ML21116A143

(Waterford 3) - Revision to License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual

ML21116A143
Person / Time
Site:	Waterford
Issue date:	04/26/2021
From:	Gaston R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2019-LLA-0203
Download: ML21116A143 (28)

Text

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.90 W3F1-2021-0017 April 26, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Revision to License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual (EPID L-2019-LLA-0203)

Waterford Steam Electric Station, Unit 3 (Waterford 3)

NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 In Reference 1, Entergy Operations, Inc. (Entergy) submitted a request for a proposed amendment to Renewed Facility Operating License (FOL) NPF-38, Appendix A, "Technical Specifications" (TS) for Waterford Steam Electric Station, Unit 3 (Waterford 3). Specifically, Entergy requested removal of TS 3/4.1.2.1 through 3/4.1.2.8, "Boration Systems," and references to the TS, and relocation of the information to the licensee-controlled Technical Requirements Manual (TRM). In Reference 2, the U.S. Nuclear Regulatory Commission (NRC) issued a request for additional information (RAI). Entergy provided a response to the RAI in Reference 3.

Subsequent to submittal of the Reference 3 RAI response, Entergy determined that the TS 3/4.1.2 equipment which provide a support function for the Auxiliary Pressurizer Spray system should be retained in the TS and relocated to TS 3/4.4.3.2, "Auxiliary Spray." Therefore, Entergy proposes to revise the Reference 1 license amendment request (LAR) to relocate, in TS 3/4.4.3.2, the Boration Systems TS equipment that is required to support the operability of the Auxiliary Pressurizer Spray system, and relocate the remaining Boration Systems TSs to the TRM, as proposed in Reference 1.

W3F1-2021-0017 Page 2 of 3 The Enclosure to this letter provides an evaluation of the proposed changes. Attachment 1 to the Enclosure provides the existing applicable TS pages, marked-up to show the proposed changes. The proposed marked-up TS pages in Attachment 1 replace the previously submitted marked-up TS pages (i.e., Attachment 1 of Reference 1), in their entirety. Attachment 2 provides a retyped (clean) TS page for the proposed changes to current TS 3/4.4.3.2, "Auxiliary Spray" that is described in the Enclosure. The proposed retyped TS page provided in supplements the previously submitted retyped TS pages (i.e., Attachment 2 of Reference 1). Attachment 3 provides a TS Bases page applicable to this proposed LAR revision, marked-up to show changes. This TS Bases page markup supplements the previously submitted marked-up TS Bases pages (i.e., Attachment 3 of Reference 1), and are provided for information only.

Entergy has reviewed the no significant hazards consideration and the environmental assessment previously submitted by Entergy in Reference 1, and determined that the conclusions reached in Reference 1 are still valid. No changes or updates are required. This letter contains no new regulatory commitments.

Should you have any questions or require additional information, please contact Paul Wood, Regulatory Assurance Manager, at 504-464-3786.

I declare under penalty of perjury, that the foregoing is true and correct. Executed on April 26, 2021.

Respectfully, Ron Gaston RWG/rrd/jls

Enclosure:

Revision to License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual Attachments to

Enclosure:

1. Revised (Markup) Technical Specification Pages

2. Revised (Clean) Technical Specification Pages

3. Revised (Markup) Technical Specification Bases Page (For Information Only)

W3F1-2021-0017 Page 3 of 3

References:

1. Entergy Operations, Inc. (Entergy) letter to U.S. Nuclear Regulatory Commission (NRC), "License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual," W3F1-2019-0062, (ML18264A023), dated September 20, 2019.

2. NRR E-mail capture, U.S. NRC to Entergy, "NRC Request for Additional Information for Waterford LAR to Relocate Boration TSs (EPID L-2019-LLA-0203)," (ML20168A395), dated June 5, 2020.

3. Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC), "Response to U.S. Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual (EPID L-2019-LLA-0203)," W3F1-2020-0043, (ML20188A364), dated July 6, 2020.

cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Waterford Steam Electric Station, Unit 3 NRR Project Manager - Waterford Steam Electric Station, Unit 3 Louisiana Department of Environmental Quality, Office of Environmental Compliance

Enclosure W3F1-2021-0017 Revision to License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual

Enclosure to W3F1-2021-0017 Page 1 of 7 Revision to License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual

1. Summary Description In Reference 1, Entergy Operations, Inc. (Entergy) submitted a request for a proposed amendment to Renewed Facility Operating License (FOL) NPF-38, Appendix A, "Technical Specifications" (TS) for Waterford Steam Electric Station, Unit 3 (Waterford 3). Specifically, Entergy requested removal of TS 3/4.1.2.1 through 3/4.1.2.8, "Boration Systems," and references to the TS, and relocation of the information to the licensee-controlled Technical Requirements Manual (TRM). In Reference 2, the U.S. Nuclear Regulatory Commission (NRC) issued a request for additional information (RAI). Entergy provided a response to the RAI in Reference 3.

