ML20248B761

Proposed TS Pages Supporting Change to TS 3.7.1.2, Surveillance Requirement 4.7.1.2 & Bases for Emergency Feedwater Sys

ML20248B761
Person / Time
Site:	Waterford
Issue date:	05/28/1998
From:	ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20248B751	List: ML20248B744 ML20248B761
References
NUDOCS 9806010376
Download: ML20248B761 (17)

Text

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PLANT SYSTEMS EMERGENCY FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.1.2 At least three independent steam generator emergency feedwater pumps and associated flow paths shall be OPERABLE with: ,

a. Two feedwater pumps, each capable of being powered from separate OPERABLE emergency busses, and

b. One feedwater pump capable of being powered from an OPERABLE steam supply system.

APPLICABILITY: MODES 1, 2, and 3.

ACTION:

a. With one emergency feedwater pump inoperable, restore the required' emergency feedwater pumps to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hturs.

c. With two emergency feedwater pumps inoperable be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c. With three emergency feedwater pumps inoperable, immediately initiate corrective action to restore at least one emergency feedwater pump to OPERAELE status as soon as possible.

S'J: VEIL L ANCE REOU1REMENTS 4.7.1.2 Tne emergency feedwater system shall be demonstrated OPERABLE:

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a. A: least once per 31 days by:

1. Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position,

b. At least once per 92 days on a STAGGERED TEST BASIS by:

1. Verifying that each motor-driven pump develops a discharge pressure of greater than or equal to 1298 psig on recirculation flow.

2. Verifying that the turbine-driven pump develops a discharge pressure of greater than or equal to 1342 psig on recirculation flow when the steam generator pressure is greater than 750 psig.

The provisions of Specification 4.0.4 are not applicable for entry into MODE 3.

WATERFORD - UNIT 3 3/4 7-4 Amendment No. Sh 96.111 jn'188MM88)*g2

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. i PLANT SYSTEMS l SURVElttANCE RE0VIREMENTS (Continued) l

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L c. At least once per 18 months during shutdown by: $

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1. Verifying that each automatic valve in the flow path actuates to its correct' position upon receipt of an emerg.ency feedwater actuation test signal.

2. Verifying that each pump starts automatically upon receipt of an emergency feedwater actuation test signal.

d. Following any cold shutdown of 30 days or longer or whenever feed- I water line cleaning through the emergency feedwater line has been performed, by verifying, by means of a flow test, the normal flow path from the condensate storage pool through each emergency feedwater ump to each of the steam generators. The provisions of Specification 4.0.4 are not applicable for entry into MODE 3 for the turbine-driven pump.

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. WATERFORD - UNIT 3 3/4 7-5 Amendment No. 96

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PLANT SYSTEMS BASES 3/4.7.1.2 EMERGENCY FEEDWATER SYSTEM i The OPERABILITY of the emergency feedwater system ensures that the Reactor Coolant System can be cooled down to less than 350*F from normal operating conditions in the event of a total loss-of-offsite power.

Each electric-driven emergency feedwater pump is capable of delivering a l total feedwater flow of 350 gpa at a pressure of 1163 psig to the entrance 1 of the steam generators. The staan-driven emergency feedwater pump is capable of delivering a total feedwater flow of 700 gpa at a pressure of 1163 psig to the entrance of the steam generators. This capacity is sufficient to ensure that adequate feedwater flow is available to remove decay heat and reduce the Reactor Coolant System temperature to less than 350*F when the shutdown cooling system may be placed into operation.

