ML20210H237

Proposed Tech Specs 3.6.2.1 Extending Allowable Outage Time to Seven Days for One Containment Spray Sys Train Inoperable

ML20210H237
Person / Time
Site:	Waterford
Issue date:	07/29/1999
From:	ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20210H213	List: ML20210H209 ML20210H237
References
NUDOCS 9908030309
Download: ML20210H237 (28)

Text

I NPF-38-221 ATTACHMENT A EXISTING SPECIFICATIONS l

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INDEX ADMINISTRATIVE CONTROLS SECTION P. AGE 6.11 RADIATION PROTECTION PR0 GRAM...............................

6-22 6.12 HIGH RADIATION AREA........................................

6-22 6.13 PROCESS CONTROL PR0 GRAM....................................

6-23 6.14 0FFSITE DOSE CALCULATION MANUAL............................

6-24 6.15 CONTAINMENT LEAKAGE RATE TESTING PROGRAM...................

6-24 l

WATERFORD UNIT 3 XVIII Amendment No. 68,124

CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.1 Two independent centainment spray systems shall be OPERA 8LE with each spray system capable of taaing suction from the RWSP on a containment spray actuation signal and automatically transferring suction to the safety injection system sump on a recirculation actuation signal. Each spray system flow path from the safety injection system sump shall be via an OPERABLE shutdown cooling heat exchanger.

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

MJ13:

With one containment spray system inoperable, restore the inoperable spray system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HDT STAND 8Y with4n the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore the inoperable spray system to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in COLD SHUTD0641 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the wa ar level in the a.

containment spray header riser is > 14g.5 feet MSL elevation.

4 b.

At least once per 31 days by verifyintthat each valve (manual, in the flow path that is not locked, power-operated, or automatic)in position, is correctly positioned to serled, or otherwise. secured take suction from the RW5p.

I By verifying, that on recirculation flow, each pump develops a total c.

i head of greater than or equal to 219 psid when tested pursuant to specification 4.0.5.

d.

At least once per 18 months, during shutdown, by:

l 1.

Verifying that each automatic valve in the flow path actuates

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to its correct position on a CSA$ test signal.

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• With Reactor Coolant System pressure > 400 psia.

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WATERFORD - UNIT 3 3/4 6-16 Amendment No. 89 I

3

CONTAllejENT SYSTEMS SURVEILLANCE'REQUIREM MTS (Continued) 2.

Verifying that upon a recirculation actuation test signal, the safety injection system sump isolation valves open and that a recirculation mode flow path via an OPERA 8LE shutdown cooling heat exchanger is established.

3.

Verifying that each spray pump starts automatically on a CSAS test signal.

l e.

At least once per 10 years by performing an air or smoke flow test l

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through each spray h ader and verifying each spray nozzle is unobstructed.

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WATERFORD - UNIT 3 3/4 6-17 Amendment do. 89

1 CONTAINME6 SYSTEMS BASES 3/4 L

.7 CONTAINMENT VENTILATION SYSTEM (Continued) l Leakage integrity tests with a maximum allowable leakage rate for purge supply and exhaust isolation valves will provide early indication of resilient material seal degradation and will allow the opportunity for repair before gross leakage failure develops. The 0.60 La leakage limit shall not be exceeded when the leakage rates determined by the leakage integrity tests of these valves are added to the previously determined total for all valves and penetrations subject to Type B and C tests.

Operability concems for purge supply and exhaust isolation valves other than those addressed in Actions "a" and "b" of Specification 3.6.1.7 are addressed under Specification 3.6.3, " Containment Isolation Valves."

3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 and 3/4.6.2.2 CONTAINMENT SPRAY SYSTEM and CONTAINMENT COOLING SYSTEM The OPERABILITY of the Containment Spray System and the Containment Cooling System ensures that containment depressurization and cooling capability will be available in the event of a LOCA or MSLB for any double-ended break of the largest reactor coolant pipe or main steam line. Under post-accident conditions these systerns will maintain the containment pressure below 44 psig and temperatures below 269.3*F during LOCA conditions or 413.5'F during MSLB conditions. The systems also reduce the containment pressure by a factor of 2 from its post-accident peak within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, resulting in lower containment leakage rates and lower offsite dose rates.

The Containment Spray System also provides a mechanism for removing iodine from the containment atmosphere under post-LOCA conditions to maintain doses in accordance with 10 CFR Part 100 limits as described in Section 6.5.2 of the FSAR.

