ML20249C832

Proposed Tech Specs 3.7.6.1,3.7.6.2,3.7.6.3,3.7.6.4 & 3.7.6.5,revising Control Room Ventilation to Be Consistent w/NUREG-1432

ML20249C832
Person / Time
Site:	Waterford
Issue date:	06/29/1998
From:	ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20249C831	List: ML20249C830 ML20249C832
References
RTR-NUREG-1432 NUDOCS 9807010277
Download: ML20249C832 (49)

Text

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NPF-38-204 ATTACHMENT A EXISTING TECHNICAL SPECIFICATIONS l

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9907010277 900629 i

l PDR ADOCK 05000302.

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PLANT SYSTEMS 3/4.7.6.1 CONTROL ROOM EMERGENCY AIR FILTRATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.1 Both control room emergency air filtration trains (S-8) shall be OPERABLE.

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

&GIlQti:

a.

With one control room emergency air filtration train inoperable, either restore the inoperable train to OPERA 8tE status within 7 days or be in at least HOT STAN08Y 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 />.

b.

With both control room emergency air filtration trains inoperable, restore one train to GPERABLE status within I hour 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 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 RE0UIREMENTS 4.7.6.1 Each control room air filtration train (S-8) shall be demonstrated i

. OPERA 8LE:

I a.

At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 10 continuous hours with the heaters on.

b.

At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following' painting, fire or chemical release in any ventilation zone communicating with the system by:

1.

Verifying that the filtration train satisfies the in-place testing acceptance criteria and uses the test procedures of Regulatory Positions C.5.a. C.5.c, and C.5.d of Regulatory Guide 1.52 Revision 2,. March 1978, and the system flow rate is 4225 cfm 1105.

2.

Verifying within 31 days after removal that a laboratory l

analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52,

. Revision 2, March 1978.

WATERFORD - UNIT 3-3/4 7-16 Amendment No.115

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I PLANT SYSTEMS

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3/4.7.6.2 CONTROL ROOM EMERGENCY AIR FILTRATION SYSTEM

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LIMITING CONDITION FOR OPERATION 3.7.6.2 Two control room emergency air filtration trains (S-8) shall be OPERABLE.

APPLICABILITY: MODES 5 and 6.

E ngg:

With one control room emergency air filtration system inoperable, a.

restore the inoperable system to OPERA 8tE status within 7 days or initiate and maintain operation of the remaining OPERA 8LE control room emergency air filtration system in the recirculation mode, b.

With both control room emergency air filtration systems inoperable, or with the OPERABLE contro' room emergency air filtration system, required to be in the recirculation acde by ACTION a being powered by an OPERABLE emergency power source, suspend al operations involving CORE ALTERAT;.0NS or positive re, activity changes SURVEILLANCE RE0UIREMENTS 4.7.6.2 The control room emergency air filtration trains 1

demonstrated OPERA 8LE per the applicable Surveilla(S-8) shall be 4.7.6.1.

nce Requirements of I

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WATERFORD - UNIT 3 3/4 7-18 Amendment No.115

PLANT SYSTEMS 3/4.7.6.3 CONTROL ROOM AIR TEMPERATURE LIMITING CONDITION FOR OPERATION 3.7.6.3 Two independent control room air conditioning units shall be OPERABLE.

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

&GI1Qti:

a.

With one control room air conditioning unit inoperable, restore the l

inoperable unit to OPERA 8LE status within 7 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 COLD SHUTDOW within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

l b.

With two control room air conditioning units inoperable, return one unit to an OPERABLE status within I hour or be in 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 COLD SHUTDOW 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 4.7.6.3 Each control room air conditioning unit shall be demonstrated l-OPERABLE:

i 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 verifying that the operating control room air conditioning unit is maintaining average control room air temperature less than or equal to 80"F.

l b.

At least quarterly, if not performed within the last quarter, by L

verifying that each control room air conditioning unit starts and l

operates for at least 15 minutes.

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WATERFORD - UNIT 3 3/4 7-18a Amendment No.115

PLANT SYSTEMS 141 7.6.4 CONTROL ROOM AIR TEMPERATURE LIMITING CONDITION FOR OPERATION 3.7.6.4 Two independent control room air conditioning units shall be OPERABLE.

APPLICABILITY: MODES 5 and 6.

ACIl0!i:

a.

With one control room air conditioning unit inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining 0PERABLE control room air conditioning unit.

b.

With both control room air conditioning units inoperable, or with the OPERABLE control room air conditioning unit, required to be in operation by ACTION a, not capable of beinfl powered by an OPERABLE emeqency power source, suspend all operat< ons involving CORE ALTERTIONS or positive reactivity changes.

i SURVEILLANCE REQUIREMENTS l

4.7.6.4 The control' room air conditioning units shall be demonstrated OPERABLE per the Surveillance Requirements of 4.7.6.3.

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WATERFORD - UNIT 3 3/4 7-18b Amendment No.115 s

PLANT SYSTEMS 3/4.7.6.5 CONTROL ROOM ISOLATION AND PRESSURIZATION l

LIMITING CONDITION FOR OPERATION l

3.7.6.5 The control room enyslope isolation and pressurization boundaries

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shall be OPERA 8LE.

APPLICABILITY: All MODES.

EllQH:

-a.

With either control room envelope isolation valve in a normal outside air flow path inoperable, maintain at least one isolation valve in the flowpath OPERA 8LE, and either restore the inoperable valve to OPERABLE status with 7 days or isolate the affected flow path 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 any Control Room Emergency Filter Outside Air Intake valve (s) inoperable, maintain at least one of the series isolation valves in a flowpath OPERA 8LE, and either restore the inoperable valve (s) to OPERA 8LE status within 7 days or isolate the affected flow path within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c.

With more than one Control Room Emergency Filter Outside Air Intake flow path inoperable, maintain at least one flow path per intake operable and restore an additional flow path to operable status within 7 days or, be in NOT 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 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 />.

d.

With the control room envelope inoperable as a result of causes other than those addressed by ACTION (a), (b), or (c) above:

I 1.

Within I hour and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter while

'the control room envelope is inoperable, verify that.the Emergency Breathing Airbanks pressure is greater than or equal to 1800 psig.

2.

MODES 1-4:

a.

If the cause of control room envelope inoperability is due l

to a known breach in the envelope of less than or equal to one square foot total area or'the breach is associated with a permanent sealing mechanism (e.g., blocking open or removing a door) then operation may continue for up to 7 days after the control room envelope is declared inoperable. Otherwise, be in HOT STAN08Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 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 />.

WATERFORD - UNIT 3 3/4 7-18c.

Amendment No.115 s

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PLANT SYSTEMS LIMITING CONDITION FOR OPEPt TION ACTION:

(Cer.tinued) b.

If the cause'of control room envelope inoperability is unknown identify the cause within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

If the cause of the failure is due to a breach within the allowable limits of ACTION d.2.a then operation may continue for up to 7 days after the control room envelope is declared inoperable. Otherwise, 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 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 />.

c.

Should a toxic gas event occur, take immediate steps to restore control room envelope integrity.

3.

MODES 5 and 6:

a.

Suspend all operations involving CORE ALTERATIONS or positive reactivity changes and if a toxic gas event occurs, take immediate steps to restore control room envelope' integrity.

SURVEILLANCE REQUIREMENTS 4.7.6.5 The control room envelope isolation and pressurization bcundaries shall be demonstrated OPERABLE at least once per 18 months by:

a.

Verifying that the control room envelope can be maintained at a positive pressure of greater than or equal to 1/8 inch water gauge relative to the outside atmosphere with a make-up air flowrate less than or squal to 200 cfm during system operation.

b.

Verifying that on a toxic pas detection test signal, the system automatically switches to the isolation mode of operation.

c.

Verifying that on a safety injection actuation test signal or a high radiation test sigaal, normal outside air flow paths isolate.

WATERFORD - UNIT 3 3/4 7-18d Amendment No.115 s

l PLANT SYSTEMS BASES 3/4.7.5 FLOOD PROTECTION The limitation on. flood protection ensures that facility protective actions will be taken in the event of flood conditions. The limit of elevation 27.0 ft..*an Sea Level is based on the maximum elevation at which the levee provides protection, the nuclear plant. island structure provides. protection to safety-related equipment up to elevation +30 ft Mean Sea Level.

3/4.7.6.1 and 3/4.7.6.2 CONTROL ROOM EMERGENCY AIR FILTRATION SYSTEM-During ari emergency, both S-8 units are started to provide filtration and adsorption of outside air and control room envelope recirculated air (reference:

FSAR6.4.3.3). Dosages received after a full power design basis LOCA were calculated to be orders of magnitude higher than other accidents involving radiation releases to the environment (reference:

FSAR Tables 15.6-18,15.7-2,15.7-4,15.7-5,15.7-7). Because the consequences of a full power design basis LOCA are more severe than those occurring during COLD SHUTDOWN and REFUELING, a separate specification, 3/4.7.6.2, requires only one OPERA 8LE S-8 unit to guard against accidents during Modes 5 and 6.

The OPERABILITY of this system anet control room design provisions are based on limiting the radiation exposure to personnel occupying the control room to 5 ren or less whole body, or its equivalent. This 'iinitation is i

consistent with the requirements of General Design Criterion 19 of Appendix A, j

10 CFR Part 50.

Operation of the system with the heaters on for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> contin-uous.over a 31-day period is sufficient to reduce the buildup'of moisture on the adsorbers and HEPA filters. Obtaining and analyzing charccal samples after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of adsorber operation (since the last sample and analysis) ansures that the adsorber maintains the efficiency assumed in the safety analysis and l.

is consistent with Regulatory Guide 1.52.

3/4.7.6.3 CONTROL tt00M AIR TEMPERATURE 1

Maintaining the control room air temperature less than or equal to 80'F l

ensures that (1) the ambient air temperature does not exceed the allowable air temperature for continuous duty rating for the equipment ard instrumentation in l

the control room, and (2) the control room will remain habitable for operations i

personnel during plant operation.

The Air Conditioning System'is designed to cool the outlet air to approximately 55'F. Theu, non-safety-related near-room heaters add enough heat i

to the air stream to keep the rooms between 70 and 75'F. Although 70 to 75*F is the normal control band, it would be too restrictive as an LC0. Control l

WATERFORD - UNIT 3 8 3/4 7-4a Amendment No.

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PLANT SYSTEMS i

BASES CONTROL ROOM AIR TEMPERATURE ~(Continued)

J Room equipment was specified for a more general temperature range to 45 to i

120*F. A prnvision for the CPC microcomputers, which might be more sensitive i

to heat, is not required here. Since maximum outside air make-up flow in'the l

. normal ventilation mode comprises less than. ten percent of the air flow from an j

AM-12 unit, outside air temperature has little affect on the AH-12s cooling coil heat load. Therefore, the ability of an AH-12 unit to maintain control room temperature in the normal mode gives adequate assurance of its capability for emergency situations.

3/4.7.6.4 CONTROL ROOM ISOLATION AND PRESSURIZATION This specification provides the operability requirements for the control i

room envelope isolation and pressurization boundaries. The Limiting Condition for Operation (LCO) specifies specific ACTION STATEMENTS for inoperable components of the control room ventilation systems, separate from the S-8 and AH-12 units. The operability of the remaining parts of the system affect the

.. ability of the control room envelope to pressurize.

ACTION STATEMENTS a and b focus or maintaining isolation characteristics.

3 The valves in the flow path referred to in ACTION a are HVC-102 & HVC-101. The Outside Air Intake (OAI) " series isolation valves" of ACTION ' and c are as j

follows:

I NORTH OAI - HVC-202B & HVC-201A HVC-202A & HVC-2018 SOUTH OAI - HVC-2048 & HVC-203A HVC-204A & HVC-2038 ACTION STATEMERT c preserves the cperator action (i.e., manually initiated filtered pressurization) that maintains the control roca envelope at a position pressure during a radiological emergem:y. As indicated above each l

OA! series isolation valve is powered by the opposite train. With more than j

one OAI flow path inoperable a single failure (i.e., train.A or 8) could prohibit the ability to maintain the control envelope at a positive pressure.

I Therefore, in the specified condition, ACTION c requires an additional flow

)

path to be returned to service within 7 days, a

ACTION STATEMENT d.2.a is intended to address-an intentional breach in the control room pressurization boundary as necessary to support maintenance or modification.- A breach of this nature shall be limited in size and governed under administrative controls. The size restrictions as stated in the ACTION are such that should a toxic event occur control room integrity can be immediately restored as described below. ACTION STATEMENT d.2.b is intended to

. restore pressurization ability as soon as possible for unintended breaches in the envelope. The 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to locate an unidentified breach is based on an WATERFORD - UNIT 3 B 3/4 7-4b Amendment No.115 i

PLANT _iY_SIEMS BASES CONTROL ~ ROOM ISOLATION AND PRESSURIZATION (Continued) evaluation that considered troubleshooting tasks that wauld be performed as necessary should the integrity of the Control Room Envelope pressure boundary fall into question.

Estimated times associated with each task were based on sound engineering judgement. The ACTION statements also recognize the MODE-independent nature of the toxic chemical threat and provides for operator protection in the event of a toxic chemical release concurrent with a breach in the control room envelope. In addition, provisions have been added to the specification that, in the event of a toxic chemical event that threatens control room habitability while in the ACTION statements, "immediate' steps" will be initiated to place the plant-in a safe condition.

In this context, the phrase "immediate steps" is taken to mean that the operators should immediately take reasonable action to restore a known breach in the envelope to an air-tight condition. Amplifying instructions are provided in Waterford 3 Administrative procedures. which impose special controls for work that will breach the control room envelope.

3/4.7.7 CONTROLLED VENTILATION AREA SYSTEM The OPERABILITY of the controlled ventilation area system ensures that radioactive materials leaking from the penetration area or the ECCS equipment within the pump room following a LOCA are filtered prior to reaching the environment. The operation of this system and the resultant effect on offsite dosage calculations was assumed in the safety analyses.

WATERFORD - UNIT'3 8 3/4 7-4c Amendment No.115

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NPF-38-204 ATTACHMENT B i

PROPOSED TECHNICAL SPECIFICATIONS I

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PLANT SYSTEMS

)]4.7.6.1 CONTROL ROOM EMERGENCY AIR FILTRATION SYSTEM M ONDITION FOR OPERATION

-3.7.6.1 Both control room emergency air filtration trains (S-8) shall be OPERABLE.

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

EllQti:-

a..

With one control room emergency air filtration train inoperable, either restore the.inoperabia train to OPERABLE status within 7 days or be in at least HOT STAN08Y 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 />.

b.

With both control room emergency air filtration trains inoperable, restore one train to OPERA 3LE status within I hour 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 CGLD 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 4.7.6.1 Each control room air filtration train (S-8) shall be demonstrated OPERABLE:

a.

At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 10 continuous hours with the heaters on.

b.

At least once per 18 months or (1) after any structural maintenance L

- on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system by:

i-1.