The surveillance requirement to verify the minimum pump discharge pressure on recirculation flow ensures that the pump performance curve has not degraded below that used to show that the pumps meet the above flow requirements and is consistent with the requirements of ASME Section XI.  ;

i 3/4.7.1.3 CONDENSATE STORAGE POOL l The OPERABILITY of the condensate storage pool (CSP) with the minimum water volume ensures that sufficient water is availabie (173,500 gallons) to cool the Reactor Coolant System to shutdown cooling entry conditions following any design basis accident. Additional makeup water is stored in the wet i

cooling tower (WCT) basins providing the capability to maintain HOT STANDBY conditions for at least an additional 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to initiating shutdown  ;

cooling. The total makeup capacity also provides sufficient cooling for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> until shutdown cooling is initiated in the event the ultimate heat sink sustains tornado damage concurrent with the tornado event. The CSP contained water volume limit (915 indicated in MODES 1, 2, and 3) includes an allowance for water not usable because of vortexing and instrumentation uncertainties.

l This provides an assurance that a minimum of 170,000 gallons of water is available in the CSP for the emergency feedwater system and that 3,500 gallons of water is available in the CSP for use by the component cooling water makeup system. The CSP contained water volume limit (115 indicated in MODE 4) includes an allowance for water not usable because of vortexing and instrumentation uncertainties. This provides an assurance that a minimum of 3,500 gallons of water is available in the CSP for the component cooling water makeup systemb If natural circulation is required, the combined capacity (WCT and CSP) is sufficient to maintain the plant at HOT STAND 8Y for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, l followed by a cooldown to shutdown cooling entry conditions assuming the availability of only onsite power or only offsite power, and the worst sia.gle failure (loss of a diesel generator or atmospheric dump valve). This requires approximately 275,000 gallons and complies with BTP RSB 5-1.

WATERFORD - UNIT 3 8 3/4 7-2 AMENDMENT N0.137 l i .

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NPF-38-206 ATTACHMENT B Proposed Specifications i

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O PLANT SYSTEMS EMERGENCY FEEDWATER SYSTEM m-LIMITING CONDITION FOR OPERATION 3.7.1.2 (W 1 mist)pree Opeconcem staar cenermop emergency feedwater" pumps and spor /atstjflow paths sha' I be OPERABLE g ,

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fa . Two edwater pumps, e h capable of being owered from separate j No OP BLE emergency bu ses, and

b. ne feedwater pump apable of being po red from an OPERABLE team supply system. a APPLICABILITY: MODES 1, 2, and 3.

ACTION:

a. With one emerg cy feedwater pump inoper le, restore the required emergency fe water pumps to OPERABLE s tus within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be i yster at least H0 STANDBY within the next hours and in HOT SHUTDOWN W .2 within th following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

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• t: . With t emergency feedwater pump inoperable be in at least H0 STAN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in SHUTDOWN within the followin 6 rs.

c. ith three emergency feedwa r pumps inoperable,'immediat y initiate corrective action to rest e at least one emergency feed ter pump to OPERABLE status as soon possible. j ,

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5'SVEILL ACE REQUIREMENTS 4.7.1.2 Tne emergency feedwater system shall be demonstrateLOPERABLE:

a. At least once per 31 days by0 I [ {_

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1. Ver ing that each va (manual, power- erated, or au atic) the flow path tha is not locked, se ed, or other secured in positio , is in its correc position. f .yw.ss v -

b. At least once per 92 days on a STAGGERED TEST BASIS b # 4.7. i,2. 6

1. Verifying sna each motor-driver pump evelops a discharge pressure of reater than or equal t 298 psig on recircula on flow.

2. Verifyi that the turbine-dri n pump develops a disc rge press e of greater than or ual to 1342 psig on rec culation fl when the steam genera pressure is greater th 750 psig.

T provisions of Specifi tion 4.0.4 are not appl able for a ntry into MODE 3.f WATERFORD - UNIT 3 3/4 7-4 Amendment No. SGr 96,111

INSERT TS 3.7.1.2 ACTIONS

a. With one steam supply to the turbine-driven EFW pump inoperable, restore the steam supply to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b. With one EFW pump inoperable for reasons other than those described in Action (a) and/or one flow path inoperable (but capable of delivering 100% flow), restore the EFW pump and/or flow path to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c. With two EFW pumps inoperable and/or one flow path inoperable (not capable of delivering 100% flow), be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

d. With three EFW pumps inoperable and/or both flow paths not capable of delivering 100% flow, immediately initiate action to restore one EFW pump and one flow path to OPERABLE status. LCO 3.0.3 and all other LCO required ACTIONS requiring MODE changes are suspended until EFW is capable of delivering 100% flow to one steam generator.

