ML20237A792

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Proposed Tech Specs,Increasing Max Boron Concentration in SITs & Rwsp from 2300 Ppm to 2900 Ppm
ML20237A792
Person / Time
Site: Waterford 
Issue date: 08/12/1998
From:
ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20237A791 List:
References
NUDOCS 9808170104
Download: ML20237A792 (15)


Text

I BORATED WATER SOURCES - OPERATING (8ITINGCONEITIONFOROPERATION 3.1.2.8 Each of the following borated water sources shall be OPERABLE:

a..

At least one of the following sources:

1)

One boric acid makeup tank, with the tank contents in accordance with Figure 3.1-1, or 2)

Two boric acid makeup tanks, with the combined contents of the tanks in accordance with Figure 3.1-1, and b.

The refueling water storage pool with:

1.

A minimum contained borated water volume of 475,500 gallons (83% of indicated level), and 2.

A boron concentration of between 2050 and 2300 ppm of boron, and l 3.

A solution temperature between 55'F and 100*F.

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

EllQH:

a.

With the above required boric acid makeup tank (s) inoperable, restore the tank (s) to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and borated to a SHUTDOWN MARGIN equivalent to the requirements of Specification 3.1.1.1 or 3.1.1.2, whichever is applicable; restore the above required boric acid makeup tank (s) to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.

With the refueling water storage pool inoperable, restore the pool to OPERABLE status within I hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.1.2.8 Each borated water source shall be demonstrated OPERABLE:

a.

At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying the RWSP temperature when the Reactor Auxiliary Building air temperature is less than 55'F l

or greater than 100*F.

b.

At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying the BANT temperature is above 55*F when the Reactor Auxiliary Building air temperature is i

less than 55*F.

c.

At least once per 7 days by:

1.

Verifying the boron concentration in the water, and 2.

Verifying the contained borated water volume of the water source.

WATERFORD - UNIT 3 3/4 1-14 AMENDMENT NO. Mr+9,129 l

9808170104 980812 PDR ADOCK 05000382 P

PDR

REQUIRED STORED BORIC ACID VOLUME AS A FUNCTION OF CONCENTRATION 15000 14000 REGION OF ACCEPTABLE C

OPE R ATION I

e 13000 E

2 d>

RWSP at 2000 ppm 1

/

8 (965)

(

RWSP at 2300 ppm g

11000 0

3 (875)

(

10000 (785) e

==

4 I

9 y

(E695)

(

U REGION OF UNACCEPTABLE g

OPERATION g

(605)

(

7000 (5J0 2.25 2.50 2.75 3 00 3.25 3 50 13.9501 (4.3751 14.825) t5.2501 15.7001 (6.1251 80RIC ACID CONCENTRATION, WT.% (ppe)

FIGURE 3.1-1 WATERFORD - UNIT 3 3/4 1-13 AMENDMENT NO. L:, " 141

i REQUIRED STORED BORIC ACID VOLUME AS A FUNCTION OF CONCENTRATION 1

15000 l

14000 REGION OF ACCEPTABLE

{

1 p

O PER ATION 2

13000 3

8 RWSP at 2000 ppm 1

Y o

RWSP 2300 ppm

)

(

f Q

o g

~

Dg (875)

(

10000 2<

(785)

I

=

$=0

<1 9

y (695)

(

u REGION OF UNACCEPTASI.E g

OPERATION g

(605)

(

7000 e

2.25 2.50 2.75 3 00 3.25 3 50 13,9001 (4,3751 (4,825)

(5,250)

(5,7001 (6,1256 80RIC ACIO CONCENTRATION, WT.% (ppa) l FIGURE 3.1-1 Tkss c.vn.vt. buds RWS9 cece%I2ot M 9 My ^,3 Z300 ppm to tqoo pIm 3/4 1-13 AMEN 0 MENT NO.

