ML20217G242

Proposed Tech Specs Modifying 3.3.3.7.3 & Surveillance Requirement 4.3.3.7.3 for Broad Range Gas Detection Sys

ML20217G242
Person / Time
Site:	Waterford
Issue date:	10/07/1997
From:	ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20217G239	List: ML20217G235 ML20217G242
References
NUDOCS 9710090271
Download: ML20217G242 (15)

Text

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NPF-38-203 ATTACHMENT A 9710090271 971007 PDR ADOCK 05000302 P

PDR

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.BSTRUMENTATION CHEMICAL DETECTION _ SYSTEMS 1

B@ @ RANGE GAS DETECTION llMITING CONDITION FOR OPERATION l

3.3.3.7.3 Two independent broad range gas detection systems shall be OPERABLE ** with their alarm / trip setpoints adjusted to actuate at the lowest achievable Immediately Dangerous to Life or Health gas concentration level of detectable toxic gases

• providing reliable operation.

l APPLICABILITY: All MODES.

ACTION:**

l a.

With one broad range gas detection system inoperable, restore the inoperable detection system to OPERABLE status within 7 days or within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> initiate and maintain operation of the control room ventilation system in the isolate mode of operation.

b.

With no broad range gas detection system OPERABLE, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate and maintain operation of the control room ventilation system in the isolate mode of operation, c.

The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REOUIREMENTS l

l 4.3.3.7.3 Each broad range gas detection system shall be demonstrated OPERABLE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and a CHANNEL FUNCTIONAL TEST at least once per 31 days. The CHANNEL FUNCTIONAL TEST will include the introduction of a standard gas.

• Including Amonia

• • The requirements of Technical Specification 3.0.1 do n>t apply during the time (approximately one minute) when the Instrument automatic background /

reference spectrum check renders the instrument (s) inoperable.

WATERFORD - UNIT 3 3/4 3-48a AMENDMENT NO. Ge H.133 r

INSTRUMENTATION BASES 3/4.3.3.6 AtCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess these variables following an accident.

The availability of accident monitoring instrumentation is important so that responses to corrective actions can be observed and the need for, and magnitude of, further actions can be determined. These essential instruments are identified by plant specific documents addressing the recomendations of Regulatory Guide 1.97, as required by Supplement-1 to NUREG-0737, "TM1 Action Ltems."

Table 3.3.10 includes most of the plant's RG 1.97 Type A and Category 1 variables. The remaining Type A/ Category 1 variables are included in their respective specifications. Type A variables are included in this LC0 because they provide the primary information required to permit the control room operator to take specific manually controlled actions, for which no automatic control is-provided, that are required for safety systems to accomplish their safety functions for Design Basis Accidents (DBAs).

Category 1 variables are the key variables deemed risk significant because they are needed to:

(1) Determine whether-other systems important to-safety are performing their intended functions; (2) Provide information to the operators that will enable them to determine the potential for causing a gross breach of the barriers to radioactivity release; and (3) Provide information regarding the release of radioactive materials to allow for early indication of the need to initiate action necessary to protect the public as well as to obtain an estimate of the magnitude of any impending threat.

With the number of OPERABLE accident monitoring channels less than the Required Nu.: hor of Channels shown in Table 3.3-10, the inoperable channel should be restored to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channel (or in the case of a Function that has only one required channel, other non-Regulatory Guide 1.g7 instrument channels to monitor the Function), the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring accident monitoring instrumentation during this interval.

If the 30 day A0T is not= met, a Special Report approved by PORC is required to be submitted to the NRC within the following 14 days. This report discusses the results of the root cause evaluation of the inoperability and identifies proposed restorative Actions. This Action is appropriate in lieu of a shutdown requirement, given the likelihood of plant conditions that would require infomation provided by this instrumentation. Also, alternative Actions are identified before a loss of functional capability condition occurs.

With the number of OPERABLE accident monitoring channels less than the Minimum Channels OPERABLE requirements of Table 3.3-10; at least one of the inoperable channels should be restored to OPERABLE status within 7 days. The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrumentation operation and the availability of alternate ireans to obtain the required information.

Contiruous operation with less than the Minimum Channels OPERABLE requirements is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the accident WATERFORD - UNIT 3 B 3/4 3-3 Amendment No. It,20,00,122,133

INSTRUMENTATION BASES monitoring instrumen*' tion. Therefore, requiring restoration of one inoperable channel limits the risk that the variable will be in a degraded condition should an accident occur.

If the 7 day requirement is not met, the l

plant must be brounht to a MODE in which the LC0 does not apply. To achieve The completion time is reasonable, ght to at least MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

this status, the plant must be brou based on operating experience, to reach the required slant conditions from full power conditions in an orderly manner and without cialienging plant systems.

l TS 3/4.3.3.6 applies to the following instrumentation:

ESFIP16750 A, ESFIPR6750 B. ESFIPR6755 A&B, RC IT10122 HA, RC 1T10112 HB, RC IT10122 CA, RC 1T10112 CB, RC IP10102 A.B.C,&D, RC IL10110 X&Y, SG ILilll3 A.B.C,&D, SG ILill23 A,B,C,&D, SG lLllll5 A2&B2, SG IL11125 A2&B2, 51 Il!7145 A, 51 ILR7145 B, all CET's, all Category 1 Containment Isolation Valve Position Indicators. EFWILI9013 A&B, HJTC's, and ENIIJ10001 C&D.

3/4.3.3.7 CHEMICAL DETECTION SYSTEMS The chemical detection systems are the chlorine and broad range toxic gas detection systems.

The OPERABILITY of the chemical detection systems ensures that sufficient capability is available to promptly detect and initiate protective action in the event of an accidental chemical release.

The chemical detection syste.as provide prompt detection of toxic gas re-leases which could pose an actual threat to safety of the nuclear power plant or significantly hamper site personnel in performance of duties necessary for the safe operation of the plant.

The broad range toxic gas detection system utilizes a Fourier Transform Infrared (FTIR) analysis technique, and therefore, the system is sensitive to a broad range of gases *. The system is sensitive to nomal fluctuations of both atmospheric and chemical composition which affect the Waterford 3 site.

