ML031820586

Transmittal of Indian Point 3 Technical Specification Bases

ML031820586
Person / Time
Site:	Indian Point
Issue date:	06/18/2003
From:	Entergy Nuclear Indian Point 3
To:	Milano P Document Control Desk, Office of Nuclear Reactor Regulation
References
28271 IP-SMM-AD-103, Rev 0
Download: ML031820586 (58)

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t IPEC SITE QUALITY RELATED IP-SMM-AD-103 Revision 0 Ein tergMANAGMENT ADMINISTRATIVE PROCEDURE INFORMATIONAL USE Page 13 of 21 JATTACHMENT 10.1 SMM CONTROLLED DOCUMENT TRANSMITTAL FORM SITE MANAGEMENT MANUAL CONTROLLED DOCUMENT TRANSMITTAL FORM - PROCEDURES Pane 1 of i C Entem CONTROLLED DOCUMENT TRANSMITTAL FORM - PROCEDURES TO: DISTRIBUTION DATE: 6118/03 TRANSMITTAL NO: 28271 (Cirle oe)

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INDIAN POINT 3 TECHNICAL SPECIFICATION BASES INSTRUCTIONS FOR UPDATE:

09-06120103 REMOVE INSERT a) List of Effective Sections; 3 pages (Rev 7) b) Section B 3.4.9; Rev 1 5 pages a) List of Effective Sections; 3 pages (Rev 9) b) Section B 3.4.9; Rev 2 5 pages c) Section B 5 pages 3.6.5; Rev 0 c) Section B 3.6.5; Rev 1 5 pages d) Section B 9 pages e) Section B 7 pages 3.7.11; Rev 1 3.7.13; Rev 1 d) Section B 9 pages e) Section B 7 pages 3.7.11; Rev2 3.7.13; Rev 2 f) Section B 3.8.7; Rev 0 8 pages g) Section B 3.8.8; Rev 0 4 pages h) Section B 3.8.9; Rev 1 14 pages f) Section B 3.8.7; Rev I 8 pages g) Section B 3.8.8; Rev 1 4 pages h) Section B 3.8.9; Rev 2 14 pages

17-JUN-03 Page:

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.e;518 DOCUMENT CONTROL DESK NRC (ALL EP'S)

OFFSITE 527 MILIANO PATRICK NRC/SR. PROJECT MANAGER OFFSITE 528 PETACHI CHRISTA WC/ONE STOP SHOP IP2 529 DECLEMENTE VINNIE OPS/(TYPE A DWG LG/ONLY) IP3/2ND FL

TECHNICAL SPECIFICATION BASES LIST OF EFFECTIVE SECTIONS BASES NIUMBER EFFECTIVE SECTION REV OF PAGES DATE TbI of Cn 1

4 05/18/2001 B 2.0 SAFETY LIMITS B 2.1.1 0

5 j 03/1912001 B 2.1.2 0

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_4 03/19/2001 B 3.0 LCO AND SR APPLICABILITY B 3.0 l

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15 l 09/30/2002 B 3.1 REACTIVITY CONTROL' B 3.1.1 0

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7 03/19/2001 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.1 0

7 03/19/2001 B 3.2.2 0

7 03/19/2001 B 3.2.3 0

9 03/19/2001 B 3.2.4 0

7 03/19/2001 B 3.3 INSTRUMENTATION B 3.3.1 1

59 09/30/2002 B 3.3.2 3

45 12/04/2002 B 3.3.3 2

19 09/30/2002 B 3.3.4 0

7 03/19/2001 B 3.3.5 0

6 03/19/2001 B 3.3.6 0

10 031l9/2001 B 3.3.7 0

6 03/19/2001 B 3.3.8 1

4 03/1712003 B 3.4 REACTOR COOLANT SYSTEM B 3.4.1 0

6 03/19/2001 B 3.4.2 0

3 03/19/2001 B 3.4.3 0

9 03/19/2001 B 3.4.4 0

4 03/19/2001 B 3.4.5 0

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20 03/19/2001 B 3.4.13 2

6 11/19/2001 B 3.4.14 0

10 03/19/2001 B 3.4.15 2

7 11/19/2001 B 3.4.16 0

7 03/19/2001 B 3.5 ECCS B 3.5.1 0

10 03119/2001 B 3.5.2 0

13 03/19/2001 B 3.5.3 0

4 03/19/2001 BASES l R NUMBER I EFFECTIVE SECTIONj REV jOF PAGES D ATE B 3.6 CONTAINMENT, B 3.6.1 0

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13 12/042002 B 3.6.7 0

6 03/19/2001 B 3.6.8 0

6 03/19/2001 B 3.6.9 0

8 03/1912001 B 3.6.10 0

12 03119/2001 B 3.7 PLANT SYSTEMS B 3.7.1 1

6 12/04/2002 B 3.7.2 0

10 03/19/2001 B 3.7.3 1

7 05/18/200 B 3.7.4 0

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4 03/19/2001 B 3.7.8 0

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4 03/19/2001 B 3.8 ELECTRICAL POWER B 3.8.1 1

32 01/22/2002 B 3.8.2 0

7 03/19/2001 B 3.8.3 0

13 03/19/2001 B 3.8.4 1

11 01/22/2002 B 3.8.5 0

4 03/19/2001 B 3.8.6 0

8 03/19/2001 B 3.8.7 1

8 06/20/2003 B 3.8.8 1

4 06/20/2003 B 3.8.9 2

14 06120/2003 B 3.8.10 0

4 03119/2001 B 3.9 REFUELING-OPERATIONS B 3.9.1 0

4 03/19/2001 B 3.9.2 0

4 03/19/2001 B 3.9.3 1

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9 03/19J2001 INDIAN POINT 3 Page I of 3 Revision 09

I II TECHNICAL SPECIFICATION BASES TECHNICAL SPECIFICATION BASES REVISION HISTORY REVISION HISTORY FOR BASES AFFECTED EFFECTIVE SECTIONS REV DATE DESCRIPTION Initial issue of Bases derived from NUREG-1431, in ALL 0

03/19/01 conjunction with Technical Specification Amendment 205 for conversion of 'Current Technical Specifications' to

'Improved Technical Specifications'.

BASES UPDATE PACKAGE 01-031901 Changes regarding containment sump flow monitor per B 3.4.13 1

03/19/01 NSE 01-3-018 LWD Rev 0.

B 3.4.15 1

l Change issued concurrent with Rev 0.

BASES UPDATE PACKAGE 02-051801 Table of Contents 1

05/18/01 Title of Section B 3.7.3 revised per Tech Spec Amend 207 B 3.7.3 1

05/18/01 Implementation of Tech Spec Amend 207 BASES UPDATE PACKAGE 03-111901 Correction to statement regarding applicability of Function B 3.3.2 1

11/19/01 5, to be consistent with the Technical Specification.

Changes to reflect reclassification of certain SG narrow B 3.3.3 1

11/19/01 range level instruments as QA Category M per NSE 97 439, Rev 1.

Changes to reflect installation of a new control room alarm B 3.4.13 2

11/19/01 for VC Sump Pump Running'. Changes per NSE 01 B 3.4.15 018, Rev 1 and DCP 01-3-023 LWD.

Clarification of allowable flowrate for CRVS in 'incident B 3.7.11 1

11/19/01 mode with outside air makeup.'

BASES UPDATE PACKAGE 04-012202 B 3.3.2 2

01/22/02 Clarify starting logic of 32 ABFP per EVL-01-3-078 MULTI, Rev 0.

B 3.8.1 1

01/22/02 Provide additional guidance for SR 3.8.1.1 and Condition Statements A.1 and B.1 per EVL-01-3-078 MULTI, Rev 0.

B 3.8.4 1

01/22/02 Revision of battery design description per plant modification and to reflect Tech Spec Amendment 209.

B 3.8.9 1

01/22/02 Provide additional information regarding MCC in Table B 3.8.9-1 per EVL-01-3-078 MULTI, Rev 0.

a; BASES:UPDATE PACKAGE 05-093002-,V B 3.0 1

09/30/02 Changes to reflect Tech Spec Amendment 212 regarding delay period for a missed surveillance. Changes adopt TSTF 358, Rev S.

B 3.3.1 1

09/30/02 Changes regarding description of turbine runback feature per EVAL-99-3-063 NIS.

B 3.3.3 2

09/30/02 Changes to reflect Tech Spec Amendment 211 regarding CETs and other PAM instruments.

B 3.7.9 1

09/30/02 Changes regarding SWN 1 and -2 valves per EVAL-00-3-095 SWS, Rev 0.

INDIAN POINT 3 Page 2 of 3 Revision 09

TECHNICAL SPECIFICATION BASES REVISION HISTORY AFFECTED EFFECTIVE I SECTIONS I REV I DATE I

DESCRIPTION

-BASES UPDATE PACKAGE 06-120402 B 3.3.2 3

12/04/02 Changes to reflect Tech Spec Amendment 213 regarding B 3.6.6 1

1.4% power uprate.

B 3.7.1 1

B 3.7.6 1

BASES UPDATE PACKAGE 07-031703 B 3.3.8 1

03/17/2003 Changes to reflect Tech Spec Amendment 215 regarding B 3.7.13 1

implementation of Alternate Source Term analysis B 3.9.3 1

methodology to the Fuel Handling Accident

___-__X__X__-_

BASES UPDATE PACKAGE 08-032803; B 3.4.9 1

03/28/2003 Changes to reflect Tech Spec Amendment 216 regarding relaxation of pressurizer level limits in MODE 3.

BASES UPDATE PACKAGE 09-062003 B 3.4.9 2

06/20/2003 Changes to reflect commitment for a dedicated operator per Tech Spec Amendment 216.

