F. w.ith the Surveillance Frequency Control Program SR 3.1. 7.4 Verify continuity of explosive charge. In accordance with the Surveillance Frequency Control Program SR 3.1. 7.5 Verify the concentration of boron in In accordance solution is within the limits of with the Figure 3.1. 7-1. Surveillance Frequency Control Program AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after water or boron is added to solution AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after solution temperature is restored to

~ 70°F (continued)

PERRY - UNIT 1 3.1-21 Amendment No. 171

SLC System 3.1. 7 URVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.7.6 Verify each SLC subsystem manual. power In accordance operated. and automatic valve in the flow with the path that is not locked. sealed. or Surveillance otherwise secured in position. is in the Frequency correct position. or can be aligned to the Control Program correct position.

SR 3.1. 7. 7 Verify each pump develops a flow rate In accordance

~ 32.4 gpm at a discharge pressure with the

~ 1220 psig. Inservice Testing Program SR 3.1. 7. 8 Verify flow through one SLC subsystem from In accordance pump into reactor pressure vessel. with the Surveillance Frequency Control Program SR 3.1. 7. 9 Veri.fy all heat traced piping between In accordance storage tank and pump suction is unblocked. with the Surveillance Frequency Control Program AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after pump suction piping temperature is restored to

~ 70°F PERRY - UNIT 1 3.1-22 Amendment No. 171

SDV Vent and Drain Valves 3.1.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3 .1. 8 .1 -------------------NOTE--------------------

Not required to be met on vent and drain valves closed during performance of SR 3. 1. 8. 2.

Verify each SDV vent and drain valve is In accordance open. with the Surveillance Frequency Control Program SR 3. 1. 8. 2 Cycle each SDV vent and drain valve to the In accordance fully closed and fully open position. with the Surveillance Frequency Control Program SR 3.1. 8. 3 Verify each SDV vent and drain valve: In accordance with the Surveillance

a. Closes in ~ 30 seconds after receipt Frequency of an actual or simulated scram Control Program signal ; and

b. Opens when the actual or simulated scram signal is reset.

PERRY - UNIT 1 3.1-25 Amendment No. 171

APLHGR 3.2.1 3.2 POWER DISTRIBUTION LIMITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

LCO 3.2.1 All APLHGRs shall be less than or equal to the limits specified in the COLR.

APPLICABILITY: THERMAL POWER 2 23.8% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any APLHGR not within A. l Restore APLHGR(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limits. within limits.

B. Required Action and B.1 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to < 23. 8% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3. 2 .1.1 Verify all APLHGRs are less than or equal Once within to the limits specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 2 23.8% RTP AND In accordance with the Surveillance Frequency Control Program PERRY - UN IT 1 3.2-1 Amendment No. 171

MCPR 3.2.2 3.2 POWER DISTRIBUTION LIMITS 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR)

LCD 3. 2. 2 All MCPRs sha 11 be greater than or equal to the MCPR operating limits specified in the COLR.

APPLICABILITY: THERMAL POWER~ 23.8% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any MCPR not within A. l Restore MCPR(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limits. within limits.

B. Required Action and B.l Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to< 23.8% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.l Verify all MCPRs are greater than or equal Once within to. the limits specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after

~ 23.8% RTP AND In accordance with the Survei l lance Frequency Control Program PERRY - UN IT 1 3.2-2 Amendment No.171

LHGR 3.2.3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 LINEAR HEAT GENERATION RATE (LHGR)

LCO 3.2.3 All LHGRs shall be less than or equal to the limits specified in the COLR.

APPLICABILITY: THERMAL POWER ~ 23.8% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TI ME A. Any LHGR not within A.1 Restore LHGR(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limits. within limits.

B. Required Action and B.1 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to< 23.8% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify all LHGRs are less than or equal to Once within*

the limits specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after

~ 23.8% RTP AND In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.2-3 Amendment No. 171

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1. Refer to Table 3.3.1.1-1 to determine which SRs apply for each RPS 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains RPS trip capability.

SURVEILLANCE FREQUENCY SR 3.3.1.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.2 ------------------NOTE-------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER~ 23.8% RTP.

Verify the absolute difference between In accordance the average power range monitor (APRM) with the channels and the calculated power Surveillance

~ 2% RTP while operating at ~ 23.8% RTP. Frequency Control Program SR 3.3.1.1.3 Ad~ust the channel to conform to a In accordance ca ibrated flow signal. with the Surveillance Frequency Control Program SR 3.3.1.1.4 --------------., ---NOTE ---*_ ---------------

Not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

PERRY - UNIT 1 3.3-3 Amendment No . 171

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.5 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequenc.p Control rogram SR 3.3.1.1.6 Verify the source range monitor CSRM) and Prior to intermediate range monitor (IRM) channels withdrawing overlap. SRMs f rbm the fully inserted position SR 3.3.1.1.7 ------------------NOTE-------------------

Only re~uired to be met during entry into MODE 2 rom MODE 1.

Verify the IRM and APRM channels overlap. In accordance with the Surveillance Frequenc.p Control rogram SR 3.3.1.1.8 Calibrate the local power range monitors. In accordance with the Surveillance Frequency .

Control Program SR 3.3.1.1.9 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.10 Calibrate the trip unit. In accordance with the Surveillance Frequenc.p Control rogram (continued)

PERRY - UNIT 1 3.3-4 Amendment No . 171

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.11 ------------------NOTES------------------

1. Neutron detectors and flow reference transmitters are excluded.

2. For Function 2.a. not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3. 3.1.1. 12 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.13 ------------------NOTES------------------

1. Neutron detectors are excluded.

2. For IRMs. not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.14 Verify the APRM flow Biased Simulated In accordance Thermal-High time constant is within the with the limits specified in the COLR. Surveillance Frequency Control Program SR 3.3.1.1.15 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program

<continued)

PERRY - UN IT 1 3.3-5 Amendment No. 171

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.16 Verify Turbine Stop Valve Closure and In accordance Turbine Control Valve Fast Closure Trip with the Oil Pressure-Low Functions are not Surveillance bypassed when THERMAL POWER is ~ 38% RTP. Frequency Control Program SR 3.3.1.1.17 Calibrate flow reference transmitters. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.18 ------------------NOTES------------------

1. Neutron detectors are excluded.

2. For Functions 3. 4 and 5 in Table 3.3.1.1-1, the channel sensors are excluded.

Verify the RPS RESPONSE TIME is within In accordance limits. with the Surveillance Frequency Contra l Program SR 3. 3 .1.1.19 Perform CHANNEL FUNCTIONAL TEST In accordance with the Surveillance Frequency Control Program PERRY - UN IT 1 3.3-6 Amendment No. 171

SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.1.2-1 to determine which SRs apply for each applicable MODE or other specified conditions.

SURVEILLANCE FREQUENCY SR 3.3.1.2.l Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3. 1. 2. 2 ------------------NOTES------------------

1. Only required to be met during CORE ALTERATIONS.

2. One SRM may be used to satisfy more than one of the following.

Verify an OPERABLE SRM detector is In accordance located in: with the Surveillance

a. The fueled region; Frequency Control Program

b. The core quadrant where CORE ALTERATIONS are being performed when the associated SRM is included tn the fueled region: and

c. A core quadrant adjacent to where CORE ALTERATIONS are being performed.

when the associated SRM is included in the fueled region.

SR 3 . 3 . 1. 2 . 3 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program (continued)

PERRY - UN IT 1 3.3-12 Amendment No . 171

SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.2.4 ------------------NOTE-------------------

Not required to be met with less than or equal to four fuel assemblies adjacent to the SRM and no other fuel assemblies in the associated core quadrant.

Verify count rate is:

In accordance with the

a. ~ 3.0 cps. or Surveillance Frequency

b. ~ 0.7 cps with a signal to noise Control Program ratio ~ 2:1.

SR 3.3.1.2.5 ------------------NOTE-------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after IRMs on Range 2 or below.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3 . 3 . 1. 2 . 6 ------------------NOTES----~-------------

1. Neutron detectors are excluded.

2. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after IRMs on Range 2 or below.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.3-13 Amendment No . 171

OPRM Instrumentation 3.3.1.3 SURVEILLANCE REQUIREMENTS

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

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . provided the OPRM maintains trip capability.

SURVEILLANCE FREQUENCY SR 3. 3. 1. 3 . 1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.3.2 Calibrate the local power range monitors. In accordance with the Surveillance Frequency Control Program.

SR 3.3 . 1. 3. 3 ------------------NOTE------~------------

Neutron detectors are excluded.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3. 1. 3. 4 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3. 1. 3. 5 Verify OPRM is not bypassed when THERMAL In accordance POWER is ~ 23.8% RTP and recirculation with the drive flow is < the* value corresponding Surveillance to 60% of rated core flow. Frequency Control Program (continued)

PERRY - UN IT 1 3.3-14b Amendment No. 171

OPRM Instrumentation 3.3.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.3.6 ------------------NOTE-------------------

Neutron detectors are excluded.

Verify the RPS RESPONSE TIME is within In accordance limits. with the Surveillance Frequency Control Program PERRY - UNIT l 3.3-14c Amendment No. 171

Control Rod Block Instrumentation

' 3.3.2.1 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1. Refer to Table 3.3.2.1-1 to determine which SRs apply for each Control Rod Block 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains control rod block capability.

SURVEILLANCE FREQUENCY SR 3. 3. 2. 1. 1 ------------------NOTE-------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after THERMAL POWER is > 66.7% RTP.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.2 ------------------NOTE---------~---------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after THERMAL POWER is > 33.3% RTP and

~ 66. 7% RTP.

Perform CHANNEL FUNCTIONAL TEST. In accordance

. with the Surveillance Frequency Control Program SR 3.3.2.1.3 ------------------NOTE-------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after any control rod is withdrawn in MODE 2.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

PERRY - UNIT 1 3.3-16 Amendment No. 171

Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3. 2. 1. 4 ------------------NOTE-------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after THERMAL POWER is ~ 19% RTP in MODE 1.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3. 3. 2 .1. 5 Calibrate the low power setpoint trip In accordance units. The Allowable Value shall be* with the

> 19% RTP and~ 33.3% RTP. Surveillance Frequency Control Program SR 3 . 3 . 2 . 1. 6 Verify the RWL high power Function is not In accordance bypassed when THERMAL POWER is> 66.7% RTP. with the Survei 11 ance .

Frequency Control Program SR 3.3.2.1.7 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.8 ------------------NOTE-------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

. after reactor mode switch is in the shutdown position.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

PERRY - UN IT 1 3.3-17 Amendment No. 171

PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3. 1. 1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3 . 3 . 3 . 1. 2 Deleted.

SR 3;3.3.1.3 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.3-22 Amendment No . 171

Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 The Remote Shutdown System Functions shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status.

B. Required Action and B.l Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.2.1 Perform CHANNEL CHECK for each required In accordance instrumentation channel that is normally with the energized. Surveillance Frequency Control Program (conttnued)

PERRY - UNIT 1 3.3-24 Amendment No. 171

Remote Shutdown System 3.3.3.2 SURVEILLANCE RtOUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.3.2.2 Verify each required control circuit and In accordance transfer switch is capable of performing with the the intended functions. Surveillance Frequency Control Program SR 3.3.3.2.3 Perform CHANNEL CALIBRATION for each In accordance required instrumentation channel, except with the valve position instrumentation. Surveillance Frequency Control Program PERRY - UN IT 1 3.3-25 Amendment No. 171

EOC-RPT Instrumentation 3.3.4.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more Functions B.1 Restore EOC-RPT trip 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months with EOC-RPT trip capability. .

capability not maintained.

C. Required Action and C.1 Remove the associated 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion recirculation pump Time not met. fast speed breaker from service.

OR C.2 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to < 38% RTP.

SURVEILLANCE REQUIREMENTS

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

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . provided the associated Function maintains EOC-RPT trip capability.

SURVEILLANCE FREQUENCY SR 3 . 3 . 4 . 1. 1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

PERRY - UNIT 1 3.3-27 Amendment No . 171

EOC-RPT Instrumentation 3.3.4.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.4.1.2 Perform CHANNEL CALIBRATION. The In accordance Allowable Values shall be: with the Surveillance

a. TSV Closure: ~ 7% closed: and Frequency Control Program

b. TCV Fast Closure. Trip Oil Pressure-Low: ~ 465 psig.

SR 3 . 3 . 4 . 1. 3 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance including breaker actuation. with the Surveillance Frequency Control Program SR 3 . 3 . 4 . 1. 4 Verify TSV Closure and TCV Fast Closure. In accordance Trip Oil Pressure-Low Functions are not with the bypassed when THERMAL POWER is~ 38% RTP. Surveillance Frequency Control Program SR 3.3.4.1.5 ------------------NOTE-------------------

Breaker arc suppression time may be assumed from the most recent performance of SR 3.3.4.1.6.

Verify the EOC-RPT SYSTEM RESPONSE TIME In accordance is within limits. with the Surveillance Frequency Control Program SR 3.3. 4. 1. 6 Determine RPT breaker arc suppression In accordance time. with the Surveillance Frequency Control Program PERRY - UN IT 1 3.3-28 Amendment No . 171

ATWS-RPT Instrumentation 3.3.4.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One Function with B.1 Restore ATWS-RPT trip 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

ATWS-RPT trip capability.

capab1 l ity not maintained.

c. Both Functions wfth C.l Restore ATWS-RPT trip 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ATWS-RPT trip capability for one capability not Function.

maintained.

D. Required Action and o.r Remove the associated 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion recirculation pump Time not met. from service.

OR D.2 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILtANCE REQUIREMENTS

--.: ---*--------NOTE -----------------------------*- -----

When a channel is placed in an inoperable status solely for performan~e *of required Surveillan~es. entry into associated Conditions and Required-Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains ATWS-RPT trip capability.

-~---------------~------------~------------------------------~--------~~-~

SURVEILLANCE FREQUENCY SR 3.3.4.2.1 Perform CRANNEL CHECK. In accordance with the

Surveillance Frequency Control Program

<cont i n*ued)

PERRY - UN IT 1 3.3-30 Amendment No. 171

ATWS-RPT Instrumentation 3.3.4.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.4.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.4.2.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.4.2.4 Perform CHANNEL CALIBRATION. The In accordance Allowable Values shall be: with the Surveillance

a. Reactor Vessel Water Level-Low Low. Frequency Level 2: ~ 127.6 inches: and Control Program

b. Reactor Vessel Pressure-High:

s; 1098 psig.

SR 3.3.4.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance including breaker actuation. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.3-31 Amendment No. 171

ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS

~-------------------NOTES------------------------------------

1. Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS 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 as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 3.c. 3.f. 3.g. and 3.h: and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions other than J.c. 3.f. 3.g. and 3.h. provided the associated Function or the redundant Function maintains ECCS initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.5 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program (continued)

PERRY - UNIT 1 3.3-38 Amendment No . 171

ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3. 3. 5. l. 6 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5;1.7 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.3-38a Amendment No. 171

RCIC System Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1. Refer to Table 3.3.5.2-1 to determine which SRs apply for each RCIC 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 as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 5:

and Cb) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1. 2. 3. and 4 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Proqram SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequenc~

Control rogram SR 3.3.5.2.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.6 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.3-46 Amendment No. 171

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1. Refer to Table 3.3.6.1-1 to determine which SRs apply for each 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY SR 3. 3.6. 1. 1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.2 ----------------NOTE--------------------

for Function 1.e in Table 3.3.6.1-1. this SR is applicable only to the Di'vision 3 and 4 instruments.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3. 3. 6. 1. 3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program (continued)

PERRY - UN IT 1 3.3-53 Amendment No. 171

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE rnEQUENCY SR 3. 3. 6. 1. 4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3 . 3. 6 . 1. 5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3 . 3. 6. 1. 6 ------------------NOTE-------------------

Channel sensors are excluded.

