ML20198N597

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Amend 161 to License DPR-72,establishing New Low Temperature Overpressure TS
ML20198N597
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 12/22/1997
From: Hebdon F
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20198N601 List:
References
NUDOCS 9801210135
Download: ML20198N597 (32)


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'e NUCLEAR REGULATORY COMMISSION WASHINGTON, o.C. 20555-0001 o

FLORIDA POWER CORPORATION CITY OF ALACHUA CITY OF BUSHNELL CITY OF GAINESVILLE CITY OF KISSIMMEE CITY OF LEESBURG CITY OF NEW SMYRNA BEACH AND UTILITIES COMMISSION.

fdU OF NEW SMYRNA BEACH CITY OF OCALA ORLANDO UTILITIES COMMISSION AND CITY OF ORLANDO SEMINOld ELECTRIC COOPERATIVE. INC.

CITY OF TALLAHASSEE DOCKET NO. 50-302 CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.161 License No. DPR-72 1.

The Nuchar Regulatory Commission (the Commission) has four'd that:

A.

The application for amendment by Florida Power Corporation, et al.

(the licensees) dated July 18,1997, as supplemented September 12, and October 25,1997, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such imetivities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

9001210135 971222 PDR ADOCK 05000302 P

PDR

7 2-2.

Accordingly, the license is emended by changes to the Techn' mal Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR 72 is hereby amended to read as follows:

Technical Soecifications The Technical Specifications contained in Appendices A and B, as revised through Arrsndment No.161, are hereby incorporated in the license. Florida Power Corporation shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGUL/P.Y COMMISSION

%LA I,Lu-Frederick J. Hebdon, Director Project Directorate 11-3 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Ae of issuance: Decenber 22, 1997 1

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ATTACHMENT TO LICENSE AMENDMENT NOl61 FACILITY OPERATING LICENSE NO. DPR-72 DOCKET NO. 50-302 Replice the following pages of the Appendix "A" Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain verticallines indicating the area of change.

Remove Replace ll il vi vi 3.4-21 3.4-21 3.4-21A 3.4-21 B 3.4-210 3.4-21 D

- 3.4-21 E 3.5-7 3.5-7 B 3.4-43 B 3.4-43 8 3.4-45 B 3.4-45 8 3.4-52 B 3.4 52 B 3.4-52A B 3.4-52B B 3.4 52C B 3.4-52D B 3.4-52E B 3.4-52F B 3.4-52G B 3.4-52H B 3.4-521 B 3.4 52J B 3.4-52K B 3.4-52L B 3.5-10 B 3.5-10 ^

B 3.5-15' B 3.5-15 B 3.5-16 B 3.5-16 B 3.5-21 B 3.5-21 B 3.5-22 8 3.5-22

i - t l-TABLE OF CONTENTS 3.3 INSTRUMENTATION (continued) 3.3.11 Emergency Feedwater Initiation and Control (EFIC) System Instrumentation.......... 3.3-26 3.3.12 Emergency Feedwater Initiation and Control (EFIC) Manual Initiation 3.3-30 3.3.13 Emergency Feedwater Initiation and Control (EFIC) Automatic Actuation Logic 3.3-32 3.3.14 Emergency Feedwater Initiation and Control (EFIC)-Emergency Feedwater (EFW)--Vector Val ve Log i c................... 3.3-34 3.3.15 Reactor Building (RB) Purge Isolation--High Radiation.................... 3.3-35 3.3.16 Control Room Isolation--High Radiation....... 3.3-36 3.3.17 Post Accident-Monitoring (PAM) Instrumentation...

3.3-38 3.3.18 Remote Shutdown System...............

3.3-42 3.4 REACTOR COOLANT SYSTEM (RCS)..............

3.4-1 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits 3.4-1 3.4.2 RCS Minimum Temperature for Criticality 3.4-3 3.4.3 RCS Pressure and Temperature (P/T) Limits 3.4-4 3.4.4 RCS Loops--MODE 3 3.4-6 3.4.5 RCS Loops--MODE 4 3.4-8 3.4.6 RCS Loops--MODE 5, Loops Filled 3.4-10 3.4.7 RCS Loops--MODE 5, Loops Not Filled 3.4-13 3.4.8 Pressurizer 3.4-15 3.4.9 Pressurizer Safety Valves 3.4-17 3.4.10 Pressurizer Power Operated Relief Valve (PORV)... 3.4-19 3.4.11 Low Temperature Overpressure Protection 3,4-21 (LTOP) System 3.4.12 RCS Ope, ational LEAKAGE 3.4-22 3.4.13 RCS Pressure Isolation Valve (PIV) Leakage.....

3.4-24 3.4.14 RCS Leakage Detection Instrumentation 3.4-27 3.4.15 RCS Specific Activity 3.4-30 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

. 5-1 3.5.1 Core Flood Tanks (CFTs) 3.5-1 3.5.2 ECCS--Operating 3.5-4 3.5.3 ECC S -- S h utdown...................

3.5-7 3.5.4 Borated Water Storage Tank (BWST) 3.5-9 3.6 CONTAINMENT SYSTEMS 3.6-1 3.6.1 Containment 3.6-1 3.6.2 Containment Air Locks 3.6-3 3.6.3 Containment Isolation Valves............

3.6-8 3.6.4 Containment Pressure................

3.6-15 3.6.5 Containment Air Temperature J.6-16 (continued)

Crystal River Unit 3 11 Amendment No.161

)

t TABLE OF CONTENTS 3.3 INSTRUMENTATION (continued)

B 3.3.12 Emergency Feedwater Initiation and Control (EFIC) Manual Initiation B 3.3-100 B 3.3.13 Emergency Feedwater Initiation and Control (EFIC) Logic B 3.3-105 B 3.3.14 Emergency Feedwater Initiation and Control (EFIC) Emergency Feedwater (EFW)-Vector Valve Lonic..................

