W3F1-2021-0038, Technical Specification Index and Bases Update to the NRC for the Period June 11, 2019 Through March 3, 2021

Technical Specification Index and Bases Update to the NRC for the Period June 11, 2019 Through March 3, 2021

ML21139A129
Person / Time
Site:	Waterford
Issue date:	05/18/2021
From:	Wood P Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2021-0038
Download: ML21139A129 (17)

Text

Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504-464-3786 Paul Wood Regulatory Assurance Manager Waterford 3 W3F1-2021-0038 10 CFR 50.71(e)

May 1, 2021 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Technical Specification Index and Bases Update to the NRC for the Period June 11, 2019 through March 3, 2021 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 Renewed Facility Operating License No. NPF-38 Pursuant to Waterford Steam Electric Station Unit 3 (Waterford 3) Technical Specification (TS) 6.16, Entergy Operations, Inc. (EOI) hereby submits an update of all changes made to the Waterford 3 Technical Specification Index and Bases since the last submittal per letter W3F1-2019-0065 (ADAMS Accession No. ML19253F290), dated September 10, 2019. This update satisfies the submittal frequency required by TS 6.16, which indicates that the submittal will be made at a frequency consistent with 10 CFR 50.71(e) and exemptions thereto.

There are no commitments associated with this submittal. Should you have any questions or comments concerning this submittal, please contact the Regulatory Assurance Manager, Paul Wood, at (504) 464-3786.

Respectfully, Paul Wood Digitally signed by Paul Wood Date: 2021.05.18 18:16:39 -05'00' PW/llb Attachments:

1. Waterford 3 Technical Specification Index and Bases Change List

2. Waterford 3 Technical Specification Index and Bases Revised Pages

W3F1-2021-0038 Page 2 (w/Attachments) cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 NRR Project Manager

Attachment 1 to W3F1-2021-0038 Waterford 3 Technical Specification Index and Bases Change List to W3F1-2021-0038 95 12/3/2019 B 3/4 0-2 Change No. 95 - These changes reflect NRC B 3/4 0-3 approved license amendment 255 and NRC B 3/4 0-4 approved safety evaluation for TSTF-529.

B 3/4 0-4a Update steps that discuss TS LCO 3.0.5 B 3/4 0-5 should not be used if other practical B 3/4 0-6 alternatives are available which comply B 3/4 0-7 with required actions. Removal of bullet discussing containment isolation valves.

Updating steps discussing surveillances required 4.0.3 is only applicable if there is reasonable exception that the associated equipment is operable and is expected that the surveillance will be met when performed. Add clarification to Containment Isolation section 6.6. (LBDCR 19-032) 96 9/17/2020 B 3/4 7-4a (1) Change No. 96 - A change of CREACS to B 3/4 7-4a (4) CREAFS on TS Bases page B 3/4 7-4a (1) is B 3/4 7-4a (5) an editorial change being made to correct typographical error. (LBDCR 20-029)

Attachment 2 to W3F1-2021-0038 Waterford 3 Technical Specification Index and Bases Revised Pages (There are 12 unnumbered pages following this cover page)

BASES equipment is removed from service. In this case, the allowable outage time limits of the ACTION requirements are applicable when this limit expires if the surveillance has not been completed. When a shutdown is required to comply with ACTION requirements, the plant may have entered a MODE in which a new specification becomes applicable. In this case, the time limits of the ACTION requirements would apply from the point in time that the new specification becomes applicable if the requirements of the Limiting Condition for Operation are not met.

Specification 3.0.2 establishes that noncompliance with a specification exists when the requirements of the Limiting Condition for Operation are not met and the associated ACTION requirements have not been implemented within the specified time interval. The purpose of this specification is to clarify that (1) implementation of the ACTION requirements within the specified time interval constitutes compliance with a specification and (2) completion of the remedial measures of the ACTION requirements is not required when compliance with a Limiting Condition of Operation is restored within the time interval specified in the associated ACTION requirements.

(LBDCR 19-032, Ch. 95)

Specification 3.0.3 establishes the shutdown ACTION requirements that must be implemented when a Limiting Condition for Operation is not met and the condition is not specifically addressed by the associated ACTION requirements.

