ML20236S091

Forwards Addl Info & Redrafted Tech Specs Re Sys,Subsystems & safety-related Cooling Functions,In Response to NRC 870417 & 0702 Comments & Agreements Reached in 870825 & 26 Meetings

ML20236S091
Person / Time
Site:	Fort Saint Vrain
Issue date:	11/19/1987
From:	Brey H PUBLIC SERVICE CO. OF COLORADO
To:	Calvo J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
References
P-87410, NUDOCS 8711240214
Download: ML20236S091 (134)

Text

{{#Wiki_filter:_ y . ~ l'. h Public Service ~ =#;a... 2420 W.'26th Ave'nue, Suite 1000, Denver, Colorado 80211 November 19, 1987 Fort St. Vrain Unit No. 1 P-87410 y U. S. Nuclear Regulatory Commission -ATTN: Document. Control Desk -Washingto'n, D.C. 20555' Attention: Mr. Jose A. Calvo Director, Project Directorate IV Docket No. 50-267

SUBJECT:

Technical Specification Upgrade Program (TSUP), Safety Related Cooling Functions

REFERENCE:

1) NRC letter, Heitner to Williams, dated 4/17/87 (G-87131) i

2) NRC letter, Heitner to Williams, dated 7/2/87 (G-87217)

3) NRC memorandum, Heitner to Calvo, dated 10/1/87 (G-37348)

4) PSC letter, Brey to j

Berkow, dated 2/28/86 (P-86169)

Dear Mr. Calvo:

This letter provides Public Service Company of Colorado's (PSC) . response to the NRC comments on the TSUP final draft specifications i for systems, sub-systems, and components with safety-related cooling functions. These comments were provided in References 1 and 2, and l PSC's proposed resolutions were discussed in meetings held on August goo \\ ] 25 and 26, 1987, as documented in Reference 3. i \\ 8711240214 371119 DR ADOCK 05000267 p eDR o. )

L P-87410 '? age 2 November 19,-1987 The attachments to this letter reflect.the agreements reached during those meetings. Attachment 1 provides-proposed drafts' of. the Technical ' Specifications that. assure forced circulation (Specification 3/4.4.1) and safe shutdown cooling capability (Section 3/4.5). 2 Attachment 2 provides proposed. drafts of other Technical ~ Specifications that. have been re-drafted to support those specifications included in Attachment 1.. Attachment.3 provides a discussion for each NRC comment provided in Reference 1. The agreements reached 'in the August 1987 meetings'are documented. AAtachment 4 provides a discussion for each NRC comment regarding the safety-related ~ cooling function that was provided in Reference 2.. .This attachment also documents agreements reached in the August 1987 meetings. -PSC. considers the attached re-drafted Technical Specifications responsive to.the. identified NRC concerns, consistent with the Fort St. Vrain-(FSV) licensing basis, as embodied in the FSAR. Due to the current developmental. status of the TSUP, these specifications have not been approved by the FSV Plant Operating Review Committee, and some further changes are anticipated due to this review effort. They have been reviewed by plant personnel, however, and they represent PSC's current positions on the identified issues. If you have any questions regarding this information, please contact Mr. M. H. Holmes.at (303) 480-6960. Very truly yours, o H. L. Brey I Manager, Nuclear Licensing and Fuels HLB /SWC/imb Attachments ) i a

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h g. i P-87410 ) Page 3: November-19, 1987 ' I cc: Regional Administrator, Regio.- IV-ATTN: Mr. T. F. Westerman, Chief Projects Section B Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain a f a 'I(: - c

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i RE-DRAFTED TECHNICAL SPECIFICATIONS l FOR SAFETY-RELATED COOLING FUNCTIONS

Qc j % a. Amendment No. ' g,. ~ 1,h 'Page 3/4 4-11 ~ g 1 j t L PRIMARY 'C00LANT SYSTEM-L y'm NOV 191987 k 23/4f4.1' PRIMARY COOLANT LOOPS AND COOLANT CIRCULATION 3e.. r; ~ ~ LIMITING CONDITION FOR OPERATION L 3.4.1;1 Two' primary'. coolant' loop's shall be in operation and circulating primary coolant, each with: ~'3.. a. Both. the steam generator.. economizer-evaporator-ti superheater (EES): section and the. reheater section operating-(each section includes six modules), and . b.. At least the minimum number of helium circulators -operating to meet power' level requirements as follows: PERCENT RATED THERMAL MINIMUM NUMBER OF POWER HELIUM CIRCULATORS n Above.50% 2 in each loop 5% through 50% 1 in each loop APPLICABILITY: POWER and LOW POWER ACTION: With only one primary coolant loop in operation, restore .a. both loops to operating status within 12 hours or be in -at least STARTUP within the next 24 hours. I b. With only one operating helium circulator in either loop, reduce reactor power to at least 50% RATED THERMAL POWER within 30 minutes. if c. With one steam generator section not operating in either primary coolant loop, restore all steam generator sections to operating status within 12 hours or be in at least STARTUP within the next 24 hours. j >m i f I \\ l i l ____a_- .a - - - - - -. ^

i ~ Amendment No. Page.3/4=4-2 DRAFT ...e NOV 191987 - 'd. With no primary coolant loops in operation, be in at least: SHUTDOWN within.10 minutes and ' restore forced-circulation with at least one circulator in at least one loop within 90 minutes, 'or mdepressurize the -PCRV. in accordance. with::the ' applicable requirement below. If forced circulation is restored within 5 hours of initial Lloss, de' pressurization may. be discontinued. p 1. For.- reactor. THERMA' L POWER equal to or greater than 125% -prior.. to SHUTDOWN ~ depressurize per. Figure 3.4.1-1. ' 2. ' For : reactor.. THERMAL POWER less.than 25% prior to SHUTDOWN, depressurize per Figure 3.4.1-2. 3'. 'With the reactor already SHUTDOWN, depressurize per Figure 3'4.1-3. ,y ' SURVEILLANCE REQUIREMENTS 4.4.'1.1.AtJ.least. once per. 12 houre the above required primary coolant equipment shall be verified to be in operation and circulating primary coolant. b l p [ v

[- Amendment No. L -S. Page 3/4 4-3 c DRAFT + NOV 191987 i 5 Ig T115 AVAILASLE PRIOR TO INfflATISW OF PCRV DEPRESURIZATION WHEN FORC80 CIRCULATION 3 5 ASO MMN AT FW {4 TO GE UNO FOR POWER LEVEL 5 EOUAL TO OR 5 SREAftR TNA5 2BE . I. y 5 ts """::: nn======='===================='====m===== o2 e9 ' E 5 t =f 1 5< 0 20 30 40 50 60 70 80 90 100 REACTOR THERMAL POWER - % Tkne Avaiable Prior to initiation of PCRV Depressurnation When Forced Circulation is Lost from a Powered Condition at FSV Figure 3.4.1-1 l l

Amendment No. Page 3/4 4-4 . f DRAFT-NOV 191987 g I I l-1 I I I I I l e Be TWIE AVAILAOLE Mt009 70 INfTIATION OF Fenv OspneseunizaTiGN A8 A FUNCTION - ~8 g l, k-

0F AVERADE CORE OUTLETTEWERATURE

\\ AT TNG OMET OF A LOPC m \\ 'I y x TO GE USEO PGA F0WER LEVELS LES TNAN 3516 I-, T ( 1 3 w I \\ 3'$ o e n

e'

-T c '4 w 'f' I N r y' N e % A -2 400' 500 800 - 700 000 900 1000 1100 1200 1300 1400 1500 AVERAGE CORE OUTLET TEMPERATURE 8F Time Available Prior to initiation of PRCV Depressurization as a Function of Average Core Outlet Temperature at the Onset of a LOFC Figure 3.4.1-2 i 1

p-Amendment No'. Page 3/4 4-5 g.. L DRAFT 1 NOV 191987 r. I I I I I I I I I I I I I .. g. 2 TRIE AVAILASLE PRIOR TO INITIATION OF / j.70 PCRV OEPRESBURlZAfl0N WNEN FORCEO f ' CIRCULATION IS LOST FROM A SHUT 00WII '9-CW10lT10N / . 5. 80 N E TO BE USED FOR A SHUTOOWN CONDITION ONLY h. r J -gm r E / / a ** / i g 2 / y' N r p o 2 [ / $ 20 q a 5: [ 10 3 O' O 100 200 '300 400 500 600 700 800 900 1000 TIME FROM REACTOR SHUT 00WN - HOURS ) Time Available Prior to initiation of PCRV Depressurization When Forced Circulation is Lost from a Shut Down Condition Figure 3.4.1-3

7,1 Amendment No. Page 3/4 4-6: c rltg * .m DRAFT PRIMARY COOLANT' SYSTEM NOV 191987 K ec 3/4.4.1 PRIMARY' C00LANT-LOOPS AND COOLANT CIRCULATION - s ' LIMITING CONDITION FOR OPERATION t E3'4.1.2' At- 'least one primary coolant loop shall be in operation and circulating primary coolant, with at least: a. One helium circulator: operating and m b. One steam. generator. section operating (either the

economizer-evaporator-superheater

(. EES) or the reheater). APPLICABILITY: STARTUP*, SHUTOOWN* and REFUELING * ~ ACTION: HWithL no. operating primary coolant loops, be in at least SHUTOOWN 'within 10 ' minutes and suspend all operations ' involving CORE ALTERATIONS or control rod movements resulting in positive reactivity changes. 1. Restore at least one loop to operating status prior to reaching a CALCULATED BULK CORE TEMPERATURE of 760 degrees F,.or 2. Initiate PCRV depressurization in accordance with the time specified in Figures 3.4.1-2 or 3.4.1-3, as applicable. - SURVEILLANCE REQUIREMENTS 4.4.1.2 At least' once per 12 hours, the above required primary coolant equipment shall be verified to be in operation and -circulating primary coolant. '

• Whenever CALCULATED BULK CORE TEMPERATURE is greater than 760 degrees F.

____U .._L

= e.- Amendment No. 1 n' Page 3/4 4-7 DRAFT I yH,, l R*' NOV 191987 -l M BASIS' FOR SPECIFICATIONS LCO 3.4.1.1/SR 4.4.1.1 AND d LCO 3.4.1.2/SR 4.4.1.2 i ] This Specification assures forced circula' tion.of primary ,' L coolant. Both. loops 'with. both steam. generator sections K ,(reheater and EES) are required to be operating and at least. one helium circulator in each loop ~, depending on the power

level, is. required to be operating.

Two loop operation is 4:> t 'compon.en t s. from overheating (FSAR Section 4.3.5.2). Single l required;.to protect the steam generator's internal y ' loop operation lis permitted only long enough to reduce power

in an. orderly manner as required for recovery; of the shutdown loop or to be below 5% power.

(FSAR Section 4.3.4). Specification '3/4.4.1.1'is applicab'le at power levels above 5%.~ power. Below 5% Epower, single loop operation is 1 acceptable, .and as long as the CALCULATED ~ BULK CORE TEMPERATURE remains below 760 degrees F (as determined per 'the: guidelines. of Specification 3.0.5), forced circulation 'is not required at all. At':1 east' two circulators (one in each loop) are required .below 50% power, consistent with the.-operating guidelines

provided in the circulator vendor's Operating and Maintenance Manual. Also, if both circulators in a loop trip, powerlis automatically reduced to about 50%. A single circulator trip will result in~a power reduction to about 50%'

power for conservatism. The requirements of Specification 3.4.1.1.b represent a power restriction, not a circulator restriction; i.e., there may be four operating circulators below 50% power.

7- - - pl ;,; Amendment No, y. Page-3/4 4-8: N DRAFT i 'Depressurization-NOV 191987 .In the unlikely-event that all forced circulation is lost 'for 90 minutes, the PCRV is depressurized to reouce the. heat transfer- .to _ the . Liner Cooling. System. Start of 'depressurization is initiated as a function of prior power levels, with 2 hours from-100% RATED THERMAL POWER being the ~ most limiting case. Operators will! continue attempts to restore forced ~cir'culation cooling until 5 hours after the loss-of forced circulation. (FSAR Section D.2.5). Multiple sources and flowpaths to establish forced convection cooling .using. circulators makes required' depressurization. highly ~;;

unlikely.

Cooldown using forced. circulation cooldown is preferred to:a depressurized cooldown with the PCRV liner ~ cooling. system.. Depressurization of the PCRV under extended loss'of. forced circulation conditions is accomplished by venting the.' reactor helium-through a train'of the helium ~ purification system and.the. reactor building vent stack filters to atmosphere. Start of depressurization times from .various reactor' power conditions are delineated in Figures ~3.5.1-1, _3.5.1-2, and 3.5.1-3 and are discussed in the FSAR o ~Section 9.'4.3.3 and Appendix D. A -Specification :3.0.5 provides'the methodology and necessary data to determine the appropriate time interval to reach a CALCULATED BULK. CORE TEMPERATURE of.760 degrees F. If the active core remains. below this temperature, 'which corresponds to the design maximum core inlet temperature as -indicated above, then the design core inlet temperature cannot be exceeded and there can be no damage to fuel or .PCRV internal components regardless of the amount, including total-absence, or reversal, or primary coolant helium flow. i

"y' ~ Amendment No. Page 3/4 5-1

s DRAFT SAFE SHUTDOWN COOLING SYSTEMS NOV 191987-3/4.5.1 HELIUM CIRCULATORS LIMITING CONDITION FOR OPERATION 3.5.1'.'l At least one helium circulator in 'each primary coolant loop shall be OPERABLE with the capability of being driven by its

.(

water turbine. APPLICABILITY: POWER, LOW POWER, STARTUP*,' SHUTDOWN *, and REFUELING * " ACTION: With less than the required OPERABLE helium circulators, restore the inoperable equipment to OPERABLE status within '72 hours or be in at least SHUTDOWN within the next 24 -hours. -SURVEILLANCE REQUIREMENTS 4.5.1L.1 :The helium circulators shall be demonstrated OPERABLE: a. At least once per REFUELING CYCLE whereby circulators 1B and.1D will'be tested during even numbered cycles and circulators 1A and 1C during odd numbered cycles, by demonstrating. operation on water turbine drive of each circulator and verifying equivalent 3.8*.' rated helium l flow on condensate at reduced ' pressure (to simulate firewater pump. discharge) using each emergency water booster pump (P-2109 and P-2110) and the emergency condensate header. Whenever CALCULATED BULK CORE TEMPERATURE is greater than 760 degrees F. i u i L l n

Amerdment No. g Page'3/4 5-2 DRAFT z b'. 'At least once per 10 years by; verifying: NOV 191987

1. -A1 helium circulator' compressor wheel rotor, turbine' wheel-and pelton wheel are free of both surface and subsurface

' de f ect s in 'accordance with the appropriate methods, procedures, and associated-acceptance criteria specified for Class I components in Article NB-2500,.Section III, ASME Code. Testing shall 'be scheduled.so :that over 4 inspection periods,'each circulator will be tested once. Other t helium circulator components, accessible without further disassembly'than required to inspect these wheels ~, shall-be visually examined, and [ .2. 'At least 10% of primary coolant pressure boundary + . bolting and other structural. bolting has been removed' for the inspection above, and it.is free of j a-inherent or developed defects. a 3. Reports .Within 90 days of examination completion, a.Special Report shall-be submitted to the NRC in accordance-with Specification 6.9.2. This report shall include the results of the helium circulator examinations, a i l i l 1 L ~ _ _ _ _ _ _ _.

7. A

Amendment No'

~1 Page 3/4 5-3 l + y ' SAFE SHUTOOWN'C00' LING SY' STEMS t3/4.5.1~ HELIUM CIRCULATORS . NOV 19'1987-LIMITING CONDITION FOR OPERATION-3.5.1.2 At 'least one ' helium circulator.shall be OPERABLE with the capability of being driven by its water turbine. -APPLICABILITY: STARTUP*, SHUTDOWN *,'and' REFUELING *

ACTION:.W1th no'0PERABLE helium circulator,.be in at least SHUTDOWN within 12. hours and. restore the required equipment to OPERABLE status prior to reaching a CALCULATED BULK CORE TEMPERATURE of1760 degrees F,

or suspend all operations involving-CORE ALTERATIONS or control ' rod movements - resulting. in positive reactivity changes. . SURVEILLANCE REQUIREMENTS 4.5.1.2 DThe helium circulators shall~be demonstrated OPERABLE by the performance of SR 4.5.1.1. Whenever CALCULATED BULK CORE TEMPERATURE is less than or equal to ~760 degrees F. L_

~ iv ' Amendment No. ~ 1 .Page 3/4~5.4 m. Om -DRAFT m/O - NOV 191987 BASIS FG.T : SPECIFICATIONS LCO 3.5.1.1/SR 4.5.1.1' AND 'LCO 3.5.1.2/SR-4.5.1.2- 'The. scope. of.'this. Specification includes the: helium circulator machine, with particular emphasis' on the water turbine (Pelton wheel) drive, and on.the water. supply piping out to the speed control valves. The connecting supply piping and turbine water; drain piping is included in Specification 3/4.5.2.

0ne helium circulator (and one steam generator EES section)

? ensures. SAFE SHUTDOWN C0 CLING when the plant is pressurized. One. helium; circulator. in each ' primary -coolant -loop is specified during POWER, LOW POWER,. STARTUP,; SHUTDOWN, and REFUELING with' CALCULATED BULK CORE. TEMPERATURE greater than 700 degrees F to-allow. fo r a single failure. One - ci rculator, operating 'with.. motive power from either (a) Lcondensate'or boosted firewater supplied via the emergency ' condensate ; header, _ or (b) feedwater or boosted firewater i . supplied via.. the emergency. feedwater header, provides ' sufficient -primary : coolant circulation for the pressurized condition. SAFE' SHUTDOWN COOLING is discussed in FSAR Section 10.3.9,_ single' failure considerations in Section 10.3.10, and condensate and boosted firewater cooldown transients in FSAR Sections 14.4.2.1 and 14.4.2.2. Two. circulators, operating' with-emergency water drive, supplied with feedwater'via the emergency feedwater header, ' provide sufficient primary coolant circulation following a

postulated Design Basis Depressurization Accident (DBA-2).

(FSAR Section 14.11.2). DBA-2 is a highly incredible event l' the; probability of which-has been determined to be approximately-1.0E-7 per year, and protection against single . failures'is not a feature of FSV (FSAR Section 14.11.1). For-the maximum credible.depressurization accident (MCA), a single; helium circulator provides sufficient circulation, as discussed in FSAR Section 14.4.3.2. The SAFE SHUT 00WN COOLING. emergency water drive source is boosted firewater, which is included in Specification i 3/4;5.5 - The helium circulator pelton wheels-can be driven by condensate from the condensate pumps (either 60's or 12 1/2%).or by feedwater from the boiler feedwater pumps; -however, these are not SAFE SHUTDOWN COOLING equipment. I l i 1

u 's ' Amendment No. (X y - y 'Page.3/4 5-5 n. F h DRAFT ( Redundancy Criteria NOV 191987 p. 'The use of 760' degrees F CALCULATED BULK CORE TEMPERATURE as k

a. division.between the. APPLICABILITY of Specification

~ ' b 3.5.1.1 verses 3.5.1.2 is explained as-follows: In the FSV' HTGR, the limiting parameter of interest is a core inlet temperature greater than 760 degrees F. The-CALCULATED: BULK CORE TEMPERATURE is a conservative calculation of the maximum' potential temperature in the core and surrounding components. The conservatism are such that if the CALCULATED BULK CORE TEMPERATURE is limited to 760 degrees F,'the design inlet temperature of:760 degrees F is i not. exceeded. Systems' used for accident prevention and l mitigation are' required to satisfy the single failure criterion whenever CALCULATED-BULK CORE TEMPERATURE is greater.'than 760 degrees F..However, when' CALCULATED BULK l CORE TEMPERATURE is equal to or less than 760 degrees F, it 'is. acceptable. to require only one OPERABLE system for accident prevention and mitigation without. single failure consideration, on the basis of the limited core cooling -requirements. 'All ' forced circulation may be. interrupted for maintenance purposes provided that-the: time calculated for CALCULATED BULK CORE TEMPERATURE to reach 760_ degrees F is not exceeded. ~However, if forced circulation is temporarily J

restored, a recalculation shall be performed, based on

{ .present conditions, to establish. a new time period for CALCULATED BULK CORE TEMPERATURE to reach 760 degrees F. Redundant systems may also be taken out of service for j maintenance -or surveillance testing provided that forced l circulation is maintained. The time to reach CALCULATED t BULK CORE TEMPERATURE equal to 760 degrees F may be recalculated as often as required. { Specification 3.0.5 provides the methodology and necessary { data to-determine the appropriate time interval to reach a i CALCULATED BULK CORE TEMPERATURE of 760 degrees F. If the l active core remains below this temperature, which j corresponds to the design maximum core inlet temperature as 1 indicated above, then the design core inlet temperature i cannot be exceeded and there can be no damage to fuel or l PCRV internal components regardless of the amount, including j total absence, or reversal, or primary coolant helium flow. o.

Amendment No. [1 Page 3/4 5-6 V>JP 'DRAPT NOV1 9 gg7-Actions V With.. CALCULATED BULK-CORE TEMPERATURE above,760 degrees F, 'an inoperable: helium' circulator is permitted for 72-hours, as.this constitutes a loss of. redundancy in SAFE SHUTDOWN ,E COOLING equipment. 72 hourst :is. consistent :with Actions required in Light Water Reactors for' loss of. redundancy in Emergency Core Cooling _ System equipment. If the' -inoperable ' helium. circulator cannot be repaired within this time, an orderly shutdown is required. With the' CALCULATED BULK CORE TEMPERATURE below 760 degrees 'F, 12 hours are allowed -to be in at least SHUTDOWN, consistent with the time allowed for an orderly shutdown x; from STARTUP.. Then, as 'long as-the inoperable equipment is ' restored.to OPERABLE-status prior to reaching 760 degrees F, no further Actions are required. Operability Demonstration is tested for. its SAFE SHUTOOWN 'Each helium ' circulator. COOLING capabilities, every other REFUELING CYCLE. This is done by _ simulating firewater. flow by throttling condensate flow, boosting it with the emergency water booster pumps, and. verifying that primary coolant flow rate is equivalent to~3.8% at full density with cold core conditions, and the resultant reduced bouyancy due to the " chimney effect". A 10 -year - ISI inspection is required to ensure helium-circulator integrity. I 1 l l

g Amendment No. 7; Page'3/4'5-7 if y 7 DRAFT SAFE SHUTDOWN COOLING SYSTEMS NOV 191987 3/4.5.2 HELIUM' CIRCULATOR AUXILIARIES ~ f -LIMITING CONDITION FOR OPERATION- ~ f f 3.5.2.1' : At least the -following helium circulator water turbine drive capabilities and auxiliary equipment shall be OPERABLE for the helium circulators that are required to be OPERABLE: a. Two SAFE SHUTOOWN COOLING (firewater) supplies for each L-water turbine drive. This includes two emergency water booster : pumps (P-2109 and P-2110) and a flow path from both the emergency feedwater: and emergency condensate headers to 'and including the helium circulator water . turbine speed control valves, b. The~ turbine water removal system, including two turbine water removal pumps,

c.

The normal bearing water system, including two normal bearing water pumps per loop, and_ two bearing water makeup pumps (P-2105 and P-2108) with two supply sources of bearing water makeup. d. The associated bearing water accumulator (T-2112, T-2113, T-2114, or-T-2115), and e. The -supply and discharge valve interlocks ensuring automatic water turbine start capability.# ' APPLICABILITY: POWER, LOW POWER, STARTUP*, SHUTDOWN *, and REFUELING

• ACTION:

a. With only one of the above required SAFE SHUTDOWN COOLING water turbine drive supplies, turbine water removal pumps, bearing water pumps per loop, sources of ~ bearing water makeup, or bearing water makeup pumps, restore the inoperable equipment to OPERABLE status within 72' hours, or be in at least SHUTOOWN within the next 24 hours. Whenever CALCULATED BULK CORE TEMPERATURE is greater than 760 degrees F.

1. The supply and discharge valve interlocks ensuring automatic water turbine start capability are only required to be OPERABLE in POWER.

i l 1

h, Amendment'No. Page 3/4 5-8 DRAFT w x (v NOV 19195/ b. With less than the above' required OPERABLE bearing water accumulators, restore the i., operable equipment to OPERABLE status within 224. hours, or be^1n at least -l -SHUTDOWN within the next 24 hours. l With

less than~ the ~above required OPERABLE valve c.

interlocks, restore the' inoperable equipment to OPERABLE status within 72 hours,, or be in at lea:t LOW POWER within the'next 12 hours. l-SURVEILLANCE REQUIREMENTS ~! .4.5.2.1'a. The helium circulator auxiliaries shall be demonstrated r

0PERABLE:

-1. At least'once per 92 days by: ~ ). Testing. the. bearing water accumulators and a verifying accumulator flow to the circulator

bearing, b) Performing a turbine water removal pump start test based on a simulated drain tank level to verify automatic actuation and pump start capability, and c) Performing a start test of bearing water makeup pump P-2105, based on a simulated low pressure in the backup bearing water supply line to verify automatic actuation and pump start capability.

2. At least once per REFUELING CYCLE by: i a) Testing the water turbine inlet and outlet valve interlocks ensuring automatic water turbine start capability by simulating a PPS signal resulting from one loop being tripped and the circulators' steam turbine drives in the l operating loop having been tripped. J b) Monitoring the proper closure of the circulator helium shutoff valves, and c) Performing a functional test of each emergency water booster pump. This is performed in conjunction with Specification SR 4.5.1.1.a. l i j. i.

g -. 3 Amendment'No. 4 .;;g Page 3/4 5-9 M ' c.w '- 7., ; DRAFT-

$^FE SHUTOOWN COOLING SYSTEMS.

