Text

License Amendment Request to Address Multiple Administrative Issues with the Technical Specifications
	ML13345A686
Person / Time
Site:	Waterford
Issue date:	12/09/2013
From:	Jacobs D; Entergy Nuclear South
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	W3F1-2013-0035
	Download: ML13345A686 (46)
	v • d • e

Entergy Nuclear South Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504 739 6660 Fax 504 739 6678 djacob2@entergy.com Donna Jacobs Site Vice President - WF3 Waterford 3 W3F1-2013-0035 December 9, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

License Amendment Request to Address Multiple Administrative Issues with the Technical Specifications Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests an amendment for the Waterford Steam Electric Station Unit 3 (Waterford 3) Technical Specifications (TS) to improve clarity, correct administrative and typographical errors, or establish consistency with NUREG-1432, Standard Technical Specifications Combustion Engineering Plants, Revision 4.0 (NUREG-1432). This includes two technical changes. The proposed changes are as follows:

TS 3.3.1, Reactor Protective Instrumentation, Table 3.3-1, Actions 6a and 6b, revision to improve clarity and consistency with NUREG-1432; TS 3.1.3.5, Shutdown CEA Insertion Limit, Applicability, revision to correct an administrative error; TS 3.3.2, Engineered Safety Features Actuation System Instrumentation, Table 3.3-3 reference to Actions 19a*, 19b, 20 revision to correct an administrative error in the numbering of Actions; TS 3.3.3.1, Radiation Monitoring Instrumentation, Table 3.3-6, Action 27 and Action 28, revision to improve clarity;

TS 3.3.3.6, Accident Monitoring Instrumentation, Table 3.3-10, Action 29, revision to correct a typographical error; TS 3.3.3.11, Explosive Gas Monitoring Instrumentation, Action b, revision to improve clarity;

W3F1-2013-0035 Page 2 of 3 TS 4.8.2.1, D.C. Sources, Surveillance Requirement c.3 add a provision to an existing surveillance test that limits the total battery inter-cell resistance to maintain battery terminal voltage above the required operating voltage.

TS 6.1, Responsibility, revision to update the position title for the Shift Manager and Site Vice President - WF3; TS 6.2.1, Offsite and Onsite Organizations, revision to update the position title for the Site Vice President - WF3; TS 6.2.2, Unit Staff, revision to update the position title for the Operations Manager - Shift; and TS 6.12, High Radiation Area, revision to update the position title for the Radiation Protection Manager.

The proposed changes have been evaluated in accordance with 10 CFR 50.91(a)(1) using the criteria in 10 CFR 50.92(c), and it has been determined that the changes involve no significant hazards consideration. The bases for these determinations are included in Attachment 1.

The proposed changes include no new commitments.

Once approved, the amendment will be implemented within 90 days.

If you have any questions or require additional information, please contact the Regulatory Affairs Manager, John Jarrell, at 504-739-6685.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 9, 2013.

Sincerely, DJ/RJP Attachments:

1. Description and Justification of Proposed Technical Specification Changes

2. Proposed Technical Specification Changes (mark-up)

3. Proposed Technical Specification Changes (clean copy)

W3F1-2013-0035 Page 3 of 3 cc: Mr. Steven A. Reynolds RidsRgn4MailCenter@nrc.gov Regional Administrator, Acting U. S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.

Arlington, TX 76011-4511 NRC Senior Resident Inspector Marlone.Davis@nrc.gov Waterford Steam Electric Station Unit 3 Cristopher.Speer@nrc.gov P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Kalv.Kalvanam~nrc.oov Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Louisiana Department of Environmental Quality Ji.Wiley@LA.gov Office of Environmental Compliance Surveillance Division P. O. Box 4312 Baton Rouge, LA 70821-4312

Attachment 1 to W3FI-2013-0035 Description and Justification of Proposed Technical Specification Changes

W3F1-2013-0035 Page 1 of 16

1.0 DESCRIPTION

OF PROPOSED TECHNICAL SPECIFICATION CHANGES This letter contains a request to amend the Technical Specifications (TS) for Operating License No. NPF-38 for Waterford Steam Electric Station Unit 3 (Waterford 3) (Reference 4.1).

The proposed TS changes listed below and shown in Attachments 2 and 3 were identified in the Waterford 3 Corrective Action Program as opportunities to improve clarity, correct administrative and typographical errors, and establish consistency with NUREG-1 432, Combustion Engineering Standard Technical Specifications, Revision 4.0, dated April 2012 (Reference 4.2). This includes two technical changes.

1. TS 3.3.1, Reactor Protective Instrumentation, Table 3.3-1, Functional Unit 15, Control Element Assembly Calculators (CEAC):

a. Table 3.3-1, Action 6.a, specifies that "With one CEAC inoperable, operation may continue for up to 7 days provided that at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , each CEA is verified to be within 7 inches (indicated position) of all other CEAs in its group."

Entergy is proposing to revise Action 6.a to add the clarification "After 7 days, operation may continue provided that Actions 6.b.1, 6.b.2, and 6.b.3 are met."

b. Table 3.3-1, Action 6.b.1, specifies that "With both CEACs inoperable, operation may continue provided that "Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months the DNBR margin required by Specification 3.2.4b (COLSS [Core Operating Limit Supervisory System] in service) or 3.2.4d (COLSS out of service) is satisfied and the Reactor Power Cutback System is disabled."

Entergy is proposing to revise Action 6.b.1 to extend the Completion Time for verification that the DNBR limit is satisfied and the Reactor Power Cutback System is disabled from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months consistent with NUREG-1422.

2. TS 3.1.3.5, Shutdown CEA [Control Element Assembly] Insertion Limit, requires that all shutdown CEAs be withdrawn to greater than or equal to 145 inches, with an APPLICABILITY of Modes 1 and 2*#** where:

See Special Test Exception 3.10.2.

With Keff greater than or equal to 1.0.

- Except for surveillance testing pursuant to Specification 4.1.3.1.2.

W3F1-2013-0035 Page 2 of 16 Entergy is proposing to revise the APPLICABILITY to Modes 1** and 2*#** to clarify that entry into Actions for LCO 3.1.3.5 is not required in Mode 1 when performing Surveillance Requirement 4.1.3.1.2, verification that each CEA is trippable, which is required every 92 days.

3. TS 3.3.2, Engineered Safety Features Actuation System Instrumentation, Table 3.3-3, requires entry into Actions 19a*, 19b, 20 (where

indicates that Specification 3.0.4 is not applicable) for an inoperable channel for the following Safety Injection System Sump Recirculation Actuation Signals:

5.b Refueling Water Storage Pool - Low; 7.b Steam Generator Level (1/2) - Low and AP (1/2) - High; and, 7.c Steam Generator Level (1/2) - Low and No Steam Generator Pressure - Low Trip (1/2).

Entergy is proposing to revise TS 3.3.2 to require entry into Actions 19 and 20 when one or more channels of Functions 5.b, 7.b, or 7.c are inoperable.

This change provides explicit recognition that all of Action 19 is required.

4. TS 3.3.3.1, Radiation Monitoring Instrumentation, LCO 3.3.3.1 requires entry into Actions specified in Table 3.3-6 if one or more radiation monitoring channels are inoperable.

Action 27 applies if one or more Effluent Accident Monitors are inoperable.

Action 27 includes a requirement that "If the monitor is not restored to OPERABLE status within 7 days after the failure, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 14 days following the event outlining the action..." Entergy is proposing to revise TS 3.3.3.1, Table 3.3-6, Action 27, to use the phrase "after the failure" instead of "following the event" to clarify that the 7 day constraint and 14 day constraint both start at the failure of the instrument.

Action 28 applies if one or more process radiation monitors are inoperable.

Action 28 is divided into two paragraphs: paragraph one specifies that operation of the plant may continue "for up to 30 days" provided grab samples are taken; and, paragraph two specifies that if the monitor is not restored to OPERABLE status within 30 days after the failure, continue sampling and prepare and submit Special Report "within 14 days."

W3F1 -2013-0035 Page 3 of 16 Entergy is proposing to revise paragraph one of Action 28 to delete the phrase "for up to 30 days" because paragraph two of the Action allows operation of the plant to continue beyond 30 days if the Special Report described in paragraph two is submitted.