B 3.6.5 1

06/20/2003 Implements Corrective Action 11 from CR-IP3-2002-02095; 4 FCUs should be in operation to assure representative measurement of containment air temperature.

B 3.7.11 2

06/20/2003 Correction to Background description regarding system response to Firestat detector actuation per ACT 02-62887.

B 3.7.13 2

06/20/2003 Revision to Background description of FSB air tempering

_units to reflect design change per DCP 95-3-142.

B 3.8.7 1

06/20/2003 Changes to reflect replacement of Inverter 34 per DCP-B 3.8.8 1

06/2012003 01-022.

B 3.8.9 2

06/20/2003 I r

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INDIAN POINT 3 Page 3 of 3 Revision 09

' i Pressurizer B 3.4.9 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.9 Pressurizer BASES BACKGROUND The pressurizer provides a point in the RCS where liquid and vapor are maintained in equilibrium under saturated conditions for pressure control purposes to prevent bulk boiling in the remainder of the RCS. Key functions include maintaining required primary system pressure during steady state operation, and limiting the pressure changes caused by reactor coolant thermal expansion and contraction during normal load transients.

The pressure control components addressed by this LCO include the pressurizer water level, the required heaters, and emergency power supplies. Pressurizer safety valves and pressurizer power operated relief valves are addressed by LCO 3.4.10, "Pressurizer Safety Valves," and LCO 3.4.11, "Pressurizer Power Operated Relief Valves (PORVs)," respectively.

The intent of the LCO is to ensure that a steam bubble exists in the pressurizer prior to power operation to minimize the consequences of potential overpressure transients.

The presence of a steam bubble is consistent with analytical assumptions. Relatively small amounts of noncondensible gases can inhibit the condensation heat transfer between the pressurizer spray and the steam, and diminish the spray effectiveness for pressure control.

Electrical immersion heaters, located in the lower section of the pressurizer vessel, keep the water in the pressurizer at saturation temperature and maintain a constant operating pressure. A minimum required available capacity of pressurizer heaters ensures that the RCS pressure can be maintained.

The capability to maintain and control system pressure is important for maintaining subcooled conditions in the RCS and ensuring the capability to remove core decay heat by either forced or natural circulation of reactor coolant.

Unless adequate heater capacity is available, the hot, high pressure condition cannot be maintained indefinitely and still provide the required subcooling (continued)

INDIAN POINT 3 B 3.4.9 - 1 Revision 2

I l

lo Pressurizer B 3.4.9 BASES BACKGROUND margin in the primary system. Inability to control the system (continued) pressure and maintain subcooling under conditions of natural circulation flow in the primary system could lead to a loss of single phase natural circulation and decreased capability to remove core decay heat.

Pressurizer heaters are powered from either the offsite.source or the diesel generators (DGs) through the four 480V vital buses as follows: bus 2A (DG 31) supports 485 kW of pressurizer heaters; bus 3A (DG 31) supports 555 kW of pressurizer heaters; bus 5A (DG 33) supports 485 kW of pressurizer heaters; and, bus 6A (DG 32) supports 277 kW of pressurizer heaters.

APPLICABLE SAFETY ANALYSES In Modes 1. 2, and 3, the LCO requirement on pressurizer water level ensures that a steam bubble exists in the pressurizer. In addition, the safety analyses for loss of load and for loss of normal feedwater include an analytical limit of 58.3% as an initial condition assumption. The analyses assume the existence of a steam bubble and saturated conditions in the pressurizer. In making this assumption, the analyses neglect the small fraction of noncondensible gases normally present. The limiting scenario for these accident analyses is with the plant at full power.

Therefore, the LCO requirement specified for MODE I ensures that the pressurizer initial condition assumption remains valid. An additional margin on the analytical limit must be allowed for instrument error.

Safety analyses presented in the FSAR (Ref. 1) do not take credit for pressurizer heater operation; however, an implicit initial condition assumption of the safety analyses is that the RCS is operating at normal pressure.

The maximum pressurizer water level limit, which ensures that a steam bubble exists in the pressurizer, satisfies Criterion 2 of 10 CFR 50.36. Although the heaters are not specifically used in accident analysis, the need to maintain subcooling in the long term during loss of offsite power, as indicated in NUREG-0737 (Ref. 2),

is the reason for providing an LCO.

(continued)

INDIAN POINT 3 B 3.4.9 - 2 Revision 2

Pressurizer B 3.4.9 BASES LCO The LCO requirement for the pressurizer to be OPERABLE with water level less than or equal to 58.3% (for MODES 1 and 2) or less than or equal to 90% (for MODE 3) ensures that a steam bubble exists.

The required pressurizer level of < 58.3% is the analytical limit used as an initial condition in the accident analysis. An additional margin of approximately 7% must be allowed for instrument error (i.e., the indicated level should not exceed 51.3%, for MODES 1 and 2 or 83%, for MODE 3).

Whenever pressurizer water level in MODE 3 is above the MODE 1 and 2 limit, a dedicated operator is assigned for operating and controlling the chemical and volume control system, including monitoring pressurizer water level.

Limiting the LCO maximum operating water level preserves the steam space for pressure control. The LCO has been established to ensure the capability to establish and maintain pressure control for steady state operation and to minimize the consequences of potential overpressure transients. Requiring the presence of a steam bubble is also consistent with analytical assumptions.

The LCO requires two groups of OPERABLE pressurizer heaters, each with a capacity > 150 kW, capable of being powered from either the offsite power source or the emergency power supply. Each of the 2 groups of pressurizer heaters should be powered from a different DG to ensure that the minimum required capacity of 150 kW can be energized during a loss of offsite power condition assuming the failure of a single DG. The minimum heater capacity required is sufficient to maintain the RCS near normal operating pressure when accounting for heat losses through the pressurizer insulation. By maintaining the pressure near the operating conditions, a wide margin to subcooling can be obtained in the loops. The value of 150 kW is sufficient to maintain pressure and is dependent on the heat losses.

APPLICABILITY The need for pressure control is most pertinent when core heat can cause the greatest effect on RCS temperature, resulting in the greatest effect on pressurizer level and RCS pressure control.

-Thus, applicability has been designated for MODES 1 and 2. The applicability is also provided for MODE 3. The purpose is to prevent solid water RCS operation during heatup and cooldown to

-avoid rapid pressure rises caused by normal operational perturbation, such as reactor coolant pump startup.

When RCS temperature is below 411 F¶,

administrative controls in the (continued)

INDIAN POINT 3 B 3.4-.9 - 3 Revision 2

I

fl Pressurizer B 3.4.9 BASES APPLICABILITY Technical Requirements Manual (Ref. 3) are used to limit the (continued) potential for exceeding 10 CFR 50, Appendix G limits.

In MODES 1, 2, and 3, there is need to maintain the availability of pressurizer heaters, capable of being powered from an emergency power supply.

In the event of a loss of offsite power, the initial conditions of these MODES give the greatest.demand for maintaining the RCS in a hot pressurized condition with loop subcooling for an extended period. For MODE 4, 5, or 6, it is not necessary to control pressure (by heaters) to ensure loop subcooling for heat transfer when the Residual Heat Removal (RHR) System is in service, and therefore, the LCO is not applicable.

ACTIONS A.1 and A.2 Pressurizer water level control malfunctions or other plant evolutions may result in a pressurizer water level above the nominal upper limit, even with the plant at steady state conditions.

If the pressurizer water level is not within the limit, action must be taken to place the plant in a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to MODE 3, with the reactor trip breakers open, within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

This takes the unit out of the applicable MODES.

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.

B.1 If one required group of pressurizer heaters is inoperable, restoration is required within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is reasonable considering that the redundant heater group is still available and the low probability of an event during this period. Pressure control may be maintained during this time using remaining heaters.

C.1 and C.2 If one group of pressurizer heaters are inoperable and cannot be restored in the allowed Completion Time of Required Action B.1, the (continued)

INDIAN POINT 3 B 3.4.9 - 4 Revision 2

11 Pressurizer B 3.4.9 BASES ACTIONS C.1 and C.2 (continued) plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 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.

SURVEILLANCE REQUIREMENTS SR 3.4.9.1 This SR requires that during steady state operation, pressurizer level is maintained below the nominal upper limit to provide a minimum space for a steam bubble.

The Surveillance is performed by observing the indicated level.

The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> has been shown by operating practice to be sufficient to regularly assess level for any deviation and verify that operation is within safety analyses assumptions of ensuring that a steam bubble exists in the pressurizer. Alarms are also available for early detection of abnormal level indications.

SR 3.4.9.2 The SR is satisfied when the power supplies are demonstrated to be capable of producing the minimum power and the associated pressurizer heaters are verified to be at their design rating.

This may be done separately by testing the power supply output and by performing an electrical check on heater element continuity and resistance. The Frequency of 24 months is considered adequate to detect heater degradation and has been shown by operating experience to be acceptable.

REFERENCES

1.

FSAR, Section 14.

2.

NUREG-0737, November 1980.

3.

IP3 Technical Requirements Manual.

INDIAN POINT 3 B 3.4.9 - 5 Revision 2

Containment Air Temperature B 3.6.5 B 3.6 CONTAINMENT SYSTEMS B 3.6.5 Containment Air Temperature BASES BACKGROUND The containment structure serves to contain radioactive material that may be released from the reactor core following a Design Basis Accident (DBA).

The containment average air temperature is limited during normal operation to preserve the initial conditions assumed in the accident analyses for a loss of coolant accident (LOCA) or steam line break (SLB).