) ' NOV 191987 oK, 3/4-5.2 HELIUM CIRCULATOR. AUXILIARIES 1 [LIMITINGC0N'DITION'FOROPERATION 3.5.2U2'Atleastthe.followingheliumcirculatorwaterturbinedrive capabilities and auxiliary equipment shall'be OPERABLE for each. helium circulator that is required to be OPERABLE: y a. One SAFE. SHUTDOWN COOLING (firewater) supply for each water turbine drive. This includes one emergency water ~~ booster pump. (P-2109 or P-2110), and e flow path from y' either Lthe. emergency feedwater or the emergency condensate header to and including the helium circulator water turbine speed' control valve. t b.' The turbine water: removal. system, including one turbine water removal pump, c. The normal bearing water system, including one bearing . water pump,'and one bearing water makeup pump (P-2105 or -P-2108),.with one supply source of bearing water makeup. d. The.. associated bearing water accumulator (T-2112, T-2113, T-2114, or T-2115). i: APPLICABILITY: STARTUP", SHUTDOWN *, and REFUELING

• j i

. ACTION: With less than the above required OPERABLE equipment, be in i at least SHUTDOWN within 12 hours, and restore the required equipment to OPERABLE status prior to reaching a CALCULATED BULK CORE TEMPERATURE of 760 degrees F, or suspend all operations involving-CORE ALTERATIONS or control rod movements resulting in positive reactivity changes. 1 SURVEILLANCE REQUIREMENTS u 4.5.2.2 The helium circulator auxiliaries shall be demonstrated OPERABLE by performance of SR 4.5.2.1. Whenever CALCULATED BULK CORE TEMPERATURE is less than or equal to 760 degrees F. i Y? _ --

m 2*,, ~ Amendment No. Page 3/4 5-10 DRAFT yy

• t e

o NOV 1 g 1987 BASIS. FOR-SPECIFICATIONS LC0 3.5 2 1/SR 4 5.2.1 AND LCO 3. 5.2.2/SR 4. 5.2.2-I h The:. scope of. this Specification. includes the helium l circulator pelton wheel supply oiping from-the emergency feedwater o r. 'emercency condensate headers (which 'are - specifically. includeJ. in Specification 3/4.5.4) to and ' including the heliun circulator water turbine speed control

valves'. 'The heliurr circulator pelton. wheel drives are includedLinSqicification3/4.5.1.

Whenever the.' CALCULATED-BULK CORE TEMPERATURE (CBCT) is greater'than!-760 -degrees F, two SAFE SHUTDOWN ' COOLING n 3 (supplies' ar'e' 'specified to ensure forced circulation in the J event of a'Magie active failure :in this piping. J One, turbine ' water removal pump has. sufficient capacity to j remove-the water'from two circulator water' turbines.

Also, the turbine' water removal tank overflow' to the reactor l building sump is.available if the normal pump flow path is j

l o's t. 'Each'.of. the. two separate and independent recirculating i bearing water loops. supplies the bearing water requirements ofL the two helium circulators in a primary coolant loop. Each of the normal bearing water loops contains three bearing water pumps in series. Each pump develops full flow and one-half the requirnd head rise. Two pumps are running, the third is a standby . Requiring two pursps to be OPERABLE when.the CBCT is gretter than 760 degrees F provides j protection. against a jingle failure. A backup supply of bearing water is-availat c e from the feedwater system. i .Makaup bearing. water requirements are normally obtained from 'tha feedwater system. A. separate bearing water makeup pump j 15.provided as a backup to supply makeup water to the j '.aearing water surge tank. The bearing water makeup pump l (P-2105) takes suction from either the deaerator (normal), j the condensate storage tanks, or the firewater system j (emergency). If this pump is inoperative, an emergency i bearing water makeup pump (P-2108) can supply water at a l reduced capacity from the condensate storage tank, or the i firewater system (emergency). I A 72-hour Action time for all the above equipment is appropriate whenever the CBCT is greater than 760 degrees F as this is a loss of redundancy in SAFE SHUTOOWN COOLING equipment. 72 hours is consistent with Actions required in i; Light Water Reactors for loss of redundancy in Emergency Core Cooling System equipment. I l l L

e - 1 %[ M Amendment No, Page 3/4 5-11 Q DRAFT NOV fg 1987 p When the ' CALCULATED BULK CORE TEMPERATURE is less than 760 degrees F, the' Action to'be shut'down within 12 hours is 0 l consistent with the time allowed for an orderly shutdown J .from STARTUP. Each' bearing water loop.contains a gas pressurizer and a bearing water accumulator capable of supplying bearing water for 30 Lseconds.at design-flow rate if no other source of . bearing water is available. This is adequate for shutdown of the affected circulators without damage to the bearings. The bearing water system, including the bearing water accumulators and the bearing water makeup pumps are 1 functionally ~ tested at 31 day and 92 day intervals to ensure proper operation. There is no redundancy in the bearing 2 water-. accumulators and-a 24 hour action statement restoration.~ time. is-provided. This is acceptable .considering the-low ~ likelihood of failures of these } P ! components. o Auto water. turbine start. is prevented if a water, turbine 1 TRIP exists orLthe auto water turbice start control switch is not in'the auto position. The aforementioned interlock circuitry _is tested once per REFUELING CYCLE, to ensure proper system operation. The automatic ~ water turbine start ~ ifeature is ' relied upon in the event the control room has to be abandoned. Since this is an unlikely event, a 72 hour action; statement restoration time is acceptable.

Also, the Action-to reduce power to the LOW POWER mode is appropriate because the interlocks are only required in the PCWER mode.

Redundancy Criteria The use of 760 degrees F CALCULATED BULK CORE TEMPERATURE as-f a division between the APPLICABILITY of Specification ) 3.5.2.1 verses 3.5.2.2 is explained as follows: E In the FSV HTGR, the limiting parameter of interest is a l core inlet temperature greater than 760 degrees F. The CALCULATED BULK CORE TEMPERATURE is a conservative . calculation of the maximum potential temperature in the core j and surrounding components. The conservatism are such that j if the CALCULATED BULK CORE TEMPERATURE i's limited to 760 { L degrees F, _ the design inlet temperature of-760 degrees F is 1 not' exceeded. Systems satisfy the single failure criterion whenever CALCULATED BULK CORE TEMPERATURE is greater than 760 degrees F. However, when CALCULATED BULK CORE TEMPERATURE is equal to or less than 760 degrees F, it is acceptable to require only one OPERABLE system for accident 4 prevention and mitigation without single failure consideration, on the basis of the limited core cooling requirements.

p- '~ ' Amendment No. 43 Page 3/4 5-12 u DRAFT. y NOV 191987 -All. forced.; circulation may be interrupted for maintenance. - purposes provided that the time calculated for CALCULATED BULKi. CORE -TEMPERATURE to. reach 760 3 degrees F is not 1 exceeded.' However,Eif forced circulation is temporarily . restored,)^a recalculation-shall. be performed, based on present: conditions,' to Lestablish a new time period for - CALCULATED' BULK' CORE TEMPERATURE' to reach 760 degrees F. . Redundant systems may:also be taken out of service for maintenance:;or.surv'ei_llance. testing.:provided that forced 1 circulation' is maintained. The' time to reach CALCULATED BULK. CORE,' TEMPERATURE ' equal _ o-760 degrees F may be t . recalculated as often as required. ~ Specification 3.0.5 provides the methodology and necessary-1. -data to-determine tne. appropriate time interval to reach a - CALCULATED LBULK CORE 1 TEMPERATURE of 760 degrees F. If the

active' core.

remains-below-this temperature, which ' E, corresponds Etc.the design maximum core inlet temperature as ~ indicated above, then-the design core inlet temperature - cannot be exceeded and there can be no damage to fuel or ' PCRV' internal co'mponents regardless of'the amount, including total ' absence, or reversal, or. primary coolant helium flow. 1; 4. T c 5 c i', 1 1

q _.[ h j Amendment No. 1 e-Page 3/4 5-13 w, d,?' DRAFT U . SAFE SHUTDOWN COOLING SYSTEMS-NOV 19 27 U-i 3/4'.5.3-STEAM GENERATORS, s V: LIMITING CONDITION FOR OPERATION j 3.5.3.1: The steam generator in each primary coolant loop shall be 1 -OPERABLE, including. both .the economizer-evaporator-superheater (EES).and reheater sections. APPLICABILITY: POWER,. LOW POWER, STARTUP*, SHUTDOWN"; and REFUELING

• ACTION: With. -less than_ the. requ' ired OPERABLE steam generator i

sections, restore the inoperable equipment-to OPERABLE l

status within 72 hours or be'in at least SHUTDOWN within the next 24 hours. j SURVEILLANCE REQUIREMENTS' 4.513.1 Each steam generator shall be' demonstrated OPERABLE at least once per 24 hours by: a. Verifying through a review of equipment status that the EES section is capable of receiving _ flow from both the g ' emergency feedwater and emergency condensate header, and b. _ Verifying 'through a review of equipment status that the reheater section is capable of receiving flow from the emergency condensate header. Whenever CALCULATED BULK CORE TEMPERATURE is greater than 760 degrees F. 1

, 91 ,m ,.gvkg q Amendment No'. Page 3/4 5-141 + p' . DRAFT SA'FE: SHUTDOWN COOLING' SYSTEMS NOV19 W L3/4.5;3-STEAM 1 GENERATORS ~ <pg,

15 s

LIMITING CONDITION FOR OPERATION n n,,' 3;5'.3.2' AtL least one steam generator in.~one primary coolant loop

with an OPERABLE helium circulator shall be OPERABLE, l including at least the economizer-evaporator-superheater L

.'(EES).or.the reheater section. g APPLICABILITY: STARTUP*, SHUTDOWN *, and REFUELING * -ACTION:' With. no. 0PERABLE steam: generator section, be in at least ~ SHUTDOWN within. 12 hours and restore the inoperable i

equipment to OPERABLE status prior'to reaching a CALCULATED

~ BULK CORE TEMPERATURE of 760. degrees F, or suspend all operations-involving-CORE ALTERATIONS or control rod l } f . movements'resulting-in positive reactivity changes. J l . SURVEILLANCE REQUIREMENTS { l l 4.5.3.2 ;The steam generators shall be demonstrated OPERABLE: ' At least.once per 24 hours by verifying through a review a, of.. equipment status that the required-steam generator section is capable of receiving flow from either the emergency condensate header (EES and reheater) or the d emergency feedwater header (EES only). b. At least once per 18 months by: -1. Veri fying proper flow through the emergency feedwater header and emergency condensate header.to the steam generator sections. f 2. Verifying the outlet flow path by cycling the valves in the six-inch vent lines and observing that the !E vent flowpaths are not obstructe:. R -Whenever CALCULATED BULK CORE TEMPERATURE is less than or equal 1 to 760 degrees F. I l.

l. t l

,e ......m__

j /.

Amendment No. N,*

Page 3/4 5 n W"

DRAFT ,9 NOV i 91987 m. w

c..At' least. once per 5 years by volumetrically examining' od

.the accessible. portions.of the 'following bimetallic welds for indications of subsurface defects:

f. ' 'y a

1. The main steam ring.. header collector to' main steam piping weld for one steam generator module in each loop', and-e. f,

2.

The main-steam ring header collector to collector-drain ~ piping weld for one steam generator module in e.

M each'. loop, and' c 3. The same two. steam generator modules shall be re- .,y4 examined at each interval. .The' -initial examination shall be performed during M SHUTDOWN or REFUELING prior to the beginning of. fuel cycle 1 5. This initial examination shall also include the bimetallic welds described above for two additional ~ steam' generator modules in each loop. .d. --Tube Leak Examination-

Each time a. steam generator'EES tube is plugged due to a leak,' specimens from the accessible subheader tubes connected to. the leaking inaccessible tubes shall be metallographically. examined.

Rebeater subheater tubes are not accessible. W .The results of this metallographic examination shall be

compared to the results from the specimens of all

-previcus tube leaks. A study shall be performed to evaluate the size and elevation of the tube leaks to determine if a cause of the leak or a trend in the degradation can be i identified. ,.i 1 1. Acceptance. Criteria An engineering evaluation shall be performed to i -determine the acceptability of: I a) Any subsurface defects identified in SR 4.5.3.2.c, b') Continued operation considering the condition of the steam generator materials, and c) OPERABILITY of the steam generator sections considering the number of plugged tubes and their ability to remove decay heat. l It L____ ___1---___

m m, p.n m, ' % 4.:.y, - - . W j,&, mE ' 3J '.: . Amendment No. .s ~Page 3/4 5-16' .:.t ' n" V. s, ' Ljypf% > l 1 s mg .7 7 DRAFTJ n+ w.. Mr. ,A Re' ports t- .NOV ig g7; s -g*.- 4 m mr c, .Within' l90 'diys of: the return Lto operation' following ,", i each.ste'am:' generator.,l tube leak' study, a Speciai- " (7 lf,, o 3". y,W ,' y 1 Report-shall be submitted ;to::the. Commission.in t accordance withi Specification.6.9.2, ;This!.' report-shall.: include the ' estimated size /and elevation of ' m ~ a-. : thefleak(s), and.at' least the ' preliminary; results of:- .mf 5.the 'metallographic'. and ' performed,.the Jpostulated 'c. engineering. ' analyses ause of the' leak if-4: ~;; ,- e. .' identified and corrective action to be taken, ', j h!. 2 x c i,; l:g 0 :;f'

.A...

t r s f +

' I',

i 9 t t k 9 x 5 a Gf 7 N[-l( t h 'f-- k /' t L -l.. ^

Y 'l f

,'l'.' ? c? is s r 'e t .r U / 49 ,' 3 '; .o

.u r

g [ ,f,_ -. _ _

Amendment No. pg Page 3/4 5 < x,c M DRAFT m ) 5 Ng191987 i BASIS-FOR-SPECIFICATIONS LCO 3.5.3.1/SR 4.5.3.1 i LC0 3.5.3.2/SR 4.5.3.2 The ' requirements.for OPERABLE steam generator (s) provide an adequate means for removing heat from the' prima ry coolant system to the ' secondary ' coolant system. The helium flow which cools' the reactor core enters the. steam generator at high temperature and gives up its heat to'the reheat steam 'section and economizer-evaporator-superheater (EES) section. $ ~1 Each steam generator. consists of six identical individual 7 ' steam generator modules operating in. parallel. Each module

consists of a reheater section and an EES section. Any one EES s'ction provides sufficient heat removal; capability' to e

g P " ensure SAFE SHUTDOWN COOLING. The. reheater sections are - lso used in certain accident analyses, such as wrong loop a dump.'with an.EES leak, but they are not relied upon for SAFE i< SHUTDOWN COOLING. h 4 'During' POWER, LOW POWER, STARTUP, SHUTDOWN, and REFUELING with CALCULATED BULK CORE TEMPERATURE' greater-than 760 degrees F,. both steam generator sections in each loop are . required'to be OPERABLE. This allows for a single failure l 'andLfensures an OPERABLE EES section for SAFE SHUTDOWN COOLING. During SHUTDOWN and REFUELING with CALCULATED BULK CORE O TEMPERATURE less than;or equal to 760. degrees F, redundancy .is not : required and either the reheater section or the EES section of one steam generator can be used for shutdown heat removal from the' primary coolant. Redundancy' Criteria ' The use of 760 degrees F CALCULATED BULK CORE TEMPERATURE as a' division-between the APPLICABILITY of Specification 3.5.3.1 verses 3.5.3.2'is explained as follows: In the -FSV HTGR,.the limiting parameter of interest is a core inlet temperature greater than 760 degrees F. The CALCULATED ' BULK CORE TEMPERATURE is a conservati"e calculation of the maximum potential temperature in the core -and surrounding components. The conservatism are such that if the CALCULATED BULK CORE TEMPERATURE is limited to 760 l degrees. F, the design inlet temperature of 760 degrees F is j not' exceeded. Systems satisfy the single failure criterion j whenever CALCULATED BULK CORE TEMPERATURE is greater than 760- degrees. F, However, when CALCULATED BULK CORE 1 TEMPERATURE-is equal to or less than 760 degrees F, it is { acceptable to require only one OPERABLE system for accident l prevention and mitigation without single failure I consideration, on the basis of the limited core cooling requirements. T u___ m

"e ~ Amendmont No. Page 3/4.5-18 DRAFT 4 'NOV 191987 i .All forced' circulation may be' interrupted for maintenance. purposes provided that the time calculated for. CALCULATED BULK CORE TEMPERATURE to reach '760 degrees F is not exceeded..However, if. forced circulation. 1 s. temporarily. restored,.a recalculation shall be. performed, based on present conditions,-to establish a new time period for CALCULATED-BULK CORE TEMPERATURE.to reach 760 degrees F. Redundant systems may.also.be taken out o f_ service for maintenance ~ or surveillance. testing pr'ovided that forced circulation is maintained.- The time to reach CALCULATED BULK CORE : TEMPERATURE equal to 760 degrees F ' may be -( recalculated'as often as required. Specification 3.0.5 provides the methodology and necessary data to determine the appropriate time interval to reach a CALCULATED BULK CORE TEMPERATURE of 760 degrees F. If the e active: core remains below this temperature, which . corresponds' to the design maximum core inlet temperature as - indicated above,.then the design core inlet temperature .cannot be exceeded and there can be no damage to fuel or PCRV internal components regardless of the amount, including . total absence, or reversal, or primary coolant helium flow, i s ' Actions With CALCULATED BULK CORE TEMPERATURE above 760 degrees F, an' inoperable steam generator section is permitted for 72 hours, as this constitutes a loss of redundancy in SAFE SHUTDOWN COOLING equipment. 72 hours is consistent with Actions-required in Light Water Reactors for loss of redundancy in Emergency Core Cooling System equipment. If the inoperable section cannot be repaired within this time, ~ an orderly shutdown is required. With the CALCULATED BULK CORE TEMPERATURE below 760 degrees F,12 hours are allowed to be in at least SHUTDOWN, consistent with the time allowed for orderly shutdown from STARTUP. Then, as long as the inoperable equipment is restored to OPERABLE status prior to reaching 760 degrees F, no further Actions are required. Operability Demonstrations The steam generator EES Sections can receive water from + either the associated emergency condensate header or the emergency feedwater 11eader. Also, the reneater sections can receive water from the emergency condensate header. During operation, these capabilities cannot be demonstrated without L disturbing plant power levels. Equipment status logs are 4 reviewed once per 24 hours to confirm that the valves that isolate the steam generator sections from the appropriate emergency condensate or emergency feedwater headers are still OPERABLE. l- +

-my ' '.,. y, 9 :; L_ 3 Amendment.No.

e. e c,

,m ~ Page 3/4 5-19 w ,, x, 7-DRAFT i NOV-191987 ...h (During' shutdown conditions, 'the required'flowpaths to all steam-generator sections are demonstrated. Also -the six i ~' inch vent. valves are . cycled and the outlets are visually-t , X..,; examined for obstructions; actual flow is not demonstrated. .y A six-inch. vent line to atmosphere from each EES discharge v header 4 is: included in, the ' SAFE SHUTDOWN COOLING flowpath to ~ reduce downstream . flow resistance and allow ' higher flowrates. (FSAR Section 10.3.9). H 'E L0 ' B1 metallic Weld Examination The' steam' generator crossover tube bimetallic welds'between Incoloy 800 and 2 1/4 Cr-1 Mo materials are not accessible for' examination. The bimetallic welds between steam l a generator ring header collector, the main steam piping, and the ' collector drain piping.are accessible, involve the same - ma teri a l s,' and ' operate. at conditions not significantly different :from the crossover tube bimetallic welds. The- . collector drain piping weld is also geometrically similar to the ' crossover tube weld. Although minimal degradation is i expected to occur, this specification allows for detection of defects which might result' from conditions that can uniquely'1 affect bimetallic _ welds made between these 'ma te ri a l s. Additional collector welds are inspected at the initial examination.to establish a baseline which could be

used, should defects.be found. in later inspections and-

,,ti . additional examinations subsequently be required. .b Tube Leak Examination During.the lifetime of the plant, a certain number of steam generator tube leaks are expected to occur, and the steam A, generators have been designed -to have these leaking tube subheaders plugged without affecting the plant's performance as.shown in FSAR Table 4.2-5. The consequences of steam generator tube leaks have been analyzed -in FSAR Section 14. 5 '. 1 It is 'important to identify the approximate size and '2 elevation .of steam generator tube leaks and to f metallographically-examine the subheader tube material W because this information can be used to analyze any trend or generic cause of tube leaks. Conclusive identification of the cause of a steam generator tube leak may enable modifications and/or changes in operation to increase the reliability and life of the steam generators and to prevent i a quantity of tube failures in excess of those analyzed in the FSAR. i I 'l QL_

p g.3- ~ ~ m E

• pr

{ ' W... g, .p,g, 3j4 5-20' 'Amencment No; g f, -l. Q, - DRAFT ~ 1 .s 1 T LBecausel of.the subheader:Ldesigns NOV1 9 ggy. I A leading to the-' steam -{ 2 sh,

generator tube bundles, internal or. external inspection and-W

' evaluation of a tube leak to' establish a conclusive cause is 4 not practical.. Metallographic examination of the' accessible? 4 di. connecting' isubheader tube will show the condition of the hinternali subheader wall', giving-an. indication-of-the' ' conditions fof1 the leaking tube. internal wall, lthereby' ' demonstrating;the~ effectiveness of water chemistry controls.

Determining the. approximate size and elevation of.the-tube leak ~may enable: evaluation of other.. possible -leak l causes m

Jsuch as tube / tube support plate : interface effects. The;Lsurveil. lance plan ~ outlined above is considered adequate to evaluate. steam generator tube' integrity and ' ensure that the ' consequences of-postulated tube leaks' remain within the limits analyzed in the FSAR. F l' ( f q. L ,() y il e ._,r.. J f,7, f ' j i; >. ~ .. 4 ~ u._.-m_ma-- - ---

. gw - - j[,.1'#', o.l Page 3/4 5-21 Amendment'No, CM i " ' f DRAFT [ SAFE SHUTDOWN' COOLING SYSTEMSi .NOV 19jgg7 W L3/4.5.4 EMERGENCY CONDENSATE AND EMERGENCY FEEDWATER HEADERS t ' EMERGENCY'C000ENSATE AND EMERGENCY FEEDWATER HEADERS - OPERATION J . LIMITING CONDITION:FOR. OPERATION L3'.5.421.LThe'. emergency condensate header and-the:. emergency feedwater 4

header shall be OPERABLE.

m. APPLICABILITY:. POWER, LOW POWER,'STARTUP*,. SHUT 00WN*, and REFUELING

• i u-ACTTON: With.either the emergency condensate header or the emergency feedwater header inoperable,~ restore the inoperable header u,'

?to OPERABLE status within 72 hours or: ~ tc 1.-When. in POWER, LOW POWER, or STAR))P, be in at least o, l SHUTDOWN within.the next 24 hours, or-2. When.in SHUTOOWN or REFUELING, suspend all operations a .involvingj CORE ALTERATIONS or control rod movement resulting in positive reactivity changes. F ' SURVEILLANCE REQUIREMENTS 4.5.4.1' No 'Ladditional Surveillance Requirements are. required other .I i than those-surveillance identified in Specifications i . SR 4. 5.1.1' a, ' SR 4 ' 7.1.1, and. SR 4. 5. 3.2.b.1. 1 l l 1

• Whenever' CALCULATED BULK CORE TEMPERATURE is greater than 760 l

' degrees F. f x i.

Amendment No. Page 3/4 5-22 DRAFT SAFE SHUTOOWN COOLING SYSTEMS NOV 19 t387 3/4.5.4 EMERGENCY CONDENSATE AND EMERGENCY FEEDWATER HEADERS EMERGENCY CONDENSATE AND EMERGENCY FEEDWATER HEADERS - SHUTDDWN LIMITING CONDITION FOR OPERATION 3.5.4.2 Either the emergency condensate header or the emergency feedwater header shall be OPERABLE. APPLICABILITY: STARTUP*, SHUTDOWN *, and REFUELING

• j i

ACTION: With both the emergency feedwater and emergency condensate header inoperable, be in at least SHUTDOWN within 12 hours and restore at least one header to OPERABLE status prior to reaching a CALCULATED BULK CORE TEMPERATURE of 760 degrees F or suspend all operations involving CORE ALTERATIONS or control rod movement resulting in positive reactivity changes. SURVEILLANCE REQUIREMENTS 4.5.4.2 No additional Surveillance Requirements are required other than those surveillance identified in Specification SR 4.5.4.1.