The purpose of this specification is to delineate the time limits for placing the unit in a safe shutdown MODE when plant operation cannot be maintained within the limits for safe operation defined by the Limiting Conditions for Operation and its ACTION requirements. It is not intended to be used as an operational convenience which permits (routine) voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable. One hour is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This time permits the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to enter lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the cooldown capabilities of the facility assuming only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the primary coolant system and the potential for a plant upset that could challenge safety systems under conditions for which this specification applies.

?(LBDCR 19-032, Ch. 95)

If remedial measures permitting limited continued operation of the facility under the provisions of the ACTION requirements are completed, the shutdown may be terminated. The time limits of the ACTION requirements are applicable from the point in time there was a failure to meet a Limiting Condition of Operation. Therefore, the shutdown may be terminated if the ACTION requirements have been met or the time limits of the ACTION requirements have not expired, thus providing an allowance for the completion of the required actions.

WATERFORD - UNIT 3 B 3/4 0-2 AMENDMENT NO. 99 Change No. 95

BASES (LBDCR 19-032, Ch. 95)

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the plant to be in the COLD SHUTDOWN MODE when a shutdown is required during the POWER MODE of operation. If the plant is in a lower MODE of operation when a shutdown is required, the time limit for entering the next lower MODE of operation applies. However, if a lower MODE of operation is entered in less time than allowed, the total allowable time to enter COLD SHUTDOWN, or other applicable MODE, is not reduced. For example, if HOT STANDBY is entered in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the time allowed to enter HOT SHUTDOWN is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> because the total time to enter HOT SHUTDOWN is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.

Therefore, if remedial measures are completed that would permit a return to POWER operation, a penalty is not incurred by having to enter a lower MODE of operation in less than the total time allowed.

?(LBDCR 19-032, Ch. 95)

The same principle applies with regard to the allowable outage time limits of the ACTION requirements, if compliance with the ACTION requirements for one specification results in entry into a MODE or condition of operation for another specification in which the requirements of the Limiting Condition for Operation are met. If the new specification becomes applicable in less time than specified, the difference may be added to the allowable outage time limits of the second specification. However, the allowable outage time limits of ACTION requirements for a higher MODE of operation may not be used to extend the allowable outage time that is applicable when a Limiting Condition for Operation is not met in a lower MODE of operation.

The shutdown requirements of Specification 3.0.3 do not apply in MODES 5 and 6, because the ACTION requirements of individual specifications define the remedial measures to be taken.

Specification 3.0.4 establishes limitations on MODE changes when a Limiting Condition for Operation is not met. It precludes placing the facility in a higher MODE of operation when the requirements for a Limiting Condition for Operation are not met and continued noncompliance with these conditions would result in a shutdown to comply with the ACTION requirements if a change in MODES were permitted. The purpose of this specification is to ensure that facility operation is not initiated or that higher MODES of operation are not entered when corrective action is being taken to obtain compliance with a specification by restoring equipment to OPERABLE status or parameters to specified limits. Compliance with ACTION requirements that permit continued operation of the facility for an unlimited period of time provides an acceptable level of safety for continued operation without regard to the status of the plant before or after a MODE change. Therefore, in this case, entry into an OPERATIONAL MODE or other specified condition may be made in accordance with the provisions of the ACTION requirements. The provisions of this specification should not, however, be interpreted as endorsing the failure to exercise good practice in restoring systems or components to OPERABLE status before plant startup.

WATERFORD - UNIT 3 B 3/4 0-3 AMENDMENT NO. 99 Change No. 95

BASES When a shutdown is required to comply with ACTION requirements, the provisions of Specification 3.0.4 do not apply because they would delay placing the facility in a lower MODE of operation.

Specification 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to Specification 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of Surveillance Requirements to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed Surveillance Requirements. This Specification does not provide time to perform any other preventive or corrective maintenance.

(LBDCR 19-032, Ch. 95)

LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.

An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples of demonstrating the OPERABILITY of other equipment are taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of a Surveillance Requirement on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of a Surveillance Requirement on another channel in the same trip system.

?(LBDCR 19-032, Ch. 95)

AMENDMENT NO. 62,99, 101, WATERFORD - UNIT 3 B 3/4 0-4 Changed by letter dated August 22, 1990 CHANGE NO. 30, 60, 95

BASES (LBDCR 19-032, Ch. 95)

The administrative controls in LCO 3.0.5 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the Required Actions. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.

?(LBDCR 19-032, Ch. 95)

EC-15515, Ch. 60)

Specification 3.0.8 LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s). This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The snubber requirements do not meet the criteria in 10 CFR 50.36, and, as such, are appropriate for control by the licensee.

