L-22-221, Supplement to Application to Revise the Technical Specifications to Adopt TSTF-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position

Supplement to Application to Revise the Technical Specifications to Adopt TSTF-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position

ML22291A436
Person / Time
Site:	Perry
Issue date:	10/18/2022
From:	Penfield R Energy Harbor Nuclear Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2022-LLA-0108, L-22-221
Download: ML22291A436 (33)

Text

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harbor Rod L. Penfield Site Vice President, Perry Nuclear October 18, 2022 L-22-221 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Energy Harbor Nuclear Corp.

Perry Nuclear Power Plant 10 Center Road P.O. Box 97 Perry, Ohio 44081 440-280-5382 10 CFR 50.90 Supplement to Application to Revise the Technical Specifications to Adopt TSTF-541, "Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position" (EPID No. L-2022-LLA-0108)

By letter dated August 5, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22217A087), Energy Harbor Nuclear Corp.

submitted a request for an amendment to the Technical Specifications (TS) for Perry Nuclear Power Plant, Unit No. 1 (PNPP). The proposed amendment modifies the TS consistent with Technical Specifications Task Force (TSTF) Traveler TSTF-541, "Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position." The August 5, 2022 letter included a description and assessment of the proposed changes, the existing TS pages marked up to show the proposed changes, revised (clean) TS pages for information only, and existing TS Bases pages marked to show the proposed changes for information only.

Energy Harbor Nuclear Corp. identified incorrect wording had been used in the TS pages. The error does not impact the description and assessment of the proposed changes, only the marked up and revised TS and TS Bases pages. Energy Harbor Nuclear Corp. hereby provides the following attachments to supersede those provided by the August 5, 2022 letter. Attachment 1 contains corrected TS pages marked up to show the proposed changes. Attachment 2 contains the corrected revised (clean) TS pages for information only. Attachment 3 contains the corrected TS Bases pages marked to show the proposed changes for information only.

There is no change to the no significant hazards consideration determination.

Perry Nuclear Power Plant L-22-221 Page 2 There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Manager-Nuclear Licensing, at (330) 696-7208.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October _j.L, 2022.

Sincerely, Ti2c}(.

Rod L. Penfield Attach men ts:

1. Technical Specification Page Markups

2. Revised Technical Specification Pages (for Information Only)

3. TS Bases Markups (for Information Only) cc:

NRC Region Ill Administrator NRC Resident Inspector NRR Project Manager Executive Director, Ohio Emergency Management Agency, (State of Ohio NRC Liaison)

Utility Radiological Safety Board Technical Specification Page Markups (8 pages follow)

ECCS - Operating 3.5.1 PERRY - UNIT 1 3.5-5 Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.5

---

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

Vessel injection/spray may be excluded.

Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.6 ------------------------------NOTE-------------------------------

Valve actuation may be excluded.

Verify the ADS actuates on an actual or simulated automatic initiation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.7 ------------------------------NOTE-------------------------------

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

Verify each ADS valve actuator strokes when manually actuated.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.8 ------------------------------NOTE-------------------------------

ECCS actuation instrumentation is excluded.

Verify the ECCS RESPONSE TIME for each ECCS injection/spray subsystem is within limits.

In accordance with the Surveillance Frequency Control Program

RPV Water Inventory Control 3.5.2 PERRY - UNIT 1 3.5-9 Amendment No. 192 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5

---

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

1.

Operation may be through the test return line.

2.

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

Operate the required ECCS injection/spray subsystem for 10 minutes.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.6 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.7

---

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program

RCIC System 3.5.3 PERRY - UNIT 1 3.5-12 Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.3.5

---

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

Vessel injection may be excluded.

Verify the RCIC System actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program

RHR Containment Spray System 3.6.1.7 PERRY - UNIT 1 3.6-25 Amendment No. 175 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.7.1 ---------------------------------NOTE-----------------------------

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

Verify each RHR containment spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.6.1.7.2 Verify each RHR pump develops a flow rate of 5250 gpm on recirculation flow through the associated heat exchangers to the suppression pool.

In accordance with the INSERVICE TESTING PROGRAM SR 3.6.1.7.3 Verify each RHR containment spray subsystem automatic valve in the flow path actuates to its correct position on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program SR 3.6.1.7.4 Verify each spray nozzle is unobstructed.

Following maintenance which could result in nozzle blockage.

AEGT System 3.6.4.3 PERRY - UNIT 1 3.6-58 Amendment No. 180 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each AEGT subsystem for 15 continuous minutes.