The setpoints associated with the system are based on testing and operating experience. Set-points are set as to prevent Immediately Dangerous to Life or Health (IDLH) gas concentration in the control room while providing reliable operation and the o>timum detection of texic gases. The setpoint is therefore subject to change w)erein necessitateo t,y operating experience such as a result of changes in the Waterford 3 area chemical atmospheric profile. The setpoint is established and controlled by procedure.

The LC0 and ACTIONS for the broad range gas detection system are annotated such that the system instrument automatic background / reference spectrum check does not constitute system inoperability tf both channels are -

• Including Amononia WATERFORD - UNIT 3 B 3/4 3-3a Amendment No. 14,20,50, 00,122,133

1 I

operable and both channels are not erforming the check situitaneousi.

The instrument automatically performs t is check. During the time that t e I

automatic background / reference spectrum check is taking place (which will be less than one minute), the channel will not perform the function of isolation of the control room. With both channels OPERABLE, the other system will be i

available to perform the control room isolation function in the event of a maintenance), when the second channel performs the automatic (e.g., for toxic gas incident. With one channel taken out of service i

background check, i

both channels will be unable to perform the function of isolating the control 4

)

room for the short time of the background check. Analysis has shown that the 1

impact on operator incapacitation and subsequent core damage risk of the background checks while one monitor is out of service for ' ts 7 day allowed outage time is negligible. Therefore, entry into the ACTION solely due to the i

automatic check is not required.

No specific manual CHANNEL CALIBRATION ts required as the system instrument performs this function as the background / reference spectrum check automatically for approximately one minute on a frequency of once every hour l

to once every four hours. The exact frequency is established based on operating experience with tht instrument.

I The performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ensures that a gross failure of the instrument has not occurred.

The CHANNEL CHECK consists l

of a comparison of the display of the standard gas (utilized in the FUNCTIONAL

, 002 and water.

Significant deviations from the expected readings and TEST)l readings could be an indication of a malfunction within the unit.

The actua CHANNEL CHECK will detect gross system failure; thus, it is the key to verifying the instrument continues to operate properly between each CHANNEL FUNCTIONAL TEST.

A CHANNEL FUNCTIONAL TEST is performed to ensure the entire channel will perform its required function.

This test includes introduction of a standard gas and verification of isolation of the control room. The time of the occurrence of the background / reference saectrum check is set during the CHANNEL FUNCTIONAL TEST such that both ciannels are not out of service simultaneously.

3/4.3.3.8 This section deleted 3/4.3.3.9 This section deleted WATERFORD - UNIT 3 B 3/4 3-3b Amendment No. 14,20,50,101,133

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NPF-38-203 ATTACHMENT B

Ild.TRUMENTNil0N QiEMICAL DETECTION SYSTEMS

^

BROAD RANGE GAS DETECTION LIMITING CONDITION FOR OPERATION 3.3.3.7.3 Two independent broad range gas detection systems shall be OPERABLE #withtheiralarm/tripsetpointsadjustedtoactuateatthelowest achievable -Imed44taly-0:n;;ren-444f: Or "estth as concentration level of detectable toxic gases

• providing reliable operati n.

IDL M APPLICABIllTY: All MODES.

ACTION:#

l a.

With one broad range gas detection system inoperable, restore the inoperable detection system to OPERABLE status withir, 7 days or wit 11n the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> initiate and maintain operation of the control room ventilation system in the isolate mode of operation, b.

With no broad range gas detection system OPERABLE, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate and maintain operation of the control room ventilation system in the isolate mode of operation.

c.

The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE RE0VIREMENTS 4.3.3.7.3 Each broad range gas detection system shall be demonstrated OPERABLE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> end a CHANNEL 4

FUNCTIONAL TEST at least once per 31 days / -The C"""$L PA.!0"*1 TEST wi14-kel;& the intr:S:ti= cf : :t=hrd ;=f, ed a e han a,I c //4 ea W gi lees + ne w pre 7 dep s. - Cal h J :o u w.*// e n ro's / e f H e kn+<ohe/.% of < s}n-e/e<d 9es n d ndpsluy f-A c *%s/raue*/

ten r *WViI) 6sse /o8 +he ce filess *% y A s velal*%.c A;) e 4 H e s k dn v ol y e s k + s. e ce /* L ~J.Hy y sr.

• Including Ammonia 7,e requir;;; ate of Techni =1 O ri'i n ti = 3.0.1 6 ::t w ;1y t ria; th:-

ti;; (:pprai;;t:1y =: minut:)

na th: !a:tr;;=t =t=; tic b;ckgr;und/ -

reference :petr= ch=h r=tr: th: in:tracat(s) inepe,; bis.

WATERFORD - UNIT 3 3/4 3-48a AMENDMENT NO. Ber&3.BB-

m INSTRUMENTATION

)

BASES

\\

3/4.3.3.6 ACCIDENT MONITORING INSTRUMENTATION

)

The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and asssss these variables following an accident.

The availability of 1

accident monitoring instrumentation is important so that responses to corrective actions can be observed and the need for, and magnitude of, further actions can be determined. These essential instruments are identified by plant specific documents addressing the recommendations of Regulatory Guide 1.97, as required by Supplement I to NUREG-0737, "THI Action items."

Table 3.3.10 includes most of the plant's RG 1.97 Type A and Category 1 variables.

The remaining Type A/ Category 1 variables are included in their i

respective specifications. Type A variables are included in this LCO because they provide the primary ir. formation required to permit the control room 4

operator to take specific manually controlled actions, for which no automatic control is provided, that are required for safety systems to accomplish their safety functions for Design Basis Accidents (DBAs).

Category 1 variables are the key variables deemed risk significant because they are needed to:

(1) Determine whether other systems important to safety are performing their intended functions; (2) Provide information to the operators that will enable them to determine the potential for causing a gross breach of the barriers to radioactivity release; and (3) Provide information regarding the release of radioactive materials to allow for early indication of the need to initiate action necessary to protect the public as well as to obtain an estimate of the 3

magnitude of any impending threat.

