Text

Discusses Util 851011 Proposed Changes to Helium Circulator, Steam Generator & Liner Cooling Sys Limiting Conditions for Operation.Review of Encls 1-3 Requested
	ML20141E512
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/27/1985
From:	Berkow H; Office of Nuclear Reactor Regulation
To:	Walker R; PUBLIC SERVICE CO. OF COLORADO
References
	NUDOCS 8601070733
	Download: ML20141E512 (48)
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o, UNITED STATES NUCLEAR REGULATORY COMMISSION 3

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W ASHINGTON, D. C. 20555 k

... d' December 27, 1985 Docket No. 50-267 Mr. R. F. Walker, President Public Service Company of Colorado Post Office Box 840 Denver, Colorado 80201

Dear Mr. Walker:

SUBJECT:

FORT ST. VRAIN (FSV) - TECHNICAL SPECIFICATION UPGRADE - NRC PROPOSED REVISIONS 10 LIMITING CONDITIONS FOR OPERATION (LCOs)

Reference:

Letter from Public Service Company of Colorado (PSr), to NRC, dated October 11,1985(P-85363)

The referenced letter proposed changes to the helium circulator, steam generator, and liner cooling system LCOs, and provided PSC responses to applicable action items resulting from the July 22-26, 1985 meetings between the NRC and PSC.

Based on the initial staff comments (Enclosure 1), a decision was made by the staff to redraft the above LCOs (Enclosure 2) into a format consistent with the Standard Technical Specifications. The equipment redundancy necessary during normal and abnormal operations was also included to ensure system

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availability in certain events as analyzcd in your FSAR. We have also provided the staff's comments (Enclosure 3) on your response to applicable action items.

We request that you review Enclosure 2 and identify to us any statements which do not accurately reflect the FSV FSAR or current plant configurations. We also request your review of the enclosed corrrnents (Enclosures 1 and 3) generated during the staff's review of your October 11, 1985 submittal.

8601070733 851227 PDR ADOCK 05000267 P

FDR

So 207 F

December 27, 1985 Mr. O. R. Lee Please provide your response within 30 days of receipt of this letter. Any questions on this material should be addressed to the assigned Project Manager, Kenneth L. Heitner.

He may be reached at (301) 492-7364.

Sincerely, Original signed by Herbert N. Berkow, Director Standardization and Special Projects Directorate Division of PWR Licensing-B, NRR

Enclosures:

1.

Marked-up copies of LCOs containing s',aff comments 2.

Redraft of LCOs into format consistent with the Standard Technical Specifications 3.

Staff Coments on PSC's Response to Applicable Action Items cc: See next page DISTRIBUTION:

Docket File NRC & L PDRs SSPD Rdg EJordan DCS BGrimes NSIC OELD PNoonan PWagner, RI V KHeitner JPartlow 0 Lynch ACRS(10)

HBerkow FMiraglia GLPlumlee, F0B e

Md

.SSPD DPWRL-B:SSPD 0 WR -B:SSPD DPW

SSPD an:ac KHeitner 0

h HBe V

2p/85 12/N/85 12/$ 85 12/j) 85

o Mr. O. R. Lee l Please provide your response within 30 days of receipt of this letter. Any questions on this material should be addressed to the assigned Project Manager, Kenneth L. Heitner. He may be reached at (301) 492-7364.

Sincerel,

f erbert N. Berkow, Director Standardization and Special Projects Directorate Division of PWR Licensing-B, NRR

Enclosures:

l 1.

Marked-up copies of LCOs containing staff comments 2.

Redraft of LCOs into_ format consistent with the Standard Technical Specifications-3.

Staff Comments on PSC's Response to Applicable Action Items cc: See next page 4

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o Mr. O. R. Lee Public. Service Company of Colorado Fort St. Vrain cc:

C. K. Millen Albert J. Hazle, Director Senior Vice President Radiation Control Division Public Service Company 4210 East lith Avenue of Colorado Denver, Colorado 80220 P. O. Box 840-Denver, Colorado 80201 J. W. Gahm Nuclear Production Manager Mr. David Alberstein,14/159A Public Service Company of Colorado GA Technologies Inc.

P. O. Box 368 P. O. Box 840 Platteville, Colorado 80651 Denver, Colorado 80201 I

J. K. Fuller, Vice President Public Service Company of Colorado P. O. Box 840 Denver, Colorado 50201 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. 0. Box 640 Platteville, Colorado 80651 1

Kelley, Stansfield & 0'Donnell Public Service Company Building Room 900 550 15th Street j

Denver, Colorado 80202 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Office of Executive Director for Operations 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Chairman, Board of County Commissioners of Weld County, Colorado Greeley, Colorado 80631 Regional Representative Radiation Programs Environmental Protection Agency 1800 Lincoln Street Denver, Colorado 80651 2

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ENCLOSURE 1 MARKED UP COPIES OF LCOs CONTAINING STAFF COMMENTS

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c Jo*go. I o F tr Amendment No.

Page 3/4 5-PRIMARY COOLANT SYSTEM 3/4.5.1 HELIUM CIRCULATORS LIMITING CONDITION FOR OPERATION 3.5.1.1 At least one helium circulator in each loop shall be g

OPE with:

a.

Emergency' circulator drive capable of providing the equivalent of 8000 rpm circulator speed at atmospheric pressure; b*

Two emergency water booster pumps (P-2109 and P-2110)

OPERABLE, including two OPERABLE flow paths with the capability to drive the circulator at 34 rated helium flow with firewater supply; c.

The turbine water remo'al

system, including two v

turbine water - removal pumps (P-2103 and P-21035)

OPERABLE;

O a-rh

=orm 1 6 ria,was r =v te=, i==1=at=,two ource-of bearing water makeup and two bearing water makeup pumps (P-2105 and P-2108) OPERABLE; e.

The associated bearing water accumulators (T-2112, T-2113, T-2114, and T-2115) OPERABLE; and f.

OPERABLE supply and discharge valve interlocks on.each associated circulator ensuring automatic water turbine start capability following steam turbine trip.9 POWER,LOWPOWER,STARTUP{andSHUTDOWN*

APPLICABILITY:

i

a. w.,-

With halculate CORE RAGE INLET TEMPERATURES greater than or equal t degrees F.

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9 he supply and discharge valve interlocks are only equired to be OPERABLE in POWER.

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o Amendment No.

Page 3/4 5-ACTION:

a.

With less than one OPERABLE helium circulator in each loop (fo reasons other than those identified in ACTIONS and c below) 0:

ith ler: ther th: ::7; ired i-S Onn L"

7ci; :nt identi'ind least'pecific :ic.

0.0.1.1, ite-e.

restore at one helium circulator in each loop or the inoperable equipment to 4t OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or:

1.

If in

POWER, 14W POWER, or STARTUP, be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or 2.

If in SHUTDOWN, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

Ob. With less than the required OPERABLE equipment identified in Specification 3.5.1.1, items a, b, c, d, or f,

but with the capability to drive a helium circulator on steam motive

power, restore the i

inoperabla equipment to OPERABLE status within 7 days or be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c.

