ML20211H054

Proposed Tech Specs Raising Emergency Feedwater Initiation Low Level Setpoint from 30% Wide Range Level to 36.3% & Increasing Calibr Frequency for Control Room Chlorine Detection Sys

ML20211H054
Person / Time
Site:	Waterford
Issue date:	02/23/1987
From:	LOUISIANA POWER & LIGHT CO.
To:
Shared Package
ML20211G999	List: ML20211H054 W3P87-0537, Application for Amends to License NPF-38,raising Emergency Feedwater Initiation Low Level Setpoint from 30% Wide Range Level to 36.3% & Increasing Calibr Frequency for Control Room Chlorine Detection Sys.Fee Paid
References
NUDOCS 8702260053
Download: ML20211H054 (40)

Text

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NPF-38-53 ATTACHMENT A 8702260053 870223 PDR ADOCK 0500 2

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TABLE 3.3-4 (Continued)

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP' VALUES i

5 ALLOWABLE 5

FUNCTIONAL UNIT

. TRIP VALUE VA,' UES i

5.

SAFETY INJECTION SYSTEM SUMP RECIRCULATION (RAS) g i

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a.

Manual RAS (Trip Buttons)

Not Applicable Not Applicable b.

Refueling Water Storage Pool - Low 10.0% (57,967 gallons) 9.3% (53,910 gallons) c.

Automatic Actuation Logic Not Applicable Not Applicable 6.

LOSS OF POWER a.

4.16 kV Emergency Bus Undervoltage

> 3245 volts

> 3245 volts (Loss of Voltage) b.

480 V Emergency Bus Undervoltage

> 372 volts

> 354 volts w

c.

4.16 kV Emergency Bus Undervoltage 2

(Degraded Voltage)

> 3640 volts

> 3604 volts

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7.

EMERGENCY FEEDWATER (EFAS) a.

Manual (Trip Buttons)

Not Applicable Not Applicable b.

Steam Generator (1&2) Level - Low

> 27.4%(3) (4)

> 26.7%(3) (4) i i

c.

Steam Generator AP - High (SG-1 > SG-2) 1 127.6 psid 1 136.6 psid i

d.

Steam Generator AP - High (SG-2 > SG-1) 1 127.6 psid 1 136.6 psid e.

Steam Generator (1&2) Pressure - Low

> 764 psia (2)

> 748 psia (2) i f.

Automatic Actuation Lo,gic Not Applicable Not Applicable

3) (5) g.

Control Valve Logic (Wide Range

> 30.0%(3) (5)

> 29.0%((3) (5) (6)

SG Level - Low)

[36.3%(3)(5)(6) 35.3%

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,gg TABLE 3.3-4 (Continued)

~n y gj TABLE NOTATIONS (1) Value may be decreased manually, to a minimum of 100 psia, as pressurizer pressure is reduced, provided the margin between the pressurizer and this value is maintained at less than or equal to 400 psi; the setpoint shall be increased automatically as pressurizer pressure is increased until the trip setpoint is reached.

Trip may be manually bypassed below 400 psia; bypass shall be automatically removed whenever pressurizer is greater than or equal.to 500 psia.

(2) Value may be decreased manually as steam generator pressure is reduced, provided the margin between the steam generator pressure and this value is maintained at less than or equal to 200 psi; the setpoint shall be increased automatically as steam generator pressure is increased until the trip setpoint is reached.

(3) % of this distance between steam generator upper and lower level instrument nozzles.

(4) Requires corresponding permissive trip signal of item 7.c., 7.d., or 7.e.

to actuate EFAS.

(5) Requires corresponding EFAS trip to actuate control valves.

(6) With SIAS trip signal present.

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WATERFORD - UNIT 3 3/4 3-21 i

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s NPF-38-53 ATTACHMENT B l

TABLE 3.3-4 (Crntinued)

ENGINEERED SAFETY FEATURES ACTUATION SYSIEM INSTRUMENTATION TRIP VA 9

ALLOWABLE VALUES._

5 TRIP VALUE E

FUNCTIONAL UNIT SAFETY INJECTION SYSTEM SUMP RECIRCULATION (RAS) l S.

Manual RAS (Trip Buttons)

Not Applicable Not Appifcable

[

10.0% (57,967 gallons) 9.3% (53,910 gallons) a.

b.

Refueling Water Storage Pool - Low Automatic Actuation Logic Not Applicable Not Applicable c.

6.

LOSS OF POWER

> 3245 volts l

> 3245 volts 4.16 kV Emergency Bus Undervoltage a.

(Loss of Voltage)

> 354 volts

> 372 volts b.

480 V Emergency Bus Undervoltage 4.16 kV Emergency Bus Undervoltage

> 3604 volts c.

> 3640 volts w1 (0egraded Voltage)

[

7.