If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported systems LCO(s) must be declared not met and the ACTIONS entered in accordance with LCO 3.0.2.

?(EC-15515, Ch. 60)

WATERFORD - UNIT 3 B 3/4 0-4a1 Change No. 95

BASES (EC-15515, Ch. 60)

LCO 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system. LCO 3.0.8.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 72 -

hour allowed outage time (AOT) is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.

LCO 3.0.8.b applies when one or more snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system. LCO 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12-hour AOT is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.

When applying LCO 3.0.8.a, the various EFW flow path combinations described in the ACTION statements for Emergency Feedwater (EFW) system must be OPERABLE during MODES when EFW is required to be OPERABLE. When applying LCO 3.0.8.a during MODES when EFW is not required to be OPERABLE, the redundant core cooling method [such as Shutdown Cooling (SDC) system] must be available. When applying LCO 3.0.8.b, a means of core cooling must remain available (EFW, SDC, equipment necessary for feed and bleed operations, etc.). Reliance on availability of a core cooling source during modes where EFW is not required by TSs provides an equivalent safety margin for plant operations when LCO 3.0.8 is not applied and meets the intent of Technical Specification Task Force (TSTF) 372.

LCO 3.0.8 requires that risk be assessed and managed. Industry and NRC guidance on the implementation of 10 CFR 50.65(a)(4) (the Maintenance Rule) does not address seismic risk. However, use of LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.

LCO 3.0.8 does not apply to non-seismic snubbers. The provisions of LCO 3.0.8 are not to be applied to supported TS systems unless the supported systems would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads.

The risk impact of dynamic loadings other than seismic loads was not assessed as part of the development of LCO 3.0.8. These shock-type loads include thrust loads, blowdown loads, water-hammer loads, steam-hammer loads, LOCA loads and pipe rupture loads.

However, there are some important distinctions between non-seismic (shock-type) loads and seismic loads which indicate that, in general, the risk impact of the out-of-service snubbers is smaller for non-seismic loads than for seismic loads. First, while a seismic load affects the entire plant, the impact of a non-seismic load is localized to a certain system or area of the

?(EC-15515, Ch. 60)

(LBDCR 19-032, Ch. 95)

WATERFORD - UNIT 3 B 3/4 0-4a2 AMENDMENT NO. 101

?(LBDCR 19-032, Ch. 95) CHANGE NO. 1, 23, 60, 95

BASES (DRN 03-524)

Some examples of this process are:

a. Emergency feedwater (EFW) pump turbine maintenance during refueling that requires testing at steam pressures > 750 psig. However, if other appropriate testing is satisfactorily completed, the EFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.

b. High pressure safety injection (HPSI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPSI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

?(DRN 03-524)

Specification 4.0.2 establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

This extension allowed by Specification 4.0.2 is also applicable to Surveillance Requirements required in Technical specification Actions. However, the extension does not apply to the initial performance. The extension only applies to each performance after the initial performance. The initial performance required by the Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single completion time. One reason for not allowing the extension to this completion time is that such an action usually verifies that no loss of function has occurred or accomplishes the function of the inoperable equipment in an alternative manner.

(DRN 03-524), (LBDCR 19-032, Ch. No. 95)

Specification 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been performed within its specified interval. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4.0.2, and not at the time that the specified interval was not met.

?(DRN 03-524), (LBDCR 19-032, Ch. No. 95)

AMENDMENT NO. 99 WATERFORD - UNIT 3 B 3/4 0-5 CHANGE NO. 23, 95

BASES (DRN 03-524), (LBDCR 19-032, Ch. No. 95)

This delay period provides an adequate time to perform Surveillances that have been missed. This delay period permits the performance of a Surveillance before complying with required actions or other remedial measures that might preclude performance of the Surveillance.

?(LBDCR 19-032, Ch. No. 95)

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements. When a Surveillance with an interval based not on time intervals, but upon specified unit conditions, operational situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, Specification 4.0.3 allows for the full delay period of up to the specified interval to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity. Specification 4.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by required actions.

(LBDCR 19-032, Ch. No. 95)

Surveillance Requirement 4.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed. Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of Surveillance Requirement 4.0.3 would be a relay contact that was not tested as required in accordance with a particular Surveillance Requirement, but previous successful performances of the Surveillance Requirement included the relay contact; the adjacent, physically connected relay contacts were tested during the Surveillance Requirement performance; the subject relay contact has been tested by another Surveillance Requirement; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed.

