ML21307A207

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2 to Updated Safety Analysis Report, Revision 13 Technical Specifications Bases TS Bases
ML21307A207
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 10/28/2021
From:
Energy Harbor Nuclear Corp
To:
Office of Nuclear Reactor Regulation
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ML21307A174 List:
References
L-21-018
Download: ML21307A207 (66)


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Technical Specification Bases Revision 13 List of Changed Pages Page 1 of 1

Page Revision Page Revision Number Number Number Number

TOC iii 13 B 3.6-31 13 B 2.0-1 13 B 3.6-88 13 B 2.0-2 13 B 3.6-144 13 B 2.0-3 13 B 3.8-36 13 B 3.0-2 13 B 3.8-37 13 B 3.0-3 13 B 3.8-40 13 B 3.2-6 13 B 3.8-49 13 B 3.2-7 13 B 3.8-50 13 B 3.2-7a 13 B 3.8-52 13 B 3.3-17 13 B 3.8-52a 13 B 3.3-18 13 B 3.8-54 13 B 3.3-30 13 B 3.8-55 13 B 3.3-31 13 B 3.8-56 13 B 3.3-48 13 B 3.8-57 13 B 3.3-49 13 B 3.8-58 13 B 3.3-71 13 B 3.8-59 13 B 3.3-72 13 B 3.8-62 13 B 3.3-76 13 B 3.8-62a 13 B 3.3-123a 13 B 3.8-63 13 B 3.3-123b 13 B 3.8-64 13 B 3.3-123c 13 B 3.8-65 13 B 3.3-123d 13 B 3.8-66 13 B 3.3-123e 13 B 3.8-67 13 B 3.3-123f 13 B 3.8-68 13 B 3.3-214 13 B 3.8-69 13 B 3.3-215 13 B 3.8-70 13 B 3.3-216 13 B 3.8-70a 13 B 3.3-218 13 B 3.8-74 13 B 3.5-15 13 B 3.8-78 13 B 3.5-16 13 B 3.8-80 13 B 3.5-20 13 B 3.8-84 13 B 3.5-20a 13 B 3.5-20b 13 B 3.5-20c 13 TSB Table of Contents (continued)

B 3.7 PLANT SYSTEMS B 3.7.1 Emergency Service Water (ESW) System - Divisions 1 and 2... B 3.7-1 B 3.7.2 Emergency Service Water (ESW) System - Division 3 B 3.7-7 B 3.7.3 Control Room Emergency Recirculation (CRER) System B 3.7-10 B 3.7.4 Control Room Heating, Ventilation, and Air Conditioning (HVAC)

System... B 3.7-17 B 3.7.5 Main Condenser Offgas..... B 3.7-22 B 3.7.6 Main Turbine Bypass System... B 3.7-25 B 3.7.7 Fuel Pool Water Level.... B 3.7-29 B 3.7.8 Deleted B 3.7.9 Deleted B 3.7.10 Emergency Closed Cooling Water (ECCW) System..... B 3.7-41

B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.1 AC Sources - Operating B 3.8-1 B 3.8.2 AC Sources - Shutdown B 3.8-34 B 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air.. B 3.8-41 B 3.8.4 DC Sources - Operating B 3.8-51 B 3.8.5 DC Sources - Shutdown... B 3.8-60 B 3.8.6 Battery Parameters. B 3.8-64 B 3.8.7 Distribution Systems - Operating. B 3.8-71 B 3.8.8 Distribution Systems - Shutdown. B 3.8-81

B 3.9 REFUELING OPERATIONS B 3.9.1 Refueling Equipment Inte rlocks.... B 3.9-1 B 3.9.2 Refuel Position One-Rod-Out Interlock... B 3.9-5 B 3.9.3 Control Rod Position... B 3.9-9 B 3.9.4 Control Rod Position Indication. B 3.9-12 B 3.9.5 Control Rod OPERABILITY - Refueling.. B 3.9-16 B 3.9.6 Reactor Pressure Vessel (RPV) Water Level - Irradiated Fuel... B 3.9-19 B 3.9.7 Reactor Pressure Vessel (RPV) Water Level - New Fuel or Control Rods........ B 3.9-22 B 3.9.8 Residual Heat Removal (RHR) - High Water Level.. B 3.9-25 B 3.9.9 Residual Heat Removal (RHR) - Low Water Level...... B 3.9-30

B 3.10 SPECIAL OPERATIONS B 3.10.1 Inservice Leak and Hydrostati c Testing Operation B 3.10-1 B 3.10.2 Reactor Mode Switch Interlock Testing... B 3.10-6 B 3.10.3 Single Control Rod Withdrawal - Hot Shutdown B 3.10-11 B 3.10.4 Single Control Rod Withdrawal - Cold Shutdown.. B 3.10-16 B 3.10.5 Single Control Rod Drive (CRD) Removal - Refueling. B 3.10-21 B 3.10.6 Multiple control Rod Withdrawal - Refueling.. B 3.10-26 B 3.10.7 Control Rod Testing - Operating.. B 3.10-29 B 3.10.8 SHUTDOWN MARGIN (SDM) Test - Refueling B 3.10-33 B 3.10.9 Suppression Pool Makeup - MODE 3 Upper Containment Pool Drain-Down B 3.10-39

PERRY - UNIT 1 Revision 13 Page iii Reactor Core SLs B 2.1.1

B 2.0 SAFETY LIMITS (SLs)

B 2.1.1 Reactor Core SLs

BASES

BACKGROUND GDC (Ref. 1) requires, and SLs ensure, that specified acceptable fuel design limits are not exceeded during steady state operation, normal operational transients, and anticipated operational occurrences (AOOs).

The fuel cladding integrity SL is set such that no significant fuel damage is calculated to occur if the limit is not violated. Because fuel damage is not directly observable, a stepback approach is used to establish an SL, such that the MCPR is not less than the limit specified in Specification 2.1.1.2. MCPR greater than the specified limit represents a conservative margin relative to the conditions required to maintain fuel cladding integrity.

The fuel cladding is one of the physical barriers that separate the radioactive materials from the environs. The integrity of this cladding barrier is related to its relative freedom from perforations or cracking.

Although some corrosion or use related cracking may occur during the life of the cladding, fission product migration from this source is incrementally cumulative and continuously measureable. Fuel cladding perforations, however, can result from thermal stresses, which occur from reactor operation significantly above design conditions.

While fission product migration from cladding perforation is just as measurable as that from use related cracking, the thermally caused cladding perforations signal a threshold beyond which still greater thermal stresses may cause gross, rather than incremental, cladding deterioration. Therefore, the fuel cladding SL is defined with a margin to the conditions that would produce onset of transition boiling (i.e., MCPR = 1.00). These conditions represent a significant departure from the condition intended by design for planned operation. This is accomplished by having a Safety Limit Minimum Critical Power Ratio (SLMCPR) design basis, referred to as SLMCPR 95/95, which corresponds to a 95% probability at a 95% confidence level (the 95/95 MCPR criterion) that transition boiling will not occur.

(continued)

PERRY - UNIT 1 B 2.0-1 Revision No. 13 Reactor Core SLs B 2.1.1

BASES

BACKGROUND Operation above the boundary of the nucleate boiling regime could result (continued) in excessive cladding temperature because of the onset of transition boiling and the resultant sharp reduction in heat transfer coefficient.

Inside the steam film, high cladding temperatures are reached, and a cladding water (zirconium water) reaction may take place. This chemical reaction results in oxidation of the fuel cladding to a structurally weaker form. This weaker form may lose its integrity, resulting in an uncontrolled release of activity to the reactor coolant.

APPLICABLE The fuel cladding must not sustain damage as a result of normal SAFETY operation and AOOs. The Tech Spec SL is set generically on a fuel ANALYSES product MCPR correlation basis as the MCPR which corresponds to a 95% probability at a 95% confidence level that transition boiling will not occur, referred to as SLMCPR 95/95.

The Reactor Protection System setpoints (LCO 3.3.1.1, Reactor Protection System (RPS) Instrumentation), in combination with other LCOs, are designed to prevent any anticipated combination of transient conditions for Reactor Coolant System water level, pressure, and THERMAL POWER level that would result in reaching the MCPR SL.

2.1.1.1 Fuel Cladding Integrity

GE critical power correlations are applicable for all critical power calculations at pressures 686 psig and core flows 10% of rated flow.

For operation at low pressures or low flows, another basis is used, as follows:

Since the pressure drop in the bypass region is essentially all elevation head, the core pressure drop at low power and flows will always be > 4.5 psi. Analyses (Ref. 2) show that with a bundle flow of 28 x 10 3 lb/hr, bundle pressure drop is nearly independent of bundle power and has a value of 3.5 psi. Thus, the bundle flow with a 4.5 psi driving head will be > 28 x 103 lb/hr. Full scale ATLAS test data taken at pressures from 14.7 psia to 800 psia

(continued)

PERRY - UNIT 1 B 2.0-2 Revision No. 13 Reactor Core SLs B 2.1.1

BASES

APPLICABLE 2.1.1.1 Fuel Cladding Integrity (continued)

SAFETY ANALYSES indicate that the fuel assembly critical power at this flow is approximately 3.35 Mwt. With the design peaking factors, this corresponds to a THERMAL POWER > 47.6% RTP. Thus, a THERMAL POWER limit of 23.8% RTP for reactor pressure

< 686 psig is conservative.