EMERGENCY FEEDWATER (EFAS)

Not Applicable Not Applicable Manual (Trip Buttons)

> 27.4%(3) (4)

> 26.7%(3) (4) a.

b.

Steam Generator (1&2) Level - Low 5 136.6 psid Steam Generator AP - High (SG-1 > SG-2) 5 127.6 psid 5 136.6 psid c.

Steam Generator AP - High (SG-2 > SG-1) i 127.6 psid

> 764 psia ( )

> 748 psia ( )

d.

Steam Generator (1&2) Pressure - Low e.

f.

Automatic Actuation Logic Not Applicable Not Applicable

,,,in 3 ^. ^T " ' ' " '

> is.ud(3) (5) m,,,

Control Valve Logic (Wide Range

[ 36.3%(3) (5) W 35.3%

g.

SG Level - Low) t, h

TABLE 3.3-4 (Continued)

TABLE NOTATIONS q.,,,

(1) Value may be decreased manually, to a minimum of 100 psia, as pressurizer pressure is reduced, provided the margin between the pressurizer and this value is maintained at less than or equal to 400 psi; the setpoint shall be increased automatically as pressurizer pressure is increased until the trip setpoint is reached.

Trip may be manually bypassed below 400 psia; bypass shall be automatically removed whenever pressurizer is greater than or equal to 500 psia.

(2) Value may be decreased manually as steam generator pressure is reduced, provided the margin between the steam generator pressure and this value is maintained at less than or equal to 200 psi; the setpoint shall be increased automatically as steam generator pressure is increased until the trip setpoint is reached.

(3) % of this distance between steam generator upper and lower level instrument nozzles.

(4) Requires corresponding permissive trip signal of item 7.c., 7.d., or 7.e.

to actuate EFAS.

(5) Requires corresponding EFAS trip to actuate control valves.

(5) Yith SIfi ti,e e-;gne; preem t.

WATERFORD - UNIT 3 3/4 3-21

i NPF-38-54 I

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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-54 This is a request to revise Technical Specification 4.3.3.7.1, Chlorine Detection System, for Waterford Steam Electric Station Unit 3.

Existing Specification See Attachment A.

Proposed Specification See Attachment B.

Description This change is requested as a result of a modification to the chlorine detection system.

As discussed with the NRC, the system originally installed that provided detection during the first cycle has proven to be unreliable.

As a result, a station modification was implemented to install a new, more reliable chlorine detection system to replace the Cycle 1 system.

The new system is a different design and therefore reflects a different channel calibration requirement based on the manufacturer's recommendation and test experience.

The new system requires calibration as frequently as the functional testing for the old system.

The proposed change requires a CHANNEL CALIBRATION at least once per 31 days in contrast to the existing requirement for calibration every 18 months.

The redundant requirement for a separate CHANNEL FUNCTIONAL TEST every 31 days has been deleted because, by Technical Specification definition 1.4, the CHANNEL CALIBRATION must include a CHANNEL FUNCTIONAL TEST.

Safety Analysis The proposed change above shall be deemed to involve a significant hazards consideration if there is a positive finding in any one of the following areas:

1.

Will the operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?

Response

No.

The calibration frequency requirement is based on the manufacturer's recommendation.

This recommendation is made to achieve at least the same level of reliability and accuracy as that established for the old j'

chlorine detection system.

Therefore, there will be no increase in the probability or consequences of any accident previously evaluated.

I i

i 2.

Will operation of the facility in accordance with the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response

No.

The proposed change in the channel calibration requirement is based on the manufacturer's recommendation and testing experience.

This frequency will achieve at least the accuracy and reliability of the previously installed detection system; therefore, this change will not create any new failure or accident paths, and the possibility of a new or different kind of accident from any accident previously evaluated can not be created.

3.

Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Response

No.

The manufacturer's recommendations assure that a channel calibration frequency of 31 days establishes at least the same level of safety as that existing in the present Technical Specification.

This calibration also establishes functionality of the system at least as often as the present Technical Specification does.

Therefore, the operation of Waterford 3 in accordance with this proposed change will not involve a significant reduction in a margin of safety.

Safety and Significant Hazards Determination Based upon the above Safety Analysis, it is concluded that (1) the proposed change does not constitute a significant hazards consideration as defined by 10 CFR 50.92; (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change, and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

O 9

e NPF-38-54 ATTACHMENT A i

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INSTRIN NTATION CHEMICAL DETECTION SYSTEMS CHLORINE DETECTION SYSTEM LIMITING CONDITION FOR OPERATION 3.3.3.7.1 Two independent chlorine detection systems, with their alare/ trip setpoints adjusted to actuate at a chlorine concentration of less than or equal to 3 ppe, shall be OPERA 8LE.

APPLICABILITY: All MODES.

