Text

Existing & Proposed TS Pages Modifying TS 3.5.2 by Extending AOT to Seven Days for One HPSI Train Inoperable & TS 3.5.3, Changing end-state to Hot Shutdown with at Least One Operable Shutdown
	ML20210M986
Person / Time
Site:	Waterford
Issue date:	08/04/1999
From:	; ENTERGY OPERATIONS, INC.
To:	;
Shared Package
ML20210M982	List: ML20210M976; ML20210M986;
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	NUDOCS 9908100249
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NPF-38-222 l

ATTACHMENT A EXISTING SPECIFICATIONS i

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9908100249 990804 PDR ADOCK 05000382 P

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4 IllD.El ADMINISTRATIVE CONTROLS SECTION f1E 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 CONTAIMENT LEAKAGE RATE TESTING PR0 GRAM...................

6-24 l

i WATERFORD UNIT 3 XVIII Amendment No. 68,124

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS - MODES 1. 2. AND 3 LIMITING CONDITION FOR OPERATION 3.S.2 Two independent emergency core cooling system (ECCS) subsystems shall be OPERABLE with each subsystem comprised of:

a.

One OPERA 8LE high-pressure safety injection pump, b.

One OPERABLE low pressure safety injection pump, and c.

An independent OPERA 8LE flow path capable of taking suction from the refueling water storage pool on a safety injection actuation signal and automatically transferring suction to the safety injection system sump on a recirculation actuation signal.

-APPLICABILITY:

M00ES 1, 2, and 3*f.

ACTION:

s.

With one ECCS subsystem inoperable, restore the inoperable subsystem to OPERA 8LE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STAN08Y within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in H0T SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b.

In the event the ECCS is actuated and injects water into the Reactor

, Coolant System, a Special. Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days des-cribing the circumstances of the actuation and the total accumulated actuation cycles to data. The current value of the usage factor for each affected safety injection no ule shall be provided in this 1

Special Report whenever its value exceeds 0.70.

Nith pressurizer pressure greater than or equal to 1750 p'sia.

fWith RCS average temperature greater than or equal to 500 F.

s WATI.RFORD - UNIT 3 3/4 5-3 l

EMERGENCY CORE COOLING SYSTEMS ll_4d.3ECCSSUB5YSTEMs-MODES 3AND4 l

M ING C00 GIT!0N FOR OPERATION

3. 5. 1 As a minimum, one ECCS subsystem comprised of the following shall be OPERABLE:

1 One OPERA 8LE high pressure safety injection pump, and a.

b.

An OPERABLE flow path capable of taking suction from the refueling water storage pool on a safety injection actuation signal and auto-matica11y transferring suction to the safety injection system sump on a recirculation actuation signal.

APPLICA8ILITY:

M00E5 38 and 4.

ACTION:

With no ECCS subsystem OPERA 8LE, restore at least one ECCS subsystem a.

to 0PERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in COLD SHUTDOWN within the,

next 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months .

b.

In the event the ECCS is actuated and injects water into the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 4.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date. The current value of the usage factor for each affected safety injection nozzle shall be provided in this Special Report whenever its value exceeds 0.70.

SURVEILLANCE REQUIng e rg 4.5.3 -The ECCS subsystem shall be demonstrated OPERABLE per the applicable Surveillance Requirements of 4.5.2.

~

'itith pressurizer pressure less than 1750 psia and the RCS average temperature less than 500*F.

O WATERFORD - UNIT 3 3/4 5-8 AMEN 0 MENT NO. 34

1 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 8ASES 3/4.5.1 SAFETY INJECTION TANKS The OPERABILITY of each of the Reactor Coolant System (RCS) safety injection tanks ensures that a sufficient volume of borated water will be immediately furced into the reactor core through each of the cold legs in the event the RCS pressure falls below the pressure of the safety injection tanks.

This initial surge of water into the core provides the initial cooling mechanism during large RCS pipe ruptures.

The limits on safety injection tank volume, boron concentration, and pressure ensure that the assumptions used for safety injection tank injection in the safety analysis are met.

The safety injection tank power operated isolation valves are considered to be " operating bypasses" in the context of IEEE Std. 279-1971, which requires that bypasses of a protective function be removed automatically whenever permissive conditions are not met.

In addition, as these safety injection '

tank isolation valves fail to meet single failure criteria, removal of power to the valves is required.

The limits for operation with a safety injection tank inoperable for any reason except an isolation valve closed minimizes the time exposure of the plant to a LOCA event occuring concurrent with failure of an additional safety injection tank which any result in unacceptable peak cladding tesseratures.

If a closed isolation valve cannot be immediately opened, the full capability of one safety injection tank is not available and proept action is required to place the reactor in a mode where this capability is not required.

3/4,5.2 and 3/4.5.3 ECCS $LESYSTDIS The OPERASILITY of two separate and independent ECC5 subsystems ensures that suffittent emergency core cooling capability will be available in the event of a RN A assuming the loss of one subsystem through any single failure considerettuk Either subsystes operating in conjunction with the safety injection the is capable of supplying sufficient core cooling to limit the peak clad (fag temperatures within acceptable limits for all postulated break sizes ranging from the double-ended break of the largest RCS cold leg pipe downward.