2.1.1.2 MCPR

The fuel cladding integrity SL is set such that no significant fuel damage is calculated to occur if the limit is not violated. Since the parameters that result in fuel damage are not directly observable during reactor operation, the thermal and hydraulic conditions that result in the onset of transition boiling have been used to mark the beginning of the region in which fuel damage could occur. Although it is recognized that the onset of transition boiling would not result in damage to BWR fuel rods, the critical power at which boiling transition is calculated to occur has been adopted as a convenient limit. The Technical Specification SL value is dependent on the fuel product line and the corresponding MCPR correlation, which is cycle independent. The value is based on the Critical Power Ratio (CPR) data statistics and a 95% probability with 95% confidence that rods are not susceptible to boiling transition, referred to as MCPR 95/95.

The SL is based on GNF2 fuel. For cores with a single fuel product line, the SLMCPR95/95 is the MCPR95/95 for the fuel type. For cores loaded with a mix of applicable fuel types, the SLMCPR 95/95 is based on the largest (i.e., most limiting) of the MCPR values for the fuel product lines that are fresh or once-burnt at the start of the cycle.

(continued)

PERRY - UNIT 1 B 2.0-3 Revision No. 13 LCO Applicability B 3.0

BASES

LCO 3.0.2 remedial measures that permit continued operation of the unit that is (continued) not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Condition no longer exists. The individual LCOs ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.11, RCS Pressure and Temperature (P/T) Limits.

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4). Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable and the ACTIONS Condition(s) are entered.

(continued)

PERRY - UNIT 1 B 3.0-2 Revision No. 13 LCO Applicability B 3.0

BASES (continued)

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a. An associated Required Action and Completion Time is not met and no other Condition applies; or
b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. Planned entry into LCO 3.0.3 should be avoided. If it is not practicable to avoid planned entry into LCO 3.0.3, plant risk should be assessed and managed in accordance with 10 CFR 50.65(a)(4), and the planned entry into LCO 3.0.3 should have less effect on plant safety than other practicable alternatives.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to enter lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

(continued)

PERRY - UNIT 1 B 3.0-3 Revision No. 13 MCPR B 3.2.2

B 3.2 POWER DISTRIBUTION LIMITS

B 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR)

BASES

BACKGROUND MCPR is a ratio of the fuel assembly power that would result in the onset of boiling transition to the actual fuel assembly power. The operating limit MCPR is established to ensure that no fuel damage results during anticipated operational occurrences (AOOs), and that 99.9% of the fuel rods avoid boiling transition if the limit is not violated. Although fuel damage does not necessarily occur if a fuel rod actually experiences boiling transition (Ref. 1), the critical power at which boiling transition is calculated to occur has been adopted as a fuel design criterion.

The onset of transition boiling is a phenomenon that is readily detected during the testing of various fuel bundle designs. Based on these experimental data, correlations have been developed to predict critical bundle power (i.e., the bundle power level at the onset of transition boiling) for a given set of plant parameters (e.g., reactor vessel pressure, flow, and subcooling). Because plant operating conditions and bundle power levels are monitored and determined relatively easily, monitoring the MCPR is a convenient way of ensuring that fuel failures due to inadequate cooling do not occur.

APPLICABLE The analytical methods and assumptions used in evaluating the AOOs to SAFETY establish the operating limit MCPR are presented in the USAR, Chapters ANALYSES 4, 6, and 15, and References 2, 3, 4, 5, and 6. To ensure that the MCPR Safety Limit (SL) is not exceeded during any transient event that occurs with moderate frequency, limiting transients have been analyzed to determine the largest reduction in critical power ratio (CPR). The types of transients evaluated are loss of flow, increase in pressure and power, positive reactivity insertion, and coolant temperature decrease. The limiting transient yields the largest change in CPR ( CPR). When the largest CPR is combined with the SLMCPR 99.9%, the required operating limit MCPR is obtained. MCPR 99.9% is determined to ensure more than 99.9% of the fuel rods in the core are not susceptible to boiling transition using a statistical model that combines all the uncertainties in operating parameters and the procedures used to calculate critical power. The probability of the occurrence of boiling transition is determined using the approved General Electric Critical Power correlations. Details of the MCPR99.9% calculation are given in Reference 2. Reference 2 also includes a tabulation of the uncertainties and the nominal values of the parameters used in the MCPR 99.9% statistical analysis.

(continued)

PERRY - UNIT 1 B 3.2-6 Revision No. 13 MCPR B 3.2.2

BASES

APPLICABLE The MCPR operating limits are derived from the MCPR 99.9% value and the SAFETY transient analysis, and are dependent on the operating core flow and ANALYSES power state (MCPRf and MCPRp, respectively) to ensure adherence to (continued) fuel design limits during the worst transient that occurs with moderate frequency (Refs. 4, 5, and 6).

Flow dependent MCPR limits (MCPR f) are determined by steady state thermal hydraulic methods using the three dimensional BWR simulator code (Ref. 7). MCPRf curves are provided based on the maximum credible flow runout transient for Loop Manual and Non Loop Manual operation. The result of a single failure or single operator error during Loop Manual operation is the runout of only one loop because both recirculation loops are under independent control. Non Loop Manual operational modes allow simultaneous runout of both loops because a single controller regulates core flow.

Power dependent MCPR limits (MCPRp) are determined by approved transient analysis models (Ref. 8). Due to the sensitivity of the transient response to initial core flow levels at power levels below those at which the turbine stop valve closure and turbine control valve fast closure scram trips are bypassed, high and low flow MCPR p operating limits are provided for operating between 23.8% RTP and the previously mentioned bypass power level.

Pressure Regulator Out of Service (PROOS) option is an analysis using the Pressure Regulator Downscale Failure (PRDF) at off-rated conditions.

At full power, the PRDF is bounded by other pressurization transients.

However, as the reactor power at the beginning of the transient decreases, the impact of the PRDF to MCPR increases.

During a PRDF transient, the pressure regulator closes the turbine control valves. This increases pressure, which increases power in the reactor.

When the reactor is at full power, the pressure and power increases quickly, causing a SCRAM. As the reactor power is decreased, the power is further from the SCRAM setpoint so it takes more time to SCRAM. This longer time to SCRAM increases the amount of specific heat in the fuel and impacts the CPR. There is a range of initial reactor power where the CPR is no longer bounded by the normal MCPR p limits.

(continued)

PERRY - UNIT 1 B 3.2-7 Revision No. 13 MCPR B 3.2.2

BASES

APPLICABLE There are two independent channels in the pressure regulating system SAFETY and the PRDF transient is not applicable when both channels are ANALYSES operable.

(continued)

The COLR identifies the range of the modified MCPR limits and the new limits. These limits may be incorporated by either a revision to the monitoring system or appropriate administrative limits.

The MCPR satisfies Criterion 2 of the NRC Final Policy Statement on Technical Specification Improvements (58 FR 39132).

LCO The MCPR operating limits s pecified in the COLR (MCPR99.9% values, MCPRf values, and MCPRp values) are the result of the Design Basis Accident (DBA) and transient analysis. The MCPR operating limits are determined by the larger of the MCPR f and MCPRp limits, which are based on the MCPR99.9% limit specified in the COLR.

APPLICABILITY The MCPR operating limits are primarily derived from transient analyses that are assumed to occur at high power levels. Below 23.8% RTP, the reactor is operating at a slow recirculation pump speed and the moderator void ratio is small. Surveillance of thermal limits below 23.8% RTP is unnecessary due to the large inherent margin that ensures that the MCPR95/95 is not exceeded even if a limiting transient occurs.

(continued)

PERRY - UNIT 1 B 3.2-7a Revision No. 13 RPS Instrumentation B 3.3.1.1

BASES

APPLICABLE 9. Turbine Stop Valve Closure (continued)

SAFETY ANALYSES, LCO, Turbine Stop Valve Closure signals are initiated by limit switches at each and APPLICABILITY stop valve. Two independent limit switches are associated with each stop valve. One of the two limit switches provides input to RPS trip system A; the other, to RPS trip system B. Thus, each RPS trip system receives an input from four Turbine Stop Valve Closure channels, each consisting of one limit switch. The logic for the Turbine Stop Valve Closure Function is such that three or more TSVs must be closed to produce a scram.

The Turbine Stop Valve Closure Allowable Value is selected to be high enough to detect imminent TSV closure thereby reducing the severity of the subsequent pressure transient.

Eight channels of Turbine Stop Valve Closure, with four channels in each trip system, are required to be OPERABLE to ensure that no single instrument failure will preclude a scram from this Function if any three TSVs should close.

This Function is required, consistent with analysis assumptions, whenever THERMAL POWER is 38% RTP. This Function is not required when THERMAL POWER is < 38% RTP since the Reactor Vessel Steam Dome Pressure-High and the Average Power Range Monitor Fixed Neutron Flux-High Functions are adequate to maintain the necessary safety margins. Enabling of this Function is normally accomplished automatically by pressure transmitters sensing turbine first stage pressure; therefore, opening of the turbine bypass valves may affect this Function. The setpoint is feedwater temperature dependent as a result of the subcooling changes that affect the turbine first stage pressure/reactor power relationship.

