ML20155F450

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Proposed Revised Improved Tech Specs (ITS) Deleting Note Re Number of Required Channels for Degrees of Subcooling Function & Subdividing Core Exit Temp Function Into Two New Functions in ITS Table 3.3.17-1
ML20155F450
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 10/30/1998
From:
FLORIDA POWER CORP.
To:
Shared Package
ML20155F448 List:
References
NUDOCS 9811060035
Download: ML20155F450 (14)
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Text

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l FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 ATTACIIMENT B 1

l LICENSE AMENDMENT REQUEST #246 REVISION 0 i

l l

Proposed ITS and ITS Bases Change Pages - Strikethrough/ Highlight I

StMe'h:re;;h Ter! Deleted, Highlistid T5t Added 9811060035 981030 M PDR ADOCK 05000302 P ppgy

PAM Instrumentation 3.3.17 ll

, . Table 3.3.17-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITIONS REFERENCED FROM FUNCTION REQUIRED CHANNELS REQUIRED ACTION D.1

1. Wide Range Neutron Flux 2 E
2. . RCS Hot Leg Temperature 2' E
3. RCS Pressure (Wide Range) 2 E
4. Reactor Coolant Inventory 2 F
5. Borated Water Storage Tank Level "2 E

. 6. High Pressure Injection Flow 2 per injection line E

- 7. Containment Sump Water Level (Flood Level) 2 E 8; Containment Pressure (Expected Post-Accident 2 E Range) 9, Containment Pressure (Wide Range) 2 E

10. Containment Isolation Valve Position 2 per penetration (a)(b) E
11. Containment Area Radiation (High Range) 2 F
12. Containment Hydrogen Concentration 2 E
13. Pressurizer Level 2 E
14. Steam Generator Water Level (Start-up Range) 2 per OTSG E

' 15. Steam Generator Water Level (Operating Range) 2 per OT5G E

16. Steam Generator Pressure 2 per OTSG E
17. Emergency Feedwater Tank Level 2 E 184. Core Exit Temperature (Backup) (Tliermocouple) 3 2 thermoceupled per core E quadrant Mb Core ~ Exit.TemperatisreE(Recorder) 2 E
19. Emergency Feedwater Flow 2 per.0TSG E
20. Low Pressure Injection Flow 2 E
21. Degrees of Subcooling 2(d) E
22. ~ Emergency Diesel Generator kW Indication 2(c) E (a) Only one position indication is required for penetrations with one Control Room indicator.

(b) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

- (c) - One indicator per EDC. j l

(d)--Thes; ;e Chenisi; ef a bii~}ing eigin ere becked-trp-by-either-of-twe-fndiettfons-ef-si.bceeling eigin I l,e;;; en sim+1er-4npitt; h. e.sh ;he Sefe;y "aremeter-0+ splay-Systee-(SPDSb-Atdeest en; 5"05 chennct must%veilable ;e pre-dde-this bedi.p. Wi;h both-S"05 channels-INOPERA0th-Condition-E-+s i appl +eebler  !

Crystal River Unit 3 3.3-41 Amendment No, j i

l

. .+

PAM Instrumentation B 3.3.17

(

I BASES FUNCTION CHANNEL A CHANNEL B

15. Steam Generator Water Level OTSG A: SP-17-LII or OTSG A: SP-18-LIl (Operating Range) SP-17-LIR OTSG B: SP-22-LIl l OTSG B: SP-21-LIl or l SP-21-LIR 1

1

16. Steam Generator OTSG A: MS-106-PIl or OTSG A: MS-107-PIl or Pressure MS-106-PIR MS-107-PIR OTSG B: MS-110-PIl or OTSG B: MS-111-PIl or MS-110-PIR MS-111-PIR  ;

i

! 17. Emergency Feedwater EF-98-LIl EF-99-LIl l- Tank Level 18s. Core Exit Quadfant Temperature WX IN-5G4TE/ W 6C-TE IM-7F-TE/ W 2C-TE (Backtep) XY IM-9E-TE/IM-13G-TE W 10C-TE/IM-11G-TE (Thermocouple) YZ IM-9H-TE/IM-100-TE N 10M-TE/IM-13L-TE ZW IM-3L-TE/IM-60-TE IM-4N-TE/IM-6L-TE 18b! Core?Esit*Temperatsre RCs171-TR RG172sTR l CRecorder)