I INSERT SR 4.7.1.2.a verifying that each manual, power-operated, or automatic valve in each water flow path and in both steam supply flow paths to the turbine-driven EFW pump steam turbine, that is not locked, sealed, or otherwise secured in position, is in its correct position.

INSERT SR 4.7.1.2.b testing the EFW pumps pursuant to Specification 4.0.5. This Surveillance requirement is not required to be performed for the turbine driven EFW pump until 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after exceeding 750 psig in the steam generators.

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4 PLANT SYSTEMS

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SURVEILLANCE REQUIREMENTS (Continued)

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c. t least once per 18 months (Bdingfutqpard)by: 1

1. Verifying that each automatic valve in the flow path actuates to its correct position upon receipt of an tpergencyteeawat actuation @ signal, gg

2. Verifyingthateachpum starts automatically upon receipt of an 6, verwy feeqpate actuation @ signal, i

d. fFollowing any c d shutdown of 30 days longer or whenever fe -

I water line el ning through the emer cy feedwater line has en performed, verifying, by means o a flow test, the normal flow path from he condensate storage 01 through each emergen feedwat ump to each of the st m generators. The prov tons of Specif cation 4.0.4 are not a icable for entry into E 3 for the i (turb'e-drivenpump.j "

fMSEAT 4.11. 2 d

. WATERFORD - UNIT 3 3/4 7-5 Amendmerit No. 96

r l INSERT SR 4.7.1.2.c NOTE NOTE: This surveillance requirement is not required to be performed for the turbine-driven EFW pump until 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after exceeding 750 psig in ,

the steam generators.

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lNSERT SR 4.7.1.2.d Prior to entering MODE 2, whenever the plant has been in MODE 4,5,6, or defueled, for 30 days or longer, or whenever feedwater line cleaning through the emergency feedwater line has been performed, by verifying flow from the condensate storage pool through both parallel flow legs to each steam generator.

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. PLANT SYSTEMS BASES 3/4.7.1.2 DERRENCY FE@ WATER SYSTEM The OPERABILITY of t

[ReactorCoolantSystemc beemergency feedwater system nsures that the coo ed down to less tha 50*F from normal operating conditions in he event of a total loss-of ffsite power.

Each electric- iven emergency feedwater p is capable of delivering total feedwater fl of 350 sps at a pressure of 163 psig to the entrance of the steam gen tors. The staan-driven ese ncy feedwater pump is cap e of delivering otal feedwater flow of 700 at a pressure of 1163 psi to the entra of the steam generators. Th s capacity is sufficient to ensure that dequate feedwater flow is aval able to remove decay heat reduce the eactor Coolant System tempera re to less than 350*F when he shutdown ooling system may be placed i o operation.

e surveillance requirement to erify the minimum pump disc rge pre ure on recirculation flow ensu that the pump performance urve has not d aded below that used to show t t the pumps meet the above ow r quirements and is consistent u h the requirements of ASME tion XI. J 3/4.7.1.3 CONDENSATE STORAGE POOL The OPERABILITY of the condensate storage pool (CSP) with the minimum water volume ensures that sufficient water is available (173,500 gallons) to cool the Reactor Coolant System to shutdown cooling entry conditions following any design basis accident. Additional makeup water is stored in the wet cooling tower (WCT) basins providing the capability to maintain HDT STAND 8Y condit' ons for at 1sast an additional 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to initiating shutdown cooling. The total makeup capacity also provides sufficient coo ing for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> untti shutdown cooling is initiated in the event the ultimate heat sink sustains tornado damage concurrent with the tornado event. The CSP contained water volume limit (gLE indicated in MODES 1, 2, and 3) includes an allowance for water not usable because of vortexing and instrumentation uncertainties.