For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

?(LBDCR 19-032, Ch. No. 95)

AMENDMENT NO. 99, WATERFORD - UNIT 3 B 3/4 0-6 CHANGE NO. 23, 95

BASES t(LBDCR 19-032, Ch. No. 95)

Failure to comply with specified intervals for surveillance requirements is expected to be an infrequent occurrence. Use of the delay period established by Specification 4.0.3 is a flexibility which is not intended to be used repeatedly to extend Surveillance intervals.

While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified interval is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.' This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

?(DRN 03-524), (LBDCR 19-032, Ch. No. 95)

WATERFORD - UNIT 3 B 3/4 0-6a CHANGE NO. 95

BASES (DRN 03-524, Ch. 23), (LBDCR 19-032, Ch. 95)

If a Surveillance is not performed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the allowed outage times of the required actions for the applicable LCO begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the allowed outage times of the required actions for the applicable LCO begin immediately upon the failure of the Surveillance.

Satisfactory performance of the Surveillance within the delay period allowed by this Specification, or within the allowed outage time of the actions, restores compliance with Specification 4.0.1.

?(DRN 03-524, Ch. 23), (LBDCR 19-032, Ch. 95)

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply. However, the Surveillance Requirements have to be met to demonstrate that inoperable equipment has been restored to OPERABLE status.

Specification 4.0.4 establishes the requirement that all applicable surveillance must be met before entry into an OPERATIONAL MODE or other condition of operation specified in the Applicability statement. The purpose of this specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into a MODE or condition for which these systems and components ensure safe operation of the facility. This provision applies to changes in OPERATIONAL MODES or other specified conditions associated with plant shutdown as well as startup.

Under the provisions of this specification, the applicable Surveillance Requirements must be performed within the specified surveillance interval to ensure that the Limiting Condition for Operation are met during initial plant startup or following a plant outage.

When a shutdown is required to comply with ACTION requirements, the provisions of Specification 4.0.4 do not apply because this would delay placing the facility in a lower MODE of operation.

(DRN 03-1807, Ch. 30)

? (DRN 03-1807, Ch. 30)

AMENDMENT NO. 99, WATERFORD - UNIT 3 B 3/4 0-7 CHANGE NO. 23, 30, 95

PLANT SYSTEMS BASES (EC-15550, Ch. 59) 3/4.7.6.1 CONTROL ROOM EMERGENCY AIR FILTRATION SYSTEM (CREAFS) (Continued)

In the pressurization mode, up to 200 cfm outside air is combined with a portion of recirculated air and the combined air flow is filtered, and then added to the air being supplied to the CRE. Pressurization of the CRE minimizes infiltration of unfiltered air through the CRE boundary. The emergency filtration units are not started in the toxic gas isolation mode.

The normal outside air entering the CRE is continuously monitored by radiation and toxic gas detectors. One detector output above the setpoint will cause actuation of the emergency radiation state or toxic gas isolation state as required. The actions of the toxic gas isolation state are more restrictive, and will override the actions of the emergency radiation state.

(LBDCR 20-029, Ch. 96)

The CREAFS operates at 4225 scfm; all of this can be recirculated air or up to 200 scfm can be outside air. When pressurizing the control room, an emergency outside air path is aligned and dampers are adjusted such that a small portion of the total air being filtered by the CREAFS (up to 200 scfm) is outside air; the remaining air (4025 - 4225 scfm) is from the normal control room HVAC system. After being routed through the emergency filtration unit, the 4225 scfm is returned to the supply duct of the normal control room HVAC system. Up to 200 scfm of outside air is allowed to pressurize the control room to a 1/8 in. w.g. Assuming use of the full 200 scfm of outside air, the air exchange rate would be approximately 6%. The CREAFS operation in maintaining the CRE habitable is discussed in the FSAR, Section 9.4.

Å(LBDCR 20-029, Ch. 96)

Redundant trains provide the required filtration should an excessive pressure drop develop across the other filter train. Normally open isolation dampers are arranged in series pairs so that the failure of one damper to shut will not result in a breach of isolation. The CREAFS is designed in accordance with Seismic Category requirements.

(LBDCR 20-029, Ch. 96)

The CREAFS is designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5 rem total effective dose equivalent (TEDE).