Three-detectors free cech of the fcHowing gre Qttedrer,I WX; IM-2G-TEfIM-SG-TE/IM-6C-TE/IM-7F-TE Qttadrant-XYt-IM-9E-TE/IM-10C-TEfIM-11G-TEfIM-136-TE Qtradrant-YZt-IM-9H-TE/IM-10M-TE/IM-100-TE/IM-13t.--TE Qtradrant-Nt-IM-9t:-TE/IM-4N-TE/IM-6t-TE/IM-60-TE and "ecerdere "C-171-TRr-RC-171-TR-4tE-473-TR I

19. Emergency Feedwater OTSG A: EF-26-FIl OTSG A: EF-26-FIl Flow OTSG B: EF-24-FIl OTSC B: EF-24-FIl
20. Low Pressure Injection Flow DHV-110 Hand / Auto station flow DHV-111 Hand / Auto station flow indication (DH-1-FK3-1) indication (DH-1-FK4-1) l
21. Degrees of Subcooling RC-4-T-I4-and EMC0238 RC-4-TI+-and ENCO-39 SPDS "A" er S"DS "B"
22. Emergency Diesel Generator ECDG-1A Wattmeter SSF-AH Main ECDG-1B Wattmeter SSF-AX Main kW Indication control board indicator control board indicator NOTES: For Function 18a. each?quadrantfrequiresiatlleast'2 OPERABLCdetectoisEone7fromfeach~ channel')

OPERABILITY of only two one detectors-(and-associated recerder) for any grottp quadrant constitutes entry into Condition A of LCO 3.3.17 Any grotep quadrant with only-one to OPERABLE detector /recerder cediaation constitutes entry into Condition C of LCO 3.3.17. Separate Condition entry is allowed for each grotsp iguadrant.

For Function 21. Mth-both-channels-of-S"05 i {+erettler-Lf0-fonditica C and its-asseefated "equired Action-are-appl +cabler (continued)

Crystal River Unit 3- B 3.3-125B Amendment No.

L .- ..

PAM Instrumentation B 3.3.17 BASES l

'~

LCO 17. Emeraency Feedwater Tank Level (continued)

The dedicated emergency feedwater (EFW) tank provides the assured, safety grade water supply for the

! Emergency Feedwater System. The EFW tank inventory is monitored and displayed by 0 to 38 feet control room level indications. The control room indicators and alarms are considered the primary indication used by the operator. Therefore, -the LCO deals specifically with this portion of the instrument string.

The design basis accidents which require emergency feedwater are those in which the main feedwater supply and/or the electrical supply to the vital feedwater -

auxiliaries has been lost, e.g., a feedwater line break or a loss of offsite power. In the event of such a loss er feedwater, the EFW tank is the initial i source of water for the EFW System. As the EFW tank l is depleted, manual operator action is necessary to

l. replenish the EFW tank or to realign the suction to the EFW pumps. Since tank level is required by the operator for manual actions following an event, it has been included in this LCO.

183. Core Exit Temoerature 'Sackus) YT6EiiidEossTeT The core exit thermocouples (CETs) provide an indication of the reactor coolant temperature as it exits the active region of the core. The CET5dpfovid5

,inputsto accident monitoring instrumentation provides a display of core exit temperature over a range of 0 l to 2500 F. The displays consists efkissd[in~cluds 16

separate temperature measurements from 16 CETs, four

! from each quadrant. Each of tThese 16 core exit temperature measurements is Ire _ continuously recorded _

in the control room on three two separate recorders as desditiedii ni F0hcti6n718bP and r pFovideli niiut!t6" the

~ Safety 1 Parameter DisplayJSystemt(SPDS)sfor, determinihg s ubcool i ngi margi n; as ; des c r.i bed;ii n d Functi oni 21. Since the control reem dispysy is the p"rimary iridication i used by the sperator distributi6n of? OPERABLE <CETsIfs impoFtahtsfo' r jassurisg af representativedindicationiof l temperaturesiacrossitheicore, this LCO deals L specifically with this portion of the instrument string.

