W3F1-2019-0062, License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual

License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual

ML19263F129
Person / Time
Site:	Waterford
Issue date:	09/20/2019
From:	Gaston R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2019-0062
Download: ML19263F129 (34)

Text

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.90 W3F1-2019-0062 September 20, 2019 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 As required by 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests an amendment to Appendix A, "Technical Specifications" of Renewed Facility Operating License No. NPF-38 for Waterford Steam Electric Station, Unit 3 (Waterford).

The proposed change will revise Waterford Technical Specifications (TS) to remove TS 3.1.2.1 through 3.1.2.8, "Boration Systems," and references to the TS and relocate the information to the licensee-controlled Technical Requirements Manual (TRM). The TRM is part of the Final Safety Analysis Report (FSAR) and any changes to the TRM are subject to the criteria of 10 CFR 50.59.

These proposed TS changes are consistent with the NRC's "Final Policy Statement on Technical Specifications Improvements," (58 FR 39132), which was issued in July 1993. This Policy Statement established that licensees may propose the removal of TS Limiting Conditions for Operation (LCOs) which do not meet any of the four criteria specified in the Policy Statement and relocate these LCOs to a licensee-controlled document. The NRC codified the four criteria in 10 CFR 50.36(c)(2)(ii) in July 1995 (60 FR 36959). The proposed changes are also consistent with NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants," Revision 4.

The Enclosure to this letter provides an evaluation of the proposed changes. Attachment 1 to the Enclosure provides the existing TS pages, marked-up to show the proposed changes. provides, for information only, marked up versions of existing TS Bases pages to show the proposed changes. Attachment 3 provides retyped (clean) TS pages.

Enclosure W3F1-2019-0062 Evaluation of the Proposed Change

Enclosure to W3F1-2019-0062 Page 1 of 13 EVALUATION OF THE PROPOSED CHANGE 1.0

SUMMARY

DESCRIPTION Entergy Operations, Inc. (Entergy) requests NRC review and approval of a proposed amendment to the Waterford Steam Electric Station, Unit 3 (Waterford) Renewed Facility Operating License No. NPF-38, Appendix A, "Technical Specifications" (TSs) to relocate the Boration Systems TSs (i.e., TS 3.1.2.1 through TS 3.1.2.8) to the Entergy-controlled Technical Requirements Manual (TRM). The requested change involves no significant hazards consideration.

This requested license amendment proposes to relocate the Boration System TSs to the Waterford TRM. The proposed relocation is consistent with the NRC's "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58 FR 39312) issued in July 1993, which provided a specific set of four (4) objective criteria to determine which of the design conditions and associated surveillances should be located in the TSs as limiting conditions for operation (LCOs). The Final Policy Statement noted that implementation of these additional criteria, as amended to 10 CFR 50.36(c)(2)(ii), may cause some requirements presently in TSs to no longer merit inclusion in TSs.

2.0 DETAILED DESCRIPTION The proposed change would relocate the following TSs to the TRM:

3.1.2.1, (Boration Systems) Flow Paths - Shutdown 3.1.2.2, (Boration Systems) Flow Paths - Operating 3.1.2.3, Charging Pumps - Shutdown 3.1.2.4, Charging Pumps - Operating 3.1.2.5, Boric Acid Makeup Pumps - Shutdown 3.1.2.6, Boric Acid Makeup Pumps - Operating 3.1.2.7, Borated Water Sources - Shutdown 3.1.2.8, Borated Water Sources - Operating These TSs ensure availability of the Boration Systems required for negative reactivity control, including the Boric Acid Makeup Tanks (BAMTs), Boric Acid Makeup pumps (BAMPs), Charging Pumps, and flow paths. Although the Boration Systems provide a means of reactivity control through boron injection, none of these systems are required to mitigate any design basis accidents or transients.

This change proposes that the Boration Systems contained in TS Section 3/4.1.2, with their LCOs, associated Actions, Surveillance Requirements, and Figures, be relocated to the TRM.

No change to these specifications other than the relocation is proposed in this license amendment request (LAR). The associated Bases will also be relocated to the TRM. The TRM is part of the Final Safety Analysis Report (FSAR) and any changes to the TRM are subject to the criteria of 10 CFR 50.59.

Enclosure to W3F1-2019-0062 Page 2 of 13 The Boration Systems ensure that negative reactivity control is available during each mode of operation. The components required to perform this function include 1) borated water sources,

2) charging pumps, 3) separate flow paths, 4) boric acid makeup pumps, and 5) an emergency power supply from operable diesel generators. The relocation of the Boration Systems TSs does not alter the design function of the Boration Systems.

2.1 System Design and Operation The BAMTs, BAMPs, and Charging Pumps are part of the Chemical and Volume Control System (CVCS). The CVCS functions to maintain RCS inventory and control Reactor Coolant System (RCS) chemistry. The BAMTs and the Refueling Water Storage Pool (RWSP) provide sources of boric acid solution for injection into the RCS. The BAMTs also supply a source of boric acid makeup to the Spent Fuel Pool (SFP) and the RWSP. The combination of the BAMTs and the RWSP contain sufficient boric acid to bring the plant to a cold shutdown condition as well as ensure that negative reactivity control is available during each mode of operation.

There are two BAMTs, each with a separate BAMP and gravity feed valve. The flow path from the BAMT to the RCS may be through either the BAMP to the suction of the Charging pumps or through the gravity feed valve to the suction of the Charging Pumps. The two separate flow paths from the discharge of the BAMPs or gravity feed valves combine into a common header at the suction of the Charging pumps. The boric acid is discharged to the RCS via the Charging Pumps. The BAMPs, gravity feed valves, and Charging Pumps receive a Safety Injection Actuation Signal (SIAS) and Containment Isolation Actuation Signal (CIAS) when RCS pressure drops or Containment Building pressure increases to their specified TS values. This aligns the system components such that boric acid can be injected into the RCS. Although the Boration Systems provide a means of reactivity control through boron injection, none of these systems are required to mitigate any design bases accidents or transients.

2.2 Current TS Requirements TS 3.1.2.1, "(Boration Systems) Flow Paths - Shutdown," requires at a minimum, one of the following boron injection flow paths to be OPERABLE and capable of being powered from an Operable emergency power source in Modes 5 & 6:

a. A flow path from the boric acid makeup tank via either a boric acid makeup pump or a gravity feed connection and any charging pump to the Reactor Coolant System if the boric acid makeup tank in Specification 3.1.2.a. is OPERABLE, or

b. The flow path from the refueling water storage pool via either a charging pump or a high pressure safety injection pump to the Reactor Coolant System if the refueling water storage pool in Specification 3.1.2.7b. is OPERABLE.