ACTION:

l With one chlorine detection system inoperable, restore the a.

inoperable detection system to OPERA 8LE status within 7 days or within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> initiate and maintain operation of the control room ventilation system in the recirculation mode of j

operation.

b.

With no chlorine detection system OPERA 8LE, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate and maintain operation of the control room ventilation system in the recirculation mode of operation.

The provisions of Specification 3.0.4 are not applicable.

c.

1 SURVEILLANCE REQUIREMENTS 4.3.3.7.1 Each chlorine detection system shall be demonstrated OPERA 8LE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a CHANNEL j

FUNCTIONAL TEST at least once per 31 days and a CHANNEL CALIBRATION at least j

once per 18 months.

l WATERFORD - UNIT 3 3/4 3-47

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INSTRLSENTATION CHEMICAL DETECTION SYSTEMS CHLORINE DETECTION SYSTEM LIMITING CONDITION FOR OPERATION 3.3.3.7.1 Two independent chlorine detection systems, with their alam/ trip setpoints adjusted to actuate at a chlorine concentration of less than or equal to 3 ppa, shall be OPERA 8LE.

APPLICA81LITY: All M00ES.

ACTION:

With one chlorine detection system inoperable, restore the a.

inoperable detection system to OPERA 8LE status within 7 days or within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> initiate and maintain operation of the control room ventilation system in the recirculation mode of operation.

b.

With no chlorine detection system OPERA 8LE, within i hour initiate and maintain operation of the control roce ventilation system in the recirculation mode of operation.

The provisions of Specification 3.0.4 are not appifcable.

c.

SURVEILLANCE REQUIREMENTS 4.3.3.7.1 Each chlorine detection system shall be demonstrated OPERA 8LE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a CHANNEL CALI8dd d

gig {T{at least once per 31 days.rf : C.".'_C L C"L!"".".TI^"

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WATERFORD - UNIT 3 3/4 3-47

NPF-38-55 I

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NS20598

DESCRIPTION AND SAFETY-ANALYSIS OF PROPOSED CHANGE NPF-38-55 This is a request to revise Technical Specifications 3.1.2.8, " Borated Water Sources - Operating" and 3.5.4, " Refueling Water Storage Pool".

Existing Specification See Attachment A Proposed Specification See Attachment B Description i

The proposed change would revise Technical Specifications 3.1.2.8b.1, " Borated Water Sources - Operating" and 3.5.4a, " Refueling Water Storage Pool".

The reason for the change is to modify the percent indicated level of the Refueling Water Storage Pool (RWSP) that corresponds to the minimum required water volume of 475,000 gallons. The current Technical Specifications refer to 82% as being equal to the required volume; however, calculations have shown that, in order to maintain the required 475,500 gallons in the RWSP, the indicated level must be equal to 82.4%.

The proposed change, therefore, would conservatively "round-up" the required level to 83% instead of " rounding-off" to 82%.

It should be noted that when this potential non-conservatism was discovered, plant records were checked and it was verified that the actual level in the RWSP never fell below 83%.

Safety Analysis The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:

1.

Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident?

Response

No The proposed change to these Technical Specifications is strictly administrative in nature and does not affect the manner in which the plant is operated.

The change is being proposed to correct a potential non-conservatism in the percent indicated level that corresponds to the minimum required volume that must be maintained in the RWSP.

The reason for maintaining a minimum volume of borated water in the RWSP is to ensure that the available supply of water to the Emergency Core Cooling System (ECCS) is consistent with the assumptions used in the large break loss of coolant accident (LOCA) presented in the FSAR.

Since the proposed change NS20598 vp r--

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increases the required level that must be maintained in the RWSP (and hence increases the required volume), there will be no affect on the LOCA analysis as described in Chapters 6 and 15 of the FSAR.

Therefore, the proposed change will not involve a significant increase in the probability or consequences of any accident.

2.

Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response

No The proposed change will ensure the indicated level of the RWSP is consistent with the volume requirement that was determined by the Safety Analysis.

There has been no physical change to plant systems, structures or components.

The only change to plant procedures will be to require an increased RWSP level when performing routine surveillance tests.

Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Will operation of the facility in accordance witn this proposed change involve a significant reduction in a margin of safety?

Response

No The intent of these specifications is to ensure that a sufficient supply of borated water is available for injection by the ECCS in the event of a LOCA.

The minimum RWSP volume requirement ensures that sufficient water will be available inside the containment to permit recirculation through the safety injection pumps and back into the core.

This minimum volume requirement also includes an allowance for water not usable because of RWSP discharge line location and other physical characteristics.

Since the proposed change simply updates the RWSP level that corresponds to this minimum volume requirement, it will not involve a significant reduction in the margin of safety.

The Commission has provided guidance concerning the application of standards for determining whether a significant hazards consideration exists by providing l

certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazards consideration.