This provides an assurance that a minimum of 170,000 gallons of water is available in the CSP for the emergency feedwater system and that 3,500 gallons of water is available in the CSP for use by the component cooling water makeup system. The CSP contained water volume limit (115 indicated in MODE 4) includes as allemence for water not usable because of wortexing and l instrumentaties uncertalaties. This provides an assurance that a minimum of l

3,500 gallonsof water is available in the CSP for the component cooling water makeup systemb If' natural circulation is required the combined capacity (WCT and CSP) is sufficient to maintain the plant at HOI STAMBY for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, followed by a cooldown to shutdown cooling entry conditions assuming the availability of only onsite power er only offsite power, and the worst single failure (loss of a diesel generator or atmospheric dump valve). This requires approximately 275,000 gallons and complies with BTP R5s 5-1.

WATERFORD - UNIT 3 8 3/4 7-2 AME E Muff NO. 137 h

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The OPERABILITY of the emergency feedwater (EFW) system ensures the Reactor Coolant System can be cooled down to shutdown cooling (SDC) system entry conditions from normal operating conditions in ll'e event of a loss of feedwater. The OPERABILITY of EFW also ensures this 1- function is performed in the event of a total loss-of-offsite power and a single active failure.

The EFW system consists of two (50% capacity) motor-driven pumps (A and B), one (100%

capacity) steam turbine-driven pump (AB) and two diverse flow paths. One flow path supplies steam generator 1 and the second flow path supplies steam generator 2. A flow path consists of the piping, valves and components from the common pump discharge header through two parallel legs to the respective steam generator. Each parallel leg contains an isolation valve and a ficw control valve.

One flow path supplying one steam generator is capable of cooling the unit to SDC entry conditions.

Either of the two parallellegs in a steam generator flow path is capable of supplying 100% of the flow required for the heat removal safety function. Both parallel legs in a flow path are required for OPERABILITY of a flow path. Both steam supplies are required for OPERABILITY of the turbine-driven EFW pump.

The limiting accident for EFW flow is the feedwater line break (FWLB) which requires 575 gpm be delivered to the intact steam generator at a pressure of 1102 psig (lowest main steam safety valve set pressure plus 3%). The two motor-driven EFW pumps combined are capable of delivering 575 gpm at a pressure of 1102 psig to the entrance of the steam generators and the turbine-driven EFW pump is capable of delivering 575 gpm at a pressure of 1102 psig to the entrance of the steam generators. The EFW system is operated for emergency situations, during surveillance testing, and Infrequently during shutdown conditions to fill the steam generators.

The flow control and isolation valves in the parallel flow legs are fail open pneumatic valves.

Safety-related nitrogen accumulators serve as a backup to the instrument air system for these pneumatic valves. Each nitrogen accumulator supplies a pair of EFW valves (one flow control valve and one isolation valve in separate parallel flow legs to the same steam generator). With a nitrogen accumulator inoperable, for example, the associated flow path would be considered inoperable (but still capable of delivering 100% of the required EFW flow) and therefore ACTION 'b" would be implemented and would provide an allowed outage time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> forthis condition. Specification 3.6.3 would also be implemented for the affected isolation valve.

Limitina Conditions for Operation The LCO requires three EFW pumps and two flow paths be OPERABLE to ensure the EFW system will perform the design safety function to mitigate the consequences of accidents that could result in overpressurization of the reactor coolant system pressure boundary. Three independent EFW pumps, utilizing two flow paths, ensure availability of residual heat removal capability for all events involving a loss of feedwater. This is accomplished by powering two pumps from independent  ;

emergency busses. The third EFW pump is powered by a steam-driven turbine supplied with steam )

from a source not isolated by the closure of the MSIVs.

ACTIONS

a. If one of the two steam supplies to the turbine-driven EFW pump steam turbine is inoperable, action must be taken to restore OPERABLE status within 7 days. The 7 day completion time is reasonable based on the redundant OPERABLE steam supply to the turbine-driven EFW pump steam turbine, the availability of redundant OPERABLE motor-driven EFW pumps, and ,

the low probability of an event requiring the inoperable steam supply to the turbine-driven i EFW pump. l l

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b. With one EFW pump inoperable for reasons other than those described in Action (a), action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This condition includes the loss of two steam supply lines to the turbine-driven EFW pump. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time is reasonable, based on the redundant capabilities afforded by the EFW system, the time needed for repairs, and the low probability of a design basis event occurring during this period. Two EFW pumps remain to supply feedwater to the steam generators.