In additten, each ECCS subsystes provides long-term core cooling capability in the recirculation mode during the accident recovery period.

When in mode 3 and with RCS temperature 5008F two 0PERABLE ECCS subsys-tems are required to ensure sufficient emergency core cooling capability is available to prevent the core from becoming critical during an uncontrolled cooldown (i.e., a steam line break) from greater than 5000F.

l WATERFORO - UNIT 3 8 3/4 5-1 Amendment No. 34

EMERGENCY CORE COOLING SYSTEMS BASES ECCS SUBSYSTEMS (Continued)

With the RCS temperature below 350*F, one OPERABLE ECCS subsystem is acceptable without single failure consideraten on the basis of the stable reachwity condition of the reactor and the limited core cooling requirements.

The tnsodium phosphate dodecahydrate (TSP) stored in dissolving baskets located in the containment basement is provided to mimmaze the possibility of corrosion cracking of certain metal components during operaten of the ECCS following a LOCA. The TSP provides this pie 6,000 by dissolving in the sump water and causing its final pH to be raised to greater than or equal to 7.0. The requirement to dissolve a.w :::1,;.uve sample of TSP in a sample of water i

borated to be representative of post-LOCA sump conditions provides assurance that the stored TSP will dissolve in borated water at the postulated post-LOCA temperatures. A boron concentration of 3011 ppm boron is postulated to be F.pc::,; Sic of the highest post-LOCA sump boron concentration. Post-LOCA sump pH will remain between 7.0 and 8.1 for the maximum (3011 ppm) and minimum (1504 ppm) boron concentretens calculated using the maximum and minimum post-LOCA sump volumes and conservatively assumed maximum and minimum source boron concentrations.

With the excepton of systems in operation, the ECCS pumps are normally in a standby, nonoperating mode. As such, flow path piping has the potential to develop voids and pockets of entrained gases. Maintaining the piping from the ECCS pumps to the RCS fun of water ensures that the system wiu perform property, injecting its full capacity into the RCS upon demand. This will prevent water hammer, pump cavitation, and pumping noncondensible gas (e.g., sir, j

nitrogen, or hydrogen) into the reactor vessel following an SIAS or dunng SDC. The 31 day frequency takes into considershon the gradual nature of gas accumulaton in the ECCS piping and the adequacy of the procedural controls goveming system operation.

I The Surveillance Requirements provided to ensure OPERABILITY of each component ensure that at a minimum, the assumptions used in the safety analyses are met and that subsystem OPERABILITY is maintained. Surveillance Requirements for throttle valve position stops and flow balance testing provide assurance that proper ECCS flows win be maintained in the event of a LOCA. Maintenance of proper flow resistance and pressure drop in the piping system to each injection point is necessary to: (1) prevent total pump flow from exceeding runout conditens when the system is in its minimum resistance configuration, (2) provide the proper flow sput between injecten points in accordance with the assumphons used in the ECCS-LOCA analyses, and (3) provide an acceptable level of total ECCS flow to an injection points equal to or above that assumed in the ECCS-LOCA analyses.

The requirement to venfy the minimum pump discharge pressure on recirculation flow ensures that the pump performance curve has not degraded below that used to show that the pump exceeds the design flow condition assumed in the safety analyse and is consstent with the requirements of ASME Sechon XI.

WATERFORD - UNIT 3 8 3/4 5-2 AMENDMENT NO. 1 0,100,147

(Continued)

Laakage rate angsplance crheria are:

)

a.

OveraN contaanrnent leakage rete acceptance criteria is 11.0 L,. During the first unit startup following each test performed in accordance with this program. the overall t

containment leakage rate acceptance critena are 5 0.60 L for the Type B and Type C tests and 5 0.75 L for Type A tests.

b.

Airlock acceptance criteria are:

1.

OveraN air look leakage rate is s 0.05 L, when tested at a P,.

2.

Leakage rate for each door seal is s 0.005 L when pressurimod to a 10 psig.

I c.

secondary containment typass leakage rate saceptance criterte is s 0.0s W when I

tested at a P,.

d.

Containment purge valves with resilient seals acceptance criterte is a 0.0s ( when tested at a P,.

The provmons et spesincomon 4.0.2 do not apply to the test Woquencies specuted in the Contanwnent Leakage Rate Testing Program.

The provisione et speculcanon 4.0.3 are appucable to the Containment Laekage Rate Teodng Program.

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WATEftPOftO-UMT 3 6 25 A&MM3ENT NO. W.

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I NPF-38-222 ATTACHMENT B PROPOSED MARKED-UP SPECIFICATIONS

lEEE l ADMINISTRATIVE CONTROLS l l 1 SECTION P.gg idLlADIAT10tLEROIECII0lLPROGRAM............................... 6-22 l 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 PROGRM... 6-24 l C ~'3( } g-S ~EE 4,Ilo ConFt Gv RATrod et S K M ANhG era ENT PROGRAM......... ~ l l l l l l WATERFORD UNIT 3 XVIII Amendment No. 68,124