TS 3.1.2.2, "(Boration Systems) Flow Paths - Operating," requires at least two boron injection flow paths to the RCS, via the charging pumps, to be Operable in Modes 1, 2, 3, and 4. The following flow paths may be used:

a. With the contents of either boric acid makeup tank in accordance with TS Figure 3.1-1, the following flow paths shall be OPERABLE:

Enclosure to W3F1-2019-0062 Page 3 of 13

1. One flow path from an acceptable boric acid makeup tank via its boric acid makeup pump; and

2. One flow path from an acceptable boric acid makeup tank via its gravity feed valve; or

b. With the combined contents of both boric acid makeup tanks in accordance with Figure 3.1-2, both of the following flow paths shall be OPERABLE:

1. One flow path consisting of both boric acid makeup pumps, and

2. One flow path consisting of both gravity feed valves.

TS, 3.1.2.3, "Charging Pumps - Shutdown," requires at least one charging pump or one high pressure safety injection pump in the boron injection flow path required Operable pursuant to Specification 3.1.2.1 to be Operable and capable of being powered from an Operable emergency power source in Modes 5 and 6.

TS, 3.1.2.4, "Charging Pumps - Operating," requires at least two independent charging pumps to be Operable in Modes 1, 2, 3, and 4.

TS, 3.1.2.5, "Boric Acid Makeup Pumps - Shutdown," requires at least one boric acid makeup pump to be Operable and capable of being powered from an Operable emergency bus if only the flow path through the boric acid pump in Specification 3.1.2.1a is Operable in Modes 5 and 6.

TS, 3.1.2.6, "Boric Acid Makeup Pumps - Operating," requires at least the boric acid makeup pump(s) in the boron injection flow path(s), required Operable pursuant to Specification 3.1.2.2.a, to be Operable and capable of being powered from an Operable emergency bus if the flow path through the boric acid pump(s) in Specification 3.1.2.2a is Operable in Modes 1, 2, 3, and 4.

TS, 3.1.2.7, "Borated Water Sources - Shutdown," requires at a minimum, one of the following borated water sources to be Operable in Modes 5 and 6:

a. One boric acid makeup tank with a boron concentration between 4900 ppm and 6125 ppm and a minimum borated water volume of 36% indicated level.

b. The refueling water storage pool (RWSP) with:

1. A minimum contained borated water volume of 12% indicated level, and

2. A minimum boron concentration of 2050 ppm.

TS, 3.1.2.8, "Borated Water Sources - Operating," requires each of the following borated water sources to be Operable in Modes 1, 2, 3, and 4 :

Enclosure to W3F1-2019-0062 Page 4 of 13

a. At least one of the following sources:

1. One boric acid makeup tank, with the tank contents in accordance with Figure 3.1-1, or

2. Two boric acid makeup tanks, with the combined contents of the tanks in accordance with Figure 3.1-2, and

b. The refueling water storage pool in accordance with Specification 3.5.4.

The Standard Technical Specifications (STS), NUREG-1432 Revision 4, does not contain the above listed Technical Specifications.

2.3 Reason for the Proposed Change The proposed change relocates Boration System TSs that do not meet the 10 CFR 50.36 requirements for retention in TS, and are not included in NUREG-1432, Revision 4, "Standard Technical Specifications - Combustion Engineering Plants." The proposed change eliminates unnecessary burden on both Entergy Operations, Inc., and the NRC associated with future revisions to the proposed relocated TSs. This proposed change also establishes consistency with NUREG-1432, Revision 4.

The basis for the relocation is the NRC's "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58 FR 39312) issued in July 1993, which provided a specific set of four (4) objective criteria to determine which of the design conditions and associated surveillances should be located in the TSs as limiting conditions for operation. The Final Policy Statement noted that implementation of these additional criteria, as codified in 10 CFR 50.36(c)(2)(ii), may cause some requirements presently in TSs to no longer merit inclusion in TSs.

3.0 TECHNICAL EVALUATION

The proposed change contained in this submittal relocates TSs 3.1.2.1, 3.1.2.2, 3.1.2.3, 3.1.2.4, 3.1.2.5, 3.1.2.6, 3.1.2.7, and 3.1.2.8 to the Waterford TRM. No change to any of these TSs is proposed other than the relocation to the TRM. NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants," do not contain any of these specifications.

Therefore, this change is consistent with NUREG-1432. In addition, 10 CFR 50.36, "Technical Specifications," lists four criteria (i.e., 10 CFR 50.36(c)(2)(ii)) that require the establishment of an LCO. The following provides a comparison of these four criteria with the basis for the relocation of the BAMTs, BAMPs, Charging Pumps, and flow paths.

Criterion 1 Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

TS 3.1.2.1 through TS 3.1.2.8 do not satisfy Criterion 1. This criterion addresses instrumentation installed to detect excessive RCS leakage. These TSs ensure the Boration Systems are available for negative reactivity control and do not provide installed instrumentation that is used to detect, and indicate

Enclosure to W3F1-2019-0062 Page 5 of 13 in the control room, a significant degradation of the reactor coolant pressure boundary.

Criterion 2 A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

TS 3.1.2.1 through TS 3.1.2.8 do not satisfy Criterion 2. This criterion captures those process variables that have initial values assumed in the design basis accident and transient analyses, and which are monitored and controlled during power operation. This criterion also includes active design features (e.g., high pressure/low pressure system valves and interlocks) and operating restrictions (e.g., pressure/temperature limits) needed to preclude unanalyzed accidents and transients. TS 3.1.2.1 through TS 3.1.2.8 are used to establish and maintain Shutdown Margin (SDM). The accident analyses assume the plant is at a specific SDM at the start of an accident. The validity of this assumption is established by TSs 3.1.1.1, "Shutdown Margin - Any CEA Withdrawn," 3.1.1.2, "

Shutdown Margin - All CEAs Fully Inserted," and 3.9.1, "Boron Concentration" which address SDM. TSs 3.1.1.1, 3.1.1.2, and 3.9.1 requirements ensure the required SDM will be established prior to entering plant conditions (i.e.,

operating Mode) where the accidents are of concern. Therefore, TS 3.1.2.1 through TS 3.1.2.8 do not establish a variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 3 A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

TS 3.1.2.1 through TS 3.1.2.8 do not satisfy Criterion 3. This criterion captures those structures, systems, and components that are part of the primary success path of the safety analysis (i.e., actions required to mitigate the consequences of the design basis accidents and transients). The primary success path of a safety analysis consists of the combinations and sequences of equipment needed to operate, so that the plant response to the design basis accidents and transients limits the consequences of these events to within the appropriate acceptance criteria. Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function. It does not include backup and diverse equipment.