Entergy is proposing to revise paragraph two of Action 28 to insert the words "the next" into the phrase "within 14 days" so that it will read "within the next 14 days" to clarify that the 14 day constraint only begins "If the monitor is not restored to OPERABLE status within 30 days after the failure."

5. TS 3.3.3.6, Accident Monitoring Instrumentation, Table 3.3-10, Action 29, includes a requirement for submission of a Sepcial (sic) Report.

Entergy is proposing to revise TS 3.3.3.6, Table 3.3-10, Action 29, to correct the spelling of the word "Special."

6. TS 3.3.3.11, Explosive Gas Monitoring Instrumentation, Action b, requires restoration of an inoperable instrument "to OPERABLE status within 30 days and, if unsuccessful, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 to explain why this inoperability was not corrected in a timely manner." There is no specified time frame for preparation and submittal of a special report to the Commission in this action statement.

Entergy is proposing to revise TS 3.3.3.11, Action b, to specify that the submittal of the special report is due within the next 14 days following expiration of the 30 day inoperable period.

7. TS 4.8.2.1, D.C. Sources, Surveillance Requirement c.3 indicates that at least once per 18 months each 125-volt battery bank shall be demonstrated operable by determining that the resistance of each cell-to-cell and terminal connection is less than or equal to 150 x 10-6 ohms. This surveillance requirement by itself does not ensure the battery is demonstrated operable.

This is because of the number of connections on the battery. If each connection's resistance were equal to 150 x 10-6 ohms, the total battery resistance would exceed a value that would maintain battery terminal voltage above its required operating voltage.

W3F1-2013-0035 Page 4 of 16 Entergy is proposing to add a provision to the surveillance indicating that the total battery inter-cell resistance value that maintains the battery terminal voltage above the required operating voltage of the emergency loads also needs to be met. The provision includes a programmatic requirement to establish a limit on the total battery inter-cell resistance using design calculations and to document results in test procedures.

8. TS 6.1, Responsibility, indicates the Vice President Operations is responsible for issuing an annual management directive assigning the control room command function responsibility and includes reference to the command function of the Shift Superintendent. The title of the Vice President Operations has changed to Site Vice President - WF3. The title of the Shift Superintendent was previously changed to Shift Manager as reflected in TS Table 6.2-1.

Entergy is proposing to revise TS 6.1 to use the titles Site Vice President -

WF3 and Shift Manager.

9. TS 6.2.1, Offsite and Onsite Organizations, indicates the Vice President Operations has corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety. The title of the Vice President Operations has changed to Site Vice President - WF3.

Entergy is proposing to revise TS 6.2.1 to use the title Site Vice President -

WF3.

10. TS 6.2.2, Unit Staff, indicates that the Operations Manager or the Assistant Operations Manager (Shift) shall hold a senior reactor operator license. The title for the Assistant Operations Manager (Shift) has changed.

Entergy is proposing to revise TS 6.2.2 to change: the title of the Assistant Operations Manager (shift) to Operations Manager - Shift.

W3F1-2013-0035 Page 5 of 16

11. TS 6.12, High Radiation Area, uses the title "Radiation Protection Superintendent - Nuclear" for the position described in Regulatory Guide (RG) 1.8, Personnel Selection and Training, Revision 1, September 1975 (Reference 4.3) as the Radiation Protection Manager.

Entergy is proposing to revise TS 6.12 to use the title Radiation Protection Manager consistent with RG 1.8 and the title used in Waterford 3 Updated Final Safety Analysis Report (UFSAR), Section 12.5.1.1.

2.0 JUSTIFICATION FOR PROPOSED CHANGES The following provides a justification for each of the proposed changes to the Waterford 3 Technical Specifications:

1. TS 3.3.1, Reactor Protective Instrumentation, Table 3.3-1, Functional Unit 15, Control Element Assembly Calculators (CEAC):

The Control Element Assembly Calculators are designed to detect misaligned CEAs and adjust reactor trip setpoints by applying a penalty factor to the core protection calculators if a misaligned CEA could adversely affect core power distribution. Only one CEAC is required to perform the safety function but two are required to be Operable to allow for a single failure of a CEAC.

The Waterford 3 design for CEACs matches the design features described in the Bases for LCO 3.3.3A, Control Element Assembly Calculators (CEACs) in NUREG-1432. Accordingly, the Waterford 3 Technical Specifications for Table 3.3-1, Functional Unit 15, CEACs, are equivalent to the requirements established in NUREG-1432, LCO 3.3.3A, with two differences.

The first difference in TS requirements for CEACs between Waterford 3 TS and NUREG-1432 occurs when one CEAC is inoperable longer than the allowable out of service time of 7 days. NUREG-1432, LCO 3.3.3A, Condition B, explicitly allows plant operation to continue indefinitely if the Actions for both CEACs inoperable are entered if one CEAC has been inoperable for more than 7 days. Waterford 3 TS 3.3.1, Table 3.3-1, Functional Unit 15, Action 6.b, allows plant operation to continue indefinitely with both CEACs inoperable if the specified Actions are entered; however, Table 3.3-1, Functional Unit 15, Actions 6.a and 6.b, do not include an explicit statement that allows plant operation to continue indefinitely when one CEAC is inoperable if the Actions for two inoperable CEACs are entered.

To improve clarity, Entergy proposes revising Table 3.3-1, Functional Unit

W3F1 -2013-0035 Page 6 of 16 15, Action 6.a, to add the statement "After 7 days, operation may continue provided that Action 6.b.1, 6.b.2, and 6.b.3 are met," consistent with the presentation of requirements in NUREG-1432, LCO 3.3.3A.

This change is needed to establish explicit direction for the Actions needed to allow plant operation to continue indefinitely when one CEAC is inoperable longer than the allowable out of service time of 7 days. This change is acceptable because Actions that have been determined to be sufficient to allow plant operation to continue indefinitely with both CEACs inoperable are sufficient to allow plant operation to continue indefinitely with only one CEAC inoperable. Additionally, the Completion Time of once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is adequate based on operating experience, considering the low probability of an undetected CEA deviation coincident with an undetected failure in the remaining CEAC within this limited time frame. Therefore, this change is acceptable.

The second difference between the requirements for CEACs in Waterford TS and NUREG-1432, LCO 3.3.3A, involves the Completion Time for verifying that the departure from nucleate boiling ratio (DNBR) limit is met and disabling the Reactor Power Cutback when either both CEACs are inoperable or one CEAC has been inoperable longer than 7 days.

Waterford 3 Technical Specification Table 3.3-1, Action 6.b.1 requires that these Actions be completed within one hour; whereas, NUREG-1 432, LCO 3.3.3A, Action B.1, allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to complete the same actions under the same Conditions.

Actions associated with this Condition involve disabling the Control Element Drive Mechanism Control System (CEDMCS), while providing increased assurance that CEA deviations are not occurring and informing all OPERABLE CPC channels, via a software flag, that both CEACs are failed.

This will ensure that the large penalty factor associated with two CEAC failures will be applied to CPC calculations. The penalty factor for two failed CEACs is sufficiently large that power must be maintained significantly

< 100% RTP if CPC generated reactor trips are to be avoided. Meeting the DNBR margin requirements ensures that power level and ASI are within a conservative region of operation based on actual core conditions. In addition to the above actions, the Reactor Power Cutback System must be disabled.

This ensures that CEA position will not be affected by Reactor Power Cutback operation.

Entergy is proposing to revise Table 3.3-1, Functional Unit 15, Action 6.b.1, to extend the Completion Time for verifying that the departure from nucleate boiling ratio (DNBR) limit is met and disabling the Reactor Power Cutback from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This change is needed to provide operators

W3F1-2013-0035 Page 7 of 16 additional time to assess the situation and perform the required activities in a controlled manner consistent with the risk associated with an inoperable CEAC function.

A 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time for these Actions is consistent with the Completion Time in NUREG-1432, LCO 3.3.3A, Action B.1, for the same Actions under the same Condition. This change is acceptable because the Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is adequate to accomplish the actions discussed above while minimizing risks. Therefore, this change is acceptable.