(continued)

PERRY - UNIT 1 B 3.3-17 Revision No. 13 RPS Instrumentation B 3.3.1.1

BASES

APPLICABLE 10. Turbine Control Valve Fast Closure, Trip Oil Pressure-Low SAFETY ANALYSES, LCO, Fast closure of the TCVs results in the loss of a heat sink that produces and APPLICABILITY reactor pressure, neutron flux, and heat flux transients that must be (continued) limited. Therefore, a reactor scram is initiated on TCV fast closure in anticipation of the transients that would result from the closure of these valves. The Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Function is the primary scram signal for the generator load rejection event analyzed in Reference 4. For this event, the reactor scram reduces the amount of energy required to be absorbed and, along with the actions of the EOC-RPT System, ensures that the MCPR SL is not exceeded.

Turbine Control Valve Fast Closure, Trip Oil Pressure-Low signals are initiated by the EHC fluid pressure at each control valve. There is one pressure switch associated with each control valve, the signal from each transmitter being assigned to a separate RPS logic channel. This Function must be enabled at THERMAL POWER 38% RTP. This is normally accomplished automatically by pressure switches sensing turbine first stage pressure; opening of the turbine bypass valves may affect this Function.

The Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Allowable Value is selected high enough to detect imminent TCV fast closure.

Four channels of the Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Function, with two channels in each trip system arranged in a one-out-of-two logic, are required to be OPERABLE to ensure that no single instrument failure will preclude a scram from this Function on a valid signal. This Function is required, consistent with the analysis assumptions, whenever THERMAL POWER is 38% RTP. This Function is not required when THERMAL POWER is 38% RTP since the Reactor Vessel Steam Dome Pressure-High and the Average Power Range Monitor Fixed Neutron Flux-High Functions are adequate to maintain the necessary safety margins.

(continued)

PERRY - UNIT 1 B 3.3-18 Revision No. 13 RPS Instrumentation B 3.3.1.1

BASES

SURVEILLANCE SR 3.3.1.1.14 REQUIREMENTS (continued) The Average Power Range Monitor Flow Biased Simulated Thermal Power-High Function uses an electronic filter circuit to generate a signal proportional to the core THERMAL POWER from the APRM neutron flux signal. This filter circuit is representative of the fuel heat transfer dynamics that produce the relationship between the neutron flux and the core THERMAL POWER. The filter time constant is specified in the COLR and must be verified to ensure that the channel is accurately reflecting the desired parameter.

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

SR 3.3.1.1.15

The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic upon the receipt of either actual or simulated automatic trip signals. The functional testing of control rods, in LCO 3.1.3, Control Rod OPERABILITY, and SDV vent and drain valves, in LCO 3.1.8, Scram Discharge Volume (SDV) Vent and Drain Valves, overlaps this Surveillance to provide complete testing of the assumed safety function.

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

SR 3.3.1.1.16

This SR ensures that scrams initiated from the Turbine Stop Valve Closure and Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Functions will not be inadvertently bypassed when THERMAL POWER is 38% RTP. This involves calibration of the bypass channels. Adequate margins for the instrument setpoint methodology are incorporated into the actual setpoint. Because main turbine bypass flow can affect this setpoint nonconservatively (THERMAL POWER is derived from turbine first stage pressure), the main turbine bypass valves must remain closed during the calibration at THERMAL POWER 38% RTP to ensure that the calibration remains valid.

(continued)

PERRY - UNIT 1 B 3.3-30 Revision No. 13 RPS Instrumentation B 3.3.1.1

BASES

SURVEILLANCE SR 3.3.1.1.16 (continued)

REQUIREMENTS If any bypass channel setpoint is nonconservative (i.e., the Functions are bypassed at 38% RTP, either due to open main turbine bypass valve(s) or other reasons), then the affected Turbine Stop Valve Closure and Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Functions are considered inoperable. Alternatively, the bypass channel can be placed in the conservative condition (nonbypass). If placed in the nonbypass condition (Turbine Stop Valve-Closure and Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Functions are enabled), this SR is met and the channel is considered OPERABLE.

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

SR 3.3.1.1.18

This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. The RPS RESPONSE TIME acceptance criteria are included in Reference 10.

As noted, neutron detectors are excluded from RPS RESPONSE TIME testing because the principles of detector operation virtually ensure an instantaneous response time. In addition, for Functions 3, 4 and 5, the associated sensors are not required to be response time tested. For these Functions, response time testing for the remaining channel components is required. This allowance is supported by Reference 11.

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

(continued)

PERRY - UNIT 1 B 3.3-31 Revision No. 13 Control Rod Block Instrumentation B 3.3.2.1

BASES

SURVEILLANCE SR 3.3.2.1.1, SR 3.3.2.1.2, SR 3.3.2.1.3, and SR 3.3.2.1.4 REQUIREMENTS (continued) The CHANNEL FUNCTIONAL TESTS for the RPC are performed by attempting to withdraw a control rod not in compliance with the prescribed sequence and verifying that a control rod block occurs. The CHANNEL FUNCTIONAL TESTS for the RWL are performed by selecting and attempting to move a restricted control rod in excess of the allowable distance. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. As noted, the SRs are not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after specified conditions are met (e.g., after any control rod is withdrawn in MODE 2).

This allows entry into the appropriate conditions needed to perform the required SRs (e.g., during a power reduction for SR 3.3.2.1.4.) The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.2.1.5

The LPSP is the point at which the RPCS makes the transition between the function of the RPC and the RWL. This transition point is automatically varied as a function of power. This power level is inferred from the first stage turbine pressure (one channel to each trip system).

These power setpoints must be verified periodically to be within the Allowable Values. If any LPSP is nonconservative, then the affected Functions are considered inoperable. Since this channel has both upper and lower required limits, it is not allowed to be placed in a condition to enable either the RPC or RWL Function. Main Turbine bypass steam flow can affect LPSP nonconservatively for the RWL; therefore, opening the turbine bypass valve may affect the Function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.2.1.6

This SR ensures the high power function of the RWL is not bypassed when power is above the HPSP. The power level is inferred from turbine first stage pressure signals. Periodic testing of the HPSP channels is required to verify the setpoint to be less than or equal to the limit.

Adequate margins in accordance with setpoint methodologies are included. If the HPSP is nonconservative, then the RWL is considered inoperable. Alternatively, the HPSP can be placed in the conservative condition (nonbypass). If

(continued)

PERRY - UNIT 1 B 3.3-48 Revision No. 13 Control Rod Block Instrumentation B 3.3.2.1

BASES

SURVEILLANCE SR 3.3.2.1.6 (continued)

REQUIREMENTS placed in the nonbypassed condition, the SR is met and the RWL would not be considered inoperable. Main Turbine bypass steam flow can affect LPSP nonconservatively for the RWL; therefore, opening the turbine bypass valve may affect the Function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.2.1.7

A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

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

SR 3.3.2.1.8

The CHANNEL FUNCTIONAL TEST for the Reactor Mode Switch-Shutdown Position Function is performed by attempting to withdraw any control rod with the reactor mode switch in the shutdown position and verifying a control rod block occurs.

As noted in the SR, the Surveillance is not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the reactor mode switch is in the shutdown position, since testing of this interlock with the reactor mode switch in any other position cannot be performed without using jumpers, lifted leads, or movable links.

This allows entry into MODES 3 and 4 if the Frequency is not met per SR 3.0.2.

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

(continued)

PERRY - UNIT 1 B 3.3-49 Revision No. 13 EOC-RPT Instrumentation B 3.3.4.1

BASES

APPLICABLE Turbine Stop Valve Closure (continued)

SAFETY ANALYSES, LCO, Closure of the TSVs is determined by a limit switch on each stop valve.

and APPLICABILITY There is one limit switch associated with each stop valve, and the signal from each limit switch is assigned to a separate trip channel. The logic for the TSV Closure is such that two or more TSVs must be closed to produce an EOC-RPT. This Function must be enabled at THERMAL POWER 38% RTP. This is normally accomplished automatically by pressure transmitters sensing turbine first stage pressure; therefore, opening the turbine bypass valve may affect the Function. Four channels of TSV Closure, with two channels in each trip system, are required to be OPERABLE to ensure that no single instrument failure will preclude an EOC-RPT from this Function on a valid signal. The TSV Closure Allowable Value is selected high enough to detect imminent TSV closure.

This protection is required, consistent with the safety analysis assumptions, whenever THERMAL POWER is 38% RTP with any recirculation pump in fast speed. Below 38% RTP or with the recirculation pump in slow speed, the Reactor Vessel Steam Dome Pressure-High and the Average Power Range Monitor (APRM) Fixed Neutron Flux-High Functions of the R eactor Protection System (RPS) are adequate to maintain the necessary safety margins.

(continued)

PERRY - UNIT 1 B 3.3-71 Revision No. 13 EOC-RPT Instrumentation B 3.3.4.1

BASES

APPLICABLE TCV Fast Closure, Trip Oil Pressure-Low SAFETY ANALYSES, LCO, Fast closure of the TCVs during a generator load rejection results in the and APPLICABILITY loss of a heat sink that pr oduces reactor pressure, neutron flux, and heat (continued) flux transients that must be limited. Therefore, an EOC-RPT is initiated on TCV Fast Closure, Trip Oil Pressure-Low in anticipation of the transients that would result from the closure of these valves. The EOC-RPT decreases reactor power and aids the reactor scram in ensuring that the MCPR SL is not exceeded during the worst case transient.