The containment average air temperature limit is derived from the input conditions used in the containment functional analyses and the containment structure external pressure analyses. This LCO ensures that initial conditions assumed in the analysis of containment response to a DBA are not violated during unit operations. The total amount of energy to be removed from containment by the Containment Spray and Cooling systems during post accident conditions is dependent upon the energy released to the containment due to the event, as well as the initial containment temperature and pressure.

The higher the initial temperature, the more energy that must be removed, resulting in higher peak containment pressure and temperature. Exceeding containment design pressure may result in leakage greater than that assumed in the accident analysis.

Operation with containment temperature in excess of the LCO limits violates an initial condition assumed in the accident analysis.

APPLICABLE SAFETY ANALYSES Containment average air temperature is an initial condition used in the DBA analyses that establishes the containment environmental qualification operating envelope for both pressure and temperature. The upper limit for containment average air temperature ensures that operation is maintained within the assumptions used in the DBA analyses for containment (Ref. 1).

(continued)

INDIAN POINT 3 8 3.6.5 - 1 Revision 1

I Containment Air Temperature B 3.6.5 BASES APPLICABLE SAFETY ANALYSES (continued)

The lower limit is to assure that the minimum service metal temperature of the containment liner is well above the NDT + 300F criterion for the liner material (Ref. 3).

The limiting DBAs considered relative to containment OPERABILITY are the LOCA and SLB. The DBA LOCA and SLB are analyzed using computer codes designed to predict the resultant containment pressure transients. No two DBAs are assumed to occur simultaneously or consecutively. The postulated DBAs are analyzed with regard to Engineered Safety Feature (ESF) systems, assuming the loss of one ESF bus, which is the worst case single active failure, resulting in one train each of the Containment Spray System, Residual Heat Removal System, and Containment Cooling System being rendered inoperable.

The limiting DBA for the maximum peak containment air temperature may be either a LOCA or a SLB. The initial containment average air temperature is assumed in the design basis analyses.

The maximum containment air temperature and the design temperature are specified in (Ref. 1).

The temperature limit is used to establish the environmental qualification operating envelope for containment. The maximum peak containment air temperature was calculated to exceed the containment design temperature for only a few seconds during the transient. The basis of the containment design temperature, however, is to ensure the performance of safety related equipment inside containment (Ref. 2).

Thermal analyses showed that the time interval during which the containment-air-temperature exceeded the containment design temperature was short enough that the equipment surface temperatures remained below the design temperature.

Therefore, it is concluded that the calculated transient containment air temperature is acceptable for the DBA LOCA or SLB.

The containment pressure transient Is sensitive to the initial air mass in containment and, therefore, to the initial containment air temperature. The limiting DBA for establishing the maximum peak containment internal pressure may be either a (continued)

INDIAN POINT 3 B 3.6.5 -2 Revision 1

Containment Air Temperature B 3.6.5 BASES APPLICABLE SAFETY ANALYSES (continued)

LOCA or a SLB.

The upper temperature limit is used in this analysis to ensure that in the event of an accident the maximum containment internal pressure will not be exceeded.

Containment average air temperature satisfies Criterion 2 of 10 CFR 50.36.

LCO During a DBA, with an initial containment average air temperature less than or equal to the LCO temperature upper limit, the resultant peak accident temperature is maintained below the containment design temperature.

As a result, the ability of containment to perform its design function is ensured.

The lower limit for containment average air temperature assures that the containment liner temperature is maintained well above the NDT temperature.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES.

Therefore, maintaining containment average air temperature within the limits is not required in MODE 5 or 6.

ACTIONS A.1 When containment average air temperature is < 50'F, it must be restored within limits immediately. This required action is necessary to ensure that a sufficient margin of safety is maintained so the NDT limit is not compromised. The completion time of immediately ensures that containment temperature is restored to within limits without delay.

(continued)

INDIAN POINT 3 B 3.6.5 - 3 Revision I

I 1.

Containment Air Temperature B 3.6.5 BASES ACTIONS When containment average air temperature is greater than 1300F, it (continued) must be restored to within limits within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

This Required Action is necessary to return operation to within the bounds of the containment analysis. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time is acceptable considering the sensitivity of the analysis to variations in this parameter and provides sufficient time to correct minor problems.

C.1 and C.2 If the containment average air temperature cannot be restored to within its limits within the required Completion Time, the plant 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 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 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.

SURVEILLANCE REQUIREMENTS SR 3.6.5.1 Verifying that containment average air temperature is within the LCO limits ensures that containment operation remains within the limits assumed for the containment analyses. In order to determine the containment average air temperature, an arithmetic average is calculated using measurements taken at locations within the containment selected to provide a representative sample of the overall containment atmosphere.

A representative measurement of containment air temperature requires an arithmetic average of temperatures measured at no fewer than 4 locations. Environmentally and seismically qualified RTDs mounted on the crane wall above the containment fan cooler units inlet are normally used for measuring containment ambient temperature.

Experience dictates that at least 4 fan cooler units should be operating to achieve adequate mixing of air to assure a representative measurement of containment air temperature. Portable temperature sensing equipment may also be used.

(continued)

INDIAN POINT 3 B 3.6.5 -4 Revision 1

Containment Air Temperature B 3.6.5 BASES SURVEILLANCE REQUIREMENTS SR 3.6.5.1 (continued)

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency of this SR is considered acceptable based on observed slow rates of temperature increase within containment as a result of environmental heat sources (due to the large volume of containment).

Furthermore, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal containment temperature condition.

REFERENCES

1.

FSAR, Section 14.3.

2.

10 CFR 50.49.

3.

FSAR, Section 5.1.

INDIAN POINT 3 B 3.6.5 - 5 Revision 1

CRVS B 3.7.11 B 3.7 PLANT SYSTEMS B 3.7.11 Control Room Ventilation System (CRVS)

BASES BACKGROUND The CRVS provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity.

chemicals, or toxic gas.

The Control Room Ventilation System consists of the following equipment: a single filter unit consisting of two roughing filters, two high efficiency particulate air (HEPA) filters; two activated charcoal adsorbers for removal of gaseous activity (principally iodines); two 100% capacity filter booster fans; and, a single duct system including dampers, controls and associated accessories to provide for three different air flow configurations. The air-conditioning units associated with the CRVS are governed by LCO 3.7.12, "Control Room Air Conditioning System (CRACS)."

The CRVS is divided into two trains with each train consisting of a filter booster fan and the associated inlet damper and the following components which are common to both trains: the control room filter unit, damper A (filter unit bypass for outside air makeup to the Control Room), damper B (filter unit inlet for outside air makeup to the Control Room), damper C (filter unit inlet for reticulated air),

and the toilet and locker room exhaust fan. The two filter booster fans (F 31 and F 32) are powered from safeguards power trains 5A (EDG 33) and 6A (EDG 32), respectively. The automatic dampers that are common to both trains are positioned in the fail-safe position (open or closed) by either of the redundant actuation channels.

The CRVS is an emergency system, parts of which operate during normal unit operations.

The three different CRVS air flow configurations are as follows:

(continued)

INDIAN POINT 3 B 3.7.11 - 1 Revision 2

CRYS B 3.7.11 BASES BACKGROUND a)

Normal operation consists of approximately 85% (8500 cfm)

(continued) unfiltered recirculated flow driven by the air-conditioning fans and approximately 15% (1500 cfm) unfiltered outside air makeup; b) Incident mode with outside air makeup (i.e. 10% incident mode) consists of approximately 87% (9250 cfm) unfiltered recirculated flow driven by the two safety related air-conditioning fans, at least 10% (> 1000 cfm) filtered recirculated flow driven by either one of the two filter booster fans and 35 to 400 cfm filtered outside air makeup; c) Incident mode with no outside air makeup (i.e. 100% incident mode) consists of 85% (9100 cfm) unfiltered recirculated flow driven by the two safety related air-conditioning fans, approximately 15% filtered recirculated flow driven by either one of the two filter booster fans and no outside air makeup.

Note that the required recirculation rates are demonstrated with surveillance tests conducted with the air conditioning system (CRACS) operating. An inoperable CRACS fan will affect the flow balance of the CRYS due to interconnected ductwork. Therefore, if the fan associated with one of the air-conditioning units governed by LCO 3.7.12 is inoperable, Conditions in both LCO 3.7.11, Control Room Ventilation System, and LCO 3.7.12, Control Room Air Conditioning System (CRACS), will apply.

Incident mode with outside air makeup is the preferred method of operation during any radiological event because it provides outside air for pressurization of the Control Room. Calculations indicate that very low flowrates (e.g. 35 cfm) of outside air makeup will maintain the Control Room at a slight positive pressure.

Nevertheless, due to the difficulty of adjusting and maintaining the flow dampers to provide a low flow, the dampers are typically adjusted to provide a flow of approximately 250 cfm (2.5% outside air makeup). However, a higher volume of outside air makeup to (continued)

INDIAN POINT 3 B 3.7.11 - 2 Revision 2

CRVS B 3.7.11 BASES BACKGROUND the Control Room increase the thyroid dose to the operators during (continued) an accident. Therefore, the Control Room dose assessment assumes a filtered outside air makeup of approximately 400 cfm (4.0% outside air makeup).

On a Safety Injection signal or high radiation in the Control Room (Radiation Monitor R-1), the CRVS will actuate to the incident mode with outside air makeup (i.e. 10% incident mode). This will cause one of the two filters booster fans to start, the locker room exhaust fan to stop, and CRVS dampers to open or close as necessary to filter all incoming outside air and direct approximately 10% of the recirculated air through the filter unit. In the event that the first booster fan fails to start, the second booster fan will start after a predetermined time delay.

If for any reason it is required or desired to operate with 100%

recirculated air (e.g., toxic gas condition is identified), the CRVS can be placed in the incident mode with no outside air makeup (i.e.