Verifying that the filtration train satisfies the in-place

')

testing accoptance criteria and uses the test procedures of l

Regulatory Positions C.5.a. C.5.c and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rate is j

4225 cfm 1105.

2.-

Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in l

accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Positics f. 6.a of Regulatory Guide 1.52, Revision 2, March 1978.

y J T.E3 FORD - UNIT 3 3/4 7-16 Amendment No. 115 h -~

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PLANT SY!,fEMS 3/4.7.0.2 CONTROL ROOM EMERGENCY AIR FILTRATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.2 Two control room emergency air filtration trains (S-8) shall be OPERABLE.

APPLICABILITY: MODES 5 @ 6

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AGILE:

G) hoe lat. sea 4]Ie.s-a.

With one control roos emergency air filtration system inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE control room emergency air filtration system in the recirculation mode.

b.

With both control room emergency air filtration systems inoperable, or with the OPERA 8LE c>ntro room emergency air filtration system, required to be in the recirculation mode by ACTION a not capable of being powered by an OPERABLE emergency power source,, suspend all operations involving CORE ALTERAT; ONS toppositive sectivity r,penges).

SURVEILLANCE REQUIREMENTS I

4.7.6.2 The control room emergency air fil ation trains (S-8 shall be demonstrated OPERA 8LE per the appl cable Surveillance) Requirements 4.7.6.1.

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Auel < ass < m U'O WATERFORD - UNIT 3 3/4 7-18 Amendment No.115 s

PLANT SYSTEMS 3/4.7.6.3 CONTROL ROOM AIR TEMPERATURE LIMITING CONDITION FOR OPERATION 3.7.6.3 Two independent contrdi room air conditioning units shall be OPERABLE.

APPLICABILITY : MODES 1, 2, 3, and 4.

ACTION:

a.

With one control room air conditioning unit inoperable, restore the inoperable unit to OPERA 8LE status within 7 days or be in H0T 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 />.

-b.

With two control room air conditioning units inoperable, return one unit to an OPERABLE status within I hour or be in 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 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 4.7.6.3 Each control room air conditioning unit shall La 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 verifying that the operating control room air conditioning unit is maintaining average control room air temperature less than.or equal to 80*F.

]

b.

At least quarterly, if not performed within the last quarter, by verifying that each control room air conditioning unit starts and operates for at least 15 minutes.

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alw w WATERFORD - UNIT 3 3/4 7-18a Amendment No.115 s

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PLANT SYSTEMS 3/4.7.6.4 CONTROL ROOM AIR TEMPERATURE LIMITING CONDITION FOR OPERATION 3.7.6.4 Two independent contro1 room air conditioning units shall be OPERABLE.

irrad:decl o

APPLICABILITY: MODES 5 @.

>d

"^d

"' m F d amdes:-

3 a.

With one control room air conditioning unit inoperable, restore the inoperable system to OPERA 8LE status within 7 days or initiate and maintain operation of the remaining 0PERABLE control room air conditioning unit.

b.

With both control room air conditioning units inoperable, or with the OPERA 8LE control room air conditioning unit, required to be in operation by ACTION a, not capable of being powered by an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS[cypositiverpactivnyenjagej.

o SURVEILLANCE REQUIREMENTS 4.7.6.4 The contro room air conditioning units shall be demonstrated OPERABLE r the Surveillance Requirements of 4.7.6.3.

ard movemed J imbded A I auc AI;cs WATERFORD - UNIT 3 3/4 7-18b Amendment No.110 s

PLANT SYSTEMS 3/4.7.6.5 CONTROL ROON ISOLATION AND PRESSURIZATION LIMITING CONDITION FOR OPERATION 3.7.6.5 The control room envilope isolation and pressurization boundaries shall be OPERABLE.

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r J A ul APPLICABILITY

All MODE.

E11Q5:

(

ass M u a.

With either control room envelope isolation valve in a normal outside air flow path inoperable, maintain at least one isolation valve in the flowpath OPERABLE, and either restore the inoperable valve to OPEpABLE status with 7 days or isolate the affected flow path 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 any Control Room Emergency Filter Outside Air Intake valve (s) inoperable, maintain at least one of the series isolation valves in a flowpath OPERABLE, and either restore the inoperable valve (s) to OPERA 8LE status within 7 days or isolate the affected flow path within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c.

With more than one Control Room Emergency Filter Outside Air Intake flow path inoperable, aaintain at least one flow path per intake operable and restore an additional flow path to operable status within 7 days or, be in HOT STAND 8Y within the next 5 hour: and 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 />.

d.

With the control room envelope inoperable as a result of causes other than those addressed by ACTION (a), (b), or (c) above:

1.

Within I hour and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter while the control room envelope is inoperable, verify that the Emergency Breathing Airbanks pressure is greater than or equal to 1800 psig.

2.

MODES 1-4:

a.

If the cause of control room envelope inoperaellity is due to a known breach in the envelope of less than or equal to one square foot total area or the breach is associated with a permanent sealing mechanism (e.g., blocking open or removing a door) then operation may continue for up to 7 days after the control room envelope is declared inoperable. Otherwise, be in H0T 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 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 />.

WATERFORD - UNIT 3 3/4 7-18c Amendment No.115 i

M r. CONDITION FOR OPERATION ACllDli:

(Continued) b.

If the cause of control room envelope inoperability is unknown identify the cause within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

If the cause of the failure is due to a breach within the allowable limits of ACTION d.2.a then operation may continue for up to 7 days after the control room envelope is declared inoperable. Otherwise, be in 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 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 />.

c.

Should a toxic gas event occur, take immediate steps to restore control room _envelopogrity_.

3.

MODES S 6 6:

) Gd a ss / ""* *

f e mb) es Suspendalloperatonsiiv'o'TvingCOREALTERATIONS domiivviracuum cnances) and if a toxic gas eve @nt a.

occurs, take immedLate steps to restore control roon l

envelope a _ +,e,w. w M - %

SURVEILLANCE REQUIREMENTS 4.7.6.5 The control room envelope isolation and pressurization boundaries shall be demonstrated OPERABLE at least once per 18 months by:

a.

Verifying that the control room envelope can be maintained at a positive pressure of greater than or equal to 1/8 inch water gauge relative to the outsida atmosphere with a make-up air flowrate less than or equal to 200 cfm during system operation.

b.

Verifying that on a toxic gas detection test signal, the system automatically switches to the isolation mode of operation.

c.

Verifying that on a safety injection actuation test signal or a high radiation test signal, nomal outside air flow paths isolate.

WATERFORD - UNIT 3 3/4 7-18d Amendment No.115

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e PLANTSYSTY BASES 3/4.7.5 FLOOD PROTECTION The limitation on flood protection ensures that facility protective actions will be taken in the event of flood conditions. The limit of elevation 27.0 ft Mean Sea Level is based on the maximum elevation at which the levee provides protection, the nuclear plant island structure provides protection to safety-related equipment up to elevation +30 ft Mean Sea Level.

3/4.7.6.1 and 3/4.7.6 l

During an emergency, both 5-8 units are started to provide filtration and adsorption of outside air and control room envelope recirculated air (reference:

FSAR 6.4.3.3).

Dosages received after a full power design basis LOCA were calculated to be orders of magnitude higher than other accidents involving radiation releases to the environment (reference: FSAR Tables 15.6-18, 15.7-2, 15.7-4, 15.7-5, 1.5.7-7) J.Becau Ine consequences or a ul ower sign Dasis LOCA are re severe than t se occurring during C0 SHUT and REFUELING, a parate specifica

n. 3/4.7.6.2, require only one OP __LE S-8 unit to gu aaainst acciden during Modes 5 and 6.

The OPERABILITY of this system and control reos design provisions are based on limiting the radiation exposure to personnel occupying the control room to 5 ren or less whole body, or its equivalent. This limitation is consistent with the requirements of General Design Criterion lg of Appendix A, I

10 CFR Part 50.

p Operation of the system with the heaters on for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> contin-l uous over a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters. Obtaining and analyzing charcoal samples after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of adsorber operation (since the last sample and analysis) ensures that the adsorber maintains the efficiency assumed in the safety analysis and is consistent with Regulatory Guide 1.52.

3/4.7.6.3fCONTROLROOMAIRTEMPERATM

^

Maintaining the control room air temperature less than or equal to 80*F ensures that (1) the cubient air temperature does not exceed the allowable air temperature for continuous duty rating for the equipment and instrumentation in the control room, and (2) the control room will remain habitable for operations personnel during plant operation.

The Air Conditioning System is designed to cool the outlet air to approximately 55'F. Then, non-safety-related near-room heaters add enough heat 1

to the air stream to keep the rooms between 70 and 75*F. Although 70 to 75'F is the normal control band, it would be too restrictive as an LCo. Control WATERFCR0 - UNIT 3 P 3/4 7-4a Amendment No.

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Ao a LANT SYSTEM l

BASES CONTROL ROOM AIR TEMPERATURE (Continued)

Room equipment was specified for a more general temperature range to 45 to 120*F. A provision for the CPC microcomputers, which might be more sensitive to heat, is not required here.

Since maximum outside air make-up flow in the normal ventilation mode comprises less than ten percent of the air flow from an AH-12 unit, outside air temperature has little affect on the AH-12s cooling coil heat load. Therefore, the ability of an AH-12 unit to maintain control room temperature in the normal mode gives adequate assurance of its capability or emergency situations.

3/4.7.6.2 CONTROL ROOM ISOLATION AND PRESSURIZATION j

This specification provides the operability requirements for the control room envelope isolation and pressurization boundaries.

The Limiting Condition for Operation (LCO) specifies specific ACTION STATEMENTS for inoperable components of the control roos ventilation systems, separate from the S-8 and AH-12 units.

The operability of the remaining parts of the system affect the ability of the control room envelope to pressurize.

ACTION STATEMENTS a and b focus on maintaining isolation characteristics.

The valves in the flow path referred to in ACTION a are HVC-102 & HVC-101.

The Outside Air Intake (OAI) " series isolation valves" of ACTION b and c are as follows:

NORTH OAI - HVC-2028 & HVC-201A HVC-202A & HVC-201B SOUTH OAI - HVC-204B & HVC-203A HVC-204A & HYC-2038 ACTION STATEMENT c preserves the operator action (i.e., manually initiated filtered pressurization) logical emergency.that maintains the control room enve a

Wom pressure during a radio As indicated above each OAI series isolation valve is powered by the opposite train. With more than one OAI flow path inoperable a single failure (i.e., train A or 8) could prohibit the ability to maintain the control envelope at a positive pressure.

Therefore, in the specified condition, ACTION c requires an additional flow path to be returned to service within 7 days.

ACTION STATEMENT d.2.a is intended to address an intentional breach in the control room pressurization boundary as necessary to support maintenance or modification. A breach of this nature shall be limited in size and governed under administrative controls. The size restrictions as stated in the ACTION are such that should a toxic event occur control room integrity can be immediately restored as described below. ACTION STATEMENT d.2.b is intended to restore pressurization ability as soon as possible for unintended breaches in the envelope.

The 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to locate an unidentified breach is based on an WATERFORD - UNIT 3 8 3/4 7-4b Amendment No.115

PLANT SYSTEMS BASES CONTROL ROOM ISOLATION AND PRESSURIZATION (Continued) evaluation that considered troubleshooting tasks that would be performed as necessary should the integrity of the Control Room Envelope pressure boundary fall into question. Estimated times associated with each task were based on sound engineering judgement. The ACTION statements also recognize the MODE-independent nature of the toxic chemical threat and provides for operator protection in the event of a toxic chemical release concurrent with a breach in the control room envelope. In addition, provisions have been added to the specification that, in the event of a toxic chemical event that threatens control room habitability while in the ACTION statements, "immediate steps" will be initiated to place the plant in a safe condition.

In this context, the phrase "immediate steps" is taken to mean that the operators should immediately take reasonable action to restore a known breach in the envelope to an air-tight condition. Amplifying instructions are provided in Waterford 3 Administrative procedures, which impose special controls for work that will breach the control room envelope.

3/4.7.7 CONTROLLED VENTILATION AREA SYSTEM The OPERABILITY of the controlled ventilation area system ensures that radioactive materials leaking from the penetration area or the ECCS equipment within the pump room following a LOCA are filtered prior to reaching the environment. The operation of this system and the resultant effect on offsite dosage calculations was assumed in the safety analyses.

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WATERFORD - UNIT 3 8 3/4 7-4c AmeMment No. tic s

NPF-38-204 ATTACHMENT C REFERENCES

l l

l 1'

NPF-38-204 LIST OF REFERENCES 1.

LER 97-022-00; Transmitted via Letter from T.R. Leonard to U.S. NRC Document Control Desk Dated July 18,1997.

2.

FSAR Section 15.4.1.5; CVCS Malfunction (Inadvertent Boron Dilution).

3.

FSAR Section 15.7.3.4; Design Basis Fuel Handling Accident.

4.

Waterford 3 Letter W3F1-95-0139 from R. F. Burski to U.S. NRC Document Control Desk Dated August 30,1995.

.5.

NRC Letter from C. P. Patel to R. P. Barkhurst Dated October 4,1995.

NPF-38-204 REFERENCE 1 LER 97-022-00 TRANSMITTED VIA LETTER FROM T.R. LEONARD TO U.S. NRC DOCUMENT CONTROL DESK DATED JULY 18,1997 l.

c - _ _ :____

d v

Ent^r etions. Inc.

I504 464 3 2 7.R. "Tod" Leonard STni$$Tl%

wateoro 3 W3F1-97-0166 A4.05 i

PR i

July 18,1997 l

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 i

)

Subject:

Waterford 3 SES Docket No. 50-382 l

License No. NPF-38 Reporting of Licensee Event Report Gentlemen:

Attached is Licensee Event Report (LER) Number 97-022-00 for Waterford Steam Electric Station Unit 3. This report provides details of a positive reactivity addition to the Reactor Coolant System in violation of Technical Specification 3.7.6.2b. This condition is being reported pursuant to 10CFR50.73(a)(2)(1)(B).

Very truly yours, T.R. Leonenk -

General Manager l

Plant Operations TRUWDM/tjs Attachment cc:

E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),

A.L. Garibaldi, J.T. Wheelock - INPO Records Center, J. Smith, N.S. Reynolds, NRC Resident inspectors Office, Administrator-LRPD

@ 'd 4 0 (; e Q S O $5ff

Reporting or Licensee Event Report W3F1-97-0166 Page 2 July 18,1997 ccMail:

J.W. Yelverton (M-ECH-65)

C.M. Dugger (W-GSB-300) i F.J. Drummond (W-GSB-305)

I E.C. Ewing (W-GSB-310)

J.M.O'Hom (W-EEC-650)

A.J. Wrape (W-GSB-315)

D.C. Mathony (W-MSB4-307)

T.J. Gaudet (W-GSB-318)

C.J. Thomas (W-GSB-318)

R.E. Allen (W-GSB-102)

B.E. Meyers (W-ADM-565)

J.B. Holman (W-GSB-320)

J. Lanci (W-MSB4-220) r r J.J. Zabritski (W-ADM-567)

L.F. Daughtery (GGNS - ADM/LIC)

S.J. Bethey C.A. Bottomiller R.J. King T.W. Gates K. Godfrey C.Gunn l

W.K. Hughey IEA D.N. Lorfing J.M. Manze!!a T.J. Sibley bec:

SRC Member:

(J.M. Hendrie)

(D.C. Shelton]

(S. Ebneter) l l

G. Fonseca (2 copies)

(W-MSB4-360) l S.T. de St. Germain (W-ADM-565) l Waterford 3 Records Center (W-GSB-100)

LER File Drawer j

Licensing Green Folder File

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DATE n5l AlSTRACT (Luvut to 1400 speoes,i.e., appresemately 15 e6ngle opeoed typewettten uneel ne On June 10,1997, at 2112 hours0.0244 days <br />0.587 hours <br />0.00349 weeks <br />8.03616e-4 months <br />, Control Room Emergency Filtration Units A and B were declared inoperable to install gravity dampers per Design Change DCP-3536.