With one flow path inoperable, but still capable of delivering 100% of the required EFW flow, action must be taken to restore the flow path to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This condition includes the loss of a nitrogen accumulator in one flow path. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time is reasonable based on the remaining OPERABLE flow path to the other steam generator and the capability of the inoperable flow path to deliver 100% of the required EFW flow to the affected steam generator.

c. With two of the required EFW pumps inoperable and/or one flow path inoperable such that it is not capable of delivering 100% of the required EFW flow the unit must be placed in at least MODE 3 within 6 hou~,. and in MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed completion time is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

d. Action (d) indicates that all required MODE changes or power reductions are suspended until the EFW system is capable of delivering 100% of the required EFW flow to one steam generator.

With three EFW pumps inoperable and/or two flow paths not capable of delivering 100% of the required EFW flow in MODES 1,2, and 3, the unit is in a seriously degraded condition with no safety-related means for conducting a cooldown. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one EFW pump and one flow path to OPERABLE status as soon as possible. While other plant conditions may require entry into LCO 3.0.3, the ACTIONS required by LCO 3.0.3 do not have l

to be co,npleted when the EFW system is not capable of delivering 100% of the required flow to at least one steam generator, because they could force the unit into a less safe condition.

Surveillance Requirements

a. Verifying the correct alignment for manual, power operated, and automatic valves in the EFW water and steam supply flow paths provides assurance that the proper flow paths exist for EFW operation. This SR does not apply to valves that are locked, sealed, or otherwise ,

secured in position, since these valves are verified to be in the correct position prior to l locking, sealing, or securing. This SR also does not apply to valves that cannot be j inadvertently misaligned, such as check valves. This SR does not require any testing or )

valve manipulations; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

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b. The SR to verify pump OPERABILITY pursuant to Specification 4.0.5 ensures that the requirements of ASME Code,Section XI, are met and ensures that the pump performance l curve has not degraded below that used to show that the pumps are capable of satisfying the i design basis accident flow requirements. Because it is undesirable to introduce cold EFW l into the steam generators while they are operating, testing is typically performed on recirculation flow. Such in-service tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicsting abnormal performance.

This SR is modified to indicate that the SR should be deferred until suitable test conditions have been established. This deferral is required because there is an in. sufficient steam pressure to perform post maintenance activities which may need to be completed prior to performing the required turbine-driven pump SR. This deferra! allows the unit to transition from MODE 4 to MODE 3 prior to the performance of this SR and provides a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> grace period once a steam generator pressure of 750 psig is reached to complete the required post maintenance activities and SR. If this SR is not completed within the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> grace period or fails, then the appropriate ACTION most be entered.

c. The SR for actuation testing ensures that EFW can be delivered to the appropriate steam generator in the event of any accident er transient that generates EFAS and MSIS signals, by demonstrating that each automatic valve in the flow path actuates to its correct position and that the EFW pumps will start on an actual or simulated actuation signal. This Surveillance covers the automatic flow control valves, automatic isolation valves, and steam admission valves but is not required for valves that are locked, sealed, or otherwise secured in the required positicn under administrative controls. The 18 month frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The 18 month frequency is acceptable, based on the desigr reliability and operating experience of the equipment.

This SR is modified to indicate that the SR should be deferred until suitable test conditions have been established. This defenalis required because there is an insufficient steam pressure to perform Ast maintenance activities which may need to be completed prior to performing the required turbine-driven pump SR. This deferral allows the unit to transition from MODE 4 to MODE 3 prior to the performance of this SR and provides a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> grace period once a steam generator pressure of 750 psig is reached to complete the requPed post maintenance activities and SR. If this SR is not completed within the 48 h. irace period cr fails, then the appropriate ACTION must be entered.

