ML053130264

Revised Pages for License Amendment Request

ML053130264
Person / Time
Site:	Palo Verde
Issue date:	11/01/2005
From:	Mauldin D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-05371-CDM/TNW/RAB
Download: ML053130264 (16)

Text

LAPS David Mauldin 10 CFR 50.90 Vice President Mail Station 7605 Palo Verde Nuclear Nuclear Engineering Tel: 623-393-5553 PO Box 52034 Generating Station and Support Fax: 623-393-6077 Phoenix, Arizona 85072-2034 102-05371 -CDM/TNW/RAB November 1, 2005 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

Letter 102-05351-CDMTNW/RAB, dated September 29, 2005, from C. D.

Mauldin, APS, to U. S. Nuclear Regulatory Commission, uRequest to Supercede a License a License Amendment Request Associated With Steam Generator Replacement and Power Uprate"

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3, Docket Nos. STN 50-52815291530 Revised Pages for License Amendment Request As a result of questions and discussions with the NRC staff concerning the amendment requested in the referenced letter, Arizona Public Service Company (APS) is providing revised pages to Attachment 3, "Changes to TS Bases." The replacement pages are provided in Enclosure 2 to this letter.

The changes are editorial and do not impact the original No Significant Hazards Consideration, or the reviews of the Plant Review Board and the Offsite Safety Review Committee.

No commitments are being made to the NRC in this letter.

Should you have any questions, please call Mr. Thomas N.Weber at (623) 393-5764.

Sincerely CDM/TNW/RAB/ca

Enclosures:

Notarized Affidavit 1.

2. Replacement Pages to Letter 102-05351, Attachment 3 Aozal A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• South Texas Project

• Wolf Creek

ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Revised Pages for Licens6 Amendment Request Page 2 cc: B.S. Mallett NRC Region IV Regional Administrator M. B. Fields NRC NRR Project Manager G. G.Warnick NRC Senior Resident Inspector A. V. Godwin Arizona Radiation Regulatory Agency (ARRA)

STATE OF ARIZONA

) ss.

COUNTY OF MARICOPA 1, David Mauldin, represent that I am Vice President Nuclear Engineering and Support, Arizona Public Service Company (APS), that the foregoing document has been signed by me on behalf of APS with full authority to do so, and that to the best of my knowledge and belief, the statements made therein are true and correct.

David Maudin Sworn To Before Me This jf Day 0 f O2)&Xa*IL , 2005.

Notary Notary Commission Stamp

Revised Pages to APS Letter 102-05351, Attachment 3 RPS Instrumentation - Operating B 3.3.1 BASES BACKGROUND Bistable Trip Units (Before CPC Upgrade) (continued)

Some measurement channels provide contact outputs to the PPS. In these cases, there is no bistable card. and opening the contact input directly de-energizes the associated bistable relays. These include the CPC generated DNBR - Low and LPD - High trips. The CPC auxiliary trip functions (e.g.. CPC VOPT algorithm) do not have any direct contact outputs to the PPS. The auxiliary trip functions act through the DNBR - Low and LPD - High trip contacts to de-energize the associated CPC initiation relays that provide a channel trip signal to the PPS parameters 3 and 4 bistable relays. Other CPC trip functions may also apply a penalty factor to cause a DNBR or LPD trip.

The trip setpoints used in the bistables are based on analytical limits derived from safety analyses (Ref. 5 and 8). The selection of these trip setpints is such that adequate protection is provided when all sensor and processing time delays are taken into account. To allow for calibration tolerances. instrumentation uncertainties, instrument drift, and severe environment errors for those RPS channels that must function in harsh environments as defined by 10 CFR 50.49 (Ref. 6). Allowable Values specified in Table 3.3.1-1. in the accompanying LCO. are conservatively adjusted with respect to the analytical limits. A detailed description of the methodology used to calculate the trip setpoints. including their explicit uncertainties. is provided in "Calculation of Trip Setpoint Values" (Ref. 7). The UFSAR Trip Setpoints are based on the calculated total loop uncertainty consistent with the methiodology as documented in the UFSAR (RG 1.105.-Re-vis'io'n

1. November 1976) (Ref. 14). The general relationship among the PVNGS trip setpoint terms is as follows: TIhe calculated Limiting Setpoint (LSp) is determined within the plant specific setpoint analysis and is based on the Analytical Limit and the lotal Loop Uncertainty. The UlSAR Irip Setpoint is egual to or more conservative than the LSP and is specified in the UFSAR. The sign Setpoint (DSP) is the field installed setting and is equal to or more conservative than the UFSAR Trip Setpoint. lhis relationship ensures that sufficient margin to the safety limit ismaintained.