Example (ii) relates to a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications, (e.g., a more stringent surveillance requirement).

In this case the proposed change is similar to Example (ii) in that it requires the RWSP to be maintained at an increased level.

NS20598

(

Safety and Significant Hazards Consideration Based on the above Safety Analysis, it is concluded'that:

(1) the proposed change does not constitute a significant hazards consideration as defined in

'10CFR50.92; (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

NS20598

I NPF-38-55 ATTACHMENT A NS20598

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REACTIVITY CONTROL SYSTEMS BORATED WATER SOURCES - OPERATING LIMITING CONDITION FOR OPERATION 3.1.2.8 Each of the following borated water sources shall be OPERABLE:

a.

At least one of the following sources:

1)

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

Two boric acid makeup tanks, with the combined contents of

.the tanks in accordance with Figure 3.1-1, and b.

The refueling water storage pool with:

1.

A minimum contained borated water volume of 475,500 gallons (82% of indicated level), and 2.

A boron concentration of between 1720 and 2300 ppm of boron, and 3.

A solution temperature between 55 F and 100*F.

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

ACTION:

With the above required boric acid makeup tank (s) inoperable, restore a.

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 SHUTOOWN 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 SHUTOOWN 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 l

l 4.1.2.8 Each borated water source shall be demonstrated OPERABLE:

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

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

b.

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

c.

At least once per 7 days by:

1.

Verifying the boron concentration in the water, and 2.

Verifying the contained barated water volume of the water source.

WATERFORD - UNIT 3 3/4 1-14 AMEN 0 MENT NO. 10

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

a.

A minimum contained borated water volume of 475,500 gallons (82%

indicated level),

b.

Between 1720 and 2300 ppa of boron, and c.

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

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTION:

With the refueling water storage pool inoperable, restore the pool to OPERABLE status within 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 4.5.4 The RWSP shall be demonstrated OPERABLE:

a.

At least once per 7 days by:

1.-

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

Verifying the baron concentration of the water.

b.

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

WATERFORD - UNIT 3 3/4 5-9

NPF-38-55 ATTACHMENT B 1

NS20598

REACTIVITY CONTROL SYSTEMS BORATED WATER SOURCES - OPERATING x

LIMITING CONDITION FOR OPERATION

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3.1.2.8 Each of the following borated water sources shall be OPERABLE:

a.

At le.tst one of the following sources:

1)

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

Two boric acid makeup tanks, with the combined contents of

.the tanks in accordance with Figure 3.1-1, and b.

The refueling water storage pool with:

1.

A minimum contained borated water volume of 475,500 gallons

.l' ;

g A of indicated level), and 2.

A boron concentration of between 1720 and 2300 ppm of boron, and 3.

A solution temperature between 55 F and 100'f.

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

ACTION:

With the above required boric acid makeup tank (s) inoperable, restore a.

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 STAND 8Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 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 SHUTOOWN 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:

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

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

b.

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

c.

At least once per 7 days by:

1.

Verifying the boron concentration in the water, and 2.

Verifying the contained borated water volume of the water source.

WATERFORD - UNIT 3 3/4 1-14 AMEN 0 MENT NO. 10

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

(v3 %

a.

A minimum contained borated water volume of 475,500 gallons 44GR' j

r indicated level),

b.

Between 1720 and 2300 ppm of boron, and c.

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

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTION:

With the refueling water storage pool inoperable, restore the pool to OPERABLE status within 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 4.5.4 The RWSP shall be demoi.:; rated OPERABLE:

a.

At least once per 7 days by:

1/

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

Verifying the boron concentration of the water.

b.

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

WATERFORD - UNIT 3 3/4 5-9 l

NPF-38-56 I

NS20599

DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-56 This is a request to revise Technical Specification 3.5.1, " Safety Injection Tanks".

Existing Specification See Attachment A Proposed Specification See Attachment B Description The proposed change would revise the note to Technical Specifications 3.5.1,

" Safety Injection Tanks". The note is applicable in Modes 3 and 4 and currently allows the safety injection tank (SIT) level to be decreased to between 60% and 83.8% level when pressurizer pressure has been decreased to less than 1750 psia and only three SITS are operable.

This lower level of 60% corresponds to the minimum required water volume of 1332 cubic feet that must be maintained in each of the three operable SITS; however, calculations have shown that, in order to maintain the required water volume of 1332 cubic feet, the SIT level must be 60.23%. The proposed change, therefore, would conservatively "round-up" the required level to 61% instead of " rounding-off" to 60%.

It should be noted that when this potential non-conservatism was discovered, plant records were checked and it was verified that the actual SIT levels never fell below 61%.

I Safety Analysis The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:

1.

Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident?