In MODE 4 when shutdown cooling is placed in operation, the Containment Spray System is realigned in order to allow isolation of the spray headers. This is necessary to avoid a single failure of the spray header isolation valve causing Reactor Coolant System depressurization and inadvertent spraying of the containment. To allow for this realignment, the Containment Spray System may be taken out-of-service when RCS pressure ii s 400 psia. At this reduced RCS pressure and the reduced temperature associated with entry into MODE 4, the probability and consequences of a LOCA or MSLB are greatly reduced. The Contoinment Cooling System is required OPERABLE in MODE 4 and is available to provide depressurization and cooling capability.

A train of Containment Cooling cor.sists of two fans (powered from the same safety bus) and their associated coolers (supplied from the same cooling water loop). One Containment Cooling train and Containment Spray train has sufficient capacity to meet post accident heat removal requirements.

Operating each containment cooling train fan unit for 15 minutes and verifying a cooling water flow rate of 625 gpm ensures that all trains are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected and corrective action taken.

Revised by NRC Letter dated WATERFORD - UNIT 3 8 3/4 6-3 March 17,1999

CONTAINMENT SYSTEMS BASES

+

3/4 6.2.1 and 3/4.6.2 2 CONTAINMENT SPRAY SYSTEM and CONTAINMENT COOLING SYSTEM (con't)

The 18 month Surveillance Requirement verifies that each containment cooling fan actuates upon receipt of an actual or simulated SIAS actuation signal. The 18 month frequency is based on engineering judgment and has been shown to be acceptable through operating experience.

Verifying a cooling water flow rate of 1200 gpm to each cooling unit provides assurance that the design flow rate assumed in the safety analyses will be achieved. The safety analyses assumed a cooling water flow rate of 1100 gpm. The 1200 gpm requirement accounts for measurement instrument uncertainties and potential flow degradation. Also considered in selecting the 18 month frequency were the known reliability

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of the Cooling Water System, the two train redundancy, and the low probability of a significant degradation of flow occurring between surveillances. The flow measurement for the 18 month test shall be done in a configuration equivalent to the accident lineup to ensure that in an accident situation adequate flow will be provided to the containment fan coolers for them to perform their safety function.

Verifying that each valve actuates to the full open position provides further assurance that the valves will travel to their full open position on a Safety injection Actuation Signal.

3/4.6.3 CONTAINMENT ISOLATION VALVES The OPERABILITY of the containment isolation valves ensures that the containment atmosphere will be isolated from the outside environment ;n the event of a release of radioactive material to the containment atmosphere or pressurization of the containment and is consistent with the requirements of GDC 54 through GDC 57 of Appendix A to 10 CFR Part 50. Containment isolation within the time limits specified for those isolation valves designed to close automatically ensures that the release of radioactive material to the i

environment will be consistent with the assumptions used in the analyses for a LOCA.

The opening of locked or sealed closed containment isolation valves on an mtermittent basis under administrative control includes the following considerations: (1) stationing an operator, who is in constant communication with control room, at the valve controls, (2) instructing this operator to close these valves in an accident situation, and (3) assuring that environmental conditions will not preclude access to close the valves and that this action will prevent the releass of radioactivity outside the containment.

" Containment isolation Valves", previously Table 3.6-2, have been incorporated into the Technical Requirements Manual (TRM).

i For penetrations with multiple flow paths, only the affected flow path (s) is required to be isolated when a

. containment isolation valve in that flow path is inoperable. The flow path may be isolated with the inoperable valve in accordance with the Action requirements, provided the leakage rate acceptance criteria, as applicable, is met and controls are in place to ensure the valve is closed. Also, the penetration is required to meet the requirements of GDC 54, and GDC-55 through GDC 57, as applicable, for all the unisolated flow paths.

Revised by NRC Letter dated March 17,1999 WATERFORD - UNIT 3 B 3/4 6-4 TSCR 97-23

(Continued)

Laekage rate assapeanes critons are:

a.

Overen omtaanment leakage rete acceptance enteria is 11.0 L. Durmg the Arzt unit startup f:":;i.g each test posformed in accordance with this program, the overall containment leakage rate acceptance arttena are 10.60 L for the Type 5 and Type C tests and 10.75 L for Type A tests.

b.

Airlock acceptance criteria are:

1.

overen air neck i.eksee rete is s 0.08 ( when tested at a P,.

2.

Leakage rate for each door seat is s 0.006 L when pressunned to a 10 psig.

I c.

Seeendary senteinmern bypass leak &ge rate neseptanos enterte is 10.08 L when i

tested et 2 P,.

d.