FLA M _thlv--t.. Ensv . _9i nor-mallystill more conscrvative than that specified by the tI A on oet ha romn rrors dectanb *_by a V}11NE UNL . e of such a change in measurement error is drift during the (continued)

PALO VERDE UNITS 1.2.3 B 3.3.1-11 REVISION 27

RPS Instrumentation - Operating B 3.3.1 interval between surveillances. A channel is inoperable if its actual setpoint is net withinnon-conservative with respect to its Allowable Value.

To maintain the margins of safety assumed in the safety analyses, the calculations of the trip variables for the DNBR - Low and Local Power Density - High trips include the measurement, calculational. and processor uncertainties and dynamic allowances as defined in the latest applicable I revision of CEN-305-P. "Functional Design Requirements for a Core Protection Calculator" (Ref. 10) and CEN-304-P." Functional Design Requirements for a Control Element Assembly Calculator." (Ref. 11). The safety (continued)

PALO VERDE UNITS.1.2.3 B 3.3.1-12 REVISION 27

RPS Instrumentation - Operating B 3.3.1 BASES BACKGROUND Bistable Trip Units (After CPC Upgrade) (continued)

Some measurement channels provide contact outputs to the PPS. In these cases, there is no bistable card, and opening the contact input directly de-energizes the associated bistable relays. 'These include the CPC generated DNBR - Low and LPD - High trips. The CPC auxiliary trip functions (e.g.. CPC VOPT algorithm) do not have any direct contact outputs to the PPS. The auxiliary trip functions act through the DNBR - Low and LPD - High trip contacts to de-energize the associated CPC initiation relays that provide a channel trip signal to the PPS parameters 3 and 4 bistable relays. Other CPC trip functions may also apply a penalty factor to cause a DNBR or LPD trip.

The trip setpoints used in the bistables are based on the analytical limits derived from the accident analysis (Ref. 5). The selection of these trip setpoints is such that adequate protection is provided when all sensor and processing time delays are taken into account. To allow for calibration tolerances, instrumentation uncertainties.

instrument drift, and severe environment errors for those RPS channels that must function in harsh environments as defined by 10 CFR 50.49 (Ref. 6). -Allowable Values I specified in Table 3.3.1-1. in the accompanying LCO are conservatively adjusted with respect to the analytical limits. A detailed description of the methodology used to calculate the trip setpoints. including their explicit I uncertainties, is provided in 'Calculation of Trip Setpoint Values' (Ref. 7). The UFSAR Trip Setpoints are based on the calculated total loop uncertainty consistent with the methodology as documented in the UFSAR (RG I.105. Revision

1. November 1976) MRef. 14). The general relationship among the PVNGS trip setpoint terms is as follows: ine calculated Limiting Setpoint (LSp) is determined within the plant specific setpoint analysis and is based on the Analytical Limit and the Total loop Uncertainty. The UFSAR Trip Setpoint is equal to or more conservative than the LSp and is specified in the UFSAR. Mhe Design Setpoint (DSp) is the field installed setting and is equal to or more conservative than the UFSAR Trip Setpoint. Ihis relationship ensures that sufficient margin to the safet limit ismaintained.

Ihno inatr se p 4nt entceF- int .tebistahIJ154o nor~mally-s-t>I more rcaons rai thanthat Gpccificd by thc Allowable Vac luto account fopr hanges in ra;ndom measurcment errorps dctctablec by a CHANELFUCTIOMNAL TEST One exampl e of uch a chnge in m ucrcment error is drift during the (continued)

PALO VERDE UNITS 1.2.3 B 3.3.1-15 REVISION 27

RPS Instrumentation - Operating B 3.3.1 lntervyal between surveillancce. A channel is inoperable if its actual setpoint is net withinnon-conservative with respect to its Allowable Value.