• Whenever CALCULATED BULK CORE TEMPERATURE is less than or equal to 760 degrees F.

b..., / ) {"llyQ'g. { -Amendment No. Y Page 3/4' 5-23~ p g.e %u. DRAFT p 'id "m

BASIS FOR SPECIFICATION LCO 3.5.4 / SR 4.5.4 at b

NOV 191987 M, ?The ' OPERABILITY'of the~ emergency condensate header and:the " 'g emergency;feedwater header ensures redundant water.. supply. 'E j~ s . paths! to J the' helium' circulators and: steam generators for- -SAFE SHUTDOWN COOLING of the plant. In 'the event of a S failure of.' the;. normal'feedwater line, the availability of-1 eithe'r.the' emergency:feedwater or emergency condensate _ lines pro'vides i adequate. shutdown capability. ' OPERABILITY of the aforementioned-headersgis accomplished during SHUTDOWN by-

verifying' flow --through each header to the steam generators 7bb and helium circulators.

m .Both thej emergency, condensate. header and the emergency .feedwater header' are considered. SAFE SHUTDOWN COOLING D' ' equipment. o 1 3 Redundancy Criteria The-u'se_ of-760 degrees F CALCULATED BULK CORE TEMPERATURE as a ndivision. between the'~ APPLICABILITY of Specification W 3.5.4.1-verses 3.5.4.2 is. explained as follows: ! In'.the FSV - HTGR, - the limiting parameter of interest is a core inlet temperature greater than-760 ' degrees F. The- ,j CALCULATED BULK CORE TEMPERATURE is a conservative l 4 f/,' lcalculationfof the maximum potential temperature in the core [i and surrounding components. The conservatism are such that 1 if the. CALCULATED BULK CORE. TEMPERATURE is limited to 760 degrees' F,. the ' design inlet temperature of 760 degrees F is not exceeded. Systems used for. accident prevention and mitigation ~Lare. required to satisfy the single failure. ' criterion whenever CALCULATED BULK CORE TEMPERATURE is-greater, then-760 degrees F. However,'when CALCULATED BULK CORE TEMPERATURE is equal toLor less than 760 degrees F, it isLLacceptable. to require only one OPERABLE system for accident prevention and mitigation without single failure consideration, on the basis of the limited core cooling ' requirements. All force'd circulation may be interrupted for maintenance . purposes provided that the time calculated for CALCULATED BULK CORE TEMPERATURE to reach 760 degrees F is not exceeded. However, if forced circulation is temporarily

restored, a recalculation shall be performed, based on present conditions, to establish a new time period for CALCULATED BULK CORE TEMPERATURE to reach 760 degrees F.

Redundant systems may also be taken out of service for n maintenance or surveillance testing provided that forced circulation.is maintained; and tne time to reacn CALCULATED - BULK: CORE TEMPERATURE equal to 760 degrees F may be recalculated as often as required. a

k"., ' h I " , y Amendment No, ff .Page 3/4 5-24" b$L s DRAFT-aq. QQ NW1 Q R Ki Specification 3.0.51.provides the methodology and necessary 7 data to determine-the appropriate time interval to reach a b CALCUALTED ! BULK. CORE' TEMPERATURE of 760' degrees F. If the 4 4

active ' core. remains 1 'below -this temperature, which corresponds;7.to the design maximum core ~ inlet temperature as' l

, m' indicated.above, then the ~ design core inlet temperature

g. :

cannot: be exceeded and there can'be no damage to fuel.or i~ PCRV internal components regardless of the amount,. including ! total absence, or reversal, or primary coolant helium flow. The emergency 1.'feedwat'er header.is not normally placed in f. . service 'until approximately; 30'. reactor power, to prevent l unnec'essary long-term wear of components: associated-with the R a" ' emergency feedwater header Nevertheless it is still 6 requiredLto.be OPERABLE during the aforementioned MODES. E a'- LActions_ a i.; With CALCULATED BULK CORE TEMPERATURE above 760 degrees F, an inoperable helium circulator is permitted for 72 hours, g-as this constitutes a loss of redundancy in' SAFE SHUTDOWN C00 LING' equipment._ 72 hours is consistent with Actions q "- ' required in Light Water Reactors for loss of redundancy'in Emergency Core: Cooling' System equipment..If the. inoperable helium: circulator cannot be repaired within this time, an orderly: shutdown is required, b WU:.h the CALCULATED BULK CORE TEMPERATURE below 760 degrees L F; 12 -hours are allowed to be-'in at. leas't-SHUTDOWN, consistent with.the time allowed for an orderly shutdown .from'STARTUP. Then, as long as the inoperable equipment is Ec: ' restored to'0PERABLE status prior to reaching 760 degrees F, . no: further Actions' are required. 1 i ' il l i CA_i_____.._.E____.__._

a Page 3/4 5-25 hi g,Cr DRAFT I SAFE SHUTDOWN C00 LING SYSTEMS. NOV 191987 ~ I -3/4.5.5 SAFE SHUTOOWN COOLING WATER SUPPLY SYSTEM h, 'd 0 LIMITING CONDITION FOR OPERATION L3.5.5l .Th'e ' SAFE -SHUTDOWN. COOLING water supply system shall be OPERABLE with: a. At.Ileast two OPERABLE circulating water makeup pumps ,a --(P-4118-P, P-41185-P, or P-4118SX-P) connectible to an essential bus, c b. Twot OPERABLE firewater pumps, both the motor driven (P-4501) and the engine driven (P-4501S), including the associated pump pits and at.least 370 gallons of fuel in the day tank, for the engine driven pump,

c...Two circulating. water makeup ponds OPERABLE with a minimum combined inventory of 20 million gallons, and di An,-OPERABLE. flow' path capable of taking suction from the circulating water makeup storage ponds and transferring the water via the circulating water makeup pumps and the firewater pumps to.the fire suppression headers, to the e

emergency-condensate header isolation valve, and to the emergency supply isolation valves for the instrument air . compressors, after coolers, emergency generator coolers, -and PCRV liner cooling system. 0- ' APPLICABILITY: 'At all times ACTION: 4 With CALCULATED BULK CORE TEMPERATURE greater than 760 , degrees F: K a, With one of the above required pumps and/or makeup ponds inoperable, restore the inoperable equipment to OPERABLE status within the 72 hours or be in at least SHUTDOWN within the next 24 hours. ] b. With two of the above required pumps and/or makeup ponds inoperable, restore at least one pump or makeup pond to OPERABLE status within 1 hour, or be in at least SHUTDOWN 1 within the next 24 hours. i l l w

==--L-'_-

--o [y% c 3 Amendmont No, , y.0" Page 3/4 5-26 se w DRAFT ] NOV i g gy H O.

ch With-the SAFE SHUTDOWN COOLING water system otherwise

. inoperable, restore the system to OPERABLE' status. within 1 .it hourv or.- be.: in: at least SHUTDOWN'within the next 24 'l l hours. n .,With s CALCULATED BULK CORE-TEMPERATURE less.than-or equal to-760' degree's F: 3 4:

ru

a. With.

one.of the above required pumps and/or makeup ponds s,

' inoperable, restore the' inoperable equipment to OPERABLE status within 14 days or p'rovide an alternate' backup pump s- ^ or water supply. The provisions of. Specification 3.0.4 are.not applicable. [b.. 'With ino capability of supplying SAFE-SHUTDOWN COOLING water to the emergency condensate. header isolation valve .? or to the emergency..feedwater hea' der isolation valve, be. 'in atlleast. SHUTDOWN within 12 hours and restore the .reauired supply capability prior to reaching a CALCULATED BULK CORE' TEMPERATURE of 760 degrees F or. suspend all Loperations involving CORE ALTERATIONS or control rod movementsiresulting in' positive reactivity changes. ~ SURVEILLANCE REQUIREMENTS-4.5.5,l'- The SAFE. SHUTDOWN COOLING water supply system-shall be demonstrated OPERABLE: a. At least;once.per 7 days by verifying the contained water supply; volume in each of the circulating water makeup ponds; b. At least once per 31 days by: 1. Starting the electric motor-driven fire pump and .~ operating it for at least 15 minutes, { 2. Starting each circulating water makeup pump that is not already running, and r 3. Verifying that each valve in the flow path, that is not locked, sealed, or otherwise secured in place is in its correct position. c. At least once per 12 months by: i 1. Performing a system flush, and 2. Cycling each testable valve in the flow path through at least one complete cycle of full travel. ____-_ a

rwn;; 'b "i D .'AmendmenO Noc q. m, Page.3/4;5-27 DRAFT g 6x NOV 191987 ' m,

d. ~ Atiileastionce; per 18 : months !by performing a: system functional: test which includes simulated-automatic.

okJ X ' actuation: of-the^ system throughout.its operating , sequence, and:~ h / 1. Verifying that 'the.' automatic valve in the flow path actuates to its correct position, '2. . Verifying that each pump (mctor-driven and engine-C S driven) develops at least 1425 gpm.at.119-psig,

• 9:

3. -Cycling each, valve-in the flow path that-is not

-m testable'during plant operation through at least one- s complete cycle of full travel, and. 4. Verifying ~ that each fire water pump starts '(sequentially) to maintain-system pressure greater r than or equal to.119 psig. At ' least! once.per 3 years by performing a flow test of e. T the system in accordance with Chapter 5, Section II of l ~ the Fire Protection handbook,14th Edition, published by the National Fire Protection Association. 'f. At' least'once per 5, years by verifying the alignment and I settlement of the. circulating. water makeup pond embankments, and. by examining the embankments and water 'c structures' for abnormal erosion,. c ra c k s ',

seepage, leakage,'andfaccumulation of silt'or debris.

4.5.5.~2 The' fire pump diesel engine shall be demonstrated OPERABLE: 'a. 'At least once per 31 days by verifying: 3 l '. The ' fuel -day tank contains at least 370 gallons of fuel, and 2. The diesel starts from ambient conditions and operates for at least 30 minutes, b. At least once per 92 days by verifying that a sample of l diesel-fuel from the fuel day tank, obtained in { accordance with ASTM-D270-1975 is within the acceptable } limits specified in Table 1 of ASTM-0975-1977 when l checked for viscosity water and sediment. c. At-least once per 18 months, by subjecting the diesel to s an inspection-in accordance with procedures prepared in l conjunction its manufacturer's recommendations for the class of service. i l l.r.'

ps,w' gg;o, n '^ y2 a. L. ' - Amendment No. f M N "J" . ic Page. 3/4 ' 5-28:. . DRAFT. cam w< s x ra & ':.t.e o jc.o 4 i 9 t:

3

&m. NOV191987; c-T'; 4.5.5;3fIThefLfire: pump-l diesel.(starting:. 24-volt battery.. bank and ......\\. Y f' R. < charger shall?be; demonstrated OPERABLE: m ], [a'.JAt'least'onceiper7daysby. verifying.that:

11. The', electrolyte.. -level ' of 'each battery'is above. the

= >, p a- -j plates',and? %N . 4 f' ~ -2;,;. Thel overall battery.: voltage 'is' greater than or equal' to 24Lvolts.

p

,a

b..LAti

least'once per 92.l days by verifying,that the specific Y.

4 lgrivity is Appropriate :for:. continued service of.:the , battery. " c.. . At.. least' once; per,.18 months.by ; veri fying that: 8 4 ;" 11. The batteries,' cell plates,.and battery racks show no-s visual indication ofL physical damage or abnormal y". ~. .W deterioration,..andl m ~ l -2. 'The -battery-to-battery and. terminal connections are r ' clean," tight, free of corrosion, and coated 1with~ ~ anticorrosion material. a: y v f A t j ti t f 1 j l 1 ,1 : - i J i t I d::

h( ' Amendment No. o Page 3/4 5 h -DRAFT ' BASIS FOR' SPECIFIC TION LCO'3;5.5 / SR 4.5.5 NOV 191987 The' SAFE SHUT 00WN COOLING water supply-syste'm provides an adequate water. supply. for ' helium circulator water turbine P operation and : emergency cooling water to the steam generators .for SAFE SHUTDOWN COOLING. The-SAFE SHUTDOWN-COOLING water supply system also supplies' water to Lthe fire suppression g p, headers.-, SAFE SHUTDOWN COOLING requirements are discussed in -Section!1.4, 10.3, ang.14.4 of the FSAR. This. specification' covers the flow path from the circulating water. makeup. storage ponds to the emergency' condensate header "~ E isolation., valves:(coverage is continued in Specification 3/4.5,4) to:the. isolation valves-for the fire. suppression

headers (coverage. is continued in Specification 3/4.7.6.1), and

,H' 'to the. isolation valves for'the essential users of firewater (PCRV liner.. cooling system, instrument air compressors, af ter coolers, and emergency generator. coolers). Additionally, this flow path to the firewater headers includes those lines to the o-fire. suppression spray system, fire hose' stations, ya rd fire hydrants and' hydrant' hose houses. The ' circulating-' water makeup system provides at. least 20 million gallons 1of-water to the-service water and' firewater systems. During extremely. cold' weather, formation'of ice on 'the: surface of the circulating water storage ponds can occur. The ;LCO limit of 20 million gallons of water is in' addition to any ice formation. The.. firewater system has'two redundant 100*; -capacity ; firewater pumps, each rated for 1500 gpin at 125 psig TDH.' The main' pump is electric-motor driven, and the standby pump' is diesel-engine L riven. 'With 370 gallons of fuel in d y storage, the-diesel-engine, driven fire pump can operate at m rated ~ conditions for 24 hours which is adequate time'to have 0: .more fuel delivered to the site. 'Each pump has its.own driver

with. independent power ' supplies and controls and is located in -

a separate room,. divided by a 3-hour fire rated concrete wall. The:. fire water pumps take suction from independent pits which . tie in directly with the main cooling tower basin. Fire water is supplied.to the main cooling tower basin from two storage -ponds via circulating water makeup pumps. The normal cooling . tower is used by the firewater systems. Two sources of makeup via two makeup pumps, neaders, and two firewater pumps are required for single failure considerations. Additionally, 20 million gallons of water in the circulating

water makeup storage ponds is required as well as an OPERABLE flow. path aligned to the emergency condensate header and firewater header.

a-

y, ' Amendment'No; .e7' Page 3/4 5 DRAFT c NOV191997 'With~twoloutLof threercirculating water makeup pumps. inoperable; or with any.'one circulating water makeup. pond inoperable-or a firewater pump inoperable and the : CALCULATED BULK CORE-

TEMPERATURE greater than 760 degrees F, a restoration time of.

727.ho~urs' is considered sufficient, as this constitutes a loss of redundancy?in SAFE SHUTDOWN COOLING equipment. 72 hours is

consistent-with4 Actions' required in Lignt Water Reactors for

. loss'of' redundancy in Emergency Core Cooling System equipment. s 'However, with all circulating water makeup pumps, headers, or firewater pumps inoperable, a restoration time of-1 hour is specified', -as. all means.of SAFE SHUTDOWN COOLING water supply are. lost. Also, Ewith 'the -CALCULATED ~ BULK CORE TEMPERATURE below 760-degrees :F,12' hours are allowed to be ' in 'at least SHUTDOWN, consistently with the time allowed for an orderly. shutdown from .A STARTUP. Then, as long as the inoperable equipment is restored to OPERABLE status prior to reaching 760 degrees F, no further Actions are required. M; The. surveillance identified in this specification will ensure that all=' equipment, water supplies, and flow paths will remain OPERABLE as specified ~in order to' meet those SAFE SHUTDOWN COOLING requirements specified above. LThe use ofl760 degrees F CALCULATED BULK CORE TEMPERATURE as-a division between the ACTIONS is explained as follows: + In. the I FSV HTGR,.the limiting parameter of interest is a core islet' temperature' greater than 760 degrees F. The CALCULATED . BULK!: CORE TEMPERATURE is a conservative calculation of the

maximum. potential'. temperature in the core and: surrounding

~ components.' The conservatism are such that if the CALCULATED l BULK CORE TEMPERATURE is limited to'760 degrees F, the design. inlet. temperature of 760 degrees F is not exceeded. Systems used for accident prevention and. mitigation are required to satisfy the single failure criterion whenever CALCULATED BULK-CORE TEMPERATURE is greater than 760 degrees F. However, when - CALCULATED BULK CORE TEMPERATURE is equal to or less than 760 ' degrees F,.it is acceptable to require only one OPERABLE system for accident prevention and mitigation without single failure consideration, on the basis of the limited core cooling requi remen ts. I h. u_--____---

_T %fh .,f 7 Amendment No. ~ Page 3/4-5-31 DRAFT

6j NOV 1. 91987

' All forced' circulation may be interrupted for maintenance l purposes 'provided that the _ time calculated for CALCULATED BULK

TEMPERATURE - to reach 760 degrees F, ;is not exceeded ' However, if forced circulation is. temporarily restored, a recalculation shall bel performed, based on present conditions, to establish a-

new. time. period _for CALCULATED BULK CORE TEMPERATURE sto reach

760' degrees-F.

Redundant' systems may_also be taken out of service for maintenance or surveillance testing provided that forced circulation is maintained; and the time -to reach - CALCULATED BULK' CORE TEMPERATURE. equal to 760 degrees F may be J recalculated as often as required. Specification _3.0.5 prov. ides the methodology and necessary data .) to determine the--appropriate time interval to reach a 11 . CALCULATED BULK CORE TEMPERATURE of 760 degrees F.- If the active ~ core remains:below this temeprature., which corresponds to..thel design -maximum core. inlet temperature as. indicated above, Ethen the design core inlet. temperature cannot be exceeded and there. can be no damage to fuel:or PCRV-internal components 1regardless'of the amount, including total absence, or reversal, or primary coolant helium flow. x 1 4 v. 1, l I l 1 I l lt 1

p,mr ] ^ + Amendment No'. 1 g' L ' 'Page 3/4 6-18, 3, pgg M DRAFT 1 4.c PCRV AND CONFINEMENT' SYSTEMS. .NOV1 9 g 1 - 3/4'.6.2 REACTOR -PLANT ' COOLING ^ WATER /PCRV LINER ~ COOLING SYSTEM - iOPERATING. ( , [. 9 LIMITING CONDITION;FOR OPERATION 4 s 3.6.2.1-The ' ' React'o'r Plant Cooling Water. (RPCW)/PCRV Liner (.y? , Cooling System (LCS) shall be OPERABLE with: a. Two.'(2) loops operating each with at least one heat = exchanger.and;one pump operating;- b. At.least three -(3)-out of. any four (4) adjacent tubes on the core support: floor side wall', core support floor

bottom ; casing,-:PCRV cavity liner sidewalls and PCRV cavity-liner. bottom head shall.be operating; c.

At.' least. five (5) out of any six (6) adjacent tubes on the PCRV. cavity liner top. head and core support floor . top casing shall be" operating, and 4 .d. ' Tubes-adjacent. to a non-operating tube shall be ~ operating. APPLICABILITY: LPOWER,uLOW POWER, STARTUP*, SHUTDOWN *, and REFUELING

• ACTION

/a, With. only one'(1) RPCW/PCRV LCS loop operating, ensure both' heat exchangers are. operating.. in-the operating

loop, restore the sacond loop to operating within 48 hours or be in SHUTDOWN within the following 12 Lhours and suspend all operations' involving positive reactivity changes. Without both heat exchangers in the operating loop.. operating or without any liner cooling system loop flow be:in SHUTDOWN within 15 minutes and suspend all operations-involving control rod movements resulting in positive reactivity changes, k

Wh'enever CALCULATED BULK CORE TEMPERATURE is greater than 760-degrees F. 'i Y 4 ___.___._.-2..

m. ,m hg . Amendment No. pm, ,, - ^ - Page 3/4 6-1g (y,, DRAFT w. a NOV191987 a m ib'..- Wi th' less :than'the above required number of PCRV Liner Cooling System. tubes' operating, other than as in ACTION j a'.-above, restore the required tubes to operating status + u within 24 hours or..be'in SHUT 00WN~within the following. -24 hours and. suspend all operations: involving positive-reactivity. changes. g,- 1 SURVEILLANCE REQUIREMENTS (, 4.6.'2.1 The~ RPCW/PCRV Liner Cooling. System shall be demonstrated-OPERABLE: -i s a. At least'once per 24. hours, by verifying that each PCRV. Liner Cooling System loop is. circulating cooling water.

at a flow. rate greater than 1100 gpm.

b. At least once per 31. days, by verifying that. liner cooling.. tube outlet temperature readings and their . respective inlet. header. temperatures (for an operating . loop) are within'one of the following limits: l. 30)Jdegrees F temperature rise for tubes cooling top head penetrations; {. '2. 20' degrees F. temperature rise'for all other zones 'except. tubes specified below; 3. Exceptions a) Core Outlet Thermocouple Penetrations Tube Delta T 7593 23 degrees F b) Core Barrel Seal / Core Support Floor Area m Tube Delta T F12T46 47 degrees F F7T43 39 degrees F F6T44 43 degrees F j F11T45 38 degrees F l' F5T47 46 degrees F j l l 1 L

c m- ' ic; - [ (qs;,

4. 9.,g..,

VD , Amendment!No. .s y P, ', . i Page - 3/4 : 6-20 t Gi DRAFT

e -

', + w '

c)1Pefiph'eral. Seal.

NOV1~9 W' y,+ ,uc, g.: [Tubei Delta T' ,..U 1 ~ 4: 359_ 23_ degrees F 4 '4S188 23 'egrees F' d J 4510-23 degrees F- ~ ~+ 35187 23 degrees F ~ --If_ the tube 1 temperature rise for any. liner cooling tube "i ^~ is not:available due to an instrument failure', the tube may:be considered OPERABLE _1f two tubesion both sides of the tube with an: instrument failure'(4 tubes total) ~ are F o, within _their respective temperature limits'as specified ' above.

o c'.

-At least.ont'e per REFUELING CYCLE by: L,v,9:' 1. Performing: a.;LCS redistribute mode functional test-to' verify the' capability'of rerouting most of :the 2, fcooling. water to the upper side walls and the top head. Le > P 20 Performing' _a functional-test 'to verify the capability to increase the PCRV. surge tank' pressure Lto;30>psig by adding helium to the tank." 1-g1 1 i D, 1 4, tif i I .[_ _ ;I i O :b_ : -

+ Amendment No. j.7 <

• Page;3/4 6-2L a.

$;M DRAFT 5 ~%a " oz PCRV AND CONFINEMENT SYSTEMS" NOV 191987; 9 3/4.6.2T REACTOR > PLANT-COOLING W'ATER/PCRV -LINER COOLING' SYSTEM - !" i LSHUTDOWN: 1 7 LIMITING. CONDITIONS FOR-OPERATIONS' (a, 3.6'.'2.2 The = Reactor Plant Cooling Water' (RPCW)/PCRV Liner Cooling-w System- (LCS) shall be OPERABLE with one RPCW/PCRV LCS loop operating ;withs.at least one heat exchanger and one pump in r each-loop operating. "3 APPLICABILITY STARTUP*#, SHUTDOWN *#, and REFUELING *# ~ ACTION: With no RPCW/PCRV LCS loop' operating, a. And with forced circulation maintained, restore at least one < loop.to operating-status prior to reaching a CALCULATED BULK CORE TEMPERATURE of 760 degrees F, or suspend all operations involving CORE ALTERATIONS or y control-rod movements resulting in positive reactivity. changes. n

b. -And with no forced circulation, be;in at least SHUTDOWN-within 10 minutes, and restore at least one loop to

' operating status. prior to reaching a CALCULATED BULK CORE TEMPERATURE. of 760 degrees F, or suspend all operations involving. CORE ALTERATIONS or control rod movements resulting in positive reactivity changes. SURVEILLANCE REQUIREMENTS 4.6 2.2 No-additional surveillance requirements other than those identified per Specification 4.6.2.1. Whenever CALCULATED BULK CORE TEMEPRATURE is less than or equal to 760 degrees F. The core support floor zone of the PCRV Liner Cooling System may be' valved out when PCRV' pressure is less than or equal to 150 ' psia and-CORE AVERAGE INLET TEMPERATURE is less than or equal to j + 200 degr'ees F., 4

p -- %gy W",', c Amendmont No. Page 3/4 6-22 m L" ..4;" DRAFT l' BASIS FOR SPECIFICATION LCO 3.6.2 / SR 4.6.2: NOV 191987

During;. operation. at POWER,- two PCRV-liner cooling system loops

'iare required.to maintain PCRV' liner cooling system temperatures f .and: stresses within the FSAR design limits'(FSAR Section 5.9.2., Thermal' Barrier and. Liner Cooling System Design and Design-Evaluation). Analytical calculations in support of the PCRV ' Liner. Cooling System design (FSAR Section 5.9.2.4) demonstrate -that operation at full power with one cooling loop for 48 hours m csatisfies the criterion which specifies.a maximum temperature increase-' of 20 degrees F in the bulk temperature of the PCRV concrete. Operation on. one loop during a. loss of forced r; circulation' accident using a PCRV ; liner cooldown with an increased liner. cooling water system cover pressure of 30 psig .may result. in temperature rises across individual cooling tubes of'240 degrees'F (outlet temperature of approximately 340 degrees F). These conditions result in acceptable liner cooling for this analyzed condition and PCRV structural integrity is preserved (FSAR Section 0.1.2.1 5). The liner.. cooling tubes are spaced in such a manner as to limit local. concrete temperatures adjacent to the liner to 150 degrees F. However,' potential failures of cooling tubes were analyzed .and their limits-follow. PCRV. liner cooling' tube failures, whether the result of leakage Lor: blocking, do..not affect the integrity of the.PCRV as long as such a failure is limited to a single tube in any set of four

adjacent tubes'on the PCRV cavity side walls, PCRV cavity bottom casing, ; core support-floor side wall or core support floor liner bottom head,

or a singlectube in any set of six adjacent tubes on i

the PCRV cavity; liner top head and core support ficor top casing. A failed: tube which doubles back on itself is considered a single tube failure. In these cases, the local temperature in the concrete would be-less than 250. degrees F (during normal two loop operation), an allowable and acceptable concrete temperature

( FSAR 5.9.2. 3. ).