100% incident mode) by remote manually operated switches. The Firestat detectors will shutdown both air conditioning units associated with the CRVS, resulting in shutting the outside air dampers. However, if any filter booster fan was running at that time, it will continue to run.

The control room is continuously monitored by radiation and toxic gas detectors. On a Safety Injection signal or high radiation in the Control Room (Radiation Monitor R-1). will cause actuation of the emergency radiation state of the CRVS (i.e., incident mode with outside air makeup (i.e. 10% incident mode)).

The CRYS does not actuate automatically in response to toxic gases.

Separate chlorine, ammonia and oxygen probes are provided to detect the presence of these gases in the outside air intake.

Additionally, monitors in the Control Room will detect low oxygen levels and high levels of chlorine and ammonia. The CRVS may be placed in the'incident mode with no outside air makeup (i.e. 100%

incident mode)Ato respond to these conditions.

Instrumentation for toxic gas monitoring is governed by the IP3 Technical Requirements Manual (TRM) ( Ref. 4).

Generally, the manually initiated actions of the toxic gas isolation state are more restrictive, and will override the actions of the emergency radiation state.

(continued)

INDIAN POINT 3 B 3.7.11 - 3 Revision 2

I p.

CRVS B 3.7.11 BASES BACKGROUND A single train will create a slight positive pressure in the L

(continued) control room. The CRVS operation in maintaining the control room habitable is discussed in the FSAR, Section 9.9 (Ref. 1).

The CRVS is designed in accordance with Seismic Category I requirements.

The CRVS is designed to maintain the control room environment for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5 rem whole body dose or 30 rem to the thyroid.

APPLICABLE SAFETY ANALYSES The CRVS active components are arranged in redundant, safety related ventilation trains.

The location of components and ducting within the control building envelope ensures an adequate supply of filtered air to all areas requiring access. The CRVS provides airborne radiological protection for the control room operators, as demonstrated by the control room accident dose analyses for the most limiting design basis accident (i.e., DBA LOCA) fission product release presented in the FSAR, Chapter 14 (Ref. 2).

Radiation monitor R-1 is not required for the Operability of the Control Room Ventilation System because control room isolation is initiated by the safety injection signal in MODES 1, 2, 3, 4, and control room isolation is not required for maintaining radiation exposure within General Design Criteria 19 limits following a fuel handling accident or gas-decay-tank rupture.

The worst case active failure of a component of the CRVS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function. However, the original CRVS design was not required to meet single failure criteria and, although upgraded from the original design, CRVS does not satisfy all requirements in IEEE-279 for single failure tolerance.

(continued)

INDIAN POINT 3 B 3.7.11 - 4 Revision 2

CRVS B 3.7.11 BASES APPLICABLE SAFETY ANALYSES (continued)

Each of the automatic dampers that are common to both trains is positioned in the fail-safe position (open or closed) by either of the redundant actuation channels.

The CRVS satisfies Criterion 3 of 10 CFR 50.36.

LCO Two CRVS trains are required to be OPERABLE to ensure that at least one is available. Total system failure could result in exceeding a dose of 5 rem whole body or 30 rem to the thyroid of the control room operator in the event of a large radioactive release.

The CRYS is considered OPERABLE when the individual components necessary to limit operator exposure are OPERABLE in both trains. A CRVS train is OPERABLE when the associated:

a.

Filter booster fan and an air-conditioning unit fan powered from the same safeguards power train are OPERABLE;

b.

HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions; and

c.

Ductwork, valves, and dampers are OPERABLE or in the incident mode, and air circulation can be maintained.

In addition, the control room boundary must be maintained, including the integrity of the walls, floors, ceilings, ductwork, and access doors.

Instrumentation for toxic gas monitoring is governed by the IP3 Technical Requirements Manual (TRM) ( Ref. 4) and is not included in the LCO.

Note that the required recirculation rates are demonstrated with surveillance tests conducted with the air conditioning system (CRACS) operating. An inoperable CRACS fan will affect the flow (continued)

INDIAN POINT 3 8 3.7.11 - 5 Revision 2

CRVS B 3.7.11 BASES LCO (continued) balance of the CRYS due to interconnected ductwork. Therefore, if the fan associated with one of the air-conditioning units governed by LCO 3.7.12 is inoperable, Conditions in both LCO 3.7.11, Control Room Ventilation System, and LCO 3.7.12, Control Room Air Conditioning System (CRACS), will apply.

APPLICABILITY In MODES 1, 2, 3, 4 CRYS must be OPERABLE to limit operator exposure during and following a DBA.

The CRVS is not required in MODE 5 or 6, or during movement of irradiated fuel assemblies and core alterations because analysis indicates that isolation of the control room is not required for maintaining radiation exposure within acceptable limits following a fuel handling accident or gas decay tank rupture.

Administrative controls address the role of the CRVS in maintaining control room habitability following an event at Indian Point Unit 2.

ACTIONS A.

1 When one CRVS train is inoperable, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CRYS train is adequate to perform the control room protection function. However, the overall reliability is reduced because a failure in the OPERABLE CRVS train could result in loss of CRYS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

B.1 When neither CRVS train is Operable, action must be taken to restore at least one train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is acceptable because of the low probability of a DBA occurring during this time period.

(continued)

INDIAN POINT 3 B 3.7.11 - 6 Revision 2

CRVS B 3.7.11 BASES ACTIONS C.1 and C.2 (continued)

If Required Actions A.1 or B.1 are not met within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk.

To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE REQUIREMENTS SR 3.7.11.1 Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system.

Note that a CRVS train includes both the filter booster fan and an air-conditioning unit fan powered from the same safeguards power train.

The 31 day Frequency is based on the reliability of the equipment and the two train redundancy availability.

SR 3.7.11.2 This SR verifies that the required CRVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).

The CRYS filter tests are in accordance with the sections of Regulatory Guide 1.52 (Ref. 3) identified in the VFTP. The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal.

Specific test Frequencies and additional information are discussed in detail in the VFTP.

(continued)

INDIAN POINT 3 B 3.7.11 - 7 Revision 2

CRVS B 3.7.11 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.11.3 This SR verifies that each CRVS train starts and operates on an actual or simulated actuation signal. The Frequency of 24 months is based on operating experience which has demonstrated this Frequency provides a high degree of assurance that the booster fans will operate and dampers actuate to the correct position when required.

SR 3.7.11.4 This SR verifies the integrity of the control room enclosure, and the assumed inleakage rates of the potentially contaminated air.

The control room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify proper functioning of the CRVS. During the operation in the incident mode with outside air makeup (i.e. 10% incident mode), the CRVS is designed to maintain the control room at a slight positive pressure with respect to adjacent areas in order to prevent unfiltered inleakage. The CRVS is designed to maintain this positive pressure with very low volumes of outside air makeup.

Due to the difficulty of adjusting and maintaining the flow dampers to provide a low flow, it was determined that the damper should be adjusted to provide a flow of approximately 250 cfm (2.5% outside air makeup). Note that the higher the volume of outside air makeup to the Control Room, the higher the thyroid dose to the operators during an accident. The acceptance criteria of 400 cfm (4.0% outside air makeup) is the volume used in the Control Room dose assessment.

The SR Frequency of 24 months on a staggered test basis is acceptable because operating experience has demonstrated that the control room boundary is not normally disturbed. Staggered testing is acceptable because the SR is primarily a verification of Control Room integrity because fan operation is tested elsewhere.

(continued)

INDIAN POINT 3 B 3.7.11 - 8 Revision 2

CRVS B 3.7.11 BASES REFERENCES

1.

FSAR, Section 9.9.

2.

FSAR, Chapter 14.

3.

Regulatory Guide 1.52, Rev. 2.

4.

IP3 Technical Requirements Manual.

INDIAN POINT 3 B 3.7.11 - 9 Revision 2

FSBEVS B 3.7.13 B 3.7 PLANT SYSTEMS B 3.7.13 Fuel Storage Building Emergency Ventilation System (FSBEVS)

BASES BACKGROUND The FSBEVS filters airborne radioactive particulates from the area of the fuel pool following a fuel handling accident. The FSBEVS, in conjunction with other normally operating systems, also provides environmental control of temperature and humidity in the fuel storage building.

The Fuel Storage Building (FSB) ventilation system maintains environmental conditions in the building enclosing the spent fuel pit and consists of the following:

Two FSB air tempering units, each consisting of: a steam heating coil, a supply fan, and an isolation damper; One FSB exhaust fan and associated outlet damper; One FSB exhaust filtration unit consisting of roughing, HEPA, and charcoal filters which includes the pneumatically operated inlet and outlet dampers for the carbon filter and manually operated dampers that allow the carbon filter to be bypassed; Inflatable seals on man doors and truck door, Area Radiation Monitor (R-5) consisting of an extended range area monitor used to measure the area radiation fields of the Fuel Storage Building; and, Ductwork, dampers, and instrumentation needed to support system operation, During normal operation, the FSB air tempering units and the FSB exhaust fan operate, as necessary, to ventilate and, if necessary, heat the FSB. Only one air tempering unit used to supply outside air to the south end of the FSB and the FSB exhaust fan (continued)

I INDIAN POINT 3 B 3.7.13 - 1 Revision 2

I ii FSBEVS B 3.7.13 BASES BACKGROUND (continued) is used to exhaust air from the north end of the FSB through the roughing filters and HEPA filters and is released to the environment via the plant vent. FSB air flow is directed from radiologically clean to less clean areas to prevent the spread of contamination.