Technical SpeelAcetion (TS) 3.7.6.2b requires the suspension of all operations involving positive reacthty changes. On June 12,1997, at 0132 hours0.00153 days <br />0.0367 hours <br />2.18254e-4 weeks <br />5.0226e-5 months <br />, OP-903-115, " Train A Integrated Emergency Diesel Generator / Engineering Safety Features Tes'," was performed. As a result of this surveillance, approximately 9% of the volume of Boric Acid Makeup Tank B was pumped into the Reactor Coolar't System (RCS). This l

resulted in RCS boron concentration being gnsator than Refueling Water Storage Pool (RWSP) concentration. On June 14,1997, Operations performed a makeup to the RCS using the operable boration flow path from the RWSP. Because the RWSP boron concentration was lower than the RCS, this condition is reportable per 10 CFR 50.73(a)(2)(i)(B) as a violation of TS 3.6.7.2b. All operations involving possible positive reactivity additions were stopped until the TS action statements were exited. TS 3.7.6.2b will be revised to remove the reference to positive reactivity addition. This event did not compromise the health and safety of the public.

I

U.S. NUCLEAR REqutATORY C0 emes 840N N 880A LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION l

FACEJTY NAM Op OOCIWT LER N M (W PAGE (3) 1 05000 2 OF 6 WATERFORD STEAM ELECTRIC STATION UNIT 3 382 97 ~ 022

~ 00 isniIN more space e requwet une endnonel coven of MRC form 304A) n 7)

REPORTABLE OCCURRENCE Technical Specification (TS) 3/4.6.7.2, " Control Room Emergency Air Filtration System,"

Action b, states with both Control Room Emergency Filtration Units (CREFU) inoperable, suspend all operations involving core alterations or positive reactivity changes. On June 14,1997, Operations performed a makeup to the Reactor Coolant System (RCS) [AB) using the operable boration flow path from th ?efueling Water l

Storage Pool (RWSP). At the time of this operation, RCS boron co.. entration was 2290 parts per million (ppm) and the RWSP concentration was 2266 ppm. Therefore, l

this action constituted a positive reactivity addition and is being reported in accordance with 10CFR50.73(a)(2)(1)(B) as an operation or condition prohibited by TS.

INITIAL CONDITIONS At the time this condition was discovered, Waterford 3 was in Operational Mode 5 (Cold Shutdown) while conducting Refueling Outage eight (RF08). The RCS was at approximately 105 degrees Fahrenheit (F) and 35 pounds per square inch atmospheric l

(psia) pressure. Both CREFU trains were inoperable due to installation of a desig~n change. Valvs BAM-141, Boric Acid Makeup Header Flow Control Valve, was removed from service to troubleshoot the valve controller. TS Action Statements 3.7.6.2b was in effect.

I EVENT DESCRIPTION On June 10,1997, at 2112 hours0.0244 days <br />0.587 hours <br />0.00349 weeks <br />8.03616e-4 months <br />, the Operations' shift crew (the crew) declared CREFU trains A and B inoperable tu install gravity dampers [UD-MP) in accordance with Design Change Package (DCP) 3536. TS 3.7.6.2b, which directs suspension of all operations involving core alterations or positive reactivity changes, was entered. At that time, RCS boron concentration was 2272 ppm and RWSP boron concentration was 2274 ppm.

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U.S. NUCLEAR REGUL.ATORY Cmmammma was LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION PA"'"TY """ (1)

C91--T LER M (#

11 PAGE (3)

MAft E

AL 05000 3

OF 6 WATERFORD STEAM ELECTRIC STATION UNIT 3 382 97 022 00 isai W more asece se regured, use ed*ewW cofwee of AMC.h Jd4A1 (17)

On June 12,1997, at 0132 hours0.00153 days <br />0.0367 hours <br />2.18254e-4 weeks <br />5.0226e-5 months <br />, the crew commenced Operations Surveillance Procedure OP-903-115, " Train A Integrated Emergency Diesel Generator / Engineering Safety Features Test." By 0150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br />, RCS prcssure had slowly risen from 28 psig to 38 psig. Boric Acid Mekeup (BAM) (CB) Pumps A and B, which were started as part of the OP-903-115 surveillance, pumped approximately 9% of BAM Tank A volume into the RCS. Sample results revealed that RCS boron concentration rose to 2300 ppm which was above the RWSP boron concentration of 2274 ppm.

On June 14,1997, the Chemistry department requested a purge of the Volume Control Tank (VCT) to reduce RCS ammonia levels. Realizing the evolution would require

1. r making up to the RCS from the RWSP, which was at a lower boron concentration, the crew performed several Shutdown Margin (SDM) calculations with different boron concentrations to ensure SDM would be maintained. The calculations demonstrated the not change in reactivity from when the plant entered TS 3.7.6.2b to when the RCS makeup occurred would be negative. in addition, since the makeup source was the operable boration flowpath, the crew concluded the makeup would not violate the intent of TS 3.7.6.2b. These points were discussed with the Operations' Manager who concurred with the conclusions. At that point, the crew performed the VCT purge evolution that included' making up to the RCS from the RWSP.

CAUSAL FACTORS The apparent root cause of this event was incorrect assumptions by Operations department sisNand management, The crew assumed that since the not change in reactivity fmm the RCS makeup e

was negative, the intent of TS 3.7.6.2b was met, The crew assumed if the makeup source was the operable boration flowpath, it e

would not constitute a violation of TS 3.7.6.2b. Even though the flowpath could be used to satisfy SDM requirements in an emergency, normal makeup constituted a positive reactivity change.

misom um we

MCFORM344A U.S. NUCLEAR AEGULATORY C006SSWO 16ae LICENSEE EVENT REPORT ILER)

TEXT CONTINUATION P"'TY "fr (1)

E9_ -fi LaR m te PAGE (3)

YtM E

M IMTERFORD STEAM ELECTRIC STATION UNIT 3 0

E 4

6 97 022 00 e r.n u (N trwre space se reouret une enwoonal cepen of MC fam 366Al (17)

The following contributing cause was identified:

The action statements of TS 3.7.6.2b, which require suspension of positive reactivity changes, are overty conservative and unnecessary, in NUREG 1432, " Standard TS for Combustion Engineering Plants," the bases for this TS states the system is designed to maintain the Control Room (NA] environment for 30 days of continuous occupancy after a Design Basis Accident without exceeding a 5 rem whole body dose or its equivalent to any part of the body. This does not involve the suspension of activities that would cause a positive reactivity change.

r CORRECTIVE MEASURES Waterford 3 will submit a TS change for TS 3.7.6 to be more in line with NUREG 1432, " Standard TS for Combustion Engineering Plants," which reads:

With two Control Room Emergency Air Cleanup Systems inoperable (in modes 5 and 6, or] during movement of irradiated fuel assemblies (or during core alterations), immediately suspend core alterations and suspend movement of irradiated fuel assemblies.

Until the TS change takes place, Operations management has provided the following direction to Control Room personnel:

i We need to be exceedingly sensitive to any positive reactivity changes that we l

may cause whenever we are in an Action Statement that reads, "... suspend all l

operations involving core alterations or positive reactivity changes." Therefore, we cannot use the RWSP as a source of makeup to the RCS if it has a lower boron concentration, even if it is well within any shutdown margin consideration and a proper boration flowpath. We cannot place a purification ion exchanger in service if it is not saturated with the same concentration of boron as the RCS.

We cannot heatup the plant with a positive moderator temperature coefficient (or cool it down if the moderator temperature coefficient is negative). Any menem mmisen

NRCFORM344A U.S. NUCLEAR REOULATORY C0044ss40N less LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION F^'* 'TY "^2"l til G - -Fi LER m (e)

Pact (3) 05000 OF 5

6 WATERFORD STEAM ELECTRIC STATION UNIT 3 382 97 022 00 TiDG (W more space e rowed une addtonet conne of MFC M 366A) (17) operations involving positive reactivity changes are of concem and should be screened accordingly.

SAFETY SIGNIFICANCE Following the receipt of a Safety hjection Actuation Signal or the detection of a high radiation at the outside air intake, the CREFU system is designed to attain a positive pressure of 1/8 inch water gauge with less than or equal to 200 cfm of outside air. The operability of this system and Control Room design provisions are based on limiting radiation exposure to five rem or less whole body, or its equivalent.

r r The bases for TS 3/4.1.2, "Boration Systems," states, "With the RCS temperature below-200 degrees F, one injection system is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the additional restrictions prohibiting CORE ALTERATIONS and positive reactivity changes in the event the single injection system becomes inoperable."

TS 3.1.2.1, 3.1.2.3, and 3.1.2.7 were reviewed to verify that the RWSP satisfied all requirements as the boration water source. In Mode 5, the requirement is a minimum boron concentration of 1720 ppm and a minimum level of 12%. Operations Procedure l

OP-100-014, " Technical Specification and Technical Requirements Compliance,"

l requires a minimum boron concentration of 2050 ppm. The boron concentration of the l

RWSP at the time of the RCS makeup (2266 ppm) exceeded both of these requirements. The TS bases for SDM states below 200*F, the specified SDM ensures that sufficient time for operator actions exists between the initial indication of the debarstion and the total loss of SDM. RCS temperature at the time of this event was 105 degrees F.

Calculations were performed at various RCS boron concentrations to determine the amount of SDM available. The calculations illustrate the small change in RCS boron concentration as a result of this event had a minimal effect on SDM:

me namim se

N NRC FORM 344A U.S. 8AMX2AA REGULATORY cot 4GSS40N 44m LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACRJTY NARE (1)

QG%ss i L.2R N M (6)

PAGE (3)

TIM E

4 l

05000 6

OF 6

WATERFORD STEAM ELECTRIC STATION UNIT 3 382 97 022

- 00 TiXi W more space a requeed, une endnord coome of MC Form 3 dea) (17)

RCS Boron Keff SDM Comments 2300 ppm 0.921 8.6%

Maximum RWSP Modes 1-4 2297 ppm 0.921 8.5%

2290 ppm 0.922 8.5%

2200 ppm 0.930 7.6%

2050 ppm 0.943 6.0%

Minimum RWSP by OP-100-014 1720 ppm 0.974 2.7%

Minimum RWSP by TS Core Operating Limits Report (COLR) 3.1.1.1 states that SDM shall be greater than ora.-

equal to that shown in Figure 1, " Shutdown Margin as a Function of Cold Leg Temperature." COLR Figure 1 Indicates that with RCS temperature at approximately 105 degrees F when this event occurred, SDM is required to be greater than or equal to 1.0%. With the minor change in Keff and SDM that occurred as a result of the makeup, it can be seen that SDM was never in danger of being jeopardized. This event did not compromise the health and safety of the public.

SIMILAR EVENTS L

LER 96-002-00 was submitted due to Waterford 3's interpretation of TS 3.7.1.2a.

(

Waterford 3 did not consider the steam drivekEmergency Feedwater Pump inoperable l

when one of the steam supply valves was taken out of service. One occasion was l

discovered in which one valve was out of service for greater than the 72-hour action

- statement allowed.

ADDITIONAL INFORMATION Energy Industry Identification System (Ells) codes are identified in the text within brackets [ ].

l mes me nen un

1 t

i i

NPF-38-204 REFERENCE 2 FSAR SECTION 15.4.1.5 CVCS MALFUNCTION (INADVERTENT BORON DILUTION) i 1

i l

l I

l

\\

l l

1 L--_--------

1 WSES FSAR UNIT 3 154145 Radiological Consequences The radiological consequences of this event are less severe than the consequences of the inadvertent opening of the atmosphenc dump valve in Subsection 151.14.

1541.5 CVCS Malfunction (Inadvertent Boron Dilution) 15415.1 Identification of Causes and Frequency Classification l

The estimated frequency of a Chemical and Volume Control System (CVCS) malfunction resulting in t

inadvertent boron dilution classifies it as a moderate frequency incident as defined in Reference 1 of l

Section 15.0. The CVCS malfunction which results in unborated water being pumped at the maximum possible rate into the RCS by the demineralized water supply system is assumed to occur. For this to occur, one or more charging pumps must be on, the primary water makeup water pumps must be on, and the demineralized water supply system must be alsned to supply water to the charging pump suction via l

the volume control tank. Since at least three simultaneous equipment malfunctions would be required to l

J produce the above conditions, the incident could only be the result of improper operator action l

accompanied by a single equipment malfunction. Since boron dilution is conducted under stnct equipment procedural controls which specify limits on the rate and magnitude of any required change in boron concentration, the probability of a sustained or erroneous dilution is very low. Analysis of the Inadvertent Boron Dilution event initiated during each operational mode (defined in the Technical Specifications) was performed pnor to Cycle 3 due to the potential for smaller pnmary 2 system active mixing volume for modes 4 and 5 (with the RCS filled). Under some conditions the primary flow through a steam generator might stagnate. This could occur dunng an RCS cooldown using the Shutdown Cooling System if the Steam generator secondary side temperature becomes greater than the RCS temperature.

In this scenario, flow through a steam generator would make a transition from forward flow to reverse flow and might include a short penod of stagnartflow. This flow stagnation could also occur near the end of a long outage where core decay heat levels may be too small to provide sufficient driving head to move '

water through the steam generators The boron dilution analysis showed that for the same K, and j

' number of charging pumps, Mode 5 with the RCS partially drained resulted in the shortest available time l

for detection of the boron dilution event. Other Modes of Operation could 2 have a shorter time to loss of shutdown margin depending on the initial conditions (Kg, etc.) and number of cha#ging pumps.

In MoJe 4, operation of two charging pumps is allowed by Technical Specifications. The remaining charging pump is required to be isolated with power removed from it. In Mode 5 with Kg less than or equal to 0.97, operation with two charging pumps is allowed. in Mode 5 with Kg greater than 0.97, operation with one ch.,yiq pump is allowed. in Mode 6, opersbon with one charging pump is allowed.