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS - MODES 1. 2. AND 3 LIMITING CONDITION FOR OPERATION 3.5.2 Two independent emergency core cooling system (ECCS) subsystems shall be OPERABLE with each subsystem comprised of: -f v.dm a. One OPERA 8LE high-pressure safety injection pump, One OPERABLE low pressure safety injection pump,f.raik and b. c. An independent OPERA 8LE flow path capable of taking suction from the refueling water storage pool on a safety injection actuation signal and automatically transferring suction to the safety injection system sump on a recirculation actuation signal. APPLICA8ILITY: MODES 1, 2, and 3 4. ACTION ' 4 - lN SER T $. / Wit ne s s noper , re re th a sub ys OPE LE tus w in 7 urs be i le HOT wi th ext 6 urs in S wi nt all ng 6 ur dg ' In the event the ECCS is actuated and injects water into the Reactor , Coolant System, a Special. Report shall be prepared and submitted to the Commission pursuant to Specification S.9.2 within 90 days des-cribing the circumstances of the actuation and the total accumulated actuat. ion cycles to date. The current value of the usage factor for each affected safety injection noule shall be provided in this Special Report whenever its value exceeds 0.70. Nith pressurizer pressure greater than or equal to 1750 psia. With RCS average temperature greater than or equal to 500*F. s WATERFORD - UNIT 3 3/4 5-3 I

j INSERT 1

a. With one ECCS subsystem inoperable due to _one high pressure safety injection train inoperable, restore the inoperable train to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours and reduce pressurizer pressure to less than 1750 psia and RCS average temperature to less than 500 F within the following 6 hours.

b. With one or more ECCS subsystems inoperable due to conditions other than (a) and 100% of ECCS flow equivalent to a single OPERABLE ECCS subsystem available, restore the inoperable subsystem to OPERABLE status within 72 hours or be in at least HOT STANDBY within the next 6 hours and reduce pressurizer pressure to less than 1750 psia and RCS average temperature to less than 500*F within the following 6 hours.

c. With both HPSI trains inoperable due to less than 100% of ECCS flow equivalent to a single OPERABLE ECCS subsystem, restore at least one HPSI train to OPERABLE status within one hour or be in at least HOT STANDBY within the next 6 hours and reduce pressurizer pressure to less than 1750 psia and RCS average temperature to less than 500 F within the following 6 hours.-

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EMERGENCY CORE COOLING SYSTEMS 3/4.5.3 ECCS SUBSYSTEMS - MODES 3 AND 4 i LIMITING ColWITION FOR OPERATION 3.5.3 As a minimum, one ECCS subsystem comprised of the following shall be OPERABLE: in g + vet One OPERABLE high pressure safety injection pump., and a. I b. An 0PERA8tE flow path capable of taking suction from the refueling water storage pool on a safety injection actuation signal and auto-matica11y transferring suction to the safety injection system sump on a recirculation actuation signal. APPLICA81LITY: MODES 3*and4.N ACTION: ) With no ECCS subsystem 0PERA8LE, restore at least one ECCS subeystem a. to OPERABLE status within 1 hour or be in within t next 20 hours. M o r swu ro o wN u.i a hh a f least o n e of t'ab/r rhu flo wn roof.n., fre<%,% opeal cu b. In the event the ECCS is actuated and injects water into the Reactor Coolant System, a Special Report shall be prepared and submitted to 'the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date. The current value of the usage factor for each affected safety injection nozzle shall be provided in this Special Report whenever its value exceeds 0.70. SURVEILLANCE REQUIR9 WITS 4.5.3 -The ECCS subsystem shall be demonstrated OPERABLE per the applicable Surve111anca Requirements of 4.5.2. "With pressurizer pressure less than 1750 psia and the RCS average temperature less than 500*F.

gjith no 0/EttA8t E sk /dow-coolk y M *% in op e v e /*'o n.

'WATERFORD - UNIT 3 3/4 5-8 AMENOMENT NO. 34

= ~ 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) BASES 3/4.5.1 SAFETY INJECTION TANKS The OPERASILITY of each of the Reactor Coolant System (RCS) safety injection tanks ensures that a sufficient volume of borated water will be inusediately forced into the reactor core through each of the cold legs in the event the RCS pressure falls below the pressure of the safety injection tanks. This initial surge of water into the core provides the initial cooling mechanism during large RCS pipe ruptures. The limits on safety injection tank volume, baron concentration, and pressure ensure that the assumptions used for safety injection tank injection in the safety analysis arje met. The safety injection tank power operated isolation valves are considered to be " operating bypasses" in the context of IEEE Std. 279-1971, which requires that bypasses of a protective function be removed automatically whenever permissive conditions are not met. In addition, as these safety injection - tank isolation valves fail to meet single failure criteria, removal of power to the valves is required. The limits for operation with a safety injection tank inoperable for any reason except an isolation valve closed minimizes the time exposure of the plant to a LOCA event occuring concurrent with failure of an additional safety injection tank which any result in unacceptable peak cladding temperatures. If a closed isolation valvt cannot be immediately opened, the full capabi*ity of one safety injection tank is not available and prompt action is required to place the reacter in a sede where this capability is not required. i 3/4 5.2 and 3/4.5.3 ECCS SUBSYSTEMS l The OPERASILITY of two separate and independent ECC5 subsystems ensures that sufficient emergency care cooling capability will be available in the event of a LEA assassing the loss of one subsystem through any single failure consideratles. Either subsystem operating in conjunction with the safety injecties tehs is capable of supplying sufficient core cooling to limit the peak clad (fag temperatures within acceptable limits for all postulated break sizes ranging'frem the double-ended break of the largest RCS cold leg pipe downward. In addition, each ECCS subsystem provides long-tern core cooling period. capability in the recirculation mode during the accident recovery &/MSEWA When in mode 3 and with RCS temperature 5008F two OPERABLE ECCS subsys-tems are required to ensure sufficient emergency core cooling capability is'available to prevent the core from becoming critical during an uncontrolled cooldown (i.e., a steam line break) from greater than 5000F. S WATERFORO - UNIT 3 8 3/4 5-1 Amendment No. 34