-,,-141 WATERFORD - UNIT 3

3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3/4.5.I SAFETY INJECTION TANKS LIMITING CONDITION FOR OPERATION 3.5.1 Each Reactor Coolant System safety injection tank shall be OPERABLE with:

a.

The isolation valve open, b.

A contained borated water volume of between 926 (40%) and 1807 (83.8%) cubic feet, c.

Between 2050 and 2300 ppm of boron, and l

d.

A nitrogen cover-pressure of between 600 and 670 psig.

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

El1QH:

a.

With one safety injection tank inoperable, except as a result of a closed isolation valve, restore the inoperable tank to OPERABLE status within I hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b.

With one safety injection tank inoperable due to the isolation valve being closed, either immediately open the isolation valve or be in at least HOT STAND 8Y within I hour and be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.5.1 Each safety injection tank shall be descastrated OPERABLE:

a.

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by:

1.

Verifying the contained borated water volume and nitrogen cover-pressure in the tanks. and 2.

Verifying that each safety injection tank isolation valve is open.

  • With pressurfter pressure greater than or equal to 1750 psia. When pressurizer pressure is less than 1750 psia, at least three safety injection tanks must be OPERABLE, each with a minimum pressure of 235 psig and a maximum pressure of 670 psig, and a contained borated water volume of between 1332 (61%) and 1807 (83.8%) cubic M With all four safety injection tanks i

OPERABLE, each tank shall han a inimum pressure of 235 psig and a maximum pressure of 670 psig, a boroa eventration of between 2050 and 2300 ppm l

)

boron, and a contained borated water volume of between 888 (39%) and 1807 i

(83.8%) cubic feet.

In MODE 4 with pressurizer pressure less than 392 psia l

(700 psia for remote shutdown from LCP-43), the safety injection tanks may be isolated.

WATERFORD UNIT 3 3/4 5-1 AMENDNENT NO. 4 M, 129 i

/V o G h 4 my es o o M,' r faye ~ fenidref fo" g on l+.ui%

i EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) b.

At least once per 31 days and within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after each solution volume increase of greater than or equal to 1% of tank volume.

by verifying the boron concentration of the safety injection tank solution.

At least once per 31 days when the RCS pressure is above 1750 psia, c.

by verifying that the isolation valve operator breakers are padlocked in the open position.

d.

At least once per 18 months by verifying that each safety injection tank isolation valve opens automatically under each of the following conditions:

1.

When an actual or simulated RCS pressure signal exceeds 535 psia, and 2.

Upon receipt of a safety injection test signal.

WATERFORD - UNIT 3 3/4 5-2 I

l l

l

[

"5 / )

EMERGENCY CORE COOLING SYSTEMS BASES ECCS SUBSYSTEMS (Continued) l With the RCS temperature below 350*F, one OPERABLE ECCS subsystem is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the limited core cooling requirements.

The trisodium phosphate dodecahydrate (TSP) stored in dissolving baskets located in the containment basement is provided to minimize the possibility of corrosion cracking of certain metal components during operation of the ECCS following a LOCA. The TSP provides this protection by dissolving in the sump water and causing its final pH to be raised to greater than or equal to 7.0. The requirement to dissolve a representative sample of TSP in a sample of water borated to be representative of post-LOCA sump conditions provides assurance that the stored TSP will dissolve in borated water at the postulated post-LOCA temperatures. A boron concentration of 3011 ppm boron is postulated to be representative of the highest post-LOCA sump boron concentration based on the assumptions used in calculation EC-S96-013.

The RWSP, SITS, and RCS maximum boron concentrations assumed are conservative estimates of future anticipated boron concentrations. The assumed maximum boron l

concentrations for the RWSP and SITS are greater than those currently allowed in Technical Specifications in order to bound future expected increases in required boron concentrations l

because of longer fuel cycles and higher energy fuel designs. Post-LOCA sump pH will remain between 7.0 and 8.1 for the maximum (3011 ppm) and minimum (1504 ppm) boron concentrations calculated using the maximum and minimum post-LOCA sump volumes and I

conservatively assumed maximum and minimum source boron concentrations.