Response: No The proposed change to this Technical Specification is strictly administrative in nature and does not affect the manner in which die plant is operated. The change is being proposed to correct a potential non-conservatism in the percent level that corresponds to the minimum required volume that must be maintained in the SITS. The reason for maintaining a minimum volume is to ensure that, in the event of a large break loss of

.NS20599

.n, m

coolant accident (LOCA), the amount of water injected into the RCS from the SITS is consistent with the amount of water assumed in the large break LOCA analysis presented in the FSAR.

Since the proposed change increases the required level that must be maintained in the RWSP (and hence increases the required volume), there will be no effect on the LOCA analyses described in Chapters 6 and 15 of the FSAR.

Therefore, the proposed change will not involve a significant increase in the probability or consequences of any accident.

2.

Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response

No The proposed change will ensure that the level of the SITS is consistent with the volume requirement that was determined by the Safety Analysis.

There has been no physical change to plant systems, structures or components.

The only change to plant procedures will be to require an increased SIT level when performing routine surveillance tests.

Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Response

No The intent of these specifications is to ensure that a sufficient volume of borated water will be immediately forced into the reactor core through each of the four cold legs in the event that the RCS pressure falls below tne pressure of the safety injection tanks.

This initial surge of water into the core provides the initial cooling mechanism during the large break LOCA analysis. The minimum SIT volume requirement ensures there is sufficient water on each of the SITS to perform the function assumed on the safety analysis.

Since the proposed change simply updates the SIT level that corresponds to the minimum volume requirement, it will not involve a significant reduction in the margin of safety.

The Commission has provided guidance concerning the application of standards for determining whether a significant hazards consideration exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazards consideration.

Example (ii) relates to a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications, (e.g., a more stringent surveillance requirement).

In this case, the proposed change is similar to Example (ii) in that it requires the SITS to be maintained at an increased level.

NS20599 Safety and Significant Hazards Consideration Based on the above Safety Analysis, it is concluded that:

(1) the proposed change does not constitute a significant hazards consideration as defined in 10CFR50.92; (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

NS20599

NPF-38-56 ATTACHMENT A NS20599

3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3/4.5.1 SAFETY INJECTION TANKS LIMITING CONDITION FOR OPERATION 3.5.1 Each Reactor Coolant System safety injection tank shall be OPERA 8LE with:

a.

The isolation valve open, b.

A contained borated water volume of between 1679 (78%) and 1807 (83.8%)

cubic feet, c.

Between 1720 and 2300 ppe of baron, and d.

A nitrogen cover pressure of between 600 and 625 psig.

APPLICABILITY:

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

ACTION:

a.

With one safety injection tank inoperable, except as a result of a closed isolation valve, restore the inoperable tank to OPERA 8LE 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 STAND 8Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b.

With one safety injection tank inoperable due to the isolation valve being closed, either immediately open the isolation valve or be in at least HOT STAN08Y within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and be in NOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.5.1 Each safety injection tank shall be demonstrated OPERA 8LE:

a.

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

1.

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

Verifying that each safety injection tank isolation valve is open.

• With pressurizer pressure greater than or equal to 1750 psia. When pressur-izer pressure-is less than 1750 psia, at least three safety injection tanks must be OPERA 8LE, each with a minimum pressure of 235 psig and a maximum pressure of 625 psig, and a contained borated water volume of between 1332 (60%) and 1807 (83.8%) cubic feet. With all four safety injection tanks OPERABLE, each tank shall have a minimum pressure of 235 psig and a maximum pressure of 625 psig, a boron concentration of between 1720 and 2300 ppe boron, and a contained borated water volume of between 888 (39%) and 1807 (83.8%) cubic feet.

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

WATERFORD - UNIT 3 3/4 5-1

NPF-38-56 ATTACHMENT B l

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NS20599

-z.. - -.

3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3/4.5.1 SAFETY INJECTION TANKS LIMITING CONDITION FOR OPERATION 3.5.1 Each Reactor Coolant System safety injection tank shall be OPERABLE with:

a.

The isolation nive open, b.

A contained borated water volume of between 1679 (78%) and 1807 (83.8%)

cubic feet, c.

Between 1720 and 2300 ppm of baron, and d.

A nitrogen cover pressure of between 600 and 625 psig.

APPLICABILITY:

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

ACTION:

a.

With one safety injection tank inoperable, except as a result of a closed isolation valve, restore the inoperable tank 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, b.

With one safety injection tank inoperable due to the isolation valve being closed, either immediately open the isolation valve or be in at least HOT STANDBY within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

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

a.

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

i.

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

Verifying that each safety injection tank isolation valve is open.