Å(LBDCR 20-029, Ch. 96)

Applicable Safety Analysis The CREAFS components are arranged in redundant, safety related ventilation trains.

The location of components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access.

The CREAFS provides airborne radiological protection for the CRE as demonstrated by the CRE occupant dose analyses for the most limiting design basis accident fission product release presented in the FSAR, Chapter 15.

Å(EC-15550, Ch. 59)

WATERFORD - UNIT 3 B 3/4 7-4a(1) CHANGE NO. 59, 96

PLANT SYSTEMS BASES

>(EC-15550, Ch. 59) 3/4.7.6.1 CONTROL ROOM EMERGENCY AIR FILTRATION SYSTEM (CREAFS) (Continued) reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day completion time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day completion time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

ACTION STATEMENT c requires that, in MODE 1, 2, 3, or 4, if the inoperable CREAFS or the CRE boundary cannot be restored to OPERABLE status within the required completion time, the unit must be placed in a MODE that minimizes the accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed completion times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

ACTION STATEMENT d.1 requires that, in MODE 5 or 6, or during movement of irradiated fuel assemblies, if required Action a cannot be completed within the required completion time, the OPERABLE CREAFS train must be immediately placed in the emergency radiation protection mode of operation. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure will be readily detected.

ACTION STATEMENT d.2 is an alternative to Action d.1 and requires immediate suspension of activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel assemblies to a safe position.

(LBDCR 20-029, Ch. 96)

ACTION STATEMENT e requires that, in MODES 5 or 6, or during movement of irradiated fuel assemblies, with one or more CREAFS trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position. SRs 4.7.6.1.d.2 and 4.7.6.1.d.4 include an exception that allows the SR to be considered met for dampers and valves that are locked, sealed, or otherwise secured in the actuated position. As a result, LCO 3.7.6.1 Action e. is not required to be entered in this situation, and the CRE boundary remains operable. The exception may only be applied to valves that have demonstrated acceptable leakage performance.

Å(LBDCR 20-029, Ch. 96)

ACTION STATEMENT f addresses the condition of both CREAFS trains being inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary. The CREAFS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LC0 3.0.3 must be entered immediately.

ACTION STATEMENT g requires that, in MODES 5 or 6, or during movement of irradiated fuel assemblies, with both CREAFS trains inoperable action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

<(EC-15550, Ch. 59)

WATERFORD - UNIT 3 B 3/4 7-4a(4) CHANGE NO. 59, 71, 96

PLANT SYSTEMS BASES (EC-15550, Ch. 59) 3/4.7.6.1 CONTROL ROOM EMERGENCY AIR FILTRATION SYSTEM (CREAFS) (Continued)

Surveillance Requirements (LBDCR 16-046, Ch. 86)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(LBDCR 16-046, Ch. 86)

(LBDCR 20-029, Ch. 96)

d. SRs 4.7.6.1.d.2 and 4.7.6.1.d.4 include an exception that allows the SR to be considered met for dampers and valves that are locked, sealed, or otherwise secured in the actuated position in Modes 5, 6, or defueled. As a result, LCO 3.7.6.1 Action e. is not required to be entered in this situation, and the CRE boundary remains operable. The exception may only be applied to valves that have demonstrated acceptable leakage performance because operability of the CRE boundary is contingent on the leak-tightness of the CRE boundary valves. Acceptable leakage performance is demonstrated by satisfactory performance of the control room tracer gas test, differential pressure testing, component testing for HVCMVAAA101 and HVCMVAAA102, and completion of scheduled preventative maintenance tasks. It is understood that component testing of the remaining twelve boundary valves is not possible due to system configuration; thus, individual component testing beyond the unfiltered inleakage and differential pressure testing is not required to be performed on these valves to demonstrate leak-tightness.

Å(LBDCR 20-029, Ch. 96)

g. This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air inleakage into the CRE is not greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Action b must be entered. Action b.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident.

Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3 (Ref. 1) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 2). These compensatory measures may also be used as mitigating actions as required by Action b.2.

Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 3). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

References

1. Regulatory Guide 1.1.96

2. NEI 99-03, "Control Room Habitability Assessment," June 2001.

3. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability," (ADAMS Accession No. ML040300694).

3/4.7.6.2 [NOT USED]

(EC-15550, Ch. 59 WATERFORD - UNIT 3 B 3/4 7-4a(5) CHANGE NO. 59, 86, 96