These TSs establish and maintain SDM. The accident analyses assume the plant is at a specific SDM at the start of an accident to provide sufficient time for the plant operators to recognize the event and terminate the event prior to a complete loss of SDM. Providing sufficient time to isolate the dilution source prior to a complete loss of SDM is the primary success path for mitigation of this event. The validity of this assumption is established by the TSs that address SDM (TSs 3.1.1.1, 3.1.1.2, and 3.9.1). This ensures the required SDM will be established prior to entering plant conditions where the accidents are of concern. The Boration Systems TSs ensure the ability to regain the required

Enclosure to W3F1-2019-0062 Page 6 of 13 SDM; which, is beyond the scope of a primary success path action. As a result, these proposed relocated TSs do not establish a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4 A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

TS 3.1.2.1 through TS 3.1.2.8 do not satisfy Criterion 4. This criterion captures only those structures, systems, and components that operating experience or probabilistic risk assessment has shown to be significant to public health and safety. The TSs proposed for relocation do not contain constraints of prime importance in limiting the likelihood or severity of the accident sequences that are commonly found to dominate risk. The Boration Systems, which are used to inject borated water to establish and maintain SDM, are not structures, systems, or components that operating experience or probabilistic safety assessment has shown to be significant to the public health and safety. The Boration Systems (Chemical Volume Control (CVC) and Boric Acid Management (BAM))

components that function to inject borated water to establish and maintain SDM are not risk significant in the current Waterford Probabilistic Safety Assessment (PSA) for the modes for which the respective TSs are applicable. A review of industry operating experience did not produce any examples where the boration system has had a significant adverse effect on public health and safety.

Neither the Technical Specifications nor surveillance requirements for the BAMTs, BAMPs, Charging Pumps or their associated flow paths meet any of these criteria. Therefore, the relocation of these TSs is allowed by 10 CFR 50.36.

During a small or large break LOCA, boron injection is assumed via the ECCS which includes the High Pressure Safety Injection (HPSI) and Low Pressure Safety Injection (LPSI) pumps.

The suction source for these pumps is the RWSP. The operation of the Charging Pumps and the injection of boric acid from the BAMT do not mitigate the small break or large break LOCA.

The required concentration, volume, and temperature of boric acid contained in the RWSP are contained in Waterford TS 3.5.4, "Refueling Water Storage Pool." This specification will not be relocated to the TRM.

The proposed change relocates TS 3.1.2.1 through TS 3.1.2.8 to the TRM. No change other than the relocation to the TRM is proposed. Any change to these systems will be reviewed in accordance with 10 CFR 50.59 to determine if the change requires prior NRC review and approval.

Enclosure to W3F1-2019-0062 Page 7 of 13

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed changes relocate the Boration Systems TSs (BAMTs, BAMPs, Charging Pumps, and Flow Paths) to the TRM. No other changes are being made to the affected TSs other than relocation. The following is a list of the applicable 10 CFR 50, Appendix A General Design Criteria (GDCs) and the responses from the Waterford FSAR that are related to the Boration Systems TSs.

CRITERION 26 - REACTIVITY CONTROL SYSTEM REDUNDANCY AND CAPABILITY CRITERION:

Two independent reactivity control systems of different design principles shall be provided.

One of the systems shall use control rods, preferably including a positive means for inserting the rods, and shall be capable of reliably controlling reactivity changes to assure that under conditions of normal operation, including anticipated operational occurrences, and with appropriate margin for malfunctions such as stuck rods, specified acceptable fuel design limits are not exceeded. The second reactivity control system shall be capable of reliably controlling the rate of reactivity changes resulting from planned, normal power changes, (including xenon burnout) to assure that acceptable fuel design limits are not exceeded. One of the systems shall be capable of holding the reactor core subcritical under cold conditions.

RESPONSE

Two independent reactivity control systems of different design principles are provided.

The first system, using Control Element Assemblies (CEAs), includes a positive means (gravity) for inserting CEAs, and is capable of reliably controlling reactivity changes to ensure that under conditions of normal operation, including anticipated operational occurrences, specified acceptable fuel design limits are not exceeded. The CEAs can be mechanically driven into the core. The appropriate margin for stuck rods is provided by assuming in the analyses of anticipated operational occurrences that the highest worth CEA is stuck out of the core.

The second system, the Chemical and Volume Control System (CVCS), uses neutron absorbing soluble boron and is capable of reliably compensating for the rate of reactivity changes resulting from planned normal power changes (including xenon burnout) such that acceptable fuel design limits are not exceeded. This system is capable of holding the reactor subcritical under cold conditions.

Either system is capable of making the core subcritical from a hot operating condition, and holding it subcritical in the hot standby condition.

Enclosure to W3F1-2019-0062 Page 8 of 13 CRITERION 27 - COMBINED REACTIVITY CONTROL SYSTEMS CAPABILITY CRITERION:

The reactivity control systems shall be designed to have a combined capability, in conjunction with poison addition by the Emergency Core Cooling System, of reliably controlling reactivity changes to assure that under postulated accident conditions and with appropriate margin for stuck rods the capability to cool the core is maintained.

RESPONSE

The reactivity control systems provide the means for making and holding the core subcritical under postulated accident conditions. Combined use of CEAs and chemical shim control by the Chemical and Volume Control System (CVCS) provides the shutdown margin required for plant cooldown and long-term xenon decay, assuming the highest worth CEA is stuck out of the core.

During some accidents, the Safety Injection System injects concentrated boric acid into the Reactor Coolant System for long-term and short-term cooling and for reactivity control.

CRITERION 28 - REACTIVITY LIMITS CRITERION:

The reactivity control systems shall be designed with appropriate limits on the potential amount and rate of reactivity increase to assure that the effects of postulated reactivity accidents can neither (1) result in damage to the reactor coolant pressure boundary greater than limited local yielding nor (2) sufficiently disturb the core, its support structures or other reactor pressure vessel internals to impair significantly the capability to cool the core. These postulated reactivity accidents shall include consideration of rod ejection (unless prevented by positive means), rod dropout, steam line rupture, changes in reactor coolant temperature and pressure, and cold water addition.