l INSERT 2 Each subsystem includes the piping, instruments, and controls to ensure the . availability of an OPERABLE flowpath capable of taking suction from the RWSP on a SlAS and automatically transferring suction to the containment sump upon a recirculation actuation signal (RAS). The flowpath for each subsystem must maintain its design independence to ensure that no single failure can disable both ECCS subsystems. An ECCS subsystem is inoperable if it is not capable of delivering the design flow to the RCS. The individual components are inoperable if they are not capable of performing their automatic design function, or if supporting systems are not available. The LCO requires the OPERABILITY of a number of independent trains. Due to the redundancy of trains and the diversity of trains, the inoperability of one component l . in a train does not render the ECCS incapable of performing its function. Neither does L the inoperability of two different components, each in a different train, necessarily result in a loss of function for the ECCS. The intent of these ACTIONS is to maintain a combination of OPERABLE equipment such that 100% of the ECCS flow equivalent to a single OPERABLE subsystem remains available. 100% of the ECCS flow equivalent to a single OPERABLE ECCS subsystem { exists when the equivalent of one HPSI train, one LPSI train, and a suction flow path as described in the LCO are OPERABLE. The OPERABLE components may be in l opposite subsystems. The HPSI component of the 100% ECCS flow equivalent may be composed of any combination of OPERABLE HPSI components such that flow is l-available to all four RCS loops. The LPSI component of the 100% ECCS flow l equivalent may be composed of any combination of OPERABLE LPSI components l such that flow is available to any two RCS loops. This allows increased flexibility in plant operations when components in opposite subsystems are inoperable. 3.5.2, ACTION (a) addresses the specific condition where the only affected ECCS subsystem is a single HPSI train. A HPSI train consists of a pump, and four injection flow paths, including motor-operated valves operated by a common AC power source. The availability of at least 100% of the ECCS flow equivalent to a single OPERABLE ECCS subsystem is implicit in the use of ACTION (a). j If LCO 3.5.2 requirements are not met due to the condition described in ACTION l L (a), then the inoperable HPSI train components must be returned to OPERABLE status within seven (7) days of discovery. This seven (7) day Allowed Outage Time is based i on the findings of deterministic and probabilistic analysis, CE NPSD-1041, "CEOG Joint i Applications Report for High Pressure Safety injection System Technical Specification

1 1 Modifications,". Seven (7) days is a reasonable amount of time to perform many corrective and preventative maintenance items on the affected HPSI train. CE NPSD-1041 concluded that the overall risk impact of the seven (7) day Allowed Outage Time was either risk-beneficial or risk-neutral. j A Configuration Risk Management Program (CRMP) defined in Administrative Controls section 6.16 is implemented in the event of entry into ACTION (a). ACTION (b) addresses other scenarios where the availability of at least 100% of the ECCS flow equivalent to a single OPERABLE ECCS subsystem exists but the full requirements of LCO 3.5.2 are not met. If conditions of ACTION (b) were to exist, then inoperable components must be restored within 72 hours of discovery. The 72 hour Allowed Outage Time is based on an NRC reliability study ( NRC Memorandum to V. Stello, Jr., from R.L. Baer, " Recommended Interim Revisions to LCOs for ECCS Components," December 1,1975 ) and is a reasonable amount of time to effect many repairs. ACTION (c) addresses the condition in which 100% ECCS flow is unavailable due to two inoperable HPSI trains and requires restoration of at least one HPSI train to OPERABLE status within one hour or the plant placed in HOT STANDBY in 6 hours and reduce pressurizer pressure to less than 1750 psia and RCS average temperature to less than 500'F within the following 6 hours. In the event less than 100% of the ECCS flow equivalent to a single OPERABLE ECCS subsystem exists due to other conditions, LCO 3.0.3 is entered and the plant must be brought to a MODE (MODE 3 with pressurizer pressure less than 1750 psia and RCS average temperature less than 500 F) in which the LCO does not apply. I 4 ) 1 l s I 5