15.4.1.5.2 Sequence of Events and Systems Operation The core is assumed to be inillegy subentical with the shutdown margin at the minimum value consistent with the technical specillection limit for the RCS condition. A CVCS malfuncbon occurs which causes unborated 2 water to be pumped into the RCS. The resulting decrease in RCS boron concentration adds reactivity to the core Prlor to 15 minutes (30 minutes for Mode 6) before shutdown margin is lost, a high l

neutron flux alarm on the startup flux channels provides an indicaton that a boron dilution event is in progress.

l s

1 15.4 15 Revision 9 (12/97)

WSES FSAR UNIT 3 This boron dilution alarm alerts the operators so that the dilution can be terminated. Operational procedures,in addition to this alarm, assure detection and termination of the boron dilution event before the shutdown margin is lost in accordance with the requirement of SRP 15.4.6.

SRP 15.4.6 specifies minimum intervals between the time when a boron dilution alarm announces an unplanned moderator dilution and the time of loss of shutdown margin:

a)

During refueling 30 minutes b)

During startup, cold shutdown, hot standby and power operation 15 minutes j

in satisfaction of these requirements LP&L provided to the NRC, in letter W3P82 3783, the Boron Dilution Alarm System setpoint analysis. The current setpoints meet these time requirements.

j 15.4.1.5.3 Core and System Performance a)

Mathematical Model Assuming complete mixing of boron in the RCS, the rate of change of boron concentration

{

during dilution is described by the following equation:

)

M

-W (1) where M

RCS mass C=

RCS boron concentration W=

charging mass flowrote of unborated water dC/dt is maximized by maximizing W and minimizing M.

Assuming I

W = constant, equal to the maximum possible value, and choosing M=

constant equal to the minimum value occurring during the boron dilution

incident, the solution of equation (1) can be written C(t) = C(o)e -t/Y (2) l 15.4 16 I

WSES-FSAR-UNIT 3 where Y = M/W = boron dilution time constant l

C(o) = initial boron concentration The time T rerJuin,d to dilute to enticality is given by

~#

' T = r in (3)

C:..

where C, v cntical boron concentration en b) input Parameters and initial Conditions Since coolant is circulated through the RCS by the Shutdown Cooling System, complete mixing of boron within the active RCS volume is assumed. The initial conditions and analysis parameters are chosen to minimize the interval from initiation of dilution to the time at which entcality is reached. The parameters for the Mode 5 partially drained case are presented below as an example.

1)

The technical specification lower limit on shutdown margin for the assumed RCS condition is used. This results in a subenbcality of at least 2.0%Ap for either technical specification condition of any CEA withdrawn or all CEAs fully inserted.

2)

The technical specification upper limit on l'w for Modes 3 - 5 is 0.99. However, the most adverse initial condition would be for an initial Kg, corresponding to 2.0%Ap subentical, since this would result in the core reaching cnbcality with no shutdown CEAs available at time of trip. Therefore, a maximem Kg of 0.98 is assumed.

3)

The RCS is assumed to be drained so that the water level is at the centerline of the hot leg nozzle. Assuming the coolant temperature is 200*F, the technical specification upper limit for cold shutdown, the resulting mass is 274,820 lbm.

4)

The flow from the charging pumps is assumed to be at their maximum rate; 44 gpm per pump. The corresponding mass flowrate, assuming cold liquid flow, is 6.12 lbm/sec per pump.

5)

The crincel boron comtration in Mode 5 cold snutdown with all CEAs inserted except for the smgle highest worth rod stuck out (N-1) and zero xenon is 1412 ppm. This l

concentrabon is casumed to minimize the time to loss of shutdown margin The initial subcnbcal boral concentrabon is found by adding the product of the inverse boron worth (84 ppm /%Ap) and the minimum shutdown margia. required to the entical boron concentrabon for Mode 5 with Kg of 0.98 is 1580 ppm.

15_4 17 Revision 9 (12/97)

l WSES-FSAR.MNIT.3 I

The parameters discussed above are summanzed in Table 15 417 j

c)

Results Using the above conservative 3 parameters in equation 3. the minimum possible time interval to ditu'e from the.ce. of 0.98 to enticality for Mode 5. partially drained with one charging pump operationalis greater than 80 minutes For all other combinations of RCS conditions. Keg. and number of charging pumps, the time to loss of shutdcwn margin is greater than 46 minutes A high neutron flux alarm on the startup flux channel will assure detection of a boron dilution event with at least 15 minutes (30 minutes for Mode 6) pnor to loss >>f shutdown margin as per l

requirements of SRP 15.4.

15 4.1.5.4 Barner Performance The barrier performance parameters dunng an inadvertent boron dilution would be less adverse than those dunng uncontrolled CEA withdrawal at power (Subsection 15.4.1.3) because there is no associatec power transient.

15.4.1.5.5 Radio'ogical Consequences There are no radiological consequences associated with this event.

15.4,1.6 Start of an inactive Reactor Coolant System Pume - Modes 3,4 or 5 With All Full Lensth CEAs on the Bottom No specific analysis of this event is provided for Modes 1 and 2 thee the Technical speciflations require that the reactor be subentical when less than four reactor coolant pumps are operating.

15.4.1.6.1 Ident$cabon of Cause 3 and Frequency Cicssificabon

. The estimateci frequency of an inadvertent startup of an inachve reactor coolant system pump classifies it as a moderate frequency incident as defined in Reference 1 of sechon 15.0.

The idle reactor coolant pump startup event is defined as the start uf a reactor coolant pump without observance of prescribed operahng procedures, assuming an initial conditiori in which one or more reactor coolants pumps are idle. This event is analyzed in support on the reduced Technical Specification shutdown margin requirements in subentical modes for Cycle 2.

15.4.1.6.2 Sequence of Events and Systeme operation If the temperature of the secondary system is significantly different from the core coolant temperature, then upon reach.,: cocient pump startup a rapid change in core coolant temperature occurs. Depending on the isothermal temperature coefilcient, a w,J ixi. ding change in core reachvity may occur.

)

Two cases were evolueled to determine the reachvity addition du6 to the inadvertent startup of a reactor cooient pump. The first case is delined as the set of conditions where the steam generator temperatur6 is less than the reactor coolor:t system tempuroture in this case the startup of an inactive purnp could cause a cooldown of the reactor coolytt system.

15.4-18 Revision 9 (12/97)

I t_

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1' NPF-38-204 REFERENCE 3 FSAR SECTION 15.7.3.4 DESIGN BASIS FUEL HANDLING ACCIDENT

WSES-FSAR-UNIT-3 Since the groundwater velocity in Zone i is appreciably less than Zone 3. activity level of the nearest surface water is an unrestncted area would be even less 15734 Design Basis Fuel Handli.9 Accidents 157.34.1 Identification of Causes and Frequency Classification The possibility of a fuel handling accident is remote because of the many interlocks and administrative controls and physicallimitations imposed on the fuel handling operations (refer to Subsection 9.14) All refueling operations are conducted in accoroance with presenbed procedures under direct surveillance of a supervisor technically trained in nuclear safety and fuel handling.

Before refueling operations start, RCS boron concentration will be increased until at least a 5%

subenticality er 2050 ppm boron is achieved, whichever is more limiting. This boron concentration is l

sufficient to keep the reactor at least 5.0% subentical with four-fingered Control Element Assemblies (CEAs) p!us 2 additional CEAs removed fron,ine core. Each CEA is individually uncoupled from the CEDM drive shaft. Positive indication of uncoupling is obtained by weighing each drive shaft and uncoupling tool. Satisfactory uncoupling is determined by proper weig' indication. Dunng head removal, the audible count rate signal from one of two operable start up channels is monitored at the refueling area and control room as additionrJ. esurance that CEAs are not inadvertently removed.

Design of the fuel storage racks and handling facilities in both the containment and fuel storage area is such that fuel will always be in a subentical geometrical array, assuming zero boron concentration in the fuel pool water. The spent fuel pool and refueling pool water contains boron at 'he refueling boron concentration. Natural convection of the surrounding water provides adequate cooling of fuel dunng handling and storage. Cooling of the water is provided by the spent fuel pool cooling system. At no time dunng th6 transfer from the reactor core to the spent fuel storage rack is a fuel assembly removed from the water. Fuel failure during refueling, as a rasult of inadvertent enticality or overheating, is not possible.

Interlocks and mechanical stops prevent the spent fuel cask handling crane from moving the cask over stored irradiated fuel and limit cask movement.

During fuel handling operations, the containment is kept in an isolable condition, with all penetrations to the outside atmosphere either closed or capable of being closed on a containment purge isolation signal (CPIS) initiated by redundant area and airbome radiation monitors. At least one of the two interlock doors on the personnellocks is kept closed. In addition to the area and airbome radiation monitors in the containment, portable monitors with audible alarms are located in the fuel handling area during refueling.

Should a fuel assembly be dropped and release activity above a presenbed level, the radiation monitors soun j an audible alarm, the containment is isolated from the outside atmosphere, and personnel are evacuated. The containment purge lines are automatically closed upon a CPIS, thus minimizing the escape of any radioactivity. The consequences of dropping a fuel assemt@ in the containment are less severe than the consequences of dropping the assembly in the Fuel Handling Building, since the containment providet a considerably greater holdup time than the Fuel Handling Building, allowing for radioactive decay of the released fission products.

15.7-5 Revision 9 (12/97)

WSES-FSAR UNIT-3 i

For this evaluation, dropping of a fuel assembly is assumed to occur breaching the cladding and releasing the volatile fission products in the gas gap of the fuel pins. In addition to the area radiation monitor located in the spent fuel cask area, portable radiation monitors capable of emitting audible alarms are located in this area during fuel handling operations. Doors in tne Fuel Handling Building are closed to waaintain controlled leakage characteristics in the spent fuel pool region during refueling operations involvitig irradiated fuel. Should a fuel assembly be dropped in the fuel transfer canal or in

. the spent fuel pool and release radioactivity above a prescribed level, the airbome radiation morViors l

sound an alarm, alerting personnel to the problem. Area radiation monitors in the Fuel Handling Building l

isolate the normal Fuel Handling Building Ventilation System and automatically initiate the filtration l

systems.

15.7.3.4.2 Sequence of Events and System Operation i

l 15.7.3.4.2.1 Design Basis Sequence of Events and System Operation The refueling procedure is described in Subsection 9.1.4. The earliest anticipated time at which a spent fuel assembly could be handled is three days after shutdown.

For the design basis accident, the failure of fuel rods in four rows parallel to one assembly face (60 fuel

- rods) was evaluated. The failure of 60 fuel rods is the largest number of fuel rods that could fail from the worst postulated assembly drop.

For the realistic accident, the failure of fuel rods in one row parallel to an assembly face (16 fuel rods) was evaluated.

An additional evaluation assuming the failure of all fuel rods in one spent fuel assembly (236 fuel rods) was performed to demonstrate that the Fuel Handling Suilding Ventilation System is capable of handling this failure consistent with the recommendations of Regulatory G'Jide 1.13, Spent Fuel Storage Facility Design Basis. This accident is not credible since the worst drop cannot result in damage to more than 60 fuel rods.

The resultant release of radiometivity is exhausted from the Fuel Handling Building during a two hour

}

period.

15.7.3.4 2.2 Structural Evaluation of Fuel Assembly in this analysis, dropping of a fuel assembly is assumed. Intertocks and procedural and administrative controls make such an event highly unlikely. However, if an assembly were damaged to the extent that one or more fuel rods were broken, the accumulated fission gams and lodines in the fuel rod gaps would be released to the surrounding water. Releasa of the solid fission products in the fuel would be negligible 4

because of the low fuel temperature during refueling.

I The fuel assembiles are stored within the spent fuel rack atine bottom of the spent fuel pool. A dropped fuel assembly could not strike more than one fuel assembly in the storage rack. Impact could occur only between the ends of the involved fuel assemblies, the bottom end fitting of the dropped fuel assembly impacting against the top and fitting of the stored fuel assembly. The maximum drop distance for this event is assumed to be 74 in from the j

l 15.7-6 i

WSES-FSAR UNIT 3 bottom of a fuel assembly in the spent fuel handling machine to the top of a fuel assembly in the storage racks. The impact velocity is 215 in./second and the impact stress in the

. fuel rod cladding is 20.100 psi.

The maximum possible drop distance for a fuel assembly in the spent fuel pool is 254 in.

This is the distance from the bottom of a fuel assembly to the spent fuel pool floor. For this drop the velocity of the fuel assembly at impact is 362 in./second, and the impact stress in the fuel rod cladding is 34.000 psi.

The analyses of the fuel assembly vertical drops reported above were performed with a calculational model that incorporates skin friction and form drag of the fuel assembly into a mathematical formulation of the fuel assembly motion which is given below:

2 y

[(Fs + Fo )/H) X g-0 (1)

X +

where:

Fs -

skin friction coefficient l

Fo -

form drag coefficient mass of a fuel assembly M

=

net weight of a fuel assembly W

=

velocity l

X acceleration X

The equation employed in calculating the impact stresses in the fuel rod clad is as follows:

j I

ai - X 5 (See Reference 1.)

(2) where:

og impact stress

=

impact velocity Xg

=

modulus of elasticity E

=

p mass density The allwable stress in the fuel rod cladding is 49,000 psi. This is the minimum yield stress value for unf rradiated Zircaloy 4 and is conservative for irradiated fuel. Thus, for the worst case futi assemoly vertical drop, the impact stresses which result from absorbing the kinetic energy of the drop are below the yield Stress of the clad and no fuel rod failures will occur.

The worst case fuel assembly horizontal impact results from a vertical drop of the maximum l

l possible distance to the fuel pool floor, followed by rotation, the assembly is assumed to j

j strike a protruding structure. The fuel storage pool is designed without such protruding

{

structures and hence the shape and nature of the assumed member is indeterminate. For this analysis, therefore, a line load has been assumed for the most severe accident.

1 15.7 7 l

i

l WSES-FSAR UNIT-3 l

An analysis of this fuel assembly drop has shown that the most severe impact location is between the top two spacer grids due to the higher impact veloc1ty of the top of the fuel assembly. Since this impact area is within the fuel rod upper plenum region, the fuel l

pellets do not provide clad support and do not enter into the failure analysis. To obtain an estimate of the number of fuel rods which might fail the fuel assembly was modeled and calculations performed with the SHOCKm computer code. The SH0CK code allows modeling of the fuel assembly to include consideration of localized deformations about the impact point as.well as general bending of the fuel assembly. The input data describing fuel material properties and pool conditions were kept consistent with the circumstances of the accident (i.e., irradiated fuel assembly material properties, water, and fuel rod cladding temperatures corresponding to spent fuel pool conditions). For this event. no more than four rows of fuel rods (60 rods) would fail due to the combined bending and localized deformation which results from absorbing the kinetic energy at impact. For conservatism, fuel rod cladding failure was assumed to occur if the stress distribution across the fuel rod tube reached a uniform value equal to the yield stress of irradiated Zircaloy. The use of irradiated fuel rod properties for the horizontal impact is conservative because of the greater energy absorbing capability of unirradiated Zircaloy.

The failure of all 236 fuel rods in one spent fuel assembly is not a credible event.