• With pressurizer pressure greate-than or equal to 1750 psia. When pressur-izer pressure is less than 1750 psfa, at least three safety injection tanks must be OPERABLE, each with a minimta pressure of 235 psig and a maximum pressure of 625 psig, and a containea borated water volume of between 1332 (g/ g)

-(405) and 1807 (83.8%) cubic feet. With all four safety injection tanks f

OPERABLE, each tank shall have a minimum pressure of 235 psig and a maximum pressure of 625 psig, a boron concentration of between 1720 and 2300 ppm boron, and a contained borated water volume of between 888 (39%) and 1807 (83.8%) cubic feet.

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

WATERFORD - UNIT 3 3/4 5-1

MPF-38-57

DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-57 This is a request to revise Technical Specification Table 3.3-11, " Fire j

Detection Instruments".

t Existing Specification See Attachment A.

Proposed Specification See Attachment B.

Description The proposed change would revise Technical Specification Table 3.3-11, 4

" Fire Detection Instruments" to:

1.

Change the two Function A (early warning fire detection and notification only) smoke detectors in the CCW Pump "A" room (Zone RAB19) to Function B (actuation of fire suppression systems and early warning and notification) instruments, and 2.

Implement certain name changes and correct typographical errors for the charcoal air filter units.

Presently, Technical Specification Table 3.3-11 indicates the presence of two smoke detectors in Fire Zone RAB19 which provide early warning fire detection and notification but do not actuate fire suppression systems. As part of the Associated Circuits Analysis modifications implemented during the first refueling outage for Waterford 3, an existing pre-action sprinkler system was extended into RAB19. Local control panel modifications allowed the use of existing early warning notification smoke detectors to also provide suppression system actuation. The proposed change will revise the RAB19 smoke detector designation from Function A to Function B to reflect the additional detector capability.

The proposed changes to Table 3.3-11 for the charcoal air filter units will correct typographical errors in filter train identification numbers and revise room name descriptions to be consistent with Waterford 3 standard usage. These changes are purely administrative.

Safety Analysis The proposed changes described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:

1.

Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident?

Response: No

V The proposed change to the RAB19 smoke detectors provides increased fire suppression capability. As such, the probability of damage to redundant safe shutdown components passing through RAB19 is decreased and the potential consequences of a fire in that area are reduced from that existing during Cycle 1.

The administrative changes to the charcoal air filter unit designations have no physical effect on plant systems.

2.

Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed changes will either enhance fire suppression capability or introduce no physical change to the plant. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Response: No The RAB19 smoke detectors vill provide an increased margin of safety over that available during Cycle 1 due to the additional suppression capability. The administrative changes to the charcoal filter units will introduce no plant changes and therefore will not affect safety margins.

The Commission has provided guidance concerning the application of standards for determining whether a significant hazards consideration exists by providing certain examples (40 FR 14870) of amendments that are considered not likely to involve significant hazards consideration.

Example (1) relates to a purely administrative change (e.g. a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature). Example (ii) relates to a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications, (e.g., a more stringent surveillance requirement).

In this case, the proposed changes to the charcoal air filter units are similar to Example (1) in that numbering errors are being corrected and nomenclature changed to be consistent with Waterford 3 usage. The RAB19 proposed change is similar to Example (ii) in placing an additional restriction (suppression system actuation) on the smoke detectors.

Safety and Significant Hazards Consideration Based on the above Safety Analysis, it is concluded that:

(1) the proposed change does not constitute a significant hazard consideration as defined in 10CFR50.92; and (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

i 1

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l NPF-38-57 ATTACHMENT A i

1

(

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..+

TABLE 3.3-11 q,,*,.,

FIRE DETECTION INSTRUMENTS TOTAL NUMBER OF INSTRUMENTS

• ELEVATION HEAT FLAME SMOKE ZONE ROOM NAME/ NUMBER (ft)

[x4)d, g Lx4y),

1.

REACTOR AUXILIARY BUILDING RA8 1A Control Room Proper /304

+46 20/0 RA8 18 Emergency Equip. H&V Room /314

. +46 0/12 RA8 10 Computer Room (above raised floor)/306 +46 5/0 Computer Room (below raised floor)/306 +46 0/7 RA8 2 Ventilation Equip. Room /239

+46 0/36 RA8 3 RA8 Corridor to Relay Room /261

+35 0/1(3) 4/0 RA8 HVAC Switchgear Equip. Room /323

+46 0/10 RA8 3A RA8 Battery Exhaust Fan Room /406

+69 0/2 RA8 4 Cable Vault /260

+35 0/27 RA8 5 Electrical Penetration Area "A"/263

+35 0/13 RA8 6 Electrical Penetration Area "B"/263A

+35 0/14 4

RA8 7 Relay Room /262

+35 (3) 12/0 Isolation Panels (9 Compartments

+35 2/0

- 2 per comp.)