With the number of OPERABLE accident monitoring channels less than the Required Number of Channels shown in Table 3.3-10, the inoperable channel hould be restored to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channel (or in the case of a Function that has only one required channel, other non-Regulatory Guide 1.97 instrument channels to monitor the Function), the passive nature of the instrument (no critical automatic action i

is assumed to occur from these instruments), and the low probability of an event requiring accident monitoring instrumentation during this interval.

if the 30 day A0T is not met, a Special Report approved by PORC is required to be submitted to the NRC within the following 14 days.

This report discusses the results of the root cause evaluation of the inoperability and identifies propeed restorative Actions. This Action is appropriate in lieu of-a shutdown iequirement, given the likelihood of plant conditions that would require information provided by this instrumentation. Also, alternative Actions are identified before a loss of functional capability condition occurs.

With the number of OPERABLE accident monitoring channels less than the Minimum Channels OPERABLE requirements of Table 3.3-10; at least onn of the inoperable channels should be restored to OPERABLE status within 7 da>

The Completion Time of 7 days is based on the relatively low probability oi an event requiring PAM instrumentation operation and the availability of alternate means to obtain the required information.

Continuous operation with less than the Minimum Channels OPERABLE requirements is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the accident WATERFORD - UNIT 3 8 3/4 3-3 Amendment No. 14,20,40,122,133

INSTpuMENTATION BASES j

monitoring instrumentation. Therefore, requiring restoration of one inoperable channel limits th6 risk that the variable will be in a degraded condition should an accident occur.

If the 7 day requirement is not met, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The completion time is reasonable, based on operating experience, to r9ach the required slant conditions from full pewer conditions in an orderly manner and without ciallenging plant systems.

TS 3/4.3.3.6 applies to the following instrumentation:

ESFIPI6750 A, ESFIPR6750 B, ESFIPR6755 A&B, RC IT10122 HA, RC 1T10112 HB, RC 1T10122 CA, RC IT10ll2 CB, RC IP10102 A.B.C,&D, RC IL10110 X&Y, SG !Lilll3 A.B.C,&D, SG ILIll23 A,8,C,&D, SG ILIlll5 A2&B2, SG ILill25 A2&B2, SI ILI7145 A, SI ILR7145 B, all CET's, all Category 1 Containment Isolation Valve Position Indicators, EFWILI9013 A&B, HJTC's, and EN!!J10001 C&D.

3/4.3.3.7 CHEMICAL DETECTION SYSTEMS The chemical detection systems are the chlorine and bread range tcxic qas detection systems.

The OPERABILITY of the chemical detection systems ensures thet sufficient capability is available to promptly detect and initiate protective ection in the event of an accidental chemical release.

The chemical detection systems provide prompt detection of toxic gas re-leases which could pose an actual threat tn safety of the nuclear power plant or significantly hamper site personnel in performance of duties necessary for the safe operation of the plant.

The broad range toxic gas detection system utilizes a Fourier Transf Infra TIR) analysis technique, and therefore, the system is se e to a broad rang ases*, The system is sensitive to normal ations of both atmospheric an ical composition which affee aterford 3 site.

The setpaints associated he system are bi n testing and operating experience.

Set-points are set r

Lamediately Dangerous to Life or Health (IDLH) gas concentration i ol room while providirt reliable operation and the o) Linum on of toxic The setpoint 's therefore subject to change wt necessitated by o>erating lance such as a result of cha n the Waterford 3 area ciemical atmosp refile. The setpoi established and controlled by procedure.

O.; Len and ACTIONS for the broad range cas_da+ etia, system are annotated such that tne. C i= *

,a automatic background / reference-spectrum ek-d L. not constitute system inopn.Lility if hath channels are

~

• Including Amononia WATERFORD - UNIT 3 8 3/4 3-3a Amendment No. 14,20,50,10i,122,133

4 operable and both channels are not performing the check situitaneousi. T s-ument automatically performs this check. Durinti the time that t automa ackground/ reference spectrum check is tak'ng place bh4c will be less than on.

ute), the channel will not perform the funs<tton of isolation I

of the control ro With both channels OPERABLE, the-other system will be available to perform tii N trol room isolationJutiction in the event of a toxic gas incident. With one nel taksa fut of service (e.g., for maintenance), when the second chann rforms the automatic background check, both channels will be unable _to-rform nction of isolating the control room for the short time,0fde background chec.

alysis has shown that the impact on operato e risk of the backgroundJc ecu)r ec'apacitation and subsequent cor i

while one monitor is out of service for day allowed i

j outage tot is negligible. Therefore, entry into the ACTION so ue to the atic check is not required.

%=

manual CHANNEL CALIBRATION is required as the system l

instrument perform on as the background ck l

automatically for a) proximately o.

requency of once every hour to once every fogr.aourrThe exact frequency

@ had based on operatinreXpiRence with the instrument.

~

The erforwance of the CHANNEL CHECK once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ensures th t a gross f the instrument has not occurred.

The CHANNEL nsists i

of a comparison o lay of the standard gas J n the FUNCTIONAL

, CO2 and water.. Sign ati "he expected readings and TEST)l readings could be an ind ion within the unit.

The actua i

• ha key to CHANNEL CHECK will y ss system failure; thus, nstrument continues to operate properly between eaDrtHANNE,L v

j A GHANNEL FUNCTIONAL TEST is performed to ensure the entire chan perform ITr requi Cfunction. This test includes introduct a standard t

j gas and verification of TTol* Mon _ot the pe h v6m. The time of the occurrence of the backfirou,nd/msferen metrum check is set during the CHANNEL FUN (I10NAL-Tfs ~such that both ciannels ar heervice slaultwoously.