B 3.3-110 B 3.3.15 Reactor Building (RB) Purge Isolation-High Radiation...................

B 3.3-114 B 3.3.16 Control Room Isolation-High Radiation......

B 3.3-119 B 3.3.17 Post Accident Monitoring (PAM) Instrumentation..

B 3.3-124 B 3.3.1B Remote 3hutdown System..............

B 3.3-145 B 3.4 REACTOR COOLANT SYSTEM (RCS).............. B 3.4-1 B 3.4.1 RCS Pressure, Temperatute, and Flow Departure from Nucleate Boiling (DNB) Limits

....... B 3.4-1 B 3.4.2 RCS Minimum Temperature for Criticality...... B 3.4-6 B 3.4.3 RCS Pressure and Temperature (P/T) Limits

..... B 3.4-9 B 3.4.4 RCS Loops-MODE 3

................. B 3.4-17 8 3.4.5 RCS Loops-MODE 4

................. B 3.4-22 B 3.4.6 RCS Loops-MODE 5, Loops Filled

.......... B 3.4-27 B 3.4.7 RCS Loops-MODE 5, Loops Not Filled

........ B 3.4-33 B 3.4.B Pressurizer.................... B 3.4-37 B 3.4.9 Pressurizer Safety Valves............. B 3.4-43 B 3.4.10 Pressurizer Power Operated Relief Valve (PORV)... B 3.4-47 B 3.4.11 Low Temperature Overpressure Protection (LTOP) System................... B 3.4-52 B 3.4.12 RCS Operational LEAKAGE.............. B 3.4-53 B 3.4.13 RCS Pressure Isolation Valve (PIV) Leakage..... B 3.4-5B B 3.4.14 RCS Leakage Detection Instrumentation....... B 3.4-65 B 3.4.15 RCS Specific Activity............... B 3.4-71 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

......... B 3.5-1 B 3.5.1 Core Flood Tanks (CFTs)

.............. B 3.5-1 B 3.5.2 ECCS-Operating

.................. B 3.5-9 B 3.5.3 ECCS-Shutdown................... B 3. 5-19 B 3.5.4 Borated Water Storage Tank (BWST)

......... B 3.5-23 8 3.6 CONTAINMENT SYSTEMS.................. B 3.6-1 B 3.6.1 Containment.................... B 3.6-1 B 3.6.2 Containment Air Locks

............... B 3.6-7 B 3.6.3 Containment Isolation Valves............ B 3.6-16 B 3.6.4 Containment Pressure................ B 3.6-30 B 3.6.5 Containment Air Temperature............ B 3.6-33 B 3.6.6-Reactor Building Spray and Containment Cooling Systems................. B 3.6-36 (continued)

Crystal River Unit 3 vi Amendment No.161

d LTOP System 3.4.11 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Low Temperature Overpressure Protection (LTOP) System LCO 3.4.11 An LTOP Syttam shall be OPERABLE with a maximum of one makeup pump capable of injecting into the RCS, high pressure injection (HPI) deactivated, the core flood tanks (CFTs) isolated and:

a.

Pressurizer level s 135 inches and an OPERABLE power operated relief valve (PORV) with a lift setpoint of s 457 psig; or b.

The RCS.depressurized and an RCS vent of 2 0.75 square inch.

APPLICABILITY:

MODE 4 when RCS temperature is s 25?'F, MODE 5, MODE 6 when the reactor vessel head is not completely detensioned.

............................N0TE----------------------------

CFT isolation is only required when CFT pressure is greater than or equal to the maximum RCS pressure for the existing RCS temperature allowed by the pressure and temperature limit curves provided in the PTLR.

Crystal River Unit 3 3.4-21 Amendment No. 161

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i LTOP System 3.4.11 ACTIONS CONDITION REQUIRED ACTION-COMPLETION TIME A. More than one makeup A.1


NOTE---------

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pump capable of Two makeup pumps may be-injecting into the capable of injecting

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RCS.

into the RCS during pump swap operation for s 15 minutes.

4 Initiate action to Immediately verify only one makeup pump is capable of injecting into the RCS.

B. HPI capable of B.1 Initiate-action to Immediately actuation.

verify HPI deactivated.

C. A CFT not isolated C.1 Isolate affected CFT.

I hour when CFT pressure is greater than or equal to the maximum RCS pressure for existing tenperature allowed in the PTLR.

D. Required Action C.1 0.1 Increase RCS 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> not met within the temperature to > 197'F.

required Completion Time.-

QB-D.2 Depressurize affected 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> CFT to < 457 psig.

E. Pressurizar level E.1 Restore pressurizer I hour

> 135 inches.

level to s 135 inches.

(continued)

Crystal River Unit 3 3.4-21A.

Amendment No.161

LTOP System 3.4.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action E.1 F.1 Close and maintain 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> not met within the closed the makeup required Completion control valve and its Time.

associated isolation valve.

AND F.2 Stop RCS heatup.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> G.

PORY inoperable.

G1 Restore PORV to I hour OPERABLE sts?.us.

H. Required Action G.1 H.1 Reduce makeup tank 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> not met within the level to s 811 inches.

required Completion Time.

8HQ H.2 Deactivate low low 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> makeup tank level interlock to the borated water storage tank suction valves.

(continued)'

Crystal River Unit 3 3.4-21B Amendment No. 161

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LTOP System 3.4.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME-I. Prnssurizer level I.1 Restore LTOP System to I hour

> 135 inches.

OPERABLE status.

i AND QB PORV inoperable.

I.2 Depressurize RCS and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> establish RCS vent of QB' 2 0.75 square inch.

4 LTOP System inoperable

-for any reason other than Condition A through Condition H.

f 4

Crystal River Unit 3 3.4-21C Amendment No.161

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LTOP System 3.4.11 SURVEILLANCE REQUIRENENTS SURVEILLANCE FREQUENCY SR 3.4.11.1 Verifv a maximum of one makeup pump is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> capable of injecting into the RCS.