RESPONSE

The bases for CEA design include ensuring that the reactivity worth of any one CEA is not greater than a preselected maximum value. The CEAs are divided into two sets: a shutdown set, and a regulating set. These sets are further subdivided into groups as necessary. Administrative procedures and control interlocks ensure that the regulating groups are withdrawn only after the shutdown groups are fully withdrawn. For the specified list of design bases anticipated operational occurrences, the CEA positions are monitored by the RPS, and a trip is initiated in the event that specified acceptable fuel design limits are approached.

The CEAs, Reactor Regulating System, and boron charging portion of the CVCS are designed so that the potential amount and rate of reactivity insertion due to normal operation and postulated reactivity accidents do not result in:

- Violation of the specified acceptable fuel design limits

- Damage to the reactor coolant pressure boundary

- Disruption of the core or other reactor internals sufficient to impair the effectiveness of emergency core cooling.

Enclosure to W3F1-2019-0062 Page 9 of 13 The RCPB and the reactor internals are designed to appropriate codes. They can accommodate the static and dynamic loads associated with an inadvertent, sudden release of energy, such as that resulting from a CEA ejection or a steam line break, without rupture and with limited deformation that will not impair the capability of cooling the core.

CRITERION 33 - REACTOR COOLANT MAKEUP CRITERION:

A system to supply reactor coolant makeup for protection against small breaks in the reactor coolant pressure boundary shall be provided. The system safety function shall be to assure that specified acceptable fuel design limits are not exceeded as a result of reactor coolant loss due to leakage from the reactor coolant pressure boundary and rupture of small piping or other small components which are part of the boundary. The system shall be designed to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished using the piping, pumps, and valves used to maintain coolant inventory during normal reactor operation.

RESPONSE

Reactor coolant makeup during normal operation is provided by the CVCS. The design incorporates a high degree of functional reliability by provision of redundant components and an alternate path for charging. The charging pumps can be powered from either onsite or offsite power sources, including the onsite emergency diesel generators.

There are three charging pumps associated with the CVCS. One or more of these pumps is normally in operation balancing the letdown purification flow and the reactor coolant pump-controlled bleed-off flow rate.

It is not the primary function of the CVCS to provide protection against small breaks; this safety function is provided by the Safety Injection System (SIS). The CVCS does have the capability, with only one charging pump available (i.e., at a flow rate of 44 gallons per minute for a single charging pump), to supplement the HPSI pump injection flow for a certain range of small breaks; additionally, the CVCS is capable of replacing the flow loss to the Reactor Coolant System for leaks in the reactor coolant piping up to 0.50 inch equivalent diameter.

CRITERION 55 - REACTOR COOLANT PRESSURE BOUNDARY PENETRATION CONTAINMENT CRITERION:

Each line that is part of the reactor coolant pressure boundary and that penetrates primary reactor containment shall be provided with containment isolation valves as follows, unless it can be demonstrated that the containment isolation provisions for a specific class of lines, such as instrument lines, are acceptable on some other defined basis:

a) One locked closed isolation valve inside and one locked closed isolation valve outside containment or,

Enclosure to W3F1-2019-0062 Page 10 of 13 b) One automatic isolation valve inside and one locked closed isolation valve outside containment or, c) One locked closed isolation valve inside and one automatic isolation valve outside containment. A simple check valve may not be used as the automatic isolation valve outside containment or, d) One automatic isolation valve inside and one automatic isolation valve outside containment. A simple check valve may not be used as the automatic isolation valve outside containment.

Isolation valves outside containment shall be located as close to containment as practical and upon loss of actuating power, automatic isolation valves shall be designed to take the position that provides greater safety.

Other appropriate requirements to minimize the probability or consequences of an accidental rupture of these lines or of lines connected to them shall be provided as necessary to assure adequate safety. Determination of the appropriateness of these requirements such as higher quality in design, fabrication, and testing, additional provisions for in-service inspection, protection against more severe natural phenomena, and additional isolation valves and containment, shall include consideration of the population density, use characteristics, and physical characteristics of the site environs.

RESPONSE

Except for the safety injection and CVCS charging lines, the reactor coolant pressure boundary as defined in 10 CFR 50 is located within the containment. The safety injection and CVCS charging lines are closed seismic Category I piping systems outside containment with isolation valves that meet the isolation criteria of GDC 55. Isolation valves are located as close to the containment as practical.

The proposed change only relocates the Boration Systems TSs to the TRM with no other changes. None of the responses to the criterion above are affected by this change. Therefore, the proposed change does not affect compliance with these regulations or guidance and will continue to ensure that the lowest functional capabilities or performance levels of equipment required for safe operation are met.

4.2 Precedent This LAR is based on similar LARs approved for Arkansas Nuclear One, Unit 2 (ANO-2) on January 31, 2001 (Reference 1) and Seabrook Unit 1 on October 3, 2003 (Reference 2). Both Waterford and ANO-2 are Combustion Engineering plants with similar Boration Systems and the Boration System design basis; and Seabrook is a Westinghouse plant with a similar Boration System design basis.

In addition, Combustion Engineering, Westinghouse, and Babcock and Wilcox plants that have converted to the Improved Standard Technical Specifications have relocated the Boration System TSs to the TRM.

Enclosure to W3F1-2019-0062 Page 11 of 13 4.3 No Significant Hazards Consideration Analysis Entergy Operations, Inc. (Entergy) has evaluated the proposed changes to the Technical Specifications (TSs) using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

Entergy proposes a change to the Waterford 3 (W3) TSs that would relocate TS 3.1.2.1, TS 3.1.2.2, TS 3.1.2.3, TS 3.1.2.4, TS 3.1.2.5, TS 3.1.2.6, TS 3.1.2.7, and TS 3.1.2.8 (including all associated Limiting Condition for Operations, Actions, Surveillance Requirements, and Figures) to the W3 Technical Requirements Manual (TRM).