Fast closure of the TCVs is determined by measuring the EHC fluid pressure at each control valve. There is one pressure switch associated with each control valve, and the signal from each switch is assigned to a separate trip channel. The logic for the TCV Fast Closure, Trip Oil Pressure-Low Function is such that two or more TCVs must be closed (pressure switch trips) to produce an EOC-RPT. This Function must be enabled at THERMAL POWER 38% RTP. This is normally accomplished automatically by pressure transmitters sensing turbine first stage pressure; therefore, opening the turbine bypass valve may affect the Function. Four channels of TCV Fast Closure, Trip Oil Pressure-Low, with two channels in each trip system, are required to be OPERABLE to ensure that no single instrument failure will preclude an EOC-RPT from this Function on a valid signal. The TCV Fast Closure, Trip Oil Pressure-Low Allowable Value is selected high enough to detect imminent TCV fast closure.

This protection is required consistent with the analysis, whenever the THERMAL POWER is 38% RTP with any recirculating pump in fast speed. Below 38% RTP or with recirculation pumps in slow speed, the Reactor Vessel Steam Dome Pressure-High and the APRM Fixed Neutron Flux-High Functions of the RPS are adequate to maintain the necessary safety margins.

(continued)

PERRY - UNIT 1 B 3.3-72 Revision No. 13 EOC-RPT Instrumentation B 3.3.4.1

BASES

SURVEILLANCE SR 3.3.4.1.3 REQUIREMENTS (continued) The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the pump breakers is included as a part of this test, overlapping the LOGIC SYSTEM FUNCTIONAL TEST, to provide complete testing of the associated safety function. Therefore, if a breaker is incapable of operating, the associated instrument channel(s) would also be inoperable.

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

SR 3.3.4.1.4

This SR ensures that an EOC-RPT initiated from the TSV Closure and TCV Fast Closure, Trip Oil Pressure-Low Functions will not be inadvertently bypassed when THERMAL POWER is 38% RTP. This involves calibration of the bypass channels. Adequate margins for the instrument setpoint methodologies are incorporated into the actual setpoint. Because main turbine bypass flow can affect this setpoint nonconservatively (THERMAL POWER is derived from first stage pressure), the main turbine bypass valves must remain closed during in-service calibration at THERMAL POWER 38% RTP, to ensure that the calibration remains valid. If any bypass channels setpoint is nonconservative (i.e., the Functions are bypassed at 38% RTP either due to open main turbine bypass valves or other reasons), the affected TSV Closure and TCV Fast Closure, Trip Oil Pressure-Low Functions are considered inoperable. Alternatively, the bypass channel can be placed in the conservative condition (nonbypass). If placed in the nonbypass condition (Turbine Stop Valve-Closure and Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Functions are enabled), this SR is met with the channel considered OPERABLE.

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

(continued)

PERRY - UNIT 1 B 3.3-76 Revision No. 13 RPV Water Inventory Control Instrumentation B 3.3.5.2

B 3.3 INSTRUMENTATION

B 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation

BASES

BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF.

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

Technical Specifications are required by 10 CFR 50.36 to include limiting safety system settings (LSSS) for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a safety action is initiated to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur. The actual settings for the automatic isolation channels are the same as those established for the same functions in MODES 1, 2, and 3 in LCO 3.3.6.1, Primary Containment and Drywell Isolation Instrumentation.

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

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

(continued)

PERRY - UNIT 1 B 3.3-123a Revision No. 13 RPV Water Inventory Control Instrumentation B 3.3.5.2

BASES

BACKGROUND The purpose of the RPV Water Inventory Control Instrumentation is to (continued) support the requirements of LCO 3.5.2, Reactor Pressure Vessel (RPV)

Water Inventory Control, and the definition of DRAIN TIME. There are functions that support automatic isolation of Residual Heat Removal subsystem and Reactor Water Cleanup system penetration flow path(s) on low RPV water level.

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

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

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

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

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

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

(continued)

PERRY - UNIT 1 B 3.3-123b Revision No. 13 RPV Water Inventory Control Instrumentation B 3.3.5.2

BASES

APPLICABLE RHR System Isolation SAFETY ANALYSES, LCO, 1.a. Reactor Vessel Water Level - Low, Level 3 and APPLICABILITY (continued) The definition of DRAIN TIME allows crediting the closing of penetration flow paths that are capable of being automatically isolated by RPV water level isolation instrumentation prior to the RPV water level being equal to the TAF.

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

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

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

This Function isolates the Group 3 and 4 valves.

Reactor Water Cleanup (RWCU) System Isolation

2.a. Reactor Vessel Water Level - Low Low, Level 2

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

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

(continued)

PERRY - UNIT 1 B 3.3-123c Revision No. 13 RPV Water Inventory Control Instrumentation B 3.3.5.2

BASES

APPLICABLE 2.a. Reactor Vessel Water Level - Low Low, Level 2 (continued)

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

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

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

This Function isolates the Group 7 valves.

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

A.1, A.2.1, and A.2.2

RHR System Isolation, Reactor Vessel Water Level - Low Level 3, and Reactor Water Cleanup System, Reactor Vessel Water Level - Low Low, Level 2 functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME. If the instrumentation is inoperable, Required Action A.1 directs immediate action to place the channel in trip. With the inoperable channel in the

(continued)

PERRY - UNIT 1 B 3.3-123d Revision No. 13 RPV Water Inventory Control Instrumentation B 3.3.5.2

BASES

ACTIONS A.1, A.2.1, and A.2.2 (continued)

tripped condition, the remaining channel will isolate the penetration flow path on low water level. If both channels are inoperable and placed in trip, the penetration flow path will be isolated. Alternatively, Required Action A.2.1 requires that the associated penetration flow path(s) to be immediately declared incapable of automatic isolation. Required Action A.2.2 directs initiating action to calculate DRAIN TIME. The calculation cannot credit automatic isolation of the affected penetration flow paths.

SURVEILLANCE The following SRs apply to each RPV Water Inventory Control Instrument REQUIREMENTS Function in Table 3.3.5.2-1.

SR 3.3.5.2.1

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

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

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

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

SR 3.3.5.2.2

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

(continued)

PERRY - UNIT 1 B 3.3-123e Revision No. 13 RPV Water Inventory Control Instrumentation B 3.3.5.2

BASES

SURVEILLANCE SR 3.3.5.2.2 (continued)

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

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

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

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

2. Information Notice 86-74, Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves, August 1986.
3. Generic Letter 92-04, Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f), August 1992.
4. NRC Bulletin 93-03, Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs, May 1993.
5. Information Notice 94-52, Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1, July 1994.

PERRY - UNIT 1 B 3.3-123f Revision No. 13 LOP Instrumentation B 3.3.8.1

BASES

APPLICABLE The specific Applicable Safety Analyses, LCO, and Applicability SAFETY discussions are listed below on a Function by Function basis.

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

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

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

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

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

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

Operating" for Applicability Bases for the DGs.

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

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

(continued)

PERRY - UNIT 1 B 3.3-214 Revision No. 13 LOP Instrumentation B 3.3.8.1

BASES

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

SAFETY (continued)

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

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

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

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

A.1

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

If the inoperable

(continued)

PERRY - UNIT 1 B 3.3-215 Revision No. 13 LOP Instrumentation B 3.3.8.1

BASES

ACTIONS A.1 (continued)

channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action A.1. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue.

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

Condition B must be entered and its Required Action taken.

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

B.1

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

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

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

(continued)

PERRY - UNIT 1 B 3.3-216 Revision No. 13 LOP Instrumentation B 3.3.8.1

BASES

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

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

SR 3.3.8.1.4

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

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

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

2. USAR, Section 5.2.
3. USAR, Section 6.3.
4. USAR, Chapter 15.

PERRY - UNIT 1 B 3.3-218 Revision No. 13 RPV Water Inventory Control B 3.5.2

B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM

B 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control

BASES

BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF.

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

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

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

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

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

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

(continued)

PERRY - UNIT 1 B 3.5-15 Revision No. 13 RPV Water Inventory Control B 3.5.2

BASES

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

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

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

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

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

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

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

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

(continued)

PERRY - UNIT 1 B 3.5-16 Revision No. 13 RPV Water Inventory Control B 3.5.2

BASES

SURVEILLANCE SR 3.5.2.1 (continued)

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

The definition of DRAIN TIME excludes from the calculation those penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths. A blank flange or other bolted device must be connected with a sufficient number of bolts to prevent draining. Normal or expected leakage from closed systems or past isolation devices is permitted. Determination that a system is intact and closed or isolated must consider the status of branch lines.

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

The exclusion of a single penetration flow path, or multiple penetration flow paths susceptible to a common mode failure, from the determination of DRAIN TIME should consider the effects of temporary alterations in support of maintenance (rigging, scaffolding, temporary shielding, piping plugs, freeze seals, etc.). If reasonable controls are implemented to prevent such temporary alterations from causing a draining event from a closed system, or between the RPV and the isolation device, the effect of the temporary alterations on DRAIN TIME need not be considered.