1 SR 3.4.11.2 Verify HPI is deactivated.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.4.11.3


NOTE---------------

Only required to be performed when CFT isolation is required

...........s..................

Verify each CFT isolation 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> valve is closed and deactivated.

SR 3.4.11.4


NOTE--------------

30 minutes Not required to be performed during RCS when complying with LCO 3.4.ll.b heatup and cooldown Verify pressurizer level is AND s 135 inches.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.4.11.5


NOTE---------------

Not required to be performed then complying with LCO 3.4.11.b Verify PORV block valve is open.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.4.11.6


NOTE----------------

Only required when complying with LCO 3.4.ll.b.

Verify RCS vent 2 0.75 square inch 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for is open.

unlocked vent opening (s)

&HD 31 days for locked vent opening (s)

(continued)

Crystal River Unit 3 3.4-210 Amendment No.161

s i

e LTOP System 3.4.11-SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.11.7 Perform CHANNEL FUNCTIONAL TEST for Within 12 PORV.

hours before or after decreasing RCS temperature to s 259'F AE 31 days thereafter SR 3.4.11.8 Perform CHANNEL CAllBRATION for PORV.

24 months SR 3.4.11.9


NOTE----------------

Not required to be performed wher, complying with LCO 3.4.ll.b Verify PORV is selectrd to the low range 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> setpoint.

Crystal River Un't 3 3.4-21E Amendment No.161

ECCS--Shutdown

3. 5.3 -

3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

3.5.3 ECCS--Shutdown LCO 3.5.3 One ECCS train shall be OPERABLE.

~

............................N0TE-----------------------

High pressure injection (HPI) may be deactivated in accordance with LCO 3.4.11, " Low Temperature Overpressure Protection (LTOP) System."

APPLICABILITY:

HODE 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Required low pressure A.1 Initiate action to Immediately injection (LPI) restore required LPI subsystem inoperable.

subsystem to OPERABLE status.

B.

Required HPI subsystem B.1 Restore required HPI 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable.

Subsystem to OPERABLE status.

C.

Required Action and C.)

Be in F10DE 5.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> associated Completion Time not met.

. Crystal. River Unit 3 3.5-7 Amendme

  • No.161.

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Pressurizer Safety. Valves

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B 3.4.9-l B 3.4-REACTOR _ COOLANT SYSTEM (RCS) l B:3.4.9 Pressurizer Safety.Vaiv6s BASES e

BACKGROUND The purpose.of the two spring loaded pressurizer l safety.

valves is to provide RCS overpressure protection. - operating-in conjunction with the Reactt,r Protection System (RPS),.two 1

valves are used to ensure that the Safety Limit (SL) of 2750 psig is not exceeded for analyzed transients during.

operation in MODES 1, 2, and 3.

For MODE 4,. MODE 5, and=

MODE 6 with the reactor vessel head not completely J

detensioned, overpressure protection.is provided by LCO 3.4.11,'LowTemperatureOverpressureProtection-(LTOP)

System."

L The self actuated pressurizer safety valves are designed in accordance with the requirements set forth in the ASME Boiler and Pressure Vessel Code,Section III (Ref. 1). The required lift pressure is 2500 psig i 2%.. The safety valves discharge stean) from the pressurizer to the reactor oolant drain tank (RCDT) located N the containment. The discharge flow is indicated by acoustic mor,itors downstream of the.

safety valves and by an increase in RCDT pressure and level.

4 The upper and'1ower pressure. limits were originally based on the 1L1% tolerance requirement for lifting pressures above 1000 psig. However, later-versions of the ASME Code allow for tolerances of up to 13%, and the use of 2% was jue.tified in Reference 2.

The lift setting is for the ambient conditions associated with MODES 1, 2, and 3.

This requires either that-the valves be set. hot or that a-correlation between hot and cold settings be established.

4 The-pressurizer safety valves are part of. the primary success path and mitigate the effects of postulated accidents. OPERABILITY of the safety valves ensures that the RCS pressure will-be limited to less than -110% of design

. pressure.

4 e

L (continued)

Crystal River Unit '3 8 3.4-43

- Amendment No.161 C.

Pressurizer Safety Valves B 3.4.9 BASES APPLICABILITY reactor coolant pressure less than 110% of its design value (continued) during certain accidents.

The LCO is not applicable in MODES 4 and 5 because LCO 3.4.11. " Low Temperature Overpressure Protection (LTOP)

System" provides overpressure protection.

Overpressure

)rotection is not required in MODE 6 with the reactor vessel lead completely dctensioned.

I ACTIONS ful With one pressurizer safety valve inoperable, restoration must take place within 15 minutes.

The Completion Time of 15 minutes reflects the importance of maintaining the RCS overpressure protection system. An inoperable safety valve coincident with a design basis overpressure event could challenge the integrity of the RCS, B.1 and B.2 If the Required Action cannot be met within the associated Completion Time or if both pressurizer safety valves are inoperable, the plant must be placed in a MODE in which the requirement does not apply. To achieve this status, the plant must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The specified Completion Times are reasonable, based on operating experience, to reach the required MODES from full power conditions in an orderly manner and without challenging plant systems.

In MODE 4 and below, overpressure protection is provided by LTOP.

Placing the plant in a lower MODE (3 and 4) reduces the RCS energy (thermal and pressure), lowers the potential for large pressurizer insurges, and thereby removes the need for overpressure protection by two pressurizer safety valves.

SURVEILLANCE SR 3.4.9.1 REQUIREMENTS The requirement to verify lift setpoint 2 2450 psig and 52550 psig is implemented in the Inservice Testing Program.