Verify the ISOLATION SYSTEM RESPONSE TIME In accordance for the main steam isolation valves is with the within limits. Surveillance Frequency Control Program SR 3. 3. 6. 1. 7 ------------------NOTE-------------------

For Function l.e in Table 3.3.6.1-1, this SR is applicable only to the Division 1 and 2 instruments.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.3-53a Amendment No. 171

RHR Containment Spray System Instrumentation 3.3.6.2 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1. Refer to Table 3.3.6.2-1 to determine which SRs apply for each RHR Containment Spray System 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . provided the associated Function maintains RHR containment spray initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.6 Perform CHANNEL CALIBRATION In accordance with the Surveillance Frequency Control Proqram PERRY - UNIT 1 3.3-62 Amendment No . 171

SPMU System Instrumentation 3.3.6.3 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1. Refer to Table 3.3.6.3-1 to determine which SRs apply for each SPMU 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . provided the associated Function maintains SPMU initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.3.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequencp Control rogram SR 3.3.6.3.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.3.3 Calibrate the trip unit. In accordance with the Surveillance Frequenc~

Control rogram SR 3.3.6.3.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequencp

. Control rogram SR 3.3.6.3.5 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequencp Control rogram SR 3.3.6.3.6 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.3-66 Amendment No. 171

Relief and LLS Instrumentation 3.3.6.4 SURVEILLANCE REQUIREMENTS

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

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . provided the associated Function maintains LLS or relief initiation capability. as applicable.

SURVEILLANCE FREQUENCY SR 3.3.6 4.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.4.2 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.6.4.3 Perform CHANNEL CALIBRATION. The In accordance Allowable Values shall be: with the Surveillance

a. Relief Function Frequency Control Program Low: 1103 +/- 15 psig Medium: 1113 +/- 15 psig High. 1123 +/- 15 psig b LLS Function Low open: 1033 +/- 15 psig close: 926 +/- 15 psig Medium open: 1073 +/- 15 psig close: 936 +/- 15 psig High open: 1113 +/- 15 psig close: 946 +/- 15 psig SR 3.3.6.4.4 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3 3-69 Amendment No. 171

CRER System Instrumentation 3.3.7.1 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1. Refer to Table 3.3.7.1-1 to determine which SRs apply for each 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains CRER initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.7.1.l Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.3-72 Amendment No. 171

LOP Instrumentation 3.3.8.1 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1. Refer to Table 3.3.8.1-1 to determine which SRs apply for each LOP 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 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.

SURVEILLANCE FREQUENCY SR 3. 3 . 8 . 1. 1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3 . 3. 8. 1. 2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3 . 3. 8 . 1. 3 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3. 3.8 . 1. 4 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.3-75 Amendment No. 171

RPS.Electric Power Monitoring 3.3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.8.2.1 ------------------NOTE-------------------

Only required to be performed prior to entering MODE 2 or 3 from MODE 4. when in MODE 4 for~ 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.8.2.2 Perform CHANNEL CALIBRATION. The In accordance Allowable Values shall be: with the Surveillance

a. Overvoltage Frequency Control Program Bus A ~ 132 V Bus B ~ 132 V

b. Undervoltage Bus A ~ 108 V Bus B ~ 108 V

c. Underfrequency (with time delay set to~ 4.0 seconds)

Bus A ~ 57 Hz Bus B 57 Hz

?: :

SR 3.3.8.2.3 Perform a system functional test. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.3-79 Amendment No. 171

Recirculation Loops Operating 3.4.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 -------------------NOTE--------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after both recirculation loops are in operation.

Verify recirculation loop jet pump flow In accordance mismatch with both recirculation loops in with the operation is: Surveillance Frequency

a. ~ 10% of rated core flow when Control Program operating at < 70% of rated core flow; and

b. ~ 5% of rated core fl ow when operating at ~ 70% of rated core flow.

PERRY - UNIT 1 3.4-4 (next page is 3.4-6) Amendment No. 171

FCVs 3.4.2 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.2 Flow Control Valves (FCVs)

LCO 3.4.2 A recirculation loop FCV shall be OPERABLE in each operating recirculation loop.

APPLICABILITY: MODES 1 and 2.

ACTIONS

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

Separate Condition entry is allowed for each FCV.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two reguired A.1 Lock up the FCV. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months FCVs inoperable.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.2.l Verify each FCV fails "as is" on loss of In accordance hydraulic pressure at the hydraulic unit. with the Survei 11 ance Frequency Control Program (continued)

PERRY - UNIT 1 3.4-6 Amendment No.171

FCVs 3.4.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.2.2 Verify average rate of each FCV movement In accordance is: with the Surveillance

a. ~ 11% of stroke per second for Frequency opening; and

Control Program

b. ~ 11% of stroke per second for closi.ng.

PERRY - UN IT 1 3.4-7 Amendment No. 171

Jet Pumps 3.4.3 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.3 Jet Pumps LCO 3.4.3 All jet pumps shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more jet pumps A.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 -------------------NOTES-----~-------------

1. Not required to be performed until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after associated recirculation loop is in operation.

2. Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after > 25% RTP.

Verify at least two of the following In accordance criteria (a. b; and c) are satisfied for with the each operating recirculation loop: Survei 11 ance Frequency

a. Recirculation loop drive flow versus Control Program flow control valve position differs by

~ 10% from established patterns.

(continued)

PERRY - UNIT 1 3.4-8 Amendment No. 171

Jet Pumps 3.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 (continued)

b. Recirculation loop drive flow versus total core flow differs by s 10% from established patterns.

c. Each jet pump diffuser to lower plenum differential pressure differs by s 20%

from established patterns. or each jet pump flow differs by s 10% from established patterns.

PERRY - UNIT l 3.4-9 Amendment No. 171

S/RVs 3.4.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.4.2 -------------------NOTE--------------------

Valve actuation may be excluded.

Verify each required relief function S/RV In accordance actuates on an actual or simulated with the automatic initiation signal. Survei 11 ance Frequency Control Program SR 3.4.4.3 -------------------NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify each required S/RV actuator strokes In accordance when manually actuated. with the Surveillance Frequency Control Program PERRY - UN IT 1 3.4-11 Amendment No. 171

RCS Operational LEAKAGE 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify RCS unidentified LEAKAGE. total In accordance LEAKAGE. and unidentified LEAKAGE increase with the are within limits. Surveillance Frequency Control Program PERRY - UNIT 1 3.4-13 Amendment No. 171

RCS Leakage Detection Instrumentation 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.l Perform CHANNEL CHECK of required drywell In accordance atmospheric monitoring system. with the Surveillance Frequency Control Program SR 3.4.7.2 Perform CHANNEL FUNCTIONAL TEST of required In accordance leakage detection instrumentation. with the Surveillance Frequency Control Program SR 3.4.7.3 Perform CHANNEL CALIBRATION of required In accordance leakage detection instrumentation. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.4-18 Amendment No.171

RCS Specific Activity 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2.2.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND B.2.2.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 -------------------NOTE--------------------

Only required to be performed in MODE 1.

Verify reactor coolant DOSE In accordance EQUIVALENT 1-131 specific activity is with the

~ 0.2 µCi/gm. Surveillance Frequency Control Program PERRY - UN IT 1 3.4-20 Amendment No.171

RHR Shutdown Cooling System-Hot Shutdown 3.4.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 -------------------NOTE--------------------

Not required to be met until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after reactor steam dome pressure is less than the RHR cut in permissive pressure.

Verify one RHR shutdown cooling subsystem In accordance or recirculation pump is operating. with the Surveillance Frequency * .

Control Program PERRY - UN IT I 3.4-23 Amendment No . 171

RHR Shutdown Cooling System-Cold Shutdown 3.4.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

8. No RHR shutdown 8.1 Verify reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in coolant circulation discovery of no operation. by an alternate reactor coolant method. circulation AND AND No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND 8.2 Monitor reactor Once per hour coolant temperature and pressure.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3. 4. 10 .1 Verify one RHR shutdown cooling subsystem In accordance or recirculation pump is operating. with the Surveillance Frequency Control Program PERRY - UN IT 1 3.4-25 Amendment No. 171

RCS P/T Limits 3.4.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. ---------NOTE--------- C.l Initiate action to Immediately Required Action C 2 restore parameter(s) shall be completed if to within limits.

this Condition is entered AND C.2 Determine RCS is Prior to Requirements of the acceptable for entering MODE 2 LCO not met in other operation or 3 than MODES 1. 2.

and 3.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3 4.11.1 -------------------NOTE--------------------

Only required to be performed during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing.

Verify: In accordance with the

a. RCS pressure and RCS temperature are Surveillance within the limits of Figure 3.4.11-1; Frequency and Control Program

b. RCS heatup and cooldown rates are within the limits of Figure 3.4.11-1.

(continued)

PERRY - UN IT 1 3.4-27 Amendment No.171

RCS P/T Limits 3.4.11 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.11.5 -------------------NOTE--------------------

Only required to be performed when tensioning the reactor vessel head bolting studs.

Verify reactor vessel flange and head In accordance flange temperatures are~ 70°F. with the Surveillance Frequency Control Program SR 3.4.11.6 -------------------NOTE--------------------

Not required to be performed until 30 minutes after RCS temperature ~ 80°F in MODE 4.

Verify reactor vessel flange and head In accordance flange temperatures are~ 70°F. with the Surveillance Frequency Control Program SR . 3 . 4 . 11 . 7 - - - - - - - - - - - - - - - - - - -NOTE ---------- ~ ---------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after RCS temperature ~ l00°F in MODE 4.

Verify reactor vessel flange and head In accordance flange temperatures are~ 70°F. with the Surveillance Frequency Control Program (continued)

PERRY - UN IT 1 3.4-29 Amendment No. 171

Reactor Steam Dome Pressure 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Reactor Steam Dome Pressure LCO 3.4.12 The reactor steam dome pressure shall be~ 1045 psig.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor steam dome A.1 Restore reactor steam 15 minutes

~ressure not within dome pressure to imit. . within limit.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 Verify reactor steam dome pressure ts In accordance

~ 1045 psig. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.4-32 Amendment No . 171

ECCS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify. for each ECCS injection/spray In accordance subsystem. the piping is filled with water with the from the pump discharge valve to the Surveillance injection valve. Frequency Control Program SR 3.5.1. 2 -------------------NOTE--------------------

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the residual heat removal cut in permissive pressure in MODE 3. if capable of being manually realigned and not otherwise inoperable.

Verify each ECCS injection/spray subsystem In accordance manual. power operated. and automatic valve with the in the flow path. that is not locked. Surveillance sealed. or otherwise secured in position. Frequency is in the correct position. Control Program SR 3. 5.1.3 Verify ADS accumulator supply pressure is In accordance

~ 150 psig. with the .

Surveillance Frequency

Control Program SR 3.5.1.4 Verify each ECCS pump develops the In accordance specified flow rate with sufficient pump with the total head to overcome the total system Inservice resistance which includes the specified Testing Program reactor-to-containment wetwell differential pressure.

REACTOR-TO-CONTAINMENT WETWELL DIFFERENTIAL SYSTEM FLOW RATE PRESSURE LPCS ~ 6110 gpm ~ 128 psid LPCI ~ 7100 gpm ~ 24 psid HPCS ~ 6110 gpm ~ 200 psid lcont1nueaJ PERRY - UN IT 1 3.5-4 Amendment No . 171

ECCS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.5 -------------------NOTE--------------------

Vessel injection/spray may be excluded.

Verify each ECCS injection/spray subsystem In accordance actuates on an actual or simulated with the automatic initiation signal. Surveillance Frequency Control Program SR 3.5.1.6 -------------------NOTE--------------------

Valve actuation may be excluded.

Verify the ADS actuates on an actual or In accordance simulated automatic initiation signal. with the Surveillance Frequency Control Program SR 3.5.1. 7 -------------------NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify each ADS valve actuator strokes when In accordance manually actuated. with the Surveillance Frequency Control Program SR 3.5.1.8 ------------------NOTE---------------------

ECCS actuation instrumentation is excluded.

Verify the ECCS RESPONSE TIME for each ECCS In accordance injection/spray subsystem is within limits. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.5-5 Amendment No. 171

ECCS-Shutdown 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Re~uired Action C.2 D.1 Initiate action to Immediately an associated restore primary Completion Time not containment to met. OPERABLE status.

AND D.2 Initiate action to Immediately restore isolation capability in each required primary containment penetration flow path not isolated.

AND D.3 -------NOTE-------

Entry and exit is permissible under administrative control.

Initiate action to Immediately close one door in each primary containment air lock.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for each required low pressure ECCS In accordance injection/spray subsystem. the suppression with the pool water level is ~ 16 ft 6 in. Surveillance Frequency

Control Program (continued)

PERRY - UN IT 1 3.5-7 Amendment No. 171

ECCS-Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify. for the required High Pressure Core In accordance Spray (HPCS) System. the: with the Surveillance

a. Suppression pool water level is Frequency

~ 16 ft 6 in: or Control Program

b. Condensate storage tank water volume is~ 249.700 gal.

SR 3.5.2.3 Verify. for each required ECCS injection/ In accordance spray subsystem. the piping is filled with with the water from the pump discharge valve to the Surveillance injection valve. Frequency Control Program SR 3.5.2.4 -------------------NOTE--------------------

One low pressure coolant injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal. if capable of being manually rea hgned and not otherwise i-noperab le.

Verify each required ECCS injection/spray In accordance subsystem manual. power operated. and with the automatic valve in the flow path. that is Surveillance not locked. sealed. or otherwise secured in Frequency position. is in the correct position. Control Program (continued)

PERRY - UN IT 1 3.5-8 Amendment No. 171

ECCS-Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5 Verify each required ECCS pump develops the In accordance specified flow rate with sufficient pump with the total head to overcome the total system Inservice resistance which includes the specified Testing Program reactor to containment wetwell differential pressure.

REACTOR TO CONTAINMENT WETWELL DIFFERENTIAL SYSTEM FLOW RATE PRESSURE LPCS ~ 6110 gpm ~ 128 psid LPCI ~ 7100 gpm ~ 24 psid HPCS ~ 6110 gpm ~ 200 psid SR 3.5.2.6 -------------------NOTE--------------------

Vessel injection/spray may be excluded.

Verify each required ECCS injection/spray In accordance subsystem actuates on an actual or with the simulated automatic initiation signal. Surveillance Frequency Control Program PERRY - UNIT 1 3.5-9 Amendment No. 171

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 Verify the RCIC System piping is filled In accordance with water from the pump discharge valve to with the the injection valve. Surveillance Frequency Control Program SR 3.5.3.2 Verify each RCIC System manual. power In accordance operated. and automatic valve in the flow with the path. that is not locked. sealed. or Survei 11 ance otherwise secured in position. is in the Frequency correct position. Control Program SR 3.5.3.3 -------------------NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with RCIC steam supply pressure In accordance

~ 920-psig and~ 1045 psig, the RCIC pump with the can develop a flow rate ~ 700 gpm against a Surveillance system head corresponding to reactor Frequency pressure. Control Program SR 3.5.3.4 ------~------------NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with RCIC steam supply pressure In accordance

~ 150 psig and ~ 165 psig. the RCIC pump with the

_can develop a flow rate ~ 700 gpm against a Surveillance system head corresponding to reactor Frequency pressure. Control Program (continued)

PERRY - UNIT 1 3.5-11 Amendment No. 171

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.3.5 -------------------NOTE--------------------

Vessel injection may be excluded.

Verify the RCIC System actuates on an In accordance actual or simulated automatic initiation with the signal. Surveillance Frequency Control Program PERRY - UN IT 1 3.5-12 Amendment No. 171

Primary Containment Air Locks 3.6.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6. 1. 2. 1 ------------------NOTES------------------

1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

2. During MODES 1. 2. and 3. results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.1.

Perform required primary containment air In accordance lock leakage rate testing in accordance with the with the Primary Containment Leakage Rate Primary Testing Program. Containment Leakage Rate Testing Program SR 3. 6. 1. 2. 2 Verify primary containment air lock seal In accordance air header pressure is ~ 90 psig. with the Surveillance Frequency Control Program (continued)

PERRY - UN IT 1 3.6-7 Amendment No. 171

Primary Containment Air Locks 3.6.1.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3. 6. 1. 2.3 ------------------NOTE-------------------

Only required to be performed upon entry or exit through the primary containment air lock.

Verify only one door in the primary. In accordance containment air lock can be opened at a with the time. Surveillance Frequency Control Program SR 3 . 6. 1. 2 . 4 Verify, from an initial pressure of In accordance 90 psig, the primary containment air with the lock seal pneumatic system pressure does Surveillance not decay at a rate equivalent to Frequency

> 1.5 psig for a period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Control Program PERRY - UN IT 1 3.6-8 Amendment No . 171

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3 . 6 . 1. 3 . 1 ------------------NOTE------------------

Only required to be met in MODES 1. 2.

and 3.