2. TS 3.1.3.5, Shutdown CEA Insertion Limit, Applicability:

LCO 3.1.3.1, which is applicable in Modes 1 and 2, requires that all CEAs are Operable. To verify CEA Operability, LCO 3.1.3.1 requires performance of Surveillance Requirement (SR) 4.1.3.1.2 every 92 days which requires moving each control rod at least 5 inches. LCO 3.1.3.5, which is also Applicable in Modes 1 and 2, requires that all shutdown CEAs remain withdrawn greater than or equal to 145 inches.

Performance of SR 4.1.3.1.2 (i.e., moving control rods at least 5 inches) may result in LCO 3.1.3.5 (i.e., all shutdown CEAs must be withdrawn to > 145 inches) not being met for very short periods of time as each CEA is moved and restored to its original position. Unless an explicit allowance for performance of SR 4.1.3.1.2 is provided, momentary entry into the Actions for LCO 3.1.3.5 could be required when SR 4.1.3.1.2 is performed on each of the shutdown CEAs.

The current Applicability for LCO 3.1.3.5 is "Modes 1 and 2*#**" where:

See Special Test Exception 3.10.2.

With Keff greater than or equal to 1.0.

- Except for surveillance testing pursuant to Specification 4.1.3.1.2.

As shown, the current Applicability for LCO 3.1.3.5 provides an explicit exemption for performance of SR 4.1.3.1.2 when in Mode 2; however, due to an administrative error, the same exemption was not provided for Mode 1.

Entergy is proposing to revise the Applicability for LCO 3.1.3.5 to correct this administrative error by providing an explicit exemption to LCO 3.1.3.5 when performing SR 4.1.3.1.2 in Mode 1. The proposed Applicability is "Mode 1** and 2*#**", which would extend the existing exemption for the performance of SR 4.1.3.1.2 to include Mode 1.

W3F1 -2013-0035 Page 8 of 16 This change is needed to provide explicit recognition that entry into the Actions for LCO 3.1.3.5 is not warranted or required if a shutdown CEA is momentarily inserted past the LCO 3.1.3.5 insertion limit by approximately 5 inches and then immediately withdrawn as part of a routine verification of CEA operability as required by SR 4.1.3.1.2. This change is acceptable because momentary insertion of individual CEAs past the LCO 3.1.3.5 insertion limit by approximately 5 inches does not have a significant effect on core power distribution, shutdown margin, ejected CEA worth, or initial reactivity insertion rate during a reactor trip. Additionally, the proposed exemption to LCO 3.1.3.5 for the performance of SR 4.1.3.1.2 is consistent with a similar exemption provided in NUREG-1 432, Section 3.1.5 APPLICABILITY. Therefore, this change is acceptable.

3. TS 3.3.2, Engineered Safety Features Actuation System Instrumentation, Table 3.3-3, Actions 19a*, 19b, 20 (* indicates Specification 3.0.4 is not applicable) for functions:

5.b Refueling Water Storage Pool - Low; 7.b Steam Generator Level (1/2) - Low and AP (1/2) - High; and 7.c Steam Generator Level (1/2) - Low and No Steam Generator Pressure - Low Trip (1/2).

TS 3.3.2, Table 3.3-3, specifies entry into Actions 19a*, 19b, 20 (* indicates Specification 3.0.4 is not applicable) when a channel for Function 5.b, 7.b or 7.c is inoperable. However, the sequence of Actions described in 19 and 19a and the formatting of Actions 19 and 19a indicate that entry into Action 19 is both intended and necessary before Action 19a can or should be initiated.

Specifically, Action 19 specifies that "With the number of channels OPERABLE one less than the Total Number of Channels, [operation] may continue, provided the inoperable channel is placed in the bypassed or tripped condition within 1 hour:"

Below the colon at the end of Action 19 and indented, Action 19a specifies "If the inoperable channel is to remain in the bypassed condition, the desirability of maintaining this channel in the bypassed condition shall be documented by the On-Site Safety Review Committee in accordance with plant administrative procedures. The channel shall be returned to OPERABLE status no later than prior to entry into the applicable MODE(S) following the next COLD SHUTDOWN."

W3F1-2013-0035 Page 9 of 16 Entergy is proposing to revise the Actions for TS 3.3.2, Table 3.3-3, Functions 5.b, 7.b and 7.c, from "19a*, 19b, 20" to "19 and 20." This change is needed to correct an error that omitted Action 19 from the list of Actions for these Functions. This change is acceptable because it explicitly identifies the sequence of actions required when a channel for Function 5.b, 7.b or 7.c is inoperable.

4. TS 3.3.3.1, Radiation Monitoring Instrumentation, Table 3.3-6, Action 27 and Action 28:

Action 27 applies if one or more Effluent Accident Monitors are inoperable.

Action 27 includes a requirement that "Ifthe monitor is not restored to OPERABLE status within 7 days after the failure, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 14 days following the event outlining the action..." Entergy is proposing to revise TS 3.3.3.1, Table 3.3-6, Action 27, to use the phrase "after the failure" instead of "following the event" to clarify that the 7 day constraint and 14 day constraint both start at the failure of the monitor.

Action 28 applies if one or more Process Monitors are inoperable. Action 28 is divided into two paragraphs: paragraph one specifies that operation of the plant may continue "for up to 30 days" provided grab samples are taken; and, paragraph two specifies that if the monitor is not restored to OPERABLE status within 30 days after the failure, continue sampling and prepare and submit a Special Report "within 14 days." Entergy is proposing to revise paragraph one of Action 28 to delete the phrase "for up to 30 days" because paragraph two of the Action allows operation of the plant to continue beyond 30 days if the Special Report described in paragraph two is submitted.

Entergy is also proposing to revise paragraph two of Action 28 to insert the words "the next" into the phrase "within 14 days" so that it reads "within the next 14 days" to clarify that the 14 day constraint only begins "If the monitor is not restored to OPERABLE status within 30 days after the failure."

These changes are administrative and are acceptable because there are no changes to the requirements when an Effluent Accident Monitor or Process Monitor is inoperable. Therefore, these changes are acceptable.

W3F1`-2013-0035 Page 10 of 16

5. TS 3.3.3.6, Accident Monitoring Instrumentation, Table 3.3-10, Action 29:

TS 3.3.3.6, Accident Monitoring Instrumentation, Table 3.3-10, Action 29, includes a requirement for submission of a Sepcial (sic) Report.

Entergy is proposing to revise TS 3.3.3.6, Table 3.3-10, Action 29, to correct the spelling of the word "Special."

This change is needed and is acceptable because it corrects a typographical error.

6. TS 3.3.3.11, Explosive Gas Monitoring Instrumentation, Action b, requires restoration of an inoperable instrument "to OPERABLE status within 30 days and, if unsuccessful, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 to explain why this inoperability was not corrected in a timely manner." There is no specified time frame for preparation and submittal of a special report to the Commission in this action statement.

Entergy is proposing to revise TS 3.3.3.11, Action b, to specify that the submittal of the special report is due within the next 14 days following expiration of the 30 day inoperable period.

This change is acceptable in that it provides a schedule for submitting the report that matches the schedule for submitting special reports from similar TS action requirements. This change is adding more specific reporting parameters than currently exists and improves the TS.

7. TS 4.8.2.1, D.C. Sources, Surveillance Requirement c.3 indicates that at least once per 18 months each 125-volt battery bank shall be demonstrated operable by determining that the resistance of each cell-to-cell and terminal connection is less than or equal to 150 x 106 ohms. This surveillance requirement by itself does not ensure the battery is demonstrated operable.

This is because of the number of connections on the battery. If each connection's resistance were equal to 150 x 10-6 ohms, the total battery resistance would exceed a value that would maintain battery terminal voltage above its required operating voltage. The required operating voltage is determined by the most limiting load's voltage requirement.

W3F1-2013-0035 Page 11 of 16 Entergy is proposing to add a provision to the surveillance indicating that the total battery inter-cell resistance value that maintains the battery terminal voltage above the required operating voltage of the emergency loads also needs to be met. The provision includes a programmatic requirement to establish a limit on the total battery inter-cell resistance using design calculations and to document results in test procedures. The value for the total resistance will be reflected in the surveillance procedure and documented. The basis for the value in the surveillance procedure will be determined by calculation using the most limiting load's voltage requirement.