To maintain the margins of safety assumed in the safety analyses, the calculations of the trip variables for the DNBR - Low and Local Power Density - High.trips include the measurement. calculational. and processor uncertainties and dynamic allowances as defined in the latest applicable revision of CEN-305-P. "Functional Design Requirements for a I Core Protection Calculator" (Ref. 10) and CEN-304-P.

'Functional Design Requirements for a Control Element I Assembly Calculator," (Ref. 11). The safety analyses (continued)

PALO VERDE UNITS 1.2,3 B 3.3.1-16 REVISION 27

RPS Instrumentation - Operating B 3.3.1 BASES LCO The LCO requires all instrumentation performing an RPS Function to be OPERABLE. Failure of any required portion of the instrument channel renders the affected channelCs) inoperable and reduces the reliability of the affected Functions.

Actions allow maintenance (trip channel) bypass of individual channels. but the bypass activates interlocks that prevent operation with a second channel in the same Function bypassed. With one channel in each Function trip channel bypassed, this effectively places the plant in a two-out-of-three logic configuration in those Functions.

The general relationship among the PVNGS trip setpoint Terms is as follows: Ihe calculated limiting setpoint (L-5p) is determined within the plant sp2cjfic setpoint analysis-and is based on the Analytical Limit and the Total Loop Uncertainty. The UFSAR Trip Setpoint is equal to or more conservative than the LSb and is specified in the UFSAR (Ref. 8). Te Design Setpoint-(Dp) is the field installed setting and isequal to or more conservative than the UhSA TIrip Setpoint. ihis relationsi will ensure that sufficient margin to the satety and/or analytical limit is maintained.

Only the Allowable Values (AVs) are specified for each RPS trip Function in the LCO. ThieAV is considered an operability limit for the channel. Nominal trip setpoints are specified in the plant specific setpoint calculations.

The nominal setpoints are selected to ensure the setpoints measured by CHANNEL FUNCTIONAL TESTS do not exceed the Allowable Value if the bistable is performing as required.

Operation with a trip setpoint less conservative than the nominal trip setpoint. but within its Allowable Value. is acceptable, provided that operation and testing are consistent with the assumptions of the plant specific setpoint calculations. If the as-found instrument setting is found to be non-conservative with respect to the AV. or the as-left instrument setting cannot be returned to a setting within As-Left lolerance (ALI). or the instrument is not functioning as reqiuired: then the instrument cha~n~neT shall be declared inoperable. A channel isinoperable if

-its actual trip setpoint is -notwithin its required Allowable Value. Each Allowable Value specified is more conservative than the analytical limit assumed in the safety analysis in order to account for instrument uncertainties (continued)

PALO VERDE UNITS 1,2.3 B 3.3.1-30 REVISION 25

RPS Instrumentation - Operating B 3.3.1 BASES LCO 5. Containment Pressure - High (continued)

The LCO requires four channels of Containment Pressure - High to be OPERABLE in MODES I and 2.

The Allowable Value is set high enough to allow for small pressure increases in containment expected during normal operation (i.e.. plant heatup) and is not indicative of an abnormal condition. It is set low enough to initiate a reactor trip when an abnormal condition is indicated.

6, 7. Steam Generator Pressure - Low This LCO requires four channels of Steam Generator #1 Pressure - Low and Steam Generator #2 Pressure - Low to be OPERABLE in MODES 1 and 2.

This Allowablc VaueUFSAR Trip Setpoint is sufficiently below tie full load operating value for steam pressure so as not to interfere with normal plant operation, but still high enough to provide the required protection in the event of excessive steam demand. Since excessive steam demand causes the RCS to cool down. resulting in positive reactivity addition to the core. If the moderator temperature coefficient is negative a reactor trip is required to offset that effect.

The trip setpoint may be manually decreased as steam generator pressure is reduced during controlled plant cooldown, provided the margin between steam generator pressure and the setpoint is maintained

• 200 psia.

This allows for controlled depressurization of the secondary system while still maintaining an active reactor trip setpoint and MSIS setpoint. until the time is reached when the setpoints are no longer needed to protect the plant. The setpoint increases automatically as steam generator pressure increases until the specified trip setpoint is reached.