Containment purge veW with rossisent seale assoptenes ortlerte le a 0.08 ( when tested et a P,.

ne previsione et speoulassion d.0.2 de not apply to the test treguensies speamed in en cantsevnent Leekage Rete Tegens Preersen.

The previsione et speameenen 4.o.s are appeestie to the contenment Laskese Rene Teenne Preeram.

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NPF-38-221 ATTACHMENT B PROPOSED MARKED-UP SPECIFICATIONS I

l neu ADMINISTRATIVE CONTROLS SECTION EAE 6.11 RADIATION PROTECTION PR0 GRAM...............................

6-22 6.12 HIGH RADIATION AREA........................................

6-22 6.13 PROCESS CONTROL PR0 GRAM....................................

6-23 6.14 0FFSITE DOSE CALCULATION MANUAL............................

6-24 6.15 CONTAINMENT LEAKAGE RATE TESTING PROGRAM...................

6-24 l

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WATERFORD UNIT 3 XVIII Amendment No. 68,124 i

i I

CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY SYSTEM LIMITING CONDITION FOR OPE *ATION 3.6.2.1 Two independent containment spray systems shall be OPERABLE with each spray system capable of taking suction from the RWSP on a containment spray actuation signal and automatically transferring suction to the safety injection system sump on a recirculation actuation signal.

Each spray system flow path from the safety injection system sump shall be via an OPERABLE shutdown cooling heat exchanger.

APPLICARILITY: MODES 1, 2, 3 /end #

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a. With one containment spray system inoper e, restore the inoperable spray system to OPERABLE status within4* inster be in at least H0T STAN08Y with4n the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; r:: tere th: i-^---"!: ;E.. :;-:yet-- te ^J:"f.".; et:t:::

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SURVEILLANCE REQUIREMENTS 4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by varifying that the water level in the a.

containment spray h6ader riser is > 149.5 feet MSL elevation.

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b.

At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, serled, or othereise. secured in position, is correctly positioned to take suction from the RW5p.

By verifying, that on recirculation flow, each pump develops a total c.

head of greater than or equal to 219 psid when tested pursuant to specification 4.0.5.

d.

At least once per 18 months, during shutdown, by:

1.

Verifying that each automatic valve in the flow path actuates to its correct position on a CSAS test signal.

412 " ::ter Sel::t4y; tee v...m e > "t 73i4.-

l WATERFORD - UNIT 3 3/4 6-16 Amendment No. 89

INSERT 1

b. With two containment spray systems inoperable, restore at least one spray system to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

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No Chq 9e3 fMs P " i t p r o v < d ecl fo' Cot b al/9 CONTAINNENT SYSTEMS

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SURVEILLANCE' REQUIREMENTS (Continued) 2.

Verifying that upon a recirculation actuation test signal, the safety injection system sump isolation valves open and that a recirculation mode flow path via an OPERABLE shutdown cooling heat exchanger is established.

j 3.

Verifying that each spray pump starts automatically on a CSAS test signal.

e.

At lecst once per 10 years by performing an air or smoke flow test l

)

through each spray header and verifying each spray nozzle is unobstructed.

blATERFORD - UNIT 3 3/4 6-17 Amendment No. 89 J

CONTAINMENT SYSTEMS BASES 3/4.61.7 CONTAINMENT VENTILATION SYSTEM (Continued) l Leakage integrity tests with a maximum allowable leakage rate for purge supply and exhaust isolation valves will provide early indication of resilient material seal degradation and will allow the opportunity for repair before gross leakage failure develops. The 0.60 La leakage limit shall not be exceeded when the leakage rates determined by the leakage integrity tests of these valves are added to the previously determined total for all valves and penetrations subject to Type B and C tests.

Operability concems for purge supply and exhaust isolation valves other than those addressed in Actions "a" and "b" of Specification 3.6.1.7 are addressed under Specification 3.6.3, " Containment isolation Valves."

3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 and 3/4.6.2.2 CONTAINMENT SPRAY SYSTEM and CONTAINMENT COOLING SYSTEM The OPERABILITY of the Containment Spray System and the Containment Cooling System ensures that containment depressurization and cooling capability will be available in the event of a LOCA or MSLB for any double-ended break of the largest reactor coolant pipe or main steam line. Under post-accident conditions these systems will maintain the containment pressure below 44 psig and temperatures below 269.3*F during LOCA conditions or 413.5'F during MSLB conditions. The systems also reduce the containment pressure by a factor of 2 from its post-accident peak within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, resulting in lower containment leakage rates and lower offsite dose rates.

g The Containment Spray System also provides a mechanism for removing iodine from the containment atmosphere under post-LOCA conditions to maintain doses in accordance with 10 CFR Part 100 limits as described in Section 6.5.2 of the FSAR.