Basis for no significant hazards consideration determination: As required by 10 CFR 50.91(a),

Entergy analysis of the issue of no significant hazards consideration is presented below:

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

Response: No The Boration Systems (i.e., Boric Acid Makeup Tanks (BAMTs), Boric Acid Makeup Pumps (BAMPs), and Charging Pumps), are part of the Chemical Volume Control System (CVCS);

which functions to maintain Reactor Coolant System (RCS) inventory and chemistry. The relocation of the Boration Systems TSs to the TRM will not alter the functions of the Boration Systems. During accident conditions when a boration source is required for accident mitigation, the Refueling Water Storage Pool (RWSP) provides suction for the High Pressure Safety Injection (HPSI) and Low Pressure Safety Injection (LPSI) pumps.

The CVCS boration systems do not mitigate any accidents. Therefore, the dose consequences associated with accident analysis will be unchanged. The HPSI and LPSI pumps, and RWSP are required by Technical Specifications.

Based on an evaluation of the criterion listed in 10 CFR 50.36(c)(2)(ii), the relocation of the CVCS Boration Systems TSs to the TRM is acceptable. No changes will be made to these systems that will affect their current operation.

Therefore, this change does not involve a significant increase in the probability of consequences of any accident previously evaluated.

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

Response: No The design and functions of the Boric Acid Makeup Tanks, Boric Acid Makeup Pumps, Charging Pumps and associated flow paths will not be changed by the relocation of the Boration Systems TSs to the TRM. These systems are not accident initiators. The proposed change does not result in any physical alterations to the plant configuration, no new structure, system, or component (SSC) is added, no SSC interfaces are modified, and no changes to any design function of an SSC or the methods of SSC operation are being made.

Enclosure to W3F1-2019-0062 Page 12 of 13 Because the proposed amendment will not change the design, configuration or method of operation of the plant, it will not create the possibility of a new or different kind of accident.

Safety Analysis Report (SAR) Chapter 15 provides the analysis of accidents that are considered credible. These accidents were evaluated in relationship to relocating these specifications to the TRM. Boric acid injection via the CVCS system was not credited in mitigating any of these accidents.

Therefore, this change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The movement of these TSs to the TRM does not change any of the requirements of the existing TSs or surveillance requirements. The proposed change does not change the design function for any of these components. Additionally, none of the Boration Systems are required to mitigate any design basis accident. The systems are used to maintain RCS chemistry and inventory and this function will be maintained.

Therefore, this change does not involve a significant reduction in the margin of safety.

Based upon the reasoning presented above, Entergy concludes that the requested change involves no significant hazards consideration, as set forth in 10 CFR 50.92(c), "Issuance of Amendment."

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility 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 change.

Enclosure to W3F1-2019-0062 Page 13 of 13

6.0 REFERENCES

1. Letter from the NRC to Energy Operations, "Arkansas Nuclear One, Unit No. 2 - Issuance of Amendment Re: Relocation of Boration Systems Technical Specifications to the Technical Requirements Manual (TAC NO. MB0610)," dated January 31, 2001 (NRC ADAMS Accession No. ML010320387)

2. Letter from the NRC to FPL Energy Seabrook, LLC, "Seabrook Station, Unit No. 1 - Issuance of Amendment Re: Relocation of Technical Specifications Associated with Boration Systems and Chemistry, and Revision of Selected Technical Specifications Associated with the Reactor Coolant System (TAC NO. MB6614)," dated October 3, 2003 (NRC ADAMS Accession No. ML032510866)

ATTACHMENTS

1. Technical Specification (TS) Page Markups

2. Technical Specification (TS) Bases Page Markups - For Information Only

3. Retyped Technical Specification (TS) Pages

Enclosure Attachment 1 W3F1-2019-0062 Technical Specification (TS) Page Markups TS Pages 3/4 1-6 3/4 1-7 3/4 1-8 3/4 1-9 3/4 1-10 3/4 1-11 3/4 1-12 3/4 1-13 3/4 1-14 3/4 1-14a

REACTIVITY CONTROL SYSTEMS 3/4.1.2 BORATION SYSTEMS FLOW PATHS-SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.1 As a minimum, one of the following boron injection flow paths shall be OPERABLE and capable of being powered from an OPERABLE emergency power source:

a. A flow path from the boric acid makeup tank via either a boric acid makeup pump or a gravity feed connection and any charging pump to the Reactor Coolant System if the boric acid makeup tank in Specification 3.1.2. 7a. is OPERABLE, or

b. The flow path from the refueling water storage pool via either a charging pump or a high pressure safety injection pump to the Reactor Coolant System if the refueling water storage pool in Specification 3.1.2.?b. is OPERABLE.

APPLICABILITY: MODES 5 and 6.

ACTION:

With none of the above flow paths OPERABLE or capable of being powered from an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.*

SURVEILLANCE REQUIREMENTS 4.1.2.1 At least one of the above required flow paths shall be demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

• Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SHUTDOWN MARGIN.

PAGES 3/4 1-6 THRU 3/4 1-14a ARE NOT USED WATERFORD - UNIT 3 3/4 1-6 AMENDMENT NO. 10, 185, 199, 249

REACTIVITY CONTROL SYSTEMS FLOW PATHS -OPERATING LIMITING CONDITION FOR OPERATION 3.1.2.2 At least two boron injection flow paths to the RCS via the charging pumps shall be OPERABLE. The following flow paths may be used:

a. With the contents of either boric acid makeup tank in accordance with Figure 3.1-1, the following flow paths shall be OPERABLE:

1. One flow path from an acceptable boric acid makeup tank via its boric acid makeup pump; and

2. One flow path from an acceptable boric acid makeup tank via its gravity feed valve; or

b. With the combined contents of both boric acid makeup tanks in accor-dance with Figure 3.1-2, both of the following flow paths shall be OPERABLE:

1. One flow path consisting of both boric acid makeup pumps, and

2. One flow path consisting of both gravity feed valves.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

With only one of the above required boron injection flow paths to the Reactor Coolant System OPERABLE, restore at least two boron injection flow paths to the Reactor Coolant System to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY and borated to a SHUTDOWN MARGIN equivalent to the requirements of Specification 3.1.1.1 or 3.1.1.2, whichever is applicable, within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore at least two flow paths to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.1.2.2 At least two of the above required flow paths shall be demonstrated OPERABLE:

a. By verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position in accordance with the Surveillance Frequency Control Program.

b. By verifying that each automatic valve in the flow path actuates to its correct position on an SIAS test signal in accordance with the Surveillance Frequency Control Program.

c. By verifying that the flow path required by Specification 3.1.2.2a.1 and 3.1.2.2a.2 delivers at least 40 gpm to the Reactor Coolant System in accordance with the Surveillance Frequency Control Program.