Reasonable controls include, but are not limited to, controls consistent with the guidance in NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4,

(continued)

PERRY - UNIT 1 B 3.5-20 Revision No. 13 RPV Water Inventory Control B 3.5.2

BASES

SURVEILLANCE SR 3.5.2.1 (continued)

REQUIREMENTS NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, or commitments to NUREG-0612, Control of Heavy Loads at Nuclear Power Plants.

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

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

SR 3.5.2.2 and SR 3.5.2.3

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

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

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

SR 3.5.2.4

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

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

(continued)

PERRY - UNIT 1 B 3.5-20a Revision No. 13 RPV Water Inventory Control B 3.5.2

BASES

SURVEILLANCE SR 3.5.2.5 REQUIREMENTS (continued) Verifying that the required ECCS injection/spray subsystem can be manually aligned, and the pump started and operated for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. This SR is modified by two Notes. Note 1 states that testing the ECCS injection/spray subsystem may be done through the test return line to avoid overfilling the refueling cavity. Note 2 states that credit for meeting the SR may be taken for normal system operation that satisfies the SR, such as using the RHR mode of LPCI for 10 minutes.

The minimum operating time of 10 minutes was based on engineering judgement.

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

SR 3.5.2.6

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

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

(continued)

PERRY - UNIT 1 B 3.5-20b Revision No. 13 RPV Water Inventory Control B 3.5.2

BASES

SURVEILLANCE SR 3.5.2.7 REQUIREMENTS (continued) This Surveillance verifies that a required LPCI subsystem or LPCS System can be manually aligned and started from the control room, including any necessary valve alignment, instrumentation, or controls, to transfer water from the suppression pool or CST to the RPV.

The Surveillance is controlled under the Surveillance Frequency Control Program.

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

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

2. Information Notice 86-74, Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves, August 1986.
3. Generic Letter 92-04, Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f), August 1992.
4. NRC Bulletin 93-03, Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs, May 1993.
5. Information Notice 94-52, Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1, July 1994.
6. General Electric Service Information Letter No. 388, RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6, February 1983.

PERRY - UNIT 1 B 3.5-20c Revision No. 13 PCIVs B 3.6.1.3

BASES

SURVEILLANCE SR 3.6.1.3.9 (continued)

REQUIREMENTS device. If both isolation devices in the penetration are closed, the actual leakage rate is the lesser leakage rate of the two devices.

A Note is added to this SR which states that these valves are only required to meet this leakage rate limit in MODES 1, 2, and 3. In the other conditions, the Reactor Coolan t System is not pressurized and specific primary leakage rate limits are not required. The Frequency is required by the Primary Containment Leakage Rate Testing Program.

A second Note makes it clear that Main Steam Line leakage need not be added into the secondary containment bypass leakage total, since Main Steam Line leakage is addressed separately in the radiological dose calculations; is not assumed to be immediately released to the environment like bypass leakage is; and because it is separately measured in SR 3.6.1.3.10.

SR 3.6.1.3.10

The analyses in References 1 and 2 are based on leakage that is less than the specified leakage rate. Leakage through each main steam line must be 100 scfh when tested at Pa, and the total leakage rate through all four main steam lines is 250 scfh. The Frequency is required by the Primary Containment Leakage Rate Testing Program.

If work is performed on a valve in a Main Steam Line following the satisfactory performance of as-found testing, the post maintenance testing must ensure that Main Steam Line leakage does not exceed 100 scfh and total leakage does not exceed 250 scfh, prior to entering MODES 1, 2, or 3.

The outboard MSIVs must have a safety related air source available for use following an accident in order for leakage to be within limits.

Therefore, anytime that this air source from the B train of P57 Safety Related Air System is not available, the outboard MSIVs may not be able to meet this surveillance requirement.

(continued)

PERRY - UNIT 1 B 3.6-31 Revision No. 13 SPMU System B 3.6.2.4

BASES

SURVEILLANCE SR 3.6.2.4.4 REQUIREMENTS (continued) The upper containment pool has two gates used to separate the pool into distinct sections to facilitate fuel transfer and maintenance during refueling operations which, when installed, limit personnel exposure and ensure adequate water submergence of the separator when the separator is stored in the pool. The SPMU System dump line penetrations are located in the steam separator storage section of the pool. To provide the required SPMU System dump volume to the suppression pool, the steam dryer storage/reactor well pool gate must be removed (or placed in its stored position) to allow communication between the various pool sections. The Surveillance is modified by a NOTE that allows installation of the steam dryer storage pool to reactor well gate if upper pool level is maintained per SR 3.6.2.4.1.c. Additional restrictions are imposed on the IFTS system to prevent accidental draining of the fuel transfer pool that could detrimentally effect assumptions made within the design basis analyses by creating additional entrapment volume areas for containment sprays (Reference 5). The fuel transfer pool gate may be in place, removed, or placed in its stored position, during power operation when no 360 Platform Troughs are submerged in the upper containment pool, since the volume of water in the fuel transfer pool is not required for SPMU. However, the fuel transfer pool gate must be removed, or placed in its storage position when any 360 Platform Trough is installed in the upper containment pool during power operations, since the volume of water in the fuel transfer pool is required for SPMU due to the inventory loss from the installation of the troughs. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.2.4.5

This SR verifies that each SPMU subsystem automatic valve actuates to its correct position on receipt of an actual or simulated automatic initiation signal. This includes verification of the correct automatic positioning of the valves and of the operation of each interlock and timer. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.4.6 overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a NOTE that excludes makeup to the suppression pool. Since all active components are testable, makeup to the suppression pool is not required.

(continued)

PERRY - UNIT 1 B 3.6-88 Revision No. 13 Drywell Isolation Valves B 3.6.5.3

BASES

Table B 3.6.5.3-1 (page 1 of 1)

Drywell Isolation Valves

Valve Number Maximum Isolation Time (seconds)

1B33-F013A NA 1B33-F013B NA 1B33-F017A NA 1B33-F017B NA 1B33-F019 5 1B33-F020 5

1C41-F006 NA 1C41-F007 NA

1G61-F030 22 1G61-F035 22 1G61-F150 22 1G61-F155 22

1M14-F055A 4 1M14-F055B 4 1M14-F060A 4 1M14-F060B 4 1M14-F065 4 1M14-F070 4

1M51-F010A 37 1M51-F010B 37

1P22-F015 18.8 1P22-F593 NA

1P43-F355 15 1P43-F400 15 1P43-F410 15 1P43-F722 NA

1P51-F652 22.5 1P51-F653 NA

1P52-F639 NA 1P52-F646 30*

1P54-F395 20*

  • Standard closure time, based on nominal pipe diameter, is approximately 12 inches per minute for gate valves and approximately four inches per minute for globe valves.

PERRY - UNIT 1 B 3.6-144 Revision No. 13 AC Sources - Shutdown B 3.8.2

BASES

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

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

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

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

(continued)

PERRY - UNIT 1 B 3.8-36 Revision No. 13 AC Sources - Shutdown B 3.8.2

BASES

LCO It is acceptable for divisions to be cross tied during shutdown conditions, (continued) permitting a single offsite power circuit to supply all required AC electrical power distribution subsystems.

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

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

a. Systems that provide core cooling are available;
b. Systems used to mitigate a fuel handling accident involving handling of recently irradiated fuel are available (due to radioactive decay, handling of fuel only requires OPERABILITY of the AC Sources when the fuel being handled is recently irradiated, i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />);
c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and
d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

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

(continued)

PERRY - UNIT 1 B 3.8-37 Revision No. 13 AC Sources - Shutdown B 3.8.2

BASES (continued)

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

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

This SR is modified by a Note which precludes requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of SRs, and preclude de-energizing a required 4160 V ESF bus or disconnecting a required offsite circuit during performance of Surveillances. With limited AC sources available, a single event could compromise both the required circuit and the DG. It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG is required to be OPERABLE. Hence the NOTE provides an exception to SR 3.0.1 during the period when only one diesel generator is OPERABLE.

REFERENCES None.

PERRY - UNIT 1 B 3.8-40 Revision No. 13 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3

BASES

SURVEILLANCE SR 3.8.3.4 (continued)

REQUIREMENTS 210 psig. For Division 3 DG, this Surveillance is met provided two air start receivers are pressurized 210 psig. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.8.3.5

Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Periodic removal of water from the storage tanks eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and from breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

PERRY - UNIT 1 B 3.8-49 Revision No. 13 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3

BASES

REFERENCES 1. USAR, Section 9.5.4.

2. Regulatory Guide 1.137.
3. ANSI N195 - 1976.
4. USAR, Chapter 6.
5. USAR, Chapter 15.
7. ASTM Standards: D4057-95 (Reapproved 2000); D1298-85; D975-89; D4176-86; D2276-88.

PERRY - UNIT 1 B 3.8-50 Revision No. 13 DC Sources - Operating B 3.8.4

BASES

BACKGROUND Each DC subsystem is located in an area separated physically and (continued) electrically from the other subsystems to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem.

There is no sharing between redundant Class 1E subsystems such as batteries, battery chargers, or distribution panels.