Additionally, the FSBEVS is designed so that the exhaust fan capacity is greater than the supply fan(s) capacity so that the FSB is normally maintained at a slight negative pressure. This ensures that ventilation air leaving the FSB passes through the filters and HEPA in the exhaust filtration unit and is released to the environment via the plant vent. When not handing irradiated fuel in the FSB, the carbon filter in the exhaust filtration unit is normally bypassed to extend the life of the charcoal. In this configuration, the manually operated charcoal filter bypass dampers are left open and the automatically operated charcoal filter face dampers (inlet and outlet dampers) are closed.

During irradiated fuel handling activities in the FSB. the FSBEVS is operated as described above except that the manually operated charcoal filter bypass dampers are closed and the charcoal filter face dampers (inlet and outlet dampers) are opened. In this configuration, the FSB is still maintained at a slight negative pressure but all FSB ventilation exhaust is directed through the roughing filters, HEPA filters, and charcoal filters and is released to the environment via the plant vent.

Following an Area Radiation Monitor (R-5) signal or manual actuation to the emergency mode of operation, the ventilation supply fans stop automatically and the associated ventilation supply dampers close automatically. The charcoal filter face dampers (inlet and outlet dampers) open automatically, if not already open. Additionally, the rolling truck door closes, if open, and the inflatable seals on the man doors and truck door are actuated. The FSB exhaust fan continues to operate. With the FSB ventilation supply stopped and the FSB boundary secured, the FSB exhaust fan is capable of maintaining the FSB at a pressure < -0.5 inches water gauge with respect to atmospheric pressure.with the exhaust flow rate < 20,000 cfm.

Ventilation dampers required to establish the boundary or flow path (e.g., air tempering unit ventilation supply inlet dampers) will fail-(continued)

INDIAN POINT 3 B 3.7.13 - 2 Revision 2

FSBEVS B 3.7.13 BASES BACKGROUND safe into the required emergency mode position. Note that the (continued) inflatable seals on man doors and truck door are not required for maintaining the FSB at these required post accident conditions.

A push button switch adjacent to the 95' elevation door leading to the Fan House allows the Fuel Storage Building Exhaust Fan to be momentarily shut down and air removed from the man door seal to allow the door to be opened for FSB ingress or egress when in the emergency mode of operation. The fan will automatically restart and the door is resealed after a preset time has elapsed (approximately 30 seconds).

The FSBEVS is discussed in the FSAR, Sections 9.5, and 14.2 (Refs. I and 2, respectively).

APPLICABLE SAFETY ANALYSES The FSBEVCS design basis is established by the consequences of the limiting Design Basis Accident (DBA), which is a fuel handling accident involving handling recently irradiated fuel.

The analysis for a fuel handling accident assumes that the FSB exhaust fan can maintain the FSB at a slight negative pressure (i.e., < -0.125 inches water gauge) with respect to atmospheric

-pressure-with the exhaust flow rate c 20,000 cfm.

Under these conditions, all FSB ventilation exhaust is assumed to be directed through the roughing filters, HEPA filters, and charcoal filters and is released to the environment via the plant vent.

This ensures that offsite post accident dose rates are within required limits.

Due to radioactive decay, FSBEVS is only required to isolate during fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />). This analysis is described in Reference 2.

The'FSBEVS satisfies'Criterion 3 of 10 CFR 50.36.

(continued)

INDIAN POINT 3 B 3.7.13 - 3 Revision 2

FSBEVS B 3.7.13 BASES LCO This LCO requires that the Fuel Storage Building Emergency Ventilation System is OPERABLE and the FSB boundary is intact.

This ensures that the required negative pressure is maintained in the FSB and FSB ventilation exhaust is directed through the roughing filters, HEPA filters, and charcoal filters and is released to the environment via the plant vent.

Failure of the FSBEVS or the FSB boundary could result in the atmospheric release from the fuel storage building exceeding the 10 CFR 100 (Ref. 3) limits in the event of a fuel handling accident involving handling recently irradiated fuel.

The FSBEVS is considered OPERABLE when the individual components necessary to control exposure in the fuel storage building are OPERABLE. FSBEVS is considered OPERABLE when its associated:

a.

Exhaust fan is OPERABLE;

b.

Roughing filter, HEPA filter and charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration function;

c.

Ductwork and dampers are OPERABLE as needed to ensure air circulation can be maintained through the filter;

d.

Ventilation supply fan trip function and ventilation supply isolation dampers closure function are OPERABLE or secured in incident position; and

e.

FSBEVS charcoal filter bypass dampers are closed and leak tested.

The inflatable seals on man doors and truck door are not required for maintaining the FSB at these required post accident conditions.

Additionally, the FSBEVS is not rendered inoperable when the FSBEVS exhaust fan is momentarily shut down and air removed from the door seal to allow the door to be opened for FSB ingress or egress when in the emergency mode of operation.

Requirements for the OPERABILITY of the Area Radiation Monitor (R-5) and associated instrumentation that initiates the FSBEVS are addressed in LCO 3.3.8, "Fuel Storage Building Emergency Ventilation System Actuation Instrumentation."

(continued)

INDIAN POINT 3 B 3.7.13 - 4 Revision 2

FSBEVS B 3.7.13 BASES LCO Requirements for leak testing the FSBEVS charcoal filter bypass (continued) dampers following closure are governed by the IP3 FSAR.

APPLICABILITY During movement of recently irradiated fuel in the fuel storage building, the FSBEVS is required to be OPERABLE to mitigate the consequences of the limiting fuel handling accident.

ACTIONS A.I When the FSBEVS is inoperable during movement of recently irradiated fuel assemblies in the fuel storage building, action must be taken to place the unit in a condition in which the LCO does not apply.

Action must be taken immediately to suspend movement of recently irradiated fuel assemblies in the fuel storage building. This does not preclude the movement of fuel to a safe position.

SURVEILLANCE REQUIREMENTS SR 3.7.13.1 This SR requires periodic verification that the FSBEVS charcoal filter bypass dampers are installed and leak tested.

This SR is performed by a visual verification that the bypass dampers are installed and an administrative verification that required leak testing was performed following the last installation of the dampers. Requirements for leak testing the FSBEVS charcoal filter bypass dampers following closure are governed by the IP3 FSAR.

This SR is performed prior to movement of recently irradiated fuel assemblies in the fuel storage building, and once per 92 days thereafter.

The 92 day Frequency is appropriate because the bypass dampers are operated under administrative controls which provide a high degree of assurance that the dampers will remain in the required position. This Frequency has been shown to be acceptable through operating experience.

(continued)

INDIAN POINT 3 8 3.7.13 - 5 Revision 2

FSBEVS B 3.7.13 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.13.2 Standby systems should be checked periodically to ensure that they function properly.

As the environmental and normal operating conditions on this system are not severe, testing the FSBEVS once every 31 days provides an adequate check on this system.

Systems are operated for > 15 minutes to demonstrate the function of the system. The 31 day Frequency is based on the known reliability of the equipment.

SR 3.7.13.3 This SR verifies that the required FSBEVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).

The FSBEVS filter tests are in accordance with the applicable portions of Regulatory Guide 1.52 (Ref. 4) as specified in the VFTP.

The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.13.4 This SR verifies that the FSBEVS starts and operates on an actual or simulated actuation signal.

The 92 day Frequency ensures that the SR is performed within a short time prior to a potential need for the FSBEVS and allows the SR to be performed only once prior to or during a refueling outage.

This SR Frequency is based on the demonstrated reliability of the system.

(continued)

INDIAN POINT 3 B 3.7.13 - 6 Revision 2

FSBEVS B 3.7.13 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.13.5 This SR verifies the integrity of the fuel storage building enclosure. The ability of the fuel building to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the FSBEVS.

During the normal mode of operation, the FSBEVS is designed to maintain a slight negative pressure in the fuel storage building, to prevent unfiltered LEAKAGE.

This test verifies that the FSB exhaust fan can maintain the FSB at a slight negative pressure (i.e., < -0.125 inches water gauge) with respect to atmospheric pressure with the exhaust flow rate < 20,000 cfm during a fuel handling accident. The Frequency of 24 months is consistent with the guidance provided in NUREG-0800, Section 6.5.1 (Ref. 5).

REFERENCES

1. FSAR, Section 9.5.

2. FSAR, Section 14.2.

3.

10 CFR 100.

4. Regulatory Guide 1.52 (Rev. 2).

5. NUREG-0800, Section 6.5.1, Rev. 2, July 1981.

INDIAN POINT 3 B 3.7.13 - 7 Revision 2

Inverters - Operating B 3.8.7 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.7 Inverters -Operating BASES BACKGROUND The inverters are the preferred source of power for the 120 V AC vital instrument buses because of the stability and reliability they achieve.

The function of the inverter is to provide AC electrical power to the vital instrument buses.

There are four 120 volt AC vital instrument buses (VIBs), Nos. 31, 32, 33 and 34. The preferred power supplies to these buses are static inverters, Nos. 31, 32, 33 and 34, which are in turn supplied from separate 125 volt DC buses, Nos. 31, 32, 33 and 34. Each of the four 125 volt DC buses is powered by a battery and associated battery charger.

Inverters 31, 32, and 33 each have an associated backup 480 V/120 V constant voltage transformer (CYT). Each of these inverters has a manual bypass switch that causes the associated VIB to receive AC power from plant AC sources via the backup CVT instead of the DC powered inverter. Inverters 31, 32, and 33 will transfer to the backup power supply (i.e., the associated CVT) automatically in the event of an inverter failure. However, this auto-transfer feature is not credited in the safety analyses. The backup CVTs for inverters 31, 32, and 33 are supplied from non-safety related buses that are stripped and not automatically re-connected following a safety injection (SI) signal or a loss of offsite power (LOOP).

Therefore, operator action is required to re-energize VIBs 31, 32, or 33 following an SI or LOOP if the associated inverter is being bypassed or fails during the event. Additionally, the potential exists that the bus powering the backup CVT may not be available following an event.