8. TS 6.1, Responsibility, indicates the Vice President Operations is responsible for issuing an annual management directive assigning the control room command function responsibility and includes reference to the command function of the Shift Superintendent. The title of the Vice President Operations has changed to Site Vice President - WF3. The title of the individual previously using the title of Shift Superintendent has changed to Shift Operations Manager.

Entergy is proposing to revise TS 6.1 to use the title Site Vice President -

WF3 and Shift Operations Manager.

This change is needed because it updates the Technical Specifications to match the titles recently given to the Vice President (VP) position and Shift Operations Manager at Waterford 3. The change is acceptable because it only revises the names that the VP and Shift Operations Manager positions are called. There is no change in the management position responsible for issuing the directive. There is no change in the management position previously called the Shift Manager that affects the administrative control requirements of the Technical Specifications.

9. TS 6.2.1, Offsite and Onsite Organizations indicates the Vice President Operations has corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety. The title of the Vice President Operations has changed to Site Vice President - WF3.

Entergy is proposing to revise TS 6.2.1 to use the title Site Vice President -

WF3.

W3F1-2013-0035 Page 12 of 16 This change is needed because it updates the Technical Specifications to match the title recently given to the Vice President (VP) position at Waterford

3. The change is acceptable because it only revises the name that the VP position is called. There is no change in the management position having corporate responsibility for overall plant nuclear safety and taking any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

10. TS 6.2.2, Unit Staff, indicates that the Operations Manager or the Assistant Operations Manager (Shift) shall hold a senior reactor operator license.

Entergy is proposing to revise TS 6.2.2 to change the title of the Assistant Operations Manager (shift) to Operations Manager - Shift.

This change is needed because it updates the Technical Specifications to address a title change to this position that has recently occurred that removed the term "assistant." The change is acceptable because it only revises the name that the manager position is called. There is no change that affects the administrative control requirements of the Technical Specifications.

11 .TS 6.12, High Radiation Area uses the title "Radiation Protection Superintendent-Nuclear" for the position described in Regulatory Guide (RG) 1.8 as the "Radiation Protection Manager."

Entergy is proposing to revise TS 6.12 to update the title "Radiation Protection Superintendent-Nuclear" to "Radiation Protection Manager" consistent with the title used in the Waterford 3 Final Safety Analysis Report (FSAR) (Reference 4.4), Section 12.5.1.1, and the commonly used title at the site and in procedures.

This change is needed and is acceptable because it updates the Technical Specifications to match the title used in Waterford 3 FSAR, Section 12.5.1.1, and the title used at the site and in site and corporate procedures for the position identified in Regulatory Guide 1.8 as the Radiation Protection Manager. Therefore, this change is acceptable.

W3F1-2013-0035 Page 13 of 16

3.0 REGULATORY ANALYSIS

3.1 Applicable Regulatory Requirements/Criteria An evaluation by Waterford 3 has determined that the proposed changes do not require any exemptions or relief from regulatory requirements and do not affect conformance to any 10 CFR 50, Appendix A, General Design Criteria, as described in the Updated Final Safety Analysis Report (UFSAR).

3.2 No Significant Hazards Consideration Waterford 3 evaluated whether a significant hazards consideration is created by the proposed amendments to the Waterford 3 Technical Specifications.

This evaluation addressed each of the three criteria set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes revise the Technical Specifications to improve clarity, correct administrative and typographical errors, and establish consistency with NUREG-1432. This includes two technical changes.

A provision to an existing surveillance test has been added that limits the total battery inter-cell resistance to maintain battery terminal voltage above the required operating voltage. A change to limit the total battery inter-cell resistance has no effect on the probability of an accident previously evaluated. The proposed change to limit the total battery inter-cell resistance does not involve a significant increase in the consequences of an accident previously evaluated. This is because the addition of this limit will ensure that the battery is demonstrated as capable to meet its safety function.

The other technical change extends the Completion Time from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for verifying that the departure from nucleate boiling ratio (DNBR) limit is met and disabling the Reactor Power Cutback when one or both CEACs are inoperable. A change to the Completion Time for Actions in response to inoperable equipment has no effect on the probability of an accident previously evaluated. The proposed change to the Completion Time for Actions in response to inoperable equipment does not involve a significant increase in the consequences of an accident previously evaluated. This is because the safety function of a CEAC is to identify

W3F1 -2013-0035 Page 14 of 16 and compensate for a misaligned CEA, and there is a low probability of occurrence during the four hour Completion Time that one or more misaligned CEAs could significantly adversely affect: core power distribution, shutdown margin, ejected CEA worth, or initial reactivity insertion rate during a reactor trip.

Consequently, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes revise the Technical Specifications to improve clarity, correct administrative and typographical errors, and establish consistency with NUREG-1432. This includes two technical changes.

A provision to an existing surveillance test has been added that limits the total battery inter-cell resistance to maintain battery terminal voltage above the required operating voltage. A change to limit the total battery inter-cell resistance does not create the possibility of a new or different kind of accident from any accident previously evaluated. This is because the addition of this limit will ensure that the battery is demonstrated as capable to meet its existing safety function and does not change the safety function in any manner.

The other technical change extends the Completion Time from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for verifying that the departure from nucleate boiling ratio (DNBR) limit is met and disabling the Reactor Power Cutback when one or both CEACs are inoperable. A change to the Completion Time for Actions in response to inoperable equipment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Consequently, the proposed changes do not create the possibility of a new or different kind of accident.

W3FI-2013-0035 Page 15 of 16

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No.

The proposed changes revise the Technical Specifications to improve clarity, correct administrative and typographical errors, and establish consistency with NUREG-1 432. This includes two technical changes.

A provision to an existing surveillance test has been added that limits the total battery inter-cell resistance to maintain battery terminal voltage above the required operating voltage. A change to limit the total battery inter-cell resistance does not involve a~significant reduction in a margin of safety. This is because the addition of this limit will ensure that the battery is demonstrated as having margin to meet its safety function.

The other technical change extends the Completion Time from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for verifying that the departure from nucleate boiling ratio (DNBR) limit is met and disabling the Reactor Power Cutback when one or both CEACs are inoperable. A change to the Completion Time for Actions in response to inoperable equipment does not affect protection criterion for plant equipment and does not reduce the margin of safety. This change provides Operators time to assess and perform the required activities in a controlled manner consistent with the risk associated with an inoperable CEAC function. Actions associated with this Condition involve disabling the Control Element Drive Mechanism Control System (CEDMCS), and signaling all OPERABLE CPC channels that both CEACs are failed. This applies a large penalty factor associated with two CEAC failures within CPC calculations. The penalty factor for two failed CEACs is sufficiently large that power must be maintained significantly < 100% Reactor Thermal Power. The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is adequate to accomplish these actions while minimizing risks. Meeting the DNBR margin requirements ensures that power level and ASI are within a conservative region of operation based on actual core conditions. In addition to the above actions, the Reactor Power Cutback System is disabled. This ensures that CEA position will not be affected by Reactor Power Cutback operation.

Consequently, there is no significant reduction in a margin of safety due to the proposed changes.

W3F1 -2013-0035 Page 16 of 16 3.3 Environmental Considerations The proposed amendments do not change any requirements with respect to the installation of or use of a facility component located within the restricted area, as defined in 10 CFR 20, or change any inspection or surveillance requirement. The proposed amendment does not involve: (i) a significant hazards consideration; (ii) a significant change in the types or significant increase in the amount of any effluent that may be released offsite; or, (iii) a significant increase in individual or cumulative occupational exposure.

Accordingly, the proposed amendments meet the criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

4.0 REFERENCES

4.1 Technical Specifications, Waterford Steam Electric Station, Unit 3, Facility Operating License No. NPF-38, Docket No. 50-382. Amendment No. 203.

4.2 NUREG-1432, Combustion Engineering Standard Technical Specifications, Revision 4.0, dated April 2012.

4.3 Regulatory Guide 1.8, Personnel Selection and Training, Revision 1, September 1975 (and later) 4.4 Updated Final Safety Analysis Report (UFSAR), Waterford Steam Electric Station, Unit 3, Facility Operating License No. NPF-38.

