Text

Proposed re-drafted Tech Specs,Upgrading Sections Re safety- Related Cooling Sys.Related Info Encl
	ML20238C348
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/23/1987
From:	; PUBLIC SERVICE CO. OF COLORADO
To:	;
Shared Package
ML20238C344	List: ML20238C343; ML20238C348;
References
	P-87441, NUDOCS 8712300212
	Download: ML20238C348 (127)
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Attachment I to P-87441 RE-DRAFTED TECHNICAL SPECIFICATIONS FOR SAFETY-RELATED COOLING FUNCTIONS hbk kDd k7 j

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Amendment No.

Page 3/4 4-1 j

DRAFT PRIMARY COOLANT SYSTEM DEC 2 31987 3/4.4.1 PRIMARY COOLANT LOOPS AND COOLANT CIRCULATION l

LIMITING CONDITION FOR OPERATION 1

l 1

3.4.1.1 Two primary, coolant loops s ha l'i be in operation ano 8

circulating primary coolant, each with:

a.

Both the steam generator economizer evaporator-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 Greater than 50?;

2 in each loop Greater than 5'4 through 1 in each loop and including 50*4 APPLICABILITY:

POWER and LOW POWER A. TION 1 a.

With only one primary coolant loop in operation, restore both loops to operating status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or b3 in at least STARTUP within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

With only one operating helium circulator in either loop, reduce reactor power to at least 50?I, RATED THERMAL POWER within 30 minutes.

j With one steam generator section not operating in either c.

prima ry coolant loop, restore all steam generator i

sections to operating status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or be in at least STARTUP within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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hoos imperation,C Q & G.e. m;

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With no primary coolant be;.n f..

least SHUTDOWN within 10 mi ntes-and ' restore horc2e circulation with at-least one:dirculater in at least oiie '

loon d.ittin 90 minutes, or-'depressurize the P"TV i ts ac'cordance withr the appligiMa @ quirement below-If.

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forced circulatf.on is restorect within 5'no:#r of initials ?.?

loss, depressurization may be discor tinuecT N-2L Y,'

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For reactor ~;TNERMAL. POWER eaual to or greater.than

, 25% priort tc SHULOOWN) ceoressurize per H%re f)"

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For 9eactor. THERh,AL POA'ER 'less than 25% pri.or.to.

SHUTOOWN,.depres:(arize per Figure r3.4.1-2.

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With 'the reactcp A ready SHUTDOWN, dipressurize per.r /*.

Figure 3.4.1-3.

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4.4.1.1 At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , he.soovextequijed primary r

coolant ecuipment shall be verified tb be in. operation and 4

circulating primary. co31 ant.

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Amendment No.

Page 3/4 4-3 h

DRAFT DEC 2 31987 f

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Tune Avaiable Prior in laitmoon of PCRV lkinwnunon when FotM Circussoon a Lost fmm a Powefod Condloon st 7 SV N gure 3.4.1-1 i

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Amindm2nt No.

Page 3/4 4-4 DRAFT DEC 2 3 937 8

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2 I-I 400 500 SOS 7'Je 800 900 100b 1100 1200 1380 1400 1500 AVERAGE CORE OUTLET TEMPERATURE 8 F

Tene Andable Price to inittation of PRCV Depressunzation as a Function of Anrage Core Outlet Tempentum at the Onwr of a LOFC Figure 3.4.1-2

Amendment No.

Page 3/4 4-5 DRAFT DEC 2 31987 e

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TEIE AVAILA8Lil PRION TO terriATION OF

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y 78 PCRV SEPRESUAIZATION WHEN FORCEO j

g CIRCULATION IS L0ff FA048 A SNUT S0WN E

CSIGITION

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0 100 200 300 400 500 000 700 000 900 1900 TIME FROM REACTOR SHUT 00WN - HOURS Tune Available Prior to initiation of PCRV Depremrharion When Forced Circulation is Lost from a Shur Down Condition Figure 3.4.1-3

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Amendment No.

Page 3/4 4-6 l

DRAFT PRIMARY COOLANT SYSTEM DEC 2 31987 3/4.4.1 PRIMARY COOLANT LOOPS AND COOLANT CIRCULATION LIMITING CONDITION FOR OPERATION 3.4.1.2 At least one primary coolant loop shall be in operation and circulating primary coolant, with at least:

a.

One helium circulator operating and b.

One steam generator section operating (either the e c o n om i z e r-e va p o ra t o r-s up e rh e a t e r (EES) or the reheater).

APPLICABILITY:

STARTUP*, SHUTDOWN

and REFUELING

ACTION:

1.

With no operating primary coolant loops, be it at least SHUTDOWN within 10 minutes and suspend all c peration s involving CORE ALTERATIONS or control rod movements resulting in positive reactivity changes, aJd 2.

Initiate PCRV depressurization in accordance witi, 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 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , 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.

Amendment No.

Page 3/4 4-7 DRAFT BASIS FOR SPECIFICATIONS LCO 3.4.1.1/SR ' 4.4.h.FC gW7-1

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LCO 3.4.1.2/SR 4.4.1.2 This Specification assures forced circulation of primary coolant.

In POWER and LOW POWER, both loops with'both steam generator sections (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 required to protect the

, steam:

generator's-internal components from overheating (FSAR Section 4.3.5.2).

Single loop operation is._ permitted only long enough to reduce power in an orderly manner as required..

for recovery of the shutdown loop or to be below5% power.

(FSAR Section 4.3.4).

Specification. 3/4.4.1.1 is applicable at power levels'above 5% power.

Below 5% power, single loop operation-is acceptable.

Also,- as long as the. CALCULATED BULK CORE-TEMPERATURE remains below-760 degrees F-(as determined per

. Specification 3.0.5),-forced circulation is not required and -

may be interrupted as required.

At least 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, power is automatically reduced to about 50%. -A single circulator trip results 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.

The equipment that is used to provide forced circulation per this Specification is also inc'uded in Specifications-3/4.5.1 and 3/4.5.3.

The distinction between these Specifications is that LCO 3.4.1 can be met 'using normal operating systems (normal feedwater to-the EES sections, cold reheat te the reheaters, and steam to the circulatcr turbinas), where LCOs 3.5.1 and 3.5.3 require SAFE SHUTDOWN COOLING capabilities (emergency condensate and emergency feedwater to the EES sections, emergency condensate to the reheaters, and booster firewater to the circulator water.

turbines).

Thirty minutes are allowed for a power reduction to.below 50.

percent if a circulator is lost, to allow the operators to I

confirm the automatic actions of the plant protective system.

See FSAR Section 7.1.2.6.

4 Amendment No.

Page 3/4 4-8 DRAFT Depressurization 3

In the unlikely event'that all forced circulation is lost for 90 minutes, the PCRV is depressurized to reduce the density of the primary coolant and thereby reduce the heat transfer to the Liner Cooling System.- This action is taken to maintain. PCRV liner integrity, as discussed in FSAR Section 0.1.1.1.

Start of depressurization is initiated as a function of prior power levels, with 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months from 100%

RATED THERMAL POWER being the most limiting case. - Operators will continue attempts to restore forced circulation 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 -i s preferrec to a

depressurized cooldown with the-PCRV liner cooling system, since forced cooling is reautred to assure prevention of fuel damage, depending on the plant power level.

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 f rom various reactor power conditions are delineated in Figures 3.4.1-1, 3.4.1-2, and 3.4.1-3 and are discussed in the FSAR Section. 9.4.3.3 and Appendix D.

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, of primary coolant helium flow.

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Amendment No.

Page-3/4 5-1 i

DRAFT SAFE SHUTOOWN COOLING SYSTEMS 3/4.5.1 HELIUM CIRCULATORS DEC 2 31987 i

l 1

LIMITING CONDITION FOR OPERATION i

3.5.1.1 At least one helium circulator in each primary coolant loop l

shall be OPERABLE including its water turbine.

APPLICABILITY:

POWER, LOW POWER, STARTUP", SHUTDOWN", and REFUELING *'

ACTION:

a.

With no OPERABLE helium circulator in one of the two primary coolant loops, restore the inoperable : equipment to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or 1.

When in POWER, LOW POWER, or STARTUP, be in at least SHUTOOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or 2.

When in. SHUTDOWN or-REFUELING, suspend. all operations involving CORE ALTERATIONS or control rod movement resulting in positive. reactivity changes.

b.

With no OPERABLE helium circulator in either primary coolant loop, restore cne helium circulator to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or 1.

When in POWER, LOW POWER, or.STARTUP, be in at least SHUTOOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or 2.

When in SHUTOOWN

.or REFUELING, suspend all operations involving CORE ALTERATIONS or control rod movement resulting in positive reactivity changes.

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

lam'endmenc. No.

[

Page 3/4.5-2 j

l PQAFT DEU 2 31987 SURVEILLANCE REQUIREMENTS _____ _

g.

4.5.1.1 The helium ci nulators shall be denonstreted OPERABLE

.a.

At least once per REFUELING CYCLE vhereby circulabr,,'B-1

= and 10 will.hD.ested during even. numbered cycles. ar d circulators 1A and ' ~1C. dur!ng odd numbered cycles, by.

demonstrating operation on waters turbine drive of each.

circulator.and, verifying equi. valent 3.8% rated helium

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flow on~ condensate at reduced pressues ito. simulate firewatar

,) ump discharge) using l each fmergency water booster punp (p-2109 and -P-2110) and. the emergency-condensate header, b.

At least once per REFUELING. CYCLE by monitoring the proper closure of the' helium shutoff valves.

c.

At least once per 10 years by verifying:

1.

A helium circulator. compressor wheel ~ rotor, turbine wheel and pelton wheel are free of both. surface and subsurface defects =

in accurdance 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 helium circulator componcnts, 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 inherent or developed defects.

3.

Reports Within 90 days of examination completion, a Special Reoort shall be submitted to the NRC in accordance with Specification 6.9.2.

This report shall include the results' of the helium' circulator examinations.

'Amendmant No.

Page;3/4 5-3' l

DRAFT SAFE SHUTDOWN COOLING SYSTEMS' DEC 2 31987 3/4.5.1 HELIUM CIRCULATORS LIMITING CONDITION FOR OPERATION 3.5.1.2 At least one helium circulator shall be OPERABLE including its water turbine.

APPLICABILITY:

STARTUP*, SHUTDOWN *, and REFUELING

ACTION: With no OPERABLE helium circulator, be in at'least SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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.

SURVEILLANCE REQUIREMENTS 4.5.1.2 The 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.

1 An endment No.

'Page 3/4 5-4

)

DRAFT DEC 2 3 W/

BASIS FOR SPECIFICATIONS LCO 3.5.1.1/SR 4.L I.1 AND-LCO'3.5.1.2/SR 4.5.1.2 The scope of this Specification includes the helium circulator machiwa, 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 %4ter drain piping is included in Specification 3/4.5.2.

One heliun, circulator-(and one steal generator EES section) ensurcs SAFE SHUT 60WN C00 LING'when the p M t is. pressurized.

d One' halfum circulator in each. primary coolant loop is

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specified during POWBR, LOW POWER,

STARTUP, SHlffDOWW, 3rd REFUELING with CALCULATED BULK CORE TEMPERATURE gre4ter than 750 degrees F to allow for a ' single failure.

One l

circulator, operating with motive power fra either (a)'

condensate or boosted firewater supplied via the ' emergency condensate header, or (b) feedwater or boosted firewater supplied via the emergency feedwater header, provides sufficient primary coolant ci'rculation'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.

The helium circulators, with feedwater supplied to their water turbines, provide sufficient cooling in the event of a PCRV depres.surization accident.

Feedwater ' supply is assured by Specification 3/4.7.1.1, as this is not SAFE SHUTDOWN COOLING-equipment.

Two circulators,-

operating with emergency water drive, supplied with feedwater

~ ia the v

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 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 (hiCA), a single helium circulator with feedwater drive crovides 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 3/4.5.5.

The helium circu'lator pelton wheels can be driven by condensate from the condensate pumps (either 60% or 12 1/2%) or by feedwater from the boiler feedwater pumps; however, these are not SAFE SHUTDOWN COOLING equipment.

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AmendmentiNt, i

Ptee 3/4 5-5.

DRAFT Redundancy Criteria DEC2 31987 The use of 760 degrees F CALCULATED BULK CORE TEMPERATURE as a division between the APPLICABILITY of Specification 3.9.1.1 verses 3.5.1.2 is explained in the Basis for Specification 3.0.5.

Specification 3.0.5 prevides the methodology and necessary data to determine the appropriate timo 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, of primary coolant helium flow.

Actions With. CALCULATED BULK CORE TEMPERATURE above 76C degress F, an inoperable helium :irculator 15-permitted for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , as this constitutes a loss of redundancy in SAFE SHUTDOWN COOLING equipment.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months are allowed to be in at least SHUTOOWN, consistent with the time allowed for an orderly shutdown i

from STARTUP. Then, as long as the inoperable equipment is restored to OPERABLE status prior to reaching 760 degrees F, i

no further Actions are required.

1 Operability Demonstration Each helium circulator is tested for its SAFE SHUTDOWN 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, j

and veri fying that primary coolant flow rate is equivalent to 3.8% at full density with cold core conditions.

Cold j

core conditions result in reduced bouyancy due to the i

" chimney effect", and thus, higher developed flow rates.

l A 10 year ISI inspection.is required to ensure helium j

circulator integrity.

1

Amendmen?. No.

Page' 3/4 5 -

DRAFT SAFE SHUTDOWN COOLING SYSTEMS DEC 2 31987 3/4.5.2 HELIUM CIRCULATOR AUXILIARIES LIMITING CONDITION FOR OPERATION 3.5.2.1 At least the following helium circulator water turbine drive capabilities and auxiliary equipment shall be 0PERABLE for the helium circulators that are required to be OPERABLE:

a.

Two SAFE SHUTDOWN COOLING (firewater)' supplies for each 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 SHUTOOWN COOLING water turbine drive supplies, turbine water removal pumps, bearing water pumps per loop, bearing water makeup pumps, or sources of bearing water makeup, J

restore the inoperable equipment to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

1 I

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

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

)

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i Amendment No.

Page 3/4 5-7 DRAFT DEC 2 31987 b.

With less than the above required OPERABLE besring water accumulators, resi. ore the ' inoperable equipment' to 3

OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or. be in at least

.j SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c.

With less than.the above required OPERABLE valve

)

interlocks, restore the inoperable equipment.to OPERABLE.

I status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or be in at least LOW POWER within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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SURVEILLANCE REQUIREMENTS 1

i

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4.5.2.1 -The helium circulator auxiliaries shall' be demonstrated OPERABLE:

a.

At least once per 92 days by:

1.

Testing the bearing water accumulators and their l

actuation valves, 2.

Performing a turbine water removal pump start test based on a simulated drain tank level to verify automatic actuation and pump start capability,-and 3.

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.

b.

At least once per REFUELING CYCLE by:

1.

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 operating loop having been tripped.

2.

Performing a functional test of each emergency water booster pump.

This is performed in' conjunction with Specification SR 4.5.1.1.a.

3.

Performing a functional test of the emergency bearing water makeup pump (P-2108).

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1 Amendment No.

Page 3/4 5-8 DRAFT I

SAFE SHUTBQWN COOLING SYLTEM; 060 2 3 1987 I

3/4 3 2 HELIUM CIRCULATOR AUXILIARIES LIMITING CONDITION FOR OPERATION.

3.5.2.E At least the following helium circulator water turbine drive capabilities and auxilicry eq?tipment shall be CPfRABLE for each helium circulator that 1: required to be OPERABLE:

C'OLING (firewater) supply for each a.