F2 in MODE 4 when shutdown cooling is placed in operation, the Containment Spray System is realigned in order to allow isolation of the spray headers. This is necessary to avoid a single failure of the spray header isolation valve causing Reactor Coolant System depressurization and inadvertent spraying of the containment. To allow for this r ent, the Containment Spray System may be taken out-of-service when 9CE preteure is c '00 psia. A reduced RCS pressure and the reduced temperature associated with Fentry into MODE 4, the probability and consequences of a LOCA or MSLB are greatly redu Containment Cooling System is required OPERABLE in MODE 4 and is available to provide depressurization and cooling capability,m>,-m-r, Qope 4 is

~

A train of Containment Cooling consists of two fans (powered from the same safety bus) and their associated coolers (supplied from the same cooling water loop). One Containment Cooling train and Containment Spray train has sufficient capacity to meet post accident heat removal requirements.

Operating each containment cooling train fan unit for 15 minutes and verifying a cooling water flow rate of

~

625 gpm ensures that all trains are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected and corrective action taken.

j Revised by NRC Letter dated WATERFORD - UNIT 3 B 3/4 6-3 March 17,1999

INSERT 2 If LCO 3.6.2.1 requirements are not met due to the condition described in ACTION (a), then the inoperable CSS train components must be retumed to OPERABLE status within seven (7) days of discovery. This seven (7) day allowed outage time is based on the findings of deterministic and probabilistic analysis, CE NPSD-1045, ' Modifications To The Containment Spray System, and Low Pressure Safety injection System Technical Specifications". Seven (7) days is a reasonable amount of time to perform many corrective and preventative maintenance items on the affected CSS train. CE NPSD-1045 concluded that the overall risk impact of the seven (7) day allowed outage time was either risk-beneficial or risk-neutral.

A Configuration Risk Management Program (CRMP) defined in Administrative Controls section 6.16 is implemented in the event of entry in+o ACTION (a).

ACTION (b) addresses the condition in which two CSS trains are inoperable and requires restoration of at least one spray system to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or the plant to be placed in HOT STANDBY in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. CE NPSD-1045 has demonstrated that HOT SHUTDOWN is an acceptable end state. (COLD SHUTDOWN is also an acceptable end state.)

l JUo Ch o9es %' s pa7 e - p m ded CONTAINMENT SYSTEMS 4cv %/W 4 BASES 3/4 6.2.1 and 3/4.6.2.2 CONTAINMENT SPRAY SYSTEM and CONTAINMENT COOLING SYSTEM (con't)

The 18 month Surveillance Requirement verifies that each containment cooling fan actuates upon receipt of an actual or simulated SIAS actuation signal. The 18 month frequency is based on engineering judgment and has been shown to be acceptable through operating experience.

Verifying a cooling water flow rate of 1200 gpm to each cooling unit provides assurance that the design flow rate assumed in the safety analyses will be achieved. The safety analyses assumed a cooling water flow rate of 1100 gpm. The 1200 gpm requirement accounts for measurement instrument uncertainties and potential flow degradation. Also considered in selecting the 18 month frequency were the known reliability of the Cooling Water System, the two train redundancy, and the low probability of a significant degradation of flow occurring between surveillances. The flow measurement for the 18 month test shall be done in a configuration equivalent to the accident lineup to ensure that in an accident situation adequate flow will be provided to the containment fan coolers for them to perform their safety function.

Verifying that each valve actuates to the full open position provides further assurance that the valves will travel to their full open position on a Safety injection Actuation Signal.

3/4 6.3 CONTAINMENT ISOLATION VALVES The OPERABILITY of the containment isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment and is consistent with the requirements of GDC 54 through GDC 57 of Appendix A to 10 CFR Part 50. Containment isolation within the time limits specified for those isolation velves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a LOCA.

The opening of locked or sealed closed containment isolation valves on an intermittent basis under administrative control includes the following considerations: (1) stationing an operator, who is in constant communication with control room, at the valve controls, (2) instructing this operator to close these valves in an accident situation, and (3) assuring that environmental conditions will not preclude access to close the valves and that this action will prevent the release of radioactivity outside the containment.