The CETs are considered the primary indication of the reactor _ coolant temperature. Core exit temperature is TheJCETsjare included in this LCO because the operator uses tMs thE indication fromithe;CETs to monitor the cooldown of the RCS following a steam generator tube rupture or small break LOCA. Operator actions to maintain a controlled cooldown, such as adjusting OTSG 1evel or pressure, would be prompted by this indication.

(continued)

Crystal River Unit 3 B 3.3-137 Amendment No.

l l

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PAM Instrumentation I

B 3.3.17 BASES LCO 18b'.E Co re' Ekit"Temoe ratWe7 Reco r'd e rl

[E(cdntinued)

The tore ~ exi tTtemperatdreTrecor' derf provi de ~ari indication of;the7reactorc coolantitemperature'as?it

~

exits 2the(active regiontoflthe' core _overfaerange*ofLO to?2500*FR CInputttoteach: recorderc isifromTeight:CETsl two;from. eachi core quadrants:,to : provide' a representative: distribution ofetemperatures7acrossithe

'coren Since the" control? room: display is(the ~ primary indicationfused byithe: operator,9thisLLCO deals

' pecifically;withi.thisiportion;ofAthehinstrument s

' string!

Core7 ekitlitimperatdreTisiconsidereditheTprimar9 indicationiof th'e) reactor coolantjtemperature'H:and is

^

included!in$thisiLC01.becabse;theLoperator?usesithis indication following .pto monitorith'elcooldown.:ofdthe::RCS a steam' generator" tube; rupture:orismall break; LOCA.d 0pe rato r ; acti on s! to ' mai ntai n . 'a Econt roll ed cooldown,:.:such 'astadjusting OTSG zlevel;ormpressure,'

would;be? prompted,byathis11ndication.!

l

19. Emeraency Feedwater Flow EFW Flow instrumentation is provided to monitor operation of decay heat removal via the OTSGs. The EFW injection flow to each OTSG (2 channels per OTSG, one associated with each EFW injection line) is determined from a differential pressure measurement calibrated to a span of 0 gpm to 1000 gpm. Each differential pressure transmitter provides an input to a control room indicator and the plant computer.

EFW Flow is used by the operator to determine the need to throttle flow during accident or transient conditions to prevent excessive RCS cooldown rates when low decay heat levels are present. EFW Flow is also used by the operator to verify that the EFW System is delivering the correct flow to each OTSG.

However, the primary indication of this function is provided by OTSG level.

These instruments are not assumed to provide information required by the operator to take a mitigation action specified in the safety analysis.

As such, they are not Type A variables. However, the monitors are deemed risk significant (Category 1) and are included within the LCO based upon this consideration.

l (continued) l Crystal River Unit 3 8 3.3-138 Amendment No.

, PAM Instrumentation B 3.3.17 BASES LCO 20. Low Pressure Iniection Flow (continued)

Low pressure injection flow instrumentation is provided to monitor flow to the RCS following a large break LOCA. It is also used to monitor LPI flow during piggy back operation following a small break LOCA. The low pressure injection flow to the rector (2 channels, one associated with.each LPI injection line) is determined from a differential pressure measurement calibrated to a span of 0 gpm to 5000 gpm.

~

The LPI flow indication is used by the operator to throttle the flow to < 2000 gpm prior to switching the pump suction from the BWST to the RB sump. This assures adequate net positive suction head (NPSH) is maintained to the pump. The indication is also used to verify LPI flow to the reactor as a prerequisite to termination of HPI flow.

Since low pressure injection flow is a Type A variable on which the operator bases manual actions required for event mitigation for which no automatic controls are provided, it has been included in this LCO.