(continued)

Crystal River Unit 3 B 3.4-45 Amendment No.161

e' LTOPSystem[

B 3.4.11 8 3.4 REACTOR 0008. ANT SYSTEM (RCS)

B 3.4.11 Low Temperature Overpressure Protection (LTOP) System BASES BACKGROUND The LTOP System controls RCS pressure at low temperatures so the integrity of the reactor coolant pressure-boundary (ROPB) is not compromised by violating the pressure and temperature (P/T) limits of ASME Code Section XI, Division 1, Code Case N-514 (Ref. 1). The reactor vessel is the limiting RCPB component for providing such protection.

The reactor vessel material is less tough at reduced temneratures than at normal operating temperature. Also, as vassel neutron irradiation accumulates, the material becomes less resistant to pressure stress at low temperatures (Ref. 2).

RCS pressure must be maintained 1cw when temperature is low and must be increased only_ as temperature is increased.

The RCS temperatures referenced throughout this LCO nd Bases are based on the same criteria as is used for beatup and cooldown monitoring (Refer to LCO 3.4.3).

Specifically, the cold leg temperature should be used with RCPs operating and the decay heat outlet temperature should be used with no RCPs operating.

Operational :naneuvering during cooldown, heatup, or any anticipated operational occurrence must be controlled to not violate LCO 3.4.3, "RCS Pressure and Temperature (P/T)

Limits." Exceeding these limits coul, lead to brittle fracturo of the reactor vessel.

LCO 3.4.3 presents requirements for administrative control of RCS pressure and temperature to prevent exceeding the P/T limits.

This LCO provides RCS overpre:sure protection in the applicable MODES by ensuring an adequate pressure relief capacity and a limited coolant addition capability.

The pressure relief capacity requires either the power operated relief valve (PORV) lift setpoint to be reduced and pressurizer coolant level at or below a maximum limit or the RCS depressurized with an RCS vent of sufficient size to

- h;ndle-the limiting transient during LTOP.

(continued) r ystal River Unit 3 B 3.4-52 Amendment No.161

l I

l LTOP System B 3.4.11 i

a r

EASES 7

-BACKGROUND The LTOP approach to protecting the vessel by limiting (continued) coolant addition capability allows a maximum of one makeup pump, and requires deactivating HPI, and isolating the core flood tanks (CFTs) when CFT pressures exceed the maximum dCS pressure for the existing RCS temperature allowed by PTLR.

Should more than one HPI pump inject on an HPI actuation, the pressurizer level and PORV or another RCS vent cannot prevent overpressurizing the RCS.

The pressurizer level limit provides a compressible vapor space or cusblon that can accommodate a coolant insurge and prevent a rapid pressure increase, allowing the operator time to stop the increase. The PORV, with reduced lift setting, or the RCS vent, is the overpressure protection device that acts as backup to the operator in terminating an increasing pressure event.

With HPI deactivated, the ability to provide RCS coolant addition is restricted. To balance the possible need for coolant addition, the LCO does not require the Makeup System to be deactivated. Due to the lower pressures asscciated with the LTOP MODES and the expected decay heat levels, the Makeup System can provide flow with the OPERABLE makeup pump through the makeup control valve. HPI can be restored by operator action.

EQRy Reauirements As designed for the LTOP System, the PORV is signaled to open if the RCS pressure approaches a limit set in the LTOP actuation circuit. The LTOP actuation circuit is the circuit which opens the PORV at the low pressure setpoint.

The LTOP actuation circuit monitors RCS pressure and.

determines when an overpressure condition is approached.

When the monitored pressure meets or exceeds the setting, the PORV is signaled to open. Maintaining the setpoint-within the limits of the LCO ensures the Reference 1 limits will be met in any event analyzed for LTOP.

-When a PORV is opened in an increasing pressure transient, the release of coolant causes the pressure increase to slow and reverse.- As tise PORV releases coolant, the RCS pressure decreases until a reset pressure is reached and the valve is signaled to close. The pressure continues to decrease below the reset pressure as the valve closes.

(continued)

Crystal River Unit 3 B 3.4-52A

- Amendment No.161

LTOP System B 3.4.11

- BASES BACKGROUND RCS Vent Reauirements (continued)

Once the RCS is desressurized, a vent exposed to the containment atmospiere will maintain the RCS at ambient containment pressure in an RCS overpressure transient, if the relieving requirements of the maximum credible LTOP transient do not exceed the capabilities of the vent. Thus, the vent path must be capable of relieving the flow of the limiting LTOP transient and maintaining pressure below LTOP limits. The required vent capacity may be provided by one or more vent paths.

For an RCS vhnt to meet the flow capacity, it requires removing a pressurizer safety valve, or similarly establishing a vent by removing an OTSG primary side manway cover or primary side handhole cover, or other vents as determined to be sufficient. The vent path (s) must be above the level of reactor coolant, so as not to drain the RCS when open.

4 APPLICABLE Analyses (Ref. 3) demonstrate that the reactor vessel SAFETY ANALYSES can be adequately protected against overpressurization transients during shutdown.

At 259'F and below, overpressure prevention is provided by an OPERABLE PORV and a restricted coolant level in the pressurizer or by a depressurized RCS and a sufficient size RCS vent.

The actual temperature at which the pressure in the P/T limit curve can fall below the PORV setpoint increases as vessel material toughness decreases due to neutron embrittle'.ient. Each time the P/T limit curves are revised, the LTOP System will be re-evaluated to ensure that its functional requirements can still be met with the PORV and pressurizer level me'thod or the depressurized and vented RCS i

condition.

Transients that are capable of overpressurizing the RCS have b en identified and evaluated (Ref 4). These transients relate to either mass input or heat input:

actuating the HPI System, dischaiging the CFTs, energizing the pressurizer heaters, failing the makeup control valve open, losing decay heat removal, starting a reactor coolant pump (RCP) with a (continued)

Crystal River Unit 3 B 3.4-52B Amendment No. 161

C-l LTOP System B 3.4.11

~ BASES APPLICABLE large-temperature mismatch between the primary and secondary SAFETY ANALYSES coolant systw s, and adding nitrogen to the pressarizer.-

(continued)

HPI actuation and CFT discharge-are the transients that result in exceeding P/T limits within < 10 minutes, in which time no operator. action is assumed to take place.