One SAFE SHUTDOWN J

water turbine drive.

This includes one emergency water booster p ut.:p (P-2109 or P-2110), and a flow path from either the emergency feedwater or the emergency condensate header to and including the helium circulator water turbine speed control valve.

b.

The turbine water removal system, including one turbine water removal pump, c.

The normal bearing water system, including two bearing water pumps, 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).

APPLICABILITY:

STARTJP*, SHUTDOWN *, and REFUELING

ACTION: With less than the above required OPERABLE equipment, be in at least SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and restore the required equipment to OPERABLE status prior to react.ing a CALCULATED BULK CORE TEMPERATURE of 760 degrees F,

or su. pend all operations involving CORE ALTERATIONS or control rod movements resulting in oositive reactivity changes.

1 SURVEILLANCE REQUIREMENTS 4.5.2.2 The helium circulator auxiliaries shall be demonstrated OPERABLE by performance of SR 4.5.2.1.

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

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Amendment'Not e

p Page.3/4-5-9

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DRAFT h

DEC 2 31987 DASI3 FOR SPECIFICATIONS LCD ~ 3.5.2.1/SR 4.5.2.1 AND-

$03_.5.2.2/SR412.2 The scope of this Specification includes the helium circulator pelton w eel supply piping from the emergency h

i.

feedwater or.

emergency condensate headers (which are specifically. included in Specification. 3/4.5.4) to and including the helium circulater water turbine speed control valves.

The helium circulator pelton wheel drives' are included in Speciffretion 3/4.5.1, Whenever the CALCULATED BULK CORE TEMPERATURE (CBCT) is greater than 760 degrees F,

two SAFE SHUTDOWN' COOLING supplies are specified to ensere forced circulation in the event of a single activs-failure in this' piping.

One turbine water removal pump has sufficient capacity to remove the water from.two circulator water turbines.

Also,.

the turbine - water removal tank overflow to the reactor building sump is available ff the normal pump flow path is lost.

Each of the two separat'e and independent recirculating' bearing water loops supplies the bearing water requirements of 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 required head rise.

Two pumps are running, the third is a standby.

Requiring two pum'ps to be OPERABLE when the CBCT is greater than 760 degrees F is acceptable because:

1) a backup supply of bearing water is ~available from the feedwater system, and 2) loss of a second bearing water pump in a loop could result in a loop shutdown but it would not affect the plant's ability to shut down on the-other loop.

Makeup bearing water requirements are normally obtained from the feedwater system. A separate bearing water makeup pump is provided as a backup to supply makeup water to the bearing water surge tank.

The bearing water makeup pump (P-2105) takes suction from either the deaerator, the condensate storage +anks (normal), or the firewater system (emergency).

If this pump is inoperative, an emergency bearing water makeup pump (P-2108) can supply water at a reduced capacity from the condensate storage tank, or the firewater system (emergency).

A 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 SHUTDOWN COOLING equipment.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is consistent with Action 6 required in Light Water Reactors for loss of redundancy in Emergency Core Cooling System equipment.

i Amendment D.

Page 3/4 5-10 DRAFT DEC 2 31987 When-the CALCULATED BULK CORE TEMPERATURE is less than 760 degrees F, the Action to be shut down within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is consistent with the time allowed for an orderly shutdown from STARTUP.

Each bearing water.lcop contains a gas pressurizer and bearing water accumulator capable of supplying bearing water for 30 seconds at. design flow rate if no other source of bearing water is available. This is adequate for snutdown of the affected circulators without damage to the bearings.

The bearing water estem, including the bearing water accumulators -and.the bearing water makeup pumps

a re functionally tested at 31 day and 92' day intervals to ensure proper operation.

There is no redundancy-in the bearing water accumulators.

and a

24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months action statement restoration ti;se is provided.

This is

-acceptable.

considering-the low itkelihood of failures ~' of these components.

Auto water turbine start is prevented if'a water turbine TRIP exists or the auto water turbine 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 feature is relied upon in the event the control' room has to be abandoned.

Since this is an unlikely event, a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 POWER mode.

Redundancy Criteria The use of 760 degrees F CALCULATED BULK CORE TEMPERATURE as a division between the APPLICABILITY of-Specification 3.5.2.1 verses 3.5.2.2 is explained in the Basis for Specification 3.0,5.

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, of primary coolant helium flow.

y Amendmsnt No.

Page 3/4'5-11 J

w gr h

SAFE SHUTDOWN COOLING SYSTEMS 2 3 $87 S/4.5.3 STEAM GF.NERATORS LIMITING CONDITION FOR OPERATION 3.5.3.1 The steam generator in each primary coolant loop with an OPERABLE helium circulator shall be OPERABLE, including both the _ economizer-ev'aporator-superhet.ter (EES) and rebeater sections.

APPLICABILITY: -POWER, LOW POWER, STARTUP*,~SHUTOOWN*, and REFUELING *'

ACTION:

a.

With one of' the required steam generetor sections inoperable, restore the inoperable' equipment to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or 1.

When in POWER, LOW POWER,'or STARTUP, be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or

~'

2.

When in SHUTDOWN or REFUELING, suspend all operations involving CORE ALTERATIONS or control rod movement resulting in positive reactivity changes.

b.

With any two of the required steam generator sections inoperable, reduce power to below 35% of RATED THERMAL POWER within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and restore. the inoperable equipment within the next 48' hours, or be in at least SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c.

With three or more of the required steam generator sections inoperable, restore at least one section to l

OPERABLE status within 1. hour, or 1.

When in POWER, LOW POWER, or STARTUP, be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or 2.

When in SHUTDOWN or REFUELING, suspend all operations involving CORE ALTERATIONS or control rod movement resulting in positive reactivity changes.

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

1 I

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' Amendment No.

Page 3/4 5-12 i

DRAFT SURVEILLANCE REQUIREMENTS EO231907 4.5.3.1 The steam generators shall be' demonstrated OPERABLE:

l a.

At least once per'18 months by:

1.

Verifying'. proper flow.

through the emergency feedwater header and emergency ccndensate header to the EES sections, and verifyirg proper flow through.

the emergency condensate' header to the reheater sections.

2.

Verifying the. outlet flow path by cycling the; valves in the six inc.h' vent lines'and' observing' that-the,

vent flowpaths are not cbstructed, b.

At.least once. per 5 years by volumetrically. examining l

the accessible portions of the foll6 wing bimetallic 1.

welds for indications of subsurface defects:

1.

The main' steam ring' header. collector to main steam piping weld for one steam generator module in each loop, and 2.

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

3.

The same two steam. generator modules shall be re-examined at each interval.

The initial examination shall -be performed during-SHUTDOWN or REFUELING prior to the beginning of fuel-cycle 5.

This initial examination shall~also include the bimetallic welds described above for-two additional steam generator medules in each loop.

c.

Tube Leak Examir.ation Each time a steam generator EES tube is plugged due to a-leak, specimens from the accessible subheader tubes I

connected to the leaking inaccessible tubes shall be l

metallographically examined.

Reheater. subheater. tube s.

l are not accessible.

l The results of this metallographic examination shall be compared.to the results from the. specimens-of all previous tube leaks.

Amendnient No.

Page 3/4.5-23 j

DRAFT l

A. study shall be performed-to evaluat'e t sz a a

elevation of the tube leaks to determine if:a 'cause of-the leak or a trend in the, degradation can be identified.

I 1.

Acceptance' Criteria j

An engineering evaluation shall be performed to determine the acceptability of.

a) Any subsurface de.fects'

' identified in.SR' 4.5.3.1.b, b) Continued operation considering the: condition of

.3 the steam generator materials, and

]

-i c) OPERABILITY of the steara generator ^. se.-ti ons consideritig the r t.,nber of piogged tubes aic).

I their ability to remove decay heat.

{

2.

Reports Within 90 d;ys of the return to operatica following-each steam generator tube leak study a Special Report shall be submitted to the Commission.in accordance with Specification 6.9.2.

This. report shall include the estimated size and e'luvatioit of

{

the leak (s), and at least the preits,inary results of j

the metallographic and engineering analyses performed, the postulated cause of the leak if identified and coirective action to be'taken.

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l Amendment No.

Page 3/4 S '

DRAFT SAFE SHUTDOWN COOLING SYSTEMS DEC 2 31987 '

3/4.5.3 STEAM GENERATORS LIMITING CONDITION FOR 0PfRAT10N 3.5.3.2 dt ieast one steam generator in one primary coolantL loop.

with aa -OPERABLE helium circulator lshall be. OPERABLE, including at least the ec o n omi ke r-e v a po ra to r-s upe rhe ate r (EES) or tne reheater section.

t APPLICABILI[Y,1 STARTUP*, SHUTDOWN *, and REFUELING

ACTION: With no OPERABLE steam generator section, be in at least SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and restore _

the inoperable equiptaent to OPERABLE status prior to reaching a CALCULATED 3ULK CORE TEMPERATURE of 760 degrees F,

or susoend all operations involving CORE ALTERATIONS or. control rod -

novements resulting in positive reactivity changes.

SURVEILLANCE REQUIREMENTS 4.S.3.2 The steam generators..shall be demonstrated OPERABLE by the performance of SR 4.5.3.1.

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

-________________d

i

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Amendment No.

Page 3/d 5-15 DRAFT l

DEC 2 31987 BASIS FOR -

SPECIFICATIONS LCO 3.5.3.1/SR 4.5.3.1 AND"'

LCO 3.5.3.2/SR 43.3.2 The requirements for OPERABLE steam generator (s) provide an adequate means for removing heat from the primary 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.

The steam generator sections are essentially passive heat exchangers.and are OPERABLE when their pressure boundaries are intact and when they are capable ~of receiving flow.from their respective emergency feedwater or condensate headers.

This is separate from their normal feedwater flow path.

Each steam generator consists of six identical individual steam generator modules operating in parallel.

Each module consists of a reheater section and an EES section. Any one EES section provides sufficient heat removal capability to ensure SAFE SHUTDOWN COOLING.

The reheater sections are also used in certain accident analyses, such as wrong loop dump with an EES leak, (FSAR Section 14.5), but they are not.

relied upon for SAFE SHUTDOWN COOLING.

During POWER.

LOW PCWER, STARTUp, SHUTDOWN, and REFUELING with CALCULATED BULK CORE TEMPERATURE greater than 760 degrees F,

both steam generator sections in both loops are required to be OPERABLE.

This allows for a single failure and ensures an OPERABLE EES section for. SAFE SHUTDOWN COOLING.

During SHUTDOWN and REFUELING with CALCULATED BULK CORE-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 in the Basis for Specification 3.0.5.

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' Amendment. No.

Page 3/4 5-16 DRAFT DEC 2 31987 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 tempe*ature-cannot. be exceeded and.there can be'no d mage to fuel or PCRV internal components regardless of the amount, including total absence, or reversal, or primary coolant helium flow.

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 hou-s' 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.

If both EES sections become inoperable, there is no SAFE SHUTDOWN COOLING capability to assure forced circulation.

Operation below 35% power is permitted for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months as the PCRV liner cooling system is capeble of preventing l

significant damage to any of the fission product barriers in the event of a LOFC from these power levels.

See F5AR Section 0.4.1.

Also, the reheaters have been calculated capable of cooldown from these power levels.

(P-86682).

With the CALCULATED BULK CORE TEMPERATURE below 750 degrees F, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months are allowed to be in at least SHUT 00WN, i

consistent with the time allowed for orderly shutdown from STARTUP. Then, as long as the inuperable eauipment 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 header. Also, the reheater sections can receive water from the emergency condensate header.

.l During shutdown conditions, the required flowpaths to all I

steam generator sections are demonstrated.

Also, the six inch vent valves are cycled and the outlets are visually examined for obstructions; actual flow is not demonstrated.

A six-inch vent line to atmosphere from each EES discharge 4

header is included in the SAFE SHUTDOWN COOLING flowpath to reduce downstream flow resistance and allow higher flowrates.

(FSAR Section 10.3.9).

Amendment No.

i

.Page 3/4 5-17.

DRAFT Bimetallic Weld Examination DEC 2 31987 The steam generator crossover tube bimetallic. welds between Incoloy 800 and 2 1/4 Cr-1 Mo materials are not.accessib'le for examination._

The' bimetallic welds between steam generator ring header collector, the main steare piping, and the collector drain piping are accessible, involvs the same materials, and operate at conditions not significantly

)

~

different from the crossover tube bimetallic welds.

The collector drain piping weld is also geometrically similar to i

i the crossover tube' weld. Although minimal degradation is expected to occur, this specification allnws for detection i

of defects which might: result from conditions that can uniquely affect bimetallic welds made between these materials.

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

?dditional-examinations subsequently be required.

, Tube Leak Examination l

During the lifetime of the plant, a certain number of steam generator tube leaks are expected to occur, and the steam 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.

It is important to identify the approximate size and elevation of steam generator tube leaks and to metallographically examine the subheader tube material because this information can be used to analyze any trend or generic cause of tube leaks.

Conclusive identificatiori 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 a quantity of tube failures in excess of those analyzed in the FSAR, Because of the subheader designs leading to the. steam generator tube bundles, internal or external inspection and evaluation of a tube. leak to establish a conclu;ive cause is not practical. Meta 11ographic examination of the accessible connecting subheader tube will show the condition of the internal subheader wall, giving an indication of the conditions of the leaking tube internal wall, thereby demonstrating the effectiveness of water chemistry controls.

Determining the approximate size and elevation of the tube leak may enable evaluation of other possible leak causes such as tube / tube support plate interface effects.

____-___________a

)o4 Amendment No.

Page'3/4 5-18 DRAFTL DEC 2 31987 The _ surveillance 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.

-l 1

l

Amendment No.

Page 3/4 5-19 DRAFT SAFE SHUTDOWN COOLING SYSTEMS DEC 2 31987 3/4.5.4 EMERGENCY CONDENSATE AND EMERGENCY FEEDWATER HEADERS EMERGENCY CONDENSATE AND EMERGENCY FEEDWATER HEADERS - OPERATION LIMITING CONDITION FOR OPERATION 3.5.4.1 The-emergency condensate header and the emergency feedwater header shall be OPERABLE.

APPLICABILITY: POWER, LOW POWER, STARTUP*, SHUTDOWN *, and REFUELING

ACTION:

a.

With either the emergency condensate header or the amergency feedwater header inoperable, restore the inoperable header to OPERABLE. status within.72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or:

1.

When in POWER, LOW POWER, or STARTUP, be in'at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or 2.

When in SHUTDOWN or REFUELING, suspend all operations involving CORE ALTERATIONS or control rod-movement resulting in positive reactivit,y changes, b.

With both the emergency condensate header and the emergency feedwater header. inoperable, restore one header to OPERABLE status within I hour, or 1.

When in POWER, LOW POWER, or' STARTUP, be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or 2.

When in SHUTDOWN or REFUELING, suspend all operations involving CORE ALTERATIONS or control rod movement resulting in positive reactivity changes.

SURVEILLANCE REQUIREMENTS 4.5.4.1 No additional Surveillance Requirements are required other than those surveillance identified in Specifications SR 4.5.1.1.a SR 4 7,1.1, and SR 4.5.3,1.a.1.

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

Amendment No.

=:

'Page 3/4 5-20 DRAFT SAFE SHUTDOWN COOLING SYSTEMS DEC 2 31987

'3/4.5.4 EMERGENCY CONDENSATE AND EMERGENCY FEEDWATER HEADERS EMERGENCY CONDENSATE AND EMERGENCY FEEDWATER HEADERS - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.5.4.2 -Either the emergency condensate header or the emergency feedwater header shall be OPERABLE.