Subsequent to submittal of the Reference 3 RAI response, Entergy determined that the TS 3/4.1.2 TS requirements associated with the equipment that provide a support function for the Auxiliary Pressurizer Spray system should be retained in the TS and relocated to TS 3/4.4.3.2, "Auxiliary Spray."

2. Detailed Description Entergy proposes to revise the Reference 1 license amendment request (LAR) to relocate, in TS 3/4.4.3.2, "Auxiliary Spray," the Boration Systems TSs for equipment required to support the safety function of the Auxiliary Pressurizer Spray system. The safety function of the Auxiliary Pressurizer Spray system is to support the reactor coolant system (RCS) depressurization during a Steam Generator Tube Rupture (SGTR) event. As stated in the Waterford 3 Updated Final Safety Analysis Report (UFSAR), section 15.6.3.2.1.2, "Sequence of Events and Systems Operation," the operator will initiate Auxiliary Pressurizer Spray flow in order to depressurize the RCS to 1000 psia, after the isolation of the affected steam generator. The RCS depressurization lowers the primary to secondary differential pressure, thus lowering the primary to secondary leakage. The operator also uses the system, in concert with the High Pressure Safety Injection (HPSI) system and pressurizer backup heaters, to control RCS inventory and subcooling.

This proposed revision to the Reference 1 LAR relocates the following TS 3/4.1.2 equipment limiting conditions for operation (LCOs) and surveillance requirements (SRs) to TS 3/4.4.3.2 "Auxiliary Spray" in order to ensure the operability of the Auxiliary Pressurizer Spray system, and thus the safety function of the system. Specifically, the following equipment, in addition to the two Auxiliary Pressurizer Spray valves, are required:

Boric acid flow paths Charging pumps Boric acid makeup pumps Boric acid makeup tanks (BAMT)

Enclosure to W3F1-2021-0017 Page 2 of 7 In addition, the title of TS 3/4.4.3.2 is being changed from "Auxiliary Spray" to "Auxiliary Pressurizer Spray" in order to better describe the safety function.

TS 3.4.3.2 LCO currently states:

3.4.3.2 Both auxiliary spray valves shall be OPERABLE.

TS 3.4.3.2 LCO will be revised to state (underlined text is added to existing text; strikeout of existing text is deleted):

3.4.3.2 Two Both auxiliary pressurizer spray valves trains shall be OPERABLE consisting of the following:

a. Both auxiliary pressurizer spray valves

b. One flow path from an acceptable boric acid makeup tank via its boric acid makeup pump

c. One flow path from an acceptable boric acid makeup tank via its gravity feed valve

d. At least two independent charging pumps

e. One boric acid makeup tank with a minimum water volume of 58% indicated level.

This proposed change is consistent with the previous TS 3/4.1.2 requirements for the auxiliary pressurizer spray valves and adds the equipment required to support operability of the Auxiliary Pressurizer Spray system into TS 3/4.4.3.2. Specifically, the following TS requirements are being relocated, as follows:

Flow paths - TS LCOs 3.1.2.2.a.1 and 3.1.2.2.a.2 are relocated to new TS LCOs 3.4.3.2.b and 3.4.3.2.c.

Charging pumps - TS LCO 3.1.2.4 is relocated to new TS LCO 3.4.3.2.d.

Boric acid makeup pump - TS SR 4.1.2.6 is relocated to new TS SR 4.4.3.2.6. The boric acid makeup pump LCO requirements are currently part of the flow path specification TS LCO 3.1.2.2.a and are relocated to new TS LCOs 3.4.3.2.b and 3.4.3.2.c.

Water sources - TS LCO 3.1.2.8.a is relocated to new TS LCO 3.4.3.2.e. The minimum required water volume is consistent with the minimum volume requirement in TS Figure 3.1-1, "Required Stored Boric Acid Volume as a Function of Concentration," which is proposed for deletion, and bounds the minimum volume necessary to ensure the operability of the Auxiliary Pressurizer Spray system.

The current TS 3.4.3.2 Action statements a. and b. were originally written for the two Auxiliary Pressurizer Spray valves; However, these did not address the requirement for the entire train (i.e., as specified above in the proposed TS 3.4.3.2). This proposed change ensures the entire safety function of the Auxiliary Pressurizer Spray system, as it encompasses each train. The TS 3.4.3.2 Action statements will be revised as follows:

Enclosure to W3F1-2021-0017 Page 3 of 7

a. With only one of the above required auxiliary pressurizer spray valves trains OPERABLE, restore both valves trains to OPERABLE status within 30 days or be in 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 none of the above required auxiliary pressurizer spray valves trains OPERABLE, restore at least one valve train to OPERABLE status within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 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 />.

The proposed Auxiliary Pressurizer Spray system Action statements address the safety function of the system, as opposed to the current TS 3.1.2 Action statements that support a reactivity safety function.