In.the-rest, operator action after that time precludes overpressurization. The analyses demonstrate that the time allowed for operator action is adequate, or the events are l

self limiting and do not exceed LTOP limits.

The following are required during the LTOP MODES to ensure that transients do not occur, which either of the LTOP overpressure protection means cannot handle:

a.

Deactivating all-but one makeup pump; b.

Deactivating HPI; and c.

Immobilizing CFT discharge isolation valves in their 4

closed positions, when C T pressure is greater than the PTLR limit.

The Reference 3 analyses demonstrate the PORV can maintain RCS pressure below limits when only one makeup pump is actuated. Consequently, the LCO allows only one makeup pump to be OPERABLE in the LTOP MODES.

Inadvertent actuation of HPI can cause the RCS pressure to exceed the LTOP limits determined by Reference 3 sooner than the 10 minutes allowed.

Consequently, HPI must be deactivated by assuring that an inadvertent HPI actuation can not inject water into the RCS through the HPI valves.

- The isolated CFTs must have their discharge valves closed and the valve power breakers in their open posit'lons. The analyses show the effect of CFT discharge is over a narrower RCS temperature range (197'F and below) than that of the LCO (259'F and below).

- Analyses performed per Reference 1 established the temperature of LTOP A>plicability at 253*F at the vessel quarter-t' location. Tie LTOP enable' temperature of 5 259'F includes correction for instrument uncertainity. The vessel materials were assumed to have a neutron irradiation 4

accumulation equal to 15 effective full power years-(EFPYs) of operation and >lant operation is assumed to be in compliance with tie RCS heatup and cooldown limitations of.

(continued)

Crystal River Unit 3 B 3.4-52C.

Amendment No.161 u

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LTOP System B 3.4.11 BASES APPLICABLE LCO 3.4.3.

In addition, Reactor Coolant Pump (RCP)

SAFETY ANALYSES operation is assumed to be restricted to greater than 85'F (continued) for the first two pumps, and greater than 225'F for pump three.

Pump four operation is not considered for LTOP.

During plant heatup, the vessel metal temperature lags the reactor coolant temperature.

Stopping the Reactor Coolant System heatup and holding for a period of 90 minutes allows the vessel metal temperature at the quarter-t location to stabilize to the reactor coolant temperature.

This LCO will deactivate the HPI actuation when the RCS temperature is s 259'F. The consequences of a small break LOCA in LTOP MODE 4 are consistent with those discussed in the bases for LCO 3.5.3, "ECCS-Shutdown," by having a maximum of one makeup pump OPERABLE for the required one OPERABLE ECCS train.

Reference 3 contains the acceptance limits that satisfy the LTOP requirements. These limits, in combination with the limitations of LCO 3.4.3, and administrrt;ve restrictions on RCP operation, provide the assurance that the reactor vessel is protected from exceeding the requirements of ASME Code Case N-514. Any change to the RCS operation or design must be evaluated against these analyses to determine the impact of the change on the LTOP acceptance limits.

PORY Perfortrance Analyses (Ref. 3) show that the vessel is protected when the PORV is set to open at s 464 psig. The PORV setpoint at or below the derived limit ensures the requirements of ASME Code Case N-514 (Reference 1) will be met.

The PORV lift setpoint limit of s 457 psig includes correction for instrument uncertainty.

The PORV set)oint will be re-evaluated for compliance when the revised )/T limits conflict with the LTOP analysis limits. The P/T limits are >eriodically modified as the reactor vessel material touginess decreases due to embrittlement induced by neutron irradiation.

Revised P/T limits are determined using neutron fluence projections and the results of examinations of the reactor vessel material irradiation surveillance specimens.

The Bases for LCO 3.4.3 discuss these examinations.

The PORV is considered an active compone t.

-Therefore, its failure represents the worst case LTOP single active failure.

(continued)

Crystal River Unit 3 B 3.4-52D Amendment No. 161

i l.

LTOP System B 3.4.11 BASES-APPLICABLE Pressurizer Level Performance SAFETY ANALYSES-(continued)

Analyses of operator response time show that the pressurizer level must be maintainr1 s 160 inches to provide the 10 minute action time for correcting transients. (Ref. 3)

The pressurizer level limit of s.135 inches includes correction for instrument uncertainties.

The pressurizer level limit will also be re-evaluated for

. compliance each time P/T limit curves are revised based on the results of the vessel material surveillance.

?

RCS Vent Performance With the RCS depressurized, analyses show a vent of 0.75 square inches is capable ot mitigating the transient resulting from full opening of the makeup control valve while the makeup pump is providing RCS makeup. The capacity of a vent this size is greater than the flow resulting from this credible transient.

The RCS vent size will also be re-evaluated for compliance each time P/T limit curves are revised based on the results of the vessel material surveillance.

4 The vent is passive and is not subject to active failure.

(continued)

. Crystal River Unit 3 B 3.4-52E Amendment No.161

LTOP System B 3.4.11 BASES (continued)

LCO The LCO requires an LTOP System OPERABLE with a limited coolant input capability and a pressure relief capability.

To limit coola;t input, the LCO requires only one makeup pump OPERABLE, the HPI deactivated, and the CFT discharge isolation vi,ves closed and immobilized.

For pressure relief, it requires either the pressurizer coolant at or below a maximum level and the PORY OPERABLE with a lift setting at or below the LTOP limit or the RCS depressurized and a vent established.

NOTE: The limits and values presented in this LCO for the PORY lift setooint, enable temperature, and pressurizer level are cofrected for instrument uncertainty. The instrumentation to be used by plant operators to assure compliance with these limits and values are specified in approved plant operating procedures.

The pressurizer is available with a coolant level s 135 inches.

The PORV is OPERABLE when its block valve is open, its lift setpoint is set at s 457 psig and testing has proven its ability to open at that setpoint, and motive power is available to the PORV and the PCRV control circuits.