15.7.3.4.3 Core and System Performance This subsection is not applicable for a fuel handling accident.

15.7.3.4.4 Barrier Performance This subsection is not applicable for a fuel handling accident.

15.7.3.4.5 Radiological Consequences 15.7.3.4.5.1 Design Basis Assumptions and Parsineters l

Assumptions and parameters used in evaluating the fuel handling accident are consistent with Regulatory Guides 1.13 (12/75) and 1.25 (3/23/72) recommendations as shown in Table 15.7 6.

The radioactive inventory of the 60 fuel rods was obtained by multiplying the activity of the most radioactive fuel rod 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after shutdown by a factor of 60. The calculational j

methods and assumptions described in Regulatory Guide 1.25 apply since: (a) the values for l

maximum fuel rod pressurization. (b) peak linear power density for the highest power assembly discharged. (c) maximum centerline operating fuel temperature for the assembly in item (b) above, and (d) average burnup for the peak assembly in item (b) above are less than j

l the corresponding values in Regulatory Guide 1.25.

The evaluation of the failure of all fuel rods in a fuel assembly (236 fuel rods) was performed to demonstrate consistency with the recommendations of Regulatory Guide 1.13. This evaluation was identical to the design basis accident with the exception that the radioactivity was obtained L; multiplying the Etivity of the most radioactive fuel rod 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after shutdown by a factor of 236.

15.7 8 i

WSES FSAR UN!T-3 The doses from a fuel handling accident occurring inside containment have been calculated assuming no isolation, and have been found to be well below the guidelines of 10CFis100. The assumption and parameters required to evaluate containment isolation are given in Table 15.7-8.

I The offsite doses are c61culated using Equacions 19 and 20 as given in Appendix 15B.

l Subsections S.4.2 and 6.5.1 provide data concerning the FHB Ventilation System which I

mitigates the consequences of an accident.

l l

15.7.3.4.5.2 Realistic Assumptions and Parameters l

Assumptions and parameters used in evaluating the realistic fuel handling accident are presented in Table 15.7-6. The radioactive inventory of the 16 fuel rods was obtained by multiplying the activity of the most radioactive fuel rod (based on 3390 MWt and 1.55 radial peaking factor) 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after shutdown ty a factor of 16.

The Fuel Handling Building ESF filter trains were identically modeled as in the design basis accident.

15.7.3.4.6 Results a)

Offsite Doses I

The potential radiological consequences resulting from the occurrence of a postulated fuel handling accident have been conservatively analyzed, using assumptions and models described in the preceding subsections.

The whole body dose due to immersion and the thyro'id dose due to inhalation have been analyzed for initial two hour period at the exclusion area boundary and for the duration of the accident at the LPZ outer boundary. The results are listed in Table 15.7-7. The resultant doses are well within the guidelines of 10CFR100.

b)

Dose to Main Control Room Personnel The radiological consequences to main control room personnel ' ollowing a fuel f

i handling accident will be less severe than the results of a loss of coolant accident (see Subsection 15.6.3.3).

15.7.3.5

$0ent Fuel Cask Drop Accidents I

i 15.7.3.5.1 Cask Drop Into Spent Fuel Pool 1

As discussed in Subsection 9.1.4, the cask handling crane is prohibited from traveling over the spent fuel pool or any unprotected safety related equipment. Thus, an accident resulting from dropping a cask or other major load into the spent fuel pool is not ~ edible.

1 15.7.3.5.2 Cask Drop to Flat Surface 15.7 9

WSES.FSAR UNIT-3 As discussed in Subsection 9.1.4. the potential drop of a spent fuel cask is limited to less thar an equivalent 30 ft. drop onto a flat, essentially unyielding, horizontal surface.

Since the spent fuel cask is designed to withstand such loadings, the radiological consequences of these accidents are not evaluated.

b 15.7 10

1 WSES FSAR-UNIT-3 j

l SECTION 15.7:

REFERENCES' l

1.

Love, A. E. H., A Treatise on the Mathematical Theory of Elasticity. 4th Edition.

I Dover Publications, New York, New York. October 1926.

'2.

Gabrielson. V. K., SH0CK A Computer Code for Solving Lumped Mass Dynamic Systems' SCL-DR 5 35, January 1966.

l l

1

~15.7-11 j

t:

3 d___..__._._____2________.___

[-

i NPF-38-204 -

REFERENCE 4 WATERFORD 3 LETTER W3F1-95-0139 FROM R. F. BURSKI To U.S. NRC DOCUMENT CONTROL DESK DATED AUGUST 30,1995 u

.-____.-._m.--___-__-.m_.

_m____.-_._______-.____.

m.

_2am._

_a___.._-.-._

m

e e'ENTERGY

'E"'"

^

R. F. Surski W3F1-95-0139 i

A4.05 PR l

August 30, 1995 U.S. Nuclear Regulatory Commission i

ATTN:

Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38

{

Request for Additional Information Regarding j

Technical Specification Change Request NPF-38-Il6 Gentlemen:

By letter dated July 18, 1901, as supplemented by letters dated March 16, 1994, December 2, 1994 and March 9, 1995, Waterford 3 proposed a change to Technical Specification (TS) 3/4.7.6, " Control Room Air Conditioning System."

Modifications to the proposed TS have been incorporated as a result of several discussions with the NRC review staff. These modifications are an effort to provide clarification that support intent of the proposed specifications and provide consistency with existing specifications. Where l

clarification was determined necessary to further define the intent of the proposed Limiting Conditions for Operation (LCOs), the proposed TS were modified conservatively such that the no significant hazards determination provided with the original submittal remains valid.

The modifications are described herein and appear in Attachment A.

Description The LCO requirements and ACTIONS for proposed specifications 3.7.6.2 and 3.7.6.4 have been nodified to be consistent with the revised standard TS 8

(NUREG 1432) and existing TS 3.7.6 during MODES 5 and 6.

Q:2 Q u B ? I h *'3W )('y

Request for Additional Information Regarding Technical Specification Change Request NPF-38-116 W3F1-95-0139 Page 2 August 30, 1995 ACTIONS a and b of proposed specification 3.7.6.3 have been revised by removing the reference to control room temperature.

Surveillance 4.7.6.3.a assures compliance with specified control room temperature.

The asterisk and associated footnote concerning an allowed breach in the

(

control room envelope have been removed from proposed specification f

3.7.6.5.

This provision is now addressed in revised ACTION STATEMENT

-d.2.a.

ACTION STATEMENT d.2.b is intended to address a situation when the control room envelope is inoperable due to failing Surveillance 4.7.6.5.a ACTION STATEMENT d.2.c is modified to remove the shutdown at power.

requirement.

Bt.SES 3/4.6.4 is modified to include clarification information concerning the provisions and restrictions of ACTION STATEMENT d.2.a.

If you should. have any questions concerning the above, please contact Paul Caropino at (504) 739-6692.

Very truly yours, s

R.F. Burski Director Nuclear Safety i

RFB/PLC/ssf Attachment L.J. Callan (NRC Region IV), C.P. Patel (NRC-NRR),

cc:

R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office, Administrator Radiation Protection Division (State of Louisiana), American Nuclear Insurers l

__________.___ _ i e

1 f

i

)

h r

i

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l 1

l l

l l

W3F1-95-0139 ATTACHMENT A i

PLANT SYSTEMS 3/4.7.6.1 C0hTROL ROOM EMERGENCY AIR FILTRATION SYSTEM LIMITING ColeITI(Di FOR OPERATION 3.7.6.1 Both control room emergency air filtration trains (S 8) shall be OPERABLE.

APPLICA8ILITY:

H00ES 1. 2. 3. and 4 ACTION:

a.

With one control room emergency air filtration train inoperable, either restore the inoperable train to OPERABLE status within 7 days 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 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 />.

b.

With both control room emergency air filtration trains inoperable, restore one train 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 COLD SHUTDOWN within the fcilowing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE RFnti1REMNTS 4.7.6.1 Each control room emergency air filtration train (S 8) shall be demonstrated OPERA 8LE:

a.

At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 10 continuous hours with the heaters on.

b.

At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system by:

1.

Verifying that the filtration train satisfies the in place testing acceptance criteria and uses the test procedures of Regulatory Positions C.S.a. C.5.c and C.S.d of Regulatory Guide 1.52. Revision 2.

March 1978, and the system flow rate is 4225 cfm *10%.

2.

Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 2. March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52. Revision 2. March 1978.

3.

Verifying a system flow rate of 4225 cfm *10% during train operation when tested in accordance with ANSI N5101975.

WATERFORD - UNIT 3 3/4 7-16 l

_ _ _ - - - _h o w r_ m _< 'ttp

I PLMT SYSTEMS l

l SLRVEILLMCE REQUIREMENTS (Continued) l l

C.

After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31

[

days after removal that a laboratory analysis of a representative carbon samle obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 2. March 1978 meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52. Revision 2. March 1978.

l d.

At least once per 18 months by:

1.

Verifying that the pressure drop across.the combined HEPA filters and charcoal adsorber banks is less than 7.8 inches water gauge while operating the train at a flow rate of 4225 cfm i105.

J 2.

Verifying that o1 a safety injection actuation test signal or a high radiation test signal, the train automatically switches into a recirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks.

3.

Verifying that heaters dissipate 10 (+0.5. -1.0) kW when tested in accordance with ANSI N510 1975.

e.

After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the 00P when they are tested in place in accordance with ANSI N5101975 while operating the train at a flow rate of 4225 cfm *10%.

f.

After each complet? or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95%

of a halogenated hydrocarbon refrigerant test gas whea they are tested in-place in accordance with ANSI N5101975 4111e operating the train at a flow rate of 4225 cfm *105.

l l

i

'k WATERFORD - UNIT 3 3/4 7-17 l

PLANT SYSTEMS 3/4.7.6.2 CONTROL ROOM EMERGENCY AIR FILTRATION SYSTEM LIMITING COE ITION FOR OPERATION 1

3.7.6.2 Two One control room emergency air filtration trains (S 8) shall be OPERABLE.

l l

APPLICABILITY:

MODES 5 and 6.

J ACTION:

utty 3+y centr:7 r--

=rgency :$- <41 r::$- tr $n: <n per g,e, : :pene 37, Oper:tt0n: 4 v0lv'n; CTE.^.LTER"!$5 or p^ itiv re::tivity ch:n;00.-

j a,

With one control room emergency air filtration system inoperable restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE control room emergency air filtration system in the recirculation mode.

L With both control room emergency 31r filtra+ jn systems inoperable, or with the OPERABLE control room emeroency air fi ation system, reauired to be in the recirculation mode by ACTION a. not cl Ole of beino powered by an OPERABLE emergency power source, suspend r i operations involvino CORE ALTERATIONS or Dositive reactivity changes.

l SLRVEILLM;"E REQUIREMENTS 4.7.6.2 The control room emergency air filtration trains (S-8) shall be demonstrated OPERABLE per the applicable Surveillance Requirements of 4.7.6.1.

l l

"%i WATERFORD - UNIT 3 3/4 7 18 l

l lL_-

PLANT SYSTENS 3/4.7.6.3 CONTROL ROON AIR TENPERATUtE LIMITING C0fEITION FOR OPERATION 3.7.6.3 Two independent control room air conditioning units shall be OPERABLE.

l APPLICABILITY:

H00ES 1. 2. 3 and 4 ACTION:

a.

With one control room air conditioning unit inoperable.

int: 9 00ntr01 r00m t3erature 1000 2^ Or O';ual t0 80*F:nd restore the inoperable unit to OPERABLE status within 7 days or be in HOT STANOBY 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 />, b.

With two control room air conditioning units inoperable. 2nd 00ntr01 r00-te ;0 rat;r: ;reater 2:n Or qu:1 'O S04 return one unit to ar 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 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 4.7.6.3 Each control room air conditioning unit 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 verifying that the operating control room l

air conditioning unit is maintaining average control room air temperature less than or equal to 80*F.

]

b.

At least quarterly. If not performed within the last quarter, by verifying that exh control room air conditioning unit starts ano operates for at least 15 minutes.

t I

i WATERFORD - UNIT 3 3/4 7 18a l

i l

1 i

PLANT SYSTEMS

)

3/4.7.6.4 CONTROL ROOM AIR TEMPERATURE LIMITING CONDITION FOR OPERATION 3.7.6.4 Two One independent control room air conditioning units shall be OPERABLE.

l l

APPLICA8ILITY:

MODES 5 and 6.

ACTION:

i ujgg 5;.y ;;g;7;7 pmm- ;j ;mngjt$mg43g 3n3;; 43mmmp37, ;;;;;gg ;33 1

Oper: tion: ' v !"dn; CTE ?LTEP"!?! Or ;0 f ttv0 re: t!"f ty changes.

l L

With one control room air conditioning unit inoperable, restore i

the inoperable system to OPERABLE status within 7 days or initiate and

{

maintain operation of the remaining OPERABLE control room air conditioning i

unit.

)

3 b

With both control room air conditioning units inocerable, or with the OPERABLE control room air conditioning unit, reouired to be in operation by ACTION a, not capable of being powered by an OPERABLE emergency power i

source, suspend all operations involving CORE ALTERATIONS or oositive l

reactivity changes.

j SLRVEILIACE pmlIRENDITS 4.7.6.4 The control room air conditioning units shall be demonstrated OPERABLE per the Surveillance Requirements of 4.7.6.3.

4 i

l WATERFORD UNIT 3 3/4 7-18b l

F l

PLANT SYSTEMS l

LINITING ColCITION FGt OPDIATION ACTION: (Continued) b.

If the cause of !detify 2: :::: Of control room envelope inoperability is unknown 20 failure identify the cause within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. rd *-iti:t" Orr::t'": ::ti r *: If the cause of the failure Is due to a breach within the allowable limits of ACTION d.2.alhgn operation may continue for up to 7 days after the control room envelope is declared inoperable. Otherwise, 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 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 />.

gh.

Should a toxic gas event occur, take immediate steps to restore control room envelope integrity M - :x : p!rt duttr ta b- *= "^T ST^"TY eie'- 2: =t S br: rd C^LO SEmZ" ri ed - t" f9hi g 20 5 :.

3.

MODES 5 and 6:

a.

Suspend all operations involvina CORE ALTERATIONS or positive reactivity changes and if a tore gas event occurs. take imediate steps to restore control room envelope integrity.

i St5tVEILUEE RFollIRDENTS 4.7.6.5 1he control room envelope isolation and pressurization boundaries shall be demonstrated OPERABLE at least once per 18 months by:

a.

Verifying that the control room envelope can be maintained at a positive l

pressure of greater than or equal to 1/8 inch water gauge relative to the l

outside atmosphere with a make up air flowrate less tnan or equal 'o 200 cfm

{

during system operation, b.

Verifying that on a toxic gas detection test signal, the system automatically switches to the isolation mode of operation.

c.

Verifying that on a safety injection actuation test signal or a high radiation test signal, normal outside air flow paths isolate.