Each battery has adequate storage capacity to meet the duty cycles discussed in the USAR, Section 8 (Ref. 4). The battery is designed with additional capacity above that required by the design duty cycle to allow for temperature variations and other factors.

The batteries for a DC electrical power subsystem are sized to produce required capacity at 80% of nameplate rating. The minimum voltage design limit is 1.875 V per cell for Division 1, 1.863 V per cell for Division 2 and 1.905 V per cell for Division 3 batteries (Ref. 4).

The battery cells are flooded lead acid construction with a nominal specific gravity of 1.215. This specific gravity corresponds to an open circuit battery voltage of approximately 125 V for a 61 cell battery for Division 1 and a 60 cell battery for Division 2 and Division 3 (i.e., cell voltage of 2.049 volts per cell (Vpc) for Division 1 and cell voltage of 2.083 Vpc for Division 2 and Division 3)). The open circuit voltage is the voltage maintained when there is no charging or discharging. Once fully charged with its open circuit voltage 2.049 Vpc, the Division 1 battery cell will maintain its capacity for 30 days without further charging per manufacturers instructions. Likewise, once fully charged with its open circuit voltage 2.083 Vpc, the Division 2 battery cell and Division 3 battery cell will maintain its capacity for 30 days without further charging per manufacturers instructions. Optimal long term performance, however, is obtained by maintaining a float voltage of 2.17 to 2.26 Vpc for Division 1 and 2 batteries, and 2.20 to 2.25 Vpc for Division 3 batteries.

This provides adequate over-potential, which limits the formation of lead sulfate and self-discharge. The nominal float voltage of 2.21 Vpc for Division 1 and 2.25 Vpc for Division 2 and Division 3 corresponds to a total float voltage output of 135 V for a 61/60 cell battery as discussed in the USAR, Section 8 (Ref. 4).

Each battery charger of Division 1 and 2 DC electrical power subsystem battery charger has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged. Each battery charger has sufficient excess capacity to restore the battery bank from the design minimum charge to its fully charged state within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while supplying normal steady state loads (Ref. 4).

(continued)

PERRY - UNIT 1 B 3.8-52 Revision No. 13 DC Sources - Operating B 3.8.4

BASES

BACKGROUND The battery charger of Division 3 DC electrical power subsystem battery (continued) charger has sufficient excess capacity to restore the battery bank from the design minimum charge to its fully charged state in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> while supplying normal steady state loads (Ref. 4).

The battery charger is normally in the float-charge mode. Float-charge is the condition in which the charger is supplying the connected loads and the battery cells are receiving adequate current to optimally charge the battery. This assures the internal losses of a battery are overcome and the battery is maintained in a fully charged state.

When desired, the charger can be placed in the equalize mode. The equalize mode is at a higher voltage than the float mode and charging current is correspondingly higher. The battery charger is operated in the equalize mode after a battery discharge or for routine maintenance.

Following a battery discharge, the battery recharge characteristic accepts current at the current limit of the battery charger (if the discharge was significant, e.g., following a battery performance test) until the battery terminal voltage approaches the charger voltage setpoint. Charging current then reduces exponentially during the remainder of the recharge cycle. Lead-calcium batteries have recharge efficiencies of greater than 95%, so once at least 105% of the ampere-hours discharged have been returned, the battery capacity would be restored to the same condition as it was prior to the discharge. This can be monitored by direct observation of the exponentially decaying charging current or by evaluating the amp-hours discharged from the battery and amp-hours returned to the battery.

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the USAR, Chapter 6 (Ref. 5) and Chapter 15 (Ref. 6),

ANALYSES assume that ESF systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the DGs, emergency auxiliaries, and control and switching during all MODES of operation.

(continued)

PERRY - UNIT 1 B 3.8-52a Revision No. 13 DC Sources - Operating B 3.8.4

BASES

APPLICABILITY b. Adequate core cooling is provided, and containment integrity and (continued) other vital functions are maintained in the event of a postulated DBA.

The DC electrical power requirements for MODES 4 and 5 are addressed in the Bases for LCO 3.8.5, DC Sources - Shutdown.

ACTIONS A.1, A.2, and A.3

Condition A represents one subsystem with required battery charger inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability.

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, avoiding a premature shutdown with its own attendant risk.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

(continued)

PERRY - UNIT 1 B 3.8-54 Revision No. 13 DC Sources - Operating B 3.8.4

BASES

ACTIONS A.1, A.2, and A.3 (continued)

If the charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristics of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (Required Action A.2).

Required Action A.2 requires that the battery float current be verified as less than or equal to 2 amps. This indicates that, if the battery had been discharged as a result of the inoperable battery charger, it is now fully capable of supplying the maximum expected load requirement. The 2 amp value is based on returning the battery for Division 1 to 92%

charge, the battery for Division 2 to 96% charge, and the battery for Division 3 to 95% charge, and assumes a 5% design margin for the battery. If at the expiration of the initial 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period the battery float current is not less than or equal to 2 amps this indicates there may be additional battery problems and the battery must be declared inoperable.

Required Action A.3 limits the restoration time for the inoperable battery charger to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time reflects a reasonable time to effect restoration of the qualified battery charger to OPERABLE status.

B.1

Condition B represents one subsystem with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized during normal operation. It is, therefore, imperative that the operators attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected subsystem. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is consistent with the allowed time for an inoperable DC distribution system subsystem.

(continued)

PERRY - UNIT 1 B 3.8-55 Revision No. 13 DC Sources - Operating B 3.8.4

BASES

ACTIONS B.1 (continued)

If one of the required Division 1 or 2 DC electrical power subsystems is inoperable for reasons other than Condition A (e.g., inoperable battery charger and associated inoperable battery), the remaining DC electrical power subsystems have the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst case single failure could, however, result in the loss of minimum necessary DC electrical subsystems, continued power operation should not exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time is based on Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

C.1

With the Division 3 DC electrical power subsystem inoperable, the HPCS System may be incapable of performing its intended function and must be immediately declared inoperable. This declaration also requires entry into applicable Conditions and Required Actions of LCO 3.5.1, ECCS -

Operating.

D.1 and D.2

If the DC electrical power subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 4 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).

(continued)

PERRY - UNIT 1 B 3.8-56 Revision No. 13 DC Sources - Operating B 3.8.4

BASES

SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a fully charged state while supplying the continuous steady state loads of the associated DC subsystem. On float charge, battery cells will receive adequate current to optimally charge the battery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float voltage established by the battery manufacturer, 2.17 Vpc for Division 1 and 2, and 2.20 Vpc for Division 3, times the number of connected cells. This voltage maintains the battery plates in a condition that supports maintaining the grid life. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

PERRY - UNIT 1 B 3.8-57 Revision No. 13 DC Sources - Operating B 3.8.4

BASES

SURVEILLANCE SR 3.8.4.2 REQUIREMENTS (continued) This SR verifies the design capacity of the battery chargers. According to Regulatory Guide 1.32 (Ref. 8), the battery charger supply is recommended to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences.

The minimum required amperes and duration ensure that these requirements can be satisfied.

This SR provides two options. One option requires that each battery charger be capable of supplying 400 amps for Division 1 and 2 and 50 amps for Division 3 at the minimum established float voltage for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The ampere requirements are based on the output rating of the chargers. The voltage requirements are based on the charger voltage level after a response to a loss of AC power. The time period is sufficient for the charger temperature to have stabilized and to have been maintained for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

The other option requires that each battery charger be capable of recharging the battery after a performance test coincident with supplying the largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur). This level of loading may not normally be available following the battery performance test and will need to be supplemented with additional loads. The duration for this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current. The battery is recharged when the measured charging current is 2 amps.

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

(continued)

PERRY - UNIT 1 B 3.8-58 Revision No. 13 DC Sources - Operating B 3.8.4

BASES

SURVEILLANCE SR 3.8.4.3 REQUIREMENTS (continued) A battery service test is a special test of the batterys capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length correspond to the design duty cycle requirements as specified in Reference 4.

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

This SR is modified by a Note. The Note allows the periodic performance of SR 3.8.6.6 in lieu of SR 3.8.4.3. This substitution is acceptable because SR 3.8.6.6 represents a more severe test of battery capacity than SR 3.8.4.3.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

2. Regulatory Guide 1.6, March 10, 1971.
3. IEEE Standard 308, 1978.
4. USAR, Section 8.
5. USAR, Chapter 6.
6. USAR, Chapter 15.
7. Regulatory Guide 1.93, December 1974.
8. Regulatory Guide 1.32, February 1977.
9. Regulatory Guide 1.129, December 1974.

PERRY - UNIT 1 B 3.8-59 Revision No. 13 DC Sources - Shutdown B 3.8.5

BASES

APPLICABILITY c. Required features necessary to mitigate the effects of events that can (continued) lead to core damage during shutdown are available; and

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

The DC electrical power requirements for MODES 1, 2, and 3 are covered in LCO 3.8.4.

ACTIONS The ACTIONS are modified by a Note indicating that LCO 3.0.3 does not apply. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require reactor shutdown.

A.1, A.2, and A.3

Condition A represents one subsystem with the required battery charger inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability.

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle.

The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, avoiding a premature shutdown with its own attendant risk.