3/4.3.3.8 This section deleted 1

3/4.3.3.9 This section deleted

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83/43-3b Amendment No. li,00,50,10t.fiW WATERFORD - UNIT 3 s e f * ~ f is e s /. A/:s heef - u ad ef me s7 4 e-te p r e 4 /e. ^tse

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i NPF 38-203 ATTACHMENT C

)

____,_,._m_.

0

' INSTRUMENTATION CHEMICAL DETECTION SYSTEMS BROAD RANGE GAS DETECTION QMITING CONDITION FO_R_ OPERATION 3.3.3.7.3 Two independent broad range gas detection systems shall be OPERABLE with their alarm / trip setpoints adjusted to actuate at the lowest achievablo IDLH gas concentration level of detectable toxic gases

• providing reliable operation.

APPLICABILITY : All MODES.

ACTION:

l

a. With one broad range gas detection system inoperable, restore the inoperable detection system to OPERABLE status within 7 days or within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> initiate and maintain operation of the control room ventilation system in the isolate mode of operation.

b. With no broad range gas detection system OPERABLE, within i hour initiate and maintain operation of the control room ventilation system in the isolate tr. ode of operation.

c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLAN.CE REQUIREMENTS 4.3.3.7.3 Each broad range gas detection system shall be demonstrated OPERABLE by performance of a CHANNEL CHECK et least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a CHANNEL FUNCTIONAL TEST at least once per 31 days and a channel calibration at least once per 7 days. Calibration will consist of the introduction of a standard gas and adjusting the instrument sensitivity based on the calibration gas relationship of the standard gas to the calibrating gas.

• Including Ammonia l

WATERFORD - UNIT 3 3/4 3-48a AMENDMENT No. 30,53,433

INSTRUMENTATION BASES T

3/4.3.3.6 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring instrumentation ensures ihat sufficient informa1on is available on selected plant parameters to monitor and assess these variables following an accident. The availability of accident monitoring instrumentation is important so that responses to corrective actions can be observed and the need for, and magnitude of, further actions can be determined. These essential instruments are identified by plant specific documents addressing the recommendations of Regulatory Guide 1.97, as required by Supplement 1 to NUREG 0737,"TMI Action Items

• Table 3.310 includes most of tne plant's RG 1.97 Type A and Category i variables.

The reniaining Type A/ Category i variables are included in their respective specifications. Type A j

variables are included in this LCO because they provide the primary information required to permit the l

control room operator to take specific manually controlled actions, for which no automatic control is l

provided, that are required for safety systems to accomplish their safety functions for Design Basis Accidents (DBAs). Category i variables are the key variables deemed risk significant because they are needed to: (1) Determine whether other systems important to safety are performing their intended functions; (2) Provide information to the operators that will enable them to determine the potential for causing a gross breach of the barriers to radioactivity release; and (3) Provide information regarding the release of radioactive materials to allow for early indication of the need to initiate action necessary to protect the public as well as to obtain an estimate of the magnitude of any impending threat.

With the number of OPERABLE accident monitoring channels less than the Required Number of Channels shown in Table 3.310, the inoperable channel should be restored to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channel (or in the case of a Function that has only one required channel, other non-Regulatory Guide 1.97 instrument channels to monitor the Function),

the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring accident monitoring instrumentation during this interval. If the 30 day AOT is not met, a Special Report approved by PORC is required to be submitted to the NRC within the following 14 days. This report discusses the results of the root cause evaluation of the inoperability and identifies proposed restorative Actions. This Action is appropriate in lieu of a shutdown requirement, given the likelihood of plant conditions that would require information provided by this instrumentation. Also, alternative Actions are identified before a loss of functional capability condition occurs.

With the number of OPERABLE accident monitoring channels less than the Minimum Channels 0PERABLE requirements of Table 3.3-10; at least one of the inoperable channels should be restored to GPERABLE status within 7 days, The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrumentation operation and the availability of alternate means to obtain the required information.

Continuous operation with less than the Minimum Channels OPERABLE requirements is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the accident 4

WATERFORD - UNIT 3 8 3/4 3-3 AMENDMENT NO. 44,20,49, m, W

4 0

INSTRUMENTATION BASES monitoring instrumentation. Therefore, requiring restoration of one Inoperable channellimits the risk that the variable will be in a degraded condition should an accident occur if the 7 day requirement is not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The completion time is reasonable, based on operating experience, to reach the required plant conditions from fu power conditions in an orderly n

manner ard without challenging plant systems.

i i

TS 3/4.3.3.6 applies to the following instrumentation: ESFIPl6750 A ESFIPR6750 B. ESFIPR6755 A&B, RC ITl0122 HA, RC ITl0112 HB, RC ITl0122 CA, RC ITl0112 CB, RC IPl0102 A.8,C,&D, RC ILl0110 X&Y, SG llli113 A,B C,&D, SG lll1123 A.B C,&D, SG ILl1115 A2&B2, SG IL11125 A2&B2, Sl ILl7145 A, Sl ILR7145 B, all CET's, all Category 1 Containment Isolation Valve Position Indicators, EFWILl9013 A&B, HJTC's, and ENllJ10001 C&D.

3/4.3 3.7 CHEMICAL DETECTION SYSTEMS The chemical detection systems are the chlorine and broad range toxic gas detection systems.

The OPERABILITY of the chemical detection systems ent' ares that sufficient capability is available to promptly detect and initiate protective action in the event of an accidental chemical release.

The chemical detection systems provide prompt detection of toxic gas releases which could pose an actual threat to safety of the nuclear power plant or significantly hamper site personnelin performance of duties necessary for thu safe operation of the plant.

The broad range toxic gas detection system operates on the principle of gas photoionization, and therefore, the system is sensitive to a broad range of gases', The system is therefore sensitive to both atmospheric and chemical composition norr"al fluctuations affecting the Waterford 3 site. The setpoint for the system is thus based on testing and operating experience, and the setpoint is set at the lowest achievable IDLH gas concentration providing reliable operation and the optimum detecticn of toxic gases.

The setpoint is therefore subject to change wherein necessitated by operating experience such as a result of changes in the Waterford 3 area chemical atmosphenc profile, The setpoint is established and controlled by procedure.