I EMERGENCY CORE COOLING SYSTEMS BASES ECCS SUBSYSTEMS fContinued) g,7 ad f/e NSre""e leds ##F' With the RCS temperature belowp509, one OPERABLE ECCS subsystem is acceptable without single failure considershon on the basis of the stable machvity condition of the reactor and the limited core cooling requirements, jgg g The trisodium phosphate dodecahydrate (TSP) stored in dissolving baskets located in the containment basement is provided to minimize the possibility of cormelon cracking of certain metal components during operation of the ECCS followmg a LOCA. The TSP provides this piet.ction by dissolving in the sump water and causing its final pH to be raised to greater than or equal to 7.0. The requirement to dissolve a representative sample of TSP in a sample of water borated to be representative of post-LOCA sump conditions provides assurance that the stored TSP will dissolve in borated water at the postulated post-LOCA temperatures. A boron concentration of 3011 ppm boron is postulated to be representative of the highest post-LOCA I sump boron concentration. Post-LOCA sump pH will remain between 7.0 and 8.1 for the I maximum (3011 ppm) and minimum (1504 ppm) boron concentrabons calculated using the maximum and minimum post-LOCA sump volumes and conservahvely assumed maximum and minimum source boron concentrations. With the exception of systems in operation, the ECCS pumps are normally in a standby, nonoperstmg mode. As such, flow path piping has the potential to develop voids and pockets of entrained gases. Maintaining the piping fmm the ECCS pumps to the RCS full of water ensures that the system will perform property, injecting its full capacity into the RCS upon demand. This will prevent water hammer, pump cavitation, and pumping noncondensible gas (e.g., sir, nitrogen, or hydrogen) into the reactor vessel following an SIAS or during SDC. The 31 day frequency takes into considershon the gradual nature of gas accumulation in the ECCS piping and the adequacy of the procedural controls goveming system operation The Surveillance Requirements provided to ensure OPERABILITY of each component ensure that at a minimum, the assumptions used in the safety analyses are met and that subsystem OPERABILITY is maintained. Surveillance Requirements for throttle valve position stops and flow balance testing provide assurance that proper ECCS flows will be maintained in the event of a LOCA. Maintenance of proper flow resistance and pressure drop in the piping system to each injection point is necessary to: (1) prevent total pump flow from exceeding runout condibons when the system is in its minimum resistance configuration, (2) provide the proper flow split between mjechon points in accordance with the assumphons used in the ECCS-LOCA analyses, and (3) provide an acceptable level of total ECCS flow to all injechon points equal to or above that assumed in the ECCS-LOCA analyses. The requrement to verify the minimum pump discharge pressure on recirculation flow ensures that the pump performance curve has not degraded below that used to show that the pump exceeds the design flow condition assumed in the safety analysis and is consistent with the requirements of ASME Section XI. WATERFORD - UNIT 3 B 3/4 5-2 AMENDMENT NO. 1 0,130,147

l lNSERT 3 l l For cases in LCO 3.5.3 where only inoperable HPSI train components result in all ECCS subsystems being inoperable, CE NPSD-1041 demonstrates that " HOT SHUTDOWN with at least one OPERABLE shutdown cooling train in operation" is an ) acceptable end state. (COLD SHUTDOWN is also an acceptable end state for this l condition.) Consequently, the Required Action specifies a maximum completion time of 20 hours from the discovery ttat the LCO requirements are not met to the time of entry l i to " HOT SHUTDOWN with at.'ast one OPERABLE shutdown cooling train in operation." l i l I l l

~ (Continued) Leakage rate aggeplance critena are: a. Overall containment leakage rate acceptance criteria is 11.0 L,. During the first unit startup following each test performed in accordance with this program, the overall containment leakage rate acceptance critena are 5 0.60 L for the Type 8 and Type C tests and 5 0.75 L for Type A tests. b. Airlock acceptance criteria are: 1. Overall air lock leakage rate is 5 0.05 L when tested at 1 P.. 4 2. Leakage rate for each door seal is s 0.005 ( when pressurtred to 110 psig. I c. Secondary containment bypass leakage rule acceptance artierta is 10.06 L when i tested at 3 P.. d. Contamment purge valves with resilient seats acceptance criteria is 5 0.06 L, when tested at 1 P,. The preisions of Speci6 cation 4.0.2 do not app 6y to the test frequencies specined in the Containment Leakage Rate Testmg Program. The p.'i-w of SpeciScation 4.0.3 are appucatne to the Containment Leakage Rate Testing Prqpam. INSERT 4 I F -w WATWIPORD = UD#T 3 6 25 N2 M 138

INSERT 4 6.16 Configuration Risk Management Program (CRMP) 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 Allowed Outage Time has been granted. The program shallinclude the following elements: Provisions for the control and implementation of a Level 1 at power, a. 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 performirg 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 quantitatively. ux

1 l l l l i 1 NPF-38-222 ATTACHMENT C l PROPOSED SPECIFICATIONS 1 l 1 l i 4 i i

INDEX ADMINISTRATIVE CONTROLS SECTION PAGE 611 RADIATION PROTECTION PROGRAM.................................. 6-22 6.12 H I G H RADI A%;)A EEA........................................................ 6-22 { ) 6.13 PROCESS CONTROL PROGRAM........................................ G-25 l ) 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 WATERFORD-UNIT 3 XVill AMENDMENT NO. 68-+24