(continued)

PERRY - UNIT 1 B 3.8-62 Revision No. 13 DC Sources - Shutdown B 3.8.5

BASES

ACTIONS A.1, A.2, and A.3 (continued)

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and the charger is not operating in the current-limiting modes, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

If the charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (Required Action A.2).

Required Action A.2 requires that the battery float current be verified as less than or equal to 2 amps. This indicates that, if the battery had been discharged as the result of the inoperable battery charger, it has now been fully recharged. If at the expiration of the initial 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period the battery float current is not less than or equal to 2 amps this indicates there may be additional battery problems and the battery must be declared inoperable.

Required Action A.3 limits the restoration time for the inoperable battery charger to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time reflects a reasonable time to effect restoration of the qualified battery charger to OPERABLE status.

B.1, B.2.1, B.2.2, and B.2.3

If more than one DC distribution subsystem is required according to LCO 3.8.8, the DC subsystems remaining OPERABLE with one or more DC power sources inoperable may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and

(continued)

PERRY - UNIT 1 B 3.8-62a Revision No. 13 DC Sources - Shutdown B 3.8.5

BASES

ACTIONS B.1, B.2.1, B.2.2, and B.2.3 (continued)

movement of recently irradiated fuel. By allowing the option to declare required features associated with an inoperable DC power source(s) inoperable, appropriate restrictions are implemented in accordance with the Required Actions of the LCOs for these associated required features.

Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative alternate actions (i.e., to suspend CORE ALTERATIONS and movement of recently irradiated fuel assemblies in the primary containment and fuel handling building) is made.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystems and to continue this action until restoration is accomplished in order to provide the necessary DC electrical power to the plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power.

SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires performance of all Surveillances required by SR 3.8.4.1 through SR 3.8.4.3. Therefore, see the corresponding Bases for LCO 3.8.4 for a discussion of each SR.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required power supply or otherwise rendered inoperable during the performance of SRs. It is the intent that these SRs must still be capable of being met, but actual performance is not required.

REFERENCES 1. USAR, Chapter 6.

2. USAR, Chapter 15.

PERRY - UNIT 1 B 3.8-63 Revision No. 13 Battery Parameters B 3.8.6

B 3.8 ELECTRICAL POWER SYSTEMS

B 3.8.6 Battery Parameters

BASES

BACKGROUND This LCO delineates the limits on battery float current as well as electrolyte temperature, level, and float voltage for the DC power source batteries. A discussion of these batteries and their OPERABILITY requirements is provided in the Bases for LCO 3.8.4, DC Sources -

Operating, and LCO 3.8.5, DC Sources - Shutdown. In addition to the limitations of this Specification, the battery monitoring and maintenance program also implements a program specified in Specification 5.5.16 for monitoring various battery parameters.

The battery cells are of flooded lead acid construction with a nominal specific gravity of 1.215. This specific gravity corresponds to an open circuit battery voltage of approximately 125 V for 61 cell battery for Division 1 and a 60 cell battery for Division 2 and Division 3 (i.e., cell voltage of 2.049 volts per cell (Vpc) for Division 1 and cell voltage of 2.083 Vpc for Division 2 and 3)). The open circuit voltage is the voltage maintained when there is no charging or discharging. Once fully charged with its open circuit voltage 2.049 Vpc, the Division 1 battery cell will maintain its capacity for 30 days without further charging per manufacturers instructions. Likewise, once fully charged with its open circuit voltage 2.083 Vpc, the Division 2 battery cell and Division 3 battery cell will maintain its capacity for 30 days without further charging per manufacturers instructions. Optimal long term performance, however, is obtained by maintaining a float voltage of 2.17 to 2.26 Vpc for Division 1 and 2 batteries, and 2.20 to 2.25 Vpc for Division 3 batteries.

This provides adequate over-potential which limits the formation of lead sulfate and self-discharge. The nominal float voltage of 2.21 Vpc for Division 1 and 2.25 Vpc for Division 2 and Division 3 corresponds to a total float voltage output of 135 V for a 61/60 cell battery as discussed in the USAR, Section 8 (Ref. 2).

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in USAR, Chapter 6 (Ref. 3) and Chapter 15 (Ref. 4), assume ANALYSES that Engineered Safety Feature systems are OPERABLE. The DC electrical power subsystems provide normal and emergency DC electrical power for the diesel generators, emergency auxiliaries, and control and switching during all MODES of operation.

(continued)

PERRY - UNIT 1 B 3.8-64 Revision No. 13 Battery Parameters B 3.8.6

BASES

APPLICABLE The OPERABILITY of the DC subsystems is consistent with the initial SAFETY assumptions of the accident analyses and is based upon meeting the ANALYSES design basis of the unit. This includes maintaining at least one (continued) subsystem of DC sources OPERABLE during accident conditions, in the event of:

a. An assumed loss of all offsite AC power or all onsite AC power; and
b. A worst case single failure.

Since battery parameters support the operation of the DC power sources, they satisfy Criterion 3 of the NRC Final Policy Statement on Technical Specification Improvements (58 FR 39132).

LCO Battery parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. Battery parameter limits are conservatively established, allowing continued DC electrical system function even with limits not met. Additional preventative maintenance, testing, and monitoring performed in accordance with the Battery Monitoring and Maintenance Program is conducted as specified in Specification 5.5.16.

APPLICABILITY The battery parameters are required solely for the support of the associated DC electrical power subsystem. Therefore, battery parameter limits are only required when the DC power source is required to be OPERABLE. Refer to the Applicability discussion in Bases for LCO 3.8.4 and LCO 3.8.5.

ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each batte ry. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable battery. Complying with the Required Actions for one inoperable battery may allow for continued operation, and subsequent inoperable batteries are governed by separate Condition entry and application of associated Required Actions.

(continued)

PERRY - UNIT 1 B 3.8-65 Revision No. 13 Battery Parameters B 3.8.6

BASES

ACTIONS A.1, A.2, and A.3 (continued)

With one or more cells in one or more batteries in one subsystem 2.07 V, the battery cell is degraded. Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> verification of the required battery charger OPERABILITY is made by monitoring the battery terminal voltage (SR 3.8.4.1) and of the overall battery state of charge by monitoring the battery float charge current (SR 3.8.6.1). This assures that there is still sufficient battery capacity to perform the intended function.

Therefore, the affected battery is not required to be considered inoperable solely as a result of one or more cells in one or more batteries 2.07 V, and continued operation is permitted for a limited period up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Since the Required Actions only specify perform, a failure of SR 3.8.4.1 or SR 3.8.6.1 acceptance criteria does not result in this Required Action not met. However, if one of the SRs is failed the appropriate Condition(s),

depending on the cause of the failures, is entered. If SR 3.8.6.1 is failed then there is not assurance that there is still sufficient battery capacity to perform the intended function and the battery must be declared inoperable immediately.

B.1 and B.2

One or more batteries in one subsystem with float > 2 amps indicates that a partial discharge of the battery capacity has occurred. This may be due to a temporary loss of a battery charger or possibly due to one or more battery cells in a low voltage condition reflecting some loss of capacity.

Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> verification of the required battery charger OPERABILITY is made by monitoring the battery terminal voltage. If the terminal voltage is found to be less than the minimum established float voltage there are two possibilities, the battery charger is inoperable or is operating in the current limit mode. TS 3.8.4 Condition A and TS 3.8.5 Condition A addresses charger inoperability. If the charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that is an indication that the battery has been substantially discharged and likely cannot perform its required design functions. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (Required Action B.2). The battery must therefore be declared inoperable.

If the float voltage is found to be satisfactory but there are one or more battery cells with float voltage less than or equal to 2.07 V, the associated

(continued)

PERRY - UNIT 1 B 3.8-66 Revision No. 13 Battery Parameters B 3.8.6

BASES

ACTIONS B.1 and B.2 (continued)

OR statement in Condition F is applicable and the battery must be declared inoperable immediately. If float voltage is satisfactory and there are no cells less than or equal to 2.07 V there is good assurance that, within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the battery will be restored to its fully charged condition (Required Action B.2) from any discharge that might have occurred due to a temporary loss of the battery charger.

A discharged battery with float voltage (the charger setpoint) across its terminals indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, avoiding a premature shutdown with its own attendant risk.

If the condition is due to one or more cells in a low voltage condition but still greater than 2.07 V and float voltage is found to be satisfactory, this is not indication of a substantially discharged battery and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is a reasonable time prior to declaring the battery inoperable.

Since Required Action B.1 only specifies perform, a failure of SR 3.8.4.1 acceptance criteria does not result in the Required Action not met.

However, if SR 3.8.4.1 is failed, the appropriate Condition(s), depending on the cause of the failure, is entered.

C.1, C.2, and C.3

With one or more batteries in one subsystem with one or more cells electrolyte level above the top of the plates, but below the minimum established design limits, the battery still retains sufficient capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of electrolyte level not met. Within 31 days the minimum established design limits for electrolyte level must be re-established.

With electrolyte level below the top of the plates there is a potential for dryout and plate degradation. Required Actions C.1 and C.2 address this potential (as well as provisions in Specification 5.5.16, Battery Monitoring and Maintenance Program). They are modified by a Note that indicates they are only applicable if electrolyte level is below the top of the plates.