Verify each inboard 42 inch primary In accordance containment purge valve is sealed closed with the except for one purge valve in a Surveillance penetration flow path while in Frequency Condition D of this LCO. Control Program SR 3 . 6 . 1. 3 . 2 ------------------NOTES------------------

1. Only required to be met in MODES 1.

2. and 3.

2. Not required to be met when the 18 inch or outboard 42 inch primary containment purge valves are open for pressure control. ALARA or air quality considerations for personnel entry. or Surveillances or special testing on the purge system that require the valves to be open.

Verify each 18 inch and outboard 42 inch In accordance primary containment purge valve is with the closed. Surveillance Frequency Control Program (continued)

PERRY - UNIT 1 3.6-15 Amendment No. 171

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3 . 6 . 1. 3 . 3 ------------------NOTES------------------

1. Only required to be met in MODES 1. 2.

and 3.

2. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

3. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment isolation In accordance manual valve and blind flange that is with the located outside primary containment. Surveillance drywell. and steam tunnel and not locked. Frequency sealed. or otherwise secured and is Control required to be closed during accident Program conditions is closed.

(continued)

PERRY - UNIT 1 3.6-16 Amendment No. 171

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3 . 6 . 1. 3 . 5 Verify the isolation time of each power In accordance operated and each automatic PCIV. except with the MSIVs. is within limits. Inservice Testing Program SR 3 . 6 . 1. 3 . 6 ------------------NOTE-------------------

Only required to be met in MODES 1. 2.

and 3.

Perform leakage rate testing for each In accordance primary containment purge valve with with the resilient seals. Surveillance Frequency Control Program AND Once within 92 days after opening the valve SR 3. 6. 1. 3. 7 Verify the isolation time of each MSIV is In accordance

~ 2.5 seconds. and~ 5 seconds. with the Inservice Testing Program SR 3 . 6 . 1. 3 . 8 Verify each automatic PCIV actuates to the In accordance isolation position on an actual or with the simulated isolation signal. Surveillance Frequency Control Program (continued)

PERRY - UN IT 1 3.6-17 Amendment No . 171

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.11 ------------------NOTES------------------

1. Only required to be met in MODES 1. 2.

and 3.

2. Feedwater lines are excluded.

Verify combined leakage rate of 1 gpm In accordance times the total number of PCIVs through with the hydrostatically tested lines that Primary penetrate the primary contatnment is not Containment exceeded when these isolation valves are Leakage Rate tested at ~ 1.1 Pa. Testing Program SR 3.6.1.3.12 ------------------NOTE------------------

Only required to be met in MODES 1.

2. and 3.

Verify each outboard 42 inch primary In accordance containment purge valve is blocked to with the restrict the valve from opening > 50°. Surveillance Frequency Control Program SR 3. 6 .1. 3 .13 ------------------NOTE-------------------

Not required to be met when the Backup Hydrogen Purge System isolation valves are open for pressure control. ALARA or air quality considerations for personnel entry. or Surveillances or special testing of the Backup hydrogen Purge System that require the valves to be open.

Verify each 2 inch Backup Hydrogen Purge In accordance System isolation valve is closed. with the Surveillance Frequency Control Program PERRY - UNIT I 3.6-19 Amendment No. 171

Primary Containment Pressure 3.6.1.4 3.6 CONTAINMENT SYSTEMS 3.6.1.4 Primary Containment Pressure LCD 3.6.1.4 Primary containment to secondary containment differential pressure shall be~ -0.1 psid and~ 1.0 psid.

APPLICABILITY: MODES 1. 2. and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment to A.1 Restore prim&ry 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months secondary containment containment to differential pressure secondary containment not within limits. differential pressure to within limits.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3 . 6 . 1. 4. 1 Verify primary containment to secondary In accordance containment differential pressure is with the within limits. Surveillance Frequency Control Program PERRY - UNIT 1 3.6-20 Amendment No.171

Primary Containment Air Temperature 3.6.1.5 3.6 CONTAINMENT SYSTEMS 3.6.1.5 Primary Containment Air Temperature LCO 3.6.1.5 Primary containment average air temperature shall be~ 95°F.

APPLICABILITY: MODES 1. 2. and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment A.1 Restore primary 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months average air containment average temperature not within air tem~erature to 1imit. within imit.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6. 1. 5 . 1 Verify primary containment average air In accordance temperature is within limit. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.6-21 Amendment No. 171

LLS Valves 3.6.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3. 6. 1. 6. 1 ------------------NOTE-------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify each LLS valve actuator strokes In accordance when manually actuated. with the Surveillance Frequency Control Program SR 3. 6. 1. 6. 2 ------------------NOTE-------------------

Valve actuation may be excluded.

Verify the LLS function of the six In accordance safety/relief valves actuates on an with the actual or simulated automatic initiation Surveillance signal. Frequency Control Program PERRY - UNIT 1 3.6-23 Amendment No. 171

RHR Containment Spray System 3.6.1. 7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3 . 6 . 1. 7 . 1 ---------.- --------NOTE -------------------

RHR containment spray subsystems may be considered OPERABLE during alignment and operation for decay heat removal when below the RHR cut in permissive pressure in MODE 3 if capable of being manually realigned and not otherwise inoperable.

Verify each RHR containment spray In accordance subsystem manual. power operated. and with the automatic valve in the flow path that is Surveillance not locked. sealed. or otherwise secured Frequency in position is in the correct position. Control Program SR 3. 6. 1. 7 . 2 Verify each RHR pump develops a flow rate In accordance of ~ 5250 gpm on recirculation flow with the through the associated heat exchangers to Inservice the suppression pool. Testing Program SR 3.6.1. 7.3 Verify each RHR containment spray In accordance subsystem automatic valve in the fl ow with the path actuates to its correct position on Surveillance an actual or simulated automatic Frequency initiation signal. Control Program SR 3. 6. 1. 7. 4 Verify each spray nozzle is unobstructed. Following maintenance which could result in nozzle blockage.

PERRY - UN IT 1 3.6-25 Amendment No.171

FWLCS 3.6.1.8 3.6 CONTAINMENT SYSTEMS 3.6.1.8 Feedwater Leakage Control System (FWLCS)

LCO 3.6.1.8 Two FWLCS subsystems shall be OPERABLE.

APPLICABILITY: MODES 1. 2. and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One FWLCS subsystem A.1 Restore FWLCS 30 days inoperable. subsystems to OPERABLE status.

B. Two FWLCS subsystems B.1 Restore one FWLCS 7 days inoperable. subsystem to OPERABLE status.

C. Required Action and C,1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.8.1 Verify associated ECCS water leg pump In accordance operates properly. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.6-26 Amendment No . 171

Primary Containment-Shutdown 3.6.1.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6. 1. 10 . 1 ------------------NOTES------------------

1. Not required to be met for pathways capable of being closed by OPERABLE primary containment automatic isolation valves.

2. Not required to be met for the Fire Protection System manual hose reel containment isolation valves.

3. Not required to be met for manual isolation valves open under administrative controls.

Verify each penetration flow path. In accordance required to be closed during accident with the conditions. is closed. Surveillance Frequency Control Program PERRY - UN IT 1 3.6-30 Amendment No . 171

Containment Vacuum Breakers 3.6.1.11 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.11.1 ------------------NOTES---------~--------

1. Not required to be met for vacuum breakers open during Surveillances.

2. Not required to be met for vacuum breakers open when performing their intended function.

Verify each vacuum breaker is closed. In accordance with the Surveillance Frequency Control Program SR 3. 6. 1. 11 . 2 Perform a functional test of each In accordance required vacuum breaker and its with the associated isolation valve. Surveillance Frequency Control Program SR 3.6.1.11.3 Verify the opening pressure differential In accordance of each required vacuum breaker is ~ 0.1 with the psid. and the opening setpoint of the Surveillance vacuum breaker isolation valve is ~ 0.052 Frequency psid and~ 0.160 psid. Control Program PERRY - UN IT 1 3.6-33 Amendment No.171

Containment Humidity Control

3. 6.1.12 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A AND not met in MODE 1. 2.

or 3. B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C. Required Action and C.1 Suspend movement of Immediately associated Completion recently irradiated Time of Condition A fuel assemblies in not met during the primary movement of recently containment.

irradiated fuel assemblies in the AND primary containment.

or during OPDRVs. C.2 Initiate action to Immediately suspend OPDRVs.

SURVEILLANCE REQUIREMENT SURVEILLANCE FREQUENCY SR 3.6.1.12.1 Verify containment average temperature- In accordance to-relative humidity to be within limits. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.6-35 Amendment No . 171

Suppression Pool Average Temperature 3.6.2.1 ACTIONS (continued CONDITION REQUIRED ACTION COMPLETION TIME E. Suppression pool E. l Depressurize the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months average temperature reactor vessel to

> 120°F. < 200 psig.

AND E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3 . 6 . 2 . 1. 1 Verify suppression pool average In accordance temperature is within the applicable with the limits. Surveillance Frequency Control Program AND 5 minutes when

performing testing that adds heat to the suppression pool PERRY - UNIT 1 3.6-38 Amendment No . 171

Suppression Pool Water Level 3.6.2.2 3.6 CONTAINMENT SYSTEMS 3.6.2.2 Suppression Pool Water Level LCO 3.6.2.2 Corrected suppression pool water level shall be

~ 17 ft 9.5 inches and~ 18 ft 6 inches.

APPLICABILITY: MODES 1. 2. and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Suppression ~ool water A.1 Restore suppression 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months level not wi hin pool water level to limits. within limits.

B. Required Action and B. l Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.2.1 Verify suppression pool water level is In accordance within limits. with the

Surveillance Frequency Control Program PERRY - UNIT 1 3.6-39 Amendment No. 171

RHR Suppression Pool Cooling System 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling In accordance subsystem manual. power operated. and with the automatic valve in the flow path that is Surveillance not locked. sealed. or otherwise secured Frequency in position is in the correct position or Control Program can be aligned to the correct position.

SR 3.6.2.3.2 Verify each RHR pump develops a flow rate In accordance

~ 7100 gpm through the associated heat with the exchangers to the suppression pool. Inservice Testing Program PERRY - UNIT 1 3.6-41 Amendment No. 171

SPMU System 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify upper containment pool water level In accordance is: with the Surveillance

a. ~ 22 ft 9 inches above the reactor Frequency pressure vessel (RPV) flange, Control Program OR

b. ~ 22 ft 5 inches above the RPV flange, and suppression pool water level~ 17 ft 11.7 inches.

SR 3.6.2.4.2 Verify upper containment pool water In accordance temperature is~ 110°F. with the Surveillance Frequency Control Program SR 3.6.2.4.3 Verify each SPMU subsystem manual. power In accordance operated. and automatic valve that is not with the locked. sealed. or otherwise secured in Surveillance position is in the correct position. Frequency Control Program SR 3.6.2.4.4 Verify a11 required upper containment In accordance pool gates are in the stored position or with the are otherwise removed from the upper Surveillance containment pool. Frequency Control Program SR 3.6.2.4.5 ------------------NOTE -----*- -------------

Actual makeup to the suppression pool may be excluded. ,

Verify each SPMU subsystem automatic In accordance valve actuates to the correct position on with the an actual or simulated automatic Surveillance initiation signal. Frequency Control Program PERRY - UNIT 1 3.6-43 (next page is 3.6-46) Amendment No. 171

Primary Containment and Drywell Hydrogen Igniters 3.6.3.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.2.1 Energize each primary containment and In accordance drywell hydrogen igniter division and with the perform current versus voltage Surveillance measurements to verify required igniters Frequency in service. Control Program SR 3.6.3.2.2 ------------------NOTE-------------------

Not required to be performed until 92 days after discovery of four or more igniters in the division inoperable.

Energize each primary containment and In accordance drywell hydrogen igniter division and with the perform current versus voltage Surveillance measurements to verify required igniters Frequency in service. Control Program SR 3.6.3.2.3 Verify each required igniter in In accordance inaccessible areas develops sufficient with the current draw for a ~ 1700°F surface Surveillance temperature. Frequency Control Program (continued)

PERRY - UNIT 1 3.6-47 Amendment No.171

Primary Containment and Drywell Hydrogen Igniters 3.6.3.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.2.4 Verify each required igniter in In accordance accessible areas develops a surface with the temperature of~ 1700°F. Surveillance Frequency Control Program PERRY - UNIT 1 3. 6-48 Amendment No . 171

Combustible Gas Mixing System 3.6.3.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.3.1 Operate each combustible gas mixing In accordance subsystem for~ 15 minutes. with the Surveillance Frequency Control Program SR 3.6.3.3.2 Verify each combustible gas mixing In accordance subsystem flow rate is ~ 500 scfm. with the Surveillance Frequency Control Program PERRY - UNIT 1 3. 6-50 Amendment No.171

Secondary Containment 3.6.4.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Secondary C. l Suspend movement of Immediately containment recently irradiated inoperable during fuel assemblies in movement of recently the primary irradiated fuel containment.

assemblies in the primary containment. AND or during OPDRVs.

C.2 Initiate action to Immediately suspend OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3 . 6 . 4 . 1. 1 Verify secondary containment vacuum is In accordance

~ 0.66 inch of vacuum water gauge. with the Surveillance Frequency Control Program SR 3.6.4.1.2 Verify the primary containment equipment In accordance hatch is closed and sealed and the shield with the blocks are installed adjacent to the Surveillance shield building. Frequency Control Program SR 3.6.4.1.3 Verify each secondary containment access In accordance door is closed. except when the access with the opening is being used for entry and exit. Surveillance Frequency Control Program PERRY - UN IT 1 3.6-52 Amendment No. 171

SCI Vs 3.6.4.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Suspend movement of Immediately associated Completion recently irradiated Time of Condition A fuel assemblies in or B not met durinl the primary movement of recent y containment.

irradiated fuel assemblies in the AND primary containment.

or during OPDRVs. D.2 Initiate action to Immediately suspend OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 ------------------NOTES------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for SCIVs that are open under administrative controls.

Verify each secondary containment In accordance isolation manual valve and blind flange with the that is not locked. sealed. or otherwise Surveillance secured and is required to be closed Frequency during accident conditions is closed. Control Program PERRY - UN IT 1 3.6-55 Amendment No.171

AEGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each AEGT subsystem for In accordance

~ 10 continuous hours with heaters with the operating. Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required AEGT filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program CVFTP).

SR 3.6.4.3.3 Verify each AEGT subsystem actuates on an In accordance actual or simulated initiation signal. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.6-58 Amendment No. 171

Drywell 3.6.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5. 1. 1 Verify bypass leakage is less than or 24 months equal to the bypass leakage limit. following 2 However. during the first unit startup consecutive following bypass leakage testing tests with performed in accordance with this SR. the bypass leakage acceptance criterion is ~ 10% of the greater than drywell bypass leakage limit. the bypass leakage limit AND 48 months following a test with bypass leakage greater than the bypass leakage limit AND

NOTE-----

SR 3.0.2 extensions are limited to 12 months.

In accordance with the Surveillance Frequency Control Program SR 3 . 6 . 5 . 1. 2 Visually inspect the exposed accessible In accordance interior and exterior surfaces of the with the drywell. Surveillance Frequency

Control Program (continued)

PERRY - UNIT 1 3.6-60 Amendment No. 171

Drywel l 3.6.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3. 6. 5 . 1. 3 Quantify air lock door seal leakage rate Once within 72 when the gap between the door seals is hours after pressurized to ~ 2.5 psig. each drywe 11 air lock door closing.

SR 3. 6. 5. 1. 4 -- ------------ --- -NOTE-- --- -----*- ------ --

An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

Quantify drywell air lock leakage by In accordance performing an air lock barrel leakage with the test at ~ 2.5 psig. Surveillance Frequency Control Program PERRY - UNIT 1 3.6-60a Amendment No . 171

Drywe 11 Air Lock 3.6.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.2.1 Deleted.