I 3/4 3.3.8 THIS SECTION DELETED 3/4.3.3.9 THIS SECTION DELETED

• Including Ammonia WATERFORD UNIT 3 B 3/4 3-3a AMENDMENT NO. 44,30,60,404,433,433

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NPF-38-203 ATTACHMENT D

=Entergy

?"m?T"":7

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• e Cha' lea M. Dugger

• [

W3F197-0073 A4.05 PR April 11, 1997 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Technical Specification Change Request NPF-38-195 Gentlemen:

The attached description and safety analysis support a change to the Waterford 3 Technical Specifications (TS). The proposed change modifies TS 3.3.3.7.3 and Surveillance Requirement 4.3.3.7.3 for the broad range gas detection system. A change to the Technical Specification Basis 3/4.3.3.7.3 has been included to support thir, change. This change to the Technical Specifications is necessary for the installation of a new, more reliable broad range gas detection system.

This proposed change has been evaluated in accordance with 10CFR50.91(a)(1),

using the criteria in 10CFR50.92(c), and it has been determined that this request involves no significant hazards consideration.

4m49re9,y

Technical Specification Change Request NPF 38195 W3F197 0073 Page 2 April 11, 1997 The circumstances surrounding this change do not meet the NRC's criteria for exigent or emergency review. However, due to reliability concerns with our currently installed broad range gas detection system, we respectfully request an expeditious

)

review. Entergy Operations requests the effective date for this change be within 60 l

l days of approval.

l Should you have any questions or comments concerning this request, please contact Mr. Early Ewing at (504) 739 6242.

Very truly yours, a

//

N lI

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C.M. Dugger Vice President, Operations

}

Waterford 3 CMD/ CWT /ssf

Attachment:

Affidavit NPF-38-195 cc:

E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR R.B. McGehee N,S. Reynolds NRC Resident inspectors Office Administrator Rad!stion Protection Division (State of Loulslana)

American Nuclear Insurers

Technical Specification Change Request NPF 38195 W3F1-97-0073 Page 3 April 11, 1997 ccMail:

J.W. Yelverton (M ECH-65)

F.J. Drummond (W GSB 305)

A.J. Wrape (W.GSB 315)

E.C. Ewing (W GSB-310)

T.J. Gaudet (W.GSB 318)

C.J. Thomas (W GSB 318)

R.E. Allen (W-GSB-102)

J.G. Dewease (M ECH-66)

K.P. Boudreaux (W ADM 523)

S.J. Bethey (M ECH-86)

W.K. Hughey (GGNS-ADM/LIC)

D.C. Mims (ANO-GSB/1C)

R.J. King (R-SB-15) bec:

J.M. Hendrie (SRC Member)

D.C. Shelton (SRC Member)

Waterford 3 Records Center (W-GSB-100)

TSCR File (NPF-38-195)

Licensing Green Folder File

.. - _ - =

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION in the matter of

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Entergy Operations, Incorporated

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Docket No. 50 382 Waterford 3 Steam Electric Station

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AFFlDAVIT Charles Marshall Dugger, being duly sworn, hereby deposes and says that he is Vice President Operations Waterford 3 of Entergy Operations, incorporated: that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Technical Specification Change Request NPF-38195; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of l

his knowledge, information and belief.

j

/

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//

1 o

L Lc L /

a w'd 4 1(r Charles Marshall Dugger Vice President Operations Waterford 3 STATE OF LOUISlANA

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1

) as PARISH OF ST. CHARLES

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Subscribed and swom to before me, a Nqtary Public in and for the Parish and State i

above named this ~ o day of

,1997.

v' 4

4 h

e es -

Notary Public My Commission expires

/ 4s M.

5 DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF.38195 The proposed change requests a change to Technical Specification 3.3.3.7.3, its j

ACTION and Surveillance Requirement 4.3.3.7.3 for the broad range gas detection system. A change to the Technical Specification Basis 3/4.3.3.7.3 has been included to support this change.

i j

l Existing Specification See Attachment A l

l Proposed Specification l

See Attachment B i

Background

I Waterford 3 la situated in a highly industrialized area. Since the transportation and use of materials present the potential for release of toxic gases, Waterford 3 was evaluated 1

to ensure appropriate design considerations. The main control room design and administrative procedures prevent the incapacitation of control room operators during postulated toxic gas events.

t j

In addition to specific detectors to monitor for chlorine, the design of Waterford 3 l-included broad range toxic gas monitors. A broad range gas detection system which i-continuously monitors incoming control room air for the presence of a large variety of

_ toxic gasses is installed in the control room air intake duct, if toxic gas relative concentration equals or exceeds the high setting, the detector system sounds an alami j

and automatically isolates the control room before toxic levels can be reached.

l The current installation of each broad range gas detection system consists of an analyzer panel that includes a photoionization detector, a local readout and alarm i

adjustments for the detection of toxic gases and Imlation of the control room. Also l

included in the original design is a single gas chrornatograph (which is no longer used) l-to aid the operator in determ!ning the gas or gases that actuated the broad range 1-monitor and has no automatk: actuation features.

l Due to the unreliability of the current monitoring system, Waterford 3 has purchased a i

new detection system; Excessive maintenance and calibration of our current system l

are required and there is reduced confidence that the units will be found in calibration.