Inverter 34 has two associated backup 480 V/120 V constant voltage transformers (CYTs). The CVTs associated with inverter 34 are powered from separate safeguards power trains using buses that are automatically re-energized following an SI or LOOP. One CVT is powered from MCC 36C and the other is powered from MCC 36B.

Inverter 34 can be manually bypassed such that either of the associated CVTs can be used to power VIB 34.

Inverter 34 will automatically transfer to the backup CVT powered from 14CC 36C in the event of an inverter failure.

(continued)

INDIAN POINT 3 B 3.8.7 - 1 Revision 1

Inverters -

Operating B 3.8.7 BASES BACKGROUND However, this auto-transfer feature is not credited in the safety (continued) analyses.

Manual operator action is needed to transfer to the backup CVT powered from MCC 36B.

Using a separate battery and inverter to power each VIB ensures a continuous source of power for the instrumentation and controls of the engineered safety features (ESF) systems and the reactor protection system (RPS) during postulated events including the loss of offsite power. This is consistent with requirements described in Generic Letter 91-011 (Ref. 1).

Continuity of power to the VIBs is assured because each of the four station batteries is sized to carry its expected shutdown loads for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (Ref. 2).

Additionally, four battery chargers have been sized to recharge these batteries while carrying the normal DC subsystem load (Ref.

2).

Note that battery charger 34 is not required by LCO 3.8.4. This is acceptable because VIB 34 can be powered by either of the two CVTs supplied by separate safeguard power trains if battery charger 34 is not available following an event.

Specific details on inverters and their operating characteristics are found in the FSAR, Chapter 8 (Ref. 2).

APPLICABLE SAFETY ANALYSES The initial conditions of Design Basis Accident (DBA) and transient analyses in the FSAR, Chapter 14 (Ref. 3), assumes Engineered Safety Feature systems are OPERABLE. The inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the RPS and ESFAS instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

(continued)

INDIAN POINT 3 B 3.8.7 - 2 Revision 1

Inverters - Operating B 3.8.7 BASES APPLICABLE SAFETY ANALYSES (continued)

The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and is based on meeting the design basis of the unit. This includes maintaining required 120 V AC vital instrument buses OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite AC electrical power or all onsite AC electrical power; and

b. A worst case single failure.

The 2 CVTs capable of supplying VIB 34 are needed to ensure the availability of power to VIB 34 following the depletion of battery

34. Although battery charger 34 would normally be used to supply VIB 34 via inverter 34, battery charger 34 is not safety related and may not be available after a design basis event.

Inverters are a part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36.

LCO The inverters (and CVTs associated with VIB 34) ensure the availability of AC electrical power for the systems instrumentation required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA.

Maintaining the required inverters (and CVTs associated with VIB 34)

OPERABLE ensures that the redundancy incorporated into the design of the RPS and ESFAS instrumentation and controls is maintained.

The four inverters ensure an uninterruptible supply of AC electrical power to the AC vital buses even if the 480 V safety buses are de-energized.

(continued)

INDIAN POINT 3 B 3.8.7 - 3 Revision 1

I J.

Inverters - Operating B 3.8.7 BASES LCO Operable inverters require the associated 120 V AC vital (continued) instrument bus to be powered by the inverter with output voltage and frequency within tolerances, and power input to the inverter from a 125 VDC station battery.

APPLICABILITY The inverters are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a.

Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients; and

b.

Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

Inverter requirements for MODES 5 and 6 are covered in the Bases for LCO 3.8.8, "Inverters - Shutdown."

ACTIONS With an inverter inoperable, its associated VIB becomes inoperable until it is re-energized from its associated backup CVT. For this reason a Note to the Actions requires entry into the Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating."

This ensures that the vital bus is re-energized within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

A.1 With one of the two CVTs capable of supplying VIB 34 not OPERABLE, VIB 34 will be powered from battery 34 via inverter 34 for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following the initiation of any event. After battery 34 is depleted, the second CVT capable of powering VIB 34 will maintain power to VIB 34 even if non-safety related battery charger 34 is not available. A 30 day Completion Time to restore both CVTs to OPERABLE is needed because a failure of the safeguards power train supporting the remaining CVT would result in the loss of two VIBs (i.e. VIB 34 and the VIB associated with (continued)

INDIAN POINT 3 B 3.8.7 - 4 Revision 1

Inverters -

Operating B 3.8.7 BASES ACTIONS A.1 (continued) the failed safeguards power train) but only after the associated batteries are depleted. A 30 day Completion Time to restore both CVTs to OPERABLE is acceptable because of the low probability of an accident in conjunction with the loss of a specific safeguards power train.

B.1 With both of the CVTs capable of supplying VIB 34 not OPERABLE, VIB 34 will be powered from battery 34 via inverter 34 for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following the initiation of any event. After battery 34 is depleted, inverter 34 may not be available to power VIB 34 because battery charger 34 is not safety related and is powered from a non-safety related bus.

Therefore, at least one CVT must be restored within 7 days.

A 7 day Completion Time to restore at least one of the two CVTs to OPERABLE is needed and is acceptable because of the following: VIB 34 will be powered from battery 34 via inverter 34 for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; non-safety related battery charger 34 may be available following an event; and, the low probability of an event during this 7 day period.

C.! and C.2 With an inverter inoperable, its associated VIB must be powered from its associated backup CVT. However, the backup CVTs for inverters 31, 32, and 33 are supplied from non-safety related buses that are stripped and not automatically re-connected following a SI signal or a LOOP. Both backup CVTs for inverter 34 are powered from safety related buses that may be de-energized until the associated safeguards power train is energized (i.e., diesel generator starts).

Therefore, a VIB powered from a backup CVT when the associated inverter is inoperable will be and could remain de-energized following a SI signal or a LOOP.

(continued)

INDIAN POINT 3 B 3.8.7 - 5 Revision 1

Inverters - Operating B 3.8.7 BASES ACTIONS C.1 and C.2 (continued)

If a VIB will be de-energized as a result of SI signal or LOOP, a loss of safety function could exist for any VIB powered function that requires power to perform the required safety function (e.g.,

automatic actuation of core spray, Regulatory Guide 1.97 instrumentation, etc.) if the redundant required feature is inoperable. Therefore, Required Action C.1 requires declaring required feature(s) supported by associated inverter inoperable when its required redundant feature(s) is inoperable. As specified in the associated Note, this requirement only applies to feature(s) that require power to perform the required safety function. 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 consistent with LCO 3.8.9, AC Distribution System - Operating, requirements for an inoperable VIB.

With an inverter inoperable and its associated VIB powered from its associated backup CVT, there is increased potential for inadvertent actuation for ESFAS or RPS functions, especially if redundant channels are inoperable and in the tripped condition. This is because these de-energize to actuate functions are relying upon interruptible AC electrical power sources (offsite and onsite). The uninterruptible inverter source to the VIBs is the preferred source for powering instrumentation trip setpoint devices. Therefore, only one inverter may be inoperable at one time and an inoperable inverter must be restored to OPERABLE within 7 days. The 7 day Completion Time is needed because it ensures that the VIBs are powered from the uninterruptible inverter source. The 7 day Completion Time is acceptable because Required Action C.1 ensures that an inoperable inverter does not result in a loss of any safety function. The 7 day Completion Time is consistent with commitments made in response to Generic Letter 91-011 (Ref. 1).

D.1 and D.2 If the inoperable devices or components cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply.

(continued)

INDIAN POINT 3 B 3.8.7 - 6 Revision 1

Inverters - Operating B 3.8.7 BASES ACTIONS D.1 and D.2 (continued)

To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE REQUIREMENTS SR 3.8.7.1 This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter.

The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation of the RPS and ESFAS connected to the AC vital buses.

The 7 day Frequency takes into account the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter malfunctions.

SR 3.8.7.2 This Surveillance verifies that the power supply to VIB 34 can be manually transferred from the inverter to each of the required CVTs.

This SR ensures that power to VIB 34 can be maintained after the depletion of battery 34. The 24 month Frequency takes into account that either of the CVTs is capable of performing this safety function and the demonstrated reliability of this equipment.

(continued)

INDIAN POINT 3 B 3.8. 7 - 7 Revision 1

I

!I Inverters -

Operating B 3.8.7 BASES REFERENCES

1.

Generic Letter 91-011, Resolution of Generic Issues 48, "LCOs for Class 1E Vital Instrument Buses," and 49, "Interlocks and LCOS for Class 1E Tie Breakers" pursuant to 10 CFR 50.54(f).

2.

FSAR, Chapter 8.

3.

FSAR, Chapter 14.

.1.

INDIAN POINT 3 B 3.8.7 - 8 Revision 1

Inverters -

Shutdown B 3.8.8 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters -Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LCO 3.8.7, "Inverters-Operating."

APPLICABLE SAFETY ANALYSES The initial conditions of Design Basis Accident (DBA) and transient analyses in the FSAR, Chapter 14 (Ref. 1), assume Engineered Safety Feature systems, including inverters that supply required 120 V AC vital instrument buses, are OPERABLE.

The DC to AC inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the Reactor Protective System and Engineered Safety Features Actuation System instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of assumptions of the supported systems' the inverters is consistent with the initial accident analyses and the requirements for the OPERABILITY.

The OPERABILITY of one inverter to each VIB bus during MODES 5 and 6 and when moving irradiated fuel ensures that:

a.

The unit can be maintained in the shutdown or refueling condition for extended periods;

b.

Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c.

Adequate power is available to mitigate events postulated during shutdown, such as a fuel handling accident.