WATERFORD - UNIT 3 3/4 7-18d l

j

PLANT SYSTEMS BASFt 3/4.7.6.1 and 3/4.7.6.2 CONTROL ROON EMEPGENCY AIR FILTRATION SYSTEM During an emergency, both S 8 units are started to provide filtration and adsorption of l

outside air and control room envelope recirculated air (reference: FSAR 6.4.3.3).

Dosages received after a full power design basis LOCA were calculated to be orders of magnitude higher than other accidents involving radiation releases to the environment (reference: FSAR l

Tables 15.6 18. 15.7 2. 15.7 4. 15.7-5. 15.7 7). Because the consequences of a full power design basis LOCA are more severe than those occurring during COLD SHUTDOWN and REFUELING, a seearate specification. 3/4.7.6.2. requires only one OPERABLE S 8 unit to guard against accidents during Modes 5 and 6.

The OPERABILITY of this system and control room design provisions are based on limiting the radiation exposure to personnel occupying the control room to 5 rem or less whole body. or its equivalent. This limitation is consistent with the requirements of General Design Criterion 19 of Appendix A.10 CFR Part 50.

Operation of the system with the heaters on for at least ten hours continuous over a thirty-one day period is sufficient to reduce the buildup cf moisture on the adsorbers and HEPA filters. Obtaining and analyzing charcoal samples after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of adsorber operation (since the last sample and analysis) ensures that the adsorber maintains the efficiency assumed in the safety analysis and is consistent with Regulatory Guide 1.52.

3/4.7.6.3 CONTROL A0(M AIR TDFERATUIE Maintaining the control room air temperature less than or equal to 80*F ensures that (1) the ambient air temperature does not exceed the allowable air temperature for continuous duty rating for the equipment and instrumentation in the control room. and (2) the control room

. will remain habitable for operations personnel during plant operation.

The Air Conditioning System is designed to cool the outlet air to approximately 55'F. Then.

non safety related near-room heaters add enough heat to the air stream to keep the rooms between 70 and 75'F. Although 70 to 75'F is the normal control band. it would be too i

restrictive as an LCO. Control Room equipment was specified for a more general temperature range of 45 to 120*F. A provision for the CPC microcomputers, which might be more sensitive to heat, is not required here. Since maximum outside air make up flow in the normal ventilation mode comprises less than ten percent of the air flow from an AH 12 unit.

outside air temperature has little affect on the AH 12s cooling coil heat load. Therefore, the ability of an AH 12 unit to maintain control room temperature in the normal mode gives adequate assurance of its capability for emergency situations.

s i

WATERFORD UNIT 3-8 3/4 7-??

l

PLANT SYSTEMS BASES (Contitud 3/4.7.6.4 CONTROL ROON ISOLATION AND PRESSURIZATION This specification provides the operability requirements for the control room envelope isolation and pressurization boundaries. The Limiting Condition for Operation (LCO) specifies specific ACTION STATEMENTS for inoperable components of the control room ventilation systems, separate from the S 8 and AH 12 units. The operability of the remaining parts of the system affect the ability of the control room envelope to pressurize.

N eutfre f-te : ce prc';f f = 1: "cluded " S: LCO " '20 f0- Of : f^^*r^'e.

pre 11cf r :11 = : for =:1' ;=:te:tf =: " '2: := trol -^^ =;;M;: er bb:E: : Of ='010p:

decr: Or d 7 :r: f0r : perf 0d ^ t t0 Orc ^^" ' day: = = "'d-f ttet b::M pre /fded that

pprcprfat d- "f:tr:tf'/e : = troh Or: 1 ph =

'^d.

ACTION STATEMENTS a and b focus on maintaining isolation characteristics. The valves in the flow path referred to in ACTION a are HVC-102 & HVC-101. The Outside Air Intake (OAI)

" series isolation valves" of ACTION b and c are as follows:

NORTH GAI - HVC 2028 & HVC-201A HVC 202A & HVC 2018

{

SOUTH GAI HVC-2048 & HVC-203A HVC-204A & HVC 2038 ACTION STATEMENT c preserves the operator action (i.e. manually initiated filtered pressurization) that maintains the control room envelope at a positive pressure during a radiological emergency. As indicated above each OAI series isolation valve is powered by the opposite train. With more than one OAI flow path inoperable a single failure (i.e.,

train A or B) could prohibit the ability to maintain the control envelope at a positive pressure. Therefore. in the specified condition. ACTION t requires an additional flow path to be returned to service within 7 days.

ACTION STATEMENT d.2.a is inter.ded to address an intentional breach in the control room Pressurization boundary as necessary to suDoort maintenance or modification. A breach of this nature shall be limited in size and governed under administrative controls. The size restrictions as stated in the ACTION are such that should a toxic event occur control room integrity can be innediately restored as described below. ACTIONSTATEMENTdJ. bis intended to restore pressurization ability as soon as possible for unintended breaches in I

the envelope. The 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to locate an unidentified breach is based on an evaluation that I

considered troubleshooting tasks that would be performed as necessary should the intecrity of the Control Room Envelope pressure boundary fall into question. Estimated times associated with each task were based on sound engineering judgment. The ACTION statements j

also recognize the MODE independent nature of the toxic chemical threat and provides for l

operator protection in the event of a toxic chemical release concurrent with a breach in the control room envelope. In addition provisions have been added to the specification that.

in the event of a Joxic chemical event that threatens control room habitability while in the ACTION statements. "innediate steps" will be initiated to place the plant in a safe condition. In this context the phrase "innediate steps" is taken to mean that the operators should innediately take reasonable action to restore a known breach in the envelope to an air-tight condition. Aglifying instructions are provided in Waterford 3 Administrative procedures, which impose special controls for work that will breach the i

control room envelope.

WATERFORD - UNIT 3 83/47??

l

,e:

-1 i-i 'ji i!

.i, NPF-38-204 l

REFERENCE 5 NRC LETTER FROM C. P. PATEL To R. P, BARKHURST DATED OCTOBER 4,1995.

l I

i-

1 UNITED STATES

• f NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30006 4001 l

October 4,1995 -.

RECElvo Fpe Mr. Ross P. Barkhurst OCT 1~

1995 Vice President Operations Entergy Operations, Inc.

ILN k

- O S N '

P. O. Box B Killona, LA 70066 j

SUBJECT:

ISSUANCE OF AMENOMENT N0.115 TO FACILITY OPERATING LICENSE l

l NPF WATERFORD STEAM ELECTRIC STATION, UNIT 3 (TAC NO. M72846)

Dear Mr. Barkhurst:

The Commission has issued the enclosed Amendment No. 115 to Facility Operating License No. NPF-38 for the Waterford Steam Electric Station, Unit 3.

The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated July 18, 1991, as supplemented by letters dated March 16, and December 2, 1994, and March 9, and August 30, 1995.

The amendment changes the Appendix A TSs by subdividing TS 3/4.7.6, " Control Room Air Condition'ng System," into five separate TSs covering the following three distinct funct'ons: control room emergency air filtration, control room air temperature, and control room isolation and pressurization. The amendment also changes the Bases sections of the TS to reflect the above changes.

A copy of our related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's next b1 weekly Federal Reaf ster notice.

1 Sincerely, 0f l

Chandu P. Patel, Project Manager Project Directorate IV-1 l

Division of Reactor Projects III/IV Office of Nuclear Reactor. Regulation s

Docket No. 50-382 l

Enclosures:

1. Amendeont No.115 to NPF-38

2. Safety Evaluation g5

1. g%

f cc w/encls:

See next page g

P.,

R CI, %

e l

1 n

1 o

i g

t~g#

&p,

h i

l l-Mr. Ross P. Barkhurst Entergy operations, Inc.

Waterford 3 cc:

I f

Mr. William H. Spell, Administrator Regional Administrator, Region IV Louisiana Radiation Protection Division U.S. Nuclear Regulatory Commission Post Office Box 82135 611 Ryan Plaza Drive, Suite 1000 Baton Rouge, LA 70884-2135 Arlington, TX 76011 Resident Inspector /Waterford NPS Mr. Jerrold G. Dewease Post Office Box 822 Vice President, Operations Killona, LA 70066 l

Support L

Entergy Operations, Inc.

Parish President Council P. O. Box 31995 St. Charles Parish Jackson, MS 39286 P. O. Box 302 Hahnville, LA 70057 Mr. R. F. Burski, Director Nuclear Safety Mr. Harry W. Keiser, Executive Vice-Entergy Operations, Inc.

President and Chief Operating Officer i

l P. O. Box B Entergy Operations, Inc.

K111ona, LA 70066 P. O. Box 31995 Jackson, MS 39286-1995 Mr. Robert 8. McGehee Wise, Carter, Child & Caraway Chainsan P.O. Box 651 Louisiana Public Service Commission Jackson, MS 39205 One Ausrican Place, Suite 1630 i

l Baton Rouge, LA 70825-1697

)

f' Mr. Dan R. Keuter l

General Manager Plant Operations Donna Ascenzi 1

l Entergy Operations, Inc.

Radiation Program Manager, Region 6 l

P.O. Box B Environmental Protection Agency J

Killont, LA 70066 Air Environmental Branch (6T-E) i l

1445 Ross Avenue l

Dallas, TX 75202-2733 1

l.

Mr. Donald W. Vinci, Licensing Manager j

l Entergy Operations, Inc.

j P. O. Box B 1

K111ona, LA 70066 l

i Winston & Stramm e 1

Attn:

N. S. Reynolds..,

1400 L Street, E k Washington, DC 20005 3502;..

a "8%

UNITED STATES y

3 NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 200064001

'+,

ENTERGY OPERATIONS. INC.

DOCKET No. 50-382 WATERFORD STEAM ELECTRIC STATION. UNIT 3 AMENOMENT TO FACILITY OPERATING LICENSE l

Amendment No. 115 License No. NPF-38 1

1.

The Nuclear Regulatory Commission (the Comunission) has found that:

A.

The application for amendment by Enterpy Operations, Inc. (the licensee) dated July 18, 1991, as supp emented by letters dated l

March 16, and December 2, 1994, and March 9, and August 30, 1995, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations tot forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (1) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 l

of the Commission's regulations and all applicable requirements have been satisfied.

I N f(

- - - - - - - - - - - - - - - - - - 2.

Accordingly, the license is amended by changes'to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Facility Operating License No. NPF-38 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No.115, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license.

Tae licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendnent is effective as of its date of issuance.

FOR THE NUCLEAR REGULATORY COPMISSION Chandu P. Patel, Project Manager Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: October 4, 1995~

I

l l

ATTACMENT TO LICENSE AMENDMENT NO.115 I

TO FACILITY OPERATING LICENSE NO. NPF-38 l

DOCKET No. 50-382 Replace the following pages of the Appendix A Technical Specifications with i

the attached pages. The revised pages are identified by Amendment number and I

contain vertical lines indicating the areas of change. The corresponding

)

overleaf pages are also provided to maintain document completeness.

REMOVE PAGES INSERT PAGES l

3/4 7-16 3/4 7-16 3/4 7-17 3/4 7-17 3/4 7-18 3/4 7-18 3/4 7-18a 3/4 7-18b 3/4 7-18c l

3/4 7-18d 1

B 3/4 7-4a B 3/4 7-4a B 3/4 7-4b 1

B 3/4 7-4c l

l i

PLANT SYSTEMS 3/4.7.5 FLOOD PROTECTION LIMITING CONDITION FOR OPERATION 3.7.5 Flood protection shall be provided for all safety-related systems, components, and structures when the water level of the Mississippi River exceeds +27.0 ft Mean Sea Level USGS datus, at the levee fronting the Waterford Unit 3 site.

APPLICA81LITY:

At all times.

ACTION:

With the water level at the levee fronting the Waterford Unit 3 site above elevation +27.0 ft Mean Sea Level USGS datum initiate and complete within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> precedures ensuring that all doors and penetrations below the +30.0 ft elevation are secure.

SURVEILLANCE REQUIREMENTS 4.7.5 The water level at the levee fronting the Waterford Unit 3 site shall be determined to be within the limits by:

Measurement at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the water level is equal a.

to or above elevation +24.0 ft Mean Sea Level USGS datum and below elevation +27.0 ft Mean Sea Level USGS datus, and b.

Measurement at least once per 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> when the water level is equal to or above elevation +27.0 ft Mean Sea Level USGS datus.

9

• i WATERFORD - UNIT 3 3/4 7-15

PLANT SYSTEMS 3/4.7.6.1 CONTROL ROOM EMERGENCY AIR FILTRATION SYSTEM 1

LIMITING CONDITION FOR OPERATION 3.7.6.1 Both control room emergency air filtration trains (S-8) shall be OPERABLE.

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

l 4CIl0N:

1 With one-control room emergency air filtration train inoperable.

l a.

either restore the inoperable train to OPERA 8LE status within 7 days l

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 l

SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.

With both control room emergency air filtration trains inoperable, restore one train to OPERABLE status within I hour or be in at least HOT STAN08Y 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 1

4.7.6.1 Each control room air filtration train (S-8) shall be demonstrated OPERA 8LE:

I At least once per 31 days on a STAGGERED TEST BASIS by initiating, a.

l from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 10 continuous hours with the heaters on.

b.

At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the. system by:

1.

Verifying that the filtration train satisfies the in-place testing acceptance criteria and uses the test procedures of Reflulatory Positions C.5.a, C.5.c. and C.5.d of Regulatory Gu< de-l.52, Revision 2, March 1978, and the system flow rate is 4225 cfts 1105.

2.

Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.

WATERFORD - UNIT 3 3/4 7-16 Amendment No.115 l

1

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) i 1

3.

Verifying a system flow rate of 4225 cfm 10% during train operation when tested in accordance with ANSI N510-1975.

After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying c.

within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52 Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C,6.a of Regulatory Guide 1.52, Revision 2, March 1978.

i d.

At least once per 18 months by:

i 1.

Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is le'ss than 7.8 inches water gauge while operating the train at a flow rate of 4225 cfm 105.

2.

Verifying that on a safety injection actuation test signal or a high radiation test signal, the train automatically switches i

into a recirculation mode of operation with flow through the L

HEPA filters and charcoal adsorber banks.

l 3.

Verifying that heaters dissipate 10 (+0.5, -1.0) kW when tested in accordance with ANSI N510-1975.

After each complete or partial replacement of a HEPA filter bank by e.

verifying that the HEPA filter banks remove greater than or equal to 99.95% of the D0P when they are tested in-place in accordance with I

ANSI N510-1975 while operating the train at a flow rate of 4225 cfm 1105.

l f.

After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or I

equal to 99.955 of a halogenated hydrocarbon refrigerant test gas when they are tested in-p' ace in accordance with ANSI N510-1975 while operating the train at a flow rate of 4225 cfm 1105.

i WATERFORD - UNIT 3 3/4 7-17 Amendment No.115

[

l PLANT SYSTEMS 3/4.7.6.2 CONTROL ROOM EMERGENCY AIR FILTRATION SYSTEM LIMITIN3 CONDITION FOR OPERATION 3.7.6.2 Two control room emergency air filtration trains (S-8) shall be OPERABLE.

APPLICABILITY: MODES 5 and 6.