SR 3.6.5.2.2 Verify drywell air lock seal air header In accordance pressure is ~ 60 psig. with the Surveillance Frequency Control .Program SR 3.6.5.2.3 ------------------NOTE-----------------~-

Only required to be performed upon entry into drywell.

Verify only one door in the drywell air In accordance lock can be opened at a time. with the Surveillance Frequency Control Program SR 3. 6. 5. 2 .4. Deleted.

SR 3.6.5.2.5 Verify, from an initial pressure of In accordance 60 psig. the drywell air lock seal with the pneumatic system pressure does not decay Surveillance at a rate equivalent to > 3 psig for a Frequency period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Control Program PERRY - UNIT 1 3.6-64 Amendment No.171

Drywell Isolation Valves 3.6.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.3.1 Verify each 24 inch and 36 inch drywell In accordance purge supply and exhaust isolation valve with the is sealed closed. Surveillance Frequency Control Program SR 3.6.5.3.2 Deleted.

SR 3.6.5.3.3 -----~------------NOTES------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2; Not required to be met for drywell isolation valves that are open under administrative controls.

Verify each drywell isolation manual Prior to valve and blind flange that is not entering MODE 2 locked. sealed. or otherwise secured and or 3 from is required to be closed during accident MODE 4. if not conditions is closed. performed in the previous 92 days SR 3.6.5.3.4 Verify the isolation time of each power In accordance operated and each automatic drywell with the isolation valve is withtn limits. Inservice Testing Program SR 3.6.5.3.5 Verify each automatic drywell isolation In accordance valve actuates to the isolation position with the on an actual or simulated isolation Surveillance signal. Frequency Control Program PERRY - UNIT 1 3.6-67 Amendment No . 171

Drywell Pressure 3.6.5.4 3.6 CONTAINMENT SYSTEMS 3.6.5.4 Drywell Pressure LCO 3.6.5.4 Drywell-to-primary containment differential pressure shall be~ -0.5 psid and ~ 2.0 psid.

APPLICABILITY: MODES 1. 2. and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell-to-primary A.1 Restore drywell-to- 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months containment primary containment differential pressure differential pressure not within limits. to within limits.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.4.1 Verify drywell-to-primary containment In accordance differential pressure is within limits. with the Surveillance Frequency Control Program PERRY - UN IT 1 3.6-69 Amendment No. 171

Drywell Air Temperature 3.6.5.5 3.6 CONTAINMENT SYSTEMS 3.6.5.5 Drywell Air Temperature LCO 3.6.5.5 Drywell average air temperature shall be~ 145°F.

APPLICABILITY: MODES 1. 2. and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell average air A.1 Restore drywe 11 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months temperature not within aven.1ge air limit. temperature to within limit.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.5.1 Verify drywell average air temperature is In accordance within limit. with the Surveillance Frequency Control Program PERRY - UN IT 1 3.6-70 Amendment No.171

Drywell Vacuum Relief System 3.6.5.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A. AND B. or C not met.

D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.6.1 -----------------NOTES-------------------

1. Not required to be met for drywell vacuum breakers open during Surveillances.

2. Not required to be met for drywell vacuum breakers open when performing their intended function.

Verify each drywell vacuum breaker and In accordance its associated isolation valve is closed. with the Surveillance Frequency Control Program SR 3.6.5 .. 6.2 Perform a functional test of each drywell In accordance vacuum breaker and its associated with the isolation valve. Surveillance Frequency Control Program SR 3.6.5.6.3 Verify the opening pressure differenhal In accordance of each drywell vacuum breaker is with the

~ 0.5 psid. and the allowable value of Surveillance each associated isolation valve is Frequency

~ 0.810 inches water gauge dp. Contra l Program PERRY - UNIT 1 3.6-72 Amendment No. 171

ESW System-Div. 1 and 2 3.7.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TI ME B. Required Action and 8.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A AND not met.

B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Both ESW Division 1 and Division 2 subsystems inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3. 7 .1.1 Verify each required Division 1 and 2 ESW In accordance subsystem manual. power operated. and with the automatic valve in the flow path servici*ng Surveillance safety related systems or components. that Frequency is not locked. sealed. or otherwise secured Control Program in position. is in the correct position.

SR 3. 7 .1. 2 Verify each required Division 1 and 2 ESW In accordance subsystem actuates on an actual or *with the simulated initiation signal. Surveillance Frequency Control Program PERRY - UNIT 1 3.7-2 Amendment No . 171

ESW System-Div. 3 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Emergency Service Water (ESW) System-Division 3 LCO 3.7.2 The Division 3 ESW subsystem shall be OPERABLE.

APPLICABILITY: MODES 1. 2. and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ESW Division 3 A.l Declare High Pressure Immediately subsystem inoperable. Core Spray System inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Verify each required Division 3 ESW In accordance subsystem manual. power operated. and . with the

automatic valve in the flow path servicing Surveillance safety related systems or components. that Frequency is not locked. sealed. or otherwise secured Control Program in position. is in the correct position.

SR 3.7.2.2 Verify the Division 3 ESW subsystem In accordance actuates on an actual or simulated with the initiation signal. Surveillance Frequency Control Program PERRY - UN IT 1 3.7-3 Amendment No . 171

CRER System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two CRER subsystems F.l Suspend movement of Immediately inoperable during recently irradiated movement of recently fuel assemblies in irradiated fuel the primary assemblies in the containment and fuel primary containment or handling building.

fuel handling building. or during AND OPDRVs.

F.2 Initiate action to Immediately suspend OPDRVs.

One or more CRER subsystems inoperable due to inoperable CRE boundary during movement of recently irradiated fuel assemblies in the primary containment or fuel handling building. or during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CRER subsystem for In accordance

~ 10 continuous hours with the heaters with the operating. Surveillance Frequency Control Program SR 3.7.3.2 Perform required CRER filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

(continued)

PERRY - UNIT 1 3.7-6 Amendment No.171

CRER System 3.7.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.3.3 Verify each CRER subsystem actuates on an In accordance actual or simulated initiation signal. with the Surveillance Frequency Control Program SR 3.7.3.4 Perform required CRE unfiltered air In accordance inleakage testing in accordance with the with the Control Room Envelope Habitability Control Room Program. Envelope Habitability Program.

PERRY - UNIT 1 3.7-7 Amendment No. 171

Control Room HVAC System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and ------------NOTE-------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition B not met during movement of recently E.l Suspend movement of Immediately irradiated fue 1 recently irradiated assemblies in the fuel assemblies in Rrimary containment or the primary fuel handling containment and fuel building, or during handling building.

OPDRVs.

AND E.2 Initiate action to Immediately suspend OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify each control room HVAC subsystem has In accordance the capability to remove the assumed heat with the load. . Surveillance Frequency Control Program PERRY - UNIT 1 3.7-10 Amendment No. 171

Main Condenser Offgas 3.7.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 Verify the release rate of the specified Once within noble gases is ~ 358 mCi/second after decay 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after a of 30 minutes. ;: : 50% increase in the nominal steady state fission gas release rate after factoring out increases due to changes

. in THERMAL POWER level SR 3.7.5.2 -------------------NOTE----------------~---

Not required to be performed until 31 days after any main steam line not isolated and SJAE in operation.

Verify the release rate of the specified In accordance noble gases is ~ 358 mCi/second after decay with the of 30 minutes. Surveillance Frequency Control Program PERRY - UNIT 1 3.7-12 Amendment No . 171

Main Turbine Bypass System 3.7.6 3.7 PLANT SYSTEMS 3.7.6 Main Turbine Bypass System LCO 3.7.6 The Main Turbine Bypass System shall be OPERABLE.

APPLICABILITY: THERMAL POWER ~ 23.8% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Main Turbine Bb~ass A.l Restore Main Turbine 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months System inopera e. By~ass System to OP RABLE status.

B. Required Action and B.1 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to< 23.8% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3. 7 .6.1

Verify one complete cycle of each main In accordance turbine bypass valve. with the Surveillance Frequency Control Program SR 3.7.6.2 Perform a system functional test. In accordance with the Survei 11 ance Frequency Control Program SR 3.7.6.3 Verify the TURBINE BYPASS SYSTEM RESPONSE In accordance TIME is within limits. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.7-13 Amendment No . 171

Fuel Pool Water Level 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Fuel Pool Water Level LCO 3.7.7 The fuel pool water level shall be~ 23 ft over the top of irradiated fuel assemblies seated in the fuel handling building (FHB) and upper containment fuel storage racks.

APPLICABILITY: During movement of irradiated fuel assembli.es in the associated fuel storage pools.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel pool water level A.l --------NOTE---------

not within limit. LCO 3.0.3 is not applicable.

Suspend movement of Immediately irradiated fuel assemblies in the associated fuel storage pool (s) .

SURVEILLANCE REQUIREMENTS .

SURVEILLANCE FREQUENCY SR 3.7.7.1 Verify the fuel pool water level is ~ 23 ft In accordance over the top of irradiated fuel assemblies with the seated in the storage racks. Surveillance Frequency Control Program PERRY - UN IT 1 3.7-14 Amendment No . 171

Fuel Handling Building 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Fuel Handling Building LCO 3.7.8 The fuel handling building CFHB) shall be OPERABLE.

APPLICABILITY: During movement of recently irradiated fuel assemblies in the FHB.

ACTIONS

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

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A, FHB inoperable. A. l Suspend movement of Immediately recently irradiated fuel assemblies in the FHB.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 Verify all FHB floor hatches and the shield In accordance blocks adjacent to the shield building are with the installed. and the FHB railroad track door Surveillance is closed. Frequency Control Program SR 3.7.8.2 Verify each FHB access door is closed. In accordance except when the access opening is being with the used for entry and exit. Surveillance Frequency Control Program PERRY - UN IT 1 3.7-15 Amendment No.171

Fuel Handling Building Ventilation Exhaust System 3.7.9 SURVEILLANCE REQUIREMENTS SURVE It LANCE FREQUENCY SR 3.7.9.1 Operate each FHB ventilation exhaust In accordance subsystem for ~ 10 continuous hours with with the heaters operating. Surveillance Frequency Control Program SR 3. 7. 9. 2 Perform FHB ventilation exhaust filter In accordance testing in accordance with the Ventilation with the VFTP Filter Testing Program (VFTP).

SR 3.7.9.3 Perform a system functional test. In accordance with the Surveillance frequency Control Program SR 3.7.9.4 Perform a CHANNEL FUNCTIONAL TEST of the In accordance FHB ventilation exhaust radiation monitor with the (noble gas) Surveillance Frequency Control Program PERRY - UNIT 1 3.7-18 Amendment No.171

ECCW System

3. 7 .10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Verify each required ECCW subsystem manual. In accordance

~ower operated. and automatic valve in the with the flow path. that is not locked. sealed. or Surveillance otherwise secured in position. is in the Frequency correct position or can be aligned to the Control Program correct position.

SR 3.7.10.2 Verify each ECCW subsystem actuates on an In accordance actual or simulated initiation signal. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.7-20 Amendment No . 171

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and In accordance indicated power availability for each with the required offsite circuit. Surveillance Frequency Control Program SR 3 .8.1.2 ------------------NOTES--------------------

1. Performance of SR 3.8.1.7 satisfies this SR.

2. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

3. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer.

Verify each DG starts from standby In accordance conditions and achieves: with the Survei 11 ance Steady state voltage ~ 3900 V and s 4400 V Frequency and freque~cy ~ 58.8 Hz ands 61.2 Hz. Control Program (continued)

PERRY - UNIT 1 3.8-5 Amendment No . 171

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 -------------------NOTES-------------------

1. DG loadings may include gradual loading as recommended by the manufacturer.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4. This SR shall be preceded by. and immediately follow. without shutdown.

a successful performance of SR 3.8.1.2 or SR 3 . 8 . 1. 7.

Verify each DG operates for ~ 60 minutes at In accordance a load ~ 5600 kW and ~ 7000 kW for with the Division 1 and 2 DGs. and ~ 2600 kW for Surveillance Division 3 DG. Frequency Control Program SR 3.8.1.4 Verify each day tank contains ~ 316 gal of In accordance fuel oil for Divisions 1 and 2 and with the

~ 279 gal for Division 3. Surveillance Frequency Control Program SR 3 ..8.1.5 Check for and remove accumulated water from In accordance each day tank. with the Surveillance Frequency Control Program SR 3.8.1.6 Verify the fuel oil transfer system In accordance operates to automatically transfer fuel oil with the from the storage tank to the day tank. Surveillance Frequency Control Program (continued)

PERRY - UNIT I 3.8-6 Amendment No. 171

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1. 7 -------------------NOTE--------------------

All DG starts may be preceded by an engine prelube period.

Verify each DG starts from standby In accordance conditions and achieves: with the Surveillance

a. In ~ 10 seconds for Division 1 and 2. Frequency and ~ 13 seconds for Division 3. Control Program voltage ~ 3900 V and frequency

~ 58.8 Hz; and

b. Steady state voltage ~ 3900 V and

~ 4400 V and frequency ~ 58.8 Hz and

~ 61.2 Hz.

SR 3.8.1.8 ---------------NOTE------------------------

This Surveillance shall not be performed in*

MODE 1 or 2 (not applicable to Division 3).

However. credit may be taken for unplanned events that satisfy this SR.

Verify manual transfer of unit power supply In accordance from the normal offsite circuit to the with the alternate offsite circuit. Surveillance Frequency Control Program (continued)

PERRY - UNIT 1 3.8-7 Amendment No. 171

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1. 9 -----------------NOTES--------------------

1. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3). However.

credit may be taken for unplanned events that satisfy this SR.

2. If performed with DG synchronized with offsite power. it shall be performed at a power factor ~ 0.9.

Verify each DG rejects a load greater than In accordance or equal to its associated single largest with the post-accident load. Following load Surveillance rejection. engine speed is maintained less Frequency than nominal plus 75% of the difference Control Program between nominal speed and the overspeed trip setpoint. or 15% above nominal.

whichever is less.

SR 3.8.1.10 -----------------NOTE---------------------

This Surveillance shall not be performed ion MODE 1 or 2 (not applicable to Division 3).

However. credit may be taken for unplanned events that satisfy this SR.

Verify each DG operating at a power factor In accordance

~ 0.9 does not trip and voltage is . with the maintained ~ 4784 V for Division 1 and 2 Surveillance DGs and $ 5000 V for Division 3 DG during Frequency and following a load rejection of a load Control Program

.~ 5600 kW for Division 1 and 2 DGs and

~ 2600 kW for Division 3 DG.

(continued)

PERRY - UN IT 1 3.8-8 Amendment No. 171

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8 1.11 -------------------NOTES-------------------

1. All DG starts may be preceded by an engine prelube period.

2. This Surveillance shall not be performed in MODE 1. 2. or 3 (not applicable to Division 3). However.

credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of In accordance offsite power signal: with the Surveillance

a. De-energization of emergency buses: Frequency Control Program b Load shedding from emergency buses for D1vis1ons 1 and 2: and

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads in ~ 10 seconds for Division 1 and 2 DGs and

~ 13 seconds for Div1s1on 3.

2. energizes auto-connected loads for Divisions 1 and 2.

3. maintains steady state voltage

~ 3900 V and~ 4400 V.

4. maintains steady state frequency

~ 58.8 Hz and ~ 61.2 Hz. and

5. supplies permanently connected and auto-connected loads for

~ 5 minutes.

(continued)

PERRY - UNIT 1 3 8-9 Amendment No. 171

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.12 -------------------NOTES-------------------

1. All DG starts may be preceded by an engine prelube period.

2. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3). However.

credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated Emergency In accordance Core Cooling System <ECCS) initiation with the signal each DG auto-starts from standby Surveillance condition and: Frequency Control Program

a. In~ 10 seconds for Division 1 and 2.

and ~ 13 seconds for Division 3. after auto-start and during tests. achieves voltage ~ 3900 V and frequency

~ 58.8 Hz; and

b. Achieves steady state voltage ~ 3900 V and ~ 4400 Vand frequency ~ 58.8 Hz and~ 61.2 Hz: and

c. Operates for~ 5 minutes.

SR 3.8.1.13 -----------------NOTE---------------------

This Surveillance shall not be performed in MODE 1. 2. or 3 (not applicable to Division 3). However. credit may be taken for unplanned events that satisfy this SR.