Technical Specification 3.4.3.2 Action a is intended to allow continued operation for 30 days with either Auxiliary Pressurizer Spray train inoperable. From an Auxiliary Pressurizer Spray system safety function standpoint, the loss of either auxiliary pressurizer spray train is still consistent with the previous action that was spray valve specific. The loss of one spray valve would be the same as the loss of one train with respect to the safety function of providing spray flow. Thus, this is consistent with the current "Action a" requirements. In addition, while in this action statement, one train may consist of either trains' components, provided at least one flow path exists from the boric acid makeup tank to the Auxiliary Pressurizer Spray valves.

Technical Specification 3.4.3.2 "Action b" addresses a loss of the Auxiliary Pressurizer Spray system safety function. This can occur by the loss of both trains, or the loss of the water source (i.e., an operable flow path, charging pumps, and minimum required BAMT volume). Thus, this is consistent with the current "Action b" requirements.

The current TS SR 4.1.2.2 states:

4.1.2.2 At least two of the above required flow paths shall be demonstrated OPERABLE:

a. By 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 in accordance with the Surveillance Frequency Control Program.

b. By verifying that each automatic valve in the flow path actuates to its correct position on an SIAS test signal in accordance with the Surveillance Frequency Control Program.

These are restated and relocated to TS SR 4.4.3.2 as follows:

4.4.3.2.3 By verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in

Enclosure to W3F1-2021-0017 Page 4 of 7 position, is in its correct position in accordance with the Surveillance Frequency Control Program.

4.4.3.2.4 By verifying that each automatic valve in the flow path actuates to its correct position on an SIAS test signal in accordance with the Surveillance Frequency Control Program.

The current TS SR 4.1.2.4 is relocated verbatim to TS SR 4.4.3.2 as follows:

4.4.3.2.5 Each required charging pump shall be demonstrated OPERABLE by verifying that each charging pump starts in response to an SIAS test signal in accordance with the Surveillance Frequency Control Program.

The current TS SR 4.1.2.6 is relocated verbatim to TS SR 4.4.3.2 as follows:

4.4.3.2.6 Each required boric acid makeup pump shall be demonstrated OPERABLE by verifying that each boric acid makeup pump starts in response to an SIAS test signal in accordance with the Surveillance Frequency Control Program.

The current TS SR 4.1.2.8.b.2 is relocated verbatim to TS SR 4.4.3.2 as follows:

4.4.3.2.7 Verify boric acid makeup tank water volume in accordance with the Surveillance Frequency Control Program.

The current TS SR 4.1.2.8.a states:

4.1.2.8 Each borated water source shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by verifying the boric acid makeup tank solution temperature is greater than or equal to 60 °F when the Reactor Auxiliary Building air temperature is less than 55 °F.

This is restated and relocated to TS SR 4.4.3.2 as follows:

4.4.3.2.8 By verifying the boric acid makeup tank solution temperature is greater than or equal to 60 °F when the Reactor Auxiliary Building air temperature is less than 55 °F in accordance with the Surveillance Frequency Control Program.

The TS 3.4.3.2 LCO applicability is Operational Modes 1, 2, and 3. The Auxiliary Pressurizer Spray safety function is to provide auxiliary spray during an SGTR event, in order to depressurize the RCS to 1000 psia. The addition of flow path component requirements to TS 3.4.3.2 does not change the specified safety function, and thus the modes of applicability remain unchanged. The verification that each required component actuates in response to a safety injection actuation system test signal is appropriate because these engineered safety features actuate to mitigate the steam generator tube rupture event.

Enclosure to W3F1-2021-0017 Page 5 of 7

2. Technical Evaluation 2.1 System Design and Operation The Auxiliary Pressurizer Spray system is used to depressurize the reactor coolant system by injecting water, via the charging pumps, into the pressurizer steam space. In order to initiate Auxiliary Pressurizer Spray flow, the operator closes the charging loop isolation valves and opens the auxiliary spray valves. This redirects the charging flow that would normally enter the reactor coolant system into the pressurizer steam space; and, by adjusting the number of charging pumps that are operating, the operator can control the rate of reactor coolant system depressurization.

2.2 Current Licensing Basis and Evaluation The Waterford 3 UFSAR Section 15.6.3.2, "Steam Generator Tube Rupture," states that the sequence of events uses the Charging System as the water supply for the Auxiliary Pressurizer Spray system (i.e., as described in Reference 3). The Auxiliary Pressurizer Spray system is used to depressurize the reactor coolant system to regain pressurizer level control and lower steam generator tube leakage. The Auxiliary Pressurizer Spray system is a mitigation system and is controlled by current TS 3.4.3.2, "Auxiliary Spray." Several support functions are required to enable the Auxiliary Pressurizer Spray to accomplish its safety function. The Auxiliary Pressurizer Spray system information provided in Reference 3 is consistent with Waterford 3 license amendment 22 (Reference 4), which added the Auxiliary Spray TS. This proposed change relocates Auxiliary Pressurizer Spray support equipment requirements from TS 3.1.2 to TS 3.4.3.2 such that the Auxiliary Pressurizer Spray support functions are retained in the TS.