" Containment isolation Valves", previously Table 3.6-2, have been incorporated into the Technical Requirements Manual (TRM).

For penetrations with multiple flow paths, only the affected flow path (s) is required to be isolated when a containment isolation valve in that flow path is inoperable. The flow path may be isolated with the inoperable valve in accordance with the Action requirements, provided the leakage rate acceptance criteria, as applicable, is met and controls are in place to ensure the valve is closed. Also, the penetration is required to meet the requirements of GDC-54, and GDC-55 through GDC 57, as applicable, for all the unisolated flow paths.

Revised by NRC Letter dated March 17,1999 WATERFORD - UNIT 3 8 3/4 6-4 TSCR 97-23

(Contmuod)

Leekage rate estoptenes artierte are:

e.

Overes conterwnent leakage rate ecceptance criterie is i 1.o L. Dunng the Arst unit startup ? ":3 each test performed in ecooraanos with trus program, the everait contsenment hakage rate acceptance entena are 5 o.60 L for the Type e end Type c tests and s 0.7s y for Type A tests.

b.

Airlook asseptance artierte are:

1.

overen air issk i eksee rete is s o.os L when meted at a P,.

2.

i.eaksee rue for each deer semi le s o.cos L when preneurtmed m a to pois.

I c.

secondary sentainment trypass leaksee rate esseptense enterte is s o.os (wNm I

testes et a P,.

d.

Centelnment purge velves with rendent eeele assoptenes enterte le s o.os ( when testes a a P,.

The pntvisione et speculsesen 4.o.2 de not apper a the test teguenales speamed in the contenment Laaksee Rene Teseing Program.

The provisione et speemassen 4.0.3 are appecame to the containment Laskese Rete Teenne Pr-em.

/W s ee r 3 0

maa="=. g.

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INSERT 3 6.16 Configuration Risk Management Program (CRMP) l The Configuration Risk Management Program (CRMP) provides a proceduralized risk-informed assessment to manage the risk associated with equipment inoperability. The program applies to technical specification structures, systems, or components for which a risk-informed Completion Time has been granted. The program shall include the following elements:

I a.

Provisions for the control and implementation of a Level 1 at power internal events PRA-informed methodology. The assessment shall be capable of evaluating the applicable plant configuration.

b.

Provisions for performing an assessment prior to entering the LCO Condition for preplanned activities.

c.

Provisions for performing an assessment after entering the LCO Condition for unplanned entry into the LCO Condition.

d.

Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the LCO Condition.

e.

Provisions for considering other applicable risk significant contributors such as Level 2 issues, and external events, qualitatively or quarsitatively.

l i

r

NPF-38-221 ATTACHMENT C PROPOSED SPECIFICATIONS l

INDEX ADMINISTRATIVE CONTROLS SECTION PAGE 6.11 RADIATION PROTECTION PROGRAM............

6-22 0.12 HIGH RADIATION AREA.....................

6-22 6.13 PROCESS CONTROL PROGRAM........

6-23 6.14 OFFSITE DOSE CALCULATION MANUAL......

6-24 6.15 CONTAINMENT LEAKAGE RATE TESTING PROGRAM.....

6-24 6.16 CONFIGURATION RISK MANAGEMENT PROGRAM...

6-25 l

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l i

WATERFORD - UNIT 3 Will AMENDMENT NO. SS,124

p CONTAINMENT SYSTEMS 3/4.6.2'DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY SYSTEM LIMITING CONDITION FOR OPERATION I

3.6.2.1 Two independent containment spray systems shall be OPERABLE with each spray system capable of taking suction from the RWSP on a containment spray actuation signal and automatically transferring suction to the safety injection system sump on a recirculation i

actuation signal. Each spray system flow path from the safety injection system sump shall be via an OPERABLE shutdown cooling heat exchanger.

APPLICABILITY: MODES 1,2, and 3.

l ACTION a.

. With one containment spray system inoperable, restore the inoperable spray system to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

l b.

With two containment spray systems inoperable, restore at least one spray system to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVElLLANCE REQUIREMENTS 4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:

a.

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the water level in the containment spray header riser is > 149.5 feet MSL elevation.

. b.

At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is correctly positioned to take suction from the RWSP.

c.

By verifying, that on recirculation flow, each pump develops a total head of greater than or equal to 219 psid when tested pursuant to Specification 4.0.5.

d.

At least once per 18 months, during shutdown, by:

1.