With no helium circulators OPERABLE and all forced circulation

lost, be in SHUTDOWN immediately and

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restore forced circulation within 90 minutes or depressurize the PCRV in accordance with the applicable requirement below 1.

As a

' function of reactor thermal power prior to

)

SHUTDOWN equal to or greater than 25%

as delineated in Figure 3.5.1-1.

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-frA 2.

As a

function of CORE AVERAGE 4eMrB9 TEMPERATURE for reactor thermal power prior to SHUTDOWN less than 2$4 as delineated in Figure 3.5.1-2.

3.

As a

function of time frota reactor SHUTDOWN as delineated in Figure 3.5.1-3.

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Pe* J e+ /.f Amandmant No.

Page 3/4 5-SURVEILLANCE REQUIREMENT 4.5.1.1 The helium circulators shall be demonstrated bPERABLE:

At least once per 31 ' days by testing the bearing water a.

accumulators and verifying accumulator riow to the TWAT acSv circulator bearing.

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At least once per AEEUELEKM;3 GEE by:

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1. N Performing a

turbine water removal pump (P-2103 and P-21035) start test based on a

simulated drain tank level to verify automati p 6tuat p and

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[SI/I8 pump start capability.

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2.

Performing a

bearing water makeup pump (P-2105 and P-2108) start test based on a simulated low pressure in the backup nearing water supply lina to verify automatic actuation and pump start capability.

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3.

Testing the water turbine inlet and outlet valve interlocks ensuring automatir water turbine start I

capability by simulating a6tiam turbine trip.f"*%.

- f 4.

Monitoring the proper closure of the circulator t

helium shutoff valves.

c.

At least once per REFUELING CYCLE on a STAGGERED TEST l

BASIS whereby circulators 13 and ID will be tested i

during even. numbered cycles and circulators IA and 1C i

-l during odd numbered cycles, by demonstrating operation on water turbine drive by:

l i

1.

Verifying an equivalent 8000 rpm (at atmospheric pressure) on feedwater motive power using the emergency feedwater header, and

' esting each circulator by verifying an i

2.

T equivalent 34 rated helium flow on condensate at reduced pressure (to simulate firewater pump discharge) using each emergency water booster pump (P-2109 and P-2110).

3,

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Page 3/4 5-d.

At lear,t once per 10 years by verifying:

1.

Each helium circulator compressor wheel rotor, turbine wheel and pelton wheel are free of both surface and subsurface defects in accordance with the appropriate

methods, procedures, and associated acceptance criteria specified for Class I components in Article NB-2500, Section

III, ASME Code.

Other helium circulator components, accessible without further disassembly than required to inspect these wheels, shall be visually examined.

2.

At least 10% of primary coolant pressure boundary bolting and other structural bolting which has been removed for the inspection above and which is exposed to the primary coolant shall be nondestructively tested for identification of i

inherent or developed defects.

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PMs / O LE Amandmant No.

-Page 3/4.5 -

PRIMARY COOLANT SYSTEM

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i 3/4.5.1 HELIUM CIRCULATORS-STARTUP, SHUTDOWN AND REFUELING 0

C O M C y b. N > +

f8"' tt PA LIMITING CONDITION FOR OPERATION h a d 4.p 3.5.1.2 At least one helium circulator shall be OPERABLE withrenc 3

kal:m eieawhe, Ortnwrsw6 e sh w.H :

a.

Emergency circulator drive capable of providing the equivalent of 8000 rpm circulator speed at atmospheric l

4 pressures t

l b.

One emergency water booster pump (P-2109 or P-2110)

OPERABLE including an. OPERABLE flow path with the capability to drive the circulator at 34 rated helium flow with firewater supply; i

c.

The turbine water removal

system, including one I

turbine water removal pump (P-2103 or P-2103S)

OPERABLEr b

d.

The normal bearing water system, including one source i

of bearing water makeup and one bearing water makeup i

pump (P-2105 or P-2108) OPERABLE; and j

e.

The associated bearing water accumulator OPERABLE.

APPLICABILITY:

STARTUP*, SRUTDOWN*, pnd REFUELING

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t With calculate D CORE AVERAGE IJLET TEMPERATURES less

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than 5

cegrees F.

ACTION:

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With no helium circulator OPERABLE, restore the required i

' circulator to OPERABLE status prior to the time calculated l

for the -core to heatup from de eat to a calculated l

CORE AVERAGE INLET TEMPERATURE o

60. egrees F or l

4 1.

Suspend all operations involving CORE ALTERATIONS or positive reactivity changes, and 2.

Initiate PCRV depressurization in accordance with the time specified in Figure 3.5.1-3.

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j2pu Sa i-1 Am2ndmant No.

Paga 3/4.5 -

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t, The requirements for an OPERABLE circulator specified provide for adequate circulator water turbine supply and circulator auxiliary' emergency water boostersupplies to assure safe shutdown cooling.

With less than two pumps (Boorted Firewater),

OPERABLE, coupled with the diverse and redundant means for a7 > ay action statement time is circulator motive power, f estoration of these pu gm considered sufficient f The capacity of each heliua circulator water turbine drive methcd is discussed in FSAR Section 14.

Effective core 1

cooling has been demonstrated analytically with each water turbine drive method.

-Additionally, these two pumps are tested by verifying an equivalent 3% rated helium flow by j

operating the circulators on water turbine drive.

Additional tests, provide assurance that a circulator can operate at an equivalent 8000 rpm at atmospheric pressure based on calculated helium density, reactor pressure and circulator inlet tamperature.

One turbine water removal pump. has sufficient capacity to remove the water from two circulator water turbines.

Also, the turbine water removal tank overflow to the reactor building sump will be used if the normal pump flow path is s

lost.

Therefore, a 7 day action statement time is considered

.)

sufficient for restoration of the

pumps, based on the redundant and diverse means of removing water from the circulator water turbines.

Each independent bearing water system provides a continuous supply of bearing water to the two circulators in each primary

~

cooling loop.

A backup supply of bearing water is provided from the steam generator feedwater system.

Makeup bearing water requirements are also normally obtained from the feedwater system.

A separate bearing water makeup pump is provided as a

backup to supply makeup water to the bearin~g water surge tank.

The bearing water makeup pump normally l

takes suction from the deaerator but can also be supplied from the condensate storage tanks.

If this pump is inoperative, an emergency bearing water makeup pump can supply water at a i

reduced capacity 1hana the condensate storage tank to the bearing water surge tank.

In an extreme emergsney, ffitered i

firewater can be provided to the bearing water surge tark by either the bearing water makeup pump or the emergency bearing water makeup pump.

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Amendment No.