INDIAN POINT 3 B 3.8.8 - 1 Revision I

Inverters -

Shutdown B 3.8.8 BASES APPLICABLE SAFETY ANALYSES (continued)

The inverters were previously identified as part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36.

LCO The inverters ensure the availability of electrical power for the instrumentation for systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. The battery powered inverters provide uninterruptible supply of AC electrical power to the VIBs even if the 480 V safety buses are de-energized.

OPERABILITY of the inverters requires that the VIB be powered by the inverter. This ensures the availability of sufficient inverter power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

This LCO does not require OPERABILITY of the constant voltage transformers (CVTs) capable of supplying VIB 34 even if inverter 34 is required to be OPERABLE.

This is acceptable because VIB 34 will be powered from battery 34 via inverter 34 for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and electrical buses may be cross connected as needed to support inverter 34 prior to the depletion of battery 34.

APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies provide assurance that:

a.

Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b.

Systems needed to mitigate a fuel handling accident are available;

c.

Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and (continued)

INDIAN POINT 3 B 3.8.8 - 2 Revision I

Inverters -

Shutdown B 3.8.8 BASES APPLICABILITY

d.

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

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.7.

ACTIONS A.1. A.2.1. A.2.2. A.2.3 and A.2.4 If more than one VIB is required by LCO 3.8.10, "Distribution Systems -Shutdown," the remaining OPERABLE Inverters may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, fuel movement, and operations with a potential for positive reactivity additions.

By the allowance of the option to declare required features inoperable with the associated inverterss) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCOs' Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions).

The Required Action to suspend positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory, provided the required SDM is maintained.

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 inverters and to continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention.

(continued)

INDIAN POINT 3 B 3.8.8 - 3 Revision 1

I 1i Inverters -

Shutdown B 3.8.8 BASES ACTIONS A.1. A.2.1. A.2.2. A.2.3 and A.2.4 (continued)

The restoration of the required inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a constant voltage source transformer.

SURVEILLANCE REQUIREMENTS SR 3.8.8.1 This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and VIBs energized from the inverter. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation connected to the VIBs. The 7 day Frequency takes into account the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter malfunctions.

REFERENCES

1. FSAR, Chapter 14.

INDIAN POINT 3 B 3.8.8 - 4 Revision 1

Distribution Systems - Operating B 3.8.9 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.9 Distribution Systems -Operating BASES BACKGROUND The onsite AC, DC, and 120 V AC vital instrument bus VIB electrical power distribution systems are divided into three safeguards power trains (5A, 2A/3A and 6A) consisting of four 480 VAC safeguards buses and associated AC electrical power distribution subsystems, four 125 VDC bus subsystems, and four VIBs.

The safeguards subsystems are arranged in three trains such that any two trains are capable of meeting minimum requirements for accident mitigation or safe shutdown. The three safeguards subsystems consist of 480 volt bus 5A (associated with DG 33), 480 volt bus 6A (associated with DG 32), and 480 volt buses 2A and 3A (associated with DG 31). Buses 2A and 3A are considered a single safeguards bus. The electrical subsystems are identified in Table B 3.8.9-1.

The AC electrical power subsystem for each train consists of an Engineered Safety Feature (ESF) 480 V bus and motor control centers.

Each 480 V bus has at least one offsite source of power as well as a dedicated onsite diesel generator (DG) source. Each of the four 480 V volt buses can receive offsite power from either the normal (138 kV) or alternate (13.8 kV) offsite source. The normal offsite power source uses either of the two 138 kilovolt (kV) ties from the Buchanan substation. The alternate offsite power source uses either of the two 13.8 kV ties from the Buchanan substation. There is no automatic transfer from the normal to the alternate source of offsite power.

Offsite power to 480 V buses 5A and 6A is supplied from 6.9 kY buses 5 and 6, respectively, which in turn receive power from either 138 kV offsite feeder via the Station Auxiliary Transformer (SAT).

Alternately, 6.9 kV buses 5 and 6 can be supplied from either of the two 13.8 kV ties via an auto-transformer associated with the 13.8 kV feeder being used.

(continued)

INDIAN POINT 3 B 3.8.9 - 1 Revision 2

Distribution Systems -

Operating B 3.8.9 BASES BACKGROUND (continued)

When the plant is at power, 480 V buses 2A and 3A are normally powered from the Main Generator via the Unit Auxiliary Transformer (UAT) and the 6.9 kV buses 2 and 3 via SSTs 2 and 3. When the plant is not operating, buses 2A and 3A are supplied from 6.9 kV buses 5 and 6, respectively, via tie breakers. Following a unit trip, power to 480 V buses 2A and 3A is maintained by a fast transfer that connects buses 2A and 3A to power supplied from offsite to 6.9 kV buses 5 and 6. If the 138 kV system is not available, either of the two independent 13.8 kV feeders can be connected to the 6.9 kV buses through associated 20 MVA 13.8 KV/6.9 KV auto-transformers. When the 13.8 kV power source is used to feed 6.9 kV buses 5 and 6 and the main generator is used to feed 6.9 kV buses 1, 2, 3 and 4, automatic transfer of the 6.9 KV buses 1, 2, 3 and 4 to the 13.8 kV source following a unit trip must be prohibited to prevent overloading of the 13.8 kV auto-transformer. Therefore, a unit trip when a 13.8 kV power source is used to feed 6.9 kV buses 5 and 6 will result in 480 V busses 2A and 3A being de-energized and subsequently being powered from DG 31.

Each of the three 480 V safeguards subsystems receives DC control power from its associated battery charger and battery source.

Battery No. 31 supplies DC control power to safeguards power train 5A including DG 33.

Battery No. 32 supplies DC control power to safeguards power train 6A including DG 32. Battery No. 33 supplies DC control power to safeguards power train 2A/3A including DG 31.

Batteries 31 and 32 also supply ESFAS and RPS trains A and B, respectively.

Additional description of this system may be found in the Bases for LCO 3.8.1, "AC Sources-Operating," and the Bases for LCO 3.8.4, "DC Sources -Operating."

The AC electrical power distribution system for each train includes the safety related motor control centers shown in Table B 3.8.9-1.

There are four 120 volt vital AC instrument buses (VIBs), each consisting of two interconnected buses.

The four VIBs are powered by static inverters that are powered from the four separate 125 volt DC buses.

(continued)

INDIAN POINT 3 B 3.8.9 - 2 Revision 2

Distribution Systems -

Operating B 3.8.9 BASES BACKGROUND (continued)

Inverters 31, 32, and 33 each have an associated backup 480 V/120 V constant voltage transformer (CVT).

Each of these inverters has a manual bypass switch that causes the associated VIB to receive AC power from plant AC sources via the backup CVT instead of the DC powered inverter.

Inverters 31, 32, and 33 will transfer to the backup power supply (i.e., the associated CVT) automatically in the event of an inverter failure. However, the backup CVTs for inverters 31, 32, and 33 are supplied from non-safety related buses that are stripped and not automatically re-connected following a safety injection (SI) signal or a loss of offsite power (LOOP).

Therefore, operator action is required to re-energize VIBs 31, 32, or 33 following an SI or LOOP if the associated inverter is being bypassed or fails during the event. Additionally, the potential exists that the bus powering the backup CVT may not be available following an event.

Inverter 34 has two associated backup 480 V/120 V constant voltage transformers (CVTs). The CVTs associated with inverter 34 are powered from separate safeguards power trains using buses that are automatically re-energized following an SI or LOOP.

Inverter 34 can be manually bypassed such that either of the associated CVTs can be used to power VIB 34.

Inverter 34 will automatically transfer to a backup power supply (i.e., the associated CVT powered from MCC 36C) in the event of an inverter failure. Manual operator action is needed to transfer to the other backup CVT that is powered from MCC 36B.

The 125 volt DC system is divided into four buses with one battery and battery charger (supplied from the 480 volt system) serving each.

The battery chargers supply the normal DC loads as well as maintaining proper charges on the batteries. The DC system is redundant from battery source to actuation devices which are powered from the batteries. Four batteries feed four DC power panels, which in turn feed major loads, such as instrument bus inverters and switchgear control circuits. DC power panels 31 and 32 feed DC distribution panels, which in turn feed relaying and instrumentation loads. Continuity of power to the VIBs is assured because each of the four station batteries is sized to carry its expected shutdown loads for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

(continued)

INDIAN POINT 3 B 3.8.9 - 3 Revision 2

I ii Distribution Systems - Operating B 3.8.9 BASES BACKGROUND Additionally, four battery chargers have been sized to recharge (continued) these batteries while carrying the normal DC subsystem load (Ref. 2).

Note that battery charger 34 is not required by LCO 3.8.4, DC Sources - Operating. This is acceptable because VIB 34 can be powered by either of the two CVTs supplied by separate safeguard power trains if battery charger 34 is not available following an event.

The 2 CVTs capable of supplying VIB 34 are needed to ensure the availability of power to VIB 34 following the depletion of battery 34.

Although battery charger 34 would normally be used to supply VIB 34 via inverter 34, battery charger 34 is not safety related and may not be available after a design basis event.

The list of all required distribution buses is presented in Table B 3.8.9-1.

APPLICABLE SAFETY ANALYSES The initial conditions of Design Basis Accident (DBA) and transient analyses in the FSAR, Chapter 14 (Ref. 1), assume ESF systems are OPERABLE. The AC, DC, and AC vital instrument bus electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

The OPERABILITY of the AC, DC, and. VIB electrical power distribution systems is consistent with the initial assumptions of the accident analyses and is based upon meeting -the design basis of the unit.

This includes maintaining power distribution systems OPERABLE during accident conditions in the event of:

a.