Verifying that each automatic valve in the flow path actuates to its correct position on a CSAS test signal.

r WATERFORD - UNIT 3 3/4 6-16 AMENDMENT NO. 69

r. -

CONTAINMENT SYdTEMS, SURVE'lLLANCE REQUIREMENTS (Continued)

2. Verifying that upon a recirculation actuation test signal, the safety injection system sump isolation valves open and that a recirculation mode flow path via an OPERABLE shutdown cooling heat exchanger is established.

3. Verifying that each spray pump starts automatically on a CSAS test signal.

e. At least once per 10 years by performing an air or smoke flow test through each spray header and verifying each spray nozzle is unobstructed.

WATERFORD - UNIT 3 3/4 6-17 AMENDMENT NO. 89

CONTAINMENT SYSTEMS

)

BASES

• 3/4.6.1.7 CONTAINMENT VENTILATION SYSTEM (Continued)

Leakage integrity tests with a maximum allowable leakage rate for purge supply and exhaust isolation valves will provide early indication of resilient material seal degradation and will allow the opportunity for repair before gross leakage failure develops. The 0.60 La leakage limit shall not be exceeded when the leakage rates determined by the leakage integrity tests of these valves are added to the previously determined total for all valves and panetrations subject to Type B and C tests.

Operability concerns for purge supply and exhaust isolation valves other than those addressed in Actions "a" and "b" of Spec;fication 3.6.1.7 are addressed under Specification 3.6.3, " Containment isolation Valves."

3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 and 3/4.6.2.2 CONTAINMENT SPRAY SYSTEM and CONTAINMENT COOLING SYSTEM

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The OPERABILITY of the Containment Spray System and the Containment Cooling System ensures that containment depressurization and cooling capability will be available in the event of a LOCA or MSLB for any double-ended break of the largest reactor coolant pipe or main steam line. Under post-accident conditions these systems will maintain the containment pressure below 44 psig and temperatures below 269.3*F during LOCA conditions or 413.5'F during MSLB conditions. The systems also reduce-the containment pressure by a factor of 2 from its post-accident peak withm 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, resulting in lower containment leakage rates and lower offsite dose rates.

The Containment Spray System (CSS) also provides a mechanism for removing iodine l

from the containment atmosphere under post-LOCA conditions to maintain doses in accordance i

with 10 CFR Part 100 limits as described in Section 6.5.2 of the FSAR.

I If LCO 3.6.2.1 requirements are not met due to the condition described in ACTION (a),

then the inoperable CSS train components must be returned to OPERABLE status within seven (7) days of discovery. This seven (7) day allowed outage time is based on the findings of deterministic and probabilistic analysis, CE NPSD-1045, " Modifications To The ContainmW Spray System, and Low Pressure Safety injection System Technical Specifications". Seven (7) days is a reasonable amount of time to perform many corrective and preventative maintenance items on the affected CSS train. CE NPSD-1045 concluded that the overall risk impact of the seven (7) aay allowed outage time was either risk-beneficial or risk-neutral.

A Configuration Risk Management Program (CRMP) defined in Administrative Controls section 6.16 is implemented in the event of entry into ACTION (a).

Revised by NRC Letter dated WATERFORD - UNIT 3 B 3/4 6-3 March 17.,1999

CONTAINMENT SYSTEMS BASES

• 3/4.6.2.1 and 3/4.6.2.2 CONTAINMENT SPRAY SYSTEM and CONTAINMENT COOLIN_G SYSTEM (Continued)

ACTION (b) addresses the condition in which two CSS trains are inoperable and requires

^ atoration of at least one spray system to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or the plant to be placed in HOT STANDBY in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. CE NPSD-1045 has demonstrated that HOT SHUTDOWN is an acceptable end state. (COLD SHUTDOWN is also an acceptable end state.)

In MODE 4 when shutdown cooling is placed in operation, the Containment Spray System is realigned in order to allow isolation of the spray headers. This is necessary to avoid a single failure of the spray header isolation valve causing Reactor Coolant System depressurization and inadvertent spraying of the containment. To allow for this realignment, the Containment Spray System may be taken out-of-service when MODE 4 is entered. At the reduced RCS pressure and the reduced temperature associated with entry into MODE 4, the probability and consequences of a LOCA or MSLB are greatly reduced. The Containment Cooling System is required OPERABLE in MODE 4 and is available to provide depressurization and cooling capability.

A train of Containment Cooling consists of two fans (powered from the same safety bus) and their associated coolers (supplied from the same cooling water loop). One Containment Cooling train and Containment Spray train has sufficient capacity to meet post accident heat removal requirements.