ACTION:

With one control room emergency air filtration system inoperable, a.

restore the inoperable system to OPERA 8LE status within 7 days or initiate and maintain operation of the remaining OPERABLE control room emergency air filtration system in the recirculation mode.

b.

With both control room emergency air filtration systems inoperable,

~

or with the OPERABLE contro' room emergency air filtration system, required to be in the recirculation mode by ACTION a not capable of being powered by an OPERABLE emergency power source,, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

i SURVEILLANCE REQUIREMENTS 4.7.6.2 The control room emergency air filtration trains (S-8 shall be demonstrated OPERA 8LE per the applicable Surveillance) Requiremen l

4.7.6.1.

1 t

i 1

WATERFORD - UNIT 3 3/4 7-18 Amendment No.115 l

j i

PLANT SYSTEMS 3/4.7.6.3 CONTROL ROOM AIR TEMPERATURE LIMITING CONDITION FOR OPERATION 3.7.6.3 Two indeperdont control room air conditioning units shall be OPERABLE.

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

EI1QK:

With one control room air conditioning unit inoperable, restore the a.

inoperable unit to OPERA 8LE status within 7 days or be in HOT STAN08Y 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 />, b.

With two control room air conditioning units inoperable, return one unit to an OPERABLE status within I hour or be in HOT STAN08Y 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 4.7.6.3 Each control room air conditioning unit 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 verifying that the operating control room air conditioning unit is maintain'ng average control room air temperature less than or equal to 80*F.

b.

At least quarterly, if not performed within the last quarter, by verifying that each control room air conditioning unit starts and operates for at least 15 minutes.

WATERFORD

. UNIT 3 3/4 7-18a Amendment No.115

PLANT SYSTEMS

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3/4.7.6.4 CONTROL ROOM AIR TEMPERATURE l

LIMITING CONDITION FOR OPERATION 3.7.6.4 Two independent control room air conditioning units shall be OPERABLE.

l APPLICABILITY: MODES 5 and 6.

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ACT10N:

a.

With one control room air conditioning unit inoperable, restore the inoperable system to OPERA 8LE status within 7 days or initiate and 1

maintain operation of the remaining 0PERABLE control room air conditioning unit.

b.

With both control room air conditioning units inoperable, or with the OPERABLE control room air conditioning unit, required to be in l

operation by ACTION a, not capable of being powered by an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

SURVEILLANCE REQUIREMENTS 4.7.6.4 The control room air conditioning units shall be demonstrated OPERA 8LE per the Surveillance Requirements of 4.7.6.3.

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- WATERFORD - UNIT 3 3/4 7-18b Amendment No.115

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PLANT SYSTEMS 3/4.7.6.5 CONTROL ROOM ISOLATION AND PRESSURIZATION

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LIMITING CONDITION FOR OPERATION 3.7.6.5 The control room envelope isolation and pressurization boundaries shall be OPERABLE.

APPLICABILITY: All MODES.

I ACTION:

With either control room envelope isolation valve in a normal outside a.

air flow path inoperable, maintain at least one isolation valve in the flowpath OPERA 8LE, and either restore the inoperable valve to i

OPERABLE status with 7 days or isolate the affected flow path 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 any control Room Emergency Filter Outside Air Intake valve (s) i inoperable, maintain at least one of the series isolation valves in a l

flowpath OPERABLE, and either restore the inoperable valve (s) to j

OPERABLE status within 7 days or isolate the affected flow path j

within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

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With more than one Control Room Emergency Filter Outside Air Intake c.

flow path inoperable, maintain at least one flow path per intake j

operable and restore an additional flow path to operable status within 7 days or, be in H0T STAN08Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD l

SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

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d.

With the control room envelope inoperable as a result of causes other than those addressed by ACTION (a), (b), or (c) above:

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Within I hour and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter while j

the control room envelope is inoperable, verify that the Emergency Breathing Airbanks pressure is greater than or equal j

to 1800 psig.

2.

MODES 1-4:

I a.

If the cause of control room envelope inoperability is due

.to a known breach in the envelope of less than or equal to one square foot tot:0 area or the breach is associated with a permanent sealing mechanism (e.g., blocking open or removing a door) f. hen operation may continue for up to 7 days after the control room envelope is declared inoperable. Otheiwise, be in NOT 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 COLD SliUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

WATERFORD - UNIT 3 3/4 7-18c Amendment No.115 l

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PLANT SyjIlH1 LIMITING CONDITION FOR OPERATION ACTION:

(Continued) b.

If the cause of control room envelope inoperability is unknown identify the cause within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

If the cause of the failure is due to a breach within the allowable limits of ACTION d.2.a then operation may continue for up to 7 days after the control room envelope is declared inoperable. Otherwise, be in HOT STAN08Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 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 />.

Should a toxic gas event occur, take immediate steps to c.

restore control room envelope integrity.

3.

~ MODES 5 and 6:

l a.

Suspend all operations involving CORE ALTERATIONS or positive reactivity changes and if a toxic gas event occurs, take immediate steps to restore control room envelope integrity.

SURVEILLANCE REQUIREMENTS 4.7.6.5 The control room envelope isolation and pressurization boundaries shall be demonstrated OPERA 8LE at least once per 18 months by:

a.

Verifying that the control room envelope can be maintained at a l

positive pressure of greater than or equal to 1/8 inch water gauge relative to the outside atmosphere with a make-up air flowrate less than or equal to 200 cfm during system operation.

b.

Verifying that on a toxic gas detection test signal, the system automatically switches to the isolation mode of operation.

Verifying that on a safety injection actuation test signal or a high c.

radiation test signal, normal outside air flow paths isolate.

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WATERFORD - UNIT 3 3/4 7-18d Amendment No. 115 t

PLANT SYSTEMS BASES i

3/4.7.5 FLOOD PROTECTION The limitation on flood protection ensures that facility protective l

actions will be taken in the event of flood conditions. The limit of elevation 27.0 ft Mean Sea Level is based on the maximum elevation at which the levee provides protection, the nuclear plant island structure provides protection to safety-related equipment up to elevation +30 ft Mean Sea Level.

3/4.7.6.1 ana 3/4.7.6.2 CONTralf00N EMERGENCY AIR FILTRATION SYSTEM During an emergency, both S-8 units are started to provide filtration and adsorption of outside air and control room envelope recirculated air t

(reference:

FSAR 6.4.3.3).

Dosages received after a full power design basis LOCA were calculated to be orders of magnitude higher than other accidents involving radiation releases to the environment (reference:

FSAR Tables l

15.6-18,15.7-2,15.7-4,15.7-5,15.7-7).

Because the consequences of a full power design basis LOCA are more severe than those occurring during COLD j

SHUTDOWN and REFUELING, a separate specification, 3/4.7.6.2, requires only one j

OPERABLE S-8 unit to guard against accidents during Modes 5 and 6.

j The OPERA 8ILITY of this system and control room design provisions are i

based on limiting the radiation exposure to personnel occupying the control room to 5 ren or less whole body, or its equivalent. This lin'tation is consistent with the requirements of General Design' Criterion 19 of Appendix A, y

10 CFR Part 50.

Operation of the system with the heaters on for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> contin-uous over a 31-day period is sufficient to reduce the buildup of moisture on i

the adsorbers and HEPA filters. Obtaining and analyzing charcoal samples after 1

l 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of adsorber operation (since the last sample and analysis) ensures j

that the adsorber maintains the efficiency assumed in the safety analysis and j

is consistent with Regulatory Guide 1.52.

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3/4.7.6.3 CONTROL R0(M AIR TEMPERATURE Maintaining the control room air temperature less than or equal to 80*F ensures that (1) the ambient air temperature does not exceed the allowable air temperature for continuous duty rating for the equipment and instrumentation in the control room, and (2) the control room will remain habitable for operations personnel during plant operation.

1 The Air Conditioning System is designed to cool the outlet air to approximate 1,y 55*F. Then, non-safety-related near-room heaters add enough heat to the air stream to keep the rooms between 70 and 75'F. Although 70 to 75"F is the normal control band, it would be too restrictive as an LC0. Control WATERFORD - UNIT 3 8 3/4 7-4a Amendment No.

L:tt:r d:t:d:

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i PLANT SYSTEMS l

BASES CONTROL ROOM AIR TEMPERATURE (Continued)

Room equipment was specified for a more general temperature range to 45 to l_

120*F. A provision for the CPC microcomputers, which might be more sensitive i

to heat, is not required here.. Since maximum outside air make-up flow in the normal ventilation mode comprises less than ten percent of the air flow from an AH-12 unit, outside air temperature has little affect on the AH-12s cooling coil heat. load. Therefore, the ability of an AH-12 unit to maintain control room temperature in the normal mode gives adequate assurance of its capability for emergency situations.

l 3/4.7.6.4 CONTROL ROOM ISOLATION AND PRESSURIZATION This specification provides the operability requirements for the control room envelope isolation and pressurization boundaries. The Limiting Condition for Operation (LCO) specifies specific ACTION STATEMENTS for inoperable components of the control room ventilation systems, separate from the S-8 and AH-12 units.

The operability of the remaining parts of the system affect the ability of the control room envelope to pressurize.

ACTION STATEMENTS a and b focus on maintaining isolation characteristics.

The valves in the flow path referred to in ACTION a are HVC-102 & HVC-101. The Outside Air Intake (OAI) " series isolation valves" of ACTION b and c are as follows:

NORTH DAI - HVC-2028 & HVC-201A HVC-202A & HVC-201B SOUTH OAI - HVC-2048 & HVC-203A HVC-204A & HVC-2038 l

ACTION STATEMENT c preserves the operator acticn (i.e., manually initiated filtered pressurization) that maintains that control room envelope at a position pressure during a radiological emergency. As indicated above each OAI series isolation-valve is powered by the opposita train. With more than one OAI flow path inoperable a single failure (i.e., train A or B) could prohibit the ability to maintain the control envelop's at a positive pressure.

Therefore, in the specified condition, ACTION c requires an additional flow l

path to be returned to service within 7 days.

ACTION STATEMENT d.2.a is intended to addresa an intentional breach in the control room pressurization boundary as necessary to support maintenance or l

modification. A breach of this nature shall be limited in size and governed under administrative controls. The size restrictions as stated in the ACTION are such that should a toxic event occur control room integrity can be immediately restored as described below. ACTION STATEMENT d.2.b is intended to restore pressurization ability as soon as possible for unintended breaches in the envelope. The 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to locate an unidentified breach is based on an WATERFORD - UNIT 3 8 3/4 7-4b Amendment No.115 L--_________________________________

PLANT SYSTEMS BASES CONTROL ROOM ISOLATION AND PRESSURIZATION (Continued) evaluation that considered troubleshooting tasks that would be performed as necessary should the integrity of the Control Room Envelope pressure boundary fall into question.

Estimated times associated with each task were based on sound engineering judgement. The ACTION statements also recognize the MODE-independent nature of the toxic chemical threat and provides for o>erator protection in the event of a toxic chemical release concurrent witt a breach in the control room envelope. In addition, provisions have been added to the 1

specification that, in the event of a toxic chemical event that threatens l

control room habitability while in the ACTION statements, "immediate steps" will be initiated to place the plant in a safe condition.

In this context, the phrase "immediate steps" is taken to mean that the operators should immediately take reasonable action to restore a known breach in the envelope to an air-tight condition. Amplifying instructions are provided in Waterford 3 Administrative procedures, which impose special controls for work that will breach the control room envelope.

3/4.7.7 CONTROLLED VENTILATION AREA SYSTEM The OPERABILITY of the controlled ventilation area system ensures that radioactive materials leaking from the penetration area or the ECCS equipment within the pump room following a LOCA are filtered prior to reaching the 1

environment.

The operation of this system and the resultant effect on offsite l

dosage calculations was assumed in the safety analyses.

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1 WATERFORD - UNIT 3 B 3/4 7-4c Amendment No.115

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UNITED STATES y

y NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 300eMcM SAFETY EVALUATION BY THE OFFICE OF NUC; EAR REACTOR REGULATI004 RELATED TO AMENOMENT N0.115 TO FACILITY OPERATING LICENSE No. NPF-38

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ENTERGY OPERATIONS. INC.

WATERFORD STEAN ELECTRIC STATION. UNIT 3 DOCKET N0. 50-382 i

1.0 INTRODUCTION

By application dated July 18, 1991, as supplemented by letters dated March 16, and December 2, 1994, and March 9, and August 30, 1995, Entergy operations,.

Inc. (the licensee), submitted a request for changes to the Waterford Steam Electric Station, Unit 3, Technical Specifications (TSs). The requested changes would revise the Control Room Air Conditioning System (CRACS) TS. The proposed amendment would subdivide TS 3/4.7.6, " Control Room A$r Condition-l ing," into five separate TSs covering the following three distinct functions:

control room emergency air filtration, control room air temperature, and j

control room isolation and pressurization. The licensee also proposed amended.

i bases sections of the TS to reflect the above changes.

The August 30, 1995, letter provided clarifying information that did not change the initial proposed no significant hazards consideration determination.

j 2.0 BACKGROUlm l

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Habitability systems are provided at nuclear reactor facilities to assure that i

operators can remain in the control room and take effective action to operate u

the plant safely under noneal operating conditions, and maintain the plant in l

a safe condition following an accident. To accomplish these functions, the CRACS at Waterford operates in one of the following three modes: nonnal operation, isolation and recirculation (toxic gas), and isolation and filtered i

recirculates with' provisions for manual initiation of pressurization using i

filtered air free one of two widely separated emergency air intakes (high radiation). A toxic chemical detection signal automatically initiates the isolation and recirculation mode of operation and overrides other CRACS I

initiation signals. A safety injection actuation signal or a high radiation detection signal automatically initiates the isolation and filtered i

recirculation mode of operation. Manual initiation of emergency modes of operation can be initiated by a control room operator at any time.

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ENCLOSURE

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p The CRACS consists of two full-capacity, redundant AH-12 air handling units; two full-capacity, redundant S-8 engineered safety features air filtration

, units, and non-safety exhaust fans and supplemental computer room air handling units.

The AH-12 air handling units are each equipped with a filter, a cooling coil supplied with essential chilled water, an electric heating element, and a centrifugal fan. The S-8 emergency filtration units are each equipped with a filter, an electric heating e'enent for dehumidification of the air stream, two HEPA filters separated by an activated charcoal bed, and a fan. The CRACS also has dual, widely separated emergency outside air intakes, and each intake has two flow paths containing one normally open, fail-as-is butterfly valve and one normally closed, fai -as-is butterfly valve in series.

he normal intake and exhaust lines are each isolated by two normally open, fail-closed butterfly valves in series. The ducting between components is constructed such that failure of one of two redundant components performing a

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specific function does not affect the redundant component performing that same p ion, nor any components performing complimentary functions.

'In the normal operating' mode, air is recirculated by one of the two redundant AH-12 air handling units, make-up air is supplied via the nomal outside air intake, and non-essential fans exhaust air from certain spaces within the control room envelope. The safety function of the CRACS performs in the normal operating mode to maintain the control room air temperature at a value that is habitab e for control room operators, and that does not cause the continuous duty temperature rating for equipment and instrumentation to be

-exceeded.