' APPLICABILITY:

STARTUP*, SHUTOOWN*~ and REFUELING

ACTION: With both the emergency' feedwater and errergency condensate header inoperable,-be in at least SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and restore at least one header to OPERABLE status prior to-reaching a CALCULATED BULR 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.

l'

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

! o Amendment No.

Page 3/4 5-21 DRAFT BASIS FOR SPECIFICATION LCO 3.5.4 / SR 4.5.4-

' 0E0 2 31987 The OPERABILITY of the emergency condensate header and the emergency feedwater header ensures redundant. water supply-paths: to the. helium circulators and steam gene.'ators for SAFE SHUTOOWN COOLING of the plant.

In the event' of-a failure of the normal feedwater line, the' availability-of either.the emergency.feedwater or emergency condensate itnes provides adequate cooling capability. OPERABILITY of the aforementioned headers is accomplished during SHUTDOWN by verifying. flow through'each header to the' steam generators.

and helium circulators.

Both the emergency.' condensate header and the' emergency feedwater header are considered SAFE SHUTDOWN-COOLING -

equipment.

Redundancy Criteria The use of 760 degrees F CALCULATED BULK CORE TEMPERATURE as a division between the APPLICABILITY 'of.-

Specification 3.5.4.1 verses 3.5.4.2 is explained in the Basis for Specification 3.0.5.

Specification 3.0.5 provides the methodology and necessary data to determine the appropriate. time-interval:to reach. a' CALCUALTED BULK CORE TEMPERATURE of 760 degrees F.

If the active core remains below this tempe ra ture',

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, of primary coolant helium flow.

The emergency feedwater-header is not normally plac~ed in :

1 service until approximately 30% reactor power, to prevent unnecessary long-term wear of components associated with the:

emergency feedwa ter header.

Nevertheless 'it: is

.still required to be OPERABLE during the aforementioned MODES.

(

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'AmerdmentM f!

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Page 3/4 N22

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Actions'-

DEC 2 31987:

With CALCULATED BULK CORE. TEMPERATURE above 760 dz[ pes F, y

an inoperable header is permitted for 72 houb,tas tni s :

1 constitutes. a ' loss' of redundancy in SAFE SHUTDGWN COOLING -

equipment. 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s-is cons 1 stent with Actiops Fesidred in Light Water Reactors for loss of redundanLT in Emsegency' Core Cooling System equipment.

If the inopb6ble header cannot : be:> repaired withhj this' time, an orderly shutdown is ):

require:L 7[

J 7

y.'

With the CAL;ULATED BULK CORE TEMPERATURE below 760 degrees i.p/A,,

F, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months '; ire allowed to.be ir# at. least. SHUTDOWN,.

^

consistent.-'wi;h.the Then,<as lod. allowed M r an orderly shutdown.

time g as eb/pperable equipment ~ '1 s1 from S*ARTUP.

f

.restoredtoOPERABLEstatuspriorto' esc {ching760 degrees.F, no further Actions are required /

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AmendmenUNb.

kf Page 3/4 5-23; Af 1

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DRAE W C'

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T DEC2 3DN SAFE SHUTDOWN COOLING SYSTEMS e

,p 3/4.5.5 SAFE SHUT 00WN COOLING WATER SUPPLY SYSTEM

+

9-p LIMITING CONDITION FOR OPERATION.

pf 3.5.5-The SAFE SHUTDOWN COOLIN'G water supply, system shall. be 3

OPERA 9LE with:

~

o a.

Two circulating water skeap storage ponds OPERABLE with a minimum combined inventory. of. 20 milljen gallons, b.

At least two OPERABLE 7. circulating water makeup pumps (P-4118-P, P-41185-P,.c A P-4118SX-P) connectible to',an essential bus, A.

5 1

c.

Two OPERABLE _ firewate, pumps, both the motor drid?n (P-4501) ano"the engine driven (P-45015), including, the associated pukp pits and at least 370 gallenstof.fgvl in the day tank, fortthe engine driven pump.1and sif c=

s d.

Two OPERABLE flow, paths ' capable of taking suction from the circulating water makeup storage (

ponds-and transferring the w'ater via the circulating water makeup pumps'and the firewater pumps to the firewater header..

that supplies SAFE $HUTDOWN COOLING equipment.

1 APPLICABILITY:

At all times ACTION:

a.

With CALCULATED BULK CORE TEMPERATURE greater than 760 degrees F:

1.

With any single component requireit by LCO 3.5.5.a, b, or c above inoperable,. restore the inoperable equipment to OPERABLE status within 72 hourt or'ce in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2.

With more than one component, eoutred by LCO' 3.5.5.a, b, or c above inoperable, fo'ut 'with' cne OPERABLE flowpath through. an:/ combinat)onofthe above required components, restore the inoperable equipment to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months >or be in at least SHUTDOWN within the next 24 todrs.

1 ii l

1 l

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Amendment No..

~

Page 3/4 5-24

4..

DRAFT

+

S

?

0E0 2 31987 -

v 3.

With no ASERABLE flowpath through the above required components, restore at. least one flowpath. 'to OPERABLE status within I hour, or a) When in POWER, LOW POWER, or.-StARTUP, be..in at least SHUTOOWN within the next 24' hours, or b) When min SHUTOOWN or. REFUELING, suspend all operations involving CORE ALTERATIONS or control-rod movement resulting in positive reactivity

's changes.

b.

With CALCULATED BULK CORE TEMPERATURE less than'or equal t'o 760 degrees F:

1.

With only one OPERABLE.flowpath through any combination of the above required components, restore the inoperable equipment to OPERABLE status within 14 days or provide alternate backup equipment or water supply.

The provisions of Specification 3.0.4 are not applicable.

2.

With no OPERABLE flowpath through the above required components, be in at least SHUTOOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and restore at least one flowpath 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.

I

$U M IL yJCs_ REQUIREMENTS 4.5.5.1 The SAFE SHUTOOWN 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 i

wakeup ponds.

I

'b.

At least once per 31 days by:

1.

Starting the electric motor-driven fire pump and

.operatinr it,for at 'ieast 15 minutes, 2.

Starting' each circulating water makeup pump that is not already running, and

-)

3.

Verifying that each valve 1n the flow path, that is h

not incked, sealed, or otherwise secu ed in place is in its correct position.

j i

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8 b'

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y Amendment No.

Page 3/4 5-25 DRAFT.

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c.

At least once per 12 months by:

DEC 2 31987 1.

Performing a system flush, and 1

2.. Cycling each valve in the flow path that is testable during. plant' operation, through at least one

complete cycle of full travel.

I d.

At least once per' 18 months by performing a system-functional test which includes simulated automatic actuation of the system throughout its operating sequence, and:

1.

Verifying that the automatic valve in the flow path actuates to its correct position, 2.

Verifying that each pump (motor-driven and engine-driven) develops at least 1425 gpm at 119 psig, 3.

Cycling each valve in the. flow path that is not testable during plant operation through at least one complete cycle of full travel, and i

4.

Verifying that each fire water pump starts (sequentially) to maintain system pressure greater than or equal to 119 psig.

At least once per 5 years by verifying the alignment and e.

settlement of the. circulating. water cakeup pond embankments, and by examining the emba.1kments and water structures for abnormal erosion,.

cracks, seepage, leakage, and accumulation 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:

1.

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 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-D975-1977 when checked for viscosity, water and sediment.

Amandment'No.

Page 3/4 5-26 DRAFT DEC 2 3 t987 c.

At least'once per 18 months, by subjecting the diesel to an inspection in.accordance with precedures prepared in conjunction its manufacturer's recommendations for the class of service.

4.5.5.3 The fire pump ~ diesel starting 24-volt battery bank and-charger shall be demonstrated OPERABLE:

a.

At least once per 7 days by. verifying that:

1.

The electrolyte level of each battery is above the

' plates, and 2.

The overall battery voltage is greater than or equal to 24 volts.

b.

At least once per 92 days by verifying that the specific gravity is appropriate for continued.-service of.the

battery, c.

At least once per 18 months by. verifying that:

1.

The batteries and battery racks show no visual indication of physical damage er abnormal deterioration, and 2.

The battery-to-battery and terminal connections are clean, tight, free of corrosion, and coated with anticorrosion material, i

l 1

l l

1

Amendment No.

Page 3/4.5-27 DRAFT BASIS FOR SPECIFICATION LCO 3.5.5 / SR 4.5.5 DEC 2 31987-l

'The SAFE SHUTDOWN COOLING water supply. system.provides an.

adequate water supply for helium circulator water turbine operation and emergency cooling water to the steam generators for SAFE SHUTDOWN COOLING. The SAFE SHUTDOWN COOLING water supply system also supplies cooling water to other SAFE SHUTDOWN COOLING equipment via the firewater header.

SAFE SHUTDOWN-COOLING requirements are discussed in'Section 1.4, 10.3, and 14.4 of the FSAR.

For protection against a single failure, there are two independent-SAFE SHUTDOWN COOLING water. flowpaths from the circulating water makeup storage ponds 'to the-firewater header. There is a single pump pit for the three circulating water makeup pumps, and a separate pump pit for the two firewater pumps.

The piping between the storage ponds and the pumps and the firewater header is redundant.

The firewater-header (10"L4502-D25 on PI 45) can be supplied from' the-firewater pumps via several different connections to ensure a reliable supply to SAFE SHUTDOWN COOLING equipment.

The SAFE SHUTDOWN COOLING equipment ~ supplied from the.

firewater header includes the emergency -condensate header (continued in Specification'3/4.5.4), the emergency feedwater.

header (continued in Specification 3/4.5.4),. the instrument air compressors and after coolers (continued in Specification 3/4.7.3), the standby diesel generator coolers (continued in Specification 3/4.8.1), and the PCRV liner cooling-system (continued in Specification 3/4.6.2).

The circulating water makeup system provides.at least 20 million gallons of water to the service water and firewater systems.

During extremely cold weather, formation of ice on-the surface of the ci_rculating 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 gpm at 125 psig TDH. The main pump is electric-motor driven, and the standby pump is diesel-engine driven.

With 370. gallons of fuel in storage, the diesel-engine driven fire pump can operate at rated conditions for 24 hoors which is adequate time to have 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 are supplied from two storage ponds via circulating water makeup pumps.

I

Amendment No.

Page 3/4_5-28~

DRAFT Actions DEC 2 31987 With the CALCULATED BULK CORE TEMPERATURE greater than 760 degrees F, and with two out of three circulating water makeup storage pumps incperable or with any one circulating water makeup pond inoperable or a firewater pump inoperable, a restoration time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is considered sufficient,'as this constitutes a loss of redundancy in SAFE SHUTDOWN COOLING equipment.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is consistent with Actions required in Light Water Reactors for loss of redundancy in Emergency Core Cooling System equipment. Any combination of components may; be inoperable for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , provided a flow path is still available.

However, with all circulating water mkeup pumps, l

headers, or firewater pumps inoperable, a restoration time of I hour is specified, as all means of SAFE SHUTDOWN COOLING water supply are lost.

Also, with the CALCULATED BULK CORE TEMPERATURE below 760 degrees F, a single flowpath may be inoperable for 14 days or backup equipment may be placed in service.

This allows periodic maintenance of components such as the storage ponds, when the decay heat removal requirements are reduced. With no 1

flow paths, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months are allowed to be in at least SHUTDOWN, consistent with the time allowed for an 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.

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.

The use of 760 degrees F CALCULATED BULK CORE TEMPERATURE as a i

division between the ACTIONS is explained in the Basis for Specification 3.0.5.

Specification 3.0.5 provides the methodology ant 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 cannet be l

exceeded and there can be no damage to fuel or PCRV internal components regardless of the amount, including total

absence, or reversal, of primary coolant helium flow.

Amendment No.

Page'3/4 6-18 DRAFT PCRV AND CONFINEMENT SYSTEMS DEC 2 31987 3/4.6.2 REACTOR PLANT COOLING WATER /PCRV LINER COOLING SYSTEM -

OPERATING.

LIMITING CONDITION FOR OPERATION 3.6.2.1 The Reactor. Plant Cooling Water (RPCW)/PCRV Liner' 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 d.

Tubes adjacent to a non-operating tube shall be operating APPLICABILITY:

POWER, LOW POWER, STARTUP*, SHUT 00WN*, and ~ REFUELING

ACTION a.

With only one (1) RPCW/PCRV LCS loop operating, ensure both heat exchanaers are operating in the operating

loop, restore the second loop to operating within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and suspend all operations involving positive reactivity

changes, b.

With no heat exchangers in the operating loop operating or with no liner cooling system loop flow be in SHUTDOWN within 15 minutes and suspend all operations involving control rod movements resulting in positive reactivity changes.

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

._______-_ _ _ __2_ -

Amendment No.

Page 3/4 6-19 DRAFT i

OEC 2 31987 c.

With less than the above required number of PCRV Liner Cooling System tubes operating, other than as in ACTION I

a. above, restore the required tubes to operating status I

within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and suspend all operations involving positive reactivity changes.

I SURVEILLANCE REQUIREMENTS 4.6.2.1 The RPCW/PCRV Liner Cooling System shall be demonstrated OPERABLE:

a.

At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , 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:

1.

30 degrees 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 7S93 23 degrees F b) Core Barrel Seal / Core Support Floor Area Tube Delta T F12T46 47 degrees F F7T43 39 degrees F F6T44 43 degrees F F11T45 38 degrees F F5T47 46 degrees F

i Amondmont No, Page 3/4 6-20 DRAFT c) Peripheral Seal DEC 2 31987 Tube Delta T 359 23 degrees.F 45188 23' degrees F i

4S10 23 degrees F 3S187

23. degrees F If the tube temperature' rise for.any liner cooling tube is not available due:to an instrument failure, the tube may be considered OPERABLE.if two tubes on both sides of the tube with an instrument failure (4 tubes total) are within their respective temperature limits as specified-above.

c.

At least once per REFUELING CYCLE by:

1.

Performing a LCS redistribute mode functional test to verify the capability of rerouting most of the-cooling water to the upper side. walls and the top head.

2.

Performing a

functional test to veri fy the capability'to increase the~PCRV surge tank'. pressure to 30 psig by adding helium-to the tank.

-Amendment No.

Page 3/4 6-21' DRAFT

'PCRV AND CONFINEMENT SYSTEMS 3/4.6.2 REACTOR PLANT COOLING WATER /PCRV LINER COOLING SYSTEM -

SHUTDOWN LIMITING CONDITIONS FOR OPERATIONS 3.6.2.2 The Reactor Plant Cooling Water (RPCW)/PCRV Liner Cooling System (LCS) shall be OPERABLE with one RPCW/PCRV LCS loop operating with at least one heat exchanger and one pump in each. loop operating.

APPLICABILITY: STARTUP*#,-SHUT 00WN*#, and REFUELING *#

i ACTION: With no RPCW/PCRV LCS loop operating,

-l a.

And' with forced circulation maintained, be in at least SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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.

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.

l 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 200 degrees F,

-l l

Amendment No.

~

Page 3/4 6-22 DRAFT BASIS FOR SPECIFICATION LCO 3.6.2 / SR 4.6.2 DEC 2 31987 -

During operation at POWER, two PCRV liner cooling system loops are required to maintain PCRV lin_er cooling system temperatures and stresses within the FSAR design li,mits (FSAR Section 5.9.2.,

Thermal Barrier and Liner Cooling System Design and Design.