Footnote (aa). which is divided into two parts. will ensure compliance with 10 CFR 50.3b in the event that the instrument set points are found not-to be conservative with respect to the as-found acceptance criteria. Part 1 requires evaluation of instrument performance for the condition where the as-found setting for these instruments is outside its As-Found (continued)

PALO VERDE UNITS 1.2.3 B 3.3.1-34 REVISION 25

RPS Instrumentation - Operating B 3.3.1 Allowable Value. Evaluation of instrument performance will verify that the instrument will continue to behave in accordance with desisn-basis assumptions.

Ihe purpose of the assessment is to ensure confidence in the instrument performance prior to returning the instrument to service. Initial evaluation will be performed by the technician performing the surveillance who will evaluate the instrument's ability to maintain a stable trip setpoint within the As-Left Tolerance (ALI). The technician s evaluation will be reviewed by on shift personnel both during the approval ot the surveillance data and as a result o0 entry ot the deviation in the site's corrective action program. In accordance with procedures, entry into the corrective action program will require review and documentation o0 the condition Tor operability.

Additional evaluation and potential corrective actions as necessary will ensure that any as-tound setting Tound outside the AFT is evaluatedfTor long-term operability trends.

Part 2 requires that the as-left setting for the instrument be returned to within the ALI of the specified trip setpoint. The specified field installed trip setpoint is termed as the Design etmt (Sp) and is equal to or more conservative than the UlSAR rip Setpoint. The general relationship among the VNGS trip setpoint terms is as follows: The calculated limiting setpoint (LSP) is determined within the plant specific setpoint analysis and is based on the Analytical Limit and lotal Loop Uncertainty. Ihe UFSAR Trip Setpoint is equal to or more conservative than the LSp and is specified in the UFSAR. The DSp is the field installed setting and is equal to or more conservative than the UFSAR Trip Setpoint. This relationship ensures that sufficient margin to the safety and/or analytical limit is maintained. If the as-found instrument setting* is found to be non-conservative with respect to the AV specified in the technical specifications, or the as-lett instrument setting cannot be returned to a setting within the ALT, or the instrument is not functioning as required: then the instrument channel shall be declared inoperable.

8. 9. Steam Generator Level - Low This LCO requires four channels of Steam Generator #1 Level - Low and Steam Generator #2 Level - Low for each (continued)

PALO VERDE UNITS 1,2.3 B 3.3.1-35 REVISION 25

RPS Instrumentation - Shutdown B 3.3.2 BASES LCO that removes power from the CEDMs may be used. The CEAs are (continued) still capable of withdrawal if the CEDMCS withdrawal circuits are disabled with power applied to the CEDMs because failures in the CEDMCS could result in CEA withdrawal.

This LCO requires all four channels of Steam Generator #1 Pressure-Low, and Steam Generator #2 Pressure-Low, to be OPERABLE in MODE 3. when the RTCBs are closed and the CEA Drive System is capable of CEA withdrawal. These RPS functions are not required in MODES 4 and 5 because the Steam Generator temperature is low, therefore the energy release and resulting cooldown following a large MSLB in MODES 4 and 5 is not significant.

Footnote (e). which is divided into two parts. will ensure compliance with 10 CFR 50.36 in the event that the instrument set points are found not to be conservative with respect to the as-found acceptance criteria. Part 1 requires evalEuation of instrument performance for the condition where the as-found setting Tor these instruments is outside its As-Found Tolerance (AFT) but conservative with respect to the Allowable Value. Evaluation of instrument performance will verity that the instrument will continue to behave in accordance with design-basis assumptions. The purpose of the assessment is to ensure contidence in the instrument performance prior to retuning the instrument to service. initial evaluation will be performed by the technician performi ng the surveillance who will evaluate the instrument s ability to maintain a stable trip setpoint within the As-Left lolerance (ALI). fhe technician's evaluation will be reviewed by on shift personnel both during the approval of the surveillance data and as a result of entry of the deviation in the site s corrective action program. in accordance with procedures.

entry into the corrective action program will require review and documentation of the condition for operability.

Additional evaluation and potential corrective actions as necessary will ensure that any as-found setting found outside the AFT is evaluated for long-term operability trends.