Within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> level is required to be restored to above the top of the

(continued)

PERRY - UNIT 1 B 3.8-67 Revision No. 13 Battery Parameters B 3.8.6

BASES

ACTIONS C.1, C.2, and C.3 (continued)

plates. The Required Action C.2 requirement to verify that there is no leakage by visual inspection and the Specification 5.5.16.b item to initiate action to equalize and test in accordance with manufacturers recommendation. They are performed following the restoration of the electrolyte level to above the top of the plates. Based on the results of the manufacturers recommended testing the batteries may have to be declared inoperable and the affected cells replaced.

D.1

With one or more batteries in one subsystem with pilot cell temperature less than the minimum established design limits, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed to restore the temperature to within limits. A low electrolyte temperature limits the current and power available. Since the battery is sized with margin, while battery capacity is degraded, sufficient capacity exists to perform the intended function and the affected battery is not required to be considered inoperable solely as a result of the pilot cell temperature not met.

E.1

With one or more batteries in redundant subsystems with battery parameters not within limits there is not sufficient assurance that battery capacity has not been affected to the degree that the batteries can still perform their required function, given that redundant batteries are involved. With redundant batteries involved this potential could result in a total loss of function on multiple systems that rely upon the batteries. The longer Completion Times specified for battery parameters on non-redundant batteries not within limits are therefore not appropriate, and the parameters must be restored to within limits on at least one subsystem within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

F.1

When any battery parameter is outside the allowances of the Required Actions for Condition A, B, C, D, or E, sufficient capacity to supply the maximum expected load requirement is not assured and the associated battery must be declared inoperable. Additionally, discovering one or more batteries in one subsystem with one or more battery cells float voltage less than or equal to 2.07 V and float current greater than 2 amps indicates that the battery capacity may not be sufficient to perform the intended functions. The battery must therefore be declared inoperable immediately.

(continued)

PERRY - UNIT 1 B 3.8-68 Revision No. 13 Battery Parameters B 3.8.6

BASES (continued)

SURVEILLANCE SR 3.8.6.1 REQUIREMENTS Verifying battery float current while on float charge is used to determine the state of charge of the battery. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a charged state.

The equipment used to monitor float current must have the necessary accuracy and capability to measure electrical currents in the expected range. The float current requirements are based on the float current indicative of a charged battery. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that states the float current requirement is not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1. When this float voltage is not maintained the Required Actions of LCO 3.8.4 ACTION A are being taken, which provide the necessary and appropriate verifications of the battery condition. Furthermore, the float current limit of 2 amps is established based on the nominal float voltage value and is not directly applicable when this voltage is not maintained.

SR 3.8.6.2 and SR 3.8.6.5

Optimal long term battery performance is obtained by maintaining a float voltage greater than or equal to the minimum established design limits provided by the battery manufacturer, which corresponds to 132.37 Vdc for Division 1, 130.2 Vdc for Division 2, and 132 Vdc for Division 3 at the battery terminals, or 2.17 Vpc for Division 1 and 2, and 2.20 Vpc for Division 3. This provides adequate over-potential, which limits the formation of lead sulfate and self discharge, which could eventually render the battery inoperable. Float voltages in this range or less, but greater than 2.07 Vpc, are addressed in Specification 5.5.16. SRs 3.8.6.2 and 3.8.6.5 require verification that the cell float voltages are greater than the short term absolute minimum voltage of 2.07 V. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.8.6.3

The limit specified for electrolyte level ensures that the plates suffer no physical damage and maintains adequate electron transfer capability.

The minimum design electrolyte level is the minimum level indication mark on the battery cell jar. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

PERRY - UNIT 1 B 3.8-69 Revision No. 13 Battery Parameters B 3.8.6

BASES

SURVEILLANCE SR 3.8.6.4 REQUIREMENTS (continued) This Surveillance verifies that the pilot cell temperature is greater than or equal to the minimum established design limit (i.e., 72°F). Pilot cell electrolyte temperature is maintained above this temperature to assure the battery can provide the required current and voltage to meet the design requirements. Temperatures lower than assumed in battery sizing calculations act to inhibit or reduce battery capacity. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.8.6.6

A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

The battery performance discharge test is acceptable for satisfying SR 3.8.6.6.

The acceptance criteria for this Surveillance are consistent with IEEE-450 (Ref. 1) and IEEE-485 (Ref. 5). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturers rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

Furthermore, the battery is sized to meet the assumed duty cycle loads when the battery design capacity reaches this 80% limit. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is < 100% of the manufacturers rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity 100% of the manufacturers rating. Degradation is indicated, according to IEEE-450 (Ref. 1), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is 10% below the manufacturers rating. All these Frequencies are consistent with the recommendations in IEEE-450 (Ref. 1).

(continued)

PERRY - UNIT 1 B 3.8-70 Revision No. 13 Battery Parameters B 3.8.6

BASES

SURVEILLANCE SR 3.8.6.6 (continued)

REQUIREMENTS This SR is modified by a Note. Credit may be taken for unplanned events that satisfy this SR. This note is provided to prevent unnecessary cycling of plant equipment.

REFERENCES 1. IEEE-450.

2. USAR, Chapter 8.
3. USAR, Chapter 6.
4. USAR, Chapter 15.
5. IEEE Standard 485, 1983.

PERRY - UNIT 1 B 3.8-70a Revision No. 13 Distribution Systems - Operating B 3.8.7

BASES

APPLICABILITY ACTIONS for an inoperable Division 3 electrical power distribution (continued) subsystem. This exception is acceptable since, with the HPCS System inoperable and the associated ACTIONS entered, the Division 3 electrical power distribution subsystems pr ovide no additional assurance of meeting the above criteria.

Electrical power distribution subsystem requirements for MODES 4 and 5 are covered in the Bases for LCO 3.8.8, "Distribution Systems -

Shutdown."

ACTIONS A.1

With one or more Division 1 or 2 required AC buses, load centers, motor control centers, or distribution panels, in one division inoperable, the remaining AC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining AC electrical power distribution subsystems could result in the minimum required ESF functions not being supported.

Therefore, the required AC buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

The Condition A worst case scenario is one division without AC power (i.e., no offsite power to the division and the associated DG inoperable).

In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators attention be focused on minimizing the potential for loss of power to the remaining division by stabilizing the unit, and on restoring power to the affected division. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time limit before requiring a unit shutdown in this Condition is acceptable because:

(continued)

PERRY - UNIT 1 B 3.8-74 Revision No. 13 Distribution Systems - Operating B 3.8.7

BASES

ACTIONS D.1 (continued)

With one or more Division 3 AC or DC electrical power distribution subsystems inoperable, the Division 3 powered systems are not capable of performing their intended functions. Immediately declaring the HPCS System inoperable allows the ACTIONS of LCO 3.5.1, ECCS-Operating, to apply appropriate limitations on continued reactor operation.

E.1

Condition E corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost.

When more than one Condition is entered, and this results in the loss of a required function, the plant is in a condition outside the accident analysis.

Therefore, no additional time is justified for continued operation.

LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.7.1 REQUIREMENTS Meeting this Surveillance verifies that the AC and DC electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

PERRY - UNIT 1 B 3.8-78 Revision No. 13 Distribution Systems - Operating B 3.8.7

Table B 3.8.7-1 (page 1 of 1)

AC and DC Electrical Power Distribution Systems

TYPE NOMINAL DIVISION 1 (a) DIVISION 2 (a) DIVISION 3 (a)

VOLTAGE

AC 4160 V EH11 EH12 EH13 Electrical Power 480 V LCCs EF-1-A EF-1-C ---

Distribution EF-1-B EF-1-D System 480 V MCCs EF-1-A-07 EF-1-C-07 EF-1-E-1 EF-1-A-08 EF-1-C-08 EF-1-E-2 EF-1-A-09 EF-1-C-09 EF-1-A-12 EF-1-C-12 EF-1-B-07 EF-1-D-07 EF-1-B-08 EF-1-D-08 EF-1-B-09 EF-1-D-09

120 V Dist. EB-1-A1 EB-1-B1 EK-1-C1 Panels EK-1-A1 EK-1-B1

120 V Bus EV-1-A EV-1-B ---

DC 125 V Bus ED-1-A Bus ED-1-B Bus ED-1-C Electrical Power MCCs ED-1-A-09 --- ---

Distribution System Dist. Panels ED-1-A-06 ED-1-B-06 1R42-S037 ED-1-B-08

(a) Each division of the AC and DC electrical power distribution systems is a subsystem.

PERRY - UNIT 1 B 3.8-80 Revision No. 13 Distribution Systems - Shutdown B 3.8.8

BASES

ACTIONS A.1, A.2.1, A.2.2, A.2.3, and A.2.4 (continued)

would not be entered. Therefore, Required Action A.2.4 is provided to direct declaring the associated required shutdown cooling subsystems inoperable, and not in operation, which results in taking the appropriate RHR-SDC ACTIONS.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC and DC electrical power distribution subsystems should be completed as quickly as possible in order to minimize the time the plant safety systems may be without power.

SURVEILLANCE SR 3.8.8.1 REQUIREMENTS This Surveillance verifies that the required AC and DC electrical power distribution subsystems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures that the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the required buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. USAR, Chapter 6.

2. USAR, Chapter 15.

PERRY - UNIT 1 B 3.8-84 Revision No. 13