Attachment 2 to W3F1-2013-0035 Proposed Technical Specification Changes (mark-up)

W3F1 -2013-0035 Page 1 of 12 TS 3.3.1, Reactor Protective Instrumentation, Table 3.3-1, Functional Unit 15, Control Element Assembly Calculators (CEAC)

(Page 1 of 2)

TABLE 3.3-1 (Continued)

ACTION STATEMENTS

2. Pressurizer Pressure - Pressurizer Pressure - High High Local Power Density - High DNBR - Low

3. Containment Pressure - Containment Pressure - High (RPS) High Containment Pressure - High (ESF)

4. Steam Generator Steam Generator Pressure - Low Pressure - Low Steam Generator AP 1 and 2 (EFAS 1 and 2)

5. Steam Generator Level Steam Generator Level.- Low Steam Generator AP (EFAS)

6. Core Protection Local Power Density - High Calculator DNBR - Low

7. Logarithmic Power Logarithmic Power Level - High Local Power Density - High 01 DNBR - Low t" Reactor Coolant Flow - Low 1)

STARTUP and/or POWER OPERATION may continue until the performance of the next required CHANNEL FUNCTIONAL TEST. Subsequent STARTUP and/or POWER OPERATION may continue.if one channel is restored to OPERABLE status and the provisions of ACTION 2 are satisfied.

ACTION 4 - With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, suspend all operations involving positive reactivity changes.

ACTION 5 - With the number of channels OPERABLE one less those required by the Minimun.Channels OPERABLE requirement, STARTUP and/or POWER OPERATION may continue provided the reactor trip breakers of the inoperable channel are placed in~the. tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ; otherwise, be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for surveillance testing per Specification 4.3.1.1.

ACTION 6 - a. With one CEAC inoperable, operation may-continue for.up to 7 days provided that at least once per. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , each CEA is verified to be within 7 inches. (indicated.position) of all other CEAs in.its group-,

Limited plant cooldown or boron. dilution is allowed provided the change is acc unted for in the calculated SHUTDOWN MARGIN.

I After 7 days, operation may 01 With the operating bypass enabled. continue provided that Actions 6.b.1,6.b.2, and 6.b.3 are met.

WATERFORD - UNIT 3 3/4 3-6. AMENDMENT NO. ,., "8

W3F1 -2013-0035 Page 2 of 12 TS 3.3.1, Reactor Protective Instrumentation, Table 3.3-1, Functional Unit 15, Control Element Assembly Calculators (CEAC)

(Page 2 of 2)

TABLE 3.3-1 (Continued)

ACTION STATEMENTS

b. With both CEACs inoperable, operation may continUe provided that:

1. Within 14ietii'the DNBR margin required by Specification 3.2.4b (COLSS in service) or 3.2.4d (COLSS out of service) is satisfied and the Reactor:

Power Cutback System is disabled, and

2. Within 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months s:

a) All CEA groups are withdrawn to and subsequently maintained at the "Full Out" position, except during surveillance testing pursuant to the requirements of Specification 4.1.3.1.2 or for control when CEA group 6 may be inserted no further than, 127.5 inches withdrawn.

b) The "RSPT/CEAC Inoperable" addressable constant in the CPCs is set to the inoperable status.

c) The Control Element Drive Mechanism Control System (CEDMCS) is placed in and subsequently maintained in the "Off' mode except during CEA group 6motion permitted by a) above, when the CEDMCS may be operated in eitherthe "Manual Group" or "Manual Individual" mode.

3. At least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , all CEAs.are verified fully withdrawn except during surveillance testing pursuant to Specification 4.1.3.1.2 or during insertion of CEA group 6 as permitted by 2.a) above, then verify at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months that the inserted CEAs are aligned within 7 inches (indicated position) of all other CEAs in its group.

ACTION 7 - With three or more auto restarts of one. non-bypassed calculator during a 12-hour interval, demonstrate calculator OPERABILITY by performing a CHANNEL FUNCTIONALTEST within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 8 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirementrestore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or open the reactortrip breakers within the next hour.

WATERFORD - UNIT 3 3/4 3-7 AMENDMENT NO. 5, 182,185

W3F1 -2013-0035 Page 3 of 12 TS 3.1.3.5, Shutdown CEA Insertion Limit, Applicability (Page 1 of 1)

REACTIVITY CONTROL SYSTEMS SHUTDOWN CEA INSERTION LIMIT LIMITING CONDITION FOR OPERATION 3.1.3.5 All shutdown cEAs shall be withdrawn to greater than or equal to 145 inches.

APPLICABILITY: MODES -and 2*#**.

ACTION::

With a maximum of one shutdown CEA withdrawn to less than 145 inches withdrawn, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either:

a. Withdraw the CEA to greater than or equal to 145 inches, or

b. Declare the CEA inoperable and determine that the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; SURVEILLANCE REQUIREMENTS 4.1.3.5 Each shutdown CEA shall be.de~termine~d to be withdrawn to greater than or equal to 145 inches withdrawn:

a. Within 15 minutes prior to withdrawal of any CEAs in. regulating groups or group P during an approach to reactor criticality, and

b. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter.

See Special Test Exception 3.10.2.

With Keff greater than or equal to 1.0.

-Except for surveillance testing pursuant to Specification .4.1.3.1.2.

WATERFORD - UNIT 3 3/4.1-24 AMENDMENT NO. 182

3.3-T(

NATLEI[ C O CD 0 -n ENGIEERED SAFETY FEATURE.S ACTUIATION SYSTEM-IN~STR1JMENTATh2N MINIMUM 0) :3 TOTAL NO. CHANNELS CHANNELS APPLICABLE EUNiCTIONALUJNIT OF CHANNELS IO-TRIP OPERABLE ACIION m

X1

"* 4. MAIN STEAM LINE ISOLATION 1,2,3 CD C) o a. Manual (Trip 2 sets of 1 set of 2 sets of 16 w~

CD 0Buttons) 2 per steam 2 per steam 2 per operat-generator generator Ing steam z generator 4/steam 1,2,3 6- 2/steam 3/steam 13, 14" Pressure - Low generator generator generator 1,2,3 CD

c. Containment Pressure - 4 2 3 13". 14" High >0) 1,2,3

d. Automatic Actuation 4 2 3 12 Co'<

Logic (0 0 C:

C.,, 5, SAFETY INJECTION SYSTEM (D =. @

0'I SUMP RECIRCULATION (RAS) =) Cl,

a. Manual RAS (Trip 0OCn >

Buttons) 2 I 2 1,2,3,4 12 hI -- L 0

b. Refueling Water Storage Pool - Low 4 2 3 1,2,3,4 199% 49b 20

c. Automatic Actuation Logic 4 2 3 1,2,3,4 12 1<

6. LOSS OF POWER (LOV)

a. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage) 3/bus 3/bus 3/bus 1,2.3 17, 18 Cl, z b. 480 V Emergency Bus 0 CD Undervoltage (Loss of Voltage) 3/bus 3/bus 3/bus 1.2,3 17. 18

t, 0)

c. 4.16 kV Emergency Z Bus Undervoltage (Degraded Voltage) 3/bus 3/bus 3/bus 1.2.3 17.18

C-A)

CD 0)

Cl) 01 0 CD TABLE 3.3-3 (Continued) 0 INQC-.0 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION C-.

MINIMUM TOTAL NO. CHANNELS CHANNELS APPLICABLE Nr)

MODES FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE

7. EMERGENCY FEEDWATER (EFAS)

a. Manual (Trip Buttons) 2 sets of 2 1 set of 2 2 sets of 2 1,2,3 CD per steam per steam per steam generator generator generator

b. SG Level (1/2) - CD Low and AP (1/2) - High 4/steam 2/steam 3/steam 1,2,3 19ar49b, 20 generator generator generator 0 CD

c. SG Level (1/2) - Low 0 ) >j and No SIG Pressure - 19a49b2O --. 0 Low Trip (1/2) 4/steam 2/steam 3/steam 1,2,3 generator generator generator 0)0

d. Automatic Actuation Logic 4 2 3 1,2,3 12 U

e. Control Valve Logic 2/steam 1/steam 2/steam 1,2,3 15 r-0 Cj)

(Wide Range SG generator generator generator Level - Low)

CD 3

CD WATERFORD - UNIT 3 3/4 3-1.6 AMEND* AENT NO. 154 34

W3F1-2013-0035 Page 6 of 12 TS 3.3.3.1, Radiation Monitoring Instrumentation Table 3.3-6, Actions 27 and 28 (Page 1 of 1)

TABLE 3.3-6 (Continued)

ACTION STATEMENTS ACTION 23 - DELETED ACTION 24 - DELETED ACTION 25 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification. 3.9.4.