Part 2 requires that the as-left setting for the instrument be returned to within the ALl of the specified trip setpoint. Ihe specified field installed trip setpoint is termed as the Design Setpoint (DSp) and is equal to or more conservative than the UFSAR Irip Setpoint. The general relationship among the PVNGS trip setpoint terms is as Tfolows: The calculated limiting setpoint (LSP) is determined within the plant specific setpoint analysis and (continued)

..- EIIN1 UNITS 1~~~.2 VERDE PALO PALO VERDE UNITS 1.2.3 B 3.3.2-6 REVISION 15

-

RPS Instrumentation - Shutdown B 3.3.2 BASES is based on the Analytical Limit and Total Loop Uncertainty. The UFSAR Irip Setpoint is equal to or more conservative than the LSp and is specified in the UISTAR.

The DSp is the field installed setting and is equal to or more conservative than the UFSAR Trip Setpoint. Ihis relationship ensures that sufficient margin to the safety and/or analytical limit ismaintained. Itthe as-found instrument setting is found to be non-conservative with respect to the AV specified in the technical specifications, or the as-left instrument setting cannot be returned to a setting within the ALT. or the instrument is not functioning as required: then the instrument channel shall be declared inoperable.

The Allowable Values are high enough to provide an operating envelope that prevents unnecessary Logarithmic Power Level - High reactor trips during normal plant operations.

The Allowable Values are low enough for the system to maintain a safety margin for unacceptable fuel cladding damage should a CEA withdrawal or MSLB event occur.

The Logarithmic Power Level - High trip may be bypassed when logarithmic power is above 1E-4% NRTP to allow the reactor to be brought to power during a reactor startup. This bypass is automatically removed when logarithmic power decreases below 1E-4% NRTP. Above 1E-4% NRTP. the Variable Over Power - High and Pressurizer Pressure - High trips provide protection for reactivity transients.

The automatic bypass removal channel is INOPERABLE when the associated Log power channel has failed. The bypass function is manually controlled via station operating procedures and the bypass removal circuitry itself is fully capable of responding to a change in the associated input bistable.

Footnotes (a) and (b) in Table 3.3.1-1 and (d) in Table 3.3.2-1 clearly require an "automatic" removal of trip bypasses. A failed Log channel may prevent, depending on the failure mode. the associated input bistable from changing state as power transitions through the automatic bypass removal setpoint. Specifically, when the indicated Log power channel is failed high (above 1E-4%), the automatic Hi-Log power trip bypass removal feature in that channel cannot function. Similarly, when the indicated Log power channel is failed low (below 1E-4%). the automatic DNBR-LPD trip bypass removal feature in that channel cannot function. Although one bypass removal feature is applicable above 1E-4% NRTP and the other is applicable below 1E-4% NRTP. both are affected by a failed Log power channel and should therefore be considered INOPERABLE.

(continued)

PALO VERDE UNITS 1.2.3 B 3.3.2-6 REVISION 15

ESFAS Instrumentation B 3.3.5 BASES BACKGROUND Bistable Trip Units (continued)

The trip setpoints and Allowable Values used in the bistables are based on the analytical limits stated in Reference 5. The selection of these trip setpoints is such that adequate protection is provided when all sensor and processing time delays are taken into account. To allow for calibration tolerances. instrumentation uncertainties.

instrument drift, and severe environment effects, for those ESFAS channels that must function in harsh environments as defined by 10 CFR 50.49 (Ref. 6). Allowable Values specified in Table 3.3.5-1. in the accompanying LCO. are conservatively adjusted with respect to the analytical limits. The UFSAR Trip Setpoints are based on the calculated total loop uncertainty consistent with the methodology as documented in the U-SAR (RG 1.105. Revision

1. November 1976) (Ret. 11). The general relationship among the PVNGS trip setpoint terms is as follows: The calculated Limiting Setpoint (LSp) is determined within the plant specific setpoint analysis and is based on the Analytical Limit and the lotal Loop Uncertainty. Ihe UFSAR Irip Setpoint is equal to or more conservative than the LSp and is specified in the VFSAR. The Design Setpoint (Dsp) is the field installed setting and is equal to or more conservative than the UFSAR Irip Setpoint. rhis relationship ensures that sufficient margin to the safety limit is maintained. A detailed description of the methodology used to calculate the trip setpoints. including their explicit uncertainties.

is provided in the "Plant Protection System Selection of Trip Setpoint Values" (Ref. 7). Thc actual nominal trip

-ctpoint cntered into the bistablc is normally still more conservative than that specified by the Allowable Value to.

account for-changec in ranolm mea ercmcnt errors detec-rtabhle by a CHANNEL FUNCTIONAL TEST. A channel is inoperable if its actual trip setpoint is not withinnon-conservative with respect to its required Allowable Value.