RA8 8A High Voltage Switchgear. Room "A"/212A

+21 0/1(1) 18/0 RA8 88 Electrical Equip. Room /2258 and High

+21 0/1(2) 28/0 Voltage Switchgear Roon "B"/212 480V Switchgear 3A32 Room

+21 (2) 2/0 RAB 8C High Voltage Switchgear Room

+21 (1) 8/0 "A-8"/2128 RA8 8E CEA M/G Set Room /216

+21 2/0 RA8 9 Remote Shutdown Panel Room /217

+21 1/0 RA8 11 Battery Room "8"/213

+21 2/0 RA8 12 Battery Room "A8"/214A

+21 2/0 RA8 13 Battery Room "A"/214

+21 2/0 RA8 15 Emergency Diesel Gen. "B" Room /222

+21 0/1 RAB 15A Emergency Diesel Gen. "B" Feed TK

+46 0/1 Room /328A RA8 16 Emergency Diesel Gen. "A" Room /221

+21 0/1 RAB 16A Emergency Diesel Gen. "A" Feed Tk.

+46 0/1 Room 328A RAB 17 CCW Heat Exchanger "B"/236

+21 0/4 RAB 18 CCW Heat Exchanger "A"/220

+21 0/4 RAB 19 CCW Pump "A"/235

+?1 2/0 RA8 20 CCW Pump "AR"/234

+21 0/2 RA8 21 CCW Pump "8"/233

+21 1/0 l

RA8 23 Corridor to CCW F%nps/218, Corridor

+21 0/39 to CCW Heat Exchangers/219 and Corridor to Emergency Dieser Gen./225A

\\

I (1) Common Resistor Wire (2) Common Resistor Wire (3) Common Resistor Wire WATERFORD - UNIT-3 3/4 3-51

1 TABLE 3.3-11 (Continued)

-s, ',i FIRE DETECTION INSTRUMENTS TOTAL NUMBER OF INSTRUMENTS

• ELEVATION HEAT FLAME SMOKE ZONE ROOM NAME/ NUMBER (ft)

M (x/y) (x/y) 2.

REACTOR CONTAINMENT BUILDING **

f RCB 1-1 Annulus /420

- 4, +21 69/0

& +46 RCB 2 Electrical Penetration Area A

+21 24/0 RCB 3 Electrical Penetration Area 8

+21 21/0 RCB 4 Reactor Cable Trays

+46 16/0 CT 1&3 Wet & Dry Cooling Tower "A" Cable Tray 1/0 CT 2&4 Wet & Dry Cooling Tower "B" Cable Tray 1/0 3.

FUEL HANDLING BUILDING FHB 2 Purification Pump Room /B155, Fuel Pool

+1 10/0 Pump "A"/8157, Fuel Pool Pump "B"/

B156, Fuel Pool Heater Exchanger /

B158 and Access Area /8-161 Emergency Filter Train Unit /8152

+1 6/0 Emergency Elect. Equip. Room /B151

+1 1/0 FHB 4 Operating Floor /361

+46 15/0 4.

CHARC0AL AIR FILTER UNITS E-35 (3A-5A) FHB Emergency Filter Train Unit

+1 1/0 E-35 (3B-5B) FHB Emergency Filter Train Unit

+1 1/0 E-17 (3A-5A) Shield Building Ventilation

+46 1/0 System "A" E-17 (3B-58) Shield Building Ventilation

+46 1/0 System "B" E-23 (3A-5A) Controlled Ventilation Area

+46 1/0 System Filter Train "A" E-23 (3A-5B) Controlled Ventilation Area

+46 1/0 System Filter Train "B" S-8 (3A-5A) Control Room Emergency Unit "A"

+46 1/0 S-8 (3B-58) Control Room Emergency Unit "B"

+46 1/0 TABLE NOTATIONS

• (x/y):

x is the number of Function A (early warning fire detection end notification only) instruments.

y is the number of Function B (actuation of fire suppression systems and early warning and notification) instruments.

• • The fire detection instruments located within the containment are not required to be OPERABLE during the performance of Type A containment leakage rate tests.

WATERFORD - UNIT 3 3/4 3-53

S 4

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NPF-38-57 i

h ATTACHMENT B I

l l

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TABLE 3.3-11

~ "

FIRE OETECTION INSTRUMENTS TOTAL NUMBER OF INSTRUMENTS

• ELEVATION HEAT FLAME SMOKE ZONE ROOM NAME/NUMER (ft)

M h/y), M 1.

REACTOR AUXILIARY 8UILDING RA8 1A Control Room Proper /304

+46 20/0 RA8 18 Emergency Equip. H&V Room /314

. +46 0/12 RA8 1D Computer Room (above raised floor)/306 +46 5/0 Computer Room (below raised floor)/306 +46 0/7 RA8 2 Ventilation Equip. Room /299

+46 0/36 RA8 3 RA8 Corridor to Relay Room /261

+35 0/1(3) 4/0 RA8 HVAC Switchgear Equip. Room /323

+46 0/10 RA8 3A RA8 Battery Exhaust Fan Room /406

+69 0/2 RA8 4 Cable Vault /260

+35 0/27 RA8 5 Electrical Penetration Area "A"/263

+35 0/13 RA8 6 Electrical Penetration Area "B"/263A

+35 0/14 RAB 7 Relay Room /262

+35 (3) 12/0 Isolation Panels (9 Compartments

+35 2/0

- 2 per comp.)