Page 3/4.5 _

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g g sdUTDOWN COOLING SYSTEMS

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g4.5.2 STEAM GENERATORS LIMITING CONDITION FOR OPERATION

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3.5.2.1 Two steam generators shall be OPERABLE with:

Boththereheater[actionandtheeconomizer-evaporator-a.

srperheater (EES) section CPERABLE (each section consisting of six modules) per steam generator, b.' The steam generatcr superheater (EES) and reheater safety valves (V-2214, V-2215, V-2216, V-2245, V-2246, V-2247, V-2225 and V-2262) OPERABLE with set points in accordance with Table 4.5.2-1, and The provisions of specification 3.0.6 are not applicable c.

until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after reaching 250 RATED THERMAL

POWER, to allow testing of the steam generator superheater and reheater safety valves, required following maintenance or per Surveillance Requirements identified in Specification 4.5.2.1 b.1.

APPLICABILITY:

POWER and LOW POWER ACTION:

a.

With less than the above required steam generator sections OPERABLE, restore the required sections to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in STARTUP within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b.

With no steun generator section OPERABLE, be in SHUTDOWN immediately and restore at least one inoperable section to OPERABLE status within 90 minutes or depressurize the PCRV.in accordance with the tires specified in Figures 3.5.1-1 or 3.5.1-2, as applicable.

c.

With one -os--asee of the requirad safety valve inoperable, restore the required valveT>k to OPERABLE status within 72 hears or restrict plant operation as follows:

asi 1.

With ene,EEs safety valve inoperable, reduce THERMAL POWER to less than 50% of RATED THERMAL POWER.

2.

With a

reheater safety valve inoperable, be in STARTUP within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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Am3ndm2nt No.

Page 3/4.5 _

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SURVEILLANCE REQUIREMENTS 4.5.2.1 The steam generators shall be demonstrated OPERABLE:

18 months by verifyin'g proper flow a.

At least once per through the emergency feedwater header and emergency condensate header to the steam generator sections.

At least once per five y% RrPw.t.u e yt.44., f1-prev.k b.

ears by:

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y*~ r 1.

Testing the superheater and reheater safety valves 4 and verifying the

. lift settings as specified in fSJ/pf /f Table 4.5.2-1.

f fr [

2.

Volumetrically examining the accessible portions of the fellowing bimetallic welds for indications of subsurface defects:

1.

The main 1 steam ring header collector to main steam piping weld for one steam generator module in each loop.

s 2.

The main steam ring header collector to

' (.

collector drain piping weld for one steam generator module in each loop.

2 3.

The same two steam generator modules shall be re-examined at each interval.

The initial examination shall be performed during SHUTDOWN or REFUELING prior to the beginning of Fuel cycle 5.

This initial examination shall also include the bimetallic welds described above for two additional steam generator modules in each loop.

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Amandment No.

Page 3/4.5 _,

c.

Tube Leak Examin'ation Each time a

steam generator tube is plugged due to a leak, specimens from the accessible subheader tubes connected to the leaking inaccessible tubes (s) shall be metallographically examined.

The results of this metallographic examination shall be compared to the results from the specimens of all previous tube leaks.

A study shall be performed to evaluate the size and elevation of the tube leaks to determine if a cause of the leak or a trend in the degradation can be identified.

1.

Acceptance criteria i

An engineering evaluation shall be performed to deternine the acceptability of:

1.

Any subsurfme-5mfe ts identified in specification (}.5.2.1c.2, f

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2.

Continued operation considering the condition of the steam generator materials, 3.

OPERABILITY of the steam generator sections considering the number of plugged tubes and their ability to remove decay heat.

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2.

Reports D^

a Within A ? -4IYI

^11C=iN5 bbs 1

E0=$'h 0I On OI AAE steam generator tube leak study a

Special Report shall be submitted to the NRC in accordance with specification 6.9.2.

This report shall include' the estimated size and elevation of the leak (s), and the

'results of the metallographic and engineering apalyses performed, the postulated cause of the leak

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if' identified and corrective action to be taken.

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?"P$A$

i Amendment No.

{

Page 3/4.5,

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(

SAFE SRUTDOWN COOLING SYSTEMS l

3/4.5.2 STEAM GENERATORS LIMITING CONDITION FOR OPERATION 3.5.2.2 The steam generator (s) shall be OPERABLE withs a.

At least two sections (rehe car or economizer-evaporator-superheater) in any combination of.one or both ateam generators OPERABLg n

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n,'t e r b.

The steam generator superheater (ESS) and rehea safety valves (V-2214, V-2215, V-2216, V-2245, V-2246, V-2247, V-2225 and V-2262) which protect the operating sections of the steam generator (s) shall be OPERABLE with setpoints in accordance with Table 4.5.2-1.

C. M haw 4 er % genom be de/tJa, et*fnAnos k e. kop 44 Cffurwe APPLICABILITY:

STARTUP and SHUTDOWN *St**A-4,h.

cin-AA.v.

w.Jo l

With 6 1cu1 M ORE A INLET TEMPERATURES greater than or equal t egrees F.

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ACTION:

i a.

With less than the above required steam generator sections OPERABLE, restore the required sections to 3

OPERABLE statu's within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ors 1.

If in STARTUP, be in at least 3RUTDOWN within the j

next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , or i

l 2.

If in

SRUTDOWN, suspend all operations involving.

CORE ALTERATIONS or positive reactivity changes.

i b.

With no steam generator sections

OPERABLE, be in SHUTDOWN immediately and restore at least one inoperable

-section to OPERABLE status or depressurize the PCRV in accordance with the times specified in Figures 3.5.1.-2 or 3.5.1-3, as applicable.

1 c.

With one ne mara of the required safety valves inoperable, restore the required valvef to OPERABLE j

status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or restrict plant operation as j

follows:

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[

P9a. /* *Ff3 Am2ndm3nt No7 Page 3/4.5 _

1.

With one EES safety valve inoperable, restrict plant

. operation to a maximum of two boiler feed pumps.

2.-

With a

reheater safety valve inoperable, be in SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

s' SURVEILLANCE REQUIREMENTS 4.5.2.2 No additional surveillances required beyond those identified per specification 4.5.2.1.

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Am3ndm3nt Mo.

Page 3/4.5 _

SAFE SHUTDOWN COOLING SYSTEMS 3/4.5.2 STEAM GENERATORS LIMITING CONDITION FOR OPERATION 3.5.2.3.

a.

At least the reheater section or the economizer-evaporator-superheater (EES) section of steam generator #shall be OPERABLE, and M

b.

The steam generator superheater or reheater safety valve (s) which protect the operating section of the steam generator shall be OPERABLE with setpoints in accordance with Table 4.5.2-1.

APPLICABILITY: SHUTDOWN

and REFUELING With dalculat CORE AVERAGE INLET TEMPERATURE less tha Q degrees F.

Mf, f ACTION:

(

With no steam generator section or'its associated safety valve (s)

OPERABLE, restore the required section or safety valve to OPERABLE status prior to the time calculated for the core to heatup from decay heat to a

calculated CO'RE AVERAGE INLET TEMPERATURE of 760 degrees F, or 1.

Suspend all operations involving CORE ALTERATIONS or positive reactivity changes, and i

2.

Initiate PCRV depressurization in accordance with the time specified in Figure 3.5.1-3.