ACTION 26 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of the control room emergency ventilation system in the recirculation mode of operation.

ACTION 27 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, either restore the inoperable Channel(s) to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or:

1. Initiate the preplanned alternate method of monitoring the appropriate parameter(s), and - -

2. If the monitor is not restored to OPERABLE st s wit in 7 days after the failure, prepare and sub ý4 Special Report to the Commission pursuan, pecification 6.9.2 within 14 days f-ll;wi9n the '.'ent tling the action taken, the cause of the inoperability andthe plans and schedule for restoring the system to OPERABLE status.

ACTION 28 - With the number of channels OPERABLE less than required by the Minimum.C~qequirements, operation of the plant may contin f9F Up t 30 d---y iovided grab samples are taken once per 8 , 0 les are analyzed for gross activity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . the next Ifthe monitor is not restored t)PERABLE status within 30 days after the failure, contin .sampling and prepare and submit a Special Report t he Commission pursuant to Specification 6.9.2 within 4 days outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status.

WATERFORD.- UNIT 3 3/4 3-31 AMENDMENT NO.-9---76,-1 231

W3F1-2013-0035 Page 7 of 12 TS 3.3.3.6, Accident Monitoring Instrumentation Table 3.3-10, Action 29 Page 1 of 1 TABLE 3.3-10 ACTION STATEMENTS Special ACTION 29 - With the number of OPERABLE accident nitoring channels less than the Required Nuber of Channels hown in Table 3.3-10, either restore the inoperable channe to OPERABLE status within 30 days, or prepare and submit a Sepois Report to the

,Commission pursuant to Specification 6.9.2 within the following 14 days. The report shall outline the preplanned alternate

-method of monitoring, the cause of the Inoperability, and the plans and schedule for restoring the instrumentation channels to OPERABLE status.

ACTION 30 - With the number of OPERABLE accident monitoring channels less than the Mini"m Channels OPERABLE requirements of Table 3.3-10; either restore the inoperable channel(s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

ACTION 31 - With the number of OPERABLE accident monitoring channels less than the Minimum Channels OPERABLE in Table 3.3-10, either restore the inoperable channel(s) to OPERABLE status within 7 days or prepare and submit a Special Report to the Commission p ursuant to Specification 6.9.2 within the following 14 days.

e report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels to OPERABLE status.

WATERFORD - UNIT 3 3/4 3-45a AMENONENT NO. 44T122

W3F1-2013-0035 Page 8 of 12 TS 3.3.3.11, Explosive Gas Monitoring Instrumentation Action b.

(Page 1 of 1)

INSTRUMENTATION EXPLOSIVE GAS MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.11 The explosive gas monitoring instrumentation channels shown in Table 3.3-13 shall be OPERABLE with their alarm/trip setpoints set to ensure that the limits of Specification 3.11.2.5 are not exceeded.

APPLICABILITY: As shown in Table 3.3-13.

ACTION:

a. With an explosive gas monitoring instrumentation channel alarm/trip setpoint less conservative than required by the above Specification, declare the channel inoperablle 3.3-13. within the following 14 days

b. With less than the minimum n instrumentation channels OPERABLE, take the ACTION shown in able 3.3-13. Restore the inoperable instrumentation to OPERABL status within 30 days and, if unsuccessful, prepare and submit pecdal Report to the Commission pursuant to Specification 6.9.2 o explain why this inoperability was not corrected in a timely manner.

c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.11 Each explosive gas monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table 4.3-9.

WATERFORD - UNIT 3 3/4 3-60 AMENOMENT NO. Vl, 68

W3F1 -2013-0035 Page 9 of 12 TS 4.8.2.1, D.C. Sources, Surveillance Requirement c.3 (Page 1 of 1)

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

b. At least once per 92 days and within 7 days after a battery discharge with battery terminal voltage below 110-volts, or battery overcharge with battery terminal voltage above 150 volts, by verifying that:

1. The parameters in Table 4.8-2 meet the Category B limits,

2. There is no visible corrosion at either terminals or connectors,

,with *atotal battrMint'er-oll reista'n'ce va~lue that maintains

.battery terminal voltage above the required operating voltage of

3. the emergency loads as established by design calculations and t

'documented in test procedures

c. At least onc per 1 months y ver

1. The cells, cell plates, and ba ery racks show no visual indication of physical damage or abnormal terioration,

2. The cell-to-cell and terminal con ections are clean, tight, and coated with anticorrosion material

3. The resistance of each cell-to-cell d terminal connection is less than or equal to 150 x 10-6 ohm , and

4. The battery charger will supply at least 150 amperes for 3A1-S, 3A2-S; 3B1-S and 382-S and 200 amperes for 3ABI-S and 3AB2-S at greater than or equal to 132 volts for at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

d. At least once per 18 months, during shutdown, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test.

e. At least once per 60 months, during shutdown, by verifying that the battery capacity is at least 80% of the manufacturer's rating when subjected to a performance discharge test. This performance discharge test may be performed in lieu of the battery service test required by Surveillance Requirement 4.8.2.1d.

f. Annual performance discharge tests of battery capacity shall be given to any battery that shows signs of degradation or has reached 851 of the service life expected for the application. Degradation is indicated when the battery capacity drops more than 10% of rated capacity from its average on previous performance tests, or is below 90% of the manufacturer's rating.

WATERFORD - UNIT 3 3/4 8-10 AMENDMENT No. 77

W3F1-2013-0035 Page 10 of 12 TS 6.1, Responsibility TS 6.2, Organization (Page 1 of 1)

ADMINISTRATIVE CONTRsLS 6,1 RESPONSIBILITY Shift Manager 6.1.1 The General Manager Plant Oper nns shall be responsible for overall unit operation and shall delegate in writing the successlo o this responsibility during his absence.

The General Manager Plant Ope ions or his designee shall approve, prior to implementation, each proposed test, experiment or m ification to systems or equipment that may affect nuclear safety.

6.1.2 The Shift S*u~~, te. . or during his absence from the control room, a designated individual shall be responsible for the control room command function. A management directive to this effect, signed by the "PrFtnO-Rt , shall be reissued to all station personnel on an annual basis.

6.2 ORGANIZATION 6.2.1 OFFSITE AND ONSITE ORGANIZATIONS Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the safety of the nuclear power plant.

a. Lines of authority, responsibility, and communication shall be established and defined from the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the FSAR.

b. The General Manager Plant Operations shall be responsible for overall unit safe operation and shall have control over those onsite activities necessar( for safe operation and maintenance of the plant. ite Vice Pesident-

c. The Yee.*P,,tld:. ft o,,: hall have corporate responsibili'ty for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

d. The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures.

6.2.2 UNIT STAFF

a. Each on-duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1; WATERFORD - UNIT 3 6-1 AMENDMENT NO. - 152

W3F1-2013-0035 Page 11 of 12 TS 6.2.2 Unit Staff (Page 1 of 1)

ADMINISTRATIVE CONTROLS UNIT STAFF (Continued)

b. At least one licensed Operator shall be in the control room when fuel is in the reactor. In addition, while the reactor is in MODE 1, 2, 3, or 4, at least one licensed Senior Operator shall be in the control room.

c. A Health Physics Technician* shall be on site when fuelis in the reactor.

d. All CORE ALTERATIONS shall be observed and directly supervised by either a licensed.

Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation.

e. The Operations Manager or the AGGIGRItn UpIr::Nori Pnora (.... shall hold a senior reactor operator license..

Operations Manager - Shift

This requirement tolerates Health Physics Technician unexpected absences for notmore than.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided management takes immediateaction to fill the required Health Physics Technician position.