RA8 8A High Voltage Switchgear. Room "A"/212A

+21 0/1(1) 18/0 RA8 88 Electrical Equip. Room /2258 and High

+21 0/1(2) 28/0 Voltage Switchgear Roon "8"/212 480V Switchgear 3A32 Room

+21 (2) 2/0 RAB 8C High Voltage Switchgear Room

+21 (1) 8/0 "A-8"/2128 RA8 8E CEA M/G Set Room /216

+21 2/0 RA8 9 Remote Shutdcwn Panel Room /217

+21 1/0 RA8 11 Battery Roon "B"/213

+21 2/0 RA8 12 Sattery Roon "A8"/214A

+21 2/0 RA8 13 Battery Roon "A"/214

+21 2/0 R48 15 Emergency Diesel Gen. "B" Room /222

+21 0/1 RA8 ISA Emergency Diesel Gen. "B" Feed TK

+46 0/1 Room /328A RA8 16 Emergency Diesel Gen. "A" Room /221

+21 0/1 RA8 16A Emergency Diesel Gen. "A" Feed Tk.

+46 0/1 Room 328A RA8 17 CCW Heat Exchanger "B"/236

+21 0/4 l

RAB 18 CCW Heat Exchanger "A"/220

+21 RAB 19 CCW Pump "A"/235

+21 RA8 20 CCW Pump "A8"/234

+21 RA8 21 CCW Pump "B"/233

+21 1/0 RAB 23 Corridor to CCW Pumps /218, Corridor

+21 0/39 to CCW Heat Exchangers/219 and Corridor to Emergency Dieser Gen./225A (1) Common Resistor Wire (2) Common Resistor Wire (3) Common Resistor Wire WATERFORD - UNIT'3 3/4 3-51

.. _ ~ _. _ _.,. _

$i TABLE 3.3-11 (Continued) kyj FIRE DETECTION INSTRUMENTS TOTAL NUMBER OF INSTRUMENTS

• ELEVATION HEAT FLAME SMOKE ZONE ROOM NAME/ NUMBER (ft)

W W (x/y) 2.

REACTOR CONTAINMENT BUILDING **

RCB 1-1 Annulus /420

- 4, +21 69/0

& +46 RCB 2 Electrical Penetration Area A

+21 24/0 RCB 3 Electrical Penetration. Area B

+21 21/0 RCB 4 Reactor Cable Trays

+46 16/0 CT 1&3 Wet & Dry Cooling Tower "A" Cable Tray 1/0 CT 2&4 Wet & Dry Cooling Tower "B" Cable Tray 1/0 3.

FUEL HANDLING BUILDING FHB 2 Purification Pump Room /B155, Fuel Pool

+1 10/0 Pump "A"/8157, Fuel Pool Pump "B"/

B156, Fuel Pool Heater Exchanger /

B158 and Access Area /B-161 Emergency Filter Train Unit /B152

+1 6/0 Emergency Elect. Equip. Room /B151

+1 1/0 FHB 4 Operating Floor /361

+46 15/0 4.

CHARC0AL AIR FILTER UNITS E-35 (3A-!

HB Emergency Filter Train Unh 'M"

+1 1/0 E-35 (38-! iB) FHB Emergency Filter Train Un+t "B"

+1 1/0 E-17 (3A-hA) Shield Building Ventilation

+46 1/0 System.ugn-Fe crca TR AIN "4" E-17 (38-hB) Shield Building Ventilation

+46 1/0 System 89u. p,,,7garna,u as" E-23 (3A-hA) Controlled Ventilation Area

+46 1/0 System Filter Train "A" E-23 (3A-hB) Controlled Ventilation Area

+46 1/0 p s&TERTRAIN"A"

+S System Filter Train "B" F

S-8 (3A-! iA) Control Room Emergency Un-t " M

+46 1/0 S-8 (38-! iB) Control Room Emergency Unit "C"L

+46 1/0 Fns TE R T a nsn "B "

TABLE NOTATIONS

• (x/y):

x is the number of Function A (early warning fire detection and I

notification only) instruments.

I y is the number of Function B (actuation of fire suppression systems and early warning and notification) instruments.

• • The fire detection instruments located within the containment are not required to be OPERABLE during the performance of Type A containment leakage rate tests.

j WATERFORD - UNIT 3 3/4 3-53

-