Setpoints in accordance with the Allowable Value will ensure that Safety Limits of LCO Section 2.0. "Safety Limits," are not violated during AQOs and the consequences of Design Basis Accidents (DBAs) will be acceptable, providing the plant is operated from within the LCOs at the onset of the AOO or DBA and the equipment functions as designed.

Functional testing of the ESFAS. from the bistable input through the opening of initiation relay contacts in the ESFAS Actuation Logic, can be performed either at power or (continued)

PALO VERDE UNITS 1.2.3 B 3.3.5-4 REVISION 0

ESFAS Instrumentation B 3.3.5 BASES LCO a. Steam Generator Pressure - Low (continued)

The Steam Generator Pressure - Low trip setpoint may be manually decreased as steam generator pressure is reduced. This prevents an RPS trip or MSIS actuation during controlled plant cooldown. The margin between actual steam generator pressure and the trip setpoint must be maintained less than or equal to the specified value of 200 psia to ensure a reactor trip and MSIS will occur when required.

Footnote (d). which is divided into two parts.

will ensure compliance with 10 C-H 5036b in the event that the instrument set points are tound not to be conservative with respect to the as-found acceptance criteria. Part 1 requires evaluation of instrument performance for the condition where the as-found settinQ for these instruments is outside its As4ound Tolerance (AFT) but conservative with respect to the Allowable Value.

Evaluation of instrument performance will verify that the instrument will continue to behave in accordance with design-basis assumptions. The purpose of the assessment isto ensure confidence inthe instrument performance prior to returning the instrument to service. Initial evaluation will be performed by the technician performing the surveillance who will evaluate the instrument s ability to maintain a stable trip setpoint within the As-Left Tolerance (ALT). The technician's evaluation will be reviewed by on shift personnel both during the approval of the surveillance data and as a result of entry of the deviation in the site s corrective action program. Inaccordance with procedures. entry into the corrective action program will require review and documentation of the condition for operability. Additional evaluation and potential corrective actions as necessary will ensure that any as-found setting found outside the AFT isevaluated for long-term operability trends.

Part 2 requires that the as-left setting for the instrument be returned to within the ALI of the specified trip setpoint. The specified field installed trip setpoint is termed as the Design (continued)

PALO VERDE UNITS 1.2.3 B 3.3.5-16 REVISION 0

ESFAS Instrumentation B 3.3.5 BASES Setpoint (DSD) and is equal to or more conservative than the U-SAK ip Setpoint. The general relationship among the PVNGS trip setpoint terms is as follows: ihe calculated limiting setpoint (LSP) is determined within the plant specific setpoint analysis and is based on the Analytical Limit and iotal Loop Uncertainty. The UFSAR Trip Setpoint is equal to or more conservative than the LSp and is specified in the UFSAR. The DSp is the field installed setting and is equal to or more conservative than the UFSAR IriD Setpoint. This relationship ensures that sufficient margin to the safety and/or analytical limit ismaintained. ITthe as-found instrument setting isfound to be non-conservative with respect to the AV specified inthe technical specitications, or the as-lett instrument setting cannot be returned to a setting within the ALI, or the instrument is not functioning as required:

then the instrument channel shall be declared inoperable.

b. Containment Pressure - High This LCO requires four channels of Containment Pressure - High to be OPERABLE in MODES 1. 2 and

3. The Containment Pressure - High signal is shared among the SIAS (Function 1), CIAS (Function 3). and MSIS (Function 4).

The Allowable Value for this trip isset high enough to allow for small pressure.increases in containment expected during normal operation (i.e.. plant heatup) and is not indicative of an abnormal condition. The setting is low enough to initiate the ESF Functions when an abnormal condition is indicated. This allows the ESF systems to perform as expected inthe accident analyses to mitigate the consequences of the analyzed accidents.

c. Steam Generator Level-High (continued)

PALO VERDE UNITS 1.2.3 B 3.3.5-16 REVISION 0