SURVEILLANCE REQUIREMENTS 4.5.2.3 No additional surveillances required beyond those identified per Specification 4.5.2.1.

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Am3ndm2nt No.

Paga 3/4 6-I Pr.; TOR FLA :T O^OLU;" ";AIZA/PCRV AND CONFINEMENT SYSTEMS 3/4.6.2 PCRV LINER COOLING SYSTEM c

LIMITING CONDITION FOR OPERATION 3.6.2.1 The Reactor Plant Cooling Water (RPCW) /PCRV Liner Cooling System (LCs) shall be OPERABLE with:

i eac/

a.

Two (2) loops OPERATINGawith at least one heat exchanger

'j and one pump i n eh 1::; in e- ~4e=+ Or/A4 r/"6,-

b.

At least three (3) eut of any four (4) adjacent tubes on the core support floor side

wall, core support floor bottom casing, PCRV cavity liner sidewalls and PCRV cavity liner bottom head shall be OPERATING; c.

At least five (5) out of any six (6) adjacent tubes on the PCRV cavity liner top head and core support floor top casing shall be OPERATING.

d.

Tubes adjacent to a

non-operating tube shall be

(.-

OPERATING e.n.,,waaa.s w.ua.n +a.w.

APPLICABILITY:

POWER, LOW POWER, STARTUP [and SHUTDOWN

t.,J.Jwd Whenever @ lculateOCORE A GE INLET TEMPERATURE is j

greater than or equal t egrees F.

Ju:, f i

i ACTION i

i a.

With only one (1) RPCW/PCRV Liner Cooling System loop OPERATING, ensure both heat exchangers are OPERATING in the OPERATING loop, restore the second loop to OPERATING j

~

within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in SHUTDONN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and suspend all operations involving positive reactivity changes.

Without both heat exchangers in the OPERATING loop OPERATING or without any liner cooling system loop flow be in SHUTDOWN within 15 minutes and suspend all operations involving positive reactivity changes.

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Am3ndm3nt No.

bM N *b Pago 3/4 6-b.

With.less than the above required number of PCRV Liner Cooling System tubes OPERATING, restore the required tubes to OPERATING status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and suspend all operations involving positive reactivity changes.

SURVEILLANCE REQUIREMENTS 4.6.2.1 The RPCW/PCRV Liner Cooling System shall be demonstrated OPERABLE:

a.

At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , by verifying that each PCRV Liner Cooling System loop is circulating cooling water at a flow rate greater than 1100 gym.

4 b.

At least once per 31

days, by verifying that liner cooling tube outlet to:nparature readings and their respective inlet header temperatures (for an operating f5T,?

loop) are within one of the following limits:

f 1.

30 degrees F temperature rise for tubes cooling top head penetrations:

C 2.

20 degrees F

temperature rise for all other zones except tubes specified below; 3.

Exceptions a) Core Outlet Thermometer Penetrations 4

4,W Tube Delta T y,W p, ob

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MVSN g,j 7893 23 degrees F 4

b) Core Barrel Seal / Core Support Floor Area Tube Delta T F12T46 47 degrees F F7T43 39 degrees F F6T44 43 degrees F F11T45 38 degrees F F5T47 46 degrees F 1

l

Amindm2nt No.

88)* f *f((

Pcg3 3/4 6-c) Peripheral Seal Tube Delta T 3S9 23 degrees F 4S188 23 degrees F 4S10 23 degress F 35187 23 degrees F If the tube outlet temperature reading for any liner cooling tube is not available due to an instrument

failure, the tube may be considered OPERABLE if two tubes on both sides of the tube with an instrument failure (4

tubes total) are within their respective temperature limits as specified above.

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f*) U' el-/ r Amsndmant No.

Pago 3/4 6-PCRV and CONFINEMENT SYSTEMS 3 /4.6. 2 *""T^*

PL""" O^^L!"O .TERfPCRV LINER COOLING SYSTEM LIMITING CONDITIONS FOR OPERATIONS f'a. 7We (2) EPew/hu AU /emas OFEAnnut 4A ame in*>+

e f. y a.I Dn en ~

he*4 sw eA*.pe k e**A k og.

j 3.6.2.2 The Reactor Plant Cooling Water (RPCW)/PCRV Liner Cooling System -(LCS) shall be OPERABLE with M One (1)

RPCW/PCRV Liner Cooling System Icop4 OPERATING Cwith as Ausst nuas excnanger and one pump]i-

_4 vow

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j APPLICABILITY: STARTUP*6, SHUTDOWN *f, and REFUELINGG l

ACTION:

a.

With no itPCW/PCRV Liner Cooling System loop OPERATING, restore at least one loop to OPERATING status prior to the time calculated for the core to heatup from decay heat to a calcula e CORE AVERAGE INLET TEMPERATURE of 760 degrees F

uspend all operations involving CORE j

ALTERATIONS or positive reactivity changes.

(;

SURVEILLANCE REQUIREMENTS I

4.6.2.2 No additional. surveillance requirements other than those identified per specification 4.6.2.1.

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Who r 6 1culatel> CORE AVERAGE INLET TZMEPRATURE is less l

tha de

~**.greesF.

6 The core support floor zone of the PCRV Liner Cooling i

System may be valved out when PCRV pressure is less than or equal to 150 psia and calculated CORE AVERAGE INLET TEMPERATURE is less than 200 degrees F.

i 4

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NJ '".S *I/.d-Am2ndmsnt No.

Page 3/4 6-i I

The action times specified for recovery of two operating loops comes from analyses. described in FSAR Section 5.9.2.4

)

i.e.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months operation on one loop before temperature of the bulk concrete would rise 20 degrees F.

With the number of cooling tubes less than required, a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months action time is sufficient to identify and restore the tube to operating status (if possible) or SHUTDOWN to make permanent repairs.

The surveillance (s) and their respective intervals are specified to verify operability of the Liner Cooling System.

Components and features of the Reactor Plant Cooling Water System that are not safety-related do not affect LCS operability.

The ISI/IST Program at Fort St. Vrain verifies operability of those barriers that separate safety and non-rafety related portions of the system.

A 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months surveillance on system flow rates provides additional verification of flow as process alarms monitor flow continuously in each liner cooling loop.

Individual tube i

4 failures would be expected to occur slowly, thus a 31' day surveillance interval will detect tube failures in time to take corrective action.

With calculated CORE AVERAGE INLET TEMPERATURE below 760 degrees F, one operating Liner Cooling System loop is

(,,

acceptable without single failure consideration on the basis of the stable reactivity condition reactor and the limitedcorecoolingrequirements.qpfthe g 3.w,, egg,7 i

When the PCRV pressure is less than 150 psia and calculated i

l CORE AVERAGE INLET TEMPERATURE is less than 200 degrees F,

i the core support floor sones of the liner cooling system may be valved out as concrete temperatures will be less than the

]

l 250 degree FSAR limitation.

Thus, leaking liner cooling tubes which are awaiting repairs will not contribute to l'

potential moisture ingress into the primary system.