For the depressurized RCS, an RCS vent is OPERABLE when open with an area of at least 0.75 square inches.

APPLICABILITY This LCO is applicable in MODE 4 when RCS temperature is s 259'F, in MODE 5, and in MODE 6 when the reactor vessel head is not completely detensioned.

The Applicability temperature of 259'F is established by analyser in accordance with Reference 1.

With the vessel nead completely detensioned, overpressurization is not possible.

The vessel head is completely detensioned when the pre-stress has been relieved from all of the studs, and the nuts are free spinning.

The Applicability is modified by a Note stating that CFT isolation is only required when the CFT pressure is more than or equal to the masimum RCS pressure for the existing

~

RCS temperature, as allowed in LC0 3.4.3.

This Note permits the CFT discharge valve surveillance performed only under these pressure and temperature conditions.

(continued)

Crystal River Unit 3 B 3.4-52F Amendment No.161

0 LTOP System B 3.4.11 BASES (continued)

ACTIONS Allowable times are specified in the LC0 to implement the actions and controls described below. Tiiese times range from immediately to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The times are based on operational and industry experience and regulatory recommendations. The times are intended to balance the time necessary to accomplish the actions and the likelihood of experiencing a limiting transient during the action.

A.1 and B.1 With two or more makeup' pumps capable of injecting into the RCS or if the HPI is activated,1 mediate actions are required to render the other pump (s) inoperable or to deactivate HPI.

Emphasis is on immediate deactivation because inadvertent injection with one or more HPI pump OPERABLE is the event of greatest siCnificance, since it causes the greatest pressure increase in the shortest time.

Required Action A.1 is modified by a Note that permits two pumps capable of RCS injection for s 15 minutes to r.110w for pump swaps.

The deactivation of HPI is accomplished by assuring that an inadvertent HPI actuation can not inject water into the RCS through the HPI valves. This may be accomplished by combinations of equipment as determined appropriate for the existing plant conditions such as, disabling all HPI valves or disabling all Makeup pumps.

If powered com)onents are,

used to accomplish deactivation, power should

)e removed to assure positive lockout.

C.l. D.I. and 0.2 An unisolated CFT requires isolation within 1 tour only when the CFT pressure is at or greater than the max 17.um RCS pressure for the existing temperature allow 2d in LC0 3.4.3.

If isolation is needed and cannot be accomplished in I hour, Required Action D.1 and Required Action D.2 provide two options, either of which must be performed in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

By increasing the RCS temperature to > 197'F, the CFT pressure of 600 psig cannot exceed the LTOP limits if both tanks are fully injected.

Depressurizing the CFTs below the LTOP limit of 457 psig also prevents exceeding the LTOP limits in the same event.

(continued)

Crystal River Unit 3 B 3.4-52G Amendment No. 161

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LTOP System B 3.4.11

' BASES:

i ACTIONS E.1. F.1 and F.2 (continued)

With the pressurizer level more than 135. inches, the time for operator action in a pressure increasing event is reduced. The postulated event most affected in the LTOP MODES is failure of the makeup control: valve, which fills 1

-the pressurizer relatively rapidly.- Restoration is required within I hour.

i If restoration within I hour cannot be accomplished, Required Actions F.1 and F.2 must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. -Actions F.1 and F.2 limit the makeup capability by closing the makeup control valve and its isolation valve, which is not required with a high pressurizer level, and permit cooldown and depressurization to continue. When the makeup is isolated, RCS heatup must be stopped because heat addition decreases the reactor cuolant density and increases the pressurizer level. Operations such as starting RC pumps and reducing decay heat removal should not be performed when in this condition.

l G.I. H.l. and H.2 With the PORV inoperable, overpressure relieving capability is lost, and restoration of the-PORV within I hour is required.

If that cannot be accomplished, the ability of the Makeup System to add water must be limited within the p

next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

I If restoration cannot be completed within I hour, Required Action H.1 and Required Action H.2 m>.st be performed to limit RCS water addition capability. Makeup is not required to be deactivated since it may be needed to maintain the RCS.

coolant level. Required Action H.1 and Required Action 3.2 require reducing the makeup tank level to 88 inches.and deactivating the. low low makeup tank level interlock to the borated water storage tank. This makes the available makeup D

water volume insufficient to exceed the LTOP limit b, a makeup control valve full opening, 4

L 4

L (continued).

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Crystal River Unit-3 i

B'3.4-52H-Amendment No. 161 l

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i LT0P System B 3.4.11 i

RASES ACTIONS 1.1 and 1.2

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(continued)

With the pressurizer level above_135 inches and the PORY inoperable or the LT0P System inoperable for any reason other than cited in Condition A through H, the system mur,t be restored to OPr.RABLE status within I hour. When this is i

not possible Required Action 1.2 requires the RCS depressurized and vented within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from the time j

either Conditio.1 started, j

One or more RCS vents may be used. A vent size of n 0.75 -

squara inches is specified.

Such a vent keeps the pressure from full flow of one M&keup pump with a wide open makeup control valve within the.LCO limit.

t This size RCS vent cannot maintain RCS pressure below LTOP limits if the HPl or CFT systems are inadvertently actuated.

l Therefore, verification of the deactivation of two Makeup pumps. HP1 injection, and the CFTs must accompany the i

depressurizing and venting.

Since these systems are rec uired deactivated by the LCO, SR 3.4.11.1, SR 3.4.11.2, enc SR 3.4.11.3 req ire verification of their deactivated stata every 12 hot.rs.

2 SURVEILLANCE The following surveillance requirement frequencies are shown REQUIREMENTS by operating experience and industry accepted practice to be sufficient to regularly assess conditions for potential degradation and to verify operation within the requirements.