Operation' of the PCRV liner cooling system during startup testing disclosed hot spots on the liner. These locations were identified and analyzed in the above FSAR Sections. The engineering evaluation indicated that operation with the hot spots would not compromise PCRV integrity and continued operation is acceptable. The temperature limits of the tubes associated with the hot' spots are'specified separately as they were analyzed i specifically for each hot' spot. Only four of the seven hot spots have. liner cooling tubes which may have temperature rises greater than 20 degrees F. _______a

q e*' m Amendment No. Page 3/4 6-23 gg 4 NOV 191987 The. ACTION. times - specified for ' recovery of two operating loops j comes'from analyses described in FSAR Section 5.9.2.4, i.e., 48 hours operation on' one loop before temperature of the bulk' concrete would rise 20 degrees F. With the-number of cooling tubes..less-than required, a 24 hour action time is sufficient to identify and restore the tube to cierating status (if' possible) .or. SHUTDOWN.to make permanent.repa rs. i The surveillance (s) and their respective intervals are specified to verify-operability of the liner cooling system. . Components 'and = features of the reactor plant cooling water system that are not safety related do not affect LCS operability. The ISI/IST ~ program at Fort St. Vrain verifies OPERABILITY of those barriers .that. separate safety and non-safety related portions of the system. A 24 hour surveillance on system flow rates provides additional verification of flow as process alarms monitor flow continuously-in.each ~ liner cooling loop. Individual tube i failures would be expected to-occur slowly, thus a 31 day SURVEILLANCE INTERVAL will detect tube failures in time to take corrective ~ action., -With: CALCULATED ' BULK CORE TEMPERATURE less than or equal to 760 degrees F, one operating liner cooling system loop is acceptable without. single failure. consideration on the basis of the stable reactivity condition..of the reactor and the limited core cooling ' requirements. When ~the PCRV pressure is less than 150 psia and.CCRE AVERAGE INLET' TEMPERATURE is less than 200 degrees F, the core support floor. zones of the-liner cooling system may.be valved out as concrete temperatures will be less. than the 250 degree FSAR -limitation. Thus, leaking liner cooling tubes which are awaiting repairs will not contribute to potential moisture ingress into the primary system. 'In. Surveillance Requirement'4.6.2.1.b., tube outlet temperatures are determined by thermocouple readings. In the event of an instrument failure (i.e., ~ thermocouple is thought to be a . failed),'the tube with the failed thermocouple may be considered OPERABLE' if-thermocouple readings for two adjacent tubes on either side of that tube'are within their respective temperature limits. If the ' tube itself failed rather than the thermocouple, then the temperature of adjacent tubes would be expected to rise. Thus, a failed thermocouple can be identified vs an actual tube failure. Power operation may continue until such time as the thermocouple. can 'oe repaired or replaced as long as the total of four adjacent tubes (two on either side of the tube with the failed instrument)' are within their respective temperature

limits, e

%i Amendment No. /D Page 3/4 6-24 7 DRAFT e m y 3.: y .The use'.of :760 degrees F CALCULATED BULK CORE TEMPERATURE as a division'between the APPLICABILITY of Specification 3.6.2.1 and a

3.6.2.2*is explained as follows

In' the FSV HTGR, the limiting parameter of interest is a core ' inlet temperature greater than 760 degrees F. The CALCULATED ' BULK CORE TEMPERATURE. is a conservative calculation of the maximum. potential temperature' in the core and surrounding components. The conservatism are such that if the CALCULATED A BULK CORE TEMPERATURE is limited to 760 degrees F, the design inlet temperature of 760 degrees F.is'not exce'eded. Systems used for accident prevention'and mitigation are required to satisfy -l the single failure criterion whenever. CALCULATED BULK CORE TEMPERATURE. is l greater than 760 degrees F. However, when CALCULATED ' BULK CORE ' TEMPERATURE is equal to or less'than 760 1 - degrees F, it is acceptab1'e to require only one OPERABLE system 1 - required. for: accident prevention and mitigation is acceptable without single. failure consideration, on the basis of the limited ! core. cooling requirements. ' 11 forced -circulation may be -interrupted.for maintenance , purposes.provided that the time calculated for CALCULATED BULK - CORE TEMPERATURE.'to reach 760- degrees F is not exceeded. 'However,._ifL forced circulation is temporarily restored, a . recalculation can_ be performed as required based on present plant

conditions, to establish-a new time period for CALCULATED fjuLK l

CORE TEMPERATURE to reach 760 degrees F. Redundant systems may <also be taken out of service for maintenance or surveillance 1 testing provided that forced circulation is maintained. The time to reach CALCULATED BULK CORE TEMPERATURE equal to 760 degrees F may be recalculated as often as required. 4 Specification 3.0.5.provides the methodology and necessary data to determine the. appropriate time' interval to reach a CALCULATED ' BULK CORE TEMPERATURE-of 760 degrees F. If the acityt core remains below this temperature, which corresponds to the design maximum core inlet temperture as indicated above, then the design core inlet temperature cannot be exceeded and there can be no damage to fuel or PCRV ~ internal components regardless of the amount, including total absence, or reveral, or primary coolant 2 helium flow. l l l

mm7 4' ' Amendment.No.

t{ "

~ Page 3/4 6-25 { = DRAFT i \\ NOV 1 g 1997' 4 PCRV.AND' CONFINEMENT SYSTEMS' 3 -l 3/4.6;3' REACTOR PLANT' COOLING ' WATER /PCRV-LINER COOLING SYSTEM TEMPERATURES LIMITING CONDITIONS'FOR OPERATION l I.6.3? The 'RPCW/PCRV Liner Cool'ing System'(LCS) temperatures shall be 3 maintained within the following limits: m a, The. maximum' average ' temperature difference between the common PCRV cooling water discharge temperature and the 'PCRV' external concrete surface temperature shall not exceed 50 degrees F. I ,e b.' The . maximum PCRV'. Liner. Cooling-System water-outlet temperature'shall not exceed 120 degrees F.

c..The ' maximum. change of the weekly average PCRV concrete-

. temperature.shall not exceed 14' degrees F per week.

d. 'The. maximum-temperature difference-across the RPCW/PCRV Liner Cooling Water ' Heat Exchanger (LCS portion) shall not exceed 20 degrees F.

l

e. ~The minimum average LCS water temperature shall be greater z

than or equal to 100 degrees F. J i ' APPLICABILITY:'At all' times' ACTION: j With any of the above limits. not satisfied, restore the i limit (s) within 24 hours, or be in SHUTOOWN or REFUELING l within the next-24 hours, and suspend all operations involving CORE ALTERATIONS control rod movements resulting in positive reactivity changes, or movement of IRRADIATED FUEL. 1 l c lN_--_

7--__. ~ "' " 'ygp . Amendment: No. WS4 ~ Page 3/4 6-26 DRAFT ny k!htl '~'2 .NOV1 9 gg7 SURVEILLANCE REQUIREMENTS m ig Tr P., ~ ~ 1.623 7The lRPCW/PCRV?: Liner.__ Cooling System ' temperatures shall be j 'f', demonstrated.to.be within their respective' _ limits ~ at 'least -once per 24 hours by: m - r. ppm . Verifying that'the maximum temperature difference averaged a. 'l over a 24: hour period between the PCRV external concrete surface temperature and the common PCRV cooling water . discharge' temperature in'each=. loop' does--~ not _ exceed 50' degrees F. n b. Verifying that the-maximum PCRV liner.-cooling water outlet l Temperature;does;not' exceed 120 degrees;F.as measured by

E PCRV liner cooling water outlet temperature. in each loop, i

m - c. ' Verifying ;( that._. the change - in pCRV concrete temperature ~ l ,y does not' exceed 14' degrees F per week as indicated by. the s weekly ~iaverage water temperature measured at'the common PCRV. cooling water outletLtemperature in each loop. The weekly. average water = temperature.is-determined by g computing _the arithmetical.mean. of 7 temperatures, r . representing eact-of -the last 7_' days of common PCRV-cooling water yutlet temperatures'in each loop. Each day + ~ results' in. a new ' computation'of a weekly average water s g temperature. The new weekly average is then compared to-the' weekly average.water temperature computed 7 days earlier toLverifyfthe~ limit of? Specification'3.6.3.c.

w d.

Verifying -that ~the maximum delta T across the RPCW/PCRV

Liner Cooling Systen heat. exchanger does not exceed 20 degrees-F as measured by the PCRV heat exchanger outlet

-temperature and the common PCRV liner cooling water outlet a;

temperature infeach

loop, e.

Verifying-that.. the ' minimum average water temperature of m the PCRV Liner' Cooling System is. greater than or equal to 100 degrees F as measured by the average of the PCRV Liner ' Cooling System heat exchanger (LCS side) inlet and outlet temperatures. l u l il 1 l

7, x. Amendment No. y

g Page' 3/4 6-27 m

p qw DRAFT a BASIS FOR SPECIFICATION LC0 3.6.3/ SR 4.6.3 NOV191Fl Thec temperature ~ limits associated with' the' Liner Cooling- . System-are not specifically discussed in' the 'FSAR. Various-FSARL sections' including 5.7, 5.9, 5.12, and 9.7 discuss (~ general! design _ limits.of the' liner and PCRV concrete. .The~ 'PCRV. liner and.-its associated cooling system. assist' in .i . maintaining' integrity of the.PCRV concrete. PCRV : bulk. concrete temperature.is not measured directly. The PCRV, Liner Cooling System temperatures and' their specified frequency,of measurement ensure that thermal stresses on the i !PCRV concrete and liner are within FSAR analyses described above and that PCRV integrity is maintained. o Since 1the PCRV concrete has a large thermal mass and inertia, 1 temperatures would. be expected' to-respond very slowly to any 1 -changes in-the specified parameters. A 24 hour restoration and-ACTION time is consistent with the expected slow temperature response of the PCRV. As a precaution, the plant 'would be SHUTDOWN and/or remain-in REFUELING mode until ' temperatures were stabilized. u 4 I i i ..-m

k, s, to-P-87410 1 b RE-DRAFTED TECHNICAL SPECIFICATIONS FOR SUPPORT FUNCTIONS {

un

6 t

' Amendment No. M. W. % Page 1-1 T J,, V ' DRAFT nu [E ' DEFINITIONS gy j g g pgp pi g4 g x, The": defined. terms of'this section appear in capitalized type and are. I v. Lapplicable throughout these> Technical Specifications.

ACTION 4f',4

[3',3 ' ACTION.. shall' be,that part of'a Specification which prescribes remedial' measures required under designated conditions,- ACTUATION LOGIC-TEST 1.2 An ACTUATION' LOGIC. TEST shall be the application of various w 1 simulated' input combinations, considering system design, in f conjunction with each possible -interlock' logic state and verification of the required logic output. ALLOWABLE VALUE 1~3. The. ALLOWABLE VALUE shall be the least conservative acceptabie "as found" value for a' TRIP SETPOINT. BASES' (BASIS) 1 .< r 1.4

The BASES shall summarize the reasons for the SAFETY LIMIT, the

~ LIMITING SAFETY SYSTEM SETTINGS, the Limiting Condition of Operation,.and the Surveillance Requirements, In accordance with 10:CFR 50.36, the' BASES are not a part of the Technical ' Specifications; CAL'CULATED BULK CORE TEMPERATURE 1.5-The CALCULATE 0' BULK CORE TEMPERATURE shall be the calculated average temperature of the core, including graphite and fuel but not;.the reflector,- assuming a loss of all forced

circulation of primary coolant flow.

Use of the CALCULATED BULK CORE-TEMPERATURE-is explained in Specification 3.0.5. CHANNEL CALIBRATION 1.6- -A CHANNEL CALIBRATION shall be the adjustment, as necessary, of

the channel such that it responds within the required range and with--the required accuracy to known values of input. The E

CHANNEL ' CALIBRATION shall encompass the entire

channel, considering system design, including the sensors and alarm, interlock and/or trip functions and may be performed by any c

D series of sequential, overlapping, or total channel steps such that the entire. channel is calibrated.

$3s M Amendment'No. Page.1-5 j ~ DEFINITIONS DRAFT i y. NOV 1.91987 o j OPERABLE' !OPERABILI'TYi j 11.. 221 A 1 : system, ' subsystem, strain, component 'or. device shall be OPERABLETor have 0PERABILITY when it is capable ' of' performing-Lits,.specified"Esafety. function (s), and: when all 'necessary jattendant instrumentation,'s controls, electrical-power, cooling or 'seali water, lubrication or other, auxiliary equipment that l lape Lrequired for the system, subsystem,- train, component,.or l ' device, to ' perform its safety function (s) are also capable of b# performing-their. ~ uated.suppCit function (s). Nonessential-r W . portions. of: 'a ' system,- subsystem, train, component'or device need:not be operational.provided-that.'the. specified safety.- - function'is maintained. m . 0PERATIONAL MODE MODE E 1.23' L An ' OPERATIONAL; MODE ' (i.s. aMODE) s' hall correspond' to any one - W - inclusive combination of Reactor Mode Switch Setting, Interlock - ~ zSequence Switch. Setting, and W RATED.. THERMAL POWER, specified- ~ ' in: Table 1.1. a . PHYSICS: TESTS

1.24! PHYSICS TESTS shall-be' those tests performed to measure the

.g fundamental nuclear characteristics of the reactor core and ~.related' instrumentation'and (1) described in Chapter 13 of the FSAR,"(2) authorized under the provisions of 10 CFR 50.59, or (3) otherwise. approved by.the Commisy9n. PLANTPROTECTIVESYSTEM('NS) P 1.25.The . PLANT PROTECTIyE: cSYSTEM (PPS) shall be the reactor i protective circuitry and the circuitry that protects various -plant components from' major. damage. This system initiates: (1) t . scram,:(2): loop: shutdown, (3) circulator trip, and (4) rod withdrawal ' prohibit functions, as addressed in Specification 13/4.3.1. POWER-TO-FLOW RATIO (P/F) 41'26' POWER-TO-FLOW: RATIO'(P/F) shall be' the percentage of RATED LTHERMAL PCWER divided by the percentage of design PRIMARY l COOLANT FLOW at RATED THERMAL POWER. -m._.- ] i_.'.___.__mi___

r~; x pm Amendment No. g1' r eage.1-7 jg s,g fa l DEFINITIONS NOV-191987L J REPORTABLE EVENT .1.'322 j REPORTABLEc EVENT!.shall be any of those conditions specified A b Sin Sections:50i72'and 50.73:of 10 CFR Part 50. 4 b . SAFE SHUTDOWN COOLING: J1:!33 SAFE " SHUTDOWN. COOLING shall be ~the removal of core stored ~ energy.and decay heat.using SAFE SHUTDOWN' COOLING Lequipment. <Thisi equipment ' includes those systems and components involved ^in' supplying Firewater to.the. steam generators and helium-circulator, water turbine drives' as described in Specification. 3/4s5;.The ' reactivity ' condition in the. core during. SAFE SHUTDOWN COOLING shall.be subcritical (keff less than or equal-N

to 0.99).

Q 4 ~ SAFETY ' LIMIT.. L1.34s'SAFETYf LIMIT (S) shall be limitations.on. process variables'as ' identified;in Specification 2'.1' These limitations are defined E o protect the fuel particle integrity and the integrity of the t ' primary coolant system boundaries. [ fSHUTDOWNMARGIN~ r ([ L1.35c SHUTDOWN MARGIN shall be the instantaneous amount of reactivity . by which the-reactor is subcritical, or would be suberitical 'from; its present condition assuming that'all OPERABLE control s p' rod pairs are fully inserted, except for the single control rod pair-of; highest reactivity worth capable of being withdrawn, which is assumed'to:be fully withdrawn. g

SITE BOUNDARY.

v s 11.36-The SITE. BOUNDARY shall be that line beyond which the land is L b neither owned, nor leased, nor otherwise controlled by the licensee. STAGGERED. TEST BASIS -1.37' A STAGGERED TEST BASIS shall consist of: a. A. test' schedule' for "n" systems, subsystems, trains, or other designated components obtained by dividing the -specified test interval into "n" equal sub-intervals, and i The testing of one system, subsystem, train, or other designated component at the beginning of each sub-interval. O

p mg, s 'l 1 y' Amendment'No. ) + (u s a,; l Page 3/4,7 - 13 J -,,W {s DRAFT .P_LANT AND SAFE SHUT 00WN COOLING SUPPORT SYSTEMS gjgg 1..,k, i3/4.7.1' TURBINE CYCLE.- t" .BOILERiFEED PUMPS. 9 4, M {I LIMITINGlCONDITION'FOR OPERATION ~ t,; 1 '3.7.1.1 Two of the three' boiler feed pumps shall be OPERABLE in any {f 'of'the following combinations: 1 l'a ; The motor driven boiler' feed pump (P-3102) OPERABLE and one of the turbine driven boiler feed pumps. (P-3101 or y. 'P-3103) 0PERABLE, or - b; Two turbine driven boiler. feed pumps (P-3101 and P-3103) + OPERABLE and either auxiliary. boiler OPERATING. y . APPLICABILITY

4. POWER, LOW POWER,.STARTUP*, SHUT 00WN*, and REFUELING

• 8 m ACTION: With--noneLof: the above combinations OPERABLE, restore either

of the above combinations to OPERABLE status within 72 hours or

F a.~:When in POWER, LOW POWER or'STARTUP, be, in at least , SHUTDOWN within.the next'24 hours, or' 'b. When.in SHUT 00WN, or REFUELING, suspend all operations involving CORE. ALTERATIONS or control rod movements resulting in positive reactivity changes. -SURVEILLANCE REQUIREMENTS (?- 4.7.1.1. At least once per REFUELING cycle, the boiler feed pumps shall be demonstrated OPERABLE by driving two helium circulators. simultaneous 1y, at an equivalent 8000 rpm (at ' atmospheric. pressure),- on the water turoines using the emergency feedwater header. This testing may be performed in conjunction with Specification SR 4.5.1.1.a. '

• With CALCULATED BULK CORE TEMPERATURE greater than 7e0 degrees F.

4 f T u _.

yy WAf

1. 4 Amendment No.

E page 3/4 7 < w DRAFT-BASIS FOR SPECIFICATION LCO 3.7.1.1'/:SR 4.7.1.1 gjgg Any one' ' of ' the boiler ' feed ~ pumps' can supply - feedwater for Lhelium circulator motive power and steam Lgenerator heat. r'emoval. The boiler feed pumps are' not_ SAFE SHUTDOWN-COOLING equipment. Emergency feedwater is required.only in othe depressurization accident (DBA-2) as discussed in FSAR ~ Section 14'11.. The : requirement for both a motor driven and. .a1 ' turbine ' driven boiler. feed pump provides redundancy in > equipment.and diversity in drive. power source. Requiring a combination..of two boiler feef pumps with a backup steam t supply if the two ' steam driven pumps are used provides additional: redundant capability fo'r safe shutdown. cooling. Either' auxiliary _ boiler will provide adequate steam-supply- .for ' driving 'the-turbine-driven boiler feed pumps if the motor-driven boiler feed pump is inoperable. . Normal steam 3-supply for the turbine-driven boiler feed pumps is-provided via the cold reheat piping. -The auxiliary boilers provide addi.tional motive capability-for these. pumps in the event normal steam' sources are unavailable. When the motor driven boiler,. feed. pump is.0PERABLE, sufficient diversity in drive " power. sources:is ensured and the auxiliary ' boiler. is not required.

Analyses performed for High Energy Line Breaks

demon:trate that the most limiting time -for restart

'o f . forced circulation-following <DBA-2 is 60 minutes (FSAR section 14.11.2.2). In ?the'.FSV HTGR, the limiting parameter of interest is a Lcore 1.nlet temperature greater then 760 degrees F. The

CALCULATED

~ BULK CORE TEMPERATURE is a conservative

calculation of the maximum potential'. temperature in the core

..and surrounding components. The conservatism are such that if the, CALCULATED BULK CORE TEMPERATURE is limited to 760 degrees. FJ the design inlet temperature of 760 degrees F is not excee'ded. Systems used :for ' accident prevention and a mitigation: are: required to satisfy the single failure -criterion whenever CALCULATED BULK CORE TEMPERATURE is , greater -than 760 degrees F. However, when CALCULATED BULK CORE TEM.PERATURE is. equal to cr less than 760 degrees F, it is acceptable to require only one 0PERABLE system for accident prevention and mitigation without single failure consideration, on the basis of the limited core cooling requirements. l 1 l i i I

g;p - A ^- R Amendment No. M Page-3/4 7 - 3 J di ' DRAFT ~ O-may be interrupted for maintenance $1 g 1997 y. All. forced circulation . purposes provided:that the time calculated for CALCULATED e, BULK. CORE TEMPERATURE.to reach 760 degrees F 'is ;not ~, exceeded..However,zif._ forced _ circulation isi temporarily. .m restored,. a1 recalculation shall be performed,-; based on

present conditions, to establish a new time period: for

' CALCULATED BULK CORE TEMPERATURE to reach 760. degrees F. Redundant systems may also.be. takeni out of service -for maintenance or. surveillance. testing provided that forced' . circulation is~ maintained; the time to reach' CALCULATED BULK V ~ CORE. TEMPERATURE equal.to 760 degrees F may be recalculated - as often as required. . Specification: 3.0.5 provides the methodology and necessary ~' data to determine the appropriate time interval to reach a ' CALCULATED. BULK CORE TEMPERATURE'of_760 degrees F. If the activen core

remains.below this temperature, which corresponds'. to the design maximum core inlet temperature as

indicated abcve, then. the design. core inlet temperature cannot be exceeded and there can be no damage to_ fuel.or PCRV' internal' components regardless of.the amount, including total absence, or reversal, or primary coolant helium flow.

m 1The.. requirement: for the-uoiler'. feed pumps to provide sufficient cooling after DBA-2 ' address a highly incredible event 1. -(FSAR Section_ 14.11.1) and a 72 hour ACTION time _ provides adequate margin should the ; boiler feed' pumps become inoperable. .Other means for cooling are available using condensate or boosted. firewater. coupled with~ physically. . redundant piping, valves and components. The boiler, feed ~ pumps. will be demonstrated OPERABLE by . driving two circulators simultaneously.at an equivalent of '8000 rpm at the--depressurized. condition (FSAR Section 14 11.2). .c ,,u

M Amendment No. Page 3/4.7-12 c. p DRAFT w n' NOV 191987 I [ ~ PLANT AND SAFE SHUTDOWN COOLING SUPPORT SYSTEMS I 3/4.7.1 TURBINE CYCLE- ' SAFETY VALVES --OPERATING . LIMITING CONDITION FOR OPERATION o- -3I7.1.5 a. The steam ' generator superheater (EES) and reheater safety valves,(V-2214, V-2215, V-2216, 'V-2245, V-2246, V-2247, V- "n 2225 and V-2262) shall be OPERABLE with set points in accordance with Table 4.7.1-1, and

b. The provisions of. Specification : 3.0.4 are not applicable-l u'ntil:.72 hours after reaching 25?o RATED THERMAL POWER, to allow testing of the steam generator superheater and reheater safety. valves required _ following maintenance or

'per Surveillance-. Requirements identified in Specification -4;7.1.5. ' A, APPLICABILITY: POWER,' LOW POWER, and STARTUP ACTION: With' one: of the required safety valves inoperable, restore the required valve to OPERABLE status within 72 hours or restrict plant operation as follows:

1. 'With an EES safety valve inoperable, reduce THERMAL POWER to

~ less' than 50?; of RATED THERMAL POWER. I 2. With an~ EES safety valve. inoperable while -in STARTUP, . restrict plant operation to a maximum of two boiler feed pumps. 3. With a reheater safety valve inoperable, be in STARTUP within 12 hours and SHUTDOWN within the next 12 hours. l

.-,; ;- 7. ;., ' 5 :...< r Vh; Amendment No. ," ' _i m Page 3/4.7-13c E;, > ' ', h

c. ;

g-DRAFT %r.:c . O 1 9 1987 ' h..k' SURVEILLANCE' REQUIREMENTS-p.: .:z,. - m .4.7.1;5 The f. safety valves.'shall be demonstrated.0PERABLE prior.to ~ 1 exceeding 25% ~ RATED -THERMAL--POWER.'unless. completed in.the rprevioust five.: years; by. testingL the superheater and reheater

safetyi< valves. as required by. Specification.4.0.4,,.and. by-

.. e ' Lverifyingithe 11ftlsetd ogs'.as:specified in Table'4.7.1-1. 3 + ),.y. t,' t.1 M ( {. [j I. ' T 5 z {t (

[ '~ ';'.y- ', ; kmendme'n't Noi'. <;,,y (@!c@ ': Page 3/4.7-14 r y + n~. -DRAFT m ..;n .e (g-P WV 191987 n m.x w ~b4 +w . TABLE - 4. 7.1-l'~ g N ', 2 '(', ~ STEAM GENERATOR < SAFETY VALVES 4 i Q b1 s / ?-.' [ L' (VALVENUMBER- ' LIFT SETTINGS' g.- iLOOP I e

V-22141

. ~Less than orJequal.to 2917..psig. V-2215-Less-than.or equal to 2846 psig 1 V-2216. 3: 'Less than or equal to 2774 psig 4 V-22251 'Less than or. equal ~to 1133 psig. ~5: ,',x LOOP II; V-2245 Less.than or equal to 2917 psigi E.l. - V-2246J Less than or. equal to 2846 psig 3 ~V-2247: Less.than or equal to 2774 psig. V-2262- .Less than or. equal' to 1133 psig h i i.S j l i t+i; 1 y, 1 l 1 -l ,,,l l

gg;A-Amendment.No. . Page ' 3/4. 7-15 DRAFT-NOV 19L1987 ^ ' PLANT AND SAFE SHUTDOWN COOLING SUPPORT SYSTEMS 3/4.'7.1 ~ TURBINE CYCLE . SAFETY VALVES - SHUTDOWN i LIMITING' CONDITION-FOR OPERATION l 3. 7.1'. 6 - The_ steam-generator superheater or raheater safety valve (s) s.,.. ^ which protect the OPERATING section(s) of the steam generator-shall.Se OPERABLE with' setpoints in accordance with Table 4. 7.1 -l.' - APPLICABILITY: SHUTDOWN and REFUELING ? ACTION: With -less.than the'above required safety valve (s) OPERABLE,. restore the~ required safety valve (s) to OPERABLE status prior-

to reach!ng-'a CALCULATED BULK CORE TEMPERATURE of 760 degrees

. F or. suspend' all operations involving CORE ALTERATIONS or cont rol.- rod movements 'resulting in positive ' reactivity changes.- SURVEILLANCE REQUIREMENTS

4. 7. l. 6.