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d. The SR for flow testing ensures that the EFW system is aligned properiy by verifying the flow i paths from the condensate storage pool (CSP) to each steam generator before entering j MODE 2 operation after being in MODE 4,5,6, or defueled, for 30 days or longer, or 1 whenever feedwater line cleaning through the emergency feedwater line has been performed.

Various combinations of pumps and valves may be used such that all flow paths (and flow legs) are tested at least once during the Surveillance. OPERABILITY of EFW flow paths must be verified before sufficient core heat is generated that would require the operation of the EFW System during a subsequent shutdown. The frequency is reasonable, based on engineering judgment, and other administrative controls to ensure that flow paths remain j CPERABLE. To further ensure EFW system alignment, the OPERABILITY of the flow paths is verified following extended outages to determine that no misalignment of valves has occurred. This SR ensures that the flow paths from the CSP 'o the steam generators are property aligned.

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NPF-38-206 LIST OF ENCLOSED REFERENCEG

1. Figure: EFW Simplified Flow Path

2. LER 96-002-00, Tech. Spec. LCO Exceeded Due To Non-Conservative Application of the Tech. Spec.

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.f-NPF-38-206 REFERENCE 2 LER 96-002-00, Tech. Spec. LCO Exceeded Due To Non-Conservative Application of the Tech. Spec.

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,,cany seansa m oocust snaam a casa m WATERFORD STEAM ELECTRIC STATION UNIT 3 05000 382 1 OF 5 rms oes TECH. SPEC. LCO EXCEEDED DUE TO NON-CONSERVATIVE APPLICATION OF THE TECH. SPEC.

OTHER FACluTIES INVOLVED ($1 /

EVENT DATE (5) LER NURMR (6) REPORT DATE (7) eactuTV NAME pocnET Nuusen N

4 NTH DAY YEAR YEAR f N MONTH DAY YEAR N/A gg FAciUTv NAME DOCKET NUMeER 02 06 94 96 - 002 -- 00 02 23 96 N/A 05000 OPERATWeG THIS REPORT IS SUBMTTED PURSUANT TO THE REOutREBENTS OF 10 CFR 9: (Check one or more) (11)

MODE (9) 1 20.2201(t0 20.2203(aH2Hv) y 50.73(aH2HO 50.73(eH2Hvm) 20.2203(eH1) 20.2203(aH3H0 50.73(eH2HW 50.73(aH2Hz)

POWER LEVEL (10) 100 20.2203(.H2HO 20.2203(.H3Hid so.73(.)(2Hm) 73.7i 20.2203(a)(2Hid 20.2203(aH4) 50.73(sH210v) -

0"HER 50.36(c)(1) 50.73(aH2)(v) s fy Abetree now 20.2203(aH2Hm) 20.2203(eH2Hiv) 50.36(c)(2) 50.73(eH2)(vn)

UCENSEE CONTACT FOR THIS LER (12)

TatarNoNE NUndeFR pnskms Aree Code unnde D.W. VINCI, LICEMSING MANAGER (504) 739-6370 COtrLETE ODE UDE FOR EACH C00MOIENT FAILURE DESCRIMD IN T>NS REPORT (13)

CAUIE SYSTIM C0tsPONENT MANUFACTURER 7 ggg CAUIE SYSTElf COMP 01ENT MANUFACTURER sN i%

SUPPLBENTAL REPORT EXPECTED (t op m h00 NTH DAY YEAR YES SueMISS40N j X

NO DATE (15)

(if yes, complete EXPECTED SUBMtS$10N DATE). j AaSTRACT (Limst to 1400 spaces,6.e., approseraetely 16 emgse-spaced typewntten linee) (18)

A recent concem questioned the need to enter the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Technical Specification (TS)