Verify each DG's automatic trips are In accordance bypassed on an actual or simulated ECCS with the initiation signal except: Surveillance Frequency

a. Engine overspeed; and Control Program

b. Generator differential current (continued)

PERRY - UNIT 1 3. 8-10 Amendment No. 171

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.14 -------------------NOTES-------------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. Credit may be taken for unplanned events that satisfy this SR.

Verify each DG operating at a power factor In accordance 5 0.9 operates for~ 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: with the Surveillance

a. For ~ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded ~ 6800 kW and Frequency 5 7000 kW for Division 1 and 2 DGs. Control Program and ~ 2860 kW for Division 3 DG: and

b. For the remaining hours of the test loaded ~ 5600 kW and 5 7000 kW for Division 1 and 2 DGs. and ~ 2600 kW for Division 3 DG.

(continued)

PERRY - UNIT 1 3. 8-11 Amendment No . 171

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.15 ------------------NOTES-------------------

1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated ~ 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months loaded ~ 5600 kW and ~ 7000 kW for Division 1 and 2 DGs. and~ 2600 kW for Division 3 OG.

Momentary transients outside of the load range do not invalidate this test.

2. All DG starts may be preceded by an engine prelube period.

Verify each DG starts and achieves: In accordance with the

a. Ins 10 seconds for Division 1 and 2. Surveillance and s 13 seconds for Division 3. Frequency voltage ~ 3900 V and frequency Control Program

~ 58.8 Hz: and

b. Steady state voltage ~ 3900 V and s 4400 V and frequency ~ 58.8 Hz and s 61.2 Hz.

SR 3.8.1.16 -------------------NOTE--------------------

Thi s Survei 11 ance sha 11 not be performed in MOOE 1. 2. or 3 (not applicable to Division 3). However. credit may be taken for unplanned events that satisfy this SR.

Verify each OG: In accordance with the

a. Synchronizes with offsite power source Surveillance while loaded with emergency loads upon Frequency a simulated restoration of offsite Control Program power:

b. Transfers loads to offsite power source; and

c. Returns to ready-to-load operation.

(continued)

PERRY - UNIT 1 3.8-12 Amendment No. 171

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.17 -------------------NOTE-------------------

This Surveillance shall not be performed in MODE 1. 2. or 3 (not applicable to Division 3). However. credit may be taken for unplanned events that satisfy this SR.

Verify. with a DG operating in test mode In accordance and connected to its bus. an actual or

with the simulated ECCS initiation signal overrides Surveillance the test mode by: Frequency Control Program

a. Returning DG to ready-to-load operation; and

b. Automatically energizing the emergency loads from offsite power.

SR 3.8.1.18 ------------------NOTE---------------------

Thi s Survei 11 ance shall not be performed in MODE 1. 2. or 3. However. credit may be taken for unplanned events that satisfy this SR.

Verify for Division 1 and 2 OGs. the In accordance sequence time is within +/- 10% of design for with the each load sequence timer. Surveillance Frequency Control Program (continued)

PERRY -: UNIT 1 3.8-13 Amendment No. 171

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.19 -------------------NOTES-------------------

1. All DG starts may be preceded by an engine prelube period.

2. This Surveillance shall not be performed in MODE 1. 2. or 3 (not applicable to Division 3). However.

credit may be taken for unplanned events that satisfy this SR.

Verify, on an actual or simulated loss of In accordance offsite power signal in conjunction with an with the actual or simulated ECCS initiation signal: Surveillance Frequency

a. De-energization of emergency buses: Control Program

b. Load shedding from emergency buses for Divisions 1 and 2: and

c. DG auto-starts from standby condition and:

1. energizes permanently connected 1oads in ~ 10 seconds for Divisions 1 and 2 and ~ 13 seconds for Division 3.

2. energizes auto-connected emergency loads (for Division 3. verify energization in~ 13 seconds).

3. achieves steady state voltage

~ 3900 V and~ 4400 V.

4. achieves steady state frequency

~ 58.8 Hz and ~ 61.2 Hz. and

5. supplies permanently connected and auto-connected emergency loads for

~ 5 minutes.

(continued)

PERRY - UNIT 1 3.8-14 Amendment No. 171

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.20 -------------------NOTE--------------------

All DG starts may be preceded by an engine prelube period.

Verify. when.s~arted simultane~usly from In accordance standby cond1t1on. each DG achieves: with the Surveillance

a. In .~ 10 seconds for Division 1 and 2. Frequency and ~ 13 seconds for Division 3. voltage Control Program

~ 3900 V and frequency ~ 58.8 Hz: and

b. Steady state voltage ~ 3900 V and

~ 4400 V and frequency ~ 58.8 Hz and

~ 61.2 Hz.

PERRY - UNIT 1 3.8-15 Amendment No. 171

Diesel Fuel Oil. Lube Oil. and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains: In accordance with the

a. ~ 73.700 gal of fuel for Div 1 DG Surveillance and Div 2 DG: and Frequencp Control rogram

b. ~ 36.700 gal of fuel for Div 3 DG.

SR 3.8.3.2 Verify lube oil inventory is: In accordance with the

a. ;::: 374 gal for Div 1 DG and Div 2 DG; Surveillance and Frequencp Control rogram

b. ;::: 260 gal for Div 3 DG.

SR 3.8.3.3 Verify fuel oil properties of new and In accordance stored fuel oil are tested in accordance with the Diesel with. and maintained within the limits of. Fuel Oil the Diesel Fuel Oil Testing Program. Testing Program SR 3.8.3.4 Verify each required DG air start receiver In accordance pressure is ~ 210 psig. with the Surveillance Frequenc~

Control rogram SR 3.8.3.5 Check for and remove accumulated water from In accordance each fuel oil storage tank. with the Surveillance Frequenc~

Control rogram SR 3.8.3.6 For each fuel oil storage tank: In accordance with the

a. Drain the fuel oil: Surveillance Frequenc~

b. Remove the sediment: and Control rogram

c. Clean the tank.

PERRY - UN IT 1 3.8-23 Amendment No . 171

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is ~ 129 V In accordance on float charge. with the Surveillance Frequency Control Program SR 3.8.4.2 Verify no visible corrosion at battery In accordance terminals and connectors. with the Surveillance Frequency Control Program Verify battery connection resistance is

~ 5.0 E-5 ohm for inter-cell connections.

5 5.0 E-5 ohm for inter-rack connections.

~ 5.0 E-5 ohm for inter-tier connections.

5 5.0 E-5 ohm for terminal connections:

for Div 1 and Div 2 and

~ 1.0 E-4 ohm for inter-cell connections.

~ 1.0 E-4 ohm for inter-rack connections.

~ 1.0 E-4 ohm for inter-tier connections.

~ 1.0 E-4 ohm for terminal connections.

for Div 3.

SR 3.8.4.3 Verify battery cells. cell plates. and In accordance racks show no visual indication of physical with the damage or abnormal deterioration that could Surveillance degrade battery performance. Frequency Control Program SR 3.8.4.4 Remove visible corrosion. and verify In accordance battery cell to cell and terminal with the connections are coated with anti-corrosion Surveillance material. Frequency Control Program (continued)

PERRY - UN IT 1 3.8-25 Amendment No. 171

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.5 Verify battery connection resistance is In accordance with the

~ 5.0 E-5 ohm for inter-cell connections. Surveillance

~ 5.0 E-5 ohm for inter-rack connections. Frequency

~ 5.0 E-5 ohm for inter-tier connections. Control Program

~ 5.0 E-5 ohm for terminal connections:

for Div 1 and Div 2 and

~ 1.0 E-4 ohm for inter-cell connections.

~ 1.0 E-4 ohm for inter-rack connections.

~ 1.0 E-4 ohm for inter-tier connections.

~ 1.0 E-4 ohm for terminal connections for Div 3.

SR 3.8.4.6 Verify each required Division 1 and 2 In accordance battery charger supplies z 400 amps at with the z 125 V for z 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months s: and each required Surveillance Division 3 battery charger supplies Frequency z 50 amps at z 125 V for z 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Control Program SR 3.8.4.7 -------------------NOTE-----------------

SR 3.8.4.8 may be performed in lieu of SR 3.8.4.7.

Verify battery capacity is adequate to In accordance supply. and maintain in OPERABLE status. with the the required emergency loads for the design Surveillance duty cycle when subJected to a battery Frequency service test. Control Program (continued)

PERRY - UNIT 1 3.8-26 Amendment No. 171

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.8 -------------------NOTE-----------------

Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is ~ 80% of the In accordance manufacturer's rating when subJected to a with the performance discharge test. Surveillance Frequency Control Program AND 12 months when battery shows *

degradation. or has reached 85%

of the expected life with capacity < 100%

of manufacturer's rating AND 24 months when battery has reached 85% of the expected life with capacity 2 100%

of manufacturer* s rat mg PERRY - UN IT 1 3.8-27 Amendment No. 171

Battery Cell Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Declare associated Immediately associated Completion battery inoperable.

Time of Condition A not met.

OR One or more batteries with average electrolyte

temperature of the representative cells

< 72°F.

OR One or more batteries with one or more battery cell parameters not within Table 3.8.6-1 Category C limits.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 Verify battery cell parameters meet ln accordance Table 3.8.6-1 Category A limits. with the Surveillance Frequency Control.Program (continued)

PERRY - UN IT 1 3.8-33 Amendment No . 171

Battery Cell Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.2 Verify battery cell parameters meet In accordance Table 3.8.6-1 Category B limits. with the Surveillance Frequency Control Program ANO Once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after battery overcharge

> 145 v SR 3.8.6.3 Verify average electrolyte temperature of In accordance representative cells is ~ 72°F. with the Surveillance Frequency Control Program PERRY - UNIT I 3.8-34 Amendment No . 171

Distribution Systems-Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A AND or B not met.

C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. One or more Division 3 D.1 Declare High Pressure Immediately AC or DC electrical Core Spray System power distribution inoperable.

subsystems inoperable.

E. Two or more divisions E.1 Enter LCO 3.0.3. Immediately with inoperable distribution subsystems that result in a loss of function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct breaker alignments and In accordance voltage to required AC and DC electrical with the power distribution subsystems. Survei l1 ance Frequency Control Program PERRY - UNIT 1 3. 8-37 Amendment No . 171

Distribution Systems-Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to Immediately sus~end operations wit a potential for draining the reactor vessel.

AND A.2.4 Initiate actions to Inmediately restore required AC and DC electrical power distribution subsystems to OPERABLE status.

AND A.2.5 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct breaker alignments and In accordance voltage to required AC and DC electrical with the power distribution subsystems. Surveillance Frequency Control Program PERRY - UNIT 1 3.8-39 Amendment No.171

Refueling Equipment Interlocks 3.9.1 3.9 REFUELING OPERATIONS 3.9.1 Refueling Equipment Interlocks LCO 3.9.1 The refueling equipment interlocks shall be OPERABLE.

APPLICABILITY: During in-vessel fuel movement with equipment associated with the interlocks.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Sus~end in-vessel Immediately refueling equipment fue movement with interlocks inoperable. equipment associated with the inoperable interlock (s).

OR A.2.1 Insert a control rod Immediately withdrawal block.

AND A.2.2 Verify all control Immediately rods ar*e fully inserted.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3. 9.1. l *Perform CHANNEL FUNCTIONAL TEST on each of In accordance the following required refueling equipment with the interlock inputs: Surveillance Frequency

a. All-rods-in. Control Program

b. Refuel platform position. and

c. Refuel platform main hoist. fuel loaded.

PERRY - UN IT 1 3.9-1 Amendment No. 171

Refuel Position One-Rod-Out Interlock 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Refuel Position One-Rod-Out Interlock LCD 3.9.2 The refuel position one-rod-out interlock shall be OPERABLE.

APPLICABILITY: MODE 5 with the reactor mode switch in the refuel position and any control rod withdrawn.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Refuel position one- A.1 Suspend control rod Immediately rod-out interlock wi thdrawa 1.

inoperable.

AND A.2 Initiate action to Immediately fully insert all insertable control rods i.n core cells containing one or more fuel assemblies.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.2.1 Verify reactor mode switch locked in refuel In accordance position. with the Surveillance Frequency Control Program (continued)

PERRY - UN IT 1 3.9-2 Amendment No . 171

Refuel Position One-Rod-Out Interlock 3.9.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.9.2.2 -------------------NOTE--------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after any control rod is withdrawn.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.9-3 Amendment No. 171

Control Rod Position 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Control Rod Position LCO 3.9.3 All control rods shall be fully inserted.

APPLICABILITY: When loading fuel assemblies into the core.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more control A.1 Suspend loading fuel Inunediately rods not fully assemblies into the inserted. core.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 Verify a11 contra l rods are fully inserted.

In accordance with the Survei.11 ance Frequency Control Program PERRY - UN IT I 3.9-4 Amendment No.171

Control Rod OPERABILITY-Refueling 3.9.5 3.9 REFUELING OPERATIONS 3.9.5 Control Rod OPERABILITY-Refueling LCO 3.9.5 Each withdrawn control rod shall be OPERABLE.

APPLICABILITY: MODE 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more withdrawn A.1 Initiate action to I1T111ediately control rods fully insert inoperable. inoperable withdrawn control rods.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 -------------------NOTE--------------------

Not required to be performed until 7 days after the control rod is withdrawn.

Insert each withdrawn control rod at least In accordance one notch. with the Surveillance Frequency Control Program SR 3.9.5.2 Verify each withdrawn control rod scram In accordance accumulator pressure is ~ 1520 psig. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.9-7 Amendment No.171

RPV Water Level-Irradiated Fuel 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Reactor Pressure Vessel (RPV) Water Level-Irradiated Fuel LCO 3.9.6 RPV water level shall be~ 22 ft 9 inches above the top of the RPV flange.

APPLICABILITY: During movement of irradiated fuel assemblies within the RPV.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RPV water level not A.1 Suspend movement of Inmediately within limit. irradiated fuel assemblies within the RPV.

SURVEILLANCE REQUIREMENTS SURVEILLANCE. FREQUENCY SR 3.9.6.1 Verify RPV water level is ~ 22 ft 9 inches In accordance above the top of the RPV flange. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.9-8 Amendment No . 171

RPV Water Level-New Fuel or Control Rods 3.9.7 3.9 REFUELING OPERATIONS 3.9.7 Reactor Pressure Vessel (RPV) Water Level-New Fuel or Control Rods LCO 3.9.7 RPV water level shall be~ 23 ft above the top of irradiated fuel assemblies seated within the RPV.

APPLICABILITY: During movement of new fuel assemblies or handling of control rods within the RPV when irradiated fuel assemblies are seated within the RPV.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RPV water level not A.1 Suspend movement of Immediately within limit. new fuel assemblies and handling of control rods within the RPV.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.7.1 Verify RPV water level is~ 23 ft above the In accordance top of irradiated fuel assemblies seated with the within the RPV. Surveillance Frequency Control Program PERRY - UNIT 1 3.9-9 Amendment No. 171

RHR-High Water Level 3.9.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.8.1 Verify one RHR shutdown cooling subsystem In accordance is operating. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.9-12 Amendment No. 171

RHR-Low Water Level 3.9.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.9.1 Verify one RHR shutdown cooling subsystem In accordance is operating. with the Surveillance Frequency Control Program PERRY - UNIT 1 3. 9-15 Amendment No. 171

Reactor Mode Switch Interlock Testing 3.10.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Ccontinued.) A.3.1 Place the reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months mode switch in the shutdown position.

OR A.3.2 --------NOTE---------

Only applicable in MODE 5.

Place the reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months mode switch in the refuel position.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3 .10. 2 .1 Verify all contra l rods are fully inserted In accordance in core cells containing one or more fuel with the assemblies. Surveillance Frequency Control Program SR 3.10.2.2 Verify no CORE ALTERATIONS are in progress. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.10-5 Amendment No.171

Single Control Rod Withdrawal-Hot Shutdown 3.10.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3. 10. 3. 1 Perform the applicable SRs for the required According to LCOs. the applicable SRs SR 3.10.3.2 -------------------NOTE--------------------

Not required to be met if SR 3.10.3.1 is satisfied for LCO 3.10.3.d.1 requirements.