Proposed TS 3.4.3.2.e establishes a minimum volume requirement for the BAMT of 58%, which equates to 6875 gallons. This value is consistent with the requirement in current TS Table 3.1-1, which is proposed for deletion and is based on the reactivity control function of the BAMT.

From an accident mitigation perspective, the BAMT is needed at the immediate start of the SGTR event, in order to ensure there is no delay in starting depressurization. Once the BAMT is depleted, the charging suction may be manually realigned from the control room to the refuel water storage pool (RWSP). Current TS 3/4.5.4 establishes the requirements for the RWSP.

The proposed TS 3.4.3.2.e volume requirement for the BAMT of 58% (i.e., 6875 gallons which corresponds to the minimum volume requirement in TS Table 3.1-1) bounds the required volume of 2612 gallons that is necessary to support the Auxiliary Pressurizer Spray system following a steam generator tube rupture event (i.e., the minimum required Auxiliary Pressurizer Spray water volume required to go from full power pressure to shutdown cooling pressure).

3. Regulatory Evaluation 3.1 Applicable Regulatory Requirements/Criteria The following regulation is applicable to the proposed change.

Enclosure to W3F1-2021-0017 Page 6 of 7 10 CFR 50.36, "Technical specifications," subparagraph (c)(2)(ii)(C), Criterion 3, requires that a technical specification limiting condition for operation be established for a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The proposed change ensures that the Auxiliary Pressurizer Spray system will complete its safety function during the applicable design basis accident.

Therefore, the proposed change does not affect compliance with these regulations or guidance and will ensure that the lowest functional capabilities or performance levels of equipment required for safe operation are met.

3.2 Applicability of Previous No Significant Hazards Consideration The No Significant Hazards Consideration (NSHC) previously submitted in Reference 1 bounds this proposed revision to the Reference 1 license amendment request. The previous NSHC stated that the Boration Systems (i.e., Boric Acid Makeup Tanks (BAMTs), Boric Acid Makeup Pumps (BAMPs), and Charging Pumps), are part of the Chemical Volume Control System (CVCS), which functions to maintain Reactor Coolant System (RCS) inventory and chemistry.

The proposed relocation of the Boration Systems equipment TSs that are required to support the operability of the Auxiliary Pressurizer Spray system to TS 3/4.4.3.2, and relocation of the remaining Boration Systems TSs to the TRM will not alter the functions of the Boration Systems, and will continue to support the safety function of the Auxiliary Pressurizer Spray system. The reactivity control function of the Boration Systems is not required to mitigate any design basis accidents or transients. The proposed relocation of the specified parts of TS 3/4.1.2 to TS 3/4.4.3.2, and the remainder of TS 3/4.1.2 to a licensee-controlled document is not a major change in scope, but rather a conservative clarification to ensure the continued ability of the Auxiliary Pressurizer Spray system to mitigate a design basis accident. Thus, the originally submitted NSHC bounds the proposed relocation in this submittal.

4. Conclusions This submittal does not alter conclusions of the no significant hazards consideration or environmental assessment previously submitted by Entergy in Reference 1. The scope of this change is to relocate the TS 3/4.1.2 support functions for the Auxiliary Pressurizer Spray system specified safety function to TS 3/4.4.3.2.

Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Enclosure to W3F1-2021-0017 Page 7 of 7

5. References

1. Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC),

"License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual," (ADAMS Accession Number ML18264A023), dated September 20, 2019.

2. NRR E-mail capture, U.S. NRC to Entergy, "NRC Request for Additional Information for Waterford LAR to Relocate Boration TSs (EPID L-2019-LLA-0203)," (ADAMS Accession Number ML20168A395), dated June 5, 2020.

3. Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC), "

Response to U. S. Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual (EPID L-2019-LLA-0203)," (ADAMS Accession Number ML20188A364), dated July 6, 2020.

4. U. S. NRC letter to Louisiana Power and Light Company, "Issuance of Amendment No. 22 to Facility Operating License NPF Waterford Steam Electric Station, Unit 3 (TAC No.

62721)," (ADAMS Accession No. ML021750615), dated August 12, 1987.

5. U. S. NRC letter to Louisiana Power and Light Company, "Waterford 3 Auxiliary Pressurizer Spray System" [Forwards Safety Evaluation Regarding Confirmatory Tests of the Auxiliary Pressurizer Spray System], (ADAMS Accession No. 8605080630), dated April 22, 1986.