No additional surveillance required beyond those identifiea per Specification 4.7.1.5. ( 7 li i

x1y : "o Amendment No. g f' Page' 3/4. 7_- 16 7 .j MAP-m NOV 191987 l M BASIS-FOR- -SPECIFICATIONS LCO 3.7.1.5/SR 4.7.1.5 AND LCO. '3.7.1.6/SR 4.7.1.6 o 1 _The economizer-~ evaporator-superheater-(EES) section of each steam generator: loop. is protected by three spring-loaded safety valves, m a

v..

'each with one-third nominal; relieving. capacity of each loop..The i

reheater section'of each steam generator loop is protected from overpressure. ' transients by a single safetv. valve.

These steam l generator' safety.' valves are described in the FSAR, Section. , 2.5.3. j 4 4 The'.above valves are required to be. tested in accordance with '(ASME-Section' XI. IGV.-requirements). every 5.. years -or after ] y O maintenance. To satisfy: theitesting criteria, the valves'must be-J . tested with. steam. 'Since,these valves'are permanently installed in. steam piping, the.' appropriate means-for testing require plant power to be -.in' excess of 22% RATED THERM.R POWER. Thus, the test must be-conducted during LOW POWER. Concitions are specified so.. .as'.to minimize operation a't power until the valves are tested. k Due to the infrequent' required -testing of these valves, the likelihood of aa accident occurring without proper valve' -testing e 6

is consideredcvery small and plant safety is not compromised.

~ During 7all ? MODES, with ~one EES safety valve inoperable,-plant Y { 1operatio'n'is-restricted to a condition for which the remaining safety ' valves.have. sufficient relieving capability to prevent 'overpressurizationLof any steam generator section: (i.e., one u boiler-~. feed' pump'.per operating loop). Conversely, with any 4 reheater safety valve inoperable, plant operation - is restricted to a.'more restrictive Mode. A 72 hour action time for repair or SHUTDOWN due to inoperable safety' valves ensures that these valves are returned to.. service in a relatively, short' period of time, during which an overpressure transient is unlikely. Operation at power for 72 hours 'does not ' result in a significant loss of safety function l for-any extended ' period. The setpoints for the safety valve;, identified in Table 4.7.1-1 are those valves identified in the FSAR with tolerances applied such that the Technical Specifications incorporate an upper bound setpoint. This is consistent with not incorporating normal o L operating limits in these Specifications. I F

19d? ' ' . Amendment flo. ~ h Page 3/4 '7-17 [g DRAFT LPLANT SYSTEMS NOV 191987 E3/4.7.1: TURBINE CYCLE' ~ ' CONDENSATE-PUMPS

LIMITING CONDITION FOR'0PERATION A

3.7.127: At111 east'one of_the.two 12 1/2% condensate pumps (P-3106 or P-31065).shall be OPERABLE. 1O

APPLICABILITY

POWER and LOW POWER r:.

' ACTION: Withf no OPERABLE 12' 1/2% condensate pump, restore at least~ ~ one pump to OPERABLE status;within 72' hours _ be in at or least STARTUP'within the next 24 hours. .,5 SURVEILLANCE REQUIREMENTS 4.7!1'7 There are ~ no additional requirements other than those required by Specification 4~0,5. 1 4

Page' 3/4 7-18 DRAFT BASIS FOR SPECIFICATION LCO 3.7.1.7/SR 4.7.1.7 The condensate pumps are used to assure forced circulation cooling under certain normal and emergency conditions. Condensate is supplied via the emergency condensate header to the helium circulator water turbines and to the steam generator EES or reheater sections. l, The condensate pumps are not SAFE SHUTDOWN COOLING equipment. l 1 There are two 60% condensate pumps and two 12 1/2% condensate pumps. The 12 1/2*; condensate pumps' are addressed in this specification because they are capable of being powered from an essential power bus and would be capable of supplying emergency condensate requirement in the event of a loss of offsite power. (FSAR Section 10.3.?) A l single pump is specified because the condensate pumps are a design feature of FSV. but they are not ultimately relied upon for forced cooling, per the FSAR. The SAFE SHUTDOWN COOLING equipment at FSV relies upon the firewater pumps (see Specification 3/4.5.5) to assure forced cooling (FSAR Sections 14.4.2, 10.3.9). 72 hours is a reasonable period of time to restore an inoperable pump .to operable status, consistent with repair times allowed for SAFE SHUTDOWN COOLING equipment.

t

p[.3_ _ /h +r Amendment-No. ML ^ .Page_3/4 7-32 (

q.. a s

l&., .h 1 / DRAFT { > PLANT ANDiSAFE SHUTDOWN COOLING SUPPORT SYSTEMS. NOV 1 g 1997

3/4;7.-5 PRIMARY. COOLANT DEPRESSURIZATION 1.

LIMITING CONDITION FOR. OPERATION-

, + p P '3!7.5 -a. ..Two flow p~aths.for primary coolant depressurization shall 1 ,be OPERABLE, each from the primary coolant system through a1 helium purification train to the reactor. building- . ventilation system exhaust. b. 'At least -650 gallons. of. liquid nitrogen shall 'be 7-maintained'in the liquid nitrogen storage tank (T-2501). ' APPLICABILITY:. POWER,. LOW POWER, and.STARTUP. ? ACTION: W.? ta..W1.th only' one' of the above required helium purification train.depressurization flow paths .0PERABLE due to regeneration of the.second pur$fication train, 1; " Initiate-action to _regenerat2 the second helium -purification train within 24 hours of its removal from service'and restore it to 0FERABLE itatus within the'following 31 days, and 2.- Be-in at least SHUTOOWN within 72 hours af ter either i

failure to regenerate within 31 days or. loss of an

. OPERABLE.depressurization flow path per ACTION a.2. 3. The-provisions of Specification 3.0.4 are not applicable. .. b~ With only one of the above required helium purification train. depressurization flow paths OPERABLE other than due

to regeneration, restore two purification train flow paths s

to OPERABLE status within 7-days, or be in at least SHUTDOWN within the next 24 hours. 4 i L L.. ' n ^' ~_--a_

F;;gt_ ;-p-m---- - - - - - - - - ~ ' - ~ ~~' = - - - + ' Amendment No. %s j 1 Page 3/4'7 > . DRAFT u,,

NOV19tgg7

.With'none:-of' the?.: required helium purification ' train ^ c, f ' depressurization flow' paths OPERABLE: 3 s .1. . Restore" at leastione'trainito OPERABLE. status within !6 ' .12 hours or be in'at least SHUTDOWN within the n e x t -_ 24.. hours, and 2. Restore-l-a t least two'- . purification-train depressur.ization flow paths to OPERABLE status within-the Lfo11owing 7 days or be :in at least SHUTOOWN. g .within.the next 24 hours.

d. 'With less than ~650. gallons of. liq'uid nitrogen in the nitrogen' storage tank,; restore the liquid nitrogen storage inventory 'to 650; gallons within 24' hours. or be.in.at -least

' SHUTDOWN.within the next 24 hours. ~ 7 ~ SURVEILLANCE REQUIREMENTS , ;a. 1 i I 2 4: 7. 5 l The : 'h'el i um ' purification ' train depressurization flow path (s) shall be demonstrated OPERABLE:

a. "At least. once per'24 hours by verifying that the liquid' '

' nitrogen storage. tank- (T-is01) contains 'at least 650 . gallons of' liquid-nitrogen. . b..At: least once' per.18 months by cycling (through one Lcomplete cycle'of full travel) the. valves for routing helium l gas to the reactor building ventilation exhaust and ..for cooling 'the high temperature filter adsorber (HTFA). D i l i r a I i .__m

y; m'

1 Amendment No. 4p. . Page 3/4 7-34. ,ws t ' DFMFT ~ BASIS.FOR SPECIFICATION LCO 3.7.5 / SR 4.7.5 NOV f 9 887 4;-

The f elium purification l system is a normally operating system h

awith redundant backups and requires no -tests or inspections beyond good' power plant operating and maintenance practices to verify. operability (FSAR Section 9.4.8). In the.unlikelyf event jof an ' accident involving an extended v - Loss Of Forced. Circulation (LOFC), one.. train of the helium

purification system must be OPERABLE to depressurize the primary coolant system.

'Depressurization' is. required to reduce the density of the 3 primary coolant'andlthereby' reduce the heat transfer to the PCRV ' : liner - cooling, system. This. action, combined' with- -.adjustmentsiin the liner cooling system flow distribution and pressure Lensures that the integrity of the PCRV liner is maintained-(FSAR Appendix 0.1.1.1). Thefin~ormal depressurization flow path provides for a filtered . release through the following OPERABLE. components: the high temperature:' filter. adsorber, the helium purification cooler, the helium purification. dryer, the low temperature gas-to gas heat exchancer, the Low Tnperature Adsorber (LTA), purified

heliu'm filter and associated piping and valves leading to the r'eactor. building. exhaust.

In' emergency conditions, a depressurization path may be L established through a regeneration train by bypassing block valve interlocks. This is not a normal flow path, but is an acceptable alternate under emergency conditions..That is, it is the same path as the normal primary coolant depressurization path with the LTA and/or purification system 7 dryeri bypassed.

The LTA would be bypassed because it is cooled by liquid' nitrogen normally and the flow. path may be restricted due : to f reezi ng~.

With the LTA bypassed, the regeneration train-can be effectively used for depressurization of the PCRV and the consequences are still well below 10CFR100 limits, e.g. bounded by the accidents described in FSAR Section 14.11.2.8. If both purification trains are inoperable other compensatory measures (such as reducing-the buffer supply to operating circulators) may be taken to minimize the increase in PCRV pressure during~an LOFC accident. This is acceptable for a limited period of time due to the availability of an alternate -depressurization flow path via the regeneration piping.

hjf!(

j

Amandment. No.'

(Page 3/4 7-35 l t., m g. DRAFT M, NOVi g y G .A ? total ~ of; ? 650.: gallons-. of liquid nitrogen is required to 4 ? EprovideLrefrigeration forithe low temperature adsorber' 'during L.depressurization (FSAR Section 9.6.6)., jThe 'only~ aspect of' system operation that-must be monitored is- ' the 'maintenancefof. the' required quantity of111guid nitrogen,in 'the.::. liquid.(nitrogen, storage tank. andL the: operability of " isolation valves =for routing': helium ' gas-'to the-reactor Lbuilding ventil.ation exhaust ~and for cooling the HTFA. ?The. standby ; pipe ispools for~ emergency' water cooling of the rhelium' cooler.and : charcoal. cooler are. tested. once..'per iREFUELINGE; CYCLE.> These coolers are-used only in the event of' .an. extended 1 css of. forced circulation accident'. The ! coolers. ..are'; disconnected 'and. do. not contain water during normal' ~ ' operation. The coolers are; tested with the' standby: ~ ~ ipe-p spools;; in:! piece fby. an' air. flow test;as construction of the Fy,, l coolers is such that the.sup' ply and ' return piping goes into '~ the.' top Jof: tne. coolers. : Any Lresidual. water would remain in j the U-tube. design..The air flow; test is sufficient to verify proper : installation and ' operation of the pipeispools and , system: cooling. pfping., l . 1l g i + t

y I

i i '[Y 5. 1 A

pr JA-Amendment No. p Page 3/4 9. i. ORAFT FUEL HANDLING AND STORAGE SYSTEMS NOV 191997 J 1 h M. 3/4.9.1-FUEL HANDLING AND MAINTENANCE IN THE' REACTOR us LIMITING CONDITION FOR OPERATION g

3. 9.1' The(following. reactor conditions shall be maintained:

a. .The PCRV shall.be depressurized to atmospheric pressure or slightly below, b. The CORE' AVERAGE INLET TEMPERATURE shall be 165 degrees F or less *, c. The reactivitf of the core shall be continuously monitored by at least two'startup channel neutron flux monitors,** and. n d. The SHUT 00WN MARGIN requirements of Specification 3.1.3 shall be met. APPLICABILITY: Whenever both primary and secondary PCRV closures of any PCRV penetration are removed ' ACTION: a. With -the conditions of a or b above not met, restore the condition (s) to within the above limits within 1 hour, or terminate fuel handling and vessel internal maintenance, retract the fuel handling mechanism or any other remote operated mechanisms from the PCRV, and close the reactor 0 isolation valve or opeMng _through tie PCRV as soon as practicable. b. With one of the above required neutron flux monitors I inoperable, or not operating, immediately suspend all operations involving CORE ALTERATIONS, any evolution resulting in positive reactivity changes,.or movement of ' IRRADIATED FUEL. Applica'ble only when the fuel handling machine is located on the reactor' vessel, with the cask isolation valve and reactor isolation valve open.

• • Applicable only during CORE ALTERATIONS affecting core reactivity.

b

.y x i% Amendment No,' ) Page 3/4 9-2 g .C Nov1g39g7

c..With both of Lthe above required neutron flux monitors inoperable or not operating:

1. 'Immediately suspend all operations involving CORE ALTERATIONS, any evolution-resulting in positive reactivity changes, or movement of IRRADIATED FUEL,

~ 2. Retract' the fuel handling mechanism or any other . remote operated mechanism from the PCRV,. - 3, Close. -the. reactor isolation valve or opening through the PCRV as soon as' practicable, and

4. 'Within 12 hours evaluate the SHUTDOWN MARGIN per Specification 4.1.3 d.

With the -SHUTDOWN MARGIN requirements of Specification e 3.1.3 not met, comply with ACTION c of Specification 3.1.3; l' l SURVEILLANCE REQUIREMENTS 4.9.1~ .The reactor pressure and temperature conditions shall be a. determined to be.within the above limits at least once per 12 hours, b. 'Each startup channel neutron flux monitor shall be demonstrated OPERABLE by performance of: 1. A CHANNEL CHECK at least once per 24 hours,

2. -A CHANNEL FUNCTIONAL TEST within 24 hours prior to the initial start of CORE ALTERATIONS, and 3.

A CHANNEL FUNCTIONAL TEST at least once per 7 days during CORE ALTERATIONS. c. Verification of SHUT 00WN MARGIN shall be in accordance with Specification 4.1.3. u l l l L I

=. M, Amendment No. Y~ 'Page 3/4 9-3 m DRAFT-f; e -BASIS FOR SPECIFICATION'LCO 3.9.1~/ SR 4.9.1 s To prevent the 'outleakage of primary coolant'and potential. release ~of activity during refueling or maintenance in the-reacto'r.' vessel,. the ' reactor must be depressurized and I.;maintainedwithintherequiredconditions.. The CORE AVERAGE INLET TEMPERATURE is limited to. 165 degrees F to prevent short-term pressurization of the fuel handling equipment over 5 psig (the maximum allowable working pressure of.the fuel handling. equipment)'as a result-of accidental inleakage of 1 water into the vessel during refueling. The ~.0PERABILITY of :the neutron flux monitors. ensures that Lredundant monitoring. capability.is available.to detect changes "in;.the' , reactivity condition of the core. (Additional information-is contained in the BASIS for Specification 3.3.1). This specification also' applies to reactor internal-maintenance that does not involve a CORE ALTERATION, such as a

helium ' circulator.changeout or modifications. or repair of the

. primary coolant purification systems.. For this maintenance, -the appropriate portions of..this specification will-apply, but since no' changes are'being made to core reactivity, it is not a' requirement to have, both Startup Channel Flux Monitors. > OPERABLE. TheoACTION statement ensures that reactor and fuel handling machine'will be placed in the safest configuration as soon as practicable, if a ' required condition cannnt be maintained. The Surveillance Requirement freauency gives adequate assurance that changes in reactor conditions will be detected in~ time.to permit corrective actions if required. L i--. =

>y . _.. ? ~ to P-87410 RESPONSE TO NRC COMMENTS REGARDING SAFETY RELATED COOLING FUNCTION DRAFT TECHNICAL SPECIFICATIONS (CONTAINED IN G-87131) l ) l

m l i 4-RESPONSE TO NRC COMMENTS This attachment addresses comments provided in NRC letter dated April 17, 1987 (G-87131). For the most part, the NRC comments have been repeated 'in their entirety. A few of the more lengthy comments have been summarized, i . Comment categories used in this Attachment are as folicws: A: PSC accepts comment es proposed A# PSC accepts comment with some changes or provides new wording B NRC accepts PSC position C NRC accepts-PSC position and PSC will justify D PSC will review further D* NRC~will review further F Comment is beyond scope of TSUP l l l 1 ___.____.m..

g NRC Comment: Definition 1.34 (SAFE SHUTDOWN CODLING)- PSC needs to be definitive and specific with regard to the use of Safe Shutdown Equipment referred to in this definition and with . regard. to what constitutes the list of Safe Shutdown Equipment per i the FSAR. PSC needs to clarify these points within DEFINITION 1,34 (in-.the NRC markup of final draft). The current wording of this definition implies that safe shutdown equipment includes whatever PSC so-chooses to include as such 'in TSUP draft Section 3/4.5. -Therefore, this definition needs to be modified to be-consistent with the FSAR Section 1.4 definition of Safe Shutdown Equipment. PSC Response: PSC agrees that Definition 1.34 requires clarification. Safe Shutdown Equipment is most correctly defined by the list in Table 1.4-2 of the UFSAR. As ~ i s -;shown in the' specification markup, PSC proposes to describe Safe. Shutdown Equipment by its design intent. PSC considers the remainder of the comment on this definition to be beyond the TSUP scope, as it requests clarifications or additions to the FSAR. Resciution: A l l l 1 l i l - _-

- r7~-r q y

95

.1.. .NRC-Comment: Table 1.1 #1 PSC has chosen to use the value of the CALCULATED BULK CORE . TEMPERATURE within the TSU! draft to demarcate.the need for redundancy requirements among safety-related cooling components within1the SHUTDOWN mode. The process of making distinctions.between the operating modes would appear to be better-served by using the limiting value of the CALCULATED CORE BULK TEMPERATURE, namely, above or below 760 degrees F, to mark the transition from HOT SHUTDOWN to ~ COLD SHUTDOWN similar to the W-STS. This demarcation should perhaps also -be made contingent upon PCRV pressure, such as above or below 100. psia. PSC Response: PSC notes that the Calculated Bul k Core Temperature is a time dependent variable that assumes a loss of forced circulation. During any operating mode, it is possible to stop forced circulation and eventually reach a bulk core temperature of 760 degrees F. The point is that with lower decay heat levels, it takes longer. PSC uses the calculated time for the bulk core temperature to reach 760 degrees F to -determine when to schedule maintenance or testing that may require, or that may present a risk of creating a loss of forced circulation. It is not a monitored parameter that can be observed and used to determine an operating mode condition. Regarding PCRV pressure, this is also not a positive indicator of operating mode because:the PCRV can be depressarized below 100 psia in either. the Shutdown or Refueling modes and it is not a required condition for either mode. (Note that the February 20, 1987 markup of LCO 3.9.1 revised the applicability of the depressurized requirements to only when primary and secondary closures are removed, not to the entire Refueling mode.) PSC agreed to revise the Applicability of all specifications that reference the Calculated Bulk Core Temperature for the Shutdown mode, to add. applicability to the Refueling mode. Additionally, PSC agreed to provide a report to clarify what interlocks are defeated by the Interlock Sequence Switch during switch position changes. Resolution: A#

l

o ' :p; .a 1 I,[a' Table.1 1.#2' i

NRC Comment

(In. LCOL3.9.I', the REFUELING mode is furthe~r defined by the condition of. having the CORE AVERAGE: INLET TEMPERATURE zbelow 165 degrees F.

.Why is this condition.not given in Table 1.1 so as to be readily Lapparent

as a' Iso ~ pplying to all' LCOs.with' REFUELING" listed in the a

1 APPLICABILITY statement?: Also, what is:the value of the CALCULATED BULK-- CORE TEMPERATURE supposed -to be during REFUELING? Such

APPLICABILITY = conditions should.be' made explicit. and direct.

s PSC Response: The February f 20,1987: draft of ~ the -Tech Specs (P-87063) revised LCO <3.9.1 tordelet'e:the Refueling mode condition from the Applicability. .LCO 3.9.1 conditions are more appropriately applied whenever the PCRV . primary.and secondary. closures are removed...Therefore, it is.not appropriate ~ to-use a 165. degrees'F Core Average Inlet Temperat're u requirement:as la -Refueling Mode definitive parameter. The 'NRC-accepted.this position. Seel PSC's. response to Comment'1.1 #1 for a discussion on Calculated Bulk Core-Temperatures. ' Resolutions.B l I k l 1 I

2;g ^ ,a g? L - - m NRC" Comment'3 2 #1: NRC/ suggested that PSC provide: Tech Specs for local and axial peaking Lfactors, Lor clarify the FSAR. l. -PSC Response-b> Thisicomment questions ~the reactor physics program.at FSV, similar to-other comments in'the NRC's; letter of 5/30/86 (G-86285). As PSC t' stated zpreviouslyJ i n. our response.of 8/15/86 (P-86496), the FSV {reactorphysicsLprogram=has a sound technical. basis, is closely, monitored, fand' has. shown. good performance through over three fuel cycles of; operation. . Thel local and axial peaking factors areidetermined during the design' ~ L- ~of each reload,7as diseussed'in TSUP' Design Feature ~5.3.4,. and are 'not' L controlled-by' the. reactor operators. As stated in P-86496,.the . analytical..models.which are used for reload desig'n have been compared with. experimental. data and with ' measured : data at-FSV, with good fagreement.1LThe'TSUP specifications do: provide for an evaluation of. PSC'sLcalculatianalf' methods that-are used in core reload' design,.by Lverifying :contro11 rod pair worths in SR 4.1.4.1.2. b' 'PSC does' not.: considerf that-LTech' Specs for local or axial peaking EfactorsD are-appropriate.

Also, additional FSAR analyses or

' discussions. to address' all aspects.of this comment are beyond the-scope'of:the TSUP. Resolutions F .np E NRC Comment-3.2 #2: I i 'NRCL, requested an expanded Fuel. Surveillance Program to demonstrate { compliance 1with' FSAR limits on axial and local radial power peaking. PSC-Response: Thel Fuels Surveillance-Program has been approved as Amendment 48 to the FSV Tech Specs. This Tech Spec 7.7 will be included verbatim as TSUP Section 6.16. -Any additional discussions are outside the scope

of.the TSUP.