In Surveillance Requirement 4.6.2.1.b.,

tube outlet i

temperatures are determined by thermocouple readings.

In i

the event of an instrument failure (i.e. a thermocouple is i

thought to be failed), the. tube with the failed thermocouple may be considered OPERABLE if thermocouple readings for two adjacent tubes on either side of that tube are within their respective temperature limits.

If the tube itself failed rather than the thermocouple, then the temperature of adjacent tubes would be expected to rise.

Thus, a failed thermocouple can be identified vs. an actual tube failure.

Power operation may continue until such time as the thermocouple can be repaired or replaced as long as the total of 4 adjacent tubes (2 on either side of the tube with the failed instrument) are within their respective temperature limits.

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f Am2ndmant No.

Pega 3/4 6-PCRV AND CONFINEMENT SYSTEMS 3/4.6.3 REACTOR PLANT COOLING WATER /PCRV LINER COOLING SYSTEM TEMPERATURES LIMITING CONDITIONS FOR OPERATION s

1 3.6.3 The RPCW/PCRV Liner cooling System (LCS) temperatures shall be maintained within the following limits:

a.

The maximum average temperature difference between the cosanon PCRV cooling water discharge temperature and the PCRV external concrete surface temperature shall not i

exceed 50 degrees F.

b.

The maximum PCRV ' Liner Cooling System water outlet temperature shall not exceed 120 degrees F. (is - - a 4 7) c.

The maximum change of the weekly average'PCRV concrete i

p,b temperature shall not exceed 14 degrees F per week.

' D. S@R l

5 The maximum temperature difference across the RPCW/PCRV

.g g,11 Liner Cooling Water Heat Exchanger (LCS portion) shall not exceed 20 degrees F.

The minimum average LCS water temperature shall be greater e.

than or equal to 100 degrees F.

APPLICABILITY: At all times ACTION:

a.

If any"of the above conditions can not be restored within

~-

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , be in SHUTDOWN or REFUELING within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ' and suspend all operations involving CORE ALTERAT}ONSorpositivereactivitychanges..

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Amandm2nt No.

Page 3/4 6-SURVEILLANCE REQUIREMENTS 4.6.3 The RPCW[PCRV Liner Cooling System temperatures shall be demonstrated to be within their respective limits at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by s'

Verifying that the maximum temperature difference averaged a.

over a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period between the PCRV external concrete surface temperature and the common PCRV cooling water discharge temperature in each Icop does not exceed 50 degrees F.

b.

Verifying that the maximum PCRV liner cooling water outlet temperature does not exceed 120 degrees F as measured by P,CRV liner cooling water outlet temperature in each loop.

c.

Verifying that the change in PCRV concrete temperature does not exceed 14 degrees F per week as indicated by the weekly average water temperature measured at the common PCRV cooling water outlet temperature in each loop.

The weekly average water temperature is determined by computing the arithmetical mean of 7

temperatures, representing each of the last 7

days of common PCRV cooling water outlet temperatures in each loop.

Each day

(, :

results in a new computation of a weekly average water temperature.

The new weekly average is then compared to the weekly average water temperature computed 7 days earlier to verify Specification 3.6.3.c.

d.

Verifying that the maximum delta T across the RPCW/PCRV Liner Cooling System heat exchanger does not exceed 20 degrees F as measured by the PCRV heat exchanger outlet temperature and the common PCRV liner cooling water outlet temperature in each loop.

I a.

Verifying that the minimum average water temperature of the PCRV Liner Cooling System is greater than or equal to 100 degrees F as measured by the average of the PCRV Liner Cooling System heat exchanger (LCS side) inlet and outlet temperatures.

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Amendment No.

Page 3/4.5 -

' PRIMARY COOLANT SYSTEM 3/4.5.1 PRIMARY COOLANT LOOPS AND C00LAN1 CIRCULATION LIMITING CONDITION FOR OPERATION l

3.5.1.1 Both primary coolant loops shall be in operation, each with:

a.

Two helium circulators OPERABLE.* Reactor power will at all times be limited in accordance with the number of circulators as follows:

Number Circulators Percent Rated Thermal Power l

1 H < P 5 35 1

2 in one loop P 5 50%

1 in each loop P 5 65%

3 P s 65%

i 4

P 1 100%

The maximum allowable reactor power level during startup of a circulator is 25%, regardless of the number of circulators already 0PERATING. This limitation is shown in Table 3.5.1-2.

b.

Both the steam generator reheater section and the economizer - evaporator - superheater (EES) section OPERATING (each section consisting of six modules).

)

j APPLICABILITY:

P0k'ER, LOW POWER, STARTUP ACTION:

a.

With less than two OPERABLE helium circulators in each loop, restore the inoperable helium circulator (s) in each loop to OPERABLE status within-24 hours, or be in at least SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , b.

With both circulators in one loop inoperable, and both circulators OPERATING in the other loop, one of the affected circulators must be restored to an OPERATING condition or the reactor must be SHUTDOWN with 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c.

With both circulators in one loop inoperable, and one circulator l~

OPERATING in the other loop, the reactor must be SHUTDOWN immediately.

CRefer to Table 3.5.1-1 for circulator OPERABILITY requirements.

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Amendmint No.

Page 3/4.5 -

d.

With no helium circulators OPERABLE and all forced circulation lost, be in SHUTDOWN immedistely and restore forced circulation within 90 minutes or depressurize the PCRV in accordance with the applicable requirement below:

1.

As a function of reactor themal power prior to SHUTDOWN equal to or greater than 25% as delineated in Figure 3.5.1-1.

2.

As a function of CORE AVERAGE OUTLET TEMPERATURE for reactor thermal power prior to SHUTDOWN less than 25%

as delineated in Figure 3.5.1-2.

3.

As a function of time from reactor SHUTDOWN as delineated in Figure 3.5.1-3.

e.

With less than the above required steam generator sections OPERATING, restore the required sections to OPERATING status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or:

1.

If in POWER or LOW POWER, be in at least STARTUP within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , or 2.

If in STARTUP, he in at least SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

f.

With no steam generator section OPERATING, commence an immediate SHUTDOWN and restore at least one inoperable section to OPERATING status within 90 minates' or depressurize the PCRV in accordance with the times specified in Figures 3.5.1-1, 3.5.1-2, or 3 5.1-3, as applicable.

SURVEILLANCE ~ REQUIREMENT 4.5.1.1 a.

The helium circulators shall be demonstrated OPERABLE:

1.

At least once per 31 days by testing the bearing water accumulators and verifying accumulator flow to the circulator bearing.

2.

At least once per 92 days by:

a)

Performing a turbine water removal pump (P-2103 and P-21035) start test based on a simulated drain tank level to verify alarm actuation and pump start capability. Also verify the turbine water removal tank overflow to the i

reactor building sump capability.

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Amendment No.