WATERFORD - UNIT 3 6-2 AMENDMENT NO. 11,4-1-,S,6,

+467221

W3F1-2013-0035 Page 12 of 12 TS 6.12, High Radiation Area (Page 1 of 1)

ADMINISTRATIVE CONTROLS HIGH RADIATION AREA (Continued)

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate level in the area has been established and personnel have been made knowledgeable of them.

c. A health physics qualified individual (i.e., qualified in radiation protection procedures) with a radiation dose rate monitoring device who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Radiation Protection Cztznkde'Pt Ma 6.12.2 In addition to the requirements of Specification 6.12.1, areas accessible to personnel with radiation levels such that a major portion of the body could receive in one hour a dose greater than 1000 mrems* but less than 500 radsý* shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the Shift Superintendent on duty and/or health physics supervision/designee. Doors shall remain locked except during periods of access by personnel under an approved RWP which shall specify the dose rate levels in the immediate work area and the maximum allowable stay time for individuals in that area. For individual areas accessible to personnel with radiation levels such that a major portion of the body could receive in I hour a dose in excess of 1000 mrems* but less than 500 rads** that are located within large areas, such as PWR containment, where no enclosure exists for purposes of locking, and no enclosure can be reasonably constructed around the individual areas, then that area shall be roped off, conspicuously posted and a flashing light shall be activated as a warning device. In lieu of the stay time specification of the RWP, direct or remote (such as use of closed circuit Tv cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities within the area.

6.13 PROCESS CONTROL PROGRAM (PCP) 6.13.1 The PCP shall be approved by the Commission prior to implementation.

6.13.2 Licensee-initiated changes to the PCP:

a. Shall be documented and records of reviews performed shall be retained as required by the Quality Assurance Program Manual. This documentation shall contain:

Measurement made at 30 centimeters from the radiation source or from any surface that the radiation penetrates.

-Measurement made at 1 meter from the radiation source or from any surface that the radiation penetrates.

WATERFORD - UNIT 3 6-23 AMENDMENT NO. 6S,+,46-*446, 161

Attachment 3 to W3F1-2013-0035 Proposed Technical Specification Changes (clean copy)

Note: Letter and page numbers are not included on the clean pages. This attachment contains 12 pages following the cover page.

TABLE 3.3-1 (Continued)

ACTION STATEMENTS

2. Pressurizer Pressure - Pressurizer Pressure - High High Local Power Density - High DNBR - Low

3. Containment Pressure - Containment Pressure - High (RPS) High Containment Pressure - High (ESF)

4. Steam Generator Steam Generator Pressure - Low Pressure - Low Steam Generator AP 1 and 2 (EFAS 1 and 2)

5. Steam Generator Level Steam Generator Level - Low Steam Generator AP (EFAS)

6. Core Protection Local Power Density - High Calculator DNBR - Low

7. Logarithmic Power Logarithmic Power Level - High Local Power Density - High (1)

DNBR - Low (1)

Reactor Coolant Flow - Low (1)

STARTUP and/or POWER OPERATION may continue until the performance of the next required CHANNEL FUNCTIONAL TEST. Subsequent STARTUP and/or POWER OPERATION may continue if one channel is restored to OPERABLE status and the provisions of ACTION 2 are satisfied.

ACTION 4 - With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, suspend all operations involving positive reactivity changes.

ACTION 5 - With the number of channels OPERABLE one less those required by the Minimum Channels OPERABLE requirement, STARTUP and/or POWER OPERATION may continue provided the reactor trip breakers of the inoperable channel are placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ; otherwise, be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for surveillance testing per Specification 4.3.1.1.

ACTION 6 - a. With one CEAC inoperable, operation may continue for up to 7 days provided that at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , each CEA is verified to be within 7 inches (indicated position) of all other CEAs in its group. After 7 days, operation may continue provided that Action 6.b.1, 6.b.2, and 6.b.3 are met.

Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SHUTDOWN MARGIN.

(1) With the operating bypass enabled.

WATERFORD - UNIT 3 3/4 3-6 AMENDMENT NO. 5,105, 225, 22.,

TABLE 3.3-1 (Continued)

ACTION STATEMENTS

b. With both CEACs inoperable, operation may continue provided that:

1. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months the DNBR margin required by Specification 3.2.4b (COLSS in service) or 3.2.4d (COLSS out of service) is satisfied and the Reactor Power Cutback System is disabled, and

2. Within 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months s:

a) All CEA groups are withdrawn to and subsequently maintained at the "Full Out" position, except during surveillance testing pursuant to the requirements of Specification 4.1.3.1.2 or for control when CEA group 6 may be inserted no further than 127.5 inches withdrawn.

b) The "RSPT/CEAC Inoperable" addressable constant in the CPCs is set to the inoperable status.

c) The Control Element Drive Mechanism Control System (CEDMCS) is placed in and subsequently maintained in the "Off' mode except during CEA group 6 motion permitted by a) above, when the CEDMCS may be operated in either the "Manual Group" or "Manual Individual" mode.

3. At least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , all CEAs are verified fully withdrawn except during surveillance testing pursuant to Specification 4.1.3.1.2 or during insertion of CEA group 6 as permitted by 2.a) above, then verify at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months that the inserted CEAs are aligned within 7 inches (indicated position) of all other CEAs in its group.

ACTION 7 With three or more auto restarts of one non-bypassed calculator during a 12-hour interval, demonstrate calculator OPERABILITY by performing a CHANNEL FUNCTIONAL TEST within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 8 With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or open the reactor trip breakers within the next hour.

WATERFORD - UNIT 3 3/4 3-7 AMENDMENT NO. 5,,-182,85,

REACTIVITY CONTROL SYSTEMS SHUTDOWN CEA INSERTION LIMIT LIMITING CONDITION FOR OPERATION 3.1.3.5 All shutdown CEAs shall be withdrawn to greater than or equal to 145 inches.

APPLICABILITY: MODES 1" and 2*#**.

ACTION:

With a maximum of one shutdown CEA withdrawn to less than 145 inches withdrawn, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either:

a. Withdraw the CEA to greater than or equal to 145 inches, or

b. Declare the CEA inoperable and determine that the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS 4.1.3.5 Each shutdown CEA shall be determined to be withdrawn to greater than or equal to 145.inches withdrawn:

a. Within 15 minutes prior to withdrawal of any CEAs in regulating groups or group P during an approach to reactor criticality, and

b. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter.

See Special Test Exception 3.10.2.

With Keff greater than or equal to 1.0.

- Except for surveillance testing pursuant to Specification 4.1.3.1.2.

WATERFORD - UNIT 3 3/4 1-24 AMENDMENT NO. +82,

TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION MINIMUM m TOTAL NO. CHANNELS CHANNELS APPLICABLE

-n FUNCTIONAL UNIT OF CHANNELS To TRIP OPERABLE MODES ACTION 0

4. MAIN STEAM LINE ISOLATION c a. Manual (Trip 2 sets of 1 set of 2 sets of 1, 2, 3 16 z Buttons) 2 per steam 2 per steam 2 per operat-

"I generator generator ing steam generator

b. Steam Generator 4/steam 2/steam 3/steam 1, 2, 3 13*, 14*

Pressure - Low generator generator generator

c. Containment Pressure - 4 2 3 1,2,3 13*, 14*

High

d. Automatic Actuation 4 2 3 1,2, 3 12 Logic

5. SAFETY INJECTION SYSTEM SUMP RECIRCULATION (RAS)

a. Manual RAS (Trip Buttons) 2 1 2 1,2,3,4 12 Cn b. Refueling Water Storage Pool- Low 4 2 3 1,2,3,4 19,20

c. Automatic Actuation Logic 4 2 3 1,2,3,4 12

6. LOSS OF POWER (LOV)

a. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage) 3/bus 3/bus 3/bus 1, 2, 3 17, 18

b. 480 V Emergency Bus m

z Undervoltage (Loss of Voltage) 3/bus 3/bus 3/bus 1,2, 3 17, 18 z c. 4.16 kV Emergency

-Bus Undervoltage z 1,2,3 17,18 0 (Degraded Voltage) 3/bus 3/bus 3/bus t

TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION MINIMUM TOTAL NO. CHANNELS CHANNELS APPLICABLE FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION

7. EMERGENCY FEEDWATER (EFAS)

a. Manual (Trip Buttons) 2 sets of 2 1 set of 2 2 sets of 2 1,2,3 15 per steam per steam per steam generator generator generator

b. SG Level (1/2) -

Low and A P (1/2) - High 4/steam 2/steam 3/stearn 1,2,3 19, 20 generator generator generator

c. SG Level (1/2) - Low and No S/G Pressure -

Low Trip (1/2) 4/steam 2/steam 3/steam 1,2,3 19, 20 generator generator generator

d. Automatic Actuation Logic 4 2 3 1,2,3 12

e. Control Valve Logic 2/steam 1/steam 2/steam 1,2,3 15 (Wide Range SG generator generator generator Level - Low)

WATERFORD - UNIT 3 3/4 3-16 AMENDMENT NO. +54,

TABLE 3.3-6 (Continued)

ACTION STATEMENTS ACTION 23 - DELETED ACTION 24 - DELETED ACTION 25 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9.4.