Resolution: F i f. n 4 i.. 1 L C_ '

t. L NRC Comment 3.4 #1: PSC should provide LCOs for the required number of OPERABLE helium circulators on steam-drive and feedwater-drive as a function of power level in the POWER, LOW POWER and STARTUP modes of operation. PSC should provide LCOs for the OPERATING and OPERABILITY requirements 'for the auxiliary. boilers during LOW POWER and STARTUP as needed to supply the circulator steam drives and boiler feed pump turbines to assure normal cooling during startup and shutdown maneuvers. PSC should revise the FSAR to clarify that the condensate-drive will not be used as a normal or routine method for removing direct fission- { generated heat unless a special exception is requested and approved l by NRC. PSC Response: i PSC proposes to include a specification for primary coolant loops and coolant. circulation, similar to STS. See attached TSUP 3/4.4.1. The NRC agreed to review this proposal. PSC does not believe that a Tech Spec for the auxiliary boilers is i appropriate. 'The auxiliary boilers were never intended to have a ~ safety significance and could represent an unjustified restriction on plant operation if included in a Technical Specification. PSC agrees that they are used during start-up and shutdown operations, but we maintain that they are not necessarily relied upon in any safety analysis. Per ANS 58.4, 4.2.4-1, Technical Specifications should be provided for equipment "when they are relied upon in the safety l analysis". The Safe Shutdown Cooling equipment is specified to be operable to assure shutdown cooling during startup and shutdown operations. The NRC accepted PSC's position. PSC does not believe that any licensing basis documents should restrict use of the condensate pumps for providing circulator drive. JThe flow requirements are contained in LC0 3.2.4 (current LC0 4.1.9) and PSC's motive power for meeting this requirement should not be i limited. The NRC accepted this position. 1 1 Resolution: D*, B, B l \\ l 1 _ - _ _

py.. 3 y, w: y[:,. &ly ~.e : ' ', s o

NRC Comment"3.4'#2:

y 4 ~ ' PSC.-frieeds -to.ciartfy f the FSAR _with ' regard to the indicated safety- { function.namely, residual l heat removal, provided by..the condensate yft 1 'supplyL.tolcirculator-water-turbinesLand. steam generators,.PSC needs ~to;iconfirm':how' potential operator' reluctance.to use untreated ,s . firewater.._ for emergency' core cooling will; not affect timely operator'- Lres'ponse to situations in'which emergency core cooling. is required. .- 3 ?, .Further,i'PSC needs'to' provide LCOs for.the OPERABILITY and OPERATING L conditions: of: the '12.5% capacity -conden, sate ~ pumps as part iof< the .effectivei1orl.equivale' ti residual heat removal.'(RHR) and auxiliary n 'feedwater (AFW); systems at Fort St.- Vrain. [, PSC' Response: ~f HThel requested FSAR. revisions'are beyond the scope of:the.TSUP. 2 n". PSC;. agreed -:to.ypropose a.new : specification. for'a single'12 1/2% condensateLpumpi..-These. pumps ~were chosen because they can be powered from.an' essential powerfbus. = Q m . Resolution: F, A# L

y.,

6 1 L

my =-- - kt wmi lNRC~ Comment'3.4'#3, #4: + PSC :needsito; provide LCOs for the effective or equivalentLresidual ~ heat removal (RHR) system at Fort? St.. Vrain, PSC needs also to respond; to the question in Comment 4. Further, PSC-needs to correct the misspelling in FSAR. Table 8.2-6. 'PSC Response: . Comment #3' requested PSC to: add a Tech Spec for the Circulating Water i System.'. PSC does not' believe that 'this Tech Spec would be Appropriate, per guidance in. ANS 58.4. The heat. removal system relied.upon in the.analysesLand assured by the Tech Specs is the Service Water System.;. The NRC agreed to consider.this position. Comment

1. 4 addresses 'the decay. heat 1 removal heat exchanget,

- Similarly, PSC does not believe that.this Tech ' Spec would be E appropriate ;because -it is not relied upon in.a safety analysis. Regarding the question' of whether the decay heat removal heat exchanger. is.used to maintain Core Average Inlet Temperature below 1165 degrees F;during REFUELING,' PSC notes.that the decay heat. removal W, ' heat 1. exchanger isLused when the condenser is out of service. During 'most refueling' conditions, the decay heat removal heat exchanger is used ;to cool the core. ' The decay heat removal heat exchanger is not an active component, it is not safety related, and it is a single component. During its use for long term core cooling, the condenser cis not taken out of service until heat removal with the decay heat removali heat exchanger is assuredc In the event neither the decay g L y -heat removal heat exchanger nor the condenser were available, the B once-thru' firewater flow path would be needed. l PSC. agrees -thati.FSAR Tables 8.2-6 should address " circulating"' instead of " circulator". This'will.be addressed outside the TSUP. L, Resolution:. D*, B, ' F s t l - .g. ._.-.w_n-

t ,a, (NRCComment3.4#5: J i NRC requested information regarding the amount of flow available when l the auxiliary boiler feed water pumps are used to drive the circulator water turbinet. .PSC Response: ~ j PSC 'has not taken credit. for the auxiliary boiler feed pumps in any safety analysis. They are discussed'in the Basis as being available in the event no other pumps are operable. This is a feature of the FSV' design. that is not relied upon. Additional analyses or testing would be -required sto determine the requested information and PSC considers this outside the scope of the TSUP. Resolution: 'F NRC Comment 3.4 #6: TSUP draft Section 3/4.4 should be retitled PRIMARY COOLANT SYSTEM, PSC Response: PSC agreed to the proposed change. J Resolution: A l l _g_ .m__-m.

. Sll,' ' 4 NRC Comment 3/4.5: PSC: needs to retitle TSUP draft Section 3/4.5 to EMERGENCY CORE COOLING SYSTEM. PSC needs to relocate into this section those Specifications which are currently located in TSUP draft Section 3/4.7 and which address systems, subsystems, and components that must operate 'to.effect' emergency core cooling under accident conditions identified. within the FSAR even though such equipment is not qualified as SAFE SHUTDOWN COOLING equipment per FSAR Section 1.4. Within Section 3/4.5, PSC needs to delineate and differentiate between those systems, subsystems, and components which are qualified as SAFE SHUTDOWN, or SAFE SHUTDOWN COOLING, and those which are relied upon for emergency core cooling without specific qualif.ication (such as DBA-2 cooling). PSC Response: PSC' believes that the title of SAFE SHUTDOWN COOLING SYSTEMS is appropriate for FSV. One of the major objectives of the TSUP, as agreed to by the NRC, was to achieve clarity and make the Tech Specs easier to use and understand for the operators. ECCS is an LWR term and concept that has never been used at FSV, and inserting it at this time would add confusion instead of clarity. PSC also ' believes that the organization of the TSUP is more consistent with our goal of clarity. As discussed above, PSC believes that Section 3/4.5 should address Safe Shutdown Cooling Systems and equipment directly involved with cooling (i.e.,

pumps, piping, and valves that are the qualified flowpath).

Those systems and equipment that support the flowpath have been located in Section 3/4.7. This allows the focus of Section 3/4.5 to be more concentrated. The title of Section 3/4.7 was expanded beyond the standard " Plant System" so that the functional relationship of some of the systems to safe shutdown cooling could be emphasized. As can be seen in the accompanying proposed revision to the helium circulator Tech Specs, PSC believes that the boiler feed pumps should not be included in the Safe Shutdown Cooling section. Further, we believe that systems like Instrument Air and Hydraulics belong in the Plant System section, even though they are required for Safe Shutdown Cooling. Based on interviews, the FSV operators would be more inclined to look in the Plant Systems Section for Tech Specs on these systems. Also, this seems consistent with STS, from a functionci viewpoint. Since these systems are used for valve actuation, the comparable LWR function would be the electrical distribution sys+-- that powers their motor operated valves, which is not included in their ECCS' Sections. It was agreed-that the original organization would be retained. Resolution: B f ) L

m, -:s 4' ..c I i, [ r'h' y ~NRC'C5bentf i.00 3.5.1.1 #1 7,< > g3 iIn -; :LCO: 3.5'.1.1.a.2, :theJ words " including two OPERABLE flow paths"' ~ ,should be_ inserted after the:last word "0PERABLE" in the condition 3 > statement';for. the operability.:of steam generator sections. This -change.is. consistent withistated conditions.for. OPERABILITY as given 17.. in. the' Basis for. LCO 3.5.1.1 on page five under the section entitled. Steam Generators.' "U

4 PSC Response:

i;'t ? '^ 'This concern 'has bee'n. addressed in revi'ed draft 4.5.3.1, which s provides acceptance, criteria' for OPERABLE. steam generator sections.

k Resolution

A:

1 J 1 l f.4 1. I p-J 1 L . l i 1

. =- l* $ g. '3.5.1.1,#2: 'NRC Comment: In LCO 3.5.1.1 1.1,- why.isLthe term " safe shutdown cooling drive" used when:the!only sources of ? motive power for 8000 rpm circulator speed 'at atmospheric pressure are:the boiler feed pumps? The boiler feed pumps'areinot included on the' SAFE SHUTDOWN COOLING equipment' list in 'either FSAR' Table'1.4-2 or'FSAR. Figure 10.3-4. Shnuld the circulator turbine driv'e requirements for DBA-2 cooling be addressed 'in a ' separate LCO? : Should not. the; DBA-2 cooling system be designated .as a separate category.of equipment?. PSC Response: PSC~ proposes to delete.this potential confusi'on by covering DBA-2 . cooling as follows: " Boiler Feed Pump operability ~ 1s assured in 3 71 1 Emergency Feedwater ' header. operability is' assured via 3.5.4 4 -(previously~3.5.3). All 'other! piping up to the helium circulator speed valves is i assured operable per 3.5.2. - Helium. circulator operation at 8000 rpm on feedwater drive is demonstrated per 4.7.1.1. By separating,the. helium circulator specification from the circulator -. auxiliary specifications, the explicit inclusion of an 8000 rpm LCO

is.not required.

l Resolution: A

NRC Comment:

3.511 #3 In LCO 13.5.1.1'.b.2, the 'words "Two safe shutdown cooling drives" ~would appear to read more appropriately as "A safe shutdown cooling ..dri ve. " ' There is.only one steam and one water turbine drive per each circulator,, and the text should reflect one drive per OPERABLE ci.rculator. since the steam drive is not a safe shutdown cooling drive. PSC' Response: .PSC' has revised LCO 3.5.1.1 to only discuss the capability of water turbine drive,.which is the only safe shutdown cooling drive. C Resolution: A , 1 ) \\ l \\ r: l6 -- j

r. - [< l I . NRC Comment: : 3. 5.1.1: #4 I t ;

In LCO' 3.5.1. lib.4, the words " normal' bearing water system"'are understood. to; refer to the' full. complement : of three bearing -water pumps per loop. The backup bearing water.. supply-system is assumed by

'the Staff.neither!to be credited in.the FSAR nor subject to Technical Specifications.

PSC's

revised response'to Action 27a, as documented lin Attachment 3!to P-86169,. is interpreted to mean ~ that backup bearing:. water is notLrequired for effecting " safe shutdown cooling."

Similarly,;the PSC response to Action 27b is act _ appropriate since -backup . bearing water..is: neither covered by the Technical

Specification' nor available (in use) below' 30% of rated power.

iPSC-Response: OThe ""normalibea6 ng water system" includes operability of two of the b three bearing'wate r pumps per loop, and this has : been clarified in-the" attached re-draft.~ 'PSC also agrees that backup bearing water is

not considered. safe shutdown' cooling.

In 'P-86169,- PSCjs response to Action 27b stated that bearing water S temperature need 1ot be: included in an LCO because the LCO and SR l requirements;. insjred: operability of the bearing water system and the

. design' features provided diversity and'. redundancy. The discussion .addressedE the: backup bearing water system as one of these design features,.but it is'notfrelied upon. PSC feels that the emphasis ishould ;be placed on the.assuran'ce included in the LCO and SR = requirements..Each normal. bearing water loop'. includes two bearing water ; coolers,. one' of which is an installed spare. Each cooler is ' supplied by service water.(whose operability is assured by a Tech -Spec) orLby. circulating ' water; there'are blind flange connections -available for additional cooling water capability as required. Resolution; fA, B 2 w: =: _ _ _ _ -.

g-y }i ,l r> _g f,

NRC Comment: '3.5.1.1 #5 gf DSection'4.0.and'LC0'4.2.1 in'the current-FSV Technical Specifications-allow only a.24 hour period for an orderly shutdown when a loop

becomes inoperable due to loss of. both circulators.

similarly, .Section?4.0,and LCO-4.3.1 of the current FSV Technical Specifications appear'.- to. imply the same 24-hour limitation for loss of both steam Egenerator sections in one11oop. TSUP draft LC0 3.5.1.1 ACTION a allows 72 hours to restore an OPERATING-but inoperable loop to OPERABLE' status before imposing the 24 hour limit to effect an orde'ly _ shutdown. The 72 hour allowance needs to be justified since r it differs from the original Technical, Specifications. .Since. PSC currently recognizes the safety function as being accomplished only .by. the1 Pelton wheel ' drive, operating on feedwater (bSA-2) or L firewater, the reference to "0PERATING loops".needs-to beideleted since the Pelton wheel drive is not used for ' operation at POWER. The second paragraph in the Basis for LCO 3.5.1.1 should also be deleted ~ a >since the OPERABILITY-or OPERATING status of the helium circulator on steam drive or on water turbine drive supplied by sources other than g .feedwater or firewater. is'~ not relevant. to this LCO. PSC should also modify' DEFINITION

1. '2 3, OPERATING-IN OPERATION, to read as follows (new wording underlined),

"A' system, subsystem, train, component or device shall be <0PERATING or IN OPERATION when it is OPERABLE per DEFINITION 1.22 and actually performing-its specified safety function (s)." OPERABLE'is-understood by:the Staff to include the operability of the ' full complement of equipment with no loss.in redundancy. PSC-Response: -_ PSC agrees that the distinction between OPERABLE and OPERATING is confusing and has_ deleted the OPERATING definition and revised the specification 'as shown. The philosophy reflected in the specification re-write is as follows: Forced' circulation is addressed in 3/4.4.1. Loss of forced circulation 'in one -loop is permitted for long enough to recover the~ shutdown loop or to effect an orderly power' reduction below ~ 2%- (24. hours). Total loss of forced circulation requires depressurization per the time requirements of the existing LC0 4.2.18. ' ~ - _ _ _ _ - _ _ _ _ _.

e Safe' shutdown cooling functions are addressed'in 3/4.5. Here a loss of redundancy is considered equivalent to a loss of redundancy _in an LWR, which is permitted for 72 hours per the STS.

PSC understands that this Action was based on a PRA performed by SAI in 1975, that considered reliability of ECCS - type components. The FSV safe shutdown cooling equipment includes pumps, valves and heat exchangers that'are not unlike those used in LWRs, and we believe that a 72 hour Action time is appropriate. Resolution: A .NRC Comment: LCO 3.5.1.1 #6 l The portion of the previous comment with regard to OPERABILITY versus OPERATING status also applies to LC0 3.5.1.1 ACTION b. A prima ry i coolant, loop can only be OPERABLE at POWER, LOW POWER and STARTUP f since the steam drive has no safety function in safe shutdown I

cooling, and since the firewater safety function should not be OPERATING under any of these conditions.

1 i PSC Response: PSC has deleted Action b. l 1 Resolution: A i I l 1 1 i i 1 J l

q..

'5 [$5;;

Q :.; .NRC Comment: 3.5.1.1 #7. o Ip., .'LCO 3.5,1.1 ACTION's e and d allow. longer response' times than allowed iin-Section 4.0 and LCOs14.2.1 and 4.2.2 of the existing-FSV Technical Speci fi cati or.s.- ~LCO:- 3.5.1.1; ACTION' c should be made clear as to whethe' J0PERABLE refers: to the Pelton ' wheel drive or' 0,, j.y. feed ' pu'mp : drivel source. - to the boiler r This-ACTION'needs?to be more explicit. o PSC1 Response:. m -n ' The. 72l hour. Action '. time :is 1 justified.in our response to comment. = 3.' 5.1.1: #5. k f these' specifications separates the' drive LTher. latest: revision o ji. source from~the drive. specification, so that the Action for an h? '

inoperable Jboiler feed pump is. contained in=the boiler. feed pump l spec, lthe? Action Lfor an.. inoperable--flowl path up through.the circulator speedL valves :is contained in the circulator auxiliaries-spec, and"the Action.for~ an. inoperable Pelton wheel drive (due to any other:: reason) 'is contained in circulator. spec.

This will be lexplai.ned in the Basis, ovi p d' Resolution: A#- NRC Comment: 3.5.1.1 #8,'#9-I n' -LCO 3.5.1.1, ACTIONS h and'i..the word "immediately" should be freplaced with.the'words "within 10 minutes." In LCO 3.5.1.1 ACTION i, the cited figure numbers should be 3.5.1-1, .3.5 1-2 and 3.5.1-3-and not 3.4.4-1, etc. PSC' Response: .'PSC agrees to replace'"immediately" with "within 10 minutes" and to ensure the figure members are correct. Due to the relocation of the forced circulation. requirements, however, PSC notes that the-figure EU ' members will be 3.4.1-1, -2 and -3. Resolution: A,- A J

.y.

Qw ' [ W sw, w ~~ .( 4;ty: s l, J:

,,-.4 y

.p k.j LNitCComment- ~.3.5.1.1 #10~

e - m,c In'SR14.5;1.1','a.2.a),fatsurveillance:for the use of the turbine water p removal 1tankLoverflow should be. included consistent-with the last ~ Lparagrap.h onftheisecond page of the' Basis-for LC0 3.5.1.1. P. J; lPSC Response: y e PSC does' ~not agree.that'a surveillance for;the TWDT overflow should .be included, because it is.not intended to be. required in the. : LCO. ~ '. - Th'is capability.is' identified in.the Basis as a design feature but it Jis'not' relied upon..-PSC= considered assuring TWDT removal capability .by3." requiring 'either;.2 pumpslor one pump and the overflow, but this U- -.was not pursuedL because of varying. storage capabilities in the

reactor bui.1 ding sump'.

~ , Re sdl ut' ion : B-

xi..

(i.g $ D NRC': Comment: '3.5.1.1 #11 Wg <In SR -- 14 ; 5 ' 1.1?. a. 2. b), bearing water makeup pump P-2108 was omitted-fand'needs to b'etincluded. PSC Response: P-2108 was1omitted from SR 4.5.1.1.a.2.6 because it.does not have the

auto-start

feature. demonstrated 1n that-test of lP-2105.

Its operability is. ass' red by the'ISIT program. u T ? Resolution: TB s. 'nI -h ^'h ( f f.____ - _ - __ -

g> fpg j S' 3.5,1.1-#12: t NRC Comment: og

SR" 4.5.1 1.a.3 Eshould include _the' exact;same provisions as the'NRC 4

A__ 1 redraft of: SR 4.5.1.1.a.2.c as given in Enclosure 2 to the NRC-NRR wx ' letter Edated December 27, 1985~ or PSC.should provide justification ~ .for not including. PSC Response:. This comment. addresses; testing the auto-water-start feature by either "simulatingia steam turbine' trip" (PSC's words) or " simulating a ' PPS signal resulting :frome:ene loop being' tripped and the circulators' steam't'urbine drivesLin the, operating loop having been tripped" (NRC's words).- ~PSC.. agrees that the _NRC's wording is consistent with FSAR Section 7.1.2.4 and'the Specification'.is being revised accordingly. Resolution: _A' r NRC' Comment: '3.5.1.1.#13 .SR 4.5.1.1.b.2.a) should be replaced.to read as follows: o. "The:imain_. steam: ring header to. main steam piping weld for one steam generator. module in'each loop,'and." iThe. proposed readin'gs for SR 4.5.1l1.b.2.a and b should be renumbered , aslb and c respectively. _The'se changes are consistent with the NRC _ redraft. version as given in ' Enclosure 2 to the NRC-NRR letter to PSC ~ dated December 27, 1985. PSC' Response: PSC': agrees that the SR should be. revised to reflect the current Tech ESpec' requirements =-as shown on'the revised T.S. ~ Resolution: A , ~ m__Am 1J__. -m--.a

jy@, h ], "'g) D NRC Comment: : 3. 5.1.1 '#1'4 ' In. SR 4.5.1L1.b.3, the~ word "in" in'the first line.should be changed

tol"is".

f ^f. 'S .PSC-agrees. i Resol ution': iA i NRC! Comment: 13'5.1.1'#15 In..SR 14 5;1.1.b.3.b), the words "and at least the pre'iminary" in ' lines.six and seven should be deleted and replaced by the word "the"' only. PSC Response: This comment-concerns the-Special' Report to be' submitted to the NRC .following aLsteam generator tube leak..This report of metallographic and engineering examinations'is to be submitted within 90 days of the return to operation following the tube leak study. PSC believes that this time period is: too restrictive to complete the examinations required for.a<fulla report. ' Metallurgical examinations often require extensive: review and discussion before a. conclusive evaluation is reached, and this t should, not be rushed because of a reporting requi rement~. PSC. intends-'to. pursue any--such eva10ation in an expeditious manner, but we do not believe.that a Tech Spec time limit . that'. is tied to plant operations is appropriate. There'is currently no time limit on.this'. report and it was agreed to leave the T.S. as written. Resolution: B t r

.w, NRC Comment: 3.5.1.1 #16 _In the first paragraph on the first page of the Basis for LC0 3.5.1.1, the words " condensate or" and " condensate and" should be .,i' deleted since PSC contends that safe shutdown cooling capability is not dependent on the availability of condensate. 'PSC Response: PSC agrees that condensate is not safe shutdown cooling and agrees to add this clarification to the Basis. However,. condensate drive capability is a design feature that enhances the confidence in pelton wheel! drive capability, and PSC believes it is appropriate to include it in'the Basis discussions. Resolution: A# l NRC Comment: 3.5.1.1 #17 The third paragraph on the first page of the basis for LCO 3.5.1.1 l should also indicate that the apparent need for "two circulators, I operating with emergency water drive, supplied with feedwater via the emergency water header" also applies to the maximum credible depressurization rate as implied by FSAR Section 14.4.3.2. PSC should address " protection against single failures" for such credible events. PSC Response: FSAR Section 14.4.3.2, Revision 5 was revised to reflect recent analyses that demonstrate acceptable cooldown after the MCA, using one-circulator on feedwater drive. Requiring two operable circulators assures single failure protection. The NRC accepted this position. Resolution: B.. _ _ _ _ _ _ _ _ _.. _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ - _ _ _ _ _ _ _ _ - _ - _ _ _ _

1. jg' b

~ -3.5.1.1 #18-NRC Comment: 4 '7 W. The' sfourth para' graph ion-the: first page of. the Basis for LCO 3.5.1.1 luse~s. mixed terminologyTcompared.to the. rest of the Basis. The. words " main. steam / water section".should, be replaced with " economizer-0 evaporator-superheater section". PSC Response: 1 7 :PSC-~ agreed. . Resolution: :A-1 i e NRC Comment-3.5.1.1.#19 l ; The third - paragraph' on page two' of the Basis for LCO 3.5.1.1-should

clearly indicate.that the. boiler feed (feedwater). pumps are not

~ qualified Tas SAFE SHUTDOWN COOLING equipment. The probability vaIue "E-7"'should be rewritten as "1.0E-7" and justified. A probability i

estimatet should-also be supplied for the maximum credible

>depressurization event.' 'PSC' Response: PSC agrees;to revise-the Basis to' clearly state that the boiler feed ipumps are not. safe shutdown cooling equipment, and to specify the DBA-2-probability as."1.0E-7." PSC does not believe that alprobability of the MCA is required, in 119ht 'of the reanalysis described in Rev. 5 FSAR Section 14.4.3.2. 3 JAlso, the analytical effort 1 required to produce this number is beyond =the' scope of TSUP Resolution: A#,.F J i i ) , I

J. l,2 , o n 5[ t NRC Comment:.'3.,5.1.1 #20 x- .y q"[ In the?- firsti paraAcaphL.on.. the' third page 'of the Basis for'LCO 3.5.1.1,-delete 4rst two' sentences and the word -"also" in the-ithird sentence.jtQ te r backup bearing water supply system is not g 14 currently covered: y :Se Technical Specifications and should not be- ..:n credited int:the Bas,; y,g.. 6 ,PSC Response: IPSCdoesnotagree.that'discussionof.thebackupbearingwatersupply w/:e s .should be deleted from the T.S. Basis. Backup bearing water is a -design feature Uof: FSV -that enhances the confidence in circulator Joperabilityt There is.nothing.in ANS 58.4. to. indicate' that T.S.

basis-:m'ust -be' restricted to discussions about T.S. equipment. 'This discussion is considered'to. support PSC's position that the LCOs and

' Actions are. appropriate. The NRC' accepted this position. s. s ' Resolution: B NRC' Comment: :3.5.1.1 #21-In: the: third' paragraph on the third page 'of the Basis for LCO 3.5.1'.1,..the words "at 31 days and REFUELING CYCLE intervals" should be i hanged to : read "at days, 92 days and REFUELING CYCLE c Lintervals". PSC Response: Based-. on. the revised specification,. the Basis is changed to read "31 day and 92 day intervals",:since there are no Refueling SRs for the bearing water system. ~ irresolution: A. l l s ) l 1 l r Li

r NRC Comment: 3.5.1.1 #22 1 On page four of the Basis for LCO 3.5.1.1, the equipment redundancy criteria is tied to the CALCULATED BULK CORE TEMPERATURE exceeding a value of 760 F. to P-86169 discusses.this parameter. l . This discussion fails to address specifically how the operator is supposed-to. calculate and use this parameter for assessing the 3 Technical: Specifications applicability on-line as the plant operates or' changes operating conditions. PSC has not, for example: (1) Presented the verification and validation methods and documentation to support estimating the CALCULATED BULK CORE TEMPERATURE (including the use of historical data); (2) Identified the_ applicable provisions of Specification 6.8 for the Administrative Controls of this calculation and the supporting calculational procedures; and (3): Provided ' justification for not providing Technical Specifications Administrative Controls for this calculation. PSC's response to this comment should be consistert with the NRC guidance on the revision to the existing Specification 4.1.9 as provided in the NRC letter, K. L. Heitner to R. O. Williams, JR., dated December 5, 1986. PSC Response: PSC provided detailed guidelines for use of the Calculated Bulk Core Temperature with our submittal of LC0 4.1.9, P-87124. The guidelines in the ' proposed LCO 4.0.4.(existing) will be added to TSUP Section 3.0. The three comments are addressed as follows: (1) The Basis for LCO 4.0.4, included in the amendment submittal of P-87124, identifies the conservative assumptions and derivation of the calculations used for this criteria. It is derived from information in the FSAR. (2) Inclusion of the curves and guidelines in the Tech Specs l obviates the need for additional Administrative Controls. .(3) Curves that can be used to determine a time to reach a Calculated Bulk Core Temperature of 760 degrees F will be included directly in the Upgraded Tech Specs, upon NRC approval. I Resolution: B (based on approval of P-87124) ~ _ _ _ _ _

w NRC Comment: 3.5.1.1 #23 FSAR Appendix C.15 cites the. water turbine automatic start as an "additicnal" engineered safety feature protection system, but this feature is net cited elsewhere in the FSAR nor outside the basis in this Specification. PSC should either delete the reference to this system in the FSAR and -basis or provide more information and appropriate specifications if any credit is to be taken for it in the safety analysis, including _the demonstration of compliance with the design criteria as is currently being done. PSC Response: 1 Although not described in detail, the auto-water start feature is included _in several loss of normal shutdown cooling analyses. Both 14.4.2 and 14.4.2.1-describe an immediate re-start on feedwater drive, which is accomplished by the auto-water start feature and is assured by the TSUP. PSC ' considers the Basis acceptable as written and additional FSAR discussion beyond the scope of the TSUP. The NRC accepted this position. l Resolution: F. NRC Comment: 3.5.1.1 #24 See. comment 1 to LCO 3.7.1.1 with regard to clarifying'the Basis on depressurized cooling requirements. PSC Response: This comment addresses the MCA requirements which were addressed in FSAR Rev. 5, as discussed above. PSC believes that the revised Basis discussions clari fy cooling requirements. The NRC accepted this position. Resolution: B

w.,' m- {g; ' 1 1 jg 2 E NRC Comment;-. : 3.5.1.2 #1,~ #3' v :Theseiare the same as" comments'3.5.1.1-#1 and #2. 'PSC-Response: ) ( See.;. responses:to Comments 3.5.1.1 #1 and #2. > Resol ution: lA#, A#' I ,g.- -NRC' Comment: 3.5.1.2'#2' - In"iLCO 3 5.1.2.b.11 and .~2 the lead word "One" should be changed to '"A". -l PSC ' Respon se': PSCproposesT tor replace "one" with "at least one", for purposes of clarity. ' Resolution: AL u-NRC: Comment: L3.5.1.2 #4,.#5 ~ -In LC0t3.5.1.2: ACTION a, the word "immediately" should be replaced .withithe words "within 10 minutes", and the words " control rod Jmovements".should be replaced with the words "any evolution." + LIn. LCO 3.5.1.2 ACTION b, the words'" control rod movements" should be replaced _with "any evolutions."_ Also, the word "immediately" should be replaced with,the words "within 10 minutes". !PSC' Response: The Actions for these items have been. relocated, and in each case "immediately" has been replaced with "within 10 minutes". PSC prefers' to-retain the words " control rod movements." This is consistent with.the recent NRC position expressed in their letter of July: 2, 1987'(G-87217), Enclosure 2, Comment 3.9.1-3. The NRC accepted this position. ~ Resolutions A, B-rs

mm-Kj;. g- - ]. - i - o. ( V q : .NRC: Comment:. 3.6.2'1 #1 ~ !LCO 13.6.2.1 / ACTION :'a and the first paragraph 'of.the Basis for LCO 4 (3.6~.2 allude to:the'48 hours of allowable operation with one LCS loop . 0PERATING;: however,.FSAR-Section: 5.9.2.4, page 5.9-13, does not ~

provide 7 specific details on the analysis that justifies the allowance 4

ut ~ 'of..the: 48 hours' grace' period. Mi < PSC Respons'e': l ) i:. JThe 48: hour 7 allowance for single loop operation is consistent with Ethe current Tech-Specs'and is retained in the TSUP The NRC accepted this position. Resolution: Bt .4-

NRC Comment

:3.6.2.1 #2.