Operating each containment cooling train fan unit for 15 minutes and verifying a cooling water flow rate of 625 gpm ensures that all trains are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected and corrective action taken.

The 18 month Surveillance Requirement verifies that each containment cooling fan actuates upon receipt of an i Nat or simulated SlAS actuation signal. The 18 month frequency is based

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on engineering judgnient and has been shown to be acceptable through operating experience.

Verifying a cooling water flow rate of 1200 gpm to each cooling unit provides assurance that the design flow rate assumed in the safety analyses will be achieved. The safety analyses assumed a cooling water flow rate of 1100 gpm. The 1200 gpm requirement accounts for measurement instrument uncertainties and potential flow degradation. Also considered in selecting the 18 month frequency were the known reliability of the Cooling Water System, the two train redundancy, and the low probability of a significant degradation of flow occurring between surveillances. The flow measurement for the 18 month test shall be done in a j

configuration equivalent to the accident lineup to ensure that in an accident situation adequate flow will be provided to the containment fan coolers for them to perform their safety function.

Revised by NRC Letter dated WATERFORD -UNIT 3 B 3/4 6-4 March 17,1999

CONTAINMENT SYSTEMS BASES

• 3/4.6.2.1 and 3/4.6.2.2 CONTAINMENT SPRAY SYSTEM and CONTAINMENT COOLING SYSTEM (Continued)

Verifying that each valve actuates to the full open position provides further assurance that the valves will travel to their full open position on a Safety injection Actuation Signal.

3/4.6.3 Cf)NTAINMENT ISOLATION VALVES The OPERABILITY of the containment isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment and is consistent with the requirements of GDC 54 through GDC 57 of Appendix A to 10 CFR Part 50.

Containment isolation within the time limits specified for those isolation valves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a LOCA.

The opening of locked or sealed closed contair6 ment isolation valves on an intermittent basis under administrative control includes the following considerations: (1) stationing an operator, who is in constant communication with control room, at the valve controls, (2) instructing this operator to close these valves in an accident situation, and (3) assuring that environmental conditions will not pred!;de access to close the valves and that this action will prevent the release of radioactivity outside the containment.

" Containment Isolation Valves", previously Table 3.6-2, have been incorporated into the Technical Requirements Manual (TRM).

For penetrations with multiple flow paths, only the affected flow path (s) is required to be isolated when a containment isolation valve in that flow path is inoperable. The flow path may be isolated with the inoperable valve in accordance with the Action requirements, provided the leakage rate acceptance criteria, as applicable, is met and controls are in place to ensure the valve is closed. Also, the penetration is required to meed the requirements of GDC-54, and GDC-55 through GDC 57, as applicable, for all the unisolated flow paths.

Revised by NRC Letter dated WATERFORD - UNIT 3 8 3/4 6-5 March 17,1999

C_ONTA!NMENT SYSTEMS BASES

• 3/4.6.4 COMBUSTIBLE GAS CONTROL The OPERABILITY of the equipment and systems required for the detection and control of hydrogen gas ensures that this equipment will be available to maintain the hydrogen concentration within containment below its flr nable limit during post-LOCA conditions. Either recombiner unit is capable of controlling the expected hydrogen generation associated with (1) zirconium-water reactions, (2) radiolytic decomposition of water, and (3) corrosion of metals within containment. These hydrogen control systems are consistent with the recommendations I

of Regulatory Guide 1.7, " Control of Combustible Gas Concentrations in Containment Following a LOCA," March 1971.

SURVEILLANCE REQUIREMENT SR 4.6.4.2.a requires performance of a system functional test for each hydrogen recombiner to ensure that the recombiners are operational and can attain and sustain the temperature necessary for hydrogen recombination. In particular, this SR requins verification that the minimum heater sheath temperature increases to 2 700 F in s 90 minutes. After reaching 700*F, the power is increased to maximum for approximately 2 minutes and verified to be 2 60 kW.

SURVEILLANCE REQUIREMENT SR 4.6.4.2.b ensures that there are no physical problems that could affect recombiner operation. Since the recombiners are mechanically passive, they are not subject to mechanical failure. The only credible failures involve loss of power, blockage of the internal flow path, missile impact, etc. A visual inspection is sufficient to detern'ine i

abnormal conditions that could cause such failures.

SURVEILLANCE REQUIREMENT SR 4.6.4.2.c requires performance of a resistance to ground test for each heater phas e to enstre that there are no detectable grounds in any heater phase. This is accomplished by wrifying t.lat the resistance to ground for any heater phase is a 10,000 ohms.