EMERGENCY CORE COOLING SYSTEMS i 3/4.5.2 ECCS SUBSYSTEMS - MODES 1. 2. AND 3 LIMITING COND'ITION FOR OPERATION 3.5.2 Two indepen@nt emergency core cooling system (ECCS) subsystems shall be OPERABLE with each subsystem comprised of: a. One OPERABLE high-pressure safety injection train, I b. One OPERABLE low-pressure safety injection train, and I c. An independent OPERABLE flow path capable of taking suction from the refueling water storage pool on a safety injection actuation signal and. automatically transferring suction to the safety injection system sump on a recirculation actuation signal. APPLICABILITY: MODES 1,2, and 3'#. ACTION-a. With one ECCS subsystem !noperable due to one high pressure safety injection train inoperable, restore the inoperable train to OPERABLE status within 7 days. or be in at least HOT STANDBY within the next 6 hours and reduce pressurizer i . pressure to less than 1750 psia and RCS average temperature to ness than I 500*F within the following 6 hours. b. With one or more ECCS subsystems inoperable due to conditions other than (a) and 100% of ECCS flow equivalent to a single OPERABLE ECCS subsystem available, restore the inoperable subsystem to OPERABLE status within 72 hours or be in at least HOT STANDBY within the next 6 hours and reduce pressurizer pressure to less than 1750 psia and RCS average temperature to less than 500*F within the following 6 hours.

With pressurizer pressure greater than or equal to 1750 psia.

With RCS average temperature greater than or equal to 500*F.

WATERFORD - UNIT 3 3/4 5-3 AMENDMENT NO. m.

1 EMERGENCY CORE CO.QLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS - MODES 1. 2JQ_3 LIMITING CONDITION FOR OPERATION c. With both HPSI trains inoperable due to less than 100% of ECCS flow equivalent to a single OPERABLE ECCS subsystem, restore at least one HPSI train to OPERABLE status within one hour be in at least HOT STANDBY within the next 6 hours and reduce pressurizer pressure to lest. than 1750 psia and RCS average temperature to less than 500*F within the following 6 hours. ] d. In the event the ECCS is actuated and injects water into the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date. The current value i of the asage fa::or for each affected safety injection nozzle shall be provided in this Special Re. ; t whenever its value exceeds 0.70. 7/ATERFORD - UNIT 3 3/4 5-3a AkENDMENT NO. 1

EMERGENCY CORE COOLING SYSTEMS 3/4.5.3 ECCS SUBSYSTEMS - MODES 3 AND 4 LIMITING CONDITION FOR OPERATION ' 3.5.3 As a minimum, one ECCS subsystem comprised of the following shall be OPERABLE: a. One OPERABLE high pressure safety injection train, and l - b. An OPERABLE flow path capable of taking suction from the refueling water storage pool on a safety injection actuation signal and automatically transferring suction to the safety injection system sump on a recirculation actuation signal. APPLICABILITY: MODES 3* and 4#. l ACTION a. With no ECCS subsystem OPERABLE, restore at least cne ECCS subsystem to OPERABLE status within 1 hour or be in HOT SHUTDOWN with at least one operable shutdown cooling train in operation within the next 20 hours. b. In the event the ECCS is actuated and injects water into the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the

actuation and the total accumulated actuation cycles to date. The current value of the usage factor for each affected safety injection nozzle shall be provided in this Special Report whenever its value exceeds 0.70.

- SURVEILLANCE REQUIREMENTS '4.5.3 The ECCS subsystem shall be demonstrated OPERABLE per the applicable Surveillance Requirements of 4.5.2.

*With pressurizer pressure less than 1750 psia and the RCS average temperature

' less than 500*F.

With no OPERABLE shutdown cooling train in operation.

l WATERFORD - UNIT 3 3/4 5-8 AMENDMENT NO.64 I i:.

e i 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) i BASES 3/4.5.1 SAFETY INJECTION TANKS l ' The OPERABILITY of each of the Reactor Coolant System'(RCS) safety injection tanks ensures that a sufficient volume of borated water will be immediately forced into the reactor core through each of the cold legs in the event the RCS pressure falls below the pressure of the

safety injection tanks. This initial surge of water into the core provides the initial cooling

' mechanism during large RCS pipe ruptures. The limits on safety injection tank volume, boron concentration, and pressure ensure that the assumptions used for safety injection tank injection in the safety analysis are met. ' The safety injection tank power operated isolation valves are considered to be " operating bypasses" in the context of IEEE Std. 279-1971, which requires that bypasses of a protective function be removed automatically whenever permissive conditions are not met. In addition, as these safety injection tank isolation valves fail to meet single failure criteria, removal of power to the valves is required.- The limits for operation with a safety injection tank inoperable for any reason except an isolation valve closed minimizes the time exposure of the plant to a LOCA event occurring . concurrent with' failure of an additional safety injection tank which may result in unacceptable peak cladding temperatures. - If a closed isolation ~ valve cannot be immediately opened, the full capability of one safety injection tank is not available and prompt action is required to place the reactor in a mode where th;s capability is not required. 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS The OPERABILITY of two separate and independent ECCS subsystems ensures that sufficient emergency core cooling capability will be available in the event of a LOCA assuming the loss of one subsystem through any single failure consideration. Either subsystem operating in conjunction with the safety injection tanks is capable of supplying sufficient core cooling to limit the peak cladding temperatures within acceptable limits for all postulated break sizes ranging from the double-ended break of the largest RCS cold leg pipe downward. In addition, each ECCS subsystem provides long-term core cooling capability in the recirculation mode during the accident recovery period. i Each subsystem includes the piping, instruments, and controls to ensure the availability of an OPERABLE flowpath capable of taking suction from the RWSP on a SIAS and automatically transferring suction to the containment sump upon a recirculation actuation signal (RAS). The flowpath for each subsystem must maintain its design indspendence to ensure that no single failure can disable both ECCS subsystems. ' WATERFORD - UNIT 3 B 3/4 5-1 AMENDMENT NO. 34