.In :LCO '3.6.2.1' ACTION a, the words " control rod movements resulting in" should be deleted. PSC Response: bse of the Action Stat'ement as written is consistent with the NRC's 3recent positioniin 'their letter of July 2,1987 (G-87217), Enclosure. 2,-CommentL3.9 1-3. The NRC accepted this position. ' Resolution-B' 41 1 i ! i u l u

T ~ ' - - - ~ ~ - ~ ~ ~ ' s y cy # l ~ in ..NRC Comment; 3.6.2.1 #3' In 'SRL 4'.6.2.1, 'PSCihas failed to_ include the provision for scanner alarm functional' tests? and calibrations =as ~provided.in -the NRC c ~redraftlin Enclosure 2.to the NRC-NRR-letter. dated December 27, 1985. 'PSC Response: 'PSC does not be'lieve that scanner surveillance are appropriate for .SR 4.6.2.1~because there is no: accompanying: LCO for. the scanner. . instrumentation.. Consistent vrith previous'NRC agreements, since this' . instrumentation is used to confirm PCRV liner tube operability and not~forfautomatic' actuation, i, surveillance per administrativeJcontrols L(1.e.. procedures) isl appropriate and an explicit Tech Spec' is.not required. These previous NRC agreements are documented in G-86635, as.forLexample, in Comment LCO 3 1.1 #3. .The NRC accepted this . position. Resol'ution:.B l .NRC' Comment: 3.6.2.1<#4 .In'the Basis:for.LC0 3.6.2, the last-sentence of the second paragraph on the~first page does not indicate -how many. tube failures were considered, nor doesL the following discussion therein provide . concrete temperature limits'as a function of.the number of failed. 9/ ' tubes. - PSC ' Response ~: -The.' numbers of failed t'ubes allowed in LC0 3.6.2.1 are in agreement

with ' FSAR. "section 5.9.2.4.

Since these' analyses resulted in acceptable concrete. temperatures, additional' concrete temperature limits'are not required. The NRC. accepted this' position, Resolution: B ~ y .. [

4,-

• r 1,' k '.' s

,D;,.. ri p. i

'4'.'.

NRC Comment

43.6.2.1 #5

. On'~page Stwo, second paragraph, of' the Basis for LCO 3.6;2, the- .ISI/IST. program >needsL to-.be clarified as to.how it " verifies - OPERABILITY". of.the: subject: barriers between safety and non-safety. ' portions'of;LCS. 'Also, clarification is needed as to how. tube flow - rate instrument.. accuracy.is assessed without-imposing Surveillance Requirements. PSC' Response:

ThelISITE = program will ' assure operab'ility of the barriers between

. ^. Jz safety and'non-safety related portions of the LCS by' means of ASME Section :XI type ' valve ~ operability testing. This includes valve cycling. As for the; temperature scanners,.the accuracy of the flow rate instrumentation.i s as'sured by. ~ administrative. controls (i.e., . procedures)' in ;a manner consistent with other plant instrumentation for TSUP parameters'. =The NRC? accepted this position. Resolution: B-1 ).' ) I 1 __ _

i! gjm

.'s t

?ar, NRC commart: 3.6.2;2 #1', #3' In LCO' 3,6.2,2 APPLICABILITY,.the pound sign (#) footnote should be b further explained as to why operation should be'allowedLin 1r degraded mode. This appears to be a new licensing condition which has not been! supported by adequate justification. On.page: two of the Basis for LCO 3.6.2, the fourth paragraph should be evaluited and revised based on comment 1 above. - PSC Response ~: The footnote permits' valving'out the core support floor LCS only~when PCRV pressure is.below 150 psia and core average inlet' temperature is less:than 200 degrees F. The existance'of leaks in' the core support floor liner cooling system is not a new. licensing issue. It appears now as a Tech Spec issue because. the.1 existing Tech Specs for.the LCS only apply during power operation ~and did not preclude valving out this zone below 150 psia. However, FSAR Section 5.9.2 4.has previously included a discussion on cooling water tube leaks in.the core support floor (pg. 5.9-14 in j UFSAR, Rev. 5). l - PSC agreed to' provide' references to previous NRC approval of the core. ~

support floor leaks. -A review of NRC correspondence found~ evidence of NRC awareness of the.-leaks, but no formal approval. The ORNL-MonthlyLReport for May 1984;(G-84191). stated that core' support'. floor leakage 'was reported in.the R IV Daily Report for April 16, 1982.

Valving out the core support floor LCS,under the stated conditions is i a precautionary measure that is supported by the Tech Spe'c Basis. j Resolution: D, to become B, upon NRC acceptance of this discussion. NRC Comment: 3.6.2.2 #2-1 In LCO -3.6.2.2 ACTION, the words " control rod movements" should be replaced with the words "any evolution". PSC Response: 'See comment 3.6.2.1 #2 above. Resolution:.B _ _ _ _ _ - _

g ' y.4 y,

hi iNRC Comment:. 3. 6'. 3 '.#1:.

r- ? lIn?LCO3.6;3. ACTION,PSCshoulddeletesubheading"a."anddeletethe .words~" control 1 rod movements." PSC Response:' See comment 3.6.2;2 #2. ' Resol uti on : - Bi A- ?ll j s ~ NRC Comment: 3.6'.3 #2-1 g

In;SR'4.6.3,- PSC should change SR 4.6'.3 to cover functional tests and

~ instrument surveillance using the wording given in-SR 4.6.3.c in the- -NRC redraft in Enclosure 2 to NRC-NRR letter dated December 27,.1985. c; PSC Response': i

Consistent. ~with previous _

NRC agreements, _PSC believes that ..;1 l surveillance of PCRV.LCS ' instrumentation should.be-performed per , administrative controls (i.e., procedures) and need' not be. 1specifically required'in the Tech. Specs. The NRC accepted this cposition. S LResolution:.B NRC Comment: 3.6.3 #3 .g The::FSARL should.Jbe~ updated. with 'a discussion of the temperature . limits associated with the LCS to correct'the deficiency noted in the Basis for. LCO 3.6.3. ~PSC Response: 'As Epreviously. agreed, FSAR changes are beyond the scope of the TSUP. ~The NRC accepted this position. Resolution: F 'l i 1 ! I l

' v,3 1! .do m .. 1...3.7 #1 NRC' Comment: LThe title'. for TSUP' draft Section 3/4.7 should be reduced simply-to PLANT SYSTEMS. SAFE SHUTDOWN COOLING SUPPORT SYSTEMS can not be support -systemsL Lif 'in fact the designated. system has to operate in order.for the " emergency core cooling"' function to be performed. -Similarly, the system should not be 'so defined if in fact-it does not . support " safe shutdown cooling"'. The current title is a _ misnomer. 'As~alsolindicated in other NRC comments, certain Specifications (LCOs

3.7.5 an'd.3.7.8)Lfail to meet the intent' of designation as PLANT SYSTEMS,. and these Specifications should be relocated to other

? appropriate TSUP draft-Sections. j PSC Response: . As L stated;.previously, ' PSC organized the Upgraded Tech Specs to ' facilitate operator use, consistent with the TSUP guidelines. NRC is . correct in noting that some. systems such.as Instrument Air and-LHydraulics are actually required for safe shutdown cooling, but it is perceived ~as'a support role, much like electrical power. PSC::placed. in Section 3/4.5, Safe Shutdown Cooling Systems, those qualified. systems-and equipment that are directly involved with L' . cooling (i.e., pumps, valves and piping that as the flowpath). PSC placed in Section 3/4.7, Plant and Safe Shutdown Cooling Support . Systems, those. systems and equipment that function to support the flowpath (i.e., assure valve operation, service water, and non-safe shutdown cooling pumps)' This allowed the focus of Section 3/4.5 to be more concentrated. The title of Section 3/4.7 was. expanded beyond the standard " Plant' System" so that the' functional relationship of - some of the' systems to safe shutdown cooling could be emphasized. 4 PSC' Acknowledged that the ACM function goes beyond fire protection ) and agreed to relocate this specification to Section 3/4.8.

However,

) ~ Sin' the: interest of operator clarity and ease of use, PSC proposed to i z. _. retain the organization of the remainder of the Upgraded Tech Specs i as submitted, and the NRC accepted this position. j Resolution: B, A# (ACM only) i l tf C_m _m_.. -

=-- p? p NRC Commenti 3.7 #2: /FSARoSections.2.5.1l:and 10.3.9 (p' age:10.3-8) define the South Platte. - River,. Fort.St. Vrain Creek,.and,the system of six shallow wells as constituting _that'which. appears to be an Ultimate. Heat Sink. Per the -licensing basis, the'onsite_ storage _ ponds capacity will be. exhausted ~ -.after.:about.-11 days thus_. requiring use of coffsite sources to

replenish'the storage ponds. 'The offsite sources,'or.ultimatef heat m

sinks,.are Lnot Ecurrently addressed-in :TSUP. draft Specification 3/4.5.4,'and the'8 asis for this Specification does not-cite the' 11. day ' limit.on' onsite capacity cited in the FSAR'. Why_is there:no Ultimate Heat Sink Specification _ consistent with the licensing-basis and similar to that exemplified by WSTS Specification 3/4'.7.57-P'SC Response: PSCp has.not..provided,a Tech Spec for an Ultimate Heat Sink:because-

there is no one specific;offsite water source,that,we rely on.

In the4 event-lthat the" onsite_ storage' ponds.are-required for core cooling', PSC--has.11 daysLto_ provide a means. of. replenishing _them. -This. would:normally be from the sources cited and various. flow paths-could be'used. The distances involved. are _ noti so great.as to ~ preclude:,use- 'of portable piping and pumper units..PSC is confident 'that' adequate offsite water. supplies can be established within 11 ' days: to. assure long term safe shutdown cooling, without a Tech Spec on'the river levels or connecting flow paths'. The NRC accepted this = position. Resolutions B ) ! l =

1 I L NRC Comment: 3.7.1.1 #1 PSC needs'to provide the necessary clarifications and changes to the -Basis for LC0 3.5.1.1 and LCO 3.7.1.1~and the FSAR with regard to depressurized cooling requirements arising from depressurizations other than DBA-2. PSC needs to clarify and justify the use of PWR .. ve s sel rupture frequencies for assessing the frequency of FSV accidental depressurizations. PSC needs to justify n_ot applying ASME Code Section XI inservice inspection requirements to FSV penetration closures. PSC Response: FSAR Rev. 5, Section 14.4.3.2 has been revised to include a discussion of MCA. cooling requirements with one circulator on feedwater drive. PSC agrees to reflect this position in the Basis l for 3.7.1.1. The NRC review of PSC's PRA for DBA-2 is being conducted as a separate issue. PSC currently surveils PCRV penetration closures per SR 5.2.2.8 (Amendment 33) and these will be included in our ISIT program, outside the TSUP. Resolution: A#, B-l l l l J i 1 l l l l

x. 3_ _ y; Ml NRC Comment: - 3. 7.1'.1 #2.. .PSC needs LtoL' relocate the LCO/SR and to: revise' the ' Basis as indicated.~ -PSC needslto_ expand or add necessary: LCOs/SRs to cover the DBA-2-cooling system requirements in_an effective manner. PSC Response: See PSC-response _to Comment 3.7 #1. PSC' agrees to clarify the Basis to clearly tstate that the Boiler Feed t pumps. and :the condensate. pumps are. not~ Safe Shutdown Cooling .. eq ui pme nt. ~ y -PSC also agrees! that the condensate pumps.must operate to provide . adequate NPSH-~for,the boiler feed pumps. This~ i s' an. operational requirement'_such that_ FSV will not be running in a condition where the boiler feed pumps would be relied upon (for DBA-2) unless the

condensate pumps were also running.

They are needed to support power operation even without'a Tech Spec requirement. .Thus a condensate pump" Tech Spec'is not required. .PSC !also believes that a Tech Spec on all of-the condensate pumps is not appropriate because of_the. resultant restraint on operational flexibility. Currently, various, combinations of the 4 pumps are _used,-especially in startup, with the 12 1/2% pumps used generally only :when thel decay' heat removal heat exchanger is in use. The demands of operational._ support are sufficient to assure. adequate 7 condensate pump operability to support DBA-2 or safe' shutdown cooling. Ati.the 'NRC's' suggestion, PSC. agreed to add a new Tech Spec on a single--12:1/2% condensate-pump. This pump was selected because.it is powered.from an essential bus. Resolutions 'A#, D* l 4 i.'< 1 ___-_____a

NRC Comment: 3.7.1.1 #3 -Should REFUELING be added to the APPLICABILITY statement since PSC has no where' indicated the value of the CALCULATED BULK CORE TEMPERATURE which must exist in order to enter the REFUELING mode? PSC Response: PSC does not believe that boiler feed pump operability is needed - during the Refueling mode. The boiler feed pumps are required to provide acceptable circulator drive in the event of DBA-2. In the Refueling mode, the PCRV is depressurized but decay heat loads are reduced so that high speed (feedwater) water turbine drive is not required. PSC does not believe that it. would be appropriate to specify a Calculated Bulk Core Temperature (CBCT) that must exist to enter the Refueling mode. The CBCT'is a time dependent variable that assumes a loss of forced. circulation. During any operating mode, including refueling, it is possible to stop forced circulation and eventually reach a CBCT of 760 degrees F. The CBCT is controlled via 3.0 guidelines and should not be a criteria for mode definition. Resolution: B NRC Comment: 3.7.1.1 #4 - FSAR Section 6.3 and FSAR Appendix Sections C.41 and C.44 need to be revised to be consistent with FSAR Sections 14.4.3.2 and 14.11.2.2 with regard to the number of operable circulators on feedwater drive needed for depressurized core cooling. FSAR Appendix Section C.44 cites an incorrect figure number in FSAR Section 14.4. Apparently, the cited figure is no longer included in the FSAR and has been replaced by Figure 14.11-11. PSC Response: Per previous agreement, changes to the FSAR are beyond the scope of the TSUP. These concerns will, however, be reviewed for the next FSAR update. Resolution: F i ' l _m__

p NRC Comment: 3.7.1.1 #5 - Previously. recommended changes to this Specification per NRC letter, K. L. Heitner to R. F. Walker,. dated May 30, 1986, remain in effect. PSC' Response:. Previous comment agreements will be reflected in the re-drafted Tech ' Specs at their next submittal. NRC accepted this position. . Resolution: B 4 I I 1 i

---~ g;- i t

J <

E I ds- !NRC Comment: 327.1.2 Does a steam / water. dump actuation always occur prior to all the. possible sequences. leading to the need for emergency core cooling, including SAFE SHUTDOWN COOLING? How does the actuation mechanism for the feedwater isolation' valves differ between the steam / water I dump and.all'the possible sequences involved in_ requiring emergency { core cooling? Does.'the latter include manual. and remote-manual operation, possible' via e different redundant electrical circuits in remote-manual operation? Dec the proposed LC0 and SR accurately . depict and -verify OPERABILITY under all.the conditions in which the { feedwater isolation valves are required to operate for emergency core . cooling? If the answer to the last question is "No," PSC needs to propose an applicable and appropriate Specification for the feedwater . isolation valves to be included in TSUP draft Section 3/4.5. Even if 1 "Yes", if these valves 'are. absolutely essential to the operation of-i the emergency ' core. cooling sy s tem,- an appropriate Specification ,f should still.be included'in the proper TSUP Section 3/4.5. l

Finally, FSAR Section 10.2 is very unclear as to when or whether the emergency feedwater. header has to be in use during STARTUP, SHUTDOWN REFUELING.

Use 'of the emergency feedwater header would 4pparently imply that the feedwater ' isolation valves are closed. Since emergency core cooling could apparently be required from STARTUP or SHUTOOWN, and perhaps even from REFUELING for which the required value of the CALCULATED CORE BULK TEMPERATURE is not defined, the APPLICABILITY statement for the feedwater isolation valve Specification should be expanded beyond POWER and LOW POWER to situations in which the isolation valves may not already be closed. PSC Responsei 'All the' above questions are aimed at justifying why the Steam / Water Dump System Tech Spec is only. applicable above 5% power, including feedwater isolation valves and control valves (HV-2201/2203, FV-2205 and HV-2202/2204, FV-2206). PSC agreed to propose a new Tech Spec for all valves actuated by SLRDIS, which includes these valves. The applicability of this specification would be whenever SLRDIS is

required, i.e.,

down to 2% power. PSC currently tests these vcives per written procedures. The new SLRDIS valve Tech Spec will be provided in a later submittal. The NRC accepted PSC's position that the Steam / Water Dump system Tech Spec ~is appropriate as is, in Section 3/4.7. Resolution: A#, B, _m______.

- _ -. _ - - - - - = - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - $ y; .l } w b^ g {

b -.

W i'- JNR(i Commenti L3.7.1.5 ~ lIn> LCOH 327.1.5.b,' the : reference to' Specification 3.0.6 should be i V changed to;3.0.4. LIn SR" 4.7.1.5,. the reference; to Specification ?4.0;6< should be changed to 4.0.4. These changes are consistent with LP Tthefdifference 'between PSC'.s April 1985 ' ' draft.. and the recent NRC y fmarkuplof..the November:1985. final draft. }PSCLResponse: ~ PSCLagreed.s t ResolNion: 'A < .a NRC Comment: '3.7.1.6 'In;-LCO.c3.7.1.6 ACTION,. change the words " control rod movements" to "any! evolutions". iPSC5 Response: PSC. believes that' " control' rod movements" is the correct wording,. consistent with the.NRC's position in their letter of July 2, 1987 L(G-87217),: Comment'3;9.1#3. The NRC accepted this position. $e ~

Resolution:

-B 'NRC' Comment:' 3.7.3-If'the instrument. air system.is: absolutely required'for the functions

defined 1n the Basis, especially the operation of the pneumatic

) valves required; for, SAFE SHUTDOWN COOLING, then this Specification 4should be relocated into TSUP' draft Section 3/4.5 as an essential part Lof the emergencybcore cooling system. Previous NRC comments -transmitted.by NRC. letter dated May 30, 1986, continue to apply. PSC Response:

Asl st'ated in the previous response to Comment 3.7 #1, PSC believes that the' Instrument Air Specification is appropriately located in

. Section.7.' The.NRC accepted this position. g Resolution: ~B l: u .w 1.; i 4 'r-}

mm m: - + f:b gw l' 4 " L, ^ i G_ i , 3. 7. 5- ]

NRC Co~mment:. -

The.TS0Piraft, Specification! for.the' Primary Coolant Depressurization- ~ ' system is. functionally : equivalent to'.the; STS.. Specifications".for

Containment Depressurization:and. Cooling Systems.

The Fort St. Vrain -Primary'CoolantLDepressurization has 'o. PLANT SYSTEMS function,- only. n containment-equivalent: functions.. Previous NRC comments transmitted by,lthe NRC' letter dateW May 30, 1986, continue to apply. H' PSClResponse: A. noted in.PSC's 'respons'e to p eviousLcomments (3.5, 3.7 #1), PSC believes that-the.TSUP objective of clarity and ease of-'use by: the ' operators..would1:be' better served by retaining..the organization as proposed.: The Primary Coolant:.Depressurization specification Lactually' uses : portions of, the' helium purification system, which is felti-to be'more easily identified ~as.-a Plant; System than :as a containment' system. ;-The NRC. accepted this position. e p: LPSC' agreed 'to ? clarify. th'e_ Bases for 3/4:7.5 to explain the reasons for PCRV:depressurization, relative to. containment and heat transfer,. Resolution: B: NRC Cominent: 3;7.8 #1 O The -ACM. diesel _ generator specification should be relocated to TSUP = ' ' ' -draft Section 3/4.8. The'ACM is not a PLANT SYSTEM, specifically not ~ -a fire' protection system. .PSC-Response: PSC1 agreed 'that the ACM functions extend beyond Fire Protection and proposed to' relocate this specification to Section 8. This revision .will.be'provided with the next submittal of the Electrical Technical Specifications. > Resolution: A#. l, g 4 l :. (.' l l w* b

by,, 8 ? h A.. p, 4

5. 80

'l,% yn t y ;p

.- j. _ 1X.

%,j .NRC-Commenti.3.7 8 #2 l The Basis.':for the= proposed specification 3/4.7.8 is'not consistent-with that given for the. existing specifications 4.2.17 and 5.2.20. ?The. Basis; for;the proposed Specification 3/4.7,8 must:be revised to ' eliminate the. implication that the intended function of the ACM is to teffect SAFE. SHUTDOWN COOLING.. Instead,!the specific' functions of the b

ACMLas; given in FSAR -Section-8.2.8.2 need to, be : included in the Basis, ;and sthe ' consequence. goal of the ACM needs to specified per

.,s a ~ FSAR-Sections' 8.2.8,< namely, insuring that "the conditions of public

healthicand' safety Consequences,fanalyzed. and presented in Design

Basis: Accident Number l 'in-(FSAR) Appendix D.1, are not exceeded' in-r

the!Tcase.of'.... disruptive faults or : events in congested cable Eareas.".The ' fact ~ that the risk goal for the ACM. is ' an " acceptable 1sub'stitution" fer the.-cold shutdown (ori safe shutdown) goal per

.7,

10CFR50,1 Appendix R, :should Lalso.be noted,- but no. statement -should be -

-/ K 'made either-: indicating-orf implying that the.NRC's agreement to an '" acceptable? -substitution" represents " equivalency" to'

the Requirements ofj;10CFR50, ' Appendix. R.