With the exception of systems in operation, the ECCS pumps are normally in a standby, nonoperating mode. As such, flow path piping has the potential to develop voids and pockets of entrained gases. Maintaining the piping from the ECCS pumps to the RCS full of water ensures that the system will perform property, injecting its full capacity into the RCS upon l

demand. This will prevent water hammer, pump cavitation, and pumping noncondensible gas (e.g., sir, nitrogen, or hydrogen) into the reactor vessel following an SlAS or during SDC. The l

31 day frequency takes into consideration the gradual nature of gas accumuh tion in the ECCS piping and the adequacy of the procedural controls goveming system operation.

The Surveillance Requirements provided to ensure OPERABILITY of each component ensure that at a minimum, the assumptions used in the safety analyses are met and that l-subsystem OPERABILITY is maintained. Surveillance Requirefrants for throttle valve position stops and flow belance testing provide assurance that proper ECCS flows will be maintained in i

the event of a LOCA. Maintenance of proper flow resistance and pressure drop in the piping system to each injection point is necessary to: (1) prevent total pump flow from exceeding runout conditions when the system is in its minimum resistance configuration, (2) provide the proper flow split between injection points in accordance with the assumptions used in the ECCS-LOCA analyses, and (3) provide an acceptable level of total ECCS flow to all injechon points equal to or above that assumed in the ECCS-LOCA analyses.

The requirement to verify the minimum pump discharge pressure on recirculation flow ensures that the pump performance curve has not degraded below that used to show that tho' pump exceeds the design flow condition assumed in the safety analysis and is consistent with the requirements of ASME Section XI.

i WATERFORD - UNIT 3 8 3/4 5-2 AMENDMENT NO. 437,130

EMERGENCY CORE COOLING SYSTEMI 3/4.5.4 REFUELING WATER STORAGE POOL LIMITING CONDITION FOR OPERATION 3.5.4 The refueling water storage pool shall be OPERABLE with:

a.

A minimum contained borated water volume of 475,500 gallons (83%

indicated level),

b.

Between 2050 and 2300 ppe of boron, and l

c.

A solution temperature of between 55'F and 100*F.

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

ACTION:

With the refueling water storage pool inoperable, restore the pool to OPERABLE status within I hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE RE0VIREMENTS 4.5.4 The RWSP shall be demonstrated OPERABLE:

a.

At least once per 7 days by:

1.

Verifying the contained borated water volume in the pool, and 2.

Verifying the boron concentration of the water.

b.

At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying the RWSP temperature when the RA8 air temperature is less than 55"F or greater than 100*F.

WATERFORD UNIT 3 3/4 5-9 AMENDMENT NO. 49, 129

\\

NPF-38-209 ATTACHMENT B PROPOSED SPECIFICATIONS l

l i

. _ _ _ _ ~

'Y Y BORATED WATER SOURCES - OPERATING LIMITING CONtfTION FOR OPERATION 3.1.2.8 Each of the following borated water sources shall be OPERABLE:

a.

At least one of the following sources:

1)

One boric acid makeup tank, with the tank contents in accordance with Figure 3.1-1, or

)

2)

Two boric acid makeup tanks, with the combined contents of the tanks in accordance with Figure 3.1-1, and b.

The refueling water storage pool with:

I 1.

A minimum contained borated water volume of 475,500 gallons (83% of indicated level), and l%O 2.

A boron concentration of between 2050 and g ppm of boron, and l 3.

A solution temperature between 55*F and 100*F.

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

i ACTION:

4 a.

With the above required boric acid makeup tank (s) inoperable, restore the tank (s) to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANOBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and borated to a SHUTDOWN MARGIN

]

equivalent to the requirements of Specification 3.1.1.1 or 3.1.1.2, i

whichever is applicable; restore the above required boric aci:1 makeup tank (s) to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.

With the refueling water storage pool inoperable, restore the pool to OPERABLE status within I hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 q-nours.