WATERFORD - UNIT 3 3/4 1-7 AMENDMENT NO. 10, 199, 249

REACTIVITY CONTROL SYSTEMS CHARGING PUMPS - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.3 At least one charging pump or one high pressure safety injection pump in the boron injection flow path required OPERABLE pursuant to Specification 3.1.2.1 shall be OPERABLE and capable of being powered from an OPERABLE emergency power source.

APPLICABILITY: MODES 5 and 6.

ACTION:

With no charging pump or high pressure safety injection pump OPERABLE or capable of being powered from an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.*

SURVEILLANCE REQUIREMENTS 4.1.2.3 No additional Surveillance Requirements other than those required by the INSERVICE TESTING PROGRAM.

• Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SHUTDOWN MARGIN.

WATERFORD - UNIT 3 3/4 1-8 AMENDMENT NO. 185, 189,250

REACTIVITY CONTROL SYSTEMS CHARGING PUMPS - OPERATING LIMITING CONDITION FOR OPERATION 3.1.2.4 At least two independent charging pumps shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

With only one charging pump OPERABLE, restore at least two charging pumps to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY and borated to a SHUTDOWN MARGIN equivalent to the requirements of Specification 3.1.1.1 or 3.1.1.2, whichever is applicable, within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore at least two charging pumps to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.1.2.4 Each required charging pump shall be demonstrated OPERABLE by verifying that each charging pump starts in response to an SIAS test signal in accordance with the Surveillance Frequency Control Program.

WATERFORD - UNIT 3 3/4 1-9 AMENDMENT NO . .i+, 249

REACTIVITY CONTROL SYSTEMS BORIC ACID MAKEUP PUMPS - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.5 At least one boric acid makeup pump shall be OPERABLE and capable of being powered from an OPERABLE emergency bus if only the flow path through the boric acid pump in Specification 3.1.2.1 a. is OPERABLE.

APPLICABILITY: MODES 5 and 6.

ACTION:

With no boric acid makeup pump OPERABLE as required to complete the flow path of Specification 3.1.2.1a., suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

• SURVEILLANCE REQUIREMENTS 4.1.2.5 No additional Surveillance Requirements other than those required by the INSERVICE TESTING PROGRAM.

• Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SHUTDOWN MARGIN.

WATERFORD - UNIT 3 3/4 1-10 AMENDMENT NO. 185, 189, 250

REACTIVITY CONTROL SYSTEMS BORIC ACID MAKEUP PUMPS - OPERATING LIMITING CONDITION FOR OPERATION 3.1.2.6 At least the boric acid makeup pump(s) in the boron injection flow path(s) required OPERABLE pursuant to Specification 3.1.2.2a. shall be OPERABLE and capable of being powered from an OPERABLE emergency bus if the flow path through the boric acid pump(s) in Specification 3.1.2.2a. is OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

With one boric acid makeup pump required for the boron injection flow path(s) pursuant to Specification 3.1.2.2a. inoperable, restore the boric acid makeup pump to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and borated to a SHUTDOWN MARGIN equivalent to the require-ments of Specification 3.1.1.1 or 3.1.1.2, whichever is applicable, restore the above required boric acid makeup pump(s) to OPERABLE status within the next 7days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.1.2.6 Each required boric acid makeup pump shall be demonstrated OPERABLE by verifying that each boric acid makeup pump starts in response to an SIAS test signal in accordance with the Surveillance Frequency Control Program.

WATERFORD - UNIT 3 3/4 1-11 AMENDMENT NO. 44, 249

REACTIVITY CONTROL SYSTEMS BORATED WATER SOURCES- SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.7 As a minimum, one of the following borated water sources shall be OPERABLE:

a. One boric acid makeup tank with a boron concentration between 4900 ppm and 6125 ppm and a minimum borated water volume of 36% indicated level.

b. The refueling water storage pool (RWSP) with:

1. A minimum contained borated water volume of 12% indicated level, and

2. A minimum boron concentration of 2050 ppm.

APPLICABILITY: MODES 5 and 6.

ACTION:

With no borated water sources OPERABLE, suspend all operations involving CORE AL TERA TIONS or positive reactivity changes.

• SURVEILLANCE REQUIREMENTS 4.1.2.7 The above required borated water source shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program when the Reactor Auxiliary Building air temperature is less than 55 ° F by verifying the boric acid makeup tank solution is greater than or equal to 60 ° F (when it is the source of borated water).

b. In accordance with the Surveillance Frequency Control Program by:

1. Verifying the boron concentration of the water, and

3. Verifying the contained borated water volume of the tank.

• Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SHUTDOWN MARGIN.

WATERFORD- UNIT 3 3/4 1-12 AMENDMENT NO. 10, 129, 185, 199, 249

REACTIVITY CONTROL SYSTEMS BORATED WATER SOURCES- OPERATING LIMITING CONDITION FOR OPERATION 3.1.2.8 Each of the following borated water sources shall be OPERABLE:

a. At least one of the following sources:

1) One boric acid makeup tank, with the tank contents in accordance with Figure 3.1-1, or

2) Two boric acid makeup tanks, with the combined contents of the tanks in accordance with Figure 3.1-2, and

b. The refueling water storage pool in accordance with Specification 3.5.4.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

a. With the above required boric acid makeup tank(s) inoperable, restore the tank(s) to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and borated to a SHUTDOWN MARGIN equivalent to the requirements of Specification 3.1.1.1 or 3.1.1.2, whichever is applicable; restore the above required boric acid makeup tank(s) to OPERABLE status within the next 7 days or be in .

COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With the refueling water storage pool inoperable, restore the pool to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.1.2.8 Each borated water source shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by verifying the boric acid makeup tank solution temperature is greater than or equal to 60 ° F when the Reactor Auxiliary Building air temperature is less than 55 ° F.

b. In accordance with the Surveillance Frequency Control Program by:

1. Verifying the boron concentration in the water, and

2. Verifying the contained borated water volume of the water source.

WATERFORD - UNIT 3 3/41-13 AMENDMENT NO. 10, 19, 129, 147, 199, 249

REQUIRED STORED BORIC ACID VOLUME AS A FUNCTION OF CONCENTRATION (VOLUME OF ONE BAMT) 11500 (96%)

11000 (92%)

10500 (87%)

' 10000 z

0

( < (82%)

La X 9500 n w 0 j

> w (78%)

g i 9000 a (73%)

L3O 4 C 8500 a (69%)

8000 (64%)

7500 (60%)

7000 (55%)

6500L 4800 BORIC ACID CONCENTRATION, ppm FIGURE 3.1-1 I

WATERFORD - UNIT 3 314 1-14 AMENDMENT NO. 40,45,141,-47 I 199

REQUIRED STORED BORIC ACID VOLUME AS A FUNCTION OF CONCENTRATION (COMBINED VOLUME OF TWO BAMT) 12500 12300 (100%) REGION OF ACCEPTABLE 12000 OPERATION (96%)

I 11500 1 iiiI I 1

\ \1 1 > RW5P at 2050ppml p (91%) _ XiL \ ><I RWSP at 2300 ppml__

11000 ZO On m (n.. N j/ I RWSP at2600 p

<ui 0 (87%)

C z X "'1 SP at/290 10500 \ X \s- A Rn - .

\ i>

(82%)

10000 LY0<

(77%)

jmu z 9500

\

(73%)

nnnn YuuU

/

(68%)

8500

-i - I I REGION OF UNACCEPTABLE (64%) I OPERATION 8000 I I I I I (59%)

__ _ _ _ t 7500 41BOO 4900 5000 5200 5400 5600 5800 6000 6125 6200 BORIC ACID CONCENTRATION, ppm FIGURE 3.1-2 I WATERFORD - UNIT 3 3/4 1-14a AMENDMENT NO. 199

Enclosure Attachment 2 W3F1-2019-0062 Technical Specification (TS) Bases Page Markups For Information Only TS Bases Pages IV XIX B 3/4 1-2 B 3/4 1-3

º(DRN 05-747, Ch. 40)

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.0 APPLICABILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 0-1 3/4.1 REACTIVITY CONTROL SYSTEMS 3/4.1.1 BORATION CONTROL SHUTDOWN MARGIN - ANY CEA WITHDRAWN . . . . . . . . . . . . . 3/4 1-1 SHUTDOWN MARGIN - ALL CEAS FULLY INSERTED . . . . . . . . 3/4 1-3 MODERATOR TEMPERATURE COEFFICIENT . . . . . . . . . . . . . . 3/4 1-4 MINIMUM TEMPERATURE FOR CRITICALITY . . . . . . . . . . . . . . 3/4 1-5 3/4.1.2 BORATION SYSTEMS FLOW PATHS - SHUTDOWN . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 1-6 FLOW PATHS - OPERATING . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 1-7 CHARGING PUMPS - SHUTDOWN . . . . . . . . . . . . . . . . . . . . . . . . 3/4 1-8 CHARGING PUMPS - OPERATING . . . . . . . . . . . . . . . . . . . . . . . . 3/4 1-9 DELETED BORIC ACID MAKEUP PUMPS - SHUTDOWN . . . . . . . . . . . . . . 3/4 1-10 BORIC ACID MAKEUP PUMPS - OPERATING . . . . . . . . . . . . . . 3/4 1-11 BORATED WATER SOURCES - SHUTDOWN . . . . . . . . . . . . . . 3/4 1-12 BORATED WATER SOURCES - OPERATING . . . . . . . . . . . . . . 3/4 1-13 BORON DILUTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 1-15 3/4.1.3 MOVABLE CONTROL ASSEMBLIES CEA POSITION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 1-18 POSITION INDICATOR CHANNELS - OPERATING . . . . . . . . . . 3/4 1-21 POSITION INDICATOR CHANNELS - SHUTDOWN . . . . . . . . . . 3/4 1-22 CEA DROP TIME . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 1-23 SHUTDOWN CEA INSERTION LIMIT . . . . . . . . . . . . . . . . . . . . . 3/4 1-24 REGULATING AND GROUP P CEA INSERTION LIMITS . . . . . . 3/4 1-25

>>(DRN 05-747, Ch. 40)

º(DRN 05-747, Ch. 40)

WATERFORD - UNIT 3 AMENDMENT NO. 11, 33, 182, 199

>>(DRN 05-747, Ch. 40) IV CHANGE NO. 40

º(DRN 05-747, Ch. 40)

INDEX LIST OF FIGURES FIGURE PAGE 3.1-1 REQUIRED STORED BORIC ACID VOLUME AS A FUNCTION OF CONCENTRATION (VOLUME OF ONE BAMT)....................... 3/4 1-14 DELETED 3.1-2 REQUIRED STORED BORIC ACID VOLUME AS A FUNCTION OF CONCENTRATION (COMBINED VOLUME OF TWO BAMT)... 3/4 1-14a 3.4-1 DELETED..................................................................................... 3/4 4-27 3.4-2 WATERFORD UNIT 3 HEATUP CURVE - 32 EFPY REACTOR COOLANT SYSTEM PRESSURE - TEMPERATURE LIMITS....................................................................................... 3/4 4-30 3.4-3 WATERFORD UNIT 3 COOLDOWN CURVE - 32 EFPY REACTOR COOLANT SYSTEM PRESSURE -TEMPERATURE LIMITS....................................................................................... 3/4 4-31 3.6-1 DELETED.................................................................................... 3/4 6-12

º(EC-15515, Ch. 60) 4.7-1 DELETED

>>(EC-15515, Ch. 60) 5.1-1 EXCLUSION AREA...................................................................... 5-2 5.1-2 LOW POPULATION ZONE.......................................................... 5-3 5.1-3 SITE BOUNDARY FOR RADIOACTIVE GASEOUS AND LIQUID EFFLUENTS................................................................. 5-4

º(EC-18742, Ch. 65) 5.6-1 ALTERNATIVE CHECKERBOARD STORAGE ARRANGEMENTS 5-6a 5.6-2 ACCEPTABLE BURNUP DOMAIN FOR UNRESTRICTED STORAGE OF IRRADIATED FUEL IN REGION 2 OF THE SPENT FUEL POOL.................................................................. 5-6b 5.6-3 ACCEPTABLE BURNUP DOMAIN FOR IRRADIATED FUEL IN A CHECKERBOARD ARRANGEMENT WITH FUEL OF 5 WT% ENRICHMENT, OR LESS, AT 27 GWD/MTU BURNUP, OR HIGHER, IN REGION 2 OF THE SPENT FUEL POOL............................................................................................ 5-6c 5.6-4 EXAMPLES OF CONTIGUOUS CHECKERBOARD CONFIGURATIONS WHICH MEET INTERFACE REQUIREMENTS........................ 5-6d