.The ACM provides for " core tsubcriticality and' safe containment" whichfis not-equivalent to a-condition of " safe-shutdown" without' fuel-damage. + PSC' Response: ~PSC~agreedito clarify the ACM T.S.: Basis to state that the ACM is not-relied'upon for.' Safe Shutdown Cooling ~ .This revision will be provided. 'with the next-submittal of the Electrical: Technical ' Speci fications. Resolution: A#: . n i

• y, 9,

-), >l.- x,;&

I ho NRC Comment: 3~.-7.8 #3 FSAR Appendix CL and FSAR Section '1.2.2.9 need to be revised to present a protrayal of the ACM functions and consequence goal consistent with that presented in FSAR Sections 8.2.8 and 14.10 and FSAR Appendix D.. Use of such terms as " safe shutdown," " safe shutdown. cooling," " emergency cooling," and " safe condition" to refer i directly or indirectly to the ACM function or to the associated operatio nof PCRV LCS should be eliminated in the FSAR Appendix C and ,FSAR Section 1.2.2.9. In addition, FSAR Appendix C.48 needs to be revised to remove the implied capability of the ACM diesel generator to perform "the sequential programming of essential electrical loads". PSC Response: As noted in Enclosure 3 to G-87131, changes to'the FSAR are beyond the scope of the TSUP and will be reviewed separately. The NRC accepted this position. Resolution: F WRC Comment: 3.7.8 #4 Previous NRC comments transmitted by the NRC letter dated May 30, 1986, continue to apply. PSC Response: Previous comment agreements will be reflected in the re-drafted Tech Specs at their next submittal. NRC accepted this position. ' Resolution: B y. , i l ____2_z-_

a

a" NRC Comment

;3.9.1 (Part 1)

The-requirement that the CORE AVERAGE INLET TEMPERATURE must.be less than.or equal to 165 degrees F is not sufficient to define safe . conditions for REFUELING..The relationship between the allowed entry intoLthe REFUELING mode and the value of the CALCULATED BULK CORE TEMPERATURE fneeds -to be specified. The cooling capacity during REFUELING should be specified in terms aof the preferred equivalent " residual heat removal" system configuration consistent with the approach'used in the W-STS Specification 3/4.9.8 and with the implied assumption, that such capacity is available per FSAR Section 9.1.1.4. 'The fact that PSC failed to identify within the FSAR the preferred equipment configuration necessary to meet the minimum operating conditions for' REFUELING should not be construed as relieving PSC from the responsibility of specifying the needed equipment OPERATING and OPERABILITY conditions within the Specifications. If PSC prefers to divide. up-or realign Specifications within TSUP draft 3/4.9 to respond to these comments, such revisions are acceptable prov!ded that the above comments and those comments previously provided by NRC in the NRC letter dated May 30, 1986, are incorporated. PSC Response: As noted ~in PSC's response to Comment 3.7.1.1 #3, PSC does not believe that it would be appropriate to specify a Calculated Bulk Core Temperature (CBCT) that must exist to enter the Refueling mode. The CBCT is'a time dependent variable that assumes a loss of forced circulation. During any operating mode, including refueling, it is possible to stop forced circulation and eventually reach a CBCT of 760' degrees F. The CBCT is controlled via 3.0 guidelines and should not be a criteria for mode definition. Although it was agreed that PSC would resolve this comment by adding " REFUELING *" to the Applicability, similar to all other Specifications that address the Calculated Bulk Core Temperature, PSC has re-evaluated this concern. The current Applicability is "Whenever both prima ry and secondary PCRV closures of any PCRV penetration are removed." PSC considers this more appropriate for maintaining the stated reactor conditions, since the Calculated Bulk Core Temperature is not currently addressed in this Specification. Consistent with. G-87217 Enclosure 2, PSC has revised Actions b and c.1 to include suspension of all evolutions resulting in positive reactivity changes if themeutron flux monitors are not all operable. Resolution: A# . l

7 @p g t b NRC. Comment: !3.9.1.(Pa'rt 2)' Currently, core' conditions'during REFUELING are unclear with regard to expected heat loads and cooling capacity. Therefore, FSAR Section 9.1 should bei revised to include figures and perhaps tables that provide a correlation of typical expected values ~for the LCALCULATED-BULK' CORE TEMPERATURE, the-calculated decay heat fraction normalized t to rated reactor power, and the CORE' AVERAGE' INLET TEMPERATURE. as. a ~ function' of-time after shutdown. Such correlated data would be usefulito demonstrate expected core heat loads and cooling capacities 'in : SHUTDOWN. preceding. entry.into REFUELING. Such informatoin should be.available for SHUTDOWN both immediately from full power at the end .of an equilibrium cycle. This comparative information.should clarify the. conditions existing within-the reactor and core..following. entry. into' SHUTDOWN and before REFUELING. 'PSC Response: , As' noted" in Enclosure 3 to G-87131, changes to the FSAR are beyond -the' scope'of the TSUP and;'will be; reviewed separately. The NRC accepted this' position.- Resolution: F.' I 1 l l 4 l.',

~ 4-kN [', b' NRC Comment: SR.4.5.1.l' In;. addition.to our previous comments, we-request that you consider further: revisions for Specification SR 4.5.1.1-. These revisions are L , necessitated ~ by concerns raised in Reportable Occurrence 50-267/86-026 with regard to demonstrating the adequate' supply of firewater simultaneously to both the helium circulator Pelton wheel and the steam generator economizer-evaporator-superheater (EES) section. SR 4'.5.1.1.b.1'.'4.b). -In SR. 4.5.1.1.b.1,needs.to be modified to be performed in conju SR~4.5.1.1.a " proper flow" through the emergency ;feedwater header and the emergency condensate header'also -should be-quantified in terms of the accident conditions. This means

the surveillance test ' conditions should be at the required flow of-simulated firewater;with accident condition back pressure in the EES section.and:at circulator; operation 3% (or 3.8%) rated helium flow on Lthrottled condensate to-simulate. firewater pump discharge.

In effect,:-SR-:4.5.1.1.2.4.b) and SR 4.5.1.1.b.1 should-reproduce test. ~ conditions equivalent to Test T-30 and/or-T-30A~so as to verify the 1 continued. efficacy of the ~ firewater-cooldown on a periodic basis. ' Test-conditions such as throttled condensate pressure and EES back-pressure need to be stipulated in the Basis for SR 4.5.1.1. .PSC Response: ( PSC' considers that this. test is 'more appropriately considered a design verification test, and. it should not. be a periodic surveillance. Furthermore,- 'PSC cannot perform a meaningful demonstration of flow;through the EES sections. The model uses flow -through the EES, throttled to prevent boiling, and exhausting out the . vent valves ~. During shutdown conditions when any testing could be performed, the back pressure due to boiling cannot be simulated, nor ] could any.two phase flows which might be experienced. Since one of j the critical limitations is choke flow of steam, any other demonstration would not be meaningful. The NRC accepted this position. Resolution: B'

-, ~-,:. > j:, ..k ' I to P-87410 i i I RESPONSE TO NRC COMMENTS REGARDING SAFETY RELATED COOLING FUNCTION DRAFT TECHNICAL SPECIFICATIONS j (CONTAINED IN ENCLOSURE 3 I TO G-87217) r Li___ -- -_

1.. w w, n , ~ - - - - - - - - - )- -u <,1 o. 3:, s '..f. 8 7 2 ,,9 ) \\ s,. J.S

RESPONSE TO NRC COMMENTS

.This:'attachmentLaddresses comments provided in Enclosure 3'to NRC m'

~ .letteridated Julyj 2,1987 (G-87217). For.the 'most.part,.the NRC: , comments; have 'been repeated.in their entirety. A few.of the more -lengthyccomments havle been summarized. , Ne N ~Commenticategories-.used;in this Attachment'are as follows: L 'A-PSC. accepts' comment as proposed ~ A#liPSC-accepts comment with some changes'or provides new wording.

B lNRCacceptsPSCposition f W..n; C: ;NRC accepts lPSC positionLand-PSC will justify.

D. .PSC1wil1 review further o". ' D*flNRC will review further .F: ; Comment'.is-beyond scope'of TSUP-f f 1 i 1,.'

,l n

L 1 f - I' " M2_.

7y, c. .~ . U~ ~ l% )NxC.' Comment: -RAIJ3.5.1;1'#1' l s _.,n, L1 .,Ba.s'ed Loni the 'PSC ' letter (P-87002) dated January 15'.1987, the ^ .+ ' condition statement-'forlLC0 3.5.1.1.a.2.needs-to. be rewritten as

follows

Both-steam generator sections (both the. economizer-evaporator-3 superheater, (EES)- and' the reheater) OPERABLE including two-

' OPERABLE flow paths. i i o - PSC Response: w 'Th'el requirement ' '.for both reheaters is' included in PSC's re-drafted -_ peci fication. S 7p -Resolution: A- ..-E >NRC Comment: <R I 3.5.1;1'#2 f Previously, the' safe; shutdown cooling. outlet flow paths were via the

by pass valves off each loop's'superheater outlet and.each loop's hot

~ reheat ' steam..line. The.by pass-valves were verified to be OPERABLE. 'as:part of the normal: operation of.the. bypass function'. The recentlyL installed sixtinch vent lines described in P-87002 are apparently not- 'o to.be used on a routine' basis. Therefore, SR 4.5.1.1.b needs to be Krevised '.: by ' renumbering surveillance b.2' and b.3 to b.3 and b.4, n respectively; and' adding a new surveillance as SR 4.5.1.1.b.2. The .new:SR 4.5.1.1.b.2 should read as follows: ' Ati least once per 18 months by verifying the OPERABILITY of each superheater' outlet flow path by verifying that the valves in the six : inch vent -lines can be opened.and that the vent flow paths are not' obstructed. s ~, ' - PSC-Response: i PSC has included a vent valve surveillance in the re-drafted Specification. 1 Resolution: A \\' i )

~ ~ ] gg9 pn~ yz, s 1 1 4 (Ei. pq

NRC' Comment:. RAI 3.5.1.1 #3 c'

,y

Subject to NRCLfinal approval of'the proposed revisions'to the Basis

~ p.~ ' forlthe; existing LCO 4.1.9,1 the following paragraph needs, to be 'added ati the? bottom of.. thei. fourth. page 'of the Basis for LC0 3.5.1.1 following>the second paragraph'of'the subsection entitled Redundance. L Criteria: q, l Specification ' 3.0'.N p'ro' ides :the methodology and necessary data v 7

to determine'.the appropriate time! interval to reach a CALCULATED ~

~ BULK CORE TEMPERATURE' of 1760 degrees F. If the active. core remains below this'. temperature, which corresponds to the design ' maximum;-co'reiinlet-temperature.as indicated above, then the . design core' inlet temperature cannot'be exceeded.and there.can be .no* damage'.:to. fuel or PCRV internal components.regardlessLof the- . amount, including.' total.. absence, or reversal, of primary co'olant -F helium flow. -PSC, needs' to " provide' the', appropriate : number "N"?for the cross- . referenced: Specification.':..The need for Specification 3.0 N has been: Lidentifieds. ini thel NRC -Request ~ for, Additional Information -at. PSC Response: PSC:' agreedto: -add, the proposed paragraph to the Basis for all Specifications;that use_the Calculated Bulk Core Temperature. The new. paragraph number.is.3'.0.5. Resolution: A l k 4 , c. = _ - _ - - _ -

f. ;q) ? ' "k NRC Comment: RAI 3.5.1.1 #4 The first paragraph. of the subsection entitled Steam Generato,s on .the fifth page of the Basis for LC0-3.5.1.1 and LCO 3.5.1.2 needs to be replaced with the.following paragraph. Whenever the CALCULATED BULK CORE TEMPERATURE exceeds 760 degrees F,. both the reheater. and. EES sections of the steam generator must be-OPERABLE. The steam generator reheater or EES sections can receive water from either the emergency condensate header or the -emergency feedwater header as required to be OPERABLE per this Specification. and per. Specification 3/4.5.3. . System flow OPERABILITY, is-determined by verifying flow from each of the aforementioned emergency headers (see LCO 3.5.3.1) through each section of each steam generator. Whenever the CALCULATED BULK CORE TEMPERATURE is'less than or equal to 760 degrees F or the . plant OPERATIONAL MODE is REFUELING, system flow OPERABILITY is determined by verifying flow from either of. the aforementioned emergency- - headers : (see LC0 3.5.3.2) through either section of either steam generator. PSC. Response: PSC. agreed that_ all. the stated flow capabilities should be demonstrated, except that the reheaters cannot receive wat n from the . emergency. feedwater header. This is accomplished on an 18 month .. basis.per the re-drafted Specification. It is not possible to demonstrate these flow capabilities (e.g., emergency condensate to the reheaters and EES sections) during plant operation. PSC believes that once the 18 month demonstrations are performed, these flowpaths should be presumed operable until some part of the flowpath is declared inoperable. A daily equipment status check has been proposed and PSC does not believe that any additional demonstration is appropriate. PSC agreed-to revise the Basis to describe the flow demonstrations and equipment status check. Resolution: A# l _ - _ 1

rc. ". F3V r i i. i : xi:',, l NRC Comment: RAI 3.5.1.1 #5 l An additional. paragraph is. also required under the subsection entitled Steam Generators on the fifth page of the Basis for LCO 3.5.1.1. This paragraph.needs to discuss the appropriate operability L requirements for the. seismically and environmentally qualified six ' inch vent lines and to cite the supporting safety analysis requiring the use of these vent lines. l PSC-Response: .PSC' agreed to add the requested paragraph to support the vent valve surveillance. Resolution: A# i NRC Comment: RAI 3.5.1.2 #1 Contrary.to NRC Comment No. 1 on LCO 3.5.1.2 as given in Enclosure I to the NRC. letter, Heitner to Williams, April' 17, 1987, the words to be added after the word "0PERABLE" in the condition statement for LC0 3 5.1.2.a.2-need to be " including one OPERABLE flow path," not two. LCO 3.5.3.2 requires only. one flow path, either the emergency j condensate header or the emergency feedwater header, to be OPERABLE l in STARTUP.and SHUTDOWN whenever the CALCULATED BULK CORE TEMPERATURE is less.than.or equal to 760 degrees F or in REFUELING. PSC Response: PSC has revised the re-drafted Specification to include the NRC comment. ' Resolution: A ) i NRC Comment: RAI 3.5.1.2 #2 See NRC Comment No. 4 on LCO 3.5.1.1. PSC Response: See previous response to Comment No. 4 on RAI 3.5.1.1. Resolution: A# 1 i

g:

t' NRC Comment:

RAI 3.5.1.2 #3 LDelete LCO 3.5.1.2.b.1. and renumber b.2 through b.5 as b.1 through b.4, respectively. The deleted LCO is neither needed nor appropriate since the. boiler feed pumps'are not required to be OPERABLE under the same APPLICABILITY statement (see LC0 3.7.1.1) nor necessarily the -emergency 'feedwater header. (see. LC0 3.5.3.2).

Also, the NRC commented that the current wording of Specifications 3/4.5.3 and 3/4.7 1.1 do not provide for.the OPERABILITY.of the feedwater-drive for the safety-related emergency core cool ir,g function when the CALCULATED. BULK CORE TEMPERATURE is less than 160 degrees F although fission heat is allowed to be as high as 5% of rated reactor power in STARTUP.

PSC Response: PSC. has re-draf ted the Specification to delete L C0 3.5.1.2.b.1. The Boiler. Feed Pumps are required operable whenever Calculated Bulk ' Core Temperature is greater than 760 degrees F, including in startup. Although technically the plant could be in a condition where the Specification' is not applicable, as a practical matter once FSV is in

startup, the time to reach 760 degrees F is short enough that PSC would generally want the affected equipment to be operable.

The NRC accepted this position. Resolution: A, B i i 1 l I l i , l l

Ry ~ . %O,u E NRC Comment: RAI:3.5.1.2 #4 24;.LCO 3.5.1:2 ACTION b needs to be~ rewritten as follows: 'b. With ?less' than the. above required OPERABLE equipment and. Ewith'no' forced _ circulation being maintained, be in at least 9 SHUTDOWN within-:10: minutes an suspend' all operations involving CORE ALTERATIONS,; control rod. movements ~ resulting

in= positive reactivity changes, or_ movement of IRRADIATED

. FUEL,-and either: 1. Restore forced circulation'on at'least'one loop prior to reaching,a CALCULATED BULK CORE TEMPERATURE-of 760. degrees F, and comply with ACTION a, or,- m

2.

Initiate'.PCRV 'depressurization in accordanceLwith the ~ ime~ specified. in Figures 3.5.1-2. or 3. 5 '.1-3,. as t applicable. 'PSC Response: - This comments deals: mostly with 're-draf ted LC0_3.4.1.2. PSC agreed .that Core Alterations lare not desirable during.an LLOFC and revised Lthe. Action. accordingly;._ NRC also' agreed that suspension of " movement of IRRADIATED FUEL".was not an appropriate ACTION for ': circumstances involving a ' loss of forced cooling. Also,- consistent with the ' discussion in. comment RAI 3.5.3.2 #1, "10. minutes" should be "12 hours". PSC agreedcto revise all' ACTIONS accordingly. ^ Re' solution : A#' s i -o .. = _

k:m ' g T-5 ma'i.,, f f I NRC'Commenti$RAli3.5.1.2f#5- In LCO,'3.5;1~.2,-L both ACTIONS ~a'. and b, the words CALCULATED BULK CORE-TEMPERATURE" are used:with; regard :to.the: required restoration of [~ .be added afterqcthewordH" TEMPERATURE" withJ the.following words eq'uipment.or conditions.,'In both-instances, a footnote symbol should J .provided in the' text of'the footnote: - Specification i.3.0.N. Lprovides ;the' methodology 'and necessary data .1 'to determine the appropriate-time.:intervalito-reach a CALCULATEDLY ! BULK CORE TEMPERATURE.of 760' degrees F. ~ t ~ PSCiineeds to( provide ;the ' appropriate number "N" for the cross-- i referencedsSpecification. ' PSC Response: 4 .TheLnew. paragraph wil.1 be-3.0.5. PSC< agrees jtsat references to' 3.0.5 'are useful but we feel that the

individual l Specifications would _become '" cluttered" if-lengthy l

expla'natoryi notes 'are.- 'added. each time the Calculated Bulk Core 1 _ Temperature 1s applied. ;PSC will add a statement to: the definition- .- and in.the Basis.that' states, 7 "Use'Tof the Calculated.-Bulk Core Temperature is explained in ..Speci fication. 3.0.5." Reso10 tion: A i 1 NRC Comment:- :RAI 3.5.3.1 #1-In :SR.4.5.'3.1, the reference to; Specifications 4.5.2.1.a needs to be deleted and replaced'with'a reference to Specification 4.5.1.1.b.1. LPSC. Response:

In the re-drafted Specifications, the corrected cross reference is 4.5.3.2.b.1.

Resolution: A-J p 1 r I _ = _ = _ _ _. _ _ _ _ _ _ _ _ - - - j

w+,., H4 ip i s<- , y!]4 NRC Comment: 'RAI.3.5.3 1'#2 i o See'above NRC Comment'No. 3 on LCO 3.5.1.2. .s 4 i SPSC Response: See previous response to Comment No. 3 on RAI 3.5.1.2. Resolutions LA B! i l .1 NRC: Comment: RAI 3.5.3.2-#1. i 'The ACTION for' LCO L3.5.3.2. needs to be deleted and replaced as follows: With_both_the emergency'feedwater-and emergency condensate header Dinoperable, be in at'least SHUT 00WN within 10 minutes and restore-ati.leasto one' header LtcL OPERABLE status-prior to reaching a ' CALCULATED' BULK-CORE' TEMPERATURE of 760 degrees. F and suspend all operations Jinvolving-CORE ALTERATIONS,' control ' rod' movements -resulting -in ' positive reactivity, changes, or movement of-IRRADIATED; FUEL. t 'PSC Response: PSC ag re ed,.- except the "and suspend" should be "or suspend". Also, it was agreed that "within 10 minutes" should'be "within 12 hours" 'and the""orfmovement of. IRRADIATED' FUEL" should be-deleted' I . Resolution: A# i I i ) 4

1 L

m___ ..L_.m-.

ur i '9: : (' Ai, s e s W 'k "n NRC Comment: 'RAI.3;5.3:2 #2,.3 and 4-Abh In the ACTION,'PSC should add the same footnote as described above in' - NRC Comment No.-5 on'LCOE3.5.1.2. .Similar information and cross references.as~provided in.the' footnote.should'also be included in the-m Basis. ~ 4 .Inl:SRJ 4.5.3.2, the reference to Specification 4.5.2.1.a.needs to.be ! deleted and replaced with'a reference to' Specification 4.5.1.1.b.1. ' See above NRC Comment No. 3 on LCO 3.5.1.2. PSC Response: See previous r'spo'nses to' Comment No. 5 on'RAI 3.5.1.2, Comment No. 1 9 e ~ - on RAI: 3.5.3.1, and. Connent No. 3 on RAI 3.5 1.2.

Resolution

.AfA,A,.B.

\\ i i i l 1 0 l m. V-~ i

i T,. L 'NRC Comment: RAI 3.5.4 i In ACTION b (the second' part of.the ACTION statement on page 3/4 5-30), PSC should add the same footnote as described above in NRC Comment No. 5 on LCO 3.5.1.2. A request to modify this ACTION has been provided in the' NRC Request for Additional Information at Enclosure 2. The words "within 24 hours" need to be replaced with the words " prior to reaching a CALCULATED BULK CORE TEMPERATURE of 760 degrees F but'within a period of time not to exceed 24 hours." Similar information and cross references as provided in the footnote should also be included in the Basis. PSC Response: The subject Action is only concerned with providing backup fire suppression. PSC is proposing to delete all fire protection Tech Specs, per GL 86-10, including this Action. .It was agreed that this Action should be replaced with one similar to that'for losing both emergency condensate and feedwater header capability, as follows: (With Calculated Bulk Core Temperature less than or equal to 760 degrees F:) b. With no capability of supplying SAFE SHUTDOWN COOLING water to the emergency condensate header isolation valve or to the emergency feedwater header isolation valve, be in at least SHUTDOWN within 12 hours and restore the required supply capability prior to. reaching a CALCULATED BULK CORE TEMPERATURE of 760 degrees F or suspend all operations involving CORE ALTERATIONS or control rod movements resulting in positive reactivity changes. Resol'ution: A#

l 1

L -__

yy g ~-- M ;*J

NRC Comment

'RAI"3.6.2.2 #1' 7

i.J / n2LLCO 3.6.2.'2,' 'the' condition-. statement' should. be deleted and-I treplaced1with the following: ,uThe1 Reactor Plant 1Co'oling Water (RPCW)/PCRV Liner. Cooling System ~ (LCS) shall'be~ OPERABLE'with: .ai One.lRPCW/PCRV LCS loop OPERATING with at least one-heat

e'xchanger.and_one pump in each-loop. OPERATING, and

b.

With.. firewater supply.available'via one-0PERABLE flow path.

.;Th'e? change.is necessitated _to comply with.the NRC guidelines'for PSC-commitments with regard.to= proposed revisions:to existing LCO 4.' 1. 9. These Eguidelines;'are.;given.in the NRC letter, Heitner to Williams,. dated December 5, 1986-(G-86631). PSC Response: 'As' agreedi'with the NRC, PSC only committed in P-87124 (response-to 4 + G-86631)?tbTensure firewater supply capability during a planned loss -'of: forced circulation, when,the liner cooling. system is relied upon 'for. decay h; eat removal. 3The proposed change. to-LCO 3.6.2.2 would -'extendithis; commitment. to anytime Calculated Bulk Core Temperature is

below 760 degrees F, Lincluding-the entire Refueling mode.

PSC belie'ves that:the. original-. concern is' addressed by the TSUP expanded requirement for firewater systeru. operability-per 3.5.4. This is . reinforced.,by: PSC's Administrative _. Controls for loss of forced circulation. 'NRC accepted.th.is position. Resolution: B. l q l ) l .Li, 1 l l l l i --i i_.._i__._._ ___2

m. v o $ [? ~ )l J nM ,( ':Q e' ?YliO;; l

NRC Comment: ' RAIL 3'6.2.2.#2:

Sr Inc LC0;'3.6.2.2,Lthe ACTION statement should be' deleted and' replaced 4 Lwith theLfollowing: t Wi.thlno RPCW/PCRV2LCS;1oop OPERATING, within;10 minutes,:be in at K least ' SHUTDOWN 1.and 1 suspend all operations- : involving CORE ' ALTERATIONS,. control rod. movements -resulting in positive Ls ireactivity changes, or movement of IRRADIATED FUEL, and: m La. Restore 1:at."least-one loop; to :0PERATING. status prior to m reachingfa:. CALCULATED' BULK CORE, TEMPERATURE of 760' degrees .a y .F, or m s: , ;b. Restore'. forced: circulation -cooling-prior to reaching a ,j CALCULATED BULK CORE ~ TEMPERATURE of 760 degrees F. The; change (isnecessitated.toLeomplywiththeNRCguidelinesfor.PSC- "'p, en commitments withl regard to proposed revisions to existing'LCO '4.1.9. (Thesei g'idelines1;are ;given"in the.NRC letter, Heitner to. Williams, u ! dated December l5, 1986. PSC Response: e ~ Requiring' al suspension ~of Core Alterations.within 10 minutes.rather than after reaching a 760 degree. Calculated-Bulk Core Temperature is; JconsistentM with the G-86631. con'ern that' all decay heat-removal c z capability could be disabled. PSC agreed:to propose a new Action that :would ' require either one operating PCRV LCS. loop or forced 'circulationiwhere the? Calculated Bult' Core Temperature is

degrees F.'

~ below 760 l Resolution: 'A# ~ i 4 r, ll:n 'i\\u Mc_._._._.._.

m -;g

g

'ZhyI nt i ]G 1 4:O 9; ^ i sNRC-Comm'ent: RAI' 3. 6 '. 2. 2.# 3 - t LIfathe.inteffacingisolationivalvesbetween'the.firewatersystemend. ~ 'l ~*' ithe RPCW/PCRV LCS-are.not covered-in:the-surveillance .on the SAFE

o SHUTDOWN-- COOLING. water? supply.-system' per SRf 4.5.4.1.f or SR-4.5l4.1.g.3,~the' subject? isolation ' valves need to be. covered by revisingzSR 4.6.2.2-appropriately.

PSC Response: m LPSC agreed to include.these" valves in the SR'4.5.5 surveillance.for the ;fi rewater.. system. 4 .Resoldtioni LA, q-i NRC. Comment:' RAI'3.6.2.2 #4,:3.7.1.6, 3'.7.4.2- .In the: ACTION, PSC should^ add.the same footnote.as described above in

NRC Comment No. 5 on LC0- 3-5.1.2.

Similar ;information and cross references:as provided in the footnote ~should also be. included in the tBasis. s 1 PSC. Response: l See prev.ious1 response'to' Comment'No. 5 to RAI 3.5.1.2. . Resolution: TA, l ' NRC Comment: RAI 3.7.1.1-1 See above NRC Comment No. 3 on LC0 3.5.1.2. I LPSC Response: See previous discussion regarding Comment-No. 3 on RAI 3.5.1.2. 1 Resolution: A, B i i ~ N. 2':: i I 1 i __}}