Page 3/4.5 -

b)

Performing a bearing water makeup pump (P-2105 and P-2108) start test based on a simulated low pressure in the backup bearing water supply line to verify automatic actuation and pump start capability.

c)

Testing the water turbine inlet and outlet valve interlocks ensuring automatic water turbine start capability by simulating a plant protective system signal resulting from one loop being tripped and the circulators' steam turbine drives in the operating loop having been tripped.

d)

Monitoring the proper closure of the circulator helium shutoff valves.

e)

Functionally testing each firewater booster pump.

3.

At least once per REFUELING CYCLE on a STAGGERED TEST BASIS whereby circulators IB and ID will be tested during even numbered cycles and circulators IA and 1C during odd numbered cycles, by demonstrating for each circulator operation on water turbine drive by:

a)

Verifying an eouivalent 8000 rpm (at atmospheric pressure) on feedwater motive power using the emergency feedwater header, and b)

Verifying an equivalent 31 rated helium flow on condensate at reduced pressure (to simulate firewater pump discharge) using each emergency water booster pump (P-2109 and P-2110), and c)

Verifying an equivalent 4.5% rated helium flow with condensate water supplied to the water - turbine drive.

4.

At least once per 10 years by verifying:

a)

A previously uninspected helium circulator compressor wheel rotor, turbine wheel, and pelton wheel is free of both surface and subsurface defects in accordance with i

the appropriate methods, procedures, and associated acceptance criteria specified for Class I components in Article NB-2500.Section III, ASME Code. Other helium circulator components, accessible without further disassembly than required to inspect these wheels, shall be visually examined, and~

Amendment No.

Page 3/4.5 -

b)

At least 10% of primary coolant pressure boundary bolting and other structural bolting which has been removed for the inspection above and which is exposed to the primary coolant shall be non-destructively tested for identification of inherent or developed defects.

c)

Reports Within 90 days of examination completion, a Special Report shall be submitted to the NRC in accordance with Specification 6.9.2.

This report shall include the results of the helium circulator examinations.

5.

The instrumentation and controls associated with 4.5.1.1.a.2 shall be functionally tested in conjunction with the specified i

testing and shall be calibrated annually.

b.

The steam generators shall-be demonstrated OPERABLE:

1.

At least once per 18 months by verifying proper flow through the emergency feedwater header and emergency condensate header to the steam generator sections.

2.

At least once per five years by:

Volumetrically examining the accessible portions of the following bimetallic welds for indications of subsurface defects:

a)

The main steam ring header collector to main steam piping weld for one steam generator module in each loop, and b)

The main steam ring header collector to collector drain piping weld for one steam generator module in each loop, and c)

The same two steam generator modules shall be re-examined at each interval.

The initial examination shall be performed during SHUTDOWN

)

or REFUELING prior to the beginning of Fuel Cycle 5.

This initial examination shall also include the bimetallic welds described above for two additional steam generator modules in each loop.

3.

Tube Leak Examination Each time a steam generator tube is plugged due to a leak, specimens from the accessible subheader tubes connected to the leaking inaccessible tube (s) shall be metallographically examined.

The results of this metallographic examination shall be compared to the results from the specimens of all previous tube leaks.

... 2..

Amendment No.

Page 3/4.5 -

A study shall be performed to evaluate the size of the tube leaks to determine if a cause of the leak or a trend in the degradation can be identified, a.

Acceptance Criteria An engineering evaluation shall be performed to determine the acceptability of:

1)

Any subsurface defects identified in Specification 4.5.1.1.b.1, 2)

Continued operation considering the condition of the steam generator materials, 3)

OPERABILITY of the steam generator sections considering the number of plugged tubes and their ability to remove decay heat.

b.

Reports Within 90 days of the return to operation following each steam generator tube leak, a Special Report shall be submitted to the NRC in accordance with Specification 6.9.2.

This report shall include the estimated size and elevation of the leak (s), and the results of the metallo-graphic and engineering analyses performed, the postulated cause of the leak if identified and corrective action to be taken.

Amendment No.

Page 3/4.5 -

TABLE 3.5.1-1 CIRCULATOR OPERABILITY A circulator is not considered OPERABLE unless the following conditions or system requirements are met for that circulator:

a.

The emergency circulator drive is capable of providing the equivalent of 8000 rpm circulator speed at atmospheric pressure; b.

The two emergency water booster pumps (P-2109 and P-2110) are OFERABLE, including two OPERABLE flow paths with the capability to drive the circulator at 3% rated helium flow with firewater supply; c.

The turbine water removal system, including two turbine water removal pumps (P-2103 and P-21035) are OPERABLE; d.

The normal bearing water system, including (P-2105 and P-2108) are OPERAB two sources of bearing water makeup and two bearing water makeup pumps e.

The associated bearing water accumulators (T-2112, T-2113 T-2114, and T-2115) art OPERABLE; and f.

The supply and discharge valve interlocks are OPERABLE on each associated circulator ensuring automatic water turbine start capability following steam turbine trip.

l

Amendment No.

Page 3/4.5 -

CIRCULATOR ARb' LIMITATIONS Initial Circulators Desired Circulators i

OPERATING OPERATING Max Power Level (Thermal)

I LOOP 1 LOOP 2 LOOP 1 LOOP 2 Initial To Start Final I

O O

1 0

0 0

33 1

0 1

1 33 25 65 l

1 1

2 1

65 25 65 2

0 2

1 50 25 65 l

2 1

2 2

65 25 100 l

The procedures for startup of a circulator are such that flow is maintained i

i cssentially in balance between the two loops to avoid exceeding the transient limits.

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.EACTOR THERMAL POWE. -16 Thee Avaanble Prior to Ishietion of PCRY Deynmuustion whos Forced i

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'F Thne Avnesbie Prior to laitiaties et PRCY Depreentharion as a Function et Assesse Core Outlet Temperature at the Onset et a LOFC Figure 3.5.1-2 l

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CIRCULATION 88 LOST FNOM A $ NUT DOWN

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Amendment No.

Page 3/4.5 -

f PRIMARY COOLANT SYSTEM 3/4.5.1 PRIMARY COOLANT LOOPS - SHUTDOWN AND REFUELING LIMITING CONDITION FOR OPERATION 3.5.1.2 At least one primary coolant loop shall be in operation with:

a.

Two helium circulators OPERABLE

and one OPERATING; b.

Either the steam generator reheater or economizer - evaporator -

superheater (EES) section OPERATING and the other section OPERABLE.

l APPLICABILITY: SHUTDOWN and REFUELING ACTION:

a.

With less than the required OPERABLE equipment identified in Specification 3.5.1.2, restore the inoperable equipment to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

b.

With no equipment OPERABLE or all forced circulation lost, suspend all operations involving CORE ALTERATIONS or positive reactivity changes and restore the required equipment to OPERATING status prior to the time calculated for the core to heatup from decay heat to a CORE AVERAGE INLET TEMPERATURE of degrees F or initiate PCRV depressurization in accordance with the time specified in Figure 3.5.1-3.

SURVEILLANCE REQUIREMENT 4.5.1.2 No additional Surveillance Requirements beyond those specified in SR 4.5.1.1.