21. Degrees of Subcooling Two channels of subcooling margin with inputs from RCS hot leg temperature (T"), core exit temperature, and RCS pressure are provided byltheiSafetyl.Parameteh DisplaV! System:(SPDS)'. Multiple core exit temperatures are auctioneered with only the highest temperature being input to the monitor. A-note-has been added to indicate that the twc channels-of subcooling margin are backed up by either of two ind+eations of subeooWg-margin based-on-simi+ar inputs through the-Safety-Parameter Display System (SPOS). At least One SPOS channel must be available to-provide thi5 backup. With both-SPDS-ehanneh INOPERABLE, Ccadition-C-h-appheabic. This is cons 4dered-necessary-because-the core ex+t thermecouple-4nputs to the subccoling margin monitors are not environmentally-qualified. The T inputs to the SPDS subcooling margin monitors and-SbDS operate over a range of 120 to 920 F. The core exit temperature inputs operate over a range of 150-to 2000ar and 150 0 to 2500 F for-the-subcooHng-margi-n monitors and SPDS, respectively. RCS pressure inputs operate over a wide range of 200 to 2500 psig anddow i angelofl0;tC600cpsig.

(continued)

Crystal River Unit 3 8 3.3-138A Amendment No.

PAM Instrumentation B 3.3.17 BASES LCO 21. Dearees of Subcooling (continued)

The subcooling margin monitors are used to verify the existence of, or to take actions to ensure the restoration of subcooling margin. Specifically, a loss of adequate subcooling margin during a LOCA

! requires the operator to trip the reactor coolant pumps (RCP's), to ensure high or low pressure injection, and raise the steam generator levels to the inadequate subcooling margin level. Since degrees of subcooling is a. Type A variable on which the operator bases manual actions required for event mitigation for l which no automatic control are provided, it has been l included in this LCO.

22. Emeraency Diesel Generator. kW Indication The Emergency Diesel Generator (EDG) provides standby (emergency) electrical power in the case of Loss of Offsite Power (LOOP). EDG kW indication is provided.

in the control room to monitor the operational status of the EDG.

EDG Power (kW) output indication is a type A variable because EDG kW indication provides the control room operator EDG load management capabilities. EDG load management enables the operator to base manual actions i of load start and stop for event mitigation.

1 i

l 1.

l_ (continued) l Crystal River Unit 3 B 3.3-138B Amendment No.

i

FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 ATTACIIMENT C l

LICENSE AMENDMENT REQUEST #246 l REVISION 0 1

l Proposed ITS and ITS Bases Change Pages - Revision Bars i

i l . _. .- - .

g i*r ,

PAM Instrumentation 3.3.17 Table 3.3.17-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITIONS REFERENCED FROM FUNCTION REQUIRED CHANNELS REQUIRED ACTION D.1

1. Wide Range Neutron Flux 2 E
2. RCS Hot Leg Temperature 2 E
3. RCS Pressure (Wide Range) 2 E
4. Reactor Coolant Inventory 2 F
5. Borated Water Storage Tank Level 2 E
6. High Pressure Injection Flow 2 per injection line E
7. Containment Sump Water Level (Flood Level) 2 E

' 8. Containment Pressure (Expected Post-Accident 2 E Range)

9. Containment Pressure (Wide Range)- 2 E
10. Containment Isolation Valve Position 2 per penetration (a)(b) E
11. Containment Area Radiation (High Range) 2 F
12. Containment Hydrogen Concentration 2 E i
13. Pressurizer Level 2 E j
14. .Cteam Generator Water Level (Start-up Range) 2 per OTSG E
15. Steam Generator Water Level (Operating Range) 2 per OTSG E
16. Steam Generator Pressure 2 per OTSG E
17. Emergency Feedwater Tank Level 2 E 18a, Core Exit Temperature (Thermocouple) 2 thermocouples per core E l quadrant i 18b. Core Exit Temperature (Recorder) 2 E
19. Emergency Feedwater Flow 2 per OTSG E
20. Low Pressure Injection Flow 2 E
21. Degrees of Subcooling 2 E
22. Emergency Diesel Generator kW Indication 2(c) E j

(a) Only one position indication is required for penetrations with one Control Room indicator.

(b) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured. l (c) One indicator per EDC. j I

I l

Crystal River Unit 3 3.3-41 Amendment No.