Evaluation).

Analytical calculation 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 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months s-satisfies 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 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 or 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 single tube in any set of six adjacent tubes on the PCRV cavity liner top head and core support floor 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 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.

Amendment No.

Page 3/4 6-23 DRAFT DEC 2 31987 The ACTION times specified.for recovery of two operatingL loops comes from analyses described in FSAR Section 5.9.2.4, i.e.,

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 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 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months action time is sufficient to identify and restore the tube to operating status (if possible) or SHUTDOWN to make permanent repairs.

The surveillance (s) and their respective intervals are specified to verify operability of +.he 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 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months surveillance on system flow rates provides additional' verification of flow as process alarms monitor flow continuously in each liner cooling 1o00.

Individual tube 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 CORE 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 vill be less than: the 250 degree FSAR limitation.

Thus, leak lng 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.,

a thermocouple is thought to be 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 be repaired or replaced as long as the total of four adjacent tubes (two on either side of the tube with the failed ins;.rument) are within their respective temperature 4

limits.

l

_ _ - _ - _ - _ _ _ _ - - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ = _ = -

c_-_

Amendment No.

Page 3/4 6-24 DRAFT I

The. use - of 760 degrees F-CALCULATED BULK CORE TEMPERATURE as h0 2 3.1987-division between the APPLICABILITY-of Specification. 3.6.2.1 'and 3.6.2.2 is explained in the Basis for Specification 3.0.5.

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.

r Amendment No.

Page 3/4 6-25 j

l' DRAFT PCRV AND CONFINEMENT SYSTEMS DEC 2 31987 3/4.6.3

-REACTOR PLANT COOLING WATER /PCRV LINER COOLING SYSTEM.

TEMPERATURES LIMITING CONDITIONS FOR OPERATION 3.6.3 The RPCW/PCRV Liner Cooling System (LCS) temperatures shall be maintained within the following limits:

a.

The maximum average temperature difference between the common PCRV cooling water discharge tempera ture and the PCRV -external concrete surface temperature shall not exceed 50 degrees F.

'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.

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

than or equal to 100 degrees F.

APPLICABILITY: At all times ACTION:

With any of the above limits not satisfied, restore the.

limit (s) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or be in SHUTDOWN or REFUELING within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and suspend all operations involving CORE ALTERATIONS or control rod movements resulting.

in positive reactivity changes.

Amondment No, 1

o

.Page 3/4 6 -

. DRAFT J

SURVEILLANCE REQUIREMENTS DEC 2 31987:

1 4.6.3 The' RPCW/PCRV Liner Cooling System temperatures shall be

' demonstrated to be within their respective _ limits at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by:

a.

Verifying that the maximum temperature di'ference averaged over a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period between the PCRV external concrete.

surface ' temperature and' the common P' RV cooling water.

discharge temp'erature in each loop. does 'not ' exceed _ 50 degrees F.

b.

Verifying that the' maximum PCRV liner cooling water outlet temperature does not exceed 120 degrees F as measured by PCRV liner cooling water outlet: temperature in each loop.

c.

Verifying that the change in PCRV concrete temperature does not exceed 14 degrees F per week as indicated by the" weekly average water temperature measured'at the common PCRV cocling water outlet temperature in each loop..The weekly average water _

temperature _ is determined by computing 'the a arithmetical mean 'of _ 7

.tempe ra ture s,

representing each of 'the last 7 days of' common PCRV cooling water octlet temperatures in each loop.

Each day-results in.a new computation of a weekly' average water temperature.

The new weekly average is' then : compared to the weekly average water temperature computed 7 days

- earlier to verify the limit of' Specification 3.6.3.c..

d.

Verifying that the maximum delta T:across the RPCW/PCRV Liner Cooling System 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' temperature in.each loop.

e.

Verifying that the minimum average water temperature of 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.

1

Amendment No.

Page 3/4'6-27 DRAFT BASIS FOR SPECIFICATION LCO 3.6.3/ SR 4.6.3 DEC 2 31987 The temperature limits associated' with the Liner Cooling System are not specifically discussed in the FSAR.

Various FSAR_ 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 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 PCRV concrete and liner are within FSAR analyses described above and that PCRV integr.ity is maintained.

Since the PCRV concrete has a large thermal mass and inertia, temperatures would be expected to respond very slowly to any changes in the specified parameters. A 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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.

to P-87441

.+

b RE-ORAFTED TECHNICAL SP_ECIFICATIONS FOR SUPPORT FUNCTIONS i

i i

i I

i 6

Amendment No.

.Page 1-1 DRAFT l

DEFINITIONS g

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications.

ACTION

)

1.1 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 simulated input combinations, considering system design, in 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 acceptable "as found" value for a TRIP SETPOINT.

BASES (BASIS) 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.

CALCULATED BULK CLRE TEMPERATURE 1.5 The CALCULATED 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 CHANNEL CALIBRATION shall encompass the entire

channel, i

considering system design, including tne sensors and alarm, j

interlock and/or trip functions and may be performed by any I

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

1 I

Amendment No.

Page 1 DRAFT DEFINITIONS DEC 2 31987 1

-j OPERABLE OPERABILITY 1.22 A system, subsystem, train, component' or device shall be

~

OPERABLE or have OPERABILITY _when it is capable of performing its specified safety function (s), and when all -necessary attendant instrumentation, controls, electrical power, ~ cooling j

or seal. water, lubrication or other auxiliary equipment that l

are required for the system, subsystem,

train, component, or device to perform its safety function (s) are also capable of performing their related support function (s).

- Nonessential portions _ of a system, subsystem', train, component or device need not be operational provided that.the specified safety function is maintained.

OPERATIONAL MODE - MODE-1.23 An OPERATIONAL MODE (i.e.

MODE) shall. correspond to any one inclusive combination of Reactor Mode Switch Setting, Interlock-Sequence Switch Setting, and % RATED THERMAL POWER, specified in Table 1.1.

PHYSICS TESTS 1.24 PHYSICS TESTS shall be those tests performed to measure the 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 Commission.

PLANTPROTECTIVESYSTEM(PPSJ 1.25 The PLANT PROTECTIVE SYSTEM (PPS) shall be the reactor protective circuitry and the circuitry that protects various plant components from major damage. This system initiates: (1) scram, (2) loop shutdown, (3) circulator trip, and (4) rod withdrawal prohibit functions, as addressed in Specification 3/4.3.1.

POWER-TO-FLOW RATIO (P/F) 1.26 POWER-TO-FLOW RATIO (P/F) for any power and flow conditions shall be the percentage of RATED THERMAL POWER divided by the percentage of design PRIMARY-COOLANT FLOW at RATED THERMAL POWER.

Amendment No.

Page 1-7' DRAFT DEFINITIONS

[ hen 2 31987 REPORTABLE EVENT.

1.32 A REPORTABLE EVENT shall be any of those conditions.soecified in Sections 50.72 and 50.73 of 10 CFR Part 50.

SAFE SHUTDOWN COOLING 1.33 SAFE SHUTDOWN COOLING shall be the removal-of core stored energy and decay heat by forced circulation, using. SAFE SHUTDOWN COOLING equipment.

This equipment. includes-those systems and. components involved in supplying Firewater to the' steam generators and helium circulator water turbine drives, as described in Specification 3/4.5. The reactivity condition.in the core during SAFE SHUTDOWN COOLING shall be subcritical.

SAFETY LIMIT 1.34 SAFETY LIMIT (S)- shall be limitations on process vari 8bles as identified in Specification 2.1.

These limitations are defined to protect the fuel particle integrity and the integrity of the primary coolant system boundaries.

SHUTDOWN MARGIN 1.35 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor. is suberitical, or would be~ subcritical l

from its present condition assuming that all OPERABLE control rod pairs are fully inserted, except for the single control rod t

pair of highest reactivity worth capable of being withdrawn, I

which is assumed to be fully withdrawn.

SITE BOUNDARY 1.36 The SITE BOUNDARY shall be that line beyond which the land is neither owned, nor leased, nor otherwise controlled by the 1

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 i

specified test interval into "n" equal sub-intervals, and b.

The testing of one system, subsystem, train, or other designated component at the beginning of each sub-interval.

i

f

=

Amendment No.

Page 3/4 7 - l' DRAFT PLANT'AND SAFE SHUTDOWN COOLING SUPp0RT SYSTEMS 7-

- 3/4.7.1 TURBINE CYCLE I

BOILER FEED PUMPS LIMITING CONDITION FOR OPERATION 3.7.1.1 Two of the three boiler feed' pumps shall be OPERABLE in any of the following combinations:

a.

The motor driven boiler feed pump (P-3102) OPERABLE and-one of the turbine driven boiler feed pumps (P-3101 or P-3103) OPERABLE, or b.

Two turbine driven boiler feed pumps (P-3101'and P-3103)

OPERABLE and either auxiliary boiler operating.

APPLICABILITY:

POWER, LOW POWER, STARTUP*, SHUT 00WNa, and REFUELING

ACTION: With none of the above combinations OPERABLE, restore either of the above combinations to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months o r.:

a.

When in POWER, LOW POWER or STARTUP, be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or

~

b.

When in SHUTDOWN, or REFUELING, suspend all operations involving CORE ALTERATIONS or control rod movements resulting in positive reactivity changes.

1 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 simultaneously, at an equivalent 8000 rpm (at atmospheric pressure),

on the water turbines 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 groater than 760 degrees F.

3

Amendmen?. No.

Page 3/4 7 - 2 DRAFT BASIS FOR SPECIFICATION LCO 3.7.1.1 / SR 4.7.1.1 DEC 2 31987 Any one of the ooiler feed pumps can supply feedwater for helium circulator motive power and steam generator heat removal.

The boiler feed pumps are not SAFE SHUTDOWN COOLING equipment.

Emergency feedwater is required only in the depressurization accident (DBA-2) as discussed in FSAR Section 14.11, and in the maximum credible depressurization accident (MCA) as discussed in FSAR Section 14.4.3.2.

The requirement for both a motor driven and a turbf ne driven boilet feed pump provides redundancy in equipment and diversity in drive power source.

Requiring a combination of two boiler feed pumps with a backup steam supply if the two steam driven pumps are used provides additional redundant capability for 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 supply for the turbine-driven boiler feed pumps is provided via the cold reheat piping.

The auxiliary boilers provide additional motive capability for these pumps in the event normal steam sources are unavailable. When the motor driven boiler feed pump is OPERABLE, sufficient diversity in drive power sources is ensured and the auxiliary boiler is not required. Analyses performed for High Energy Line Breaks demonstrate that the most limiting time for restart of forced circulation following DBA-2 is 60 minutes (FSAR section 14.11.2.2).

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, of primary coolant helium flow.

The requirement for the boiler feed pumps to provide sufficient cooling after DBA-2 addresses a highly incredible event (FSAR Section 14.11.1) and a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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.

This is the circulator flow assumed in FSAR Section 14.11.2 to assure fuel integrity in the highly unlikely event of DBA-2.

The helium circulator flow requirements are discussed in the BASIS for Specification 3/4.5.1.

1

' l Amendment No, Page 3/4 7 - 3

'. i DRAFT DEC 2 31987 Curing plant operation, whenever the boiler feed pumps are operating, various support equipment, such as.the condensate system will'also.be operating as required.

-' - - - - - - - - - - -. - ~ _ - _ - _ _ _ _ _ _ _ _ _ _

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Amendment No.

Page'3/4.7-12

-DRAFT i

PLANT AND SAFE SHUTDOWN COOLING SUPPORT SYSTEMS 0E0 2 31987-3/4.7.1 TURBINE CYCLE SAFETY VALVES - OPERATING i

LIMITING CONDITION FOR OPERATION _

3.7.1.5 The steam generator superheater (EES) and reheater safety valves (V-2214, V '2215, V-2216, V-2245, V-2246, V-2247,. V-2225 and V-2262) shall be OPERABLE with set points in accordance with Table 4.7.1-1.

APPLICABILITY:

POWER ACTION: With one of the required EES safety valves inoperable in either or both loops or with one reheater safety valve inoperable, restore the.-required valve to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or restrict plant operation as follows:

a.

With an EES safety valve inoperable, reduce THERMAL POWER to less than 50% of RATED THERMAL POWER.

b.

With a reheater safety valve inoperable, be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SURVEILLANCE REQUIREMENTS 4.7.1.5 The superheater and reheater safety valves shall be demonstrated OPERABLE by testing in accordance with the applicable ASME Code requirements. The test frequency is specified in the ASME Code, and the lift settings are specified in Table 4.7.1-1.

Applicable testing shall be performed prior to exceeding 30% RATED THERMAL POWER.

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o Amendment No..

Page'3/4 7-23 DRAFT i

OEC 2 31987 l

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-TABLE 4'.7 1-l' l

STEAM GENERATOR SAFETY VALVES VALVE NUMBER LIFT SETTINGS LOOP I V-2214 Less than'or equal to 2917 psig :

V-2215-Less than or equal.to 2846.psig V-2216 Less' than or equal. to 2774 psig V-2225 Less than. cr equal to 1133~ psig '

LOOP II V-2245 Less than or equal to 2917 psig-V-2246 Less than or equal to 2846 psig V-2247 Less than or equal to 2774 psig V-2262 Less than or equal to 1133 psig l

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I Amendment No' 1

Page 3/4 7 i DRAFT I

1 PLANT AND SAFE SHUTDOWN COOLING SUPPORT SYSTEMS EC 2 31987

.3/4.7.1 TURBINE CYCLE' l

SAFETY VALVES - SHUTDOWN-LIMITING CONDITION FOR OPERATION i

3.7.1.6 a.

At least one safety valve for each operating section of j

the steam generator shall.be OPERABLE with.its setpoint in accordance with Table 4.7.1-1.

b.

The provisions of Specification 3.0.4 are not applicable.

APPLICABILITY:

LOW POWER, STARTUP, SHUTDOWN and REFUELING ACTION: With less than the above required safety valves OPERABLE, a.

When in LOW POWER. or STARTUP, restore the inoperable valve to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,.or b.

When in' SHUTDOWN or REFUELING, restore the inoperable valve 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.

SURVEILLANCE REQUIREMENTS 4.7.1.6 No additional surveillance required beyond those identified per Specification 4.7.1.5.

1

o Amendment No.

Page 3/4 7-15 DRAFT OE0 2 31987 BASIS FOR SPECIFICATIONS LCO 3.7.1.5/SR 4.7.1.5 AND LCO 3.7.1.6/SR 4.7.1.6

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i The e c o n omi z e r-e v a p o ra t o r-s u p e rh e a te r (EES) section of each steam j

generator loop is protected by three spring-loaded safety valves, 1

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 safety valve.

These steam j

generator safety valves are described in the FSAR, Section 10.2.5.3.

i i

These steam generator safety valves are designed to relieve steam and l

can be damaged by rapid cyclic actuations that occur when they j

relieve water.

To protect these valves, only one EES safety valve and the reheater safety valve are maintained in service in each loop, through startup evolutions until about 30% power. When the steam conditions support their use, all the steam safety valves are placed in service.

The use of one safety valve per steam generator section at low power levels is in accordance with the requirements of the applicable piping code, as it is capable of relieving the available flow. Also, there are other power actuated valves that are capable of relieving pressure from the main steam and reheat piping.

The above valves are required to be tested in accordance with ASME Section XI, IGV requirements every 5 years (or less, depending on, failures) or after maintenance.

To satisfy the testing criteria, the valves must be tested with steam.

Since these valves are permanently installed in steam piping, the appropriate means for testing requires plant power to be in excess of 22% RATED THERMAL POWER.