The system selected to replace the current system is more sensitive, has greater

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resolution, and is more stable. Replacing the existing broad range gas monitor system l

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. -. -. ~. -. _ _,,. -.,. -, - _. - - _ - - - -

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will enhance the monitoring of toxic gasses and reduce the cost of maintenance and l

calib, ration.

l The new monitors, known as Air Composition >4onitors by the vendor, Tolosense, Inc..

j util!ze a Fourier Transform Infrared (FTIR) analysis technique, The FTIR broad range gas detector system utilizes microprocessor gas analysis based on infrared spectrum analysis, and is more accurate than the currently installed unit. Existing alarms and isolation signals will function as presently installed. The gas concentration setpoints j

presently used is a single quantity which is based on the worst case gas, which has the lowest immediately Dangerous to Life or Health (IDLH) value. With the replacement units, setpoints may be made for each analyzed gas. The replacement system has the capability of measuring the concentration of all gases of concern to control room habitability except chlorine. The vendor will provide a backup chlorine monitor on the same skid but it will not be seismicallv qualified. The new chlorine monitor will, therefore, be a backup to the sepcate existing seismically qualified chlorine monitors, which will remain unchanged. In order for the new instrument to properly account for l

CO2 and moisture in the air, it is necessary to periodically establish a baseline i

reference for the infrared spectrum. This is dune by taking a background or reference i

spectrum. The spectrum must not contain any of the measured gases and should be i

free of infrared absorbing gases to the extent that is practical, Instrument air is used for

{

this purpose. This funct!on is an integral part of and is performed automatically by the instrument. The time period for this background check is typically every two hours, i

however the frequency can be adjusted from one to four hours. This normal mode of j

operation of the instrument takes approximately one minute, During this sme'l period of i-time, the instrument is not capable of responding to a toxic gas condition. However, the i

other channel will be available to respond to a toxic gas and has full capabilities to i

isolate the control room in the event a toxic gas condition occurs during this one minute l

time period. The time at which the background / reference spectrum check occurs will be j

staggered such that both systems are not out of service simultaneously In_the event the redundant system is out of service, the contrcl room will be without protection for a i

maximum of one minute per hour, which is less than the allowed outage time for in the

[

current ACTIONS as required by Technical Specifications. However, this automatic j

background / reference spectrum feature, designed to enhance system performance, i

creates a problem with verbatim compliance with the Technical Specifications as l

currently written and necessitates a change to the Technical Specifications.

- Description i

The proposed change to Technical Specification 3.3.3.7.3 annotates the Specification and ACTIONS that the out of service condition for automatic background / reference 4

i spectrum check is not considered to constitute a condition of inoperability of the detection system if both trains are operable and both channels are not performing the j

check simultaneously. This change is being made to ensure that verbatim compliance with the Technical Specification can be achieved without entering the ACTION every j

2 l

4 l-L

- - - - -.J

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time the automatic self check takes place. This is necessary to reduce operator burden l

by removing the requirement of entering an equipment out of service with associated l

pape'rwork each time a broad range gas detection system performs its automatic j

- background / reference spectrum, which can occur as often as once per hour per l

detector, The automatic background / reference spectrum is set for a frequency of onca per hour to once per four hours. The exact frequency of occurrence of the automatic background / reference spectrum will be based on operating experience with the instrument, Additionally, the Surveillance Requirements are being revised consistent l

with the new detection system.

l During the time that the automatic background / reference spectrum check is taking place (which will be less than one minute), the channel will not perform the function of i

isolation of the control room Analysis has shown that the impact on operator i

incapacitation and subsequent core damage risk of this backg.cund check is negligible.

With both channels operable, the other system will be available to perform the control room isolation function in the event of a toxic gas incident. With one channel taken out I

of service (e.g., for maintenance), when the second channel performs the automatic j-background check, both channels will be unable to perform the function of isolating the control room for the short time of the background check, Analysis has shown that the j

impact on operator incapacitation and subsequent core damage risk of the background checks while one monitor is out of service for its 7 day allowed outage time is negligible, i

Additionally, the new detection system performs the calibration check in a different l

manner from the present detection system. While the old system required a manual j

adjustment of instrument sensitivity based on the relationship of the standard gas to the calibration ges, the new system automatically shifts the air sample source from the i

control room inlet plenum to air inside the system cabinet. The cabinet is continuously j

supplied with instrument air, which in effect performs a purge of the cabinet. Should j

instrument air be lost, the control room ventilation system goes into the recirculation a

mode and isolates from the outside atmosphere This is due to the fail position of the j

control room dampers on loss of instrument air. The system uses this air to perform a self-check and reestablishes the gas baseline for monitoring As this channel t

background / reference spectrum check occurs automatically on a preset schedule at a 4

j maximum of once per four hour period, the currently required manual calibration at a i

frequency of once per seven days is being deleted. This change is more conservative i

than the current requirement of once por seven days, Introduction of a standard gas,

].

which was part of the calibration, will become part of the CHANNEL FUNCTIONAL TEST, consistent with the requirements of the new system.

1 j

For consistency, the CHANNEL CHECK, performed on a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequency, will be performed using the display of the specific standard gas used for the CHANNEL FUNCTIONAL TEST in addition to CO2 and water, This is consistent with the vendor recommendations for this system. The CHANNEL FUNCTIONAL TEST will be expanded to require introduction of a standard gas and ensuring that the time of 3

occurrence of the background / reference check is set such that both channels are not

]

out of service simultaneously.

The Bases for the Chemical Detection Systems is being changed to reflect the new system. Verbiage is being added for the annotated LCO as to operability and entry into i

the ACTIONS. The broad range gas detection system description is being modified to reflect the new principle of operation. Addit!onelly, the term IDLH is being spelled out l

as "Immediately Dangerous to Life or Health'in the LCO and Bases. An explanation of the Surveillance Testing is being included consistent with the Bases for similar systems in NUREG 1432," Standard Technical Specifications, Combustion Engineering Plants".

Safety Analysis i

The proposed change described aw.d shall be deemed to involve a significant

]

hazards consideration if there is a positive finding in any of the following areas:

1.

Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response

No The broad range gas detection system has no effect on the accidents analyzed in Chapter 15 of the Final Safety Analysis Report. It's only effect is on habitability of the control room, which will be enhanced by installation of the new monitoring system and this change to the Technical Specifications. Analysis has shown that the impact on operator incapacitation and subsequent core damage risk of this background check is negligible.

I Therefore, the proposed change will not involve a significant increase i

in the probability or consequences of any accident previously evaluated.

3 2.

Will operation of the facility in accordance with this proposed chand create the possibility of a new or different type of accident from any accident previously evolusted?

i

Response

No.

j The proposed Technical Specification change in itself does not change the i

design or configuration of the plant. The new system for broad range toxic gas monitoring performs the same function as the old system, but it accomplishes this with a more sophisticated system that increases reliability, i

Therefore, the proposed change will not create the possibility of a new 4

5 or different kind of accident from any accident previously evaluated.