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4

.j s , .,

PAM Instrum:ntation B 3.3.17 BASES-4 FUNCTION CHANNEL A CHANNEL B

15. Steam Generator Water Level. OTSG A: SP-17-LII or OTSG A: SP-18-LIl (Operating Range) SP-17 LIR OTSG B: SP-22-LIl OTSG B: SP-21-LIl or SP-21 LIR 4
16. Steam Generator OTSG A: MS-106-PIl or OTSG A: MS-107-PIl or Pressure MS-106-PIR MS-107-PIR OTSG 8: MS-110-PIl or OTSG B: MS-111-PIl or MS-110-PIR MS-111-PIR
17. Emergency Feedwater EF-98-LIl EF-99-LIl Tank Level 3 _

4 18a. Core Exit Quadrant

' Temperature WX IM-5G-TE/IM-6C-TE IM-7F-TE/IM-2G-TE (Thermocouple) XY IM-9E-TE/IM-13G-TE IM-10C-TE/IM-11G-TE YZ IM-9H-TE/IM-100-TE IM-10M-TE/IM-13L-TE ZW IM-3L-TE/IM-60-TE IM-4N--TE/IM-6L-TE 18b. Core Exit Temperature RC-171-TR RC-172-TR (Recorder)

19. Emergency Feedwater OTSG A: EF-26-FIl OTSG A: EF-26-FIl.

Flow OTSG 8: EF-24-FIl OTSG 8: EF-24-FIl 20, Low Pressure Injection Flow DHV-110 Hand / Auto station flow DHV-111 Hand / Auto station flow i indication (DH-1-FK3-1) indication (DH-1-FK4-1) j

21. Dearees of Subcoolina EMCO-38 EMCO-39
22. Emergency Diesel Generator ECDG-1A Wattmeter SSF-AH Main EGDG-1B Wattmeter SSF-AX Main kW Indication control board indicator control board indicator NOTES: For Function 18a, each quadrant requires at least 2 OPERA 8LE detectors, one from each channel.

OPERASILITY of only one detector for any quadrant constitutes entry into Condition A of LCO 3.3.17. i Any quadrant with no OPERABLE detector constitutes entry into Condition C of LCO 3.3.17. Separate Condition entry is allowed for each quadrant.

l l

I (continued)

Crystal River Unit 3 B 3.3-125B Amendment No.

i

< ** i PAM Instrum2ntation B 3.3.17 BASES LCO 17. Emeraency Feedwater Tank Level I (continued) l The dedicated emergency feedwater (EFW) tank provides j the assured, safety grade water supply for the i Emergency Feedwater System. The EFW tank inventory is i monitored and displayed by 0 to 38 feet control room level indications. The control room indicators and alarms are considered the primary indication used by I the operator. Therefore, the LCO deals specifically  :

with this portion of the instrument string. l l

The design basis accidents which require emergency  !

feedwater are those in which the main feedwater supply and/or the electrical supply to the vital feedwater auxiliaries has been lost, e.g. , a feedwater line break or a loss of offsite power. In the event of .

such a loss of feedwater, the EFW tank is the initial  !

source of water for the EFW System. As the EFW tank I is depleted, manual operator action is necessary to i l

replenish the EFW tank or to realign the suction to the EFW pumps. Since tank level is required by the operator for manual actions following an event, it has been included in this LCO.

18a. Core Exit Temperature (Thermocouple) l The core exit thermocouples (CETs) provide an I indication of the reactor coolant temperature as it l exits the active region of the core. The CETs provide  !

input to accident monitoring instrumentation over a '

range of 0 to 2500 F, and include 16 separate temperature measurements from 16 CETs, four from each quadrant. These 16 core exit temperature measurements are continuously recorded in the control room on two separate recorders as described in Function 18b, and I provide input to the Safety Parameter Display System '

(SPDS) for determining subcooling margin as described in Function 21. Since the distribution of OPERABLE CETs is important for assuring a representative i indication of temperatures across the core, this LCO l deals specifically with this portion of the instrument string.

I The CETs are considered the primary indication of the reactor coolant temperature. The CETs are included in I this LCO because the operator uses the indication from the CETs to monitor the cooldown of the RCS following a steam generator tube rupture or small break LOCA.

Operator actions to maintain a controlled cooldown, such as adjusting OTSG level or pressure, would be prompted by this indication. 1

)

(continued)

Crystal River Unit 3 B 3.3-137 Amendment No. l l

, " *~

PAM Instrumantation B 3.3.17 BASES LCO 18b. Core Exit Temoerature (Recorder)

(continued)

The core exit temperature recorders provide an indication of the reactor coolant temperature as it exits the active region of the core over a range of 0 to 2500*F. Input to each recorder is from eight CETs, two from each core quadrant, to provide a representative distribution of temperatures across the core. Since the control room display is the primary indication used by the operator, this LCO deals specifically with this portion of the instrument string.