Enclosure, Attachment 1 W3F1-2021-0017 Revised (Markup) Technical Specification Pages (TS pages)

(11 Pages to Follow) 3/4 1-6 3/4 1-7 3/4 1-8 3/4 1-9 3/4 1-10 3/4 1-11 3/4 1-12 3/4 1-13 3/4 1-14 3/4 1-14a 3/4 4-9a

REACTIVITY CONTROL SYSTEMS 3/4.1.2 BORATION SYSTEMS FLOW PATHS-SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.1 As a minimum, one of the following boron injection flow paths shall be OPERABLE and capable of being powered from an OPERABLE emergency power source:

a. A flow path from the boric acid makeup tank via either a boric acid makeup pump or a gravity feed connection and any charging pump to the Reactor Coolant System if the boric acid makeup tank in Specification 3.1.2. 7a. is OPERABLE, or

b. The flow path from the refueling water storage pool via either a charging pump or a high pressure safety injection pump to the Reactor Coolant System if the refueling water storage pool in Specification 3.1.2.?b. is OPERABLE.

APPLICABILITY: MODES 5 and 6.

ACTION:

With none of the above flow paths OPERABLE or capable of being powered from an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.*

SURVEILLANCE REQUIREMENTS 4.1.2.1 At least one of the above required flow paths shall be demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program by 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.

• Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SHUTDOWN MARGIN.

PAGES 3/4 1-6 THRU 3/4 1-14a ARE NOT USED WATERFORD - UNIT 3 3/4 1-6 AMENDMENT NO. 10, 185, 199, 249

Relocate to new LCO 3.4.3.2.b and new LCO 3.4.3.2.c REACTIVITY CONTROL SYSTEMS FLOW PATHS - OPERATING LIMITING CONDITION FOR OPERATION 3.1.2.2 At least two boron injection flow paths to the RCS via the charging pumps shall be OPERABLE. The following flow paths may be used:

a. With the contents of either boric acid makeup tank in accordance with Figure 3.1-1, the following flow paths shall be OPERABLE:

1. One flow path from an acceptable boric acid makeup tank via its boric acid makeup pump; and

2. One flow path from an acceptable boric acid makeup tank via its gravity feed valve; or

b. With the combined contents of both boric acid makeup tanks in accor dance with Figure 3.1-2, both of the following flow paths shall be OPERABLE:

1. One flow path consisting of both boric acid makeup pumps, and

2. One flow path consisting of both gravity feed valves.

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

ACTION:

With only one of the above required boron injection flow paths to the Reactor Coolant System OPERABLE, restore at least two boron injection flow paths to the Reactor Coolant System 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 and borated to a SHUTDOWN MARGIN equivalent to the requirements of Specification 3.1.1.1 or 3.1.1.2, whichever is applicable, within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore at least two flow paths to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.1.2.2 At least two of the above required flow paths shall be demonstrated OPERABLE:

a. By 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 in accordance with the Surveillance Frequency Control Program.

b. By verifying that each automatic valve in the flow path actuates to its correct position on an SIAS test signal in accordance with the Surveillance Frequency Control Program.

c. By verifying that the flow path required by Specification 3.1.2.2a.1 and 3.1.2.2a.2 delivers at least 40 gpm to the Reactor Coolant System in accordance with the Surveillance Frequency Control Program.

Relocate to new SR 4.4.3.2.3 and new SR 4.4.3.2.4 WATERFORD - UNIT 3 3/4 1-7 AMENDMENT NO. 10, 199, 249

REACTIVITY CONTROL SYSTEMS CHARGING PUMPS - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.3 At least one charging pump or one high pressure safety injection pump in the boron injection flow path required OPERABLE pursuant to Specification 3.1.2.1 shall be OPERABLE and capable of being powered from an OPERABLE emergency power source.

APPLICABILITY: MODES 5 and 6.

ACTION:

With no charging pump or high pressure safety injection pump OPERABLE or capable of being powered from an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.*

SURVEILLANCE REQUIREMENTS 4.1.2.3 No additional Surveillance Requirements other than those required by the INSERVICE TESTING PROGRAM.

• Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SHUTDOWN MARGIN.

WATERFORD - UNIT 3 3/4 1-8 AMENDMENT NO. 185, 189,250

Relocate to new LCO 3.4.3.2.d REACTIVITY CONTROL SYSTEMS CHARGING PUMPS - OPERATING LIMITING CONDITION FOR OPERATION 3 .1.2.4 At least two independent charging pumps shall be OPERABLE.

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

ACTION:

With only one charging pump OPERABLE, restore at least two charging 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 and borated to a SHUTDOWN MARGIN equivalent to the requirements of Specification 3.1. 1.1 or 3.1.1.2, whichever is applicable, within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore at least two charging pumps to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.1.2.4 Each required charging pump shall be demonstrated OPERABLE by verifying that each charging pump starts in response to an SIAS test signal in accordance with the Surveillance Frequency C ontrol Program.

Relocate to new SR 4.4.3.2.5 WATERFORD- UNIT 3 3/4 1-9 AMENDMENT NO. 44,249

REACTIVITY CONTROL SYSTEMS BORIC ACID MAKEUP PUMPS - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.5 At least one boric acid makeup pump shall be OPERABLE and capable of being powered from an OPERABLE emergency bus if only the flow path through the boric acid pump in Specification 3.1.2.1a. is OPERABLE.

APPLICABILITY: MODES 5 and 6.