' 3.

Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Rcvonse:

No The broad range gas detection system has no effect on a margin of safety as defined by Section 2 of the Technical Specifications, l*'s only effect is on habitability of the control room, which will be enhanceo >y installation of the new monitoring system and this change to the Technical Specifications.

Therefore, the proposed change will not involve a significant reduction j

in a margin of safety.

1 l

Safety and Significant Hazards Determination

)

Based on the above safety analysis, it !s concluded that: (1) the proposed change does not constitu;= a significant hazards consideratien as defined by 10CFR50.92; and (2) _

there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) this action will not rusult in a condition l

- which significantly alters the impact of the straton on the environment as described in the NRC final environmental statement.

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NPF-38-195 ATTACHMENT A Q WHI 6 000Y b p

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INSTRUMENTATION CHEMICAL DETECTION SYSTENS BROAD RAhGE GAS DETECTION LIMITING CONDITION FOR OPERATION 3.3.3.7.3 Two independent broia range gas detection systees shall be operable with their alare/ trip setpoint adjusted to actuate at the lowest achievable IDLH gas concentration level e ' detectable toxic gases" providing reliable operation.

APPLICA81LIITY:

All MODES.

ACTION:

With one broad range gas detection system inoperable, restore the a.

inoperable detection system to OPERA 8LE status within 7 days or within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> initiate and maintain operation of the control room ventilation system in the isolate mode of operation.

I b.

With no broad range gar detection system OPERA 8LE, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate and maintain operation of the' control room venti 1'ation system in the isolate mode of operation.

l c.

The provisions of Specification 3.0.4 are not applicable.

4 SURVEILLANCE REQUIREMENTS-4.3.3.7.3 Each broaa range gas detection systes shall be demonstrated OPERA 8LE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a CHANNEL FUNCTIONAL TEST at least once per 31 days and a channel calibration at laast once per 7 days.

Calibration will cor.sist of the introduction of a standard gas and adjusting the instrument sensitidty based on the calibration gas relationsh<p of the standard gas to the calibrating gas, t

" Including Ammonia WATERFORD - UNIT 3 3/4 3-48a AMENDMENT No. 28,53

0 4

6 fNSTRUMENTATION BASES 3/4.3.3.6 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess these variables following an accident.

This capability is consistent with the recommendations of Regulatory Guide 1.97, " Instrumentation fer Light Water-Cooled Nuclear Plants to Assest Plant Conditions During and l'ollowing an Accident," December 1990 and NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations."

Table 3.3-10 includes Regulatory Guide 1.97 Category I key variables.

The remaining Category I variables are included in their respective specifications.

The Subcooled Margin Monitor (SMM), the Heated Junction Thermocouple (HJTC), and the Core Exit Thermocouples (CET) comprise the Inadequate Core Cooling (ICC) instrumentation required by Item II.F.2 NUREG-0737, the Post TMI-2 Action Plan.

The function of the ICC instrumentation is to enhance the ability of the plant operator to diagnose the approach to existence of, and recovery from ICC.

Additionally, they aid in tracking reactor coolant inventory.

These instruments are included in the Technical Specificas. ions at the request of NRC Generic Letter 83-37.

These are not required by the accident analysis, nor to bring the plant to Cold Shutdown, In the event more than four sensors in a Reactor Vessel Level channel are inoperable, repairs may only be ;,ossible during the next refueling outage.

This is because the sensors are accessible only after the missile shield and reactor vessel head are removed.

It is not feasible to repair a channel except during a refueling outage when the missile shield and reactor vessel head are removed to refuel the core.

If only one channel is inoperable, it should be restored to OPERABLE status in a refueling outage as soon as reasonably possible.

If both channels are inoperable, at least one channel shall be restored to OPERA 8LE status in the nearest refueling outage.

3/4.3.3.7 CHEMICAL DETECTION SYSTEMS The chemical detection systems are the chlorine and broad range toxic gas detection systems.

The OPERA 81L JY of the chemical detection systems ensures that sufficient capability is available to promptly detect and initiate protective action in the event of an accidental chemical release.

The chemical detection systems provide prompt detection of toxic gas re-lenses which could pose an actual threat to safety of the nuclear power plant or significantly hamper site personnel in performance of duties necessary for the safe operation of the plant.

The broad range toxic gas detection a.es operates on the principle of gas photoionization, and therefore, the system is sensitive to a broad range of gases." The system is therefore sensitive to both atmospheric and chemical composition normal fluctuations affecting the Waterford 3 site.

The setpoint

• Including Amononia WATERFORD - UNIT 3 B 3/4 3-3 AMEN 0 MENT NO. I4, 26, 49

n

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O INSTRUMENTATION BASES for the system is thus based or. testing and operating experience, and the set-point is set at the lowest achievable IDLH gas concentration providing reliable operation and the optimum detection of toxic gases.

The setpoint is therefore subject to change wherein necessitated by operatins experience such as a result of changes in the Waterford 3 area chemical atmospheric profile.

The setpoint is established and controlled by procedure.

3/4.3.3.8 This section deleted 3/4.3.3.9 This section dele (gd i

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WATERFORD - UNIT 3 8 3/4 3-3a AMEN 0 MENT NO. 11,20,50,104

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NPF-38-195 ATTACHMENT B 1

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4 INSTRUMENTATION CHEMICAL DETECTION SYSTEMS BROAD RANGE GAS DETECTION LIMITING CONDITION FOR OPERATION i

3.3.3.7.3 Two inds,-wncent broad range gas detection systems shall be OPERABLE " with their alarm /tnp I

i setpoints adjusted to actuate at the lowest achievable Immediately Dangerous to Life or Health gas concentration level of detectable toxic gases

• providing reliable operation.

APPLICABILITY: AllMODES.