3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) BASES 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS / Continued) An ECCS subsystem is inoperable if it is not capable of delivering the design flow to the RCS The individual components are inoperable if they are not capable of perfomling their automatic design function, or if supporting systems are not available. The LCO requires the OPERABILITY of a number of independent trains. Due to the redendancy of trains and the diversity of trains, 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 these ACTIONS is to maintain a combination of OPERABLE equipment such that.100% of the ECCS flow equivalent to a single OPERABLE subsystem remains available. 100% of the ECCS flow equivalent to a single OPERABLE ECCS subsystem exists when the equivalent of one HPSI train, one LPSI train, and a suction flow path as described in the LCO are OPERABLE. The OPERABLE components may be in opposite subsystems. The HPSI component of the 100% ECCS flow equivalent may be composed of any combination of OPERABLE HPSI components such that flow is available to all four RCS loops. The LPSI component of the 100% ECCS flow equivalent may be composed of any combration of OPERABLE LPSI components such that flow is available to any two RCS loop: This allows increased flexibility in plant operations when components in opposite subsystem 6 s.O . Inoperable. 3.5.2, ACTION (a) addresses the specific condition where the only affected ECCS . subsystem is a single HPSI train. A HPSI train consists of a pump, and four injection flow paths, including motor-operated valves operated by a common AC power source. The availability of at least 100% of the ECCS flow equivalent to a single OPERABLE ECCS subsystem is implicit in the use of ACTION (a). If LCO 3.5.2 requirements are not met due to the condition described in ACTION (a), then the inoperable HPSI 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-1041, "CEOG Joint Applications Report for High Pressure Safety injection System Technical Specification Modifications." Seven (7) days is a reasonable amount of time to perform many corrective and preventative maintenance items on the affected HPSI train. CE NPSD-1041 concluded that the overall risk impact of the seven (7) day Allowed Outage Time was skher risk-beneficial or risk-neutral. WATERFORD - UNIT 3 B 3/4 5-2 AMENDMENT NO. o

ms

3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

' BASES 3/4.5.2 AND 3/4.5.3 ECCS SUBSYSTEMS (Continued) A Configuration Risk Management Program'(CRMP) defined in Administrative Controls section 6.16 is implemented in the event of entry into ACTION (a). ACTION (b) addresses other scenarios where the availability of at least 100% of the ECCS flow equivalent to a single OPERABLE ECCS subsystem exists but the full requirements of LCO 3.5.2 are not met. If conditions of ACTION (b) were to exist, then inoperable components must be restored within 72 hours of discovery. The 72 hour Allowed Outage Time is based on an NRC reliability study ( NRC Memorandum to V. Stello, Jr., from R.L. Baer, "F.ccommended Interim Revisions to LCOs for ECCS Components," December 1,1975 ) and is a reasonable amount of time to effect many repairs. ACTION (c) addresses the condition in which 100% ECCS flow is unavailable due to two inoperable HPSI trains and requires restoration of at least one HPSI train to OPERABLE status within one hour or the plant placed in HOT STANDBY in 6 hours and reduce pressurizer pressure to less than 1750 psia and RCS average temperature to less than 500*F within the following 6 hours, in the event less than 100% of the ECCS flow equivalent to a single OPERABLE ECCS subsystem exists due to other conditions, LCO 3.0.3 is entered and the plant must be brougr t to a MODE (MODE 3 with pressurizer pressure less than 1750 psia and RCS average temperature ' less than 500*F) in which the LCO does not apply. When in MODE 3 and with RCS temperature greater thar. or equal to 500*F two OPERABLE ECCS subsystems are required to ensure sufficient emergency core cooling capability is available to prevent the core from becoming critical during an uncontrolled cooldown (i.e., a steam line break) from greater than or equal to 500*F. With the RCS temperature below 500*F and the RCS pressure below 1750 psia, one OPERABLE ECCS subsystem'is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the limited core cooling reauirements. For cases in LCO 3.5.3 where only inoperable HPSI train components result in all ECCS subsystems being inoperable, CE NPSD-1041 demonstrates that " HOT SHUTDOWN with at least one OPERABLE shutdown cooling train in operation" is an acceptable end state. (COLD SHUTDOWN is also an acceptable end state for this condition.) Cr. oquently, the Required Action specifies a maximum completion time of 20 hours from the discovery that the LCO requirements are not met to the time of entry to " HOT SHUTDOWN with at least one OPERABLE shutdown cooling train in operation." WATERFORD - UNIT 3 8 3/4 5-3 AMENDMENT NO.