>>(EC-18742, Ch. 65) 6.2-1 DELETED..................................................................................... 6-3 6.2-2 DELETED..................................................................................... 6-4

>>(DRN 05-747, Ch. 40)

º(DRN 05-747, Ch. 40)

WATERFORD - UNIT 3 XIX AMENDMENT NO. 13, 27, 102, 184, 188,

>>(DRN 05-747, Ch. 40) 196, 199 CHANGE NO. 40, 60, 65

REACTIVITY CONTROL SYSTEMS THIS PAGE IS NOT USED BASES 3/4.1.2 BORATION SYSTEMS

º(DRN 04-1243, Ch. 38)

The boron injection system ensures that negative reactivity control is available during each mode of facility operation. The components required to perform this function include (1) borated water sources, (2) charging pumps, (3) separate flow paths, (4) boric acid makeup pumps, and (5) an emergency power supply from OPERABLE diesel generators.

>>(DRN 04-1243, Ch. 38)

With the RCS average temperature above 200°F, a minimum of two separate and redundant boron injection systems are provided to ensure single functional capability in the event an assumed failure renders one of the systems inoperable. Allowable out-of-service periods ensure that minor component repair or corrective action may be completed without undue risk to overall facility safety from injection system failures during the repair period.

º(DRN 04-1243, Ch. 38)

The boration capability is sufficient to provide a SHUTDOWN MARGIN of 5.15%

delta k/k with zenon-free conditions, RCS temperature greater than 200°F, and letdown secured. The maximum expected boration capability requirement occurs at EOL from full power equilibrium xenon conditions assuming the most reactive CEA stuck out of the core and requires boric acid solution from the boric acid makeup tanks in the allowable concentrations and volumes of Specification 3.1.2.8 plus 10,064 gallons of 2050 ppm borated water from the refueling water storage pool. The higher limit of 83% indicated is specified to be consistent with Specification 3.5.4 in order to meet the ECCS requirements.

>>(DRN 04-1243, Ch. 38)

º(DRN 03-375, Ch.19)

With the RCS temperature below 200°F one injection system is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the additional restrictions prohibiting CORE ALTERATIONS and positive reactivity changes in the event the single injection system becomes inoperable. Temperature changes in the RCS impose reactivity changes by means of the moderator temperature coefficient. Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SDM. This will require a new SDM calculation be performed if the current SDM calculation does not bound the temperature change. Small changes in RCS temperature are unavoidable and so long as the required SDM is maintained during these changes, any positive reactivity additions will be limited to acceptable levels. Introduction of temperature changes must be evaluated to ensure they do not result in a loss of required SDM.

>>(DRN 03-375, Ch. 19)

º(DRN 04-1243, Ch. 38)

The boron capability required below 200°F is based upon providing a 2% delta k/k SHUTDOWN MARGIN after xenon decay and cooldown from 200°F to 140°F. This condition requires either 1,727 gallons of 2050 ppm borated water from the refueling water storage pool or boric acid solution from the boric acid makeup tanks in accordance with the requirements of Specification 3.1.2.7.

>>(DRN 04-1243, Ch. 38)

AMENDMENT NO. 10, 129 WATERFORD - UNIT 3 B 3/4 1-2 CHANGE NO. 19, 38

REACTIVITY CONTROL SYSTEMS BASES BORATION SYSTEMS (Continued)

º(DRN 04-1243, Ch. 38)

The contained water volume limits include allowance for water not available because of discharge line location, instrument tolerances, and other physical characteristics. The unusable water volume in one Boric Acid Makeup Tank is half the unusable water volume when using two Boric Acid Makeup Tanks. Consequently, Figures 3.1-1 and 3.1-2 are provided for using one or two Boric Acid Makeup Tanks to satisfy the requirements of TS 3.1.2.2 and 3.1.2.8.

The 60 °F minimum Boric Acid Makeup Tank solution indicated temperature limit insures that the boron will not precipitate even at the maximum allowed boron concentration when instrument accuracies are considered. The precipitation temperature at the maximum allowed Boric Acid Makeup Tank boron concentration is 50.2 °F. The 60 °F minimum indicated temperature limit also insures that the minimum Boric Acid Makeup Tank solution temperature assumed in the safety analysis (49 °F) is bounded. The 55 °F Reactor Auxiliary Building temperature prerequisite for monitoring Boric Acid Makeup Tank solution temperature is acceptable due to the increased accuracy of the Reactor Auxiliary Building temperature indications available on the plant monitoring computer.

>>(DRN 04-1243, Ch. 38)

The OPERABILITY of one boron injection system during REFUELING ensures that this system is available for reactivity control while in MODE 6.

º(DRN 04-1243, Ch. 38)

>>(DRN 04-1243, Ch. 38)

(LBDCR 16-046, Ch. 86)

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

ç(LBDCR 16-046, Ch. 86) 3/4.1.2.9 BORON DILUTION This specification is provided to prevent a boron dilution event, and to prevent a loss of SHUTDOWN MARGIN should an inadvertent boron dilution event occur. Due to boron concentration requirements for the RWSP and boric acid makeup tanks, the only possible boron dilution that would remain undetected by the operator occurs from the primary makeup water through the CVCS system.

Isolating this potential dilution path or the OPERABILITY of the startup channel high neutron flux alarms, which alert the operator with sufficient time available to take corrective action, ensures that no loss of SHUTDOWN MARGIN and unanticipated criticality occur.

The ACTION requirements specified in the event startup channel high neutron flux alarms are inoperable provide an alternate means to detect boron dilution by monitoring the RCS boron concentration to detect any changes. The frequencies specified in the COLR provide the operator sufficient time to recognize a decrease in boron concentration and take appropriate corrective action without loss of SHUTDOWN MARGIN. More frequent checks are required with more charging pumps in operation due to the higher potential boron dilution rate.

WATERFORD - UNIT 3 B 3/4 1-3 AMENDMENT NO. 9-102 CHANGE NO. 38, 86

Enclosure Attachment 3 W3F1-2019-0062 Retyped Technical Specification (TS) Pages TS Page 3/4 1-6

PAGES 3/4 1-6 THRU 3/4 1-14a ARE NOT USED WATERFORD - UNIT 3 3/4 1-6 AMENDMENT NO. 10, 185,199, 249