In the toxic gas mode, air is recirculated within the control room envelope by the redundant AH-12 air handling units, the exhaust fans are secured, the l

emergency outside air. intake paths are isolated by redundant valves in series, and the normal outside air intake and exhaust paths are isolated by redundant valves in series.

In this operating mode, the safety functions of the CRACS are to maintain control room temperature in an acceptable range, and reduce l

.the rate of toxic gas infiltration to an acceptable.value for protective action by the operators.

l In the high radiation mode, air is recirculated within the control room envelope by.the redundanti AH-12 air handling units, a portion of the recirculate 4.e k is through redundant S-8 emergency filtration units to

- remove radienst,tve from the air, the exhaust fans are secured, and L

the norsel entside air totake and exhaust paths are isolated by redundant valves:in sortes. ThkCRACS desiga allows a control room operator to remotely open an emergency air intake path to supply a small amount of outside air to

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the S-8 emergency filtration unit for pressurization of the control room envelope.

In the high radiation mode, the safety functions are to maintain control room temperature in an acceptable range, and to reduce the rate of infiltration of radioactive material by flitration, adsorption, and pressurization such that the calculated dose to' operators is in an acceptabl,e range.

'j The five separate proposed TSs are:. TS 3/4.7.6.1, " Emergency Air Filtration L,.

(operational modes 1 through 4);" TS 3/4.7.6.2, " Emergency Air Filtration (operational modes 5 and 6);" TS 3/4.7.6.3, " Control Room Air Temperature

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(operational modes 1 through 4);" TS 3/4.7.6.4, " Control Room Air Temperature l

(operational modes 5 and 6);" and TS 3/4.7.6.5, " Control Room Isolation and Pressurization."

Inoperability of the S-8 emergency filtration units is addressed by the proposed action statements of TS 3/4.7.6.1 and TS 3/4.7.6.2.

The proposed action statements of TS 3/4.7.6.3 and TS 3/4.7.6.4 address inoperability of the AH-12 air handling units.

Finally, the proposed action statements of TS 3/4.7.6.5 address inoperability of the control room isolation l

and pressurization functions.

3.0 EVALUATION The staff has reviewed the design configuration of the control room habitability systems at Waterford. Based on that review, the staff concluded that the principle components of the system are functionally independent.

The staff determined tnat the components share reliance on the electrical l

distribution system, but a separate TS addresses the potential effects of electrical distribution system inoperability on the essential components of the CRACS. Therefore, the splitting of TS 3/4.7.6 into functionally independent specifications is acceptable.

The proposed TS 3/4.7.6.1 retains the limiting condition for operation, action l

statements, and surveillance requirements from the existing TS that are applicable to the S-8 emergency filtration units in operational modes 1, 2, 3, and 4 (power operation, startup, hot standby, and hot shutdown, respectively).

The proposed limitino condition for o wration specifies that both 5-8 control room emergency air f'Itration units stall be operable.

Proposed action statement 3.7.6.1.a applies to conditions where one control room emergency air filtration train is inoperable. This action statement is i

censistent with the improved standard technical specifications for Combustion Engineering -(CE) plants (NUREG-1432), and the allowed outage time of seven days with one inoperable emergency filtration train is consistent with the L

safety importance of the system. Therefore, proposed action statement 3.7.6.1.a is acceptable.

Proposed acties statement 3.7.6.1.b applies when both control room emergency filtration trefas are i rable. This action statement, as modified by letter dat

.MarghtlGr.!

, is also consistent with the improved standard technical ffcaties k for CE plants (NUREG-1432), and the required actions, which are i feal-ta those under TS 3.0.3, are also consistent with the safety importance of the system. Therefore, proposed action statement 3.7.6.1.b is acceptable.

The surveillance test requirements of TS 4.7.6.1 implement the guidance of Regulatory Guide 1.52, " Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorpt< on Units of Light-Water-Cooled Nuclear Power Plants." Therefore, the surveillance test requirements are acceptable.

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.-- Proposed TS 3/4.7.6.2 retains the limiting condition for operation, the action statements and the applicable surveillance requirements-from the existing TS that are applicable to the S-8 emergency filtration units in operational modes 5 and 6 (cold shutdown and refueling, respectively). The action statement for one inoperable train in operational modes 5 and 6, specifies restoring the inoperable train to operable status within 7 days or placing the remain' ng operable train in operation in its emergency mode, otherwise it will require suspending activities with the potential to release l

radioactivity. This action statement ensures that the remaining train is operable, the failures preventing automatic actuation will have no effect, and any active failure will be readi' y detected. Proposed action statement 3.7.6.2 requires suspension of operations involving core alterations or positive-reactivity changes when both control room emergency filtration trains are inoperable.- The staff finds the proposed limiting condition for operation for operational modes 5 and 6 consistent with the existing TS for Waterford 3 and with the staff's current position in NUREG-1432. Thus, it is acceptable.

Proposed surveillance requirement 4.7.6.2 invokes the surveillance requirements of proposed TS 3/4.7.6.1 for the S-8 emergency filtration units, thereby implementing the guidance of Regulatory Guide 1.52 (RG 1.52).

Therefore, this proposed surveillance requirement is acceptable.

Proposed TS 3/4.7.6.3 and TS 3/4.7.6.4 establish limiting conditions for operation and action statements for the M-12 air handling units that are similar to the provisions of proposed TS 3/4.7.6.1 and TS 3/4.7.6.2 for the S-8 emergency filtration units. Proposed TS 3/4.7.6.3 applies in operational modes 1, 2, 3, and 4, and proposed TS 3/4.7.6.4 applies in operational modes 5 and 6.

Proposed TS 3/4.7.6.3 maintains a limiting condition for operation that specifies that two independent control room air conditioning units shall be operable. This limiting condition for operation is acceptable because it ensures at least one operable, full-capacity M-12 air handling unit will remain operable following a postulated single failure.

Proposed action statement 3.7.6.3.a applies to conditions where one control room emergenty air conditioning unit is inoperable. This action statement i

specifies as allowed outage time of seven days to restore the one inoperable M-12 air hand 41 unit to operable status, which is conservative relative to j

the 30-day all estage time for one inoperable control room cooling-system

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prescribed by the improved standard TSs for CE plants (NUREG-1432). However, the licensee stated that, because maximum outside air makeup flow is less than 10 percent of the M-12 unit air flow, outside air temperature has little effect on heat removal requirements. Therefore, maintenance of an acceptable I

control reca air temperature is dependent on availability of an M-12 air handling unit, and a 7-day allowed outage time for one inoperable unit is appropriate.

If the inoperable M-12 unit is not restored to operable status within~seven days, the action statement specifies placing the reactor in hot standby in the next six hours, and 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 />, which the staff concluded is an appropriate set of actions for that condition.

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l 1 Proposed action statement 3.7.6.3.b specifies an allowed outage time of one hour to restore one AH-12 unit to operable status when both AH-12 air handling units are inoperable. This action statement is consistent with the improved standard TSs for CE plants (NUREG-1432), and the required actions, which are identical to those under TS 3.0.3, are also consistent with the safety importance of the system.

l Proposed surveillance requirements 4.7.6.3.a and 4.7.6.3.b are intended to demonstrate operability of the control room air conditioning units.

Proposed surveillance requirement 4.7.6.3.a is similar to an existing surveillance requirement, and it specifies verification that average control room air l

temperature is less than or equal to 80*F at leest once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The

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essential chilled water system, which provides cooling water to the AH-12 units, is governed by a separate TS, so surveillance requirement 4.7.6.3.a involves only the cooling coil and fan portions of the AH-12 air handling unit.

Because, as descr' bed above, seasonal outside air temperature changes have a minor effect on the heat removal necessary to maintain a stable control room temperature, periodic verification of control room temperature provides acceptable assurance that the cooling coil and fan of the operating AH-12 unit l

are performing adequately. Surveillance requirement 4.7.6.3.b is an l

additional surveillance test proposed by the licensee that specifies l

verification that each AH-12 unit starts and operates on a quarterly basis.

The staff concluded that surveillance requirements 4.7.6.3.a and 4.7.6.3.b provide acceptable assurance that both AH-12 units are capable of starting and operating when necessary, and are acceptable.

Proposed TS 3/4.7.6.4 retains the existing limiting condition for operation in L

operational modes 5 and 6 which specifies that both control room air conditioning units shall be opera >1e.

The action statement for one inoperable air conditioning unit in operational modes 5 and 6 specifies restoring the inoperable system to operable status within seven days, or placing the remaining operable unit in operation. This action statement ensures that the l

remaining train is operable, the failures preventing automatic actuation will have no effect, and any active failure will be read'ly detected. Proposed action statement 3.7.6.4b requires suspension of operations involving core alterations or itiveL reactivity changes when both control room air conditioni are feoperable. The staff finds'the proposed limiting l

condition-femfer operational modes 5 and 6 consistent with the i

existi 3 and with the staff's current position in NUREG-l 1432.

j, acceptable,

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Propged survetTiance' requirement 4.7.6.4 invokes the surveillance r 4 S1ments of proposed TS 3/4.7.6.3 for the AH-12 air handling units.

l Therefore, this proposed surveillance requirement is acceptable.

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Proposed TS 3/4.7.6.5 adds a limiting condition for operation that specifies that the control room envelope isolation and pressurization boundaries shall be operable.

Proposed action statements 3.7.6.5.a, 3.7.6.5.b and 3.7.6.5 4 l

specify actions for inoperable conditions affecting the ability to isolate the i

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i I normal outside air flow paths, isolate the emergency air intake paths, and maintain at least one flow path for each emergency intake operable for control i

room pressurization, respectively.

Each of these action statements permits an

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allowed outage time of seven days when the functional capability is maintained but redundancy is lost.

Because the valves in eacn flow path affect only the ability to isolate or pressurize the control room envelope and not to recirculate air within the control room, valve operability is independent of the operability of the S-8 emergency filtration units and the AH-12 air handling units. The 7-day allowed outage time and the actions specified when the allowed outage time is not satisfied are consistent with the corresponding

. specifications for the emergency filtration units and control room air i

conditioning units for a loss of functional capability of the redundant component when the functional capability of the remaining operable component is maintained. Therefore, proposed action statements 3.7.6.5.a. 3.7.6.5.b, l

and 3.7.6.5.c are acceptable.

l Proposed action statement 3.7.6.5.d addresses control room envelope inoperability resulting from causes other than those addressed by proposed action statements 3.7.6.5.a. 3.7.6.5.b, and 3.7.6.5.c.

Therefore, this, proposed action statement applies to breaches in the control ;*oom envelope other than the design intake and exhaust locations in the.CRACS. The licensee has proposed additional action statement that permits breaches in the control roce envelope for a period not to exceed seven days on an intermittent basis under administrative control provided that the breach origin is known and the characteristics of the breach allow operators to readily seal the breach in an effective manner. The purpose of this action statement is to provide a i

maintenance and modification provision during normal operation that would permit minor changes to the control room envelope boundary while the unit f s operating at power.

Proposed action statement 3.7.6.5.d.1 specifies pericdic verification that the emergency breathing air bank pressure is adequate when the control room envelope "ygg..

The licensee justified this proposed change on the basis of the conservative

-nature of control room habitability analyses, the capability to readily

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eitigate the. impact on operators of a degraded control room envelope boundary, and the very low probability of an event requiring control room isolation i

during the short period a known breach is allowed to exist with the reactor operating at power. The control room habitability analyses assume that the control room is surrounded by a cloud of toxic or radioactive material and that the post-isolation in-leakage would occur directly from that cloud.

Actually, the control room is bounded on three sides by the reactor auxiliaries building (RAB), and on a fourth side by the turbine building.

The

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two ressining sides, neither of which has doors or other penetrations, are exposed to tae outside atmosphere. Because the wall shared with the turbine

, building has only an air-lock door and the walls shared with the RA8 contain many more penetrations, the licensee concluded that most in-leakage to the control room would be from the RA8. The licensee determined by analysis that toxic chemical concentrations in the control room are almost entirely from in-leakage after isolation.

By considering the effect of the RA8 on control room 1

toxic chemical concentrations, the licensee determined that the rate of

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buildup in toxic cheetcal concentration would be slower than the rate i

determined assuming direct in-leakage from the outside atmosphere.

Based on I

this information, the licensee concluded that operators would have adequate l

time to don protective breathing apparatus before being exposed to elevated levels of toxic chemicals for any credible breach of the control room l

l envelope.

The staff determined thct the open doors and small breaches in the walls

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forming the control room envelope, which would probably communicate with the i

RA8, would not have a si ificant effect on performance of the control room envelope because the dif rential pressure and the associated air flow between surrounding areas and the control room would be small when the CRACS is l

operated in the isolation mode. Additionally, an emergency air supply s sted J

l for the control room at Waterford is designed to provide a six hour supp y of j

breathable air at a rate of six scfm for each of 17 control room and security personnel. This provision complies with the guidance of Regulatory Guide 1.78

' (RG 1.78), " Assumptions for Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release," where

' possible hazardous chwical accidents any be of long duration and may cause the applicable toxiciwy limits to be exceeded. Finally, monitoring of the l

installed gas detection systems and notification of industrial emergencies l

through the St. Charles Parish Emergency Preparedness / Industrial Hotline System provides the control room operators with enhanced identification capability for toxic chemical emergencies and a greater probability that.

adequate time will be available to take protective actions.

The licensee stated that administrative procedures place special controls on work that will breach the control room envelope. The special controls include provision of an ese taining materials necessary to restore control room

' air-t'ght condition. With the exception of notific ts, the above considerations also apply to events involvin ease.

The staf0 tion statement 3.7.6.5.d to be acceptable based on the following tensiderettens:

1) the low probability of a challenge to the control room envelope during the period where an identified breach in the control room envelope may exist while the plant is in operational modes 1, 2, 3, or 4; 2) the conservative nature of the design basis toxic chemical and radiological event analyses; l

l 3) the features available at Waterford that provide enhanced identification capability for toxic chemical events;

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4) the characteristics of permitted breaches in the control room envelope are such that actions to restore control room envelope integrity would have a high probability of success; and the permanently installed emergency breathin 5) periodic verification of air bank pressure. g air banks and the Proposed surveillance requirements 4.7.6.5.a. 4.7.6.5.b, and 4.7.6.5.c retain the portions of the existing surveillance requirements applicable to the isolation and pressurization functions of the CPACS. Proposed surveillance requirement 4.7.6.5.a modifies'the existing surveillance requirement by specifying that the control room pressurization function be demonstrated with a make-up air flow rate of less than or equal to 200 cfa. This specific flow i-rate is consistent with the radiological analyses. Therefore, these proposed surveillance requirements are acceptable.

i Based on the above discussion the staff has found that the proposed revision to TS 3.7.6 is acceptable. The division of the original TS into separate specifications based on function is acceptable bect.use the individual specifications apply to functionally independent components and retain substantially all of the original limiting conditions for operation, action l

statements