Refer to Table 3.5.1-1 for circulator OPERABILITY requirements.

.. =.

=-

s Amendment No.

Page 3/4.5 -

. PRIMARY COOLANT SYSTEM 3/4.5.2 SAFETY VALVES LIMITING CONDIT'ON FOR OPERATION i

3.5.2.1 a.

The ste.im generator superheater (EES) and reheater safety valves (V-2214, V-2215, V-2216, V-2245 V-2246, V-2247, V-2225 and a

V-2262) shall be OPERABLE with set points in accordance with Table 4.5.2-1, and b.

The provisions of Specificetion 3.0.6 are not applicable until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after reaching 255 kATED THERMAL POWER, to allow testing of the steam generator superheater and reheater safety valves required following maintenance or per Surveillance Requirements identified in Specification 4.5.2.1.

APPLICABILITY: POWER, LOW POWER, and STARTUP ACTION:

With one of the required safety valves inoperable, restore the required valve to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or restrict plant operation as follows:

1.

With an EES safety valve inoperable, reduce THERMAL POWER to less than 50% of RATED THERMAL POWER.

2.

With an EES safety valve inoperable while in STARTUP or SHUTDOWN, restrict plant operation to a maximum i

i of two boiler feed pumps, 3.

With a reheater safety valve inoperable, be in STARTUP i

-within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

SURVEILLANCE REQUIREMENTS 4.5.2.1 The safety valves shall be demonstrated OPERABLE prior to exceeding 25% RATED THERMAL POWER unless completed in the previous five years by testing the superheater and reheater safety valves as required specified in Table 4.5 R., and by verifying the lift settings as by Specification 4.0.

I 4

s Amendment No.

Page 3/4.5 t

e TABLE 4.5.2-1 STEAM GENERATOR SAFETY VALVES i

VALVE NUMBER LIFT SETTING IDOP I V-2214 Less than or equal to 2917 psig V-2215 Less than or equal to 2846 psig i

V-2216 Less than or equal to 2774 psig V-2225 Less than or equal to 1133 peig LOOP II f-V-2245 Less than or equal to 2917 psig

(

V-2246 4

V-2247 Less than or equal to 2846 psig V-2262 Less than or equal to 2774 psig Less than or equal to 1133 psig I

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Amendment No.

Page 3/4.5 -

~

PRIMARY COOLANT SYSTEH 3/4.5.2 SAFET7 VALVE - SHUTDOWN AND REFUELING LIMITING CONDITION FOR OPERATION 3.5.2.2 The steam generator superheater or reheater safety valve (s) which protect the operating section of the steam generator shall be OPERABLE with setpoints in accordance with Table 4.5.2-1.

APPLICABILITY: SHUTDOWN and REFUELING ACTION:

With no associated safety valve (s) OPERABLE. restore *he required safety valve to OPERABLE status prior to the tt:ee calculated for the core to heatup from decay heat to a CORE AVERAGE INLET TEMPERATURE of degrees F. or:

1.

Suspend all operations involving CORE ALTERATIONS or positive reactivity changes, and 2.

Initiate PCRV depressurization in accordance with the time specified in Figure 3.5.1-3.

SURVEILLANCE REOUIREMENTS 4.5.2.2 No additional surveillances required beyond those identified per Specification 4.5.2.1.

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i Amendment No.

Page 3/4.5 -

PCRV AND CONFINEMENT SYSTEMS 3/4.6.2 PCRV LINER COOLING SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.1 The Reactor Plant Cooling Water (RPCW)/PCRV Liner Cooling System (LCS) shall be OPERABLE with:

i a.

Two (2) loops 0PERATING, each with at least one heat exchanger and one pump OPERATING; b.

At least three (3) out of any four (4) adjacent tubes on the core support floor side wall, core support floor i

bottom casing, PCRV cavity liner sidewalls, and PCRV cavity liner bottom head shall be OPERATING; c.

At least five (5) out of any six (6) adjacent tubes on the PCRV cavity liner top head and core support floor top casing shall be OPERATING.

d.

Tubes adjacent to a non-operating tube shall be OPERATING.

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e.

An DPERABLE flow path to provide firewater to the LCS.

APPLICABILITY: POWER, LOW POWER, and STARTUP ACTION a.

Withonlyone(1)RPCW/PCRVLinerCoolingSystemloop OPERATING, ensure both heat exchangers are OPERATING in the OPERATING loop, restore the second loop to OPERATING within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and suspend all operations involving positive reactivity changes. Without both heat exchangers in the OPERATING loop OPERATING or without any liner cooling system loop flow, be in SHUTDOWN within 15 minutes and suspend all operations involvino positive reactivity changes.

l b.

With less than the above requir.1 number of PCRV Liner Cooling System tubes OPERATING, i store the required I

tubes to OPERATING status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and suspend all operations involving positive reactivity changes.

Amendmant No.

Page 3/4.5 -

SURVEILLANCE REQUIREMENTS 4.6.2.1 The RPCW/PCRV Liner Cooling System shall be demonstrated OPERABLE:

a.

At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , by verifying that each PCRV Liner Cooling System loop is circulating cooling water at a flow rate greater than 1100 gpm.

b.

At least once each 31 days by:

1.

Verifying that each valve (manual, power operated, or automatic) in the firewater flow path to the LCS that is not locked, sealed, or otherwise secured in position, is in its correct position.

2.

Functional testing the PCRV Cooling System flow scanner alarms.

c.

At least once per 366 days by:

1.

Performing a CHANNEL CALIBRATION of the PCRV cooling

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system flow scanner, associated alarms, and six (6) subheader flow meters.

2.

Performing a LCS redistribute mode functional test to verify the capability of rerouting most of the cooling

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water to the upper side walls and the top head.

3.

Performing a fuhetional test to verify the capability to

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remotely increase the PCRV surge tank pressure to 30 psig by adding helium from a helium bottle to the tank.

ee.

Amendment No.

Page 3/4.5 -

PCRV and' CONFINEMENT SYSTEMS 3/4.6.2 PCRV LINER COOLING SYSTEM - SHUTDOWN AND REFUELING LIMITING CONDITIONS FOR OPERATIONS l

3.6.2.2 The Reactor Plant Cooling Water (RPCW)/PCRV Liner Cooling System (LCS) shall be OPERABLE with:

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a.

Two (2) RPCW/PCRV LCS loops OPERABLE with at least one pump and one heat exchanger in each loop.

l b.

One (1) RPCW/PCRV Liner Cooling System loop with at least one heat exchanger and one pump OPERATING.

APPLICABILITY: SHUTDOWN # and REFUELING #

ACTION:

a.

With less than the required OPERABLE RPCW/PCRV LCS loops, restore the inoperable loop to OPERABLE status within 7 days or suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

b.

With no RPCW/PCRV Liner Cooling System loop OPERATING, I

restore at least one loop to OPERATING status prior to l

the time calculated for the core to heatup from decay 1

heat to a CORE AVERAGE INLET TEMPERATURE of degrees F j

and suspend all operations involving CORE ALT HXTIONS or

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positive reactivity changes.