Verify all control rods. other than the In accordance control rod being withdrawn. in a five by with the five array centered on the control rod Surveillance being withdrawn, are disarmed. Frequency Control Program SR 3.10.3.3 Verify all control rods. other than the In accordance control rod being withdrawn. are fully with the inserted. Surveillance Frequency Control Program PERRY - UNIT 1 3.10-8 Amendment No. 171

Single Control Rod Withdrawal-Cold Shutdown 3.10.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

8. One or more of the 8.1 Suspend withdrawal of Immediately above requirements not the control rod and met with the affected removal of associated control rod not CRD.

insertable.

AND 8.2.1 Initiate action to Immediately fully insert all control rods.

OR 8.2.2 Initiate action to Immediately satisfy the re3uirements of this LC .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.4.1 Perform the applicable SRs for the required According to

LCOs. applicable SRs SR 3.10.4.2 -------------------NOTE-------------~-----

Not required to be met if SR 3.10.4.1 is satisfied for LCD 3.10.4.c.1 requirements.

Verify all control rods. other than the In accordance control rod being withdrawn. in a five by with the five array centered on the control rod Surveillance being withdrawn. are disarmed. Frequency Control Program (continued)

PERRY - UNIT 1 3.10-11 Amendment No.171

Single Control Rod Withdrawal-Cold Shutdown 3.10.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.4.3 Verify all control rods. other than the In accordance control rod being withdrawn. are fully with the inserted. Surveillance Frequency Control Program SR 3.10.4.4 -------------------NOTE--------------------

Not required to be met if SR 3.10.4.1 is satisfied for LCD 3.10.4.b.1 requirements.

Verify a control rod withdrawal block is ln accordance inserted. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.10-12 Amendment No. 171

Single CRD Removal-Refueling 3.10.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.1 Initiate action to Immediately fully insert all control rods.

OR A.2.2 Initiate action to Immediately satisfy the requirements of this LCO.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.5.1 Verify a11 contra ls rods. other than the In accordance control rod withdrawn for the removal of with the the associated CRD. are fully inserted. Surveillance Frequency Control Program SR 3.10.5.2 Verify a11 contra l rods. other than the In accordance control rod withdrawn for the removal of with the the associated CRD. in a five by five array Surveillance centered on the control rod withdrawn for Frequency the removal of the associated CRD. are Control Program disarmed.

SR 3.10.5.3 Verify a control rod withdrawal block is In accordance inserted. with the Surveillance Frequency Control Program (continued)

PERRY - UN IT 1 3.10-14 Amendment No. 171

Single CRO Removal-Refueling 3.10.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.5.4 Perform SR 3.1.1.1. According to SR 3.1. l. l SR 3.10.5.5 Verify no CORE ALTERATIONS are in progress. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.10-15 Amendment No. 171

Multiple Control Rod Withdrawal-Refueling 3.10.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3.1 Initiate action to Immediately fully insert all control rods in core cells containing one or more fuel

. assemblies.

OR A.3.2 Initiate action to Immediately satisfy the requirements of this LCO.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.6.1 Verify the four fuel assemblies are removed In accordance from core cells associated with each with the control rod or CRD removed. Survei.11 ance Frequency Control Program SR 3.10.6.2 Verify all other control rods in core cells In accordance containing one or more fuel assemblies are with the fully inserted. Surveillance Frequency Control Program SR 3.10.6.3 -------------------NOTE--------------------

Only required to be met during fuel loading.

Verify fuel assemblies being loaded are in In accordance compliance with an approved spiral reload with the sequence. Surveillance Frequency Control Program PERRY - UNIT 1 3.10-17 Amendment No . 171

SDM Test-Refueling 3.10.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.8.2 -------------------NOTE--------------------

Not required to be met if SR 3.10.8.3 satisfied.

Perform the MODE 2 applicable SRs for According to LCO 3.3.2.1. Function l.b of the applicable Table 3.3.2.1-1. SRs SR 3.10.8.3 -------------------NOTE--------------------

Not required to be met if SR 3.10.8.2 satisfied.

Verify movement of control rods is in During control compliance with the approved control rod rod movement sequence for the SDM test by a second licensed operator or other qualified member of the technical staff.

SR 3.10.8.4 . Verify no other CORE ALTERATIONS are in In accordance progress. with the Surveillance Frequency Control Program (continued)

PERRY - UN IT 1 3.10-21 Amendment No. 171

SOM Test-Refueling 3.10.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.8.5 Verify each withdrawn control rod does not Each time the go to the withdrawn overtravel position. control rod is withdrawn to "full out" position AND Prior to satisfying LCO 3.10.8.c requirement after work on control rod or CRD System that could affect coupling SR 3.10.8.6 Verify CRD charging water header pressure In accordance

~ 1520 psig. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.10-22 Amendment No . 171

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Control Room Envelope Habitability Program (continued) protection is provided to permit access and occupancy of the CRE under design basis accident (OBA) conditions without personnel receiving radiation exposures in excess of 5 rem Total Effective Dose Equivalent (TEDE) for the duration of the accident. The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.

b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

c Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.l and C.2 of Regulatory Guide 1.197. "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors."

Revision 0. May 2003. and (ii) assessing CRE habitability at the Frequencies specified in Sections C.l and C.2 of Regulatory Guide 1.197. Revision 0.

d. Measurement of leakage through the outside air intake and exhaust dampers at a Frequency of 24 months. The results shall be trended and used as part of the periodic assessment of the CRE boundary.

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences. Unfiltered air inleakage 11m1ts for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. .The provisions of SR 3.0.2 are applicable to the Freguencies for assessing CRE habitability. determining CRE unfiltered inleakage. and measuring outside air intake and exhaust damper leakage. as required by paragraphs c and d.

respectively.

(continued)

PERRY - UNIT 1 5.0-15c Amendment No. 171

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.15 Surve111 anee EC~Ql.1-§!l~.Y Contra l Prog.r.!'.!m This program provides controls for Surveillance Frequencies. The program sha 11 ensure that Surve1 l lance Requirements spec1 fied in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10. "Risk-Informed Method for Control of Surveillance Frequencies." Revision 1

c. The provisions of Surveillance Requirements 3.0 2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

PERRY - UNIT 1 5.0-15d Amendment No. 171

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 171 TO FACILITY OPERATING LICENSE NO. NPF-58 FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION. LLC OHIO EDISON COMPANY PERRY NUCLEAR POWER PLANT. UNIT NO. 1 DOCKET NO. 50-440

1.0 INTRODUCTION

By application dated March 25, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14084A165), as supplemented by letters dated October 7, 2014, and August 24, 2015 (ADAMS Accession Nos. ML14281A125 and ML15237A035, respectively), FirstEnergy Nuclear Operating Company (the licensee or FENOC) requested changes to the technical specifications (TSs) for the Perry Nuclear Power Plant, Unit 1 (PNPP or Perry). The supplemental letters dated October 7, 2014, and August 24, 2015, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register (FR) on September 16, 2014 (79 FR 55512).

The proposed changes would revise the TSs by relocating specific surveillance requirement (SR) frequencies to a licensee-controlled program in accordance with Nuclear Energy Institute (NEI) 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies" (ADAMS Accession No. ML071360456). The requested changes are consistent with the U.S. NRG-approved Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) Change Traveler TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF [Risk-Informed TSTF]

Initiative Sb" (ADAMS Accession No. ML090850642). The Federal Register notice published on July 6, 2009 (74 FR 31996), announced the availability of TSTF-425, Revision 3. When implemented, TSTF-425, Revision 3, relocates most periodic frequencies of TS surveillances to the Surveillance Frequency Control Program (SFCP), and provides requirements for the new SFCP in the Administrative Controls section of the TSs. All surveillance frequencies can be relocated except the following:

Enclosure 2

Frequencies that reference other approved programs for the specific interval (such as the lnservice Testing Program or the Primary Containment Leakage Rate Testing Program);

Frequencies that are purely event-driven (e.g., "Each time the control rod is withdrawn to the 'full out' position");

Frequencies that are event-driven, but have a time component for performing the surveillance on a one-time basis once the event occurs (e.g., "within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after thermal power reaching~ 95% RTP"); and

Frequencies that are related to specific conditions (e.g., battery degradation, age and capacity) or conditions for the performance of a surveillance requirement (e.g.,

"drywell to suppression chamber differential pressure decrease").

The licensee proposed to add the SFCP to TSs, Section 5.0, "Administrative Controls,"

Subsection 5.5, "Programs and Manuals." The SFCP describes the requirements for the program to control changes to the relocated surveillance frequencies. The TS Bases for each affected surveillance would be revised to state that the frequency is controlled under the SFCP.

The existing TS Bases information describing the basis for the surveillance frequency will be relocated to the licensee-controlled SFCP. The proposed changes to the Administrative Controls section of the TSs to incorporate the SFCP include a specific reference to NEI 04-10, Revision 1, as the basis for making any changes to the surveillance frequencies once they are relocated out of the TSs.

In a letter dated September 19, 2007 (ADAMS Accession No. ML072570267), the NRC staff approved Topical Report NEI 04-10, Revision 1, as acceptable for referencing in licensing actions, to the extent specified and under the limitations delineated in NEI 04-10, Revision 1, and in the NRC staff's safety evaluation (SE) for NEI 04-10, Revision 1.

The licensee proposed other changes and deviations from TSTF-425, which are discussed in Section 3.3 of this SE.

2.0 REGULATORY EVALUATION

2.1 Applicable Commission Policy Statements In the "Final Policy Statement: Technical Specifications for Nuclear Power Plants," dated July 22, 1993 (58 FR 39132), the NRC addressed the use of Probabilistic Safety Analysis (PSA, currently referred to as Probabilistic Risk Assessment or PRA) in STS. In this 1993 publication, the NRC states:

The Commission believes that it would be inappropriate at this time to allow requirements which meet one or more of the first three criteria [of Title 1O of the Code of Federal Regulations (10 CFR), Section 50.36] to be deleted from Technical Specifications based solely on PSA (Criterion 4). However, if the results of PSA indicate that Technical Specifications can be relaxed or removed, a deterministic review will be performed.

The Commission Policy in this regard is consistent with its Policy Statement on "Safety Goals for the Operation of Nuclear Power Plants," 51 FR 30028, published on August 21, 1986. The Policy Statement on Safety Goals states in

part, "* *

probabilistic results should also be reasonably balanced and supported through use of deterministic arguments. In this way, judgments can be made * *

about the degree of confidence to be given these [probabilistic]

estimates and assumptions. This is a key part of the process for determining the degree of regulatory conservatism that may be warranted for particular decisions.

This defense-in-depth approach is expected to continue to ensure the protection of public health and safety."

The Commission will continue to use PSA, consistent with its policy on Safety Goals, as a tool in evaluating specific line-item improvements to Technical Specifications, new requirements, and industry proposals for risk-based Technical Specification changes.

Approximately two years later, the NRC provided additional detail concerning the use of PRA in the "Final Policy Statement: Use of Probabilistic Risk Assessment in Nuclear Regulatory Activities," dated August 16, 1995 (60 FR 42622). In this publication, the NRC states:

The Commission believes that an overall policy on the use of PRA methods in nuclear regulatory activities should be established so that the many potential applications of PRA can be implemented in a consistent and predictable manner that would promote regulatory stability and efficiency. In addition, the Commission believes that the use of PRA technology in NRC regulatory activities should be increased to the extent supported by the state-of-the-art in PRA methods and data and in a manner that complements the NRC's deterministic approach ....

PRA addresses a broad spectrum of initiating events by assessing the event frequency. Mitigating system reliability is then assessed, including the potential for multiple and common cause failures. The treatment therefore goes beyond the single failure requirements in the deterministic approach. The probabilistic approach to regulation is, therefore, considered an extension and enhancement of traditional regulation by considering risk in a more coherent and complete manner....

Therefore, the Commission believes that an overall policy on the use of PRA in nuclear regulatory activities should be established so that the many potential applications of PRA can be implemented in a consistent and predictable manner that promotes regulatory stability and efficiency. This policy statement sets forth the Commission's intention to encourage the use of PRA and to expand the scope of PRA applications in all nuclear regulatory matters to the extent supported by the state-of-the-art in terms of methods and data ....

Therefore, the Commission adopts the following policy statement regarding the expanded NRC use of PRA:

( 1) The use of PRA technology should be increased in all regulatory matters to the extent supported by the state-of-the-art in PRA methods and data and in a manner that complements the NRC's deterministic approach and supports the NRC's traditional defense-in-depth philosophy.

(2) PRA and associated analyses (e.g., sensitivity studies, uncertainty analyses, and importance measures) should be used in regulatory matters, where practical within the bounds of the state-of-the-art, to reduce unnecessary conservatism associated with current regulatory requirements, regulatory guides, license commitments, and staff practices. Where appropriate, PRA should be used to support the proposal for additional regulatory requirements in accordance with 10 CFR 50.109 (Backfit Rule). Appropriate procedures for including PRA in the process for changing regulatory requirements should be developed and followed. It is, of course, understood that the intent of this policy is that existing rules and regulations shall be complied with unless these rules and regulations are revised.

(3) PRA evaluations in support of regulatory decisions should be as realistic as practicable and appropriate supporting data should be publicly available for review.

(4) The Commission's safety goals for nuclear power plants and subsidiary numerical objectives are to be used with appropriate consideration of uncertainties in making regulatory judgments on the need for proposing and backfitting new generic requirements on nuclear power plant licensees.

2.2 Applicable Regulations In 10 CFR, Section 50.36, the NRC established its regulatory requirements related to the content of TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) SRs; (4) design features; and (5) administrative controls. These categories will remain in the PNPP TSs.

Paragraph 50.36(c)(3) of 10 CFR states, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The FR notice published on July 6, 2009 (74 FR 31996),

which announced the availability of TSTF-425, Revision 3, states that the addition of the SFCP to the TSs provides the necessary administrative controls to require that surveillance frequencies relocated to the SFCP are conducted at a frequency to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The FR notice also states that changes to surveillance frequencies in the SFCP are made using the methodology contained in NEI 04-10, Revision 1, including qualitative considerations, results of risk analyses, sensitivity studies and any bounding analyses, and recommended monitoring of structures, systems, and components (SSCs), and are required to be documented.

Existing regulatory requirements, such as 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants" (i.e., the Maintenance Rule), and 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," require licensee monitoring of surveillance test failures and implementing corrective actions to address such failures. Such failures can result in the licensee increasing the frequency of a surveillance test. In addition, by

having the TSs require that changes to the frequencies listed in the SFCP be made in accordance with NEI 04-10, Revision 1, the licensee will be required to monitor the performance of SSCs for which surveillance frequencies are decreased to assure reduced surveillance testing does not adversely impact the SSCs.

2.3 Applicable NRC Regulatory Guides and Review Plans Regulatory Guide (RG) 1.174, Revision 2, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis" (ADAMS Accession No. ML100910006), describes an acceptable risk-informed approach for assessing the nature and impact of proposed permanent licensing-basis changes by considering engineering issues and applying risk insights. This regulatory guide also provides risk acceptance guidelines for evaluating the results of such evaluations.

RG 1.177, Revision 1, "An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications" (ADAMS Accession No. ML100910008), describes an acceptable risk-informed approach specifically for assessing proposed TS changes.

RG 1.200, Revision 2, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities" (ADAMS Accession No. ML090410014),

describes an acceptable approach for determining whether the quality of the PRA, in total or the parts that are used to support an application, is sufficient to provide confidence in the results, such that the PRA can be used in regulatory decision making for light-water reactors (LWRs).

General guidance for evaluating the technical basis for proposed risk-informed changes is provided in NUREG-0800, "Standard Review Plan [SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," Chapter 19, Section 19.2, "Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance" (ADAMS Accession No. ML071700658). Guidance on evaluating PRA technical adequacy is provided in SRP, Chapter 19, Section 19.1, Revision 3, "Determining the Technical Adequacy of Probabilistic Risk Assessment for Risk-Informed License Amendment Requests After Initial Fuel Load" (ADAMS Accession No. ML12193A107). More specific guidance related to risk-informed TS changes is provided in SRP, Chapter 16, Section 16.1, Revision 1, "Risk-Informed Decisionmaking: Technical Specifications" (ADAMS Accession No. ML070380228), which includes changes to surveillance test intervals (STls) (i.e.,

surveillance frequencies) as part of risk-informed decision making. Section 19.2 of the SRP references the same criteria as RG 1.177, Revision 1, and RG 1.174, Revision 2, and states that a risk-informed application should be evaluated to ensure that the proposed changes meet the following key principles:

The proposed change meets the current regulations, unless it explicitly relates to a requested exemption or rule change ....