ACTION:

With no boric acid makeup pump OPERABLE as required to complete the flow path of Specification 3.1.2.1a.,suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

• SURVEILLANCE REQUIREMENTS 4.1.2.5 No additional Surveillance Requirements other than those required by the INSERVICE TESTING PROGRAM.

• Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SHUTDOWN MARGIN.

WATERFORD - UNIT 3 3/4 1-10 AMENDMENT NO. 185,189,250

REACTIVITY CONTROL SYSTEMS BORIC ACID MAKEUP PUMPS-OPERATING LIMITING CONDITION FOR OPERATION 3.1.2.6 At least the boric acid makeup pump(s) in the boron injection flow path(s) required OPERABLE pursuant to Specification 3.1.2.2a. shall be OPERABLE and capable of being powered from an OPERABLE emergency bus if the flow path through the boric acid pump(s) in Specification 3.1.2.2a. is OPERABLE.

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

ACTION:

With one boric acid makeup pump required for the boron injection flow path(s) pursuant to Specification 3.1.2.2a. inoperable, restore the boric acid makeup pump to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and borated to a SHUTDOWN MARGIN equivalent to the require ments of Specification 3.1.1.1 or 3.1.1.2, whichever is applicable, restore the above required boric acid makeup pump(s) to OPERABLE status within the next 7.days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.1.2.6 Each required boric acid makeup pump shall be demonstrated OPERABLE by verifying that each boric acid makeup pump starts in response to an SIAS test signal in accordance with the Surveillance Frequency Control Program.

Relocate to new SR 4.4.3.2.6 WATERFORD - UNIT 3 3/4 1-11 AMENDMENT NO. 44,249

REACTIVITY CONTROL SYSTEMS BORATED WATER SOURCES SHUTDOWN LIMIT ING CONDITION FOR OPE R ATION 3.1.2.7 As a minimum, one of the following borated water sources shall be OPERABLE:

a. One boric acid makeup tank with a boron concentration between 4900 ppm and 6125 ppm and a minimum borated water volume of 36% indicated level.

b. The refueling water storage pool (RWSP) with:

1. A minimum contained borated water volume of 12% indicated level, and

2. A minimum boron concentration of 2050 ppm.

APPLICABILITY: MODES 5 and 6.

ACTION:

With no borated water sources OPERABLE, suspend all operations involving CORE AL TERATIONS or positive reactivity changes.

• SU RVEILLANCE REQUIREMENTS 4.1.2.7 The above required borated water source shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program when the Reactor Auxiliary Building air temperature is less than 55 c F by verifying the boric acid makeup tank solution is greater than or equal to 60 c F (when it is the source of borated water).

b. In accordance with the Surveillance Frequency Control Program by:

1. Verifying the boron concentration of the water, and

3. Verifying the contained borated water volume of the tank.

• Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SHUTDOWN MARGIN.

WATERFORD- UNIT 3 3/4 1-12 AMENDMENT NO. 10,129,185,199,249

REACTIVITY CONTROL SYSTEMS BORA TED WATER SOURCES - OPERATING LIMITIN G CONDITION FOR OPERATION 3.1.2.8 E ach of the following borated water sources shall be OPERABLE:

a. At least one of the following sources:

Relocate to new LCO 1) One boric acid makeup tank, with the tank contents in accordance with Figure 3.1-1, or a minimum water volume of 58% indicated level.

3.4.3.2.e

2) Two boric acid makeup tanks, with the combined contents of the tanks in accordance with Figure 3.1-2, and

b. The refueling water storage pool in accordance with Specification 3.5.4.

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

ACTION:

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

b. With the refueling water storage pool inoperable, restore the pool to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

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

Relocate a. In accordance with the Surveillance Frequency Control Program bBy verifying the to new SR boric acid makeup tank solution temperature is greater than or equal to 60 ° F 4.4.3.2.8 when the Reactor Auxiliary Building air temperature is less than 55 °F in accordance with the Surveillance Frequency Control Program.

b. In accordance with the Surveillance Frequency Control Program by:

Relocate to

1. Verifying the boron concentration in the water, and new SR 4.4.3.2.7

2. Verifying the contained boratedic acid makeup tank water volume of the water source. in accordance with the Surveillance Frequency Control Program.

WATERFORD - UNIT 3 3/4 1-13 AMENDMENT NO. 10, 19, 129, 147,199,249

REQUIRED STORED BORIC ACID VOLUME AS A FUNCTION OF CONCENTRATION (VOLUME OF ONE BAMT) 11500 (96%)

11000 (92%)

10500 (87%)

' 10000 z

0

( < (82%)

La X 9500 n w 0 j

> w (78%)

g i 9000 a (73%)

L3O 4 C 8500 a (69%)

8000 (64%)

7500 (60%)

7000 (55%)

6500L 4800 BORIC ACID CONCENTRATION, ppm FIGURE 3.1-1 I

WATERFORD - UNIT 3 314 1-14 AMENDMENT NO. 40,45,141,-47 I 199

REQUIRED STORED BORIC ACID VOLUME AS A FUNCTION OF CONCENTRATION (COMBINED VOLUME OF TWO BAMT) 12500 12300 (100%) REGION OF ACCEPTABLE 12000 OPERATION (96%)

I 11500 1 iiiI I 1

\ \1 1 > RW5P at 2050ppml p (91%) _ XiL \ ><I RWSP at 2300 ppml__

11000 ZO On m (n.. N j/ I RWSP at2600 p

<ui 0 (87%)

C z X "'1 SP at/290 10500 \ X \s- A Rn - .