Core exit temperature is considered the primary indication of the reactor coolant temperature, and is l included in this LCO because the operator uses this I indication to monitor the cooldown of the RCS I following a steam generator tube rupture or small j break LOCA. Operator actions to maintain a controlled '

cooldown, such as adjusting OTSG level or pressure, would be prompted by this indication.

19. Emeraency Feedwater Flow EFW Flow instrumentation is provided to monitor operation of decay heat removal via the OTSGs. The EFW injection flow to each OTSG (2 channels per OTSG, one associated with each EFW injection line) is determined from a differential pressure measurement calibrated to a span of 0 gpm to 1000 gpm. Each differential pressure transmitter provides an input to a control room indicator and the plant computer.

EFW Flow is used by the operator to determine the need to throttle flow during accident or transient conditions to prevent excessive RCS cooldown rates when low decay heat levels are present. EFW Flow is also used by the operator to verify that the EFW System is delivering the correct flow to each OTSG.

However, the primary indication of this function is provided by OTSG level.

These instruments are not assumed to provide information required by the operator to take a mitigation action specified in the safety analysis.

As such, they are not Type A variables. However, the monitors are deemed risk significant (Category 1) and

. are included within the LCO based upon this consideration.

(continued)

Crystal River Unit 3 B 3.3-138 Amendment No.

PAM Instrumsntation B 3.3.17 BASES LCO 20. Low Pressure Iniection Flow (continued)

Low pressure injection flow instrumentation is provided to monitor flow to the RCS following a large break LOCA. It is also used to monitor LPI flow during piggy back operation following a small break LOCA. The low pressure injection flow to the rector (2 channels, one associated with each LPI injection line) is determined from a differential pressure measurement calibrated to a span of 0 gpm to 5000 gpm.

The LPI flow indication is used by the operator to throttle the flow to < 2000 gpm prior to switching the pump suction from the BWST to the RB sump. This assures adequate net positive suction head (NPSH) is maintained to the pump. .The indication is also used to verify LPI flow to the reactor as a prerequisite to termination of HPI flow.

Since low pressure injection flow is a Type A variable on which the operator bases manual actions required for event mitigation for which no automatic controls are provided, it has been included in this LCO.

21. Dearees of Subcoolina Two channels of subcooling margin with inputs from RCS

), core exit temperature, and hot RCSleg temperature pressure (T"ded by the Safety Parameter are provi Display System (SPDS). Multiple core exit temperatures are auctioneered with only the highest temperature being input to the monitor. The T, inputs to the SPDS subcooling margin monitors operate over a range of 120 to 920 F. The core exit temperature inputs operate over a range of 0 to 2500 F. RCS pressure inputs operate over a wide range of 200 to 2500 psig and low range of 0 to 600 psig.

(continued)

Crystal River Unit 3 B 3.3-138A Amendment No.

, <* . o

  • PAM Instrum:ntation B 3.3.17 BASES LCO 21. Q.earees of Subcoolina (continued)

The subcooling margin monitors are used to verify the existence of, or to take actions to ensure the restoration of subcooling margin. Specifically, a loss of adequate subcooling margin during a LOCA requires the operator to trip the reactor coolant pumps (RCP's), to ensure high or low pressure injection, and raise the steam generator levels to the inadequate subcooling margin level. Since degrees of subcooling is a Type A variable on which the operator bases manual actions required for event mitigation for which no automatic control are provided, it has been included in this LCO.

22. Emeraency Diesel Generator. kW Indication The Emergency Diesel Generator (EDG) provides standby (emergency) electrical power in the case of Loss of Offsite Power (LOOP). EDG kW indication is provided in the control room to monitor the operational status of the EDG.

EDG Power (kW) output indication is a type A variable because EDG kW indication provides the control room operator EDG load management capabilities. EDG load ,

management enables the operator to base manual actions '

of load start and stop for event mitigation.

1 l

I (continued) 1 I

Crystal River Unit 3 B 3.3-138B Amendment No.

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