The proposed change is consistent with the defense-in-depth philosophy.

The proposed change maintains sufficient safety margins.

When proposed changes result in an increase in core damage frequency (CDF) or risk, the increase(s) should be small and consistent with the intent of the Commission's Safety Goal Policy Statement. ...

The impact of the proposed change should be monitored using performance measurement strategies.

3.0 TECHNICAL EVALUATION

The licensee's adoption of TSTF-425, Revision 3, provides for administrative relocation of applicable surveillance frequencies to the SFCP, and provides for the addition of the SFCP to the Administrative Controls section of TSs. The changes to the Administrative Controls section of the TSs will also require the application of NEI 04-10, Revision 1, for any changes to surveillance frequencies within the SFCP. The licensee's application to implement the changes described in TSTF-425, Revision 3, included documentation regarding the PRA technical adequacy consistent with RG 1.200, Revision 2. NEI 04-10, Revision 1, states that PRA methods are used with plant performance data and other considerations to identify and justify modifications to the surveillance frequencies of equipment at nuclear power plants. This is consistent with guidance provided in RG 1.174, Revision 2, and RG 1.177, Revision 1, in support of changes to STls.

3. 1 Review Methodology Regulatory Guide 1.177, Revision 1, identifies five key safety principles required for risk-informed changes to TSs. Each of these principles is addressed by NEI 04-10, Revision 1.

3.1.1 The Proposed Change Meets Current Regulations Paragraph 50.36(c)(3) of 10 CFR Part 50 requires that TSs include surveillances which are "requirements relating to test, calibration, or inspection to assure that necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The licensee is required by its TSs to perform surveillance tests, calibration, or inspection on specific safety-related equipment (e.g.,

reactivity control, power distribution, electrical, and instrumentation) to verify system operability.

Surveillance frequencies are based primarily upon deterministic methods such as engineering judgment, operating experience, and manufacturer's recommendations. The licensee's use of NRG-approved methodologies identified in NEI 04-10, Revision 1, provides a way to establish risk-informed surveillance frequencies that complements the deterministic approach and supports the NRC's traditional defense-in-depth philosophy.

The SRs themselves are remaining in the TSs, as required by 10 CFR 50.36(c)(3). This change is analogous with other NRG-approved TS changes in which the SRs are retained in TSs, but the related surveillance frequencies are relocated to licensee-controlled documents, such as surveillances performed in accordance with the In-Service Testing Program and the Primary Containment Leakage Rate Testing Program. Thus, this proposed change complies with 10 CFR 50.36(c)(3) by retaining the requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The regulatory requirements in 10 CFR 50.65, 10 CFR Part 50, Appendix B, and the monitoring required by NEI 04-10, Revision 1, ensure that surveillance frequencies are sufficient to assure that the requirements of 10 CFR 50.36 are satisfied, and that any performance deficiencies will be identified and appropriate corrective actions taken. The licensee's SFCP ensures that SRs specified in the TSs are performed at intervals sufficient to assure the above regulatory requirements are met. Based on the above, the staff concludes that the proposed change

meets the first key safety principle of RG 1.177, Revision 1, by complying with current regulations.

3.1.2 The Proposed Change Is Consistent With the Defense-in-Depth Philosophy The defense-in-depth philosophy is maintained if:

A reasonable balance is preserved among prevention of core damage, prevention of containment failure, and consequence mitigation.

Over-reliance on programmatic activities to compensate for weaknesses in plant design is avoided.

System redundancy, independence, and diversity are preserved commensurate with the expected frequency, consequences of challenges to the system, and uncertainties (e.g., no risk outliers). (Because the scope of the proposed methodology is limited to revision of surveillance frequencies, the redundancy, independence, and diversity of plant systems are not impacted.)

Defenses against potential common cause failures are preserved, and the potential for the introduction of new common cause failure mechanisms is assessed.

Independence of barriers is not degraded.

Defenses against human errors are preserved.

The intent of the General Design Criteria in 10 CFR Part 50, Appendix A, is maintained.

The changes to the Administrative Controls section of the TSs will require the application of NEI 04-10, Revision 1, for any changes to surveillance frequencies within the SFCP.

NEI 04-10, Revision 1, uses both the CDF and the large early release frequency (LERF) metrics to evaluate the impact of proposed changes to surveillance frequencies. The guidance of RG 1.174, Revision 2, and RG 1.177, Revision 1, for changes to CDF and LERF is achieved by evaluation using a comprehensive risk analysis, which assesses the impact of proposed changes including contributions from human errors and common cause failures (CCFs).

Defense-in-depth is also included in the methodology explicitly as a qualitative consideration outside of the risk analysis, as is the potential impact on detection of component degradation that could lead to an increased likelihood of CCFs. Therefore, the NRC staff concludes that both the quantitative risk analysis and the qualitative considerations assure a reasonable balance of defense-in-depth is maintained to ensure protection of public health and safety, satisfying the second key safety principle of RG 1.177, Revision 1.

3.1.3 The Proposed Change Maintains Sufficient Safety Margins The engineering evaluation that will be conducted by the licensee under the SFCP when frequencies are revised will assess the impact of the proposed frequency change to assure that sufficient safety margins are maintained. The guidelines used for making that assessment will include ensuring the proposed surveillance test frequency change is not in conflict with approved industry codes and standards or adversely affects any assumptions or inputs to the safety analysis; or, if such inputs are affected, justification is provided to ensure sufficient safety margin will continue to exist.

The design, operation, testing methods, and acceptance criteria for SSCs specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as

described in the plants' licensing bases, including the Updated Final Safety Analysis Report and TS Bases, because these are not affected by changes to the surveillance frequencies.

Similarly, there is no impact to safety analysis acceptance criteria as described in the plant licensing basis. Based on the above, the NRC staff concludes that safety margins are maintained by the proposed methodology, and the third key safety principle of RG 1.177, Revision 1, is satisfied.

3.1.4 When Proposed Changes Result in an Increase in CDF or Risk, the Increases Should Be Small and Consistent with the Intent of the Commission's Safety Goal Policy Statement RG 1.177, Revision 1, provides a framework for evaluating the risk impact of proposed changes to surveillance frequencies which requires identification of the risk contribution from impacted surveillances, determination of the risk impact from the change to the proposed surveillance frequency, and performance of sensitivity and uncertainty evaluations. The changes to the Administrative Controls section of the TSs will require application of NEI 04-10, Revision 1, in the SFCP. NEI 04-10, Revision 1, satisfies the intent of RG 1.177, Revision 1, guidance for evaluation of the change in risk, and for assuring that such changes are small by providing the technical methodology to support risk-informed TSs for control of surveillance frequencies.

3.1.4.1 Quality of the PRA The quality of the licensee's PRA must be commensurate with the safety significance of the proposed TS change and the role the PRA plays in justifying the change. That is, the greater the change in risk or the greater the uncertainty in that risk from the requested TS change, or both, the more rigor that must go into ensuring the quality of the PRA.

Regulatory Guide 1.200 provides regulatory guidance for assessing the technical adequacy of a PRA. The current revision (i.e., Revision 2) of this RG endorses, with clarifications and qualifications, the use of (1) American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) RA-Sa-2009, "Addenda to ASME RA-S-2008 Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications" (i.e., the PRA Standard), (2) NEI 00-02, "PRA Peer Review Process Guidance" (ADAMS Accession Nos. ML061510619 and ML063390593), and (3) NEI 05-04, "Process for Performing Internal Events PRA Peer Reviews Using the ASME/ANS PRA Standard" (ADAMS Accession No. ML083430462).

The licensee has performed an assessment of the PRA models used to support the SFCP using the guidance of RG 1.200, Revision 2, to assure that the PRA models are capable of determining the change in risk due to changes to surveillance frequencies of SSCs, using plant-specific data and models. Capability Category II of the NRG-endorsed PRA standard is the target capability level for supporting requirements for the internal events PRA for this application. Any identified deficiencies to those requirements are assessed further to determine any impacts to proposed decreases to surveillance frequencies, including the use of sensitivity studies where appropriate, in accordance with NEI 04-10, Revision 1.

In Enclosure B to the application dated March 25, 2014, the licensee summarized the following:

1997 probabilistic safety assessment (PSA) peer review certification;

2008 gap analysis self-assessment to ASME/ANS PRA Standard RA-Sb-2005, "Addenda to ASME RA-S-2002 Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications";

2011 focused-scope peer review for the LERF portion of the PRA model; and

2012 focused-scope peer review for the internal flooding portion of thePRA model.

The response to PRA Request for Additional Information (RAI) 1, provided in the licensee's letter dated October 7, 2014, provides the peer review facts and observations (F&Os) findings and suggestions for the 2008 gap analysis and the 2011 and 2012 focused-scope peer reviews.

The response stated the "1997 PSA Peer Review Certification F&Os were not included as the follow-on reviews were a complete reevaluation to the PRA standard in effect and supersede this information. Therefore, the 1997 PSA Peer Review Certification F&Os are not considered relevant to the application." The response to RAI 2, provided in the licensee's letter dated August 24, 2015, clarifies that the 2008 independent gap assessment was considered to be equivalent to an industry peer review, but was not formally declared a peer review because utility peers were not part of the peer review team. The response also explained that the 2008 gap assessment reevaluated the F&Os from the 1997 peer review.

The NRC staff notes that new peer reviews, which include consideration of previous peer review findings and the licensee's implementation of the resolution to those findings, can be used to close-out earlier peer review F&Os. The original findings of the newly peer-reviewed elements are then sunset/eliminated and replaced by any new findings resulting from the new peer review. The NRC staff also notes that gap assessments need to be performed if the latest peer review was not against the latest endorsed PRA Standard and associated revision to RG 1.200 (i.e., Revision 2). In Enclosure B to the application dated March 25, 2014, the licensee explained that both the LERF and internal flooding portions of the model were peer reviewed against the currently endorsed PRA Standard. In response to RAI 3, provided in the licensee's letter dated August 24, 2015, the results of the gap analysis to the currently endorsed PRA Standard were provided for the remaining portions of the PNPP PRA. The licensee explained that no gaps were identified as a result of this assessment. Therefore, the NRC staff concluded that the use of the F&Os from the 2008 gap analysis, with the additional gap analysis to the current PRA Standard, and the 2011 and 2012 focused-scope peer reviews was acceptable, and the F&Os from the 1997 PSA Peer Review Certification were not relevant to the application.

The NRC staff reviewed (1) the summary of the peer review finding and (2) the licensee's resolution to the finding, for the F&Os listed in the responses to RAI 1, provided in the licensee's letter dated October 7, 2014, to determine whether any gaps in the PRA model were identified that could impact the application. The NRC staff assessed these peer review F&Os to ensure any deficiencies in meeting Capability Category II can be addressed for the SFCP per the NRG-approved NEI 04-10, Revision 1 methodology.

The NRC staff concluded that the F&O dispositions were acceptable for this application, but noted several PRA revisions which could constitute "PRA upgrades" as defined in the PRA Standard. The PRA Standard defines upgrades as, "incorporation into a PRA model of a new methodology or significant changes in scope or capability that impact the significant accident sequences or the significant accident progression sequences." A PRA revision that constitutes a PRA upgrade requires a peer review, in accordance with the endorsed PRA Standard.

The response to RAI 2, provided in the licensee's letter dated August 24, 2015, reviewed the disposition of model changes and discussed the PRA Standard Supporting Requirements that were evaluated as part of the focused-scope peer reviews, which would have identified gaps in the underlying logic model (i.e., the Internal Events PRA). As part of this review, the licensee determined that the change in offsite power recovery modeling was considered to be a PRA upgrade. The licensee stated that a focused-scope peer review was performed in July 2015 for the Supporting Requirements related to offsite power recovery: DA-A 1, DA-C 1, DA-C 16, AS-87, QU-A 1, QUA2, QU-A5, and QU-F2. In the RAI 2 Response Attachment, included in the licensee's letter dated August 24, 2015, the licensee stated:

The offsite power recovery focused scope peer review did not result in any findings, but did identify a number of suggestions. Those suggestions were items to correct or enhance the documentation, and are not expected to have any impact on the results of the offsite power recovery analysis and implementation.

The NRC staff reviewed the F&O suggestions and concluded that the recommendations for enhanced documentation would not impact this application.

Based on the licensee's assessments using the currently applicable PRA standard and revision of RG 1.200, the NRC staff concludes that the level of PRA quality, combined with the evaluation and disposition of gaps, is sufficient to support the evaluation of changes proposed to surveillance frequencies within the SFCP, and is consistent with Regulatory Position 2.3.1 of RG 1.177, Revision 1.

3.1.4.2 Scope of the PRA The changes to the Administrative Controls section of the TSs will require the licensee to evaluate each proposed change to a relocated surveillance frequency using NEI 04-10, Revision 1, to determine its potential impact on risk (i.e., CDF and LERF) from internal events, fires, seismic, other external events, and shutdown conditions. In cases where a PRA of sufficient scope or quantitative risk models are unavailable, the licensee uses bounding analyses, or other conservative quantitative evaluations. A qualitative screening analysis may be used when the surveillance frequency impact on plant risk is shown to be negligible or zero.

The licensee has an at-power internal events and internal flooding PRA model. In accordance with NEI 04-10, Revision 1, the licensee will use these models to perform quantitative evaluations to support the development of changes to surveillance frequencies in the SFCP.

This is acceptable because the NRC-approved methodology in NEI 04-10, Revision 1, allows for more refined analysis to be performed to support changes to surveillance frequencies in the SFCP.

In Enclosure B to its application dated March 25, 2014, the licensee stated that the PNPP seismic PRA has not been completed. The licensee stated that until the seismic PRA is implemented, the results of the seismic margin assessment performed for the Individual Plant Examination of External Events (IPEEE) must be qualitatively evaluated for its impact on STI extensions. The licensee also stated that the PNPP PRA does not include a fire model and the results of the fire risk assessment performed for the IPEEE must be qualitatively assessed for its impact on STI extensions. The licensee also stated that its IPEEE concluded that the risk of

other external events, such as high winds, floods, aircraft accidents, hazardous materials, and turbine missiles, determined that there are no significant events of concern. In accordance with NEI 04-1 O, Revision 1, the licensee can perform qualitative or quantitative analyses to evaluate the impact of external events on surveillance frequency changes.

In Enclosure B to its application dated March 25, 2014, the licensee explained that PNPP does not currently have a low power or shutdown PAA model. However, the licensee explained that the PNPP SFCP will qualitatively assess shutdown events using the principles contained in NUMARC 91-06, "Guidelines for Industry Actions to Address Shutdown Management," (ADAMS Accession No. ML14365A203), consistent with NEI 04-10, Revision 1.

Based on the above, the NRG staff concludes that through the application of NRG-approved NEI 04-10, Revision 1, the licensee's evaluation methodology is sufficient to ensure that the scope of the risk contribution of each surveillance frequency change is properly identified for evaluation and is consistent with Regulatory Position 2.3.2 of AG 1.177, Revision 1.

3.1.4.3 PAA Modeling The licensee's methodology includes the determination of whether the SSCs affected by a proposed change to a surveillance frequency are modeled in the PAA. Where the SSC is directly or implicitly modeled, a quantitative evaluation of the risk impact may be carried out.

The methodology adjusts the failure probability of the impacted SSCs, including any impacted CCF modes, based on the proposed change to the surveillance frequency. Where the SSC is not modeled in the PAA, bounding analyses are performed to characterize the impact of the proposed change to the surveillance frequency. Potential impacts on the risk analyses due to screening criteria and truncation levels are addressed by the requirements for PAA technical adequacy consistent with guidance contained in AG 1.200, and by sensitivity studies identified in NEI 04-10, Revision 1.

Based on the above, the NRG staff concludes that through the application of NRG-approved NEI 04-10, Revision 1, the PNPP PAA modeling is sufficient to ensure an acceptable evaluation of risk for the proposed changes in surveillance frequency, and is consistent with Regulatory Position 2.3.3 of AG 1.177, Revision 1.