ACTION: "

l 1

a. With one broad range gas detection system inoperable, restore the inoperable detection system to OPERABLE status within 7 days or within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> initiate and maintain operation of the control room ventilation system in the isolate mode of operadon.

b. With no broad range gas detection system OPERABLE, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> laitiate and maintain operation of the control room ventilation system in the isolate mode of operation.

c. The provisions of Specification 3.0.4 are not applicable.

l i

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SURVEILLANCE REQUIREMENTS 4.3.3.7.3 Each broad range gas detection system shall be demonstrated OPERABLE by performance of a 4

CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and a CHANNEL FUNCTIONAL TEST at least once per 31 days. The CHANNEL FUNCTIONAL TEST willinclude the introduction of a standard gas.

4 4

1 i

• Including Ammonia

" The requirements of Technical Specifkstion 3.0.1 do not apply during the time (approximately one minute) when the Instrument automatic background / reference spectrum check renders the instrument (s) l inoperable.

WATERFORD - UNIT 3 3/4 3-48a AMENDMENT NO. 20. 53 i

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9 INSTRUMENTATION BASES 3/4.3.3 6 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitonng instrumentation ensures that sufficient information is available on selected plant partmeters to monitor and assess these vanables following an accident. This capability is consistent with the recommendations of Regulatory Guide 1.97,

" Instrumentation for Light-Wa'er-Cooled Nuclear Plants to Assess Plant Conditions Danng and Following an Accident," December 1980 and NUREG-0578,"TMl 2 Lessons Leamed Task Force Status Report and Short Term Recommendations." Table 3.3-10 includes Regulatory Guide 1.97 Category I key variables. The remaining Category I variables are included in their respective specifications.

The Subcooled Margin Monitor (SMM), the Heated Junction Thermocouple (HJTC), and the Core Exit Thermocouples (CET) comprise the Inadequate Core Cooling (ICC) instrumentation required by item II.F.2 NUREG-0737, the Post TMI-2 Action Plan. The function of the ICC instrumentation is to enhance the ability of the plant operator to diagnose the approach to existence of, and recovery from ICC. Additionally, they a!d in tracking reactor coolant inventory. These instruments are included in the Technical Specifications at the request of NRC Generic Letter 83-37.

These are not required by the accident analysis, nor to bring the plant to Cold Shutdown.

In the event more inan four sonsors in a Reactor Vessel Level channel are inoperable, repairs may only be possible during the next refueling optage. This is because the sensors are accessible only after the missile shield and reactor vessel head are removed. It is not feasible to repair a channel 1xcept during a refueling outage when the missile shield and reactor vessel head are removed to refuel the core, if only one channel is inoperable, it should be restored to OPERABLE status in a refueling outage as soon as reasonably possible. If both channe's are inoperable, at least one channel shall be restored to OPERABLE status in the nearest refueling outage.

3/4.3.3.7 CHEMICAL DiiTECTION SYSTEMS The chemical detection systems are the chlorine and broad range toxiyas detection syste'as.

The OPERABILITY of the chemical detecbon systems ensures that sufRcient capability is available to promptly detect and initiate protective action in the event of an accidental chemical release.

The chemcal detecton systems provide prompt detection of toxic gas releases which could pose an actual threat to safety of the nuclear power plant or significantly hamper site personnel in performance of dubee necessary for the safe operation of the plant.

The breed range toxic gas detection system utilizes a Fcurier Transform infrared (FTIR) analysis technique, and therefore, the system is ansitive to a broad range of gases". The system is sensithre to normal fluctuations of both atmospheric and chemical composition which affect the Waterford 3 site. The setpoints

• Including Amrnonia WATERFORD - UNIT 3 B 3/4 3-3 AMENDMENT NO. M 20,4E

w 4

INSTRUMENTATION BASES associated with the system are based on testing and operating experience. Set-points are set as to prevent immediately Dangerous to Life or Health (IDLH) gas concentration in the control room while providing reliable operation and the optimum detection of toxic gases. The setpoint is therefore subject to change wherein necessitated by operating experience such as a result of changes in the Waterford 3 area chemical atmospheric profile. The setpoint is established and controlled by procedure.

The LCO and ACTIONS for the broad range gas detection system are annotated such that the system instrument automatic background / reference spectrum check does not constitute system inoperability if both channels are operable and both channels are not performing the check simultaneously. The instrument automatically performs this check. During the time that the automatic background / reference spectrum check is taking place (which will be less than crst minute), the channel will not perform the function of isolation of the control room. With both cnannels OPERABLE, the other system will be available to perform the control room isolation funcbon in the event of a toxic gas incident. With one channel taken out of service (e g., for maintenance), when the second channel performs the utomatic background check, both channels wil be unable to perform the function of isota'.ing the control room for the short time of the background check Analysis has shown that the impact on operator incapacitation and subsequent core damage risk of the background checks while one monitor is out of service for its 7 day allowed outage time is negligible. Therefore, entry into the ACTION solely due to the automatic check is not required.

No specific manual CHANNEL CALIBRATION is required as the system instrument performs this function as the background / reference spectrum check automatically for approximately one minute on a frequency of once every hour to once every four hours. The exact frequency is established based on operating experience with the instrument.

The perfomwnce of the CHANNEL CHECK once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ensures that a gross failure of the instrument has not occurred. The CHANNEL CHECK consists of a comparison of the display of the standard gas (ublized in the FUNCTIONAL TEST), CO2 and water, Significant deviations from the expected readings arid actual readings could be an indicabon of a malfuncbon within the unit. The CHANNEL CHECK will detect gross system failure; thus, it is the key to verifving the instrument' continues to operate property between each CHANNEL FUNCTIONAL TEST.

A CHANNEL FUNCTIONAL TEST is perfctmed to ensure the entire channel will perform its required funcbon This test includes introduction of a standard gas and venficabon of isolabon of the control room. The time of the occurrence of the background / reference smetrum check is set during the CHANNEL FUNCTIONAL TEST such that both channels are not out of service simultaneously.

3/4.3.3.8 THIS SECTION DELETED 3/4.3.3.g THIS SECTION O' LETED d

WATERFORD - UNIT 3 8 3/4 3.3a AMENDMENT NO. 44, 30, 60,404