EMERGENCY CORE COOLING SYSTEMS BASES ~ ~ 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS (Continued) ' The trisodium phosphate dodecahydrate (TSP) stored in dissolving baskets located in the containment basement is provided to minimize the possibility of corrosion cracking of certain metal components during operation of the ECCS following a LOCA. The TSP provides this j protection by dissolving in the sump water and causing its final pH to be raised to greater than or ) equal to 7.0. The requirement to dissolve a representative sample of TSP in a sample of water borated to be representative of post-LOCA sump conditions provides assurance that the stored TSP will dissolve in borated water at the postulated post-LOCA temperatures. A boron concentration of 3011 ppm boron is postulated to be representative of the highest post-LOCA sump boron concentration. Post LOCA sump pH will remain between 7.0 and 8.1 for the maximum (3011 ppm) ard minimum (1504 ppm) boron concentrations calculated using the' maximum and minimum pcm.OCA sump volumes and conservatively assumed maximum and minimum source boron concentrations. . With the exception of systems in operation, the ECCS pumps are normally in a standby, nonoperating mode. As such, flow path piping has the potential to develop voids and pockets of entrained gases. Maintaining the piping from the ECCS pumps to the RCS full of water ensures that the system will perform properly, injecting its full capacity into the RCS upon demand. This will prevent water hammer, pump cavitation, and pumping noncondensible gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel following an SIAS or during SDC. The 31 day frequency takes into consideration the gradual nature of gas accumulation in the ECCS piping and the adequacy of the procedural controls governing system operation. The Surveillance Requirements provided to ensure OPERABILITY of each component ensure that at a minimum, the assumptions used in the safety analyses are met and that subsystem OPERABILITY is maintained. Surveillance Requirements for throttle valve position stops and flow balance testing provide assurance that proper ECCS flows will be maintained in the event of a LOCA. Maintenance of proper flow resistance and pressure drop in the piping system to each injection point is necessary to: (1) prevent total pump flow from exceeding runout conditions when the system is in its minimum resistance configuration, (2) provide the proper flow split between injection points in accordance with the assumptions used in the ECCS-LOCA analyses, and (3) provide an acceptable level of total ECCS flow to all injection points j equal to or above that assumed in the ECCS-LOCA analyses. I The requirement to verify the minimum pump discharge pressure on recirculation flow ensures that the pump perfc.mance curve has not degraded below that used to show that the pump exceeds the design flow condition assumed in the safety analysis and is consistent with the requirements of ASME Section XI. i WATERFORD - UNIT 3 B 3/4 5-4 AMENDMENT NO. 127,100,147

EMERGENCY CORE COOLING SYSTEMS BASES l 3/4.5.4 REFUELING WATER STORAGE POOL (RWSP) I The OPERABILITY of the refueling water storage pool (RWSP) as part of the ECCS also ensures that a sufficient supply of borated water is available for injection by the ECCS in the event of a LOCA.' The limits on RWSP minimum volume and boron concentration ensure that (1) sufficient water is available within containment to permit recirculation cooling flow to the core, and (2) the reactor will remain subcritical in the cold condition following mixing of the RWSP and the RCS water volumes with all CEAs inserted except for the most reactive control assembly. These assumptions are consistent with the LOCA analyses. The contained water volume limit includes an allowance for water not usable because of pool discharge line location or other physical characteristics. The lower limit on contained water volume, the specific boron concentration and the physical size (approximately 600,000 gallons) of the RWSP also ensure a pH value of between 7.0 and 11.0 for the solution recirculated within containment after a LOCA. This pH band ) minimizes the evolution ofiodine and minimizes the effect of chloride and caustic stress i corrosion on mechanica? systems and components. T he' maximum limit on the RWSP temperature ensures that the assumptions used in the containment pressure analysis under design base accident conditions remain valid and avoids the possibility of containment overpressure. The minimum limit on the RWSP temperature is required to prevent freezing and/or boron precipitation in the RWSP. i l . WATERFORD - UNIT 3 B 3/4 5-5 AMENDMENT NO.427;-130

l ADMINISTRATIVE CONTROLS I CONTAINMENT LEAKAGE RATE TESTING PROGRAM (Continued) Leakage rate acceptance criteria are: Overall containment leakage rate acceptance criteria is s 1.01., During the first a. unit startup following each test performed in accordance with this program, the overall containment leakage rate acceptance criteria are s 0.60 ( for the Type B and Type C tests and s 0.75 t, for Type A tests. b. Air lock acceptance criteria are: 1. Overall air lock leakage rate is s 0.05 L, when tested at 2 P,. 2. Leakage rate for each door seal is 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 seals acceptance criteria is s 0.06 L, when tested at 2 P. The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. 3 The p~, visions of Specification 4.0.3 are app!! cable to the Containment Leakage Rate Testing Program. i 6.16 CONFIGURATION RISK MANAGEMENT PROGRAM (CRMP) l The Configuration Risk Management Program (CRMP) provides a proceduralized risk-informed assessment to manage th s risk associated with equipment inoperability. The program applies to Technical Specification structures, systems, or components for which a risk-informed Allowed Outage Time has been granted. The program shallinclude the following elements: 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. WATERFORD - UNIT 3 6-25 AMENDMENT NO. +24-438 i

1 ADMINISTRATIVE CONTROLS CONFIGURATION RISK MANAGEMENT PROGRAM (CRMP)(Continued) J 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 equiprnent out of service conditions while in the LCO Condition. i e. Provisions for coroidering other applicable risk significant contributors such as Level 2 issues, and external events, qualitatively or quantitatively. WATERFORD - UNIT 3 6-26 AMENDMENT NO. <-}}

ML20210M986

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