SURVEILLANCE REQUIREMENTS 4.1.2.8 Each borated water source shall be demonstrated OPERABLE:

l a.

At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying the RWSP temperature when j

the Reactor Auxiliary Building air temperature is less than 55"F or greater than 100*F.

l l

b.

At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying the BAMT temperature is above 55*F when the Reactor Auxiliary Building air temperature is less than 55*F.

c.

At least once per 7 days by:

1.

Verifying the boron concentration in the water, and 2.

Verifying the contained borated water volume of the water source.

WATERFORD - UNIT 3 3/4 1-14 AMENDMENT NO. Md9,129 I

l 1

YY 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

~

3/4.5.1 SAFETY INJECTION TANKS LIMITING CONDITION FOR OPERATION 3.5.1. Each Reactor Coolant System safety injection tank shall be OPERABLE with:

a.

The isolation valve open, b.

A contained borated water volume of between 926 (40%) and 1807 (83.8%) cubic feet 3bOC c.

Between 2050 and g ppa of baron, and l

d.

A nitrogen cover-pressure of between 600 and 670 psig.

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

ACTION:

I a.

With one safety injection tank inoperable, except as a result of a closed isolation valve, restore the inoperable tank to OPERABLE status within I hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

l b.

With one safety injection tank inoperable due to the isolation valve l

being closed, either immediately open the isolation valve or be in l

at least HOT STANDBY within I hour and be in HOT SHUTDOWN within the l

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

SURVEILLANCE RE0VIREMENTS 4.5.1 Each safety injection tank shall be demonstrated OPERABLE:

l a.

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by:

1.

Vrrifying the contained borated water volume and nitrogen cover-pressure in the tanks, and 2.

Verifying that each safety injection tank isolation valve is open.

  • With pressurizer pressure greater than or equal to 1750 psia. When pressurizer pressure is less than 1750 psia, at least three safety injection tanks must be OPERA 8LE, each with a minimum pressure of 235 psig and a maximum pressure of 670 psig, and a contained borated water volume of between 1332 (61%) and 1807 (83.8%) cubic feet. With all four safety injection tanks OPERABLE, each tank shall have a minimum pressure of 235 psig and a a imum N e pressure of 670 psig, a bnron concentration of between 2050 and ppm T

boron, and a contained borated water volume of betwean 888 (39%) and 1807 (83.8%) cubic feet.

In MODE 4 with pressurizer pressure less than 392 psia (700 psia for remote shutdown from LCP-43), the safety injection tanks may be isolated.

WATERFORD - UNIT 3 3/4 5-1 AMENudENT NO. + M, 129 l

1,' ? ?

hjo Cl, amp es o n W' faf e - /<- eroded for f c,x f,' n v ily EMERGENCY CORE COOLING SYSTEMS I

SURVEILLANCE REQUIREMENTS (Continued) b.

At least once per 31 days and within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after each solution volume increase of greater than or equal to 1% of tank volume by verifying the baron concentration of the safety injection tank solution.

c.

At least once per 31 days when the RCS pressure is above 1750 psia, by verifying that the isolation valve operator breakers are padlocked in the open position.

d.

At least once per 18 months by verifying that each safety injection tank isolation valve opens automatically under each of the following conditions:

1.

When an actual or simulated RCS pressure signal exceeds 535 psia, and 2.

Upon receipt of a safety injection test signal.

l WATERFORD - UNIT 3 3/4 5-2 l

u__________.

(." I EMERGENCY CORE COOLING SYSTEMS BASES ECCS SUBSYSTEMS (Continued)

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

I The trisodium phosphate dodecahydrate (TSP) stored in dissolving baskets located in the containment basement is provided to minimize the possibility of corrosion cracking of certain metal components during operation of the ECCS following a LOCA. The TSP provides this protection by dissolving in the sump water and causing its final pH to be raised to greater than or equal to 7.0. The requirement to dissolve a representative sample of TSP in a sample of water borated to be representative of post-LOCA sump conditions provides assurance that the stored TSP will dissolve in borated water at the postulated post-LOCA temperatures. A boron concentration of 3011 ppm boron is postulated to be representative of the highest post-LOCA sump boron concentration.izzd ;. ^.M rrz;'_c.e inf b :i" '. G-57,40.