SR 3.4.11.1. SR 3.4.11.2. and SR 3.4.11.3 Verifications must be performed that only one makeup pump is capable of injecting into the RCS, the HPI is deactivated, and the CFT discharge isolation valves are closed and immobilized. These Surve111ances ensure the minimum coolant input capability will not create an Rfi overpressure condition to challenge the LT0P System. The Surve111ances are required at 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> intervals.

A Note modifies SR 3.4.11.3 by only requiring this Surveillance when CFT isolation is required, i

4 L

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.(continued)

Crystal River Unit 3 B 3.4-521

. Amandment No.161 j

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LT0P System 8 3.4.11 j

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' BASES I

SURVEILLANCE 1R 3.4.11.4 REQUIREMENTS l

(continued)

Verification of the pressurizer level at s H5 inches by observing control room or other indications ensures a j

cushion of sufficient size is available to reduce the rate of pressure increase from potential transients, j

The 30 minute Surveillance Frequency during heatup and cooldown must be performed for the LC0 Applicability period I

when temperature changes can cause pressurizer level i

variations. This Frequency may be discontinued when the-i ends of these conditions are satistied, as defined in plant j

procedures. Thereafter, the Surveillance '1 required at 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> intervals.

A Note modifies the SR by not requiring the Surveillance when complying with LCO 3.4.ll.b.

SR 3.4.11.5 t

Verification that the PORV block valve is open ensures a flow path to the PORV. This is required at 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> L

intervals.

A Note taodifies the SR by not requiring the Surve411ance when complying with LCO 3.4.ll.b.

SR 3.4.11.6 When stipulated by LCO 3.4.ll.b, the RCS vent of at least 0.75 square inch must be verified open for relief protection.

For an unlocked vent opening, the Frequency is every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

For a locked vent opening in the RCS, the required Frequency is every 31 days.

t A Note modifies the SR by requiring the Surveillance when complying with LC0 3.4.ll.b.

i c

(continued) t 1

I

' Crystal River Unit 3

_B 3.4-52J Amendment No. 161

~, - -

LTOP System 8 3.4.11 BASES SUR*/EILLANCE SR 3.4.11.7 REQUIREMENTS (continued)

A CHANNEL FUNCTIONAL TEST is required within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before or after decreasing RCS temperature to s 259'F and every 31 days thereafter to ensure the setpoint is proper for using the PORY for LTOP.

PORV actuation is not needed, as it could depressurize the RCS.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequency considers the unlikelihood of a low temperature overpressure event during the time.

SR 3.4.11.8-The performance of a CHANNEL CAllBRATION is required every 24 months. The LHANNEL CAllBRATION for the LTOP setpoint ensures that the PORV will be actuated at the appropriate RCS pressure by verifying the accuracy of the instrument string.

The calibration can only be performed in shutdown.

The frequency considers the refueling cycle.

SR 3.4.11.9 Verification that the PORV is selected to the low range setpoint ensures the overpressure protection flow path through the PORV.

This is required at 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> intervals.

A Note modifies the SR by not requiring the Surveillance when complying with LCO 3.4.ll.b.

(continued)

Crystal River Unit 3 B 3.4 52K Amendment No. 161

o5 LTOP System B 3.4.11 BASES (continued)

REFERENCES 1.

ASME Code Case N 514, " Low Temperature Overpressure Protection Section XI, Division 1".

2.

Generic Letter 88 11, *NRC Position on Radiation Embrittlement of Reactor Vessel Materials and its impact on Plant Operations".

3.

FPC Calculation F97 0003, "CR 315 EFPY LTOP Limits".

4.

B&W Nuclear Services (FTI) Document 51-1176431-01,

" Crystal River 3 Reactor Vessel Low Temperature OverpressureProtection(LTOP)".

Crystal River Unit 3 B 3.4-52L Amendment No. 161

~

I *,

ECCS-Operating 8 3.5.2 4

BASES BACKGROUND safety valves. The LPI pumps are capable of disc >1rging to (continued) the RCS at an RCS pressure of approximately 200 pata. When the BWST has been nearly etaptied, the suction for the LPI pumps is manually transferred to the reactor building emergency sump.

The HPI pumps cannot take suction directly from the sump.

If HPI is still needed, a cross connect from the discharge side of the LPI pump to the suction of the HPI pumas would be opened. This is known as " piggy backing" HPI to LPI, and enables continued HPI to the RCS, if needed, after the BWST is emptied to the switchover point.

In the long term cooling period, flow paths in the LPI System can be established to preclude the possibility of boric acid 'a the core region reaching an unacceptably high concentration. One flow path is from the hot leg through the decay heat suction line and then in a reverse direction through the reactor building emergency sur.p suction line into the sump. The other flow path uses the gaps between the hot leg nozzles and the reactor vessel.

These gaps provide a flow path between the outlet annulus and the inlet nozzle /downtomer region of the reactor vessel.

Either flow path is capable of providing the required flow rates to ensure boron precipitation is not a concern.

HPI also functions to supply borated water to the reactor core following increased heat removal events, such as large SL8s.

During a large break LOCA, RCS pressure will decrease to

< 200 psia in < 20 seconds. The ECCS is actuated upon receipt of an Engineered Safeguards Actuation System (ESAS) signal. The actuation of safeguard loads is accomplished in a programmed time sequence.

If offsite power is available, the safeguard loads start immediately (in the programmed sequence).

If offsite power is not available, the engineered safety feature (ESF) buses shed normal operating loads and are connected to the diesel generators.

Safeguard loads are then actuated in the programmed time sequence.

The time delay associated with diesel starting, sequenced loading, and pump starting determines the time required (continued)

Crystal River Unit 3 83.510 Amendment No.161

ECCS-Operating B 3.5.2 6ASf3 A mtinued) n,~

'34fd AJ With one or more ECCS train inoperable and at least 100% of s

the flow equivalent to a single OPERABLE ECCS train available, the inoperable components must be returned to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on NRC recommendations (Ref. 3) that are based on a risk evaluation and is a reasonable time for many repairs.