Thus, the test must be conducted during LOW POWER, and OPERABILITY cannot be demonstrated at lower power levels.

During all MODES, with one EES safety valve inoperable, plant operation is restricted to a condition for which the remaining safety valves have sufficient relieving capability to prevent overpressurization of any steam generator section.

Conversely, with any reheater safety valve inoperable, plant operation is restricted to a more restrictive Mode.

A 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months does not i

result in a significant loss of safety function for any extended period.

The setpoints for the safety valves identified in Table 4.7.1-1 are those values identified in the FSAR with tolerances applied such that l

the Technical Specifications incorporate an upper bound setpoint.

This is consistent with not incorporating normal operating limits in j

these Specifications.

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' Amendment No.(7,q,,,- - g - ([1( '

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'Page 3/4 7-17.?? -

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't DRAFT L

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.o !v 3 PLANT SYSTEMS DEC 2 3 $81 T-a]

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'3/4.7.1. TURBINE CYCLE

V CONDENSATE PUMPS l

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s LIMITING CONDITION FOR OPERATION" if o

3.7.1.7 At least one of the two 12 1/2% condensate-pumps (P-3106 ori P-31065) shall be OPERABLE.

APPLICABILITY:

POWER and LOW POWER ACTION: With no OPERABLE 12 1/2% condansate pump, restore'at least

. ;g one pump.to OPERABLE-status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at

i' p y>-

least STARTUP within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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'2 SURVEILLANCE REQUIREMENTS

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[" M 4.7.1.7 There are no additional requirements other than those required by Specification 4.0.5.

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Amendment No_

i Page 3/4 7-10 DRAFT BASIS FOR SPEC 7FICATION LCO 3.7.1.7/SR 4.7.1.7 DEC 2 31987 The condensate pumps are used to assure forced circulation cooling under certain normal and emergency cotidi ti on s.

Condensate i s supplied via the emergency condensate header to'ene helium circulator water turbines and to the steam generator EES or reheater sections.

The condensate pumps are not SAFE SHUTDOWN COOLING equipment.

There are two 60% condensate pumps and two 12 1/2% condensate pumps.

The 12 1/2% condensate pumps are addressed in this specification Secause they are capable of being powered from an essential pows bus ar.d would be capable of supplying emergency condensate requireme, clin the event of' a less of offsite power.

(FSAR Section 10.3.2) A single pump is specified because the cordensate pumps are a part of l

the design of FSV, but they are not ultimately relied upon for forced I 4

cooling, per the FSAR. The SAFE SHUTD'JWN COOLING equipment at F3V relies upon the firewater pumps (see Specification 3/4.5.5) to assure forced cooling (FSAR 3ections 14.4.2, 10.3.9).

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is a reasonable period of time to restore an inoperable pump to operable status, consistent with repair times allowed for SACE SHUTDOWN COOLING equipment.

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Page 3/4'7-32 Amendment No.

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DRAFT dU NLANT AND SAFE SHUTDOWN COOLING SUPPORT SYSTEMS DEC 2 31987 3/4.7.5PR{tiARYCOOLANTDEPRESSURIZATION LIMIT}NGCONDIT10NFOR'0PERATION 3.7.5 a.

Two flow paths for f.rimary coolant depressurization shall be.0PERABLE, each from'the priraary coolant system. ' through-a helium puri/1 cation' train to the reactor: building.

..L' ventilation system exhaust.

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b.

At least 650 gallons of liquid nitrogen shall be 5

I maintained in the liquid nitrogen storage tank (T-2501).

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APPLICABILITY:

POWER,LOWkCVER,andSTANTUP i

t ACTION:

a.

With only one cf the above required helium purification train depressurization flow paths OPERABLE due to regeneration of the second purification train, l

s 1.

. Initiate action to regenerate the second helium purification train within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of its removal from service and restor'e it to 0PERABLE status within

~

the following.31 days, and 2.

Be in at least SHUTDOWN'within 72-hours after failure to regenerate within 31 days.

3.

The provfdons of Specification 3.0.4 are not --

. I applicable, b.

With only one of the above required helium purifiwtion-train depressurization flow paths OPERABLE other than due to regeneration restore two purification train flow paths-to OPERABLE status within 7 days, or be in-at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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'Amendmen?. No.

Page_3/4 7 DRAFT a

DEC 2 31997 c.

With none' of ithe _requi_ red helium purification train depressurization flow paths OPERABLE:

1.

Restore ~at least one train to OPERABLE status within

'12' hours or be.in at'least. SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and 2.

Restore' at least' two purification train.

depressurization flow paths to OPERABLE status within the following 7' days or be: in'at least-SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

d.

With -less than 650 gallons.of liquid nitrogen in the nitrogen storage tank, restore the liquid nitrogen storage inventory, to 650 gallons within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least SHUT 00WN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SURVEILLANCE REQUIREMENTS 4.7.5 The helium purification train depressurization. flow path (s) shall be demonstrated OPERABLE:

per 24 ' hours by verifying that the liquid a.

At least once nitrogen storage tank (T-2501) contains. at least'650 gallons of liquid nitrogen.

b.

At least once per 18. months by cycling (through one complete cycle of full travel) the valves for routing helium gas to the reactor building ventilation exhaust and for cooling the high temperature filter adsorber (HTFA).

Amendment No.

Page 3/4 7-34 DRAFT BASIS FOR SPECIFICATION LCO 3.7.5 / SR 4.7.5 DEC 2 31987 The helium purification system is a normally operating system with 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 unlikely event of an accident involving an extended 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 primary coolant and thereby reduce the heat transfer to the PCRV liner cooling system.

This action, combined with adjustments in the liner cooling system flow distribution and pressure ensures that the integrity of the PCRV liner is maintained (FSAR Appendix 0.1.1.1).

The normal 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 icw temperature gas-to gas heat exchanger, the Low Temperature Adsorber (LTA), purified helium filter and associated piping and valves leading to the reactor building exhaust.

In emergency conditions, a depressurization path may be 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 dryer bypassed.

The LTA would be bypassed because it is cooled by liquid nitrogen normally and the flow path may be restricted due to freezing.

With the LTA bypassed, the regeneration train can be effectively used for depressurization of the PCRV and the consequences are -t'll well below 10CFR100 limits, e.g.

bounded by the acci n..ts 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 circulator 2) 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.

4

i Amendment No.

Page 3/4 7-35 DRAFT liquidnitrogenisrequired}hh231997 A total of 650 gallons of provide refrigeration for the low temperature adsorber during depressurization (FSAR Section 9.6.6).

The only aspect of system operation that must be monitored is the maintenance of the required quantity of liquid nitrogen in the liquid nitrogen storage tank and the operability of isolation valves for routing helium gas to the reactor building ventilation exhaust and for cooling the HTFA.

The HTFA coolers are used only in the event of an extended loss of forced circulation accident.

The coolers are dry during normal operation and are isolated from the Reactor Plant Cooling Water system by two valves with a tell-tale drain.

The cycling of these valves is performed in a manner that does not introduce water into the coolers, as any residual water would remain there due to the U-tube design.

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~ Amendment No.

Page'3/4 9-1 4

DRAFT i

FUEL HANDLING AND STORAGE SYSTEMS DEC 2 3 t987 3/4.9.1 FUEL HANDLING AND MAINTENANCE IN THE REACTOR LIMITING CONDITION FOR OPERATION I

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 reactivity of the core shall be continuously monitored by at least two startup channel. neutron flux monitors,**

and d.

The SHUTDOWN 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 I hour, or terminate fuel handling and vessel' internal maintenance, L

retract the fuel handling mechanism or any other remote I

operated mechanisms from the PCRV, and close the reactor i

isolation valve or opening through the PCRV as soon as practicable, b.

With one of the above required neutron flux monitors f

I incperable, or not. operating,. immediately suspend all-operations involving CORE ALTERATIONS, any evolution resulting in positive reactivity changes, or movement.of 4

IRRADIATED FUEL.

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Applicable only when the fuel handling machine is located on the.

i reactor vessel, with the cask isolation valve and reactor isolation valve open.

Applicable only during CORE ALTERATIONS affecting core reactivity.

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Amendment No.

Page 3/4 9-2

~

DRAFT c.

With both' of the above required neutron flux moni b3 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 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . evaluate the SHUTDOWN MARGIN per Specification 4.1.3 d.

With the SHUTDOWN MARGIN requirements of Specification 3.1.3 not met, comply with ACTION c of Specification 3.1.3.

SURVEILLANCE REQUIRE.MENTS 4.9.1 a.

The reactor pressure and temperature conditions shall be determined to be within the above limits at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , b.

Each startup channel neutron flux' monitor shall be-demonstrated OPERABLE by performance of:

1.

A CHANNEL CHECK at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , 2.

A CHANNEL FUNCTIONAL TEST within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 SHUTDOWN MARGIN shall be in accordance with Speci fication 4.1.3.

t-Amendment No.

page-3/4 9-3 BASIS FOR SPECIFICATION LCC 3.9.1 / SR 4.9.1 To prevent the outleakage of primary coolant and potential release of activity during refueling or maintenance in the reactor. vessel, the reactor must be depressurized and maintained within the required conditions.

The CORE AVERAGE-

-INLET TEMPERATURE is limited to 165 degrees F to prevent 1 short-term pressurization of the fuel handling equipment over 5 psig (the maximum allowable working pressure of the fuel handling equipmant) as a result of accidental inleakage of water into the vessel during refueling.

The ' OPERABILITY of the neutron. flux monitors ensures that redundant 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.

The ACTION statement ensures that reactor and fuel handling machine will be placed in the safest configuration as soon as practicable, if a required condition cannot be ma,intained.

The Surveillance Requirement frequency gives adequate.

assurance that changes in reactor conditions will be detected in time to permit corrective actions if required.

to P-87441 A

6 i

i RESPONSE TO NRC COMMENTS REGARDING SAFETY RELATED COOLING FUNCTION DRAFT TECHNICAL SPECIFICATIONS (CONTAINED IN G-87131) 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.

Comment categories used in this Attachment are as follows:

A PSC accepts comment as 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 The Resolutions documented herein reflect discussions and agreements reached during meetings between PSC and the NRC on August 25-27, 1987, and where noted, on December 2 and 3, 1987.

j _ _ - - _ -

NRC Comment:

Definition 1.34 (SAFE SHUTDOWN COOLING)

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 the FS/.R.

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 is 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.

Resolution: A i

i i ____

I NRC Comment:

Table 1.1 #1 PSC has chosen to use the value of the CALCULATED BULK CORE TEMPERATURE within the TSUP draft to demarcate the need for redundancy requirements among safety-related cooling components within the SHUTDOWN mode.

The process of making distinctions between j

the operating modes would appear to be better-served by using the i

limiting value of the CALCULATED CORE BULK TEMPERATURE, namely, above i

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 i

100 psia.

1 i

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 depressurized 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 LC0 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 wnat interlocks are defeated by the Interlock Sequence Switch during switch position changes.

Resolution: A#

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NRC' Comment:

Table 1.1L#2L In LCO 3.9.1, the REFUELING mode ~is!further defined by the: condition

. of;having 'the-CORE AVERAGE INLET TEMPERATURE below : 165' degrees F.

Why : i s this condition not' given in Table 1.1: s~o as to bel readily.

apparent as also applying' to-all LCOs with REFUELING listed ~1n the

. 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.

PSC Re'sponse:

The February 20, 1987 draft of the. Tech Specs (P-87063)-revised LCO 3.9.1 to delete the Refueling mode'conditi'on 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 Temperature-requirement'as' a Refueling. Mode: definitive parameter.

'The NRC.

accepted this position.

See. PSC's response to Comment 1.1 #1 for a discussion on Calculated-Bulk Core Temperatures.

Resolution:

B 1

! _ _ _ _ - - _ _ _ = _ _

= _ _

4 e

NRC Comment 3.2 #1:

)

.1 NRC suggested that PSC provide Tech Specs for local and axial peaking factors, or clarify the FSAR.

i PSC Response:

This comment questions the reactor physics program at FSV, similar to other. comments in the NRC's letter of 5/30/86 (G-86285).

As PSC

-stated.previously in our response of 8/15/86 (P-86496), the FSV reactor physics program has a~

sound:~ technical

basis, is closely monitored, and has shown good performance through over three fuel cycles of operation.

The local and axial peaking factors are determined during the design of each reload, as discussed in TSUP Design Feature 5.3.4, and are not controlled by the reactor operators. As stated in P-86496, the analytical models which are used for reload design'have been compared with experimental data and with measured-data at FSV, with good agreement. -The TSUP specifications do provide for an evaluation of PSC's calculational methods that are used in core reload design, by verifying control rod pair worths in SR 4.1.4.1.2.

PSC does not consider that Tech Specs for local or axial peaking factors are appropriate.

Also, additional FSAR analyses or discussions to address all aspects of this comment are beyond the' scope of the TSUP.

Resolution:

F NRC Comment 3.2 #2:

f NRC requested an expanded Fuel Surveillance Program to demonstrate compliance with FSAR limits on axial and local radial power peaking.

PSC Response:

The Fuel Surveillance Program has been approved as Amendment 48 to the FSV Tech Specs. This Tech Spec 7.7 will be included verbatim

.a s J

TSUP Section 6.16.

Any additional discussions are outside the scope of the TSUP.

Resolution:

F 1

l q !

1

i 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 codes 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 thst 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 by NRC.

PSC Response:

PSC proposes to include a specification for primary' coolant loops and l

coolant circulation, similar to STS.

See attached TSUP. 3/4.4.1

.The.

~

NRC agreed to review this proposal, and in a meeting on December 2/3, 1987, the NRC agreed that this proposal is responsive to-their concerns.

PSC does not believe that a Tech' Spec for.the auxiliary boilers is 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 d. hey are relied upon in the safety-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.

The flow requirements are contained in LCO 3.2.4 (current LC0 4.1.9) and PSC's motive power for meeting this requirement' should not be limited.

The NRC accepted this position.

Resolution: A#, B, B 4

i - _ - - - - - _ - _ _ - - - - - - - - - - - - - - - - - - - - - - - -

A

NRC Comment 3.4 #_2:

PSC needs to clarify the FSAR with regard to the indicated safety function,namely, residual heat removal, provided by the condensate supply to circulator water-turbines and steam generators.

PSC needs to confirm how potential operator reluctance to use untreated firewater for emergency core cooling will not affect timely operator response to situations in which emergency core cooling is required.

Further, PSC needs to provide LCOs for the OPERABILITY and OPERATING conditions of the 12.5% capacity condensate pumps as part of the effective or equivalent residual heat removal (RHR) and auxiliary feedwater (AFW) systems at Fort St. Vrain.

PSC Response:

The requested FSAR revisions are beyond'the scope of the.TSUP.

PSC agreed to propose a new specification for a single 12 1/2%

condensate pump.

These pumps were chosen'because they can be powered from an essential power bus.

Resolution:

F, A#

i

., i

1

'l NRC Comment 3.4 #3, #4:

PSC needs to provice LCOs for the effective or equivalent residualf i

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.

_ g PSC Response:

Comment #3 requested PSC to add a. Tech Spec for the Circulating Water System.

-PSC does not believe that this Tech Spec would be approp:iate, per guidance in ANS 58. 4.'

The heat removal system.

relied upon in the analyses and assured by the; Tech Specs is the Service Water System. The NRC agreed to consider this position, and in a meeting on December 2/3, 1987; the NRC agreed that a' Tech Spec for the Circulating Water System is not required.

Comment.

4 addresses the decay' heat removal heat. exchanger.

Similarly, PSC does not believe' that this Tech Spec would be 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 165 degrees F during REFUELING, PSC notes that the decay heat removal heat exchanger is used when the condenser is out of service During e

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 is not taken out of service until heat removal with the decay heat removal heat exchanger is assured.

In the event neither the decay heat removal heat exchanger nor the condenser were available, the once-thru firewater flow path would be needed.

PSC agrees that FSAR Tables 8.2-6 should address " circulating" instead of '.' circulator".

This will be addressed outside the TSUP.

Resolution:

B, B, F d

i a

NRC Comment 3.4 #5:

NRC requested information regarding the amount of flow available when the auxiliary boiler feed water pumps are used to drive.the circulator water turbines.

PSC Response:

PSC has not taken credit for the c.uxiliary 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 requi red to determine the requested information and PSC considers this outside the scope of the TSUP.

Resolution:

F 1

4 NRC Comment 3.4 #6:

l TSUP draft Section 3/4.4 should be retitled PRIMARY C00LANT' SYSTEM.

PSC Response:

PSC agreed to the proposed change.

Resolution: A l

i 1

l

_g_

i I

)

_j

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 i

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. tnose which are relied upon for emergency core cooling without specific qualification (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 corcistent with our goal of clarity.

As discussed above, PSC believes that Section 3/4.5 should address Safe Shutdown Cooling Syst6ms 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 beheve that systems like Instrument Air and Hydraulics belong in tho 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 functional viewpcint.

Since these systems are used for valve actuation, the comparable LWR function would be the electrical distribution system that powers their moter operated valves, which is not included in i

their ECCS Sections.

It was agreea that the original organization would be retained.

Resolution:

B 1

)

j NRC Comment:

LCO 3.5.1.1 #1 In LCO 3.5.1.1.a.2, the words " including two OPERABLE flow paths" should be inserted after the last word "0PERABLE" in the condition a

statement for the operability of steam generator sections. This charige is consistent with stated conditions for OPERABILITY as given in the Basis for LCO 3.5.1.1 on page five under the section entitled Steam Generators.

PSC Response:

This concern has been addressed in revised draft 4.5.3.1, which provides acceptance criteria for OPERABLE steam generator sections.

l Resolution: A J

i 1

NRC Comment:

3.5.1.1 #2 In LCO 3.5.1.1.b.1, why is the 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 are not included on the SAFE SHUTOOWN COOLING equipment list in either FSAR Table 1.4-2 or FSAR Figure 10.3-4.

Should the circulator turbine drive 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 confusion by covering DBA-2 cooling as follows:

Boiler Feed Pump operability is assured in 3.7.1.1.

Emergency F??dwater header operability is assured via 3.5.4 (previously 3.5.3).

All other piping up to the helium circulator speed valves is 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.

Resolution: A NRC Comment:

3.5.1 #3 In LCO 3.5.1.1.b.2, the words "Two safe shutdown cooling drives" would appear to read more appropriately as "A safe shutdown cooling d ri ve. " There is only one steam and one water turbine drive per each circulator, and the text should reflect one drive.per OPERABLE circulator 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.

Resolution: A - _ _ _ _ _ - _ _ _

NRC Comment:

3.5.1.1 #4 In LCO 3.5.1.1.b.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 in Attachment 3 to P-86169, is interpreted to mean that backup bearing water is not required for effecting " safe shutdown cooling."

Similarly, the PSC response to Action 27b is not appropriate since backup bearing water is neither covered by the Technical Specification nor available (in use) below 30% of rated power.

PSC Response:

The " normal bearing water system" includes operability of two of the three bearing water 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, PSC's response to Action 27b stated that bearing water temperature need not be included in an LCO because the LCO and SR requirements insured operability of the bearing water system and the design features provided diversity and redundancy.

The discussion addressed the backup bearing water system as one of these design features, but it is not relied upon.

PSC feels that the emphasis should be placed on the assurance included in 'the LCO and SR requirements.

Each normal bearing water loop includes two bea ri r.g water coolers, one of which is an installed spare.

Each cooler is supplied by service water (whose operability is assured by a Tech Spec) or by circulating water; there are blind flange connections available for additional cooling water capability as required.

Resolution:

A, B i

l l

1

. [.

. _ _. _ _ _.____-________- _ _ a

NRC Comment:

3.5.1.1 #5 Section 4.0 and LCO 4.2.1 in the current FSV Technical Specifications allow only a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period for an orderly shutdown when a loop becomes inoperable due to loss of both circulators.

similarly, l

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 J

generator se:tions in one loop.

TSUP draft LC0 3.5.1.1 ACTION a j

allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore an OPERATING but inoperable loop to OPERABLE status before imposing the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limit ;to effect an orderly shutdown.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowance needs to be justified since it differs from the original Technical Specifications.

Since PSC currentiy recognizes the safety function as being accomplished only by the Pelton wheel drive, operating on feedwater (DBA-2) or firewater, the reference to "0PERATING loops" needs to be deleted 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 since the OPERABILITY or OPERATING status of the helium circulator on steam drive or on water turbine drive supplied by sources other than feedwater or firewater is not relevant to this LCO.

PSC should also modify DEFINITION 1.23, OPERATING-IN OPERATION, to read as follows (new wording underlined).

"A

system, subsystem, train, component or device shall be l

OPERATING or IN OPERATION when it is OPERABLE per DEFINITION 1.22 and actually performing its specified safety function (s)."

OPERABLE is unterstood by the Staff to include the operability of the full complement of equipment with no loss in redundancy pSC Pesponse:

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 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ).

Total loss of forced circulation requires I

depressurization per the time requirements of the existing LCO l

4.2.18. l

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 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Action time is appropriate.

Resolution: A NRC Comment:

LCO 3.5.1.1 #6 The portion of the previous comment with regard to OPERABILITY versus OPERATING status also applies to LC0 3.5.1.1 ACTION b.

A primary coolant loop can only be OPERABLE at POWER, LOW POWER and STARTUP since the steam drive has no safety function in safe shutdown cooling, and since the firewater safety function should not be OPERATING under any of these conditions.

PSC Response:

PSC has deleted Action b.

l Resolution: A l

l l

1 l l

l

NRC Comment:

3.5.1.1 #7 LCO 3.5.1.1 ACTION s e and d allow longer response times than allowed in Section 4.0 and LCOs 4.2.1 and 4.2.2 of the existing FSV Technical Specifications.

LCO 3.5.1.1 ACTION c should be made clear as to whether OPERABLE refers to the Pelton wheel drive or to the boiler feed pump drive source.

This ACTION needs to be more explicit.

PSC Response:

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Action time is justified in our response to comment 3.5.1.1 #5.

The latest revision of these specifications separates the drive source from the drive specification, so ~ that the Action for an inoperable boiler feed pump is contained in the boiler feed pump spec, the Action for an inoperable flow path up through the circulator speed 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 explained in the Basis.

Resolution: A#

l NRC Comment:

3.5.1.1 #8, #9 In LCO 3.5.1.1 ACTIONS h and i, the word "immediately" should be replaced with the words "within 10 minutes."

~

In LCO 3.5.1.1 ACTION 1, 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.

i

{

PS[ Response:

PSC agrees to replace "immediately" with "within 10 minutes" and to ensure the figure members are correct.

Due to the relocation of the i

forced circulation requirements, however, PSC notes that the figure j

members will be 3.4.1-1, -2 and -3.

1 Resolution:

A, A i

i NRC Comment:

3.5.1.1 #10 In SR 4.5.1.1.a.2.a), a surveillance for the use of the turbine water removal tank overflow should be included consistent with the last paragraph on the second page of the Basis for LCO 3.5.1.1.

PSC Response:

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.

This capability is identified in the Basis as a design feature but it is not relied upon.

PSC considered assuring TWDT removal capability by requiring either 2 pumps or one pump and the overflow, but this was not pursued because of varying storage capabilities in the reactor building sump.

Resolution: B NRC Comment:

3.5.1.1 #11 In SR 4.5.1.1.a.2.b),

bearing water makeup pump P-2108 was omitted and needs to be included.

PSC Response:

P-2108 was omitted from SR 4.5.1.1.a.2.6 because it does not have the auto-start feature demonstrated in that test of P-2105.

Its operability is assured by the ISIT program.

Resolution: B. _ _ _ - - - _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _

NRC Comment:

3.5.1.1 #12

]

SR 4.5.1.1.a.3 should include the exact same provisions as the NRC redraft of SR 4.5.1.1.a.2.c as given in Enclosure 2 to the NRC-NRR 1etter dated December 27, 1985, or PSC should provide justification for not including.

PSC Response:

This comment addresses testing the auto-water start feature by either

" simulating a steam turbine trip" (PSC's words) or. " simulating a PPS signal resulting from one loop being tripped and the circulators' steam turbine drives in 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 NRC Comment:

3.5.1.1 #13 SR 4,5.1.1.b.2.a) should be replaced to read as follows:

"The main steam ring header to main steam piping weld for one steam generator module in each locp, and."

The proposed readings for SR 4.5.1.1.b.2.a and b should be renumbered as b and c respectively. These 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 Spec requirements, as shown on the revised T.S.

Resolution:

A 1 l

7 NRC Comment:

'3.5.1.1 #14 In SR 4.5.1.1.b.3, the word "in" in the first line should be changed to "is",

t PSC Response:

i

/ gg PSC agrees.

~

3 Resolution: 'A

/'

[

1.

\\

i NRC Comment:

3.5.1.1 #15 In -SR 4.5.1.1.b.3.b),

the' words'"ar.:1 at least the' preliminary".in.

\\.,

4ikd-g ;j lines six and seven'should be deletid aid replaced by the word "the":

only.

I

N.

/

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9

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PSC Response:

ga. <7,,.

4 concernstheSpecialReportto'besubmittedtotheNRdC< k' This comment following a steam generator tube leak.

This report of metallographie.,.

and engineering examinations is to be submitted within 90 days of the y.,

(

return to. operation following'the tube leak' study.

PSC. believes that

" d, thi s time period is too restrictive to complete the examinations required for a full report. Metallurgical examinations often require 4

-i' extensive review and discussion before a conclusive evaluation is

(?

reached, and this should not be rushed because of a reporting ut requirement.

PSC intends. to pursue' any such ' evaluation in'an S

A. -

expeditious manner, but we do not believe.that a Tech Spec time limit-

\\; <j that is tied to plant operations is appropriate. There is currently

-(/i;l t

no time limit on this report and it was agreed to leave the T.S..as ?

written.

t

.5 Resolution: B i

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NRC Comment:

3.5.1.1 #16 i

In the first paragraph on the first page of the Basis for LCO J

3.5.1.1, the words " condensate or" and " condensate and" should be 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 feature of the FSV design that enhances the confidence in pelton wheel drive capability, and PSC believes it is appropriate to include it in the Basis discussions.

The NRC accepted this position in a meeting on December 2/3, 1987.

Resolution: A#, 8 NRC Comment:

3.5.1.1 #17 The third paragraph on the first page of the basis for LCO 3.5.1.1 should also indicate that the apparent need for "two circulators, operating with emergency water drive, supplied with feedwater via t.he emergency water header" also applies to the maximum credible depressurization rate as implied by FSAR Sectior; 14.4.3.2.

PSC-should address " protection against single failures" for such credible events.

PSC Response:

i FSAR Section 14.4.3.2, Revision 5 was rr<ised to reflect recent i

analyses that demorstrata acceptable cooldown'after the MCA, using i]

one circulator x

6edwater drive.

Requiring two operable circulators assures single failure protection.

The NRC accepted this position.

{

Resolution:

B i

b ~ 4% m,

F#1 4

'~

5

. lj-y x

to UI,. ' O, y O NRC' Commenti d.5.3.1 #19 u

/v The fourth paragraph, on' the fi rst page ' of' the Basi s' for.LCO 3.5.1.1'

@p*)i:t

1., ' 4 Luses mixed terminology compared.to the. rest of.the Basis.

The Lwords-

" main' steam / water section" should be repla'ced with " economizer-evapor:ator-superheater section".

PSC Rossense:

/

-PSC agreed.

Resolution: A h

?

^!

y

(. k NRC rimmer,t:

3.5.1.1 #19 t

Ts 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-qualifft:d as' SAFE SHUTOOWN COOLING equipment. The probability,value

E-1" should be rewritten' as '"1.0E-.7" and Justified. ~ A probability estf6 ate shod 1d also

.be supplied for, the maximumf credible depressurization event.

q, t

PSC Response:

PSC agrees to revise the Basis to clearly state t. hat th'e boiler feedt

~

pumps are;nehJsafe shutdown cooling equipment, and 'to specify'-the DBA-2 probab!)ity as "1.0E-7."

'/

PSC does not believe that a probability of the MCA is required..in Hght of( tt'e reanalysis described in Rev. 5 FSAR Section 14.4.3;2.

Also, the analytical effort required to produce this' number.is beyond

/

.the scope 'of TSUP.

Resolution: A#, F-q 4

~ 21 ~

_y q

1 n

A

l

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I l

NRC Comment:

3.5.1.1 #20 In the first paragraph on the third page of the Basis for LCO 3.5.1.1, delete the first two sentences and the word "also" in the third sentence.

The backup bearing water supply system is not currently covered in the Technical Specifications and should not be credited in the Basis.

PSC Response:

PSC does not agree that discussion of the backup bearing water supply should be deleted from the T.S. Basis.

Backup bearing water is a design feature of FSV that enhances the confidence in circulator operability. There is nothing in ANS 58.4 to indicate that T.S.

basis must 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.

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 l

be changed to read "at 31 days, 92 days and REFUELING CYCLE l

intervals".

l PSC Response:

Based on the revised specification, the Basis is changed to read "31 l

day and 92 day intervals", since there are no Refueling SRs for the i

bearing water system.

Resolution:

A l

~ 22 -

i H

NRC Comment:

3.5.1.1 #22'-

f 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.760lmdeglxF..-to P-86169 discusses this-parameter.

This discussion fails to' address specifically how, the operator is supposed.to calculate ~and use this--. parameter for assessing the Technical' Specifications applicability on-line as the plant operates or changes operating conditions.

PSC has not,.for example:

(1) Presented.

th'e 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 consistent 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 Ternerature 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 5ection 3.0.

The three comments are addressed as follows:

(1) The Basis for LCO 4.0.4, included in the amendment. submittal 4

of P-87124, identifies the conservative assumptions and i

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 obviates the need for additional Administrative Controls.

i (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 Upgradedt Tech Specs, upon NRC approval.

Resolution: B (based on approval of P-87124) !

l'

NRC Comment:

3.5.1.1.#23 FSAR Appendix C.15' cites the - water turbine automatic start as an.

" additional" engineered. safety' feature protection system, but this feature is not 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 Lif 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:

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.

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 clarify cooling requirements.

The NRC accepted:this position.

Resolution:

B 1 )

i 1

o

~m____________

NRC Comment:

3.5.1.2 #1, #3 These are the same as comments 3.5.1.1 #1 and #2.

PSC Response:

See responses to Comments 3.5.1.1 #1 and #2.

Resolution: A#, A#

NRC Comment:

3.5.1.2 #2 In LCO 3.5.1.2.b.1 and.2 the lead word "One" should be changed to "A".

PSC Response:

PSC proposes to replace "one" with "at least one", for purposes of clarity.

Resolution: A 1

l l

NRC Comment:

3.5.1.2 #4, #5 In LCO 3.5.1.2 ACTION a, the word "immediately" should be replaced with the words "within 10 minutes",

and the words " control rod l

movements" should be replaced with the words "any evolution."

In 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.

Resolution:

A, B i

l

~,

e NRC Comment:

3.6.2.1 #1 LCO 3.6.2.1 ' ACTION _ as and the first' paragraph of the Basis.for LC0~

3.6.2 allude to the 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of allowable operation with one'LCS loop OPERATING;

however, FSAR Section 5.9.2.4,.

page 5.9-13, does not-provide specific details on the analysis that justifies the allowance-of the 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months grace period.

PSC Response:

The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months allowance for single loop operation is consistent with

'the current' Tech Specs and is retained in the.TSUP. The NRC accepted

'this position.

Resolution:

B 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:

Use of the Action Statement as written is consistent with the NRC's recent position in their letter of July 2,1987 (G-87217),.. Enclosure 2, Comment 3.9.1-3.

The-NRC accepted this position.

Resolution: B f

A 1 j a

]

I

'NRC Comment:

3.6.2.1 #3 j

a In Sk 4.6.2.1, PSC'has failed to include the provision for scanner'

)

alarm functional tests and -calibrations as provided in.the NRC i

redraft in Enclosure 2 to the NRC-NRR-letter dated December 27, 1985.

PSC Response:

PSC.does not believe that scanner. surveillance are appropriate for-SR 4.6.2.1 because there.is no accompanying LC0 for.the scanner instrumentation. Consistent.with previous NRC, agreements, since this.

instrumentation is used to confirm PCRV liner tube operability.'and not for automatic actuation, surveillance per administrative controls (i.e.,' procedures) is appropriate and an explicit' Tech' Spec 'is not' required.

These previous NRC agreements are. documented in G-86635, as for example, in Comment LCO-3.1.1 #3.

The NRC. accepted this position.

Resol ution':

B

'I NRC Comment:

3.6.2.1 #4 In the Basis for LCO 3.6.2, th'e last sentence of the second' paragraph

. indicate how many tube failures were on the first page does not considered, nor does the following discussion: therein provide' concrete temperature limits as a function'of the number o f., failed tubes.

PSC Response:

The numbers of failed tubes allowed in~LCO 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 3

limits are not required.

The NRC accepted this position.

Resolution:

B k

i i 4 1

l

.i NRC Comment:

3.6.2 I #5 On page two, second paragraph,. of the Basis for.LCO 3.6.2, the ISI/IST program needs 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.Jaccuracy -is. assessed without. imposing Surveillance.

Requirements.

PSC Response:

The ISIT program will ' assure operability of the barriers between i

safety and non-safety related portions of. the LCS by means of ASME.'

1 Section -XI type valve operability testing.

.This includes valve' cycling.

'As for the temperature scanne r's,

the. accuracy of.the flow rate instrumentation. is -assur'ed by administrative.

controls

-(i.e.,

procedures) in a manner consistent with other plant instrumentation for TSUP parameters.

The NRC accepted this position.

Resolution:

B - - _ ____-__ _ __. _ _ - _ _ _ _ _ _ _ _ _ _ _

NRC' Comment: '3.6.2.2~#1, #3 In' LCO 3.6~.2.2 APPLICABILITY, the pound sign (#) footnote should be-further explained as to why bperation should be allowed in a degraded t

mode.

.This appears' to be a new licensing condition which has nct been supported by adequate justification.

On page two of'the Basis for LCO 3.6.2, the fourth paragraph should be evaluated 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.

i 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 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 UFSAR, Rev. 5).

PSC agreed to provide references to previous NRC approval of_the core

-support floor leaks. A review of NRC correspondence found evidence 1

of NRC awareness of the leaks, but no formal approval. The ORNL Monthly Report 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 conditional is a precautionary measure that is supported by the Tech Spec Basis.

In a meeting on December 2/3, 1987, the NRC accepted this position.

Resolution:

B NRC Comment:

3.6.2.2 #2 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.

l l

Resolution:

B i

1 ;

l l-

I NRC Comment:

3.6.3 #1 In LCO 3.6.3 ACTION, PSC should delete subheading "a." and delete the words " control rod movements."-

t i

-PSC Response:

.)

See comment 3.6.2.2 #2.

Resolution:

B, A NRC Comment:

3.6.3 #2 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.

PSC Response:

Consistent with previous NRC agreements, PSC believes that surveillance of PCRV LCS instrumentation should be performed per administrative controls (i.e.,

procedures) and need 'not be specifically required in the Tech Specs.

The NRC accepted this position.

Resolution:

B NRC Comment:

3.6.3 #3 The FSAR should be 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 previously agreed, FSAR changes are beyond the scope of the TSUP.

The NRC accepted this position.

Resolution:

F i

I i

4 4:.

NRC Comment:

3.7 #1 The-title for TSUP draft Section 3/4.7'should'be reduced simply to PLANT SYSTEMS.

SAFE SHUTDOWN COOLING' SUPPORT SYSTEMS can not be support systems if in fact the designated. system has t.o 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 also indicated in other NRC comments, certain Specifications (LCOs 3.7.5 and 3.7.8)' fail to meet'the intent -of designation as PLANT SYSTEMS',. and these~ Specifications' should be relocated -to other appropriate TSUP draft: Sections.

PSC' Response:

As,. stated.previously, PSC organized' the Upgraded 1 Tech Specs to facilitate operator use, consistent with the TSUP guidelines.

NRC is correct in noting that some systems such as Instrument Air.and Hydraulics 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.

cooling (i.e., pumps, valves and piping that are 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 come of the systems to safe shutdown cooling could be emphasized.,

PSC acknowledged that the ACM function goes beyond fire protection and agreed to relocate this' specification..to Section 3/4.8.' However, in the interest of operator clarity and' ease of use, PSC proposed to' 3

retain the organization of the remainder of the Upgraded Tech' Specs-as submitted, and the NRC accepted this position.

Resolution:

B, A# (ACM only)

)

u j i

.NRC Comment':

3. 7. ' #2 -

FSAR Sections.2.5.1 and 10.3.9 (page 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 offsite sources.to replenish the ' storage ponds. The offsite sources, or ultimate heat ~

sinks, are not currently addressed.in TSUP -draft Specification-3/4.5.4, and the Basis 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 PSC' Response:

PSC 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

~

the event that the 'onsite storage ponds are required for core cooling, PSC has 11 days to 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 not so great as to preclude use -of portable piping and pumper units, PSC is confident' that adequate offsite water supplies can be established within Lil' 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.

Resolution: B

J NRC Comment:

3.7.1.1 #1 PSC needs to provide the necessart clarifications and changes to the Basis for LCO 3.5.1.1 and LCO 3.

1 and the FSAR. with: 1 regard to

.depressurized cooling requir,,e*.F arising from depressurizations other than DBA-2.

PSC needs to rify and justify the~ use of PWR e

vessel rupture frequencies for, ssessing the frequency 'of: FSV accidental depressurizations.

PSC.,eeds to justify not 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 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 theseLwill be included in our ISIT program, outside the TSUP.

Resolution: A#, B

- 1

NRC Comment:

3.7.1.1 #2..

3 PS'C needs to' relocate the LC0/SR and to revise.--the Basis'as indicated.

PSC needs to expand or add necessary LCOs/SRs to cover

- i the DBA-2 cooling system requirements in'an effective manner.

fl PSC Response:

See PSC response to Comment 3.7 #1.

PSC agrees to clarify the Basis to clearly state that the Boiler Feed -

pumps.and the condensate pumps are not Safe Shutdown Cooling equipment.

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 suppert-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 the decay heat removal heat exchanger is.in use. The' demands of operational support' 'are sufficient to assure. adequate condensate pump operability to support DBA-2 or. safe shutdown cooling.

At the NRC's suggestion, PSC agreed to add a new Tech Spec'on a single 12 1/2*6 condensate pump.

This pump was selected sbecause it can be powered from an essential bus.and would supply emergency condensate in the event of a loss of offsite power. The NRC reviewed PSC's proposed Specification 3/4.7.1.7 and agreed in a meeting on December 2/3, 1987, that it is responsive to their~ concerns.

Resolution: A NRC Comment:

3.7.1.1 #3 Should REFUELING be cdded 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 agrees to revise the Applicability of this Specification to require boiler feed pumps whenever the CALCULATED BULK CORE TEMPERATURE is greater than 760 degrees F.

This includes part of the REFUELING mode.

PSC does not believe that it would be appropriate to specify a Calculated Bulk Core Temperature (CBCT) that must exist to enter the Refuelir.g 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: A NRC Comment:

3.7.1.1 #4 FSAR Section 6.3 and FSAR Appendix Sections C.41 and C.44 need to be reviaed 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 j

the TSUP.

These concerns will, however, be reviewed for the next FSAR update.

Resolution:

F l

i i _o

6 NRC Comment:

3.7.1.1 #5 i

Previously recommended changes to this Specification per NRC letter, 1

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 i

i ;

1 I

~

NRC Comment:

3.7.1.2 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 feedwat9r isolation valves differ between' the steam / water

. dump 'and. all the possible. sequences 1nvolved in requiring emergency

-core cooling? Does the -latter include manual. and' remote-manual operation, possible via different redundant electrical circuits in remote-manual operation? Do the proposed LC0 and SR accura tely ;

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 "Yes",:if these valves are absolutely essential to the operation of.

the. emergency core cooling system, an. appropriate Specification should still be included in the proper TSUP Section 3/4.5.

Finally, FSAR Section 10.2 is very unclear as to when or whether the emergency feedwater header has to be in use during STARTUP,. SHUT 00WN and.

REFUELING.

Use of the emergency feedwater. header would apparently imply that the feedwater isolation valves. are closed.

Since emergency core cooling could apparently be. required from STARTUP or SHUTDOWN, 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 Response:

All the above questions are aimed at justifying why the Steam / Water Gump System Tech Spec.1s only applicable above 5%- power, including feedwater isolatien 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' valves 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.

This SLRDIS valve Tech Spec will remain an Open Item until the later submittal. _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ = _ - _ _ _ _ _ _

l NRC Comment:

3.7.1.5 l

In LCO 3.7.1.5.b, the reference to Specification 3.0.6 should be changed to 3.0.4.

In SR 4.7.1.5, the reference to Specification 4.0.6 should be changed to 4.0.4.

These changes are consistent with l

the difference between PSC's April 1985 draft and the recent NRC l

markup of the November 1985 final draft.

PSC Response:

PSC agreed.

Resolution: A i

l NRC Comment:

3.7.1.6 In LCO 3.7.1.6 ACTION, change the words " control rod movements" to "any evolutions".

PSC Response:

PSC believes that " control rod movements" is the correct wording, consistent with the NRC's position in their letter of. July 2,

1987 (G-87217), Comment 3.9.1 #3. The NRC accepted this position.

Resolution: B NRC Comment:

3.7.3 If the instrument air system is absolutely required for the functions

]

defined in the Basis, especially the operation of the pneumatic

{

valves required for SAFE SHUT 00WN COOLING, then this Specification i

should be reloct.ted into TSUP draft Section 3/4.5 as an essential part of the emergency core cooling system.

Previous NRC comments transmitted by NRC letter dated May 30, 1986, continue to apply.

i PSC Response:

As stated in the previous response to Comment 3.7 #1, PSC believes I

that the Instrument Air Specification is appropriately located in 1

Section 7.

The NRC accepted this position.

l Resolution:

B s

1 i

]

r 1

NRC Comment:

3.7.5 The TSUP draft Specification for the Primary Coolant.Depressurization l

system is functionally equivalent to the STS ' Specifications for 1

Containment Depressurization and Cooling Systems..The Fort St. Vrain' l

Primary Coolant Depressurization has no PLANT SYSTEMS function, 'only.

.j

~

containment-equivalent -functions.

Previous NRC comments transmitted 4

by the NRC letter' dated May 30, 1986, continue'to apply.

PSC Response:

A' noted in PSC's response to previous comments (3.5, 3.7 #1),.PSC j

believes that the TSUP objective.of clarity and. ease of use by the-

-)

operators' would be' better served by retaining the organization as-proposed.

The Primary Coolant Depressurization specification actually uses portions of the helium purification system, which'is felt to be more easily identified as a Plant System than as a j

containment system. The NRC accepted this position.

PSC agreed to clarify the Bases for 3/4.7.5 to explain the reasons for PCRV depressurization, relative to containment and heat transfer.

Resolution: B

.NRC Comment:

3.7.8 #1 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:

PSC 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#

1 1 ;

'l NRC Comment:

3.7.8 #2 The Basis for the proposed specification 3/4.7.8 is not consistent; j

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.

effect SAFE SHUTOOWN COOLING.. Instead, the specific' functions of the ACM as given in FSAR Section 8.2.8.2. need to be included in the Basis, and the consequence goal of the ACM needs to specified per FSAR Sections 8.2 8, namely, insuring that "the conditions of. public health and safetyLconsequences, analyzed and presented in Design Basis Accident Number 1 in (FSAR) Appendix D.1, are not exceeded. in the case of disruptive faults or. events in congested cable-areas."' The fact that the risk goal for the ACM is an " acceptable substitution" for the cold shutdown (or safe shutdown) goal per 10CFR50, Appendix'R, should also be noted, but no statement should be made either indicating or implying that the NRC's agreement to'an

" acceptable substitution" represents equivalency" to '. the requirements of 10CFR50, Appendix R.

The ACM provides for'" core subcriticality and safe containment" which is not equivalent to a condition of " safe shutdown" without fuel damage.

PSC Response:

PSC agreed to 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 Specifications.

Resolution: A#

! I I

4 NRC Comment:

3.7.8 #3 FSAR Appendix C 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 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-871.31, changes to the FSAR are beyond the scope of the TSUP and will be reviewed separately.

The NRC accepted this position.

Resolution:

F NRC 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 c

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 into the REFUELING mode and the value of the-CALCULATED BULK CORE TEMPERATURE needs to be specified.

The cooling capacity during REFUELING should be specified in terms of the preferred equivalent

" residual heat removal" system configuration consistent with the 4

approach used in the W-STS Specification 3/4.9.8 and with the implied l

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 diside up or realign Specifications within TSUP draft 3/4.9 to l

respond to these comments, such revisions are acceptable provided 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 vould 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 primary 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 the neutron flux monitors are not all operable.

Resolution: A#

1

e NRC Comment:

3.9.1 (Part 2)

Currently, core. conditions during REFUELING are unclear with regard to expected heat loads and cooling capacity. ~-Therefore, FSAR Section

'9.1-should. be ' revised to. include figures and perhaps-tables that

provide'a correlation of typi. cal expected values for the. CALCULATED BULK CORE. TEMPERATURE,:the calculated decay heat fraction' normalized H

to rated reactor power, and the CORE AVERAGE. INLET TEMPERATURE as a function of. tin;e~ after shutdown.

Such correlated data.would be-.

- useful to 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 ar, equilibrium cycle'. This comparative information should clarify the-conditions existing within the reactor and core following entry 1

into SHUTDOWN and beforeLREFUELING.

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

-[

l

)

i i '

l l

l

't a

NRC Comment! SR 4.5.1.1 In' addition to our previous comments,.we request that you consider further revisions.for Specification.SR 4.5.'1.1.

These revisions are-

-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 needs to be modified to be performed in conjunction.with SR 4.5.1.1.a.4.b).

In SR' 4.5.1.1.b.1,

" proper flow".through.~the e;aergency 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 throttled ' condensate to simulate firewater. pump discharge.

.In1

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 continued efficacy of the firewater cooldown on a periodic 3 asis.

Test conditions'such as throttled condensat'e pressure and EES back.

pressure need to be stipulated in the Basis'for SR 4.5~ 1 1.

PSC Resoonse:

PSC considers that this test is 'more appropriately considered a design verification test and it should' not 'be ai periodic surveillance.

Furthermore, PSC cannot perform a meaningful demonstrat1on of flow through the EES sections. 'The model uses flew 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 coula any two phase flows which might be experienced.. S'nce one of the critical limitations is : choke flow of. steam, any other demonstration would not be meaningful.

The. NRC accepted this position.

Resolution: B __-________ _ _ _ _ - -

+

,e to P-87441 RESPONSE TO NRC COMMENTS REGARDING SAFETY RELATED COOLING FUNCTION DRAFT TECHNICAL SPECIFICATIONS (CONTAINED IN ENCLOSURE 2 TO G-87217) i i

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L'

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.c-RESPONSE TO NRC COMMENTS This attachment addresses comments provided:in Enclosure 3 to NRC letter dated ~ July 2,1987 (G-87217).

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 follows:

A PSC accepts comment as proposed A# PSC accepts comment with some changes or provides l

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 The Resolutions documented herein-reflect discussions and agreements.

reached during meetings between PSC and the NRC on August 25-27, 1987, and where noted, on December 2 and 3, 1987.

1 i-1

.I e

7 4

NRC Comment:

RAI 3.5.1.1 #1 Based on the PSC letter (P-87002) dat'ed. January 15, 1987.the condition. statement for LC0 3.5.1.1.a.2 needs to -be' rewr$tten as-follows:

cw N1

%.j Both steam generator-:, sections _(both the' economizer-evaporator -

.4f y superh' eater (EES)-;and the reheater) OPERABLE including two

_l OPERABLE flow paths.

u

s. m

_PSC Response:

The requirement for both reheaters is included.in PSC's re-drafted

-t Specification.

3 Resolution: A U

? k}1 e.

4 NRC Comment:

RAI 3.5.1.1 #2 c

Previously, the safe-shutdown cooling outlet flow oaths'were via the

\\I by pass valves off each loop's superheater outlet and each loop's hot t

reheat steam line. The by pass valves were verified to be OPERABLE as part of the normal operation of the bypass function.

The recently 4

(<

installed'six inch vent lines described in:P-87002 are apparently not g'

l to be used on a routine b' sis. Therefore, SR 4,5.1.1.b needs to,bo

. \\

a revised by renumbering surveillance b.2. and b.3 to b.3 and b;4',-

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:

w 1

s s

At least once per 18 months by. verifying'the OPERABILITY Rf each

'I -

superheater outlet flow path by verifying that.the valves l'n'~ the -

g Y

six inch vent lines can be opened and that the vent flow paths x

are not obstructed.

iy PSC Response:

,3 L

t" PSC has included a vent valve surveillance ~ in the re-drafte 6 r

Specification.

O Resolution: A i

3 l

4 f.

b

f. '

i i J.

f

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4 lv 3-NRC Comment: 'RAI'3.5.1.1 #3 f

X

~

Subject to'NRC final approval.-of'the proposed revisions to.the Basis 1

for.the existing LCO.4.1.9,fthe following. paragraph needs to be added-at the bottom of-the fourth page..ofC the Basis for:LCO 3.5:,1/1 following the second' paragraph of the subsection entitled Redundnce Criteria:

w i.

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r.

Specification 3.0.N provides the meth'odol'gy and necessary data o

to determine'the appropriate time _intervat;to reach a CALCULATED BULK COREL TEMPERATURE,of.760 -degrees 1 F. :If:the: active core remains below this. temperature, which corresponds.to ~ thefdesign:

maximum core. inletlLtemperature Jas' indicatedi 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, of primary.' coolant helium flow.'

A i ;.-.. qi PSC needs. 'to provide: ~ the appropriate; number.

"N for the cross -

referenced Specification. The need for Specification 3.0.N has, been identified

- i r.

'Se' NRC Request.for Additional :Information-at.

n

(

PSC Response:

PSC agreed to ' add' the proposed. paragraph' to Ihe' Basis for all Specifications that use the Calculated Bulk Core. Temperature.

The new paragraph number is 3.0.5.

Resolution: A n

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NRC Comment:

RAI 3.5 d.] #4 V

j The first paragisph. of the subsection' entitled Steam Generators on

,,j the fifth page of the Basis-for LCO 3.5.1.1.and LC0 3.5.1.2 needs-- to q

be replaced with the.following. paragraph.

Whenever-the CALCULATED BULK CORE TEMPERATURE exceeds 760 degrees F, both the reheater and1EC3; sections of the steam generator must-

.be' OPERABLE.

The stba"n generator reheater or EES sections can s

receive water from either tne emergency condensate' header or? the?

emergency feedwater ' header as required to be'0PERABLE per this

. Specification and per Specification.3/4.5.3..

System. flow,

x OPERABILITY. is,setermined -byl verifying flow from each:of;the.

Hoteinentioned emergency. headers '(see LC0 3.5.3.1) through each.

I si: tion of each steak generator. Whenever the CALCULATED BULK-CME TEMPERATURE is less than or equal,to 760 degrees. F 'or. the-plant OPERATICA;L MOCE 1s REFUELING, system flow OPERABILITY-is determined cy verifying flow from either. of the' aforementioned emergency heacers (see LCO 3.5.3.2) through'either section of either steam gerierator.

PSC Response:

PSC-ajreed 5that all the stated f?ow-capabilities should be demonstr'ated, b eept that the rehefters canc.ot receive water from the emergency feidwater header.

TMs is acc'omplished on:an 18 month basis per the 're-dra f ted Specification.

It. is not possible to demonstrate these ~ f'i bw, capabilities (e.g., emerge.ncy condensate to the rehnters and'EES secticos) during plant operatipn.

PSC believes that once.the 18 month den. castrations are performed, these flowpaths should be presumed operable until some part:.of; the flowpath is ce:la red inoperable.

A daily equipment status check has been propostd and PSC dees not believe that any. additional demonstration is 4pnropriate.

PSC~ egreed to revise the Basis to describe the flow demonstrations and I.couipment status check.

Resolution:

A#

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7 4'

4 NRC Comment:

RAI 3.5.1.1 #5 An additional paragraph is also required under the subsection entitled Steam Generators on the fifth page of the Basis for LC0 3.5.1.1.

This paragraph needs to discuss the appropriate operability 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.

PSC Response:

PSC agreed to add the requested paragraph to support the vent valve surveillance.

Resolution: A#

NRC Comment:

RAI 3.5.1.2'#1 Contrary to NRC Comment No. 1 on LC0 3.5.1.2 as given in Enclosure 1 to the NRC letter, Heitner to Williams,. April 17, 1987, the words to be added after the word "0PERABLE" in the condition statement for LCO 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 condensate header or the emergency feedwater header, to be OPERABLE in STARTUP and SHUTDOWN whenever the CALCULATED BULK CORE TEMPERATURE is less than or equal to 760 degrees F or in REFUELING.

PSC Response:

I PSC has revised the re-drafted Specification to include the NRC comment.

Resolution: A NRC Comment:

RAI 3.5.1.2 #2 See NRC Comment No. 4 on LC0 3.5.1.1.

PSC Response:

See previous response to Comment No. 4 on RAI 3.5.1.1.

Resolution: A#

)

4

'1

t 4

NRC Comment:

RAI 3.5.1.2 #3 Delete LC0 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 LCO 3.7.1.1) nor necessarily the emergency feedwater header (see LCO 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 cooling function when the CALCULATED BULK CORE TEMPERATURE is less than 760 degrees F although fission heat is allowed to be as high as 5% of rated reactor power in STARTUP.

PSC Response:

PSC has re-drafted the Specification to delete LCO 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 l _ _ _ _ - - - - - - - - - - - - - - - - - - _ _ _ _. - - _ _ _ _ _. _ _. -. - - - - - - -

_j

6..

i i s.

NRC Comment:

RAI 3.5.1.2 #4 4.

LCO 3.5.1.2 ACTION b needs to be rewritten as follows:

b.

With less 'than the above required OPERABLE equipment and.

with no forced circulation being maintained, be in at.least.

SHUTDOWN.-within 10' minutes an suspend. all. operations 1 involving CORE ALTERATIONS, control. rod movements resulting' in positive reactivity. changes' or movement of-IRRADIATED FUEL, and either:

1.

Restore forced circulation 'on at >1 east' cne loop prior to reaching a CALCULATED. BULK ~ CORE TEMPERATURE of 760:

degrees F, and comply with ACTION a,'or, 2.

Initiate PCRV -depressurization in accordance with the time -specified in. Figures -3.5.1-2.or 3.5.1-3, as applicable..

~

PSC Response:

This comment deal s - mostly with re-draf ted LCO 3.4-1.2.

PSC agreed-that. Core Alterations are not desirable during an LOFC and revised-the 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 PA! 3.5.3.2'#1, "10 minutes" should be "12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ". PSC agreed to revise'all ACTIONS accordingly.

Resolution: A# _

i 6'

'NRC Comment:

RAI 3.5.1.2 #5 In LCO 3.5.1.2, both ACTIONS a and'b, the words " CALCULATED BULK CORE TEMPERATURE" are used with regard ~ to the required. restoration of equipment or conditions.

In both' instances, a footnote symbol should-

'be:added after. the. word." TEMPERATURE" with~ the following words provided in the text of theLfootnote:

. Specification 3.0.N provides the methodology and necessary data to determine the appropriate time interval to reach a' CALCULATED-BULK CORE. TEMPERATURE of 760 degrees.F.

PSC needs to'- provide the. appropriate number "N" for the cross-referenced Specification.

PSC Response:

The new paragraph will be.3.0.5.

PSC agrees that references to 3 0.5 are eseful but.we' feel that the-individual Specifications would become " cluttered" if lengthy explanatory notes are added each.. time the ~ Calculated Bulk Core-Temperature is applied.

PSC wil1~ add a statement to 'the definition-and in the Basis that states, "Use of the Calculated. Bulk ' Core Temperature is explained in Specification 3.0.5."

Resolution: A 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.

PSC Response:

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

Resolution: A 5

NRC Comment:

RAI 3.5.3.1 #2 See above NRC Comment No. 3 on LCO 3.5.1.2.

PSC Response:

See previous response to Comment No. 3 on RAI 3.5.1.2.

Resolution:

A, B NRC Comment:

RAI 3.5.3.2 #1 The ACTION for LCO 3.5.3.2 needs to be deleted and replaced as follows:

With both the emergency feedwater and emergency condensate header inoperable, be in at least SHUTDOWN within 10 minutes and restore at least one header to OPERABLE status prior to reaching a CALCULATED BULK CORE TEMPERATURE of 760 degrees F and suspend all operations involving CORE ALTERATIONS, control rod movements resulting in positive reactivity changes, or movement of IRRADIATED FUEL.

PSC Response:

PSC agreed, except the "and suspend" should be "or suspend". Also, it was agreed that "within 10 minutes" should be "within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months " and the "or movement of IRRADIATED FUEL" should be deleted.

Resolution: A#

l i

NRC Comment:

RAI 3.5.3.2 #2, 3 and 4 In the ACTION, PSC shculd add the same footnote as described above in NRC Comment No. 5 on LCC 3.5.1.2.

Similar information and cross references as provided in the footnote should also be included in the Basis.

In SR 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.J.

See above NRC Comment No. 3 on LCO 3.5.1.2.

PSC Response:

See previous responses to Comment No. 5 on RAI 3.5.1.2, Comment No. 1 on RAI 3.5.3.1, and Comment No. 3 on RAI 3.5.1.2.

Resolution:

A,A,A,B

/ - ___ _ _-

4 NRC Comment:

RAI 3.5.4 1

In ACiION 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 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " 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 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ."

Similar information and cross references as provided in the footnote should also be included in the Basis.

PSC Response:

The subjec+. 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:)

6.

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 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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.

Resolution: A#

s NRC Comment:

RAI 3.6.2.2 #1' In LCO 3.6.2.2, the condition statement should' be deleted and replaced with the following:

The Reactor Plant Cooling Water (RPCW)/PCRV Liner Cooling System (LCS) shall be OPERABLE with:

a.

One RPCW/PCRV LCS loop OPERATING with at least one heat exchanger and one pump.in each loop OPERATING, and b.

With firewater supply available via one OPERABLE flow path.

The change is ne:essitated to comply with the NRC guidelines for PSC commitments with regard to proposed revisions to existing LCO 4.1.9.

These guidelines are given in the NRC letter, Heitner to Williams, dated December 5, 1986 (G-86631).

PSC Response:

As agreed with the NRC, PSC only committed in P-87124 (response to G-86631) to ensure firewater supply capability during a planned loss of forced circulation, when'the liner cooling system is relied upon for decay heat removal.

The proposed change to LCO 3.6.2.2 would extend this commitment to anytime Calculated Bulk Core Temperature is below 760 degrees F,

including the entire Refueling mode.

F3C believes that the original concern is addressed by the TSUP expanded requirement for firewater system operability per 3.5.4.

This is reinforced by PSC's Administrative Controls for loss of forced circulation. NRC accepted this position.

Resolution:

B

~ ~,

4 NRC Comment: RAI 3.6.2.2 #2-In LCO 3.6.2.2, the ACTION statement should be deleted and replaced' with the.following:

q With no RPCW/PCRV LCS loop OPERATING,.within 10. minutes, be in at

.I least' SHUTDOWN' andl suspend all operations involving! CORE ALTERATIONS,.

control rod movements resulting in positive reactivity changes, or movement of IRRADIATED FUEL, and:

H a.

Restore at. least one loop to OPERATING status prior to reaching a CALCULATED BULK CORE TEMPERATURE of 760' degrees F, or q

b.

Restore forced circulation cooling prior to reaching a CALCULATED BULK CORE TEMPERATURE of 760 degrees F.

The change is necessitated to comply with the NRC guidelines for PSC commitments with' regard to proposed revisions to existing LCO 4.' 1. 9.-

These guidelines are given in the NRC. letter, Heitner to~ Williams,.

dated December 5, 1986.

PSC Response:

Requiring a suspension of Core Alterations within 10 minutes rather than after reaching a 760 degree Calculated. Bulk Core Temperature is-consistent with the G-86631 concern that all decay heat removal capability could be disabled. PSC agreed to-propose a new Action that would require either one -operating PCRV LCS loop or forced circulation where the Calculated Bulk Core Temperature is below 760 degrees F.

Resolution: A#

l NRC Comment:

RAI 3.6.2.2 #3 If the interfacing isolation valves between the firewater system and the RPCW/PCRV LCS are not covered in the surveillance on the SAFE SHUTDOWN COOLING water supply system per SR 4.5.4.1.f or SR 4.5.4.1.g.3, the subject isolation valves need to be covered by revising SR 4.6.2.2 appropriately.

PSC Response:

PSC agreed to include these valves in the SR 4.5.5 surveillance for the firewater system.

This will be part of the ISI program foi plant valves and is beyond the current TSUP.

Resolution:

F 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 LCO 3.5.1.2.

Similar information and cross references as provided in the footnote should also be included in the Basis.

PSC Response:

See previous response to Comment No. 5 to RAI 3.5.1.2.

Resolution: A NRC Comment:

RAI 3.7.1.1 See above NRC Comment No. 3 on LC0 3.5.1.2.

pSC Response:

See previous discussion regarding Comment No. 3 on RAI 3.5.1.2.

Resolution:

A, B - _ _ _ _ _ _

_

ML20238C348

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