\ i>

(82%)

10000 LY0<

(77%)

jmu z 9500

\

(73%)

nnnn YuuU

/

(68%)

8500

-i - I I REGION OF UNACCEPTABLE (64%) I OPERATION 8000 I I I I I (59%)

__ _ _ _ t 7500 41BOO 4900 5000 5200 5400 5600 5800 6000 6125 6200 BORIC ACID CONCENTRATION, ppm FIGURE 3.1-2 I WATERFORD - UNIT 3 3/4 1-14a AMENDMENT NO. 199

PRESSURIZER a. Both auxiliary pressurizer spray valves

b. One flow path from an acceptable boric acid makeup tank via its boric acid makeup pump pressurizer c. One flow path from an acceptable boric acid makeup tank via its gravity feed valve REACTOR COOLANT SYSTEM d. At least two independent charging pumps

e. One boric acid makeup tank with a minimum water volume of 58%

AUXILIARY SPRAY indicated level.

LIMITING CONDITION FOR OPERATION 3.4.3.2 Both auxiliary spray valves shall be OPERABLE. consisting of the following:

APPLICABILITY: MODES 1, 2 and 3.

pressurizer trains trains ACTION: Two

a. With only one of the above required auxiliary spray valves OPERABLE, restore both valves to OPERABLE status within 30 days or be in HOT trains 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 />. train pressurizer trains

b. With none of the above required auxiliary spray valves OPERABLE, restore at least one valve to OPERABLE status within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 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 />.

s SURVEILLANCE REQUIREMENTS 4.4.3.2.1 The auxiliary spray valve shall be verified to have power available to each valve in accordance with the Surveillance Frequency Control Program.

4.4.3.2.2 The auxiliary spray valves shall be cycled in accordance with the Surveillance Frequency Control Program.

4.4.3.2.3 By 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 in accordance with the Surveillance Frequency Control Program.

4.4.3.2.4 By verifying that each automatic valve in the flow path actuates to its correct position on an SIAS test signal in accordance with the Surveillance Frequency Control Program.

4.4.3.2.5 Each required charging pump shall be demonstrated OPERABLE by verifying that each charging pump starts in response to an SIAS test signal in accordance with the Surveillance Frequency Control Program.

4.4.3.2.6 Each required boric acid makeup pump shall be demonstrated OPERABLE by verifying that each boric acid makeup pump starts in response to an SIAS test signal in accordance with the Surveillance Frequency Control Program.

4.4.3.2.7 Verify boric acid makeup tank water volume in accordance with the Surveillance Frequency Control Program.

4.4.3.2.8 By verifying the boric acid Makeup tank solution temperature is greater than or equal to 60 °F when the Reactor Auxiliary Building air temperature is less than 55 °F in accordance with the WATERFORD - UNIT 3Control Program.

Surveillance Frequency 3/4 4-9a Amendment No. 2-2-, 249

Enclosure, Attachment 2 W3F1-2021-0017 Revised (Clean) Technical Specification Pages (TS pages)

(2 Pages to Follow) 3/4 4-9a 3/4 4-9b

REACTOR COOLANT SYSTEM AUXILIARY PRESSURIZER SPRAY LIMITING CONDITION FOR OPERATION 3.4.3.2 Two auxiliary pressurizer spray trains shall be OPERABLE consisting of the following:

a. Both auxiliary pressurizer spray valves

b. One flow path from an acceptable boric acid makeup tank via its boric acid makeup pump

c. One flow path from an acceptable boric acid makeup tank via its gravity feed valve

d. At least two independent charging pumps

e. One boric acid makeup tank with a minimum water volume of 58% indicated level.

APPLICABILITY: MODES 1, 2 and 3.

ACTION:

a. With only one of the above required auxiliary pressurizer spray trains OPERABLE, restore both trains to OPERABLE status within 30 days or be in 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 none of the above required auxiliary pressurizer spray trains OPERABLE, restore at least train to OPERABLE status within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 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 />.

SURVEILLANCE REQUIREMENTS 4.4.3.2.1 The auxiliary spray valves shall be verified to have power available to each valve in accordance with the Surveillance Frequency Control Program.

4.4.3.2.2 The auxiliary spray valves shall be cycled in accordance with the Surveillance Frequency Control Program.

4.4.3.2.3 By 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 in accordance with the Surveillance Frequency Control Program.