An assumed loss of all offsite power or all onsite AC electrical power; and (continued)

INDIAN POINT 3 B 3.8.9 - 4 Revision 2

Distribution Systems - Operating B 3.8.9 BASES APPLICABLE SAFETY ANALYSES (continued)

b. A worst case single failure.

The distribution systems satisfy Criterion 3 of 10 CFR 50.36.

LCO The required power distribution subsystems listed in Table B 3.8.9-1 ensure the availability of AC, DC, and VIB electrical power for the systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA. The AC, DC, and VIB electrical power distribution subsystems are required to be OPERABLE.

Maintaining the AC, DC, and VIB electrical power distribution subsystems OPERABLE ensures that the redundancy incorporated into the design of ESF is not defeated. Therefore, a single failure within any system or within the electrical power distribution subsystems will not prevent safe shutdown of the reactor.

OPERABLE AC electrical power distribution subsystems require the associated buses and safety related motor control centers to be energized to their proper voltages. OPERABLE DC electrical power distribution subsystems require the associated buses to be energized to their proper voltage from either the associated battery or charger. OPERABLE vital instrument bus electrical power

.distribution subsystems require the associated buses to be energized to their proper voltage from the associated inverter via inverted DC voltage or constant voltage transformer.

In addition, tie breakers between redundant safety related AC, DC, and VIB power distribution subsystems must be open. This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, that could cause the failure of a redundant subsystem and a loss of essential safety function(s).

If any tie breakers are closed, the affected redundant electrical power distribution subsystems are considered inoperable. This applies to the onsite, safety (continued)

INDIAN POINT 3 B 3.8.9 - 5 Revision 2

I

!I Distribution Systems -

Operating B 3.8.9 BASES I

LCO related redundant electrical power distribution subsystems. It (continued) does not, however, preclude redundant 480 V buses from being powered from the same offsite circuit.

APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a.

Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients; and

b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

Electrical power distribution subsystem requirements for MODES 5 and 6 are covered in the Bases for LCO 3.8.10, "Distribution Systems -

Shutdown."

ACTIONS A.1 With one or more required AC buses or motor control centers (except VIBs) in one train inoperable, the remaining AC electrical power distribution subsystems in the other trains 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 and that redundant required features are OPERABLE. The overall reliability is reduced, however, because a single failure in the remaining power distribution subsystems could result in the minimum required ESF functions not being supported.

Therefore, the required AC buses and motor control centers 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 />.

Condition A worst scenario is one train without AC power (i.e., no offsite power to the train and the associated DG inoperable). In this Condition, the unit is more vulnerable to a loss of the minimum required AC power. It is, therefore, imperative that the (continued)

INDIAN POINT 3 B 3.8.9 - 6 Revision 2

Distribution Systems - Operating B 3.8.9 BASES ACTIONS A.1 (continued) unit operator's attention be focused on minimizing the potential for loss of power to the remaining trains by stabilizing the unit, and on restoring power to the affected train. 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 of:

a.

The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected train, to the actions associated with taking the unit to shutdown within this time limit; and

b.

The potential for an event in conjunction with a single failure of a redundant component in the train with AC power.

The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, a DC bus is inoperable and subsequently restored OPERABLE, the LCO may already have been not met for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This could lead to a total of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, since initial failure of the LCO, to restore the AC distribution system. At this time, a DC circuit could again become inoperable, and AC distribution restored OPERABLE. This could continue indefinitely.

The Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This will result in establishing the time zero" at the time the LCO was initially not met, instead of the time Condition A was entered. The 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

(continued)

INDIAN POINT 3 B 3.8.9 - 7 Revision 2

I 1.

Distribution Systems - Operating B 3.8.9 BASES ACTIONS B.1 (continued)

With one VIB inoperable, the remaining OPERABLE AC vital instrument buses are capable of supporting the minimum safety functions necessary to shut down the unit and maintain it in the safe shutdown condition assuming redundant required features are inoperable.

Overall reliability is reduced, however, since an additional single failure could result in the minimum required ESF functions not being supported. Therefore, the required AC vital instrument bus must be restored to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by powering the bus from the associated inverter via inverted DC, or constant voltage transformer.

Condition B represents one VIB without power; potentially both the DC source and the associated AC source are nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of minimum required noninterruptible power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining vital instrument buses and restoring power to the affected vital instrument bus.

This 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is more conservative than Completion Times allowed for the vast majority of components that are without adequate vital instrument bus AC power. Taking exception to LCO 3.0.2 for components without adequate vital instrument bus AC power, that would have the Required Action Completion Times shorter than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> if declared inoperable, is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) and not allowing stable operations to continue;

b.

The potential for decreased safety by requiring entry into numerous Applicable Conditions and Required Actions forcomponents without adequate VIB AC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train; and (continued)

I INDIAN POINT 3 B 3.8.9 - 8 Revision 2

-~~~~isrbto Sytm prtn Distribution Systems - Operating B 3.8.9 BASES ACTIONS B.1 (continued)

c.

The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time takes into account the importance to safety of restoring the VIB to OPERABLE status, the redundant capability afforded by the other OPERABLE vital buses, and the low probability of a DBA occurring during this period.

The second Completion Time for Required Action B.1 establishes a limit on the maximum allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

This could lead to a total of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, since initial failure of the LCO, to restore the VIB distribution system.

At this time, an AC train could again become inoperable, and VIB distribution restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time 'clock." This will result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition B was entered. The 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

C.1 With one DC bus inoperable, the remaining DC electrical power distributionvsubsystems 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 and that redundant required features are OPERABLE. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystems could result in the minimum required ESF functions not being supported.

(continued)

INDIAN POINT 3 B 3.8.9 - 9 Revision 2

Distribution Systems - Operating B 3.8.9 BASES ACTIONS C.1 (continued)

Therefore, the required DC buses must be restored to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by powering the bus from the associated battery or charger.

Condition C represents one train without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. In this situation, the unit is significantly more vulnerable to a loss of minimum required DC power.

It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining trains and restoring power to the affected train.

This 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is more conservative than Completion Times allowed for the vast majority of components that would be without power.

Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, is acceptable because of:

a.

The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable operations to continue;

b.

The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train; and

c.

The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time for DC buses.-is consistent with Regulatory Guide 1.93 (Ref. 2).

The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition C is entered while, for (continued)

INDIAN POINT 3 B 3.8.9 - 10 Revision 2

Distribution Systems - Operating B 3.8.9 BASES ACTIONS C.1 (continued) instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

This could lead to a total of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, since initial failure of the LCO, to restore the DC distribution system. At this time, an AC train could again become inoperable, and DC distribution restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This will result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

D.1 and D.2 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging plant systems.

E.1 With one or more trains with inoperable distribution subsystems that result in a loss of safety function, adequate core cooling, containment OPERABILITY and other vital functions for DBA mitigation would be compromised, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

(continued)

INDIAN POINT 3 B 3.8.9 - 11 Revision 2

l Distribution Systems -

Operating B 3.8.9 BASES SURVEILLANCE REQUIREMENTS SR 3.8.9.1 This Surveillance verifies that the AC, DC, and AC vital instrument bus 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 7 day Frequency takes into account the redundant capability of the AC, DC, and AC vital instrument bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES

1.

FSAR, Chapter 14.

2.

Regulatory Guide 1.93, December 1974.

INDIAN POINT 3 B 3.8.9 - 12 Revision 2

Distribution Systems -

Operating B 3.8.9 Table B 3.8.9-1 (page 1 of 2)

AC and DC Electrical Power Distribution Systems TYPE VOLTAGE Safeguards Safeguards Safeguards Power Power Power Train 5A Train 2A/3A Train 6A (DG 33)

(DG 31)

(DG 32)

AC Electrical Power Distribution subsystems 480 V bus 5Ak bus 2A' bus 3A' MCC 36C bus 6A' MCC 36B MCC 36D5 MCC MCC MCC 36A 36E' 3116 AC vital(4) 120 V bus 31 bus 33 bus 32 bus 343 instrument bus 31A bus 33A bus 32A bus 34A3 buses (VIBs)

DC buses 125 V bus 312 bus 332 bus 322 bus 342 NOTES:

(1)

Tie breakers must and 6A.

be open between buses 5A and 2A and between buses 3A (2)

Tie breakers between DC buses must be open.

(3)

The AC Power supply to the VIB 34 and VIB 34A is supplied from MCC 36B or MCC 36C as described in the Bases for LCO 3.8.7, Inverters - Operating.

(4)

Each bus pair (e.g., 31 and 31A) constitutes a single vital instrument bus.

(5)

MCC 36D and MCC 36E are only required to meet LCO 3.8.9 when the associated DG is OPERABLE or when the MCC powers 35 Battery Charger to meet LCO 3.8.4. This is acceptable since these are the only components powered from these MCCs that support Technical Specification specified functions. Additionally, note that power from MCC 36D also supports heat detectors for the release of Fire Door FDR-30-CB, electrical thermal links for the C02 dampers, and interlocks for the exhaust fans in control (continued)

INDIAN POINT 3 B 3.8.9 - 13 Revision 2

Distribution Systems - Operating B 3.8.9 Table B 3.8.9-1 (page 2 of 2)

AC and DC Electrical Power Distribution Systems NOTES:

(continued) building areas of the Cable Spreading Room, Battery Rooms, and Switchgear Room.

These fire protection components are inoperable upon loss of power from MCC 36D (refer to Technical Requirements Manual 3.7.A.3, 3.7.A.4, and 3.7.A.7).

(6)

MCC 311 is only required to meet LCO 3.8.9 when the Main Feedwater Inlet Isolation Valves are OPERABLE since these are the only components powered from this MCC that support Technical Specification specified functions.

INDIAN POINT 3 B 3.8.9 - 14 Revision 2