In accordance with the Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required AEGT filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

In accordance with the VFTP SR 3.6.4.3.3 Verify each AEGT subsystem actuates on an actual or simulated initiation signal, except for dampers that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program

ESW System-Div. 1 and 2 3.7.1 PERRY - UNIT 1 3.7-2 Amendment No. 171 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time of Condition A not met.

OR Both ESW Division 1 and Division 2 subsystems inoperable.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each required Division 1 and 2 ESW subsystem manual, power operated, and automatic valve in the flow path servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.7.1.2 Verify each required Division 1 and 2 ESW subsystem actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program

ESW System-Div. 3 3.7.2 PERRY - UNIT 1 3.7-3 Amendment No. 171 3.7 PLANT SYSTEMS 3.7.2 Emergency Service Water (ESW) System-Division 3 LCO 3.7.2 The Division 3 ESW subsystem shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ESW Division 3 subsystem inoperable.

A.1 Declare High Pressure Core Spray System inoperable.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Verify each required Division 3 ESW subsystem manual, power operated, and automatic valve in the flow path servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.7.2.2 Verify the Division 3 ESW subsystem actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program

CRER System 3.7.3 PERRY - UNIT 1 3.7-7 Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.3.3 Verify each CRER subsystem actuates on an actual or simulated initiation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program SR 3.7.3.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

In accordance with the Control Room Envelope Habitability Program.

Revised Technical Specification Pages (for Information Only)

(8 pages follow)

ECCS - Operating 3.5.1 PERRY - UNIT 1 3.5-5 Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.5

---

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

Vessel injection/spray may be excluded.

Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.6 ------------------------------NOTE-------------------------------

Valve actuation may be excluded.

Verify the ADS actuates on an actual or simulated automatic initiation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.7 ------------------------------NOTE-------------------------------

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

Verify each ADS valve actuator strokes when manually actuated.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.8 ------------------------------NOTE-------------------------------

ECCS actuation instrumentation is excluded.

Verify the ECCS RESPONSE TIME for each ECCS injection/spray subsystem is within limits.

In accordance with the Surveillance Frequency Control Program Information Only

RPV Water Inventory Control 3.5.2 PERRY - UNIT 1 3.5-9 Amendment No. 192 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5

---

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

1.

Operation may be through the test return line.

2.

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

Operate the required ECCS injection/spray subsystem for 10 minutes.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.6 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.7

---

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program Information Only

RCIC System 3.5.3 PERRY - UNIT 1 3.5-12 Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.3.5

---

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

Vessel injection may be excluded.

Verify the RCIC System actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program Information Only

RHR Containment Spray System 3.6.1.7 PERRY - UNIT 1 3.6-25 Amendment No. 175 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.7.1 ---------------------------------NOTE-----------------------------

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

Verify each RHR containment spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.6.1.7.2 Verify each RHR pump develops a flow rate of 5250 gpm on recirculation flow through the associated heat exchangers to the suppression pool.

In accordance with the INSERVICE TESTING PROGRAM SR 3.6.1.7.3 Verify each RHR containment spray subsystem automatic valve in the flow path actuates to its correct position on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program SR 3.6.1.7.4 Verify each spray nozzle is unobstructed.

Following maintenance which could result in nozzle blockage.

Information Only

AEGT System 3.6.4.3 PERRY - UNIT 1 3.6-58 Amendment No. 180 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each AEGT subsystem for 15 continuous minutes.

In accordance with the Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required AEGT filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

In accordance with the VFTP SR 3.6.4.3.3 Verify each AEGT subsystem actuates on an actual or simulated initiation signal, except for dampers that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program Information Only

ESW System-Div. 1 and 2 3.7.1 PERRY - UNIT 1 3.7-2 Amendment No. 171 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time of Condition A not met.

OR Both ESW Division 1 and Division 2 subsystems inoperable.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each required Division 1 and 2 ESW subsystem manual, power operated, and automatic valve in the flow path servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.7.1.2 Verify each required Division 1 and 2 ESW subsystem actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program Information Only

ESW System-Div. 3 3.7.2 PERRY - UNIT 1 3.7-3 Amendment No. 171 3.7 PLANT SYSTEMS 3.7.2 Emergency Service Water (ESW) System-Division 3 LCO 3.7.2 The Division 3 ESW subsystem shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ESW Division 3 subsystem inoperable.

A.1 Declare High Pressure Core Spray System inoperable.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Verify each required Division 3 ESW subsystem manual, power operated, and automatic valve in the flow path servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.7.2.2 Verify the Division 3 ESW subsystem actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program Information Only

CRER System 3.7.3 PERRY - UNIT 1 3.7-7 Amendment No. 171 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.3.3 Verify each CRER subsystem actuates on an actual or simulated initiation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program SR 3.7.3.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

In accordance with the Control Room Envelope Habitability Program.