4.4.3.2.4 By verifying that each automatic valve in the flow path actuates to its correct position on an SIAS test signal in accordance with the Surveillance Frequency Control Program.

4.4.3.2.5 Each required charging pump shall be demonstrated OPERABLE by verifying that each charging pump starts in response to an SIAS test signal in accordance with the Surveillance Frequency Control Program.

4.4.3.2.6 Each required boric acid makeup pump shall be demonstrated OPERABLE by verifying that each boric acid makeup pump starts in response to an SIAS test signal in accordance with the Surveillance Frequency Control Program.

4.4.3.2.7 Verify boric acid makeup tank water volume in accordance with the Surveillance Frequency Control Program.

WATERFORD - UNIT 3 3/4 4-9a Amendment No. 22, 249

REACTOR COOLANT SYSTEM 

6859(,//$1&(5(48,5(0(176 &RQWLQXHG 4.4.3.2.8 By verifying the boric acid makeup tank solution temperature is greater than or equal to 60 °F when the Reactor Auxiliary Building air temperature is less than 55 °F in accordance with the Surveillance Frequency Control Program.

WATERFORD - UNIT 3 3/4 4-9E Amendment No.

Enclosure, Attachment 3 W3F1-2021-0017 Revised (Markup) Technical Specification Bases Pages (For Information Only)

(TS Bases page)

(1 Page to Follow)

B 3/4 4-2

REACTOR COOLANT SYSTEM BASES SAFETY VALVES (Continued) valves are OPERABLE, an operating shutdown cooling loop, connected to the RCS, provides overpressure relief capability and will prevent RCS overpressurization. In addition, the overpressure protection system provides a diverse means of protection against RCS overpressurization at low temperatures.

During operation, all pressurizer code safety valves must be OPERABLE to prevent the RCS from being pressurized above its safety limit of 2750 psia. The combined relief capacity of these valves is sufficient to limit the system pressure to within its Safety Limit of 2750 psia following a complete loss of turbine generator load while operating at RATED THERMAL POWER and assuming no reactor trip until the first Reactor Protective System trip setpoint (Pressurizer Pressure-High) is reached and also assuming no operation of the steam dump valves.

Demonstration of the safety valves= lift settings will occur only during reactor shutdown and will be performed in accordance with the provisions of Section XI of the ASME Boiler and Pressure Vessel Code.

3/4.4.3 PRESSURIZER An OPERABLE pressurizer provides pressure control for the Reactor Coolant System during operations with both forced reactor coolant flow and with natural circulation flow. The minimum water level in the pressurizer assures the pressurizer heaters, which are required to achieve and maintain pressure control, remain covered with water to prevent failure, which could occur if the heaters were energized while uncovered. The maximum water level in the pressurizer ensures that this parameter is maintained within the envelope of operation assumed in the safety analysis. The maximum water level also ensures that the RCS is not a hydraulically solid system and that a steam bubble will be provided to accommodate pressure surges during operation. The steam bubble also protects the pressurizer code safety valves against water relief. The requirement to verify that on an SIAS test signal the pressurizer heaters are automatically shed from the emergency power sources is to ensure that the non-Class 1E heaters do not reduce the reliability of or overload the emergency power source. The requirement that a minimum number of pressurizer heaters be OPERABLE enhances the capability to control Reactor Coolant System pressure and establish and maintain natural circulation.

The auxiliary pressurizer spray is used to depressurize the RCS by cooling the pressurizer steam space. The auxiliary pressurizer spray is used during those periods when normal pressurizer spray is not available, such as the later stages of a normal RCS cooldown. The auxiliary pressurizer spray also distributes boron to the pressurizer when normal pressurizer spray is not available.

The auxiliary pressurizer spray is used, in conjunction with the of the HPSI pumps, during the recovery from a steam generator tube rupture accident. The auxiliary pressurizer spray is also used during a natural circulation cooldown as a safety related means of RCS depressurization to achieve shutdown cooling system initiation conditions and subsequent COLD SHUTDOWN per the requirements of Branch Technical Position (RSB) 5-1.

º(DRN 06-916, Ch. 48)

>>(DRN 06-916, Ch. 48)

(LBDCR 16-046, Ch. 86)

Each train The ofSurveillance the auxiliaryFrequency pressurizer spray system is controlled underconsists of a water the Surveillance supply Control Frequency through either the boric acid Program. makeup pump or the gravity feed valve to the charging pumps and then through the pressurizer spray valves. Each train is required to be operable to support the auxiliary spray

ç(LBDCR 16-046, Ch. 86) safety function.

(DRN Action A is the loss of one train, the remaining train may consist of multiple train 04-1223, Ch. 33) components provided auxiliary pressurizer flow can still be achieved (e.g. boric acid makeup tank B through the boric acid makeup pumps to charging pump A then discharging through auxiliary spray valve B). The loss of both trains or the loss of the water source would require entry into WATERFORD Action B. - UNIT 3 B 3/4 4-2 AMENDMENT NO. 22 CHANGE NO. 48, 86