ACTION (3.7.1.2.a) when either steam supply to the turbine driven EFW pump is either out of service or inoparable. The TS Limiting Condition for Operation (LCO) requires that the pump be " capable of being powered from an OPERABLE steam supply l system." Since there are separate steam supplies (one from each Steam Generator) to '

the turbine driven EFW pump, a literal application of the TS prevented entry ir,to the TS ACTION when one supply was either out of service or inoperable. A review of the equipment out of service (EOS) records for MS-401 A & B, the EFW Pump AB Steam Supply Valves, indicates that MS-401B was out of service from 2-3-94 at 1445 hours0.0167 days <br />0.401 hours <br />0.00239 weeks <br />5.498225e-4 months <br /> until 2-8-94 at 1117 hours0.0129 days <br />0.31 hours <br />0.00185 weeks <br />4.250185e-4 months <br />. During this time, the plant was in Mode 1. This exceeds the 1.C0 for TS 3.7.1.2. The cause of this event was the misleading wording of TS 3.7.1.2.b. A change to OP-100-014, Technical Specification Compliance, now requires  ;

entry into the TS ACTION stetement if either MS 401 A or B is declared out of service.

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This eaent did not compromiss the health and safety of the public.

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LICENSEE EVEPT REPORT (LER)

TEXT CONTINUATION FAOiUTY NAw (1) DOCKET LER NUWR (6) PAGE (3)

N R NU 0 0 WATERFORD STEAM ELECTRIC STATION UNIT 3 96 - 002 - 00 TEXT (It more space os requoted. use additoonal copons of NRC Form 366A) (11)

REPORTABLE OCCURRENCE This event involves a component being inoperable in excess of the time specified by  !

the limiting condition for operation (LCO) for Technical Specification (TS) 3.7.1.2. This is reportable as a condition prohibited by Technical Specifications pursuant to 10 CFR 50.73(a)(2)(i)(B). The deportability determination of this event was made on 1-24-96.

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INITIAL CONDITIONS On 2-3-94 at 1445 hours0.0167 days <br />0.401 hours <br />0.00239 weeks <br />5.498225e-4 months <br />, the EFW Pump AB Steam Supply Valve MS-401B (Ells identifier SB-ISV) was declared out of service while the plant was operating in Mode 1 at approximately 100% power. There was no major equipment out of service specific to this event. No Technical Specification LCOs were in effect specific to this event. l These conditions remained unchanged through 2-8-94 at 1117 hours0.0129 days <br />0.31 hours <br />0.00185 weeks <br />4.250185e-4 months <br /> when MS-401B was returned to service.

EVENT DESCRIPTION The NRC recently questioned the need to enter the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> TS ACTION (3.7.1.2.a) if either steam supply to the turbine driven EFW pump (Ells identifier BA-P) is out of service or inoperable. Condition report (CR-96-0035) was generated to address this concem. The TS LCO requires that the pump be " capable of being powered from an OPERABLE steam supply system." Since there are separate steam supplies (one from each Steam Generator) to the turbine driven EFW pump, a literal application of the TS may have prevented the entry into the TS ACTION when one supply was either out of service or inoperable. In conversations with Operations personnel, it was determined that when one MS-401 valve was out of service, the turbine driven EFW pump would remain operable as long as the second valve was operable.

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LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACIUTY NAAE (1) I DOCKET tin NunSEn (S) PAGE (3) uan stNa n ng WATERFORD STEAM ELECTRIC STATION UNIT 5 m1,,,_..,...-..._._,.,c,_-,(,,,

I0 2 96 -- 002 -

00 1

The above application of the TS did not consider an event where a Main Steam or Main Feedwater Line break occurs on the steam generator feeding the remaining steam supply valve and the single active failure involves a motor driven EFW pump. In this event, only one motor driven EFW pump would be available. The accident analysis in l Chapter 15 of the FSAR assumes an available EFW flow of 700 gpm (i.e., one turbine driven EFW pump or two electrical driven EFW pumps).

Given that this literal TS application was non-conservative, Waterford 3 may have been in past violation of TS action statement 3.7.1.2.a. To determine this, a search of the Equipment Out of Service (EOS) data base was performed over the past 3 years for MS-401 A & B, EPN Pump AB Turbine Steam Supply Valves. The times these components had been out of service were reviewed to determine whether the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO had ever been exceeded when the TS was applicable.