ACTION 26 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of the control room emergency ventilation system in the recirculation mode of operation.

ACTION 27 - With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, either restore the inoperable Channel(s) to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or:

1. Initiate the preplanned alternate method of monitoring the appropriate parameter(s), and

2. If the monitor is not restored to OPERABLE status within 7 days after the failure, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 14 days after the failure outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status.

ACTION 28 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirements, operation of the plant may continue provided grab samples are taken once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and these samples are analyzed for gross activity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If the monitor is not restored to OPERABLE status within 30 days after the failure, continue sampling and prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next 14 days outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status.

WATERFORD - UNIT 3 3/4 3-31 AMENDMENT NO. -91,-76,-9-7-,

2-3-1,

TABLE 3.3-10 ACTION STATEMENTS ACTION 29 - With the number of OPERABLE accident monitoring channels less than the Required Number of Channels shown in Table 3.3-10, either restore the inoperable channel to OPERABLE status within 30 days, or prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels to OPERABLE status.

ACTION 30 - With the number of OPERABLE accident monitoring channels less than the Minimum Channels OPERABLE requirements of Table 3.3-10; either restore the inoperable channel(s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

ACTION 31 - With the number of OPERABLE accident monitoring channels less than the Minimum Channels OPERABLE in Table 3.3-10, either restore the inoperable channel(s) to OPERABLE status within 7 days or prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the following 14 days.

The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels to OPERABLE status.

WATERFORD - UNIT 3 3/4 3-45a AMENDMENT NO. 22,

INSTRUMENTATION EXPLOSIVE GAS MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.11 The explosive gas monitoring instrumentation channels shown in Table 3.3-13 shall be OPERABLE with their alarm/trip setpoints set to ensure that the limits of Specification 3.11.2.5 are not exceeded.

APPLICABILITY: As shown in Table 3.3-13.

ACTION:

a. With an explosive gas monitoring instrumentation channel alarm/trip setpoint less conservative than required by the above Specification, declare the channel inoperable, and take the ACTION shown in Table 3.3-13.

b. With less than the minimum number of explosive gas monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-13. Restore the inoperable instrumentation to OPERABLE status within 30 days and, if unsuccessful, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the following 14 days to explain why this inoperability was not corrected in a timely manner.

c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.11 Each explosive gas monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table 4.3-9.

WATERFORD - UNIT 3 3/4 3-60 AMENDMENT NO. 17,68,

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

b. At least once per 92 days and within 7 days after a battery discharge with battery terminal voltage below 110-volts, or battery overcharge with battery terminal voltage above 150 volts, by verifying that:

1. The parameters in Table 4.8-2 meet the Category B limits,

2. There is no visible corrosion at either terminals or connectors, or the connection resistance of these items is less than 150 x 10-6 ohms, and

3. The average electrolyte temperature of a random sample of at least ten of the connected cells is above 70 0 F.

c. At least once per 18 months by verifying that:

1. The cells, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration,

2. The cell-to-cell and terminal connections are clean, tight, and coated with anticorrosion material,

3. The resistance of each cell-to-cell and terminal connection is less than or equal to 150 x 10-6 ohms with a total battery inter-cell resistance value that maintains battery terminal voltage above the required operating voltage of the emergency loads as established by design calculations and documented in test procedures, and

4. The battery charger will supply at least 150 amperes for 3A1-S, 3A2-S, 3B1-S and 3B2-S and 200 amperes for 3AB1-S and 3AB2-S at greater than or equal to 132 volts for at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

d. At least once per 18 months, during shutdown, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test.

e. At least once per 60 months, during shutdown, by verifying that the battery capacity is at least 80% of the manufacturer's rating when subjected to a performance discharge test. This performance discharge test may be performed in lieu of the battery service test required by Surveillance Requirement 4.8.2.1d.

f. Annual performance discharge tests of battery capacity shall be given to any battery that shows signs of degradation or has reached 85% of the service life expected for the application. Degradation is indicated when the battery capacity drops more than 10%

of rated capacity from its average on previous performance tests, or is below 90% of the manufacturer's rating.

WATERFORD - UNIT 3 3/4 8-10 AMENDMENT NO. 77,

ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The General Manager Plant Operations shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

The General Manager Plant Operations or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that may affect nuclear safety.

6.1.2 The Shift Manager, or during his absence from the control room, a designated individual shall be responsible for the control room command function. A management directive to this effect, signed by the Site Vice President - WF3, shall be reissued to all station personnel on an annual basis.

6.2 ORGANIZATION 6.2.1 OFFSITE AND ONSITE ORGANIZATIONS Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the safety of the nuclear power plant.

a. Lines of authority, responsibility, and communication shall be established and defined from the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the FSAR.

b. The General Manager Plant Operations shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.

c. The Site Vice President - WF3 shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

d. The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures.

6.2.2 UNIT STAFF

a. Each on-duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1; WATERFORD - UNIT 3 6-1 AMENDMENT NO. 18, 41, 63 146,152,

ADMINISTRATIVE CONTROLS UNIT STAFF (Continued)

b. At least one licensed Operator shall be in the control room when fuel is in the reactor. In addition, while the reactor is in MODE 1, 2, 3, or 4, at least one licensed Senior Operator shall be in the control room.

c. A Health Physics Technician* shall be on site when fuel is in the reactor.

d. All CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation.

e. The Operations Manager or the Operations Manager - Shift shall hold a senior reactor operator license.

This requirement tolerates Health Physics Technician unexpected absences for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided management takes immediate action to fill the required Health Physics Technician position.

. WATERFORD -UNIT 3 6-2 AMENDMENT NO. 18,4,146.J, 509, 6

,2- 2 ,

ADMINISTRATIVE CONTROLS HIGH RADIATION AREA (Continued)

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate level in the area has been established and personnel have been made knowledgeable of them.

c. A health physics qualified individual (i.e., qualified in radiation protection procedures) with a radiation dose rate monitoring device who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Radiation Protection Manager in the RWP.

6.12.2 In addition to the requirements of Specification 6.12.1, areas accessible to personnel with radiation levels such that a major portion of the body could receive in one hour a dose greater than 1000 mrems* but less than 500 rads** shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the Shift Superintendent on duty and/or health physics supervision/designee. Doors shall remain locked except during periods of access by personnel under an approved RWP which shall specify the dose rate levels in the immediate work area and the maximum allowable stay time for individuals in that area. For individual areas accessible to personnel with radiation levels such that a major portion of the body could receive in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months a dose in excess of 1000 mrems* but less than 500 rads** that are located within large areas, such as PWR containment, where no enclosure exists for purposes of locking, and no enclosure can be reasonably constructed around the individual areas, then that area shall be roped off, conspicuously posted and a flashing light shall be activated as a warning device. In lieu of the stay time specification of the RWP, direct or remote (such as use of closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities within the area.

6.13 PROCESS CONTROL PROGRAM (PCP) 6.13.1 The PCP shall be approved by the Commission prior to implementation.

6.13.2 Licensee-initiated changes to the PCP:

a Shall be documented and records of reviews performed shall be retained as required by the Quality Assurance Program Manual. This documentation shall contain:

Measurement made at 30 centimeters from the radiation source or from any surface that the radiation penetrates.

- Measurement made at 1 meter from the radiation source or from any surface that the radiation penetrates.

WATERFORD - UNIT 3 6-23 AMENDMENT NO. 6,8,116, 46,-+16,

v t e Letter Sequence Request
TAC:MF3230, (Approved, Closed)
Initiation Request Acceptance... Supplement Administration Questions 22 August 2014 Answers Results Approval Other:
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W3F1-2013-0035, License Amendment Request to Address Multiple Administrative Issues with the Technical Specifications

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