" : *^" S'T:, ;nd "00.Timr hn: ::===^ Maa? :r JT:d i. -i.

...uv.

9:^.x 21 S'am ens;:'d t-:-P -rar..

i... "
: rr c J n=--no n wucun sa-nu.iivn. iur u.. R,^.7.ud O'T: r- ~==* *=a 5:n e cier.*:, ;;;;;;;d h T;;M ce:

-4,.we.uvu..neide,; M.aJiumi e,,,C :fbz r r b.c 7 ;d Lisa enn..-E n in:n; ef lvnvoi iv.; of

..i; ',:vMi :n;;; '"r' f n'- :- Post-LOCA sump pH will remain between 7.0 and 8.1 for the maximum (3011 ppm) and minimum'(1504 ppm) boron i

concentrations calculated using the maximum and minimum post-LOCA sump volumes and J

conservatively assumed maximum and minimum source boron concentrations.

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

(e.g., sir, riitrogen, or hydrogen) into the reactor vessel following an SIAS or during SDC. The 31 day frequency takes into consideration the gradual nature of gas accumulation in the ECCS piping and the adequacy of the procedural controls goveming system operation.

1 l

1 The Surveillance Requirements provided to ensure OPERABILITY of each component ensure that at a minimum, the assumptions used in the safety analyses are met and that l

subsystem OPERABILITY is maintained. Surveillance Requirements for throttle valve position stops and flow balance testing provide assurance that proper ECCS flows will be maintained in the event of a LOCA. Maintenance of proper flow resistance and pressure drop in the piping system to each injection point is necessary to: (1) prevent total pump flow from exceeding I

runout conditions when the system is in its minimum resistance configuration, (2) provide the proper flow split between injection points in accordance with the assumptions used in the ECCS-LOCA analyses, and (3) provide an acceptable level of total ECCS flow to all injection points equal to or above that assumed in the ECCS-LOCA analyses.

The requirement to verify the minimum pump discliarge pressure on recirculation flow ensures that the pump performance curve has not degraded below that used to show that the pump exceeds the design flow condition assumed in the safety analysis and is consistent with the requirements of ASME Section XI.

WATERFORD - UNIT 3 B 3/4 5-2 AMENDMENT NO. 437,130


a

I ',T (

EMERGENCY CORE COOLING SYSTEMS 3/4.5.4 REFUELING WATER STORAGE POOL I

l LIMITING CONDITION FOR OPERATION l

3.5.4 The refueling water storage pool shall be OPERABLE with:

a.

A minimum contained borated water volume of 475,500 gallons (83%

l indicated level),

f MM b.

Between 2050 and j)JMr ppe of boron, and l

c.

A solution temperature of between 55*F and 100*F.

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

KI1QN:

With the refueling water storage pool inoperable, restore the pool to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least NOT STAND 8Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

l SURVEILLANCE REQUIREMENTS 4.5.4 The RWSP shall be demonstrated OPERABLE:

a.

At least once per 7 days by:

1.

Verifying the contained borated water volume in the pool, and 2.

Verifying the boron concentration of the water.

b.

At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying the RWSP temperature when the RA8 air temperature is less than 55*F or greater than 100*F.

I WATERFORD UNIT 3 3/4 5-9 AMENDMENT NO. 49, 129 l

p, l

1

)

l u

NPF-38-209 ATTACHMENT C REFERENCES 1

l

y29 l

q.,

NPF-38-209

)

i l

LIST OF REFERENCES

1. Waterford 3 letter W3F1-97-0053 dated March 27,1997, TSCR NPF-38-191.

I 1

l

_ _ _ _ _ _ _ _ _ _ _ _