3/4.6.5 VACUUM RELIEF VALVES The OPERABILITY of the primary containment to annulus vacuum relief valves with a setpoint of less than or equal + 0.3 psid ensures that the containment internal pressure differential does not become more negative than the containment design limit for internal pressure differential of 0.65 psi. This situation would occur, for the worst case, if all containment heat removal systems (containment spray, containment cooling, and other HVAC systems) were inadvertently started with only one vacuum relief valve OPERABLE.

WATERFORD - UNIT 3 B 3/4 6-6 AMENDMENT NO. -75,110,131

CONTAINMENT SYSTEMS BASES

• 3/4.6.6 SECONDARY CONTAINMENT 3/4.6.6.1 SHIELD BUILDING VENTILATION SYSTEM The OPERABILITY of the shield building ventilation systems ensures that containment vesselleakage occurring during LOCA conditions into the annulus will be filtered through the HEPA filters and charcoal adsorber trains prior to discharge to the atmosphere. This requirement is necessary to meet the assumptions used in the safety analyses and limit the site boundary radiation doses to within the limits of 10 CFR Part 100 during LOCA conditions.

Operation of the system with the heaters on for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> continuous over a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters.

Obtaining and analyzing charcoal samples after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of adsorber operation (since the last sample and analysis) ensures that the adsorber maintains the efficiency assumed in the safety analyses and is consistent with Regulatory Guide 1.52.

3/4.6.6.2 SHIELD BUILDING INTEGRITY SHIELD BUILDING INTEGRITY ensures that the release of radioactive materials from the.

primary containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the safety analyses. This restriction, in conjunction with operation of the shield building ventilation system, will limit the site boundary radiation doses to within the limits of 10 CFR Part 100 during accident conditions.

3/4.6.6.3 SHIELD BUILDING STRUCTURAL INTEGRITY This limitation ensures that the structural integrity of the containment shield building will be maintained comparable to the original design standards for the life of the facility. Structural integrity is required to provide (1) protection for the steel vessel from external missiles, (2) radiation shielding in the event of a LOCA, and (3) an annulus surrounding the steel vessel that can be maintained at a negative pressure during accident conditions. A visualinspection is sufficient to demonstrate this capability.

WATERFORD - UNIT 3 B 3/4 6-7 AMENDMENT NO.131

MISTRATIVE CONTROLS

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CONTAlkMENT LEAKAGE RATc TESTING PROGRAM (Continued)

Leakage rate acceptance criteria are:

a.

Overall containment leakage rate acceptance criteria is s 1.0 (. During the first unit startup following each test performed in accordance with this program, the overall containment leakage rate acceptance criteria ares 0.601., for the Type B and Type C tests and s 0.75 L for Type A tests.

b.

Air lock acceptance criteria are:

1.

Overall air lock leakage rate is s 0.051., when tested at 2 P,.

2.

Leakage rate for each door sealis s 0.005 L, when pressurized toa 10 psig.

c.

Secondary containment bypass leakage rate acceptance criteria is s 0.06 L, when tested at 2 P,.

d.

Containment purge valves with resilient seats acceptance criteria is s 0.06 L, when tested atz P,.

The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of Specification 4.0.3 are applicable to the Containment Leakage Rate Testing Program.

6.16 CONFIGURATION RISK MANAGEMENT PROGRAM (CRifE)

The Configuration Risk Management Program (CRMP) provides a preceduralized risk-informed assessment to manage the risk associated with equipment inoperability. The program applies to technical specification structures, systems, or components for which a risk-informed Completion

. Time has been granted. The program shall include the following elements:

a.

Provisions for the control and implementation of a Level 1 at power intemal events PRA-informed methodology. The assessment shall be capable of evaluating the applicable plant configuration.

b.

Provisions for performing an assessment prior to entering the LCO Condition for j

preplanned activities.

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WATERFORD - UNIT 3 6-25 AMENDMENT NO. 127,100

ADMINISTRATIVE CONTROLS CONFIGlJRATION RISK MANAGEMENT PROGRAM (CRMP) (Continued) c.

Provisions for performing an assessment after entering the LCO Condition for unplanned entry into the LCO Condition.

d.

Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the LCO Condition.

e.

Provisions for considering other applicable risk significant contributors such as Level 2 issues, and extemal events, qualitatively or quantitatively.

WATERFORD - UNIT 3 6-26 AMENDMENT NO.