Information Only TS Bases Markups (for Information Only)

(12 pages follow)

ECCS - Operating B 3.5.1 PERRY - UNIT 1 B 3.5-11 Revision No. 11 BASES SURVEILLANCE SR 3.5.1.4 (continued)

REQUIREMENTS elevation head loss and piping system friction loss at the required flow rate. This safety analysis value is determined by engineering calculation.

In addition, pump operability may be limited by the ASME required action range value for these pumps. The Frequency for this Surveillance is in accordance with the INSERVICE TESTING PROGRAM requirements.

SR 3.5.1.5 The ECCS subsystems are required to actuate automatically to perform their design functions. This Surveillance test verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCS, LPCS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup, and actuation of all automatic valves to their required positions. This Surveillance also ensures that the HPCS System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool on a condensate storage tank low water level signal and on a suppression pool high water level signal. The SR excludes automatic valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to valves that are locked, sealed, or otherwise secured in the actuated position since the affected valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve to the non-actuated position requires verification that the SR has been met within its required Frequency. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1, Emergency Core Cooling System (ECCS)

Instrumentation, overlaps this Surveillance to provide complete testing of the assumed safety function.

HPCS testing may be performed in any MODE. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

Information Only

RPV Water Inventory Control B 3.5.2 PERRY - UNIT 1 B 3.5-20b Revision No. 13 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 SR excludes automatic valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to valves that are locked, sealed, or otherwise secured in the actuated position since the affected valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve to the non-actuated position requires verification that the SR has been met within its required Frequency.

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

(continued)

Information Only

RPV Water Inventory Control B 3.5.2 PERRY - UNIT 1 B 3.5-20c Revision No. 13 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 SR excludes automatic valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to valves that are locked, sealed, or otherwise secured in the actuated position since the affected valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve to the non-actuated position requires verification that the SR has been met within its required Frequency.

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.

Information Only

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

RCIC System B 3.5.3 PERRY - UNIT 1 B 3.5-26 Revision No. 12 BASES SURVEILLANCE SR 3.5.3.5 (continued)

REQUIREMENTS automatic pump startup and actuation of all automatic valves to their required positions. This Surveillance test also ensures that the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool on a condensate storage tank low water level signal and on a suppression pool high water level signal. The SR excludes automatic valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to valves that are locked, sealed, or otherwise secured in the actuated position since the affected valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve to the non-actuated position requires verification that the SR has been met within its required Frequency. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.3, Reactor Core Isolation Cooling (RCIC)

System Instrumentation, overlaps this Surveillance to provide complete testing of the assumed safety function.

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

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

REFERENCES

1.

10 CFR 50, Appendix A, GDC 33.

2.

USAR, Section 5.4.6.

3.

Memorandum from R.L. Baer (NRC) to V. Stello, Jr. (NRC),

"Recommended Interim Revisions to LCO's for ECCS Components,"

December 1, 1975.

Information Only

RHR Containment Spray System B 3.6.1.7 PERRY - UNIT 1 B 3.6-46 Revision No. 12 BASES SURVEILLANCE SR 3.6.1.7.1 (continued)

REQUIREMENTS A Note has been added to this SR that allows RHR containment spray subsystems to be considered OPERABLE during alignment and operation for decay heat removal with reactor steam pressure less than the RHR cut in permissive pressure in MODE 3, if capable of being manually realigned (remote or local) and not otherwise inoperable. This allows operation in the RHR shutdown cooling mode during MODE 3 if necessary.

SR 3.6.1.7.2 Verifying each RHR pump develops a flow rate 5250 gpm with flow through the associated heat exchangers ensures that pump performance has not degraded below the required flow rate during the cycle. It is tested in the suppression pool cooling mode to demonstrate pump OPERABILITY without spraying down equipment in primary containment.

Flow is a normal test of centrifugal pump performance required by the ASME Code (Ref. 2). This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the INSERVICE TESTING PROGRAM.

SR 3.6.1.7.3 This SR verifies that each RHR containment spray subsystem automatic valve actuates to its correct position upon receipt of an actual or simulated automatic actuation signal. Actual spray initiation is not required to meet this SR. The SR excludes automatic valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to valves that are locked, sealed, or otherwise secured in the actuated position since the affected valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured.

Placing an automatic valve in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve to be repositioned to the non-actuated position to support the accident analysis.

Restoration of an automatic valve to the non-actuated position requires verification that the SR has been met within its required Frequency. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.2.5 overlaps this SR to provide complete testing of the safety function.