3.1.4.4 Assumptions for Time Related Failure Contributions The failure probabilities of SSCs modeled in PRAs may include a standby time-related contribution and a cyclic demand-related contribution. In Enclosure B to its application dated March 25, 2014, the licensee explained that the standby time-related contribution evaluation will be performed in accordance with NEI 04-10, Revision 1. NEI 04-10, Revision 1, criteria adjust the time-related failure contribution of SSCs affected by the proposed change to a surveillance frequency. This is consistent with AG 1.177, Revision 1, Section 2.3.3, which permits separation of the failure rate contributions into demand and standby for evaluation of SRs. If the available data do not support distinguishing between the time-related failures and demand failures, then the change to surveillance frequency is conservatively assumed to impact the total failure probability of the SSC, including both standby and demand contributions. The SSC failure rate (per unit time) is assumed to be unaffected by the change in test frequency, such that the failure probability is assumed to increase linearly with time, and will be confirmed by the required monitoring and feedback implemented after the change in surveillance frequency is

implemented. The NEI 04-10 process requires consideration of qualitative sources of information with regards to potential impacts of test frequency on SSC performance, including industry and plant-specific operating experience, vendor recommendations, industry standards, and code-specified test intervals. Thus, the process is not reliant upon risk analyses as the sole basis for the proposed changes.

The potential benefits of a reduced surveillance frequency, including reduced downtime and reduced potential for restoration errors, test-caused transients, and test-caused wear of equipment, are identified qualitatively, but are not quantitatively assessed. NEI 04-10, Revision 1, requires performance monitoring of SSCs whose surveillance frequencies have been revised as part of a feedback process to assure that the change in test frequency has not resulted in degradation of equipment performance and operational safety. The monitoring and feedback includes consideration of Maintenance Rule monitoring of equipment performance. In the event of SSC performance degradation, the surveillance frequency will be reassessed in accordance with the methodology, in addition to any corrective actions which may be required by the Maintenance Rule.

Based on the above, the NRC staff concludes that through the application of NRG-approved NEI 04-10, Revision 1, the licensee has employed reasonable assumptions with regard to extensions of STls, and is consistent with Regulatory Position 2.3.4 of RG 1.177, Revision 1.

3.1.4.5 Sensitivity and Uncertainty Analyses By having the TSs require that changes to the frequencies listed in the SFCP be made in accordance with NEI 04-10, Revision 1, the licensee will be required to have sensitivity studies that assess the impact of uncertainties from key assumptions of the PRA, uncertainty in the failure probabilities of the affected SSCs, impact on the frequency of initiating events, and any identified deviations from Capability Category II of the PRA standard. Where the sensitivity analyses identify a potential impact on the proposed change, revised surveillance frequencies are considered, along with any qualitative considerations that may bear on the results of such sensitivity studies. The licensee will also be required to perform monitoring and feedback of SSC performance, once the revised surveillance frequencies are implemented. Based on the above, the NRC staff concludes that through the application of NRG-approved NEI 04-10, Revision 1, the licensee has appropriately considered the possible impact of PRA model uncertainty and sensitivity to key assumptions and model limitations and is consistent with Regulatory Position 2.3.5 of RG 1.177, Revision 1.

3.1.4.6 Acceptance Guidelines In accordance with the TS SFCP, the licensee will be required to quantitatively evaluate the change in total risk (including internal and external events contributions) in terms of CDF and LERF for both the individual risk impact of a proposed change in surveillance frequency and the cumulative impact from all individual changes to surveillance frequencies using NEI 04-10, Revision 1. Each individual change to surveillance frequency must show a risk impact below 1E-6 per year for change to CDF, and below 1E-7 per year for change to LERF. These changes to CDF and LERF are consistent with the acceptance criteria of RG 1.174, Revision 2, for very small changes in risk. Where the RG 1.174, Revision 2, acceptance criteria are not met, the process in NEI 04-10, Revision 1, either considers revised surveillance frequencies that are consistent with RG 1.174, Revision 2, or the process terminates without permitting the

proposed changes. Where quantitative results are unavailable for comparison with the acceptance guidelines, appropriate qualitative analyses are required to demonstrate that the associated risk impact of a proposed change to surveillance frequency is negligible or zero.

Otherwise, bounding quantitative analyses are required that demonstrate the risk impact is at least one order of magnitude lower than the RG 1.174, Revision 2, acceptance guidelines for very small changes in risk. In addition to assessing each individual SSC surveillance frequency change, the cumulative impact of all changes must result in a risk impact less than 1E-5 per year for change to CDF, and less than 1E-6 per year for change to LERF, and the total CDF and total LERF must be reasonably shown to be less than 1E-4 per year and 1E-5 per year, respectively. These values are consistent with the acceptance criteria of RG 1.174, Revision 2, as referenced by RG 1.177, Revision 1, for changes to surveillance frequencies.

Consistent with the NRC's SE dated September 19, 2007, for NEI 04-10, Revision 1, the TS SFCP will require the licensee to calculate the total change in risk (i.e., the cumulative risk) by comparing a baseline model that uses failure probabilities based on surveillance frequencies prior to being changed per the SFCP to a revised model that uses failure probabilities based on the changed surveillance frequencies. The NRC staff further notes that the licensee includes a provision to exclude the contribution to cumulative risk from individual changes to surveillance frequencies associated with insignificant risk increases (i.e., less than 5E-8 CDF and 5E-9 LERF) once the baseline PRA models are updated to include the effects of the revised surveillance frequencies.

The quantitative acceptance guidance of RG 1.174, Revision 2, is supplemented by qualitative information to evaluate the proposed changes to surveillance frequencies, including industry and plant-specific operating experience, vendor recommendations, industry standards, the results of sensitivity studies, and SSC performance data and test history. The final acceptability of the proposed change is based on all of these considerations and not solely on the PRA results. Post implementation performance monitoring and feedback are also required to assure continued reliability of the components. Based on the above, the NRC staff concludes that the licensee's application of NRG-approved NEI 04-10, Revision 1, provides acceptable methods for evaluating the risk increase associated with proposed changes to surveillance frequencies, consistent with Regulatory Position 2.4 of RG 1.177, Revision 1.

Therefore, the staff concludes that the proposed methodology satisfies the fourth key safety principle of RG 1.177, Revision 1, by assuring any increase in risk is small consistent with the intent of the Commission's Safety Goal Policy Statement.

3.1.5 The Impact of the Proposed Change Should Be Monitored Using Performance Measurement Strategies The licensee's adoption of TSTF-425, Revision 3, requires application of NEI 04-10, Revision 1, in the SFCP. NEI 04-10, Revision 1, requires performance monitoring of SSCs whose surveillance frequencies have been revised as part of a feedback process to assure that the change in test frequency has not resulted in degradation of equipment performance and operational safety. The monitoring and feedback includes consideration of Maintenance Rule monitoring of equipment performance. In the event of SSC performance degradation, the surveillance frequency will be reassessed in accordance with the methodology, in addition to any corrective actions which may be required by the Maintenance Rule. The performance monitoring and feedback specified in NEI 04-10, Revision 1, is sufficient to reasonably assure

acceptable SSC performance and is consistent with Regulatory Position 3.2 of RG 1.177, Revision 1. Thus, the staff concludes that the fifth key safety principle of RG 1.177, Revision 1, is satisfied.

3.2 Addition of Surveillance Frequency Control Program to Administrative Controls The licensee proposed including the SFCP and specific requirements into the PNPP TSs, Section 5.5.15, as follows:

Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure that the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Technical Specifications Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

The proposed program is consistent with the model application of TSTF-425 and, therefore, the staff concludes that it is acceptable.

3.3 Deviations from TSTF-425 and Other Changes In Section 2.2 of the application, dated March 25, 2014, the licensee identified deviations from TSTF-425, Revision 3. The staff's evaluation of the deviations is provided in the sections below.

3.3.1 Basis Insert Revision The insert provided in TSTF-425 for the TS Bases states, "The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk, and is controlled under the Surveillance Frequency Control Program." In a letter dated April 14, 2010 (ADAMS Accession No. ML100990099), the NRC staff agreed that the insert applies to surveillance frequencies that are relocated and subsequently evaluated and changed in accordance with the SFCP, but does not apply to frequencies relocated to the SFCP but not changed. Therefore, the licensee revised the insert for the Bases to, "The Surveillance Frequency is controlled under the Surveillance Frequency Control Program." The licensee stated that this is an administrative deviation from TSTF-425 with no impact on the NRC staff's model SE dated July 6, 2009 (7 4 FR 31996). The NRC staff evaluated the proposed changes and finds that the changes

submitted to the TS Bases are consistent with the TS changes. The staff agrees that the deviation is administrative in nature and does not impact the staff's model SE. Therefore, the staff finds these changes to be acceptable.

3.3.2 Technical Specification Section 5.5.15 Insert The TSTF-425 TS Section 5.5.15 insert references NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies." The licensee proposed the following revision to the reference to NEI 04-10 in TS Section 5.5.15: "Risk-Informed Technical Specifications Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies." The licensee stated that this is an administrative deviation from TSTF-425 with no impact on the NRC's model SE dated July 6, 2009 (74 FR 31996). The NRC staff evaluated this deviation and determined that the proposed change is the correct and full title of NEI 04-10, as transmitted to the NRC by NEI by letter April 19, 2007 (ADAMS Accession No. ML071360426). Therefore, the staff finds this administrative change to be acceptable.

3.3.3 Differences Between PNPP TSs and NUREG-1434 The licensee provided a cross reference between NUREG-1434, "Standard Technical Specifications General Electric BWR/6 Plants," SRs included in TSTF-425 versus the PNPP SRs included in the LAR. The licensee categorized the cross-reference into the following basic categories:

NUREG-1434 SRs included in TSTF-425 and corresponding PNPP SRs with identical SR numbers;

NUREG-1434 SRs included in TSTF-425 and corresponding PNPP SRs with differing SR numbers;

NUREG-1434 SRs included in TSTF-425 that are not contained in the PNPP TS; and

PNPP plant-specific SRs that are not contained in NUREG-1434.

For the first three categories, the licensee considers the deviations to be administrative deviations from TSTF-425 with no impact on the NRC's model SE dated July 6, 2009 (74 FR 31996). The NRC staff has evaluated these deviations and agrees that they are administrative in nature, and do not impact the NRC's model SE. Therefore, the staff finds these deviations to be acceptable.

For the last category, in Section 2.2 of the application dated March 25, 2014, the licensee identified the following PNPP plant-specific TSs and associated SRs that are not contained in NUREG-1434:

3.3.1.3, "Oscillation Power Range Monitor (OPRM) Instrumentation"

3.6.1.8, "Feedwater Leakage Control System (FWLCS)"

3.6.1.10, "Primary Containment - Shutdown"

3.6.1.11, "Containment Vacuum Breakers"

3.6.1.12, "Containment Humidity Control"

3.7.8, "Fuel Handling Building (FHB)"

3.7.9, "FHB Ventilation Exhaust System"

3. 7 .10, "Emergency Closed Cooling Water (ECCW) System"

The licensee determined that, with the exception of SR 3.7.9.2, the PNPP plant-specific SRs involve fixed periodic frequencies and do not meet any of the four exclusion criteria of TSTF-425 (delineated in Section 1.0 of this SE). Changes to SR frequencies that do not meet the exclusion criteria would be controlled under the SFCP. The licensee stated that the SFCP provides the necessary administrative controls to require that surveillances related to testing, calibration, and inspection are conducted at a frequency to assure that the necessary quality of the systems and components is maintained, the facility operation will be within safety limits, and that the LCOs will be met. The licensee also stated that the changes to frequencies in the SFCP would be evaluated using the methodology and probabilistic risk guidelines contained in NEI 04-10, Revision 1, as approved by NRC letter dated September 19, 2007. The NEI 04-10, Revision 1 methodology includes qualitative considerations, risk analyses, sensitivity studies, and bounding analyses, as necessary, and recommended monitoring of the performance of SSCs for which frequencies are changed to assure that reduced testing does not adversely impact the SSCs. The NEI 04-10, Revision 1 methodology satisfies the five key safety principles specified in RG 1.177 relative to changes in surveillance frequencies. Therefore, the licensee stated that the proposed relocation of the PNPP-specific surveillance frequencies is consistent with TSTF 425 and with the NRC staff's model SE dated July 6, 2009 (74 FR 31996).

The staff has evaluated the proposed deviation for the identified plant-specific TS SRs listed Section 2.2 of the application and has determined that the SR frequencies, with the exception of SR 3.7.9.2, do not meet any of the exclusion criteria in TSTF-425, Revision 3, and that the frequencies are fixed periodic frequencies. Surveillance Requirement 3.7.9.2 is not being relocated to the SFCP by the licensee. Therefore, the staff finds that relocation of these plant-specific TS SR frequencies to the SFCP is acceptable.

3.4 Summary and Conclusions The NRC staff has reviewed the licensee's proposed relocation of specific surveillance frequencies to a licensee-controlled document, and controlling changes to these surveillance frequencies in accordance with a new program, the SFCP, identified in the Administrative Controls of TSs. The NRC staff confirmed that this amendment does not relocate surveillance frequencies that reference other approved programs for the specific interval, are purely event-driven, are event-driven but have a time component for performing the surveillance on a one-time basis once the event occurs, or are related to specific conditions. The SFCP and TSs Section 5.0, Subsection 5.5.15 references NEI 04-10, Revision 1, which provides a risk-informed methodology using plant-specific risk insights and performance data to revise surveillance frequencies within the SFCP. This methodology supports relocating surveillance frequencies from TSs to a licensee-controlled document, provided those frequencies are changed in accordance with the NEI 04-10, Revision 1, which is specified in the Administrative Controls section of the TSs.

The proposed licensee adoption of TSTF-425, Revision 3, and risk-informed methodology of NRG-approved NEI 04-10, Revision 1, as referenced in the Administrative Controls section of TSs, satisfies the key principles of risk-informed decision making applied to changes to TSs as delineated in RG 1.177 and RG 1.174, in that:

The proposed change meets current regulations;

The proposed change is consistent with defense-in-depth philosophy;

The proposed change maintains sufficient safety margins;

Increases in risk resulting from the proposed change are small and consistent with the Commission's Safety Goal Policy Statement; and

The impact of the proposed change is monitored with performance measurement strategies.

The regulation in 10 CFR 50.36(c) discusses the categories that will be included in TSs. The regulation in 10 CFR 50.36(c)(3) discusses the specific category of Surveillance Requirements and states: "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The NRC staff finds that with the proposed relocation of surveillance frequencies to a licensee-controlled document and administratively controlled in accordance with the TS SFCP, the licensee continues to meet the regulatory requirement of 10 CFR 50.36, and specifically, 10 CFR 50.36(c)(3), Surveillance Requirements.

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or changes the surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (79 FR 55512). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that 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.

Principal Contributor: D. Gennardo, NRR J. Evans, NRR Date: February 23, 2016

ML15307A349 *by email OFFICE DORL/LPL3-1 /PM DORL/LPL3-1/LA DRA/APLA/BC DSS/SRXB/BC NAME KGreen MHenderson SRosenberg CJackson DATE 01/29/16 01/26/16 10/30/2015 11/13/2015 OFFICE DSS/STSB/BC DE/El CB/BC* DE/EEEB DE/EEEB TMartinez-Navedo NAME RElliott MWaters (non-concur) SSom (non-concur)

DATE 11/19/2015 11/22/2015 2/16/2016 2/02/2016 OFFICE DE/EEEB* DE/EEEB DE/EE EB DE/EEEB/BC NAME GMatharu (non-concur) SRay (non-concur) RMathew (non-concur) JZimmerman (non-concur)

DATE 2/03/2016 2/03/2016 2/03/2016 2/03/2016 OFFICE OGC DORL/DD DORL/LPL3-1 /BC DORL/LPL3-1 /PM STurk (NLO w/noted NAME changes) GWilson DWrona KGreen DATE 2/10/2016 2/23/2016 2/22/2016 2/23/2016

v t e Letter Sequence Approval
CAC:MF3720, (Approved, Closed)
Initiation Acceptance... Administration Questions Answers Results Approval Other:
MONTHYEAR2016-02-23 [Table View]

ML15307A349

Text

SUBJECT:

Dear Mr. Hamilton:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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