An ECCS train is inoperable if it is not capable of delivering the design flow to the RCS, The LCO requires the OPERABILITY of a number of independent subsystems. Due to the redundancy of trains and the diversity of subsystems, the inoperability of one component in a train does not render the ECCS incapable of performing its function. Neither does the inoperability of two different components, each in a different train, necessarily result in a loss of function for the ECCS, The intent of this Condition is to maintain a combination of equipment such that the safety injection (SI) flow equivalent to 100%

of a single train remains available.

This allows increased flexibility in plant operations under circumstances when components in opposite trains are inoperable.

An event accompanied by a loss of offsite power and the failure of an EDG can disable one ECCS train until power is restored. A reliability analysis (Ref. 3) has shown the risk of having one full ECCS train inoperable to be sufficiently low to justify continued operation for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

With one or more components inoperable such that the flow equivalent to a single OPERABLE ECCS train is not available, the facility is in a condition outside the accident analyses.

Therefore, LCO 3.0.3 must be immediately entered.

l (continued)

Crystal River Unit 3 8 3.5-15 Am7ndment No.161 l

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ECCS Operating 8 3.5.2 BASES ACTIONS (continued) l 8.1 and 8.2 If the ino)efable components cannot be returned to OPERABLE status wit 11n the associated Com)letion Times, the plan +

must be placed in a MODE in whic) the LCO does not apply.

To achieve this status, the plant must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at least MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVE!LLANCE SR 3.5.2.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in t.ie ECCS flow paths provides assurance that the proper flow paths will exist for ECCS i

operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. These valves include valves in the main flow paths and the first normally closed valve in a branch line. There are several exceptions for valve position verification due to the low potential for these types of valves to be mispositioned. The valve types which are not verified as part of this SR include vent or drain valves (both inside and outside the RB), relief valves outside the RB, instrumentation valves (both inside and outside the RB), check valves (both inside and outside the RB), and sample line valves (inside and outside the RB). A valve that receives an actuation signal is allowed to be in a nonaccident sosition provided the valve will automatically reposition wit 11n the proper stroke time. This Surveillance does not require any testing or valve manipulation; rather, (continued)

Crystal River Unit 3 8 3.5-16 Amendment No. 161

~.

ECCS-Shutdown 8 3.5.3 BASES LCO During an event requiring ECCS actuation, a flow path is (continued) required to provide an abundant supply of water from the BWST to the RCS, via the ECCS pumps and their respective discharge flow paths, to each of the four cold leg injection nozzles and the reactor vessel.

In the long term, this flow path may be switched to take its supply from the reactor building emergency sump and to supply its flow to the RCS hot and cold legs.

i This LCO is modified by a Note which states that HPI may be deactivated in accordance with LCO 3.4.11. " Low Temperature Overpressure Protection (LTOP) System". Operator action is thenrequiredtoinitiateHPl.

In the event of a loss of coolantaccident(LOCA)requiringHPIactuation,thetime required for operator action has been shown by analysis to be acceptable.

APPLICABILITY In MODES 1, 2, and 3, the OPERABILITY requirements for the ECCS are covered by LCO 3.5.2, "ECCS-Operating."

In MODE 4 with the RCS temperature below 280'F, one OPERABLE ECCS train is acceptable without single failure consideration, on the basis of the stable reactivity condition of the reactor and the limited core cooling requirements.

In MODES 5 and 6, plant conditions are such that the probability of an event requiring ECCS injection is extremely low.

Core cooling requirements in MODE 5 are addressed by LCO 3.4.6, "RCS Loops-MODE 5, Loops Filled,"

and LCO 3.4.7, "RCS Loops-MODE 5 Loops Not Filled."

MODE 6 core cooling recuirements are addressed by LCO 3.9.4,

" Decay Heat Removal anc Coolant Circulation-High Water Level," and LCO 3.9.5, " Decay Heat Removal and Coolant Circulation-Low Water Level."

(continued)

Crystal River Unit 3 B 3.5-21 Amendment No.161

ECCS-Shutdown l

B 3.5.3 BASES (continued)

ACTIONS M

If no LPI subsystem is OPERABLE, the unit is not ?repared to respond to a LOCA or to continue cooldown using tl1e DHR/LPI pumps and decay heat heat exchangers. The immediate Completion Time ensures that prompt action is initiated to restore the required cooling capacity. Normally, in MODE 4 reactor decay heat must be removed by a DHR/LPI train operating with suction from the RCS.

If no DHR/LPI train is OPERABLE for this function, reactor decay heat must be removed by some alternate method, such as use of the steam generator (s),(OTSG).

The alternate means of heat removal must continue untti the inoperable ECCS LPI subsystem can be restored to operation so that continuation of decay heat removal (DHR) is provided.

M If no ECCS HPI subsystem is OPERABLE, due to the inoperability of the HPI pump or flow path from the BWST, the plant is not prepared to provide high pressure response to Design Basis Events requiring ECCS response.

The I hour Completion Time to restere at least one ECCS HPI subsystem to OPERABLE status ensures that prompt action is taken to provide the required cooling capacity or to initiate actions to place the plant in MODE $ w1ere an ECCS train is not required.

This Condition does not apply to HPI subsystem components which are deactivated for the purposes of complying with LCO 3.4.11, ' Low Temperature Overpressure Protection (LTOP)

System". With these components deactivated, the HPI subsystem is still considered OPERABLE based upon guidance in NRC Generic Letter g1-18. This guidance allows substitution of m:inual operator action for otherwise automatic functions for the purposes of determining OPERABILITY. The substitutions are limited and must be evaluated against the assumptions in the accident analysis.

In the case of deactivating HPI in MODE 4, the components are available for injection following manual operator action to restore the system to OPERABLE status and tiis action can be accomplished within the time frame required to respond to the transient / accident.

(continued)

Crystal River Unit 3 8 3.5-22 Amendment No. 161

.