(continued)

Information Only

AEGT System B 3.6.4.3 PERRY - UNIT 1 B 3.6-122 Revision No. 12 BASES SURVEILLANCE SR 3.6.4.3.1 (continued)

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

SR 3.6.4.3.2 This SR verifies that the required AEGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The AEGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 4). The VFTP includes testing HEPA filter efficiency, system flow rate, and general operating parameters of the filtration system. (Note:

Values identified in the VFTP are Surveillance Requirement values.)

Specified test frequencies and additional information are discussed in detail in the VFTP.

SR 3.6.4.3.3 This SR verifies that each AEGT subsystem starts and isolation dampers open upon receipt of a manual initiation signal from the control room and an actual or simulated initiation and operates throughout its emergency operating sequence for the LOCA signal. The SR excludes automatic dampers that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to dampers that are locked, sealed, or otherwise secured in the actuated position since the affected dampers were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the damper to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic damper to the non-actuated position requires verification that the SR has been met within its required Frequency. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.5.1.6 overlaps this SR to provide complete testing of the safety function. This Surveillance can be performed with the reactor at power.

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

REFERENCES

1.

10 CFR 50, Appendix A, GDC 41.

2.

USAR, Section 6.5.3.

3.

USAR, Section 15.6.5.

4.

Regulatory Guide 1.52, Rev. 4.

5.

Deleted.

Information Only

AEGT System B 3.6.4.3 PERRY - UNIT 1 B 3.6-122 Revision No. 12 Information Only

ESW System - Div. 1 and 2 B 3.7.1 PERRY - UNIT 1 B 3.7-5 Revision No. 11 BASES SURVEILLANCE SR 3.7.1.1 (continued)

REQUIREMENTS rather, it involves verification that those valves potentially capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

Isolation of the ESW subsystem to components or systems does not necessarily affect the OPERABILITY of the associated ESW subsystem.

As such, when the ESW subsystem pump, valves, and piping are OPERABLE, but a branch connection off the main header is isolated, the associated ESW subsystem needs to be evaluated to determine if it is still OPERABLE.

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

SR 3.7.1.2 This SR verifies that the automatic isolation valves of the Division 1 and Division 2 ESW subsystems will automatically realign to the safety or emergency position to provide cooling water exclusively to the safety related equipment during an accident event. This is demonstrated by use of an actual or simulated initiation signal. This SR also verifies the automatic start capability of the ESW pump in each subsystem. The SR excludes automatic valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to valves that are locked, sealed, or otherwise secured in the actuated position since the affected valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve to the non-actuated position requires verification that the SR has been met within its required Frequency. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.5.1.6 overlaps this SR to provide complete testing of the safety function.

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

REFERENCES

1.

Regulatory Guide 1.27, Revision 2, January 1976.

2.

USAR, Section 9.2.1.

3.

USAR, Table 9.2-7.

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ESW System-Div. 3 B 3.7.2 PERRY - UNIT 1 B 3.7-9 Revision No. 11 BASES SURVEILLANCE SR 3.7.2.1 (continued)

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

SR 3.7.2.2 This SR verifies that the automatic isolation valve of the Division 3 ESW subsystem will automatically realign to the safety or emergency position to provide cooling water exclusively to the safety related equipment during an accident event. This is demonstrated by use of an actual or simulated initiation signal. This SR also verifies the automatic start capability of the Division 3 ESW pump. The SR excludes automatic valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to valves that are locked, sealed, or otherwise secured in the actuated position since the affected valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve to the non-actuated position requires verification that the SR has been met within its required Frequency. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.5.1.6 overlaps this SR to provide complete testing of the safety function.

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

REFERENCES

1.

USAR, Section 9.2.1.

2.

USAR, Chapter 6.

3.

USAR, Chapter 15.

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CRER System B 3.7.3 PERRY - UNIT 1 B 3.7-15 Revision No. 11 BASES SURVEILLANCE SR 3.7.3.3 REQUIREMENTS (continued)

This SR verifies that each CRER subsystem starts and operates on an actual or simulated initiation signal, and the isolation dampers that establish a portion of the CRE boundary close within 10 seconds. The SR excludes automatic dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to dampers or valves that are locked, sealed, or otherwise secured in the actuated position since the affected dampers or valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve or damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve or damper to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve or damper to the non-actuated position requires verification that the SR has been met within its required Frequency. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.5 overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.3.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 7), which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 10). These compensatory measures may be used as mitigating actions as required by Required Action B.2.

Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions (Ref. 11). Depending upon the nature of the problem and the corrective action, a full scope Information Only

CRER System B 3.7.3 PERRY - UNIT 1 B 3.7-15 Revision No. 11 inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

(continued)

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