SURVEILLANCE REQUIREMENTS 1

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4.6.2.'2 No additional surveillance requirements other than those identified j

per Specification 4.6.2.1.

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The core support floor zone of the PCRV Liner Cooling System may be valved out when PCRV pressure'is less than or equal to 150 psia and calculated CORE AVERAGE INLET TEMPERATURE is less than 200 degrees F.

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Amendment No.

i Page 3/4.5 -

PCRV AND CONFINEMENT SYSTEMS 3/4.6.3 PCRV LINER COOLING SYSTEM TEMPERATURES LIMITING CONDITIONS FOR OPERATION i

3.6.3 The RPCW/PCRV Liner Cooling System (LCS) temperatures shall be maintained within the following limits:

a.

The maximum average temperature difference between the common PCRV cooling water discharge temperatures and the PCRV external concrete surface temperature shall not exceed 50 degrees F.

b.

The maximum RPCW Heat Exchanger outlet temperature shall not exceed 120 degrees F.

c.

The maximum change of the weekly average PCRV concrete temperature shall not exceed 14 degrees F per week.

d.

The maximum allowable cooling water temperature rise for OPERATING PCRV liner cooling tubes shall not exceed the following limits:

1.

30 degrees F temperature rise for tubes cooling top head penetrations; 2.

20 degrees F temperature rise for all other zones except tubes specified below; 3.

Exceptions:

a)

Core Outlet Thermometer Penetrations Tube Delta T 7593 23 degrees F b)

Core Barrel Seal / Core Support Floor Area Tube Delta T F12T46 47 degrees F F7T43 39 degrees F F6T44 43 degrees F F11T45 38 degrees F F5T47 46 degrees F c)

Peripheral Seal Tube Delta T 359 23 degrees F 4S188 23 degrees F 4510 23 degrees F 35187 23 degrees F

Amendment No.

Page 3/4.5 -

(3.6.3.dcont.)

If the tube outlet temperature reading for any liner cooling tube is not available due to an instrument failure, the tube may be considered OPERABLE if two tubes on both sides of the tube with an instrument failure (4 tubes total) are within their respective temperature limits as specified above.

1 e.

The minimum everage of the inlet and outlet LCS water temperatures shall be greater than or equal to 100 degrees F.

APPLICABILITY: At all Times I

ACTION:

With any of the above conditions not met, restore these conditions within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or be in SHUTDOWN or REFUELING within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

SURVEILLANCE REOUIREMENTS 4.6.3 The RPCW/PCRV Liner Cooling System temperatures shall be demonstrated to be within their respective limits:

a.

At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by:

1.

Verifying that the maximum temperature difference averaged i

over a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period between the PCRV external concrete surface temperature and the comon PCRV cooling water discharge temperature in each loop does not exceed 50 degrees F.

2.

Verifying that the maximum PCRV liner cooling water outlet i

temperature does not exceed 120 degrees F as measured by PCRV liner cooling water outlet temperature in each loop.

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3.

Verifying that the change in PCRV concrete temperature does

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1 not exceed 14 degrees F per week as indicated by the weekly average water temperature. The weekly average water temper-ature is determined by computing the arithmetical mean of 7 temperatures, representing each of the last 7 days of comon PCRV cooling water outlet temperatures in each loop. Each day results in a new computation of a weekly average water temperature. The new weekly average is than compared to the weekly average water temperature computed 7 days earlier to verify Specification 3.6.3.c.

4.

Verifying that the minimum everage water temperature of the PCRV Liner Cooling System is greater than or equal to 100 degrees F as measured by the average of the PCRV Liner Cooling System heat exchanger (LCS side) inlet and catlet temperatures.

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Amendment No.

Page 3/4.5 -

.b.

At least once per 31 days by:

1.

Verifying that liner cooling tube outlet temperature readings and their respective inlet header temperatures (for an operating loop) are within the specified limits of Specification 3.6.3.d.

2.

Functional testing the associated RPCW temperature scanner alarms, c.

At least once per 366 days by perfoming a CHANNEL CALIBRATION of the PCRV cooling system temperature scanner, associated alarms, thirty-six (36) subheader outlet temperature indicators, ninety-seven (97) liner cooling tube outlet thermocouples, and PCRV surface temperature indicators.

ENCLOSURE 3 STAFF COP 9 TENTS ON PSCs RESPONSE TO APPLICABLE ACTION ITEMS

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Coments on PSCs Response to Action Items Attachment 2 to P-85363 1.

Introduction - NRC Staff Coment:

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Without an NRC Policy Statement, the staff is unable to accept PSC's adoption of the subjective criterion used by the Atomic Safety and Licensing Appeal Board in ALAB-531, "that Technical Specifications are to be reserved for those matters as to xhich imposition of rigid conditions or limitations upon reactor operation is deemed necessary

[

to obviate the possibility of an abnormal situation or event giving rise to an imediate threat to the public health and safety." (9 M C 263, 1979)

The NRC is currently in the process of attempting to remove the j

subjective-judgement term "immediate threat" from the above criterion by identifying objective criteria that would capture this subjective concept.

I 2.

Action 27a Response - NRC Staff Coment:

Based on the above position, the statement,'"The loss of buffer helium l

does not pose an 'imediate threat' to the public health and safety."

is an unacceptable basis. Buffer helium could be considered as analogus j

to the reactor coolant pump shaft seal system, which is not a W-STS requirement. However, the W-STS does require leakage detection systems which are analogous to monitoring for helium leakage in the reactor building at Fort St. Vrain.

FSAR, Section 4.2.2.3.7, Page 4.2-23 does imply that buffer helium is not vital, but also states that the pressure boundary integrity of the buffer helium system is required to maintain primary coolant pressure in the bearing water surge tank, ensuring proper operation of the bearing water system which is vital for continued helium circulator operation.

l Proposed Resolution r-PSC should resubmit their response to Action Item 27a based on the above l

coments.

3.

Action 27b Response - NRC Staff Coment:

The statement, "...a high bearing water temperature does not pose an l

imediate threat...." is an unacceptable basis. The staff also considers j

specifying maximum circulator bearing water temperature in the Tech Specs as analogous to the W-STS LC0 3/4.7.5 for the ultimate heat sink (UHS). The UHS LC0 ensures that cooling water is provided to safety-related equipment without exceeding equipment design temperatures.

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a Proposed Resolution i

PSC should resubmit their response to Action Item 27b and address the above connents.

4.

Action 27c Response - NRC Staff Conment:

The statement. "Since an immediate threat to the public health and safety is not identified...." is an unacceptable basis.

Proposed Resolution PSC should resubmit their response to Action Item 27c.

5.

Action 27d Response - NRC Staff Comment:

The FSAR should be updated to clarify the licensee's position on circulator interlocks whose failure could prevent any source of motive power from being supplied to circulator drives.

Proposed Resolution PSC should submit this clarification in their next annual FSAR revision.

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ML20141E512

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ML20141E512

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Dear Mr. Walker:

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