The review of the EOS records indicated that MS-4018 was out of service from 2-3-94 at 1445 hours0.0167 days <br />0.401 hours <br />0.00239 weeks <br />5.498225e-4 months <br /> until 2-8-94 at 1117 hours0.0129 days <br />0.31 hours <br />0.00185 weeks <br />4.250185e-4 months <br />; a total of 116 hours0.00134 days <br />0.0322 hours <br />1.917989e-4 weeks <br />4.4138e-5 months <br /> and 32 minutes. During this time, the plant was in Mode 1. This exceeds the LCO for Technical Specification 3.7.1.2. An EOS records search was also performed for this period to determine the status of the motor driven EFW pumps and inotors. A review of EOS records and the control room daily log sheets for 2-3-94 through 2-8-94 has shown that the two motor driven EFW pumps were operable during this time.

Based on the information above, it was determined that between 2-6-94 at 1445 hours0.0167 days <br />0.401 hours <br />0.00239 weeks <br />5.498225e-4 months <br /> and 2-8-94 at 1117. hours Waterford 3 exceeded the LCO for Technical Specification 3.7.1.2. That condition is reportable under 10 CFR 50.73(a)(2)(i)(B). The deportability determination for this event was completed 1-24-96.

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l- CAUSAL FACTORS l l

The root cause of this event was the misleading wording in the present TS. This event i was the result of a literal application of the Technical Specifications. TS 3.7.1.2.b requires one feedwater pump capable of being powered from an OPERABLE steam  !

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' NRC FORAd SSGA U.S. NUCGAR REGULATORY COSASBSION itse LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACIUTY NAhE 0) DOCKET ER NURM (8) PAGE (31 .

YEAR E ," A 05000 4 "

WATERFORD STEAM ELECTRIC STATION tmIT 3 382 96 .. 002 00 TEXT (1f more space os reworod. use additoonal copoes of NMC form 366Al 01l supply system. Since there are separate steam supplies (one from each generator) to the turbine driven EFW pump, a literal application of the TS would be that if either steam supply were available, then the turbine driven EFW pump would have had an operable steam supply.

IMMEDIATE CORRECTIVE MEASURES Change 1 to OP-100-014, Technical Specification Compliance, added specific guidelines in step 5.2.21 for the EFW Pump AB Steam Supply. These guidelines state that both steam supplies are required to be Operable for EFW Pump AB. If one steam supply is declared inoperable, then declare the EFW Pump AB inoperable and take the required Actions of Technical Specification 3.7.1.2.

ACTIONS TO PREVENT RECURRENCE in the future, Waterford 3 plans to adopt an EFW Technical Specification similar to that in NUREG 1432, Standard Technical Specifications for Combustion Engineering Plants.

This will clarify the wording of this TS. Until this TS change is made, training on Change 1 to OP-100-014, Technical Specification Compliance, will be provided to Operations personnel during Operator Requalification Training.

l SAFETY SIGNIFICANCE l

l A review of the safety significance of this event was performed by Safety & Engineering i Analysis. The effects of MS-4018 being out of service in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> were evaluated by consiering Station Blackout and accidents which cause the increase or decrease in heat removal by the secondary system. In support of this evaluation, the control room daily logs were reviewed to determine whether any plant transients had occurred during the time the valve was out of service. No precursor to the these accidents occurred during the post 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period. There was, therefore, no nuclear safety significance to the extra out of service time for MS-401B.

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,I FoRu assa u.s. NUCtfAR REGut.AT0 fly C-isen LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACIUTY NAIE (1) DOCKET LER N (8) PAGEtal 05000 5 OF 5 Id4TEkFORD STEAM ELECTRIC STATION UN , 3 382  %- 002 -- 00 TEXT (It more space os requwed, use additional copies of NRC Form 366A) (17)

In addition to the above, the realistic analysis described in the Chapter 10 of the FSAR )

has determined that any one EFW pump can supply adequate flow for decay heat removal to one or both steam generators. This is addressed in table 10.4.9A-1.

SIMILAR EVENTS 1

There have been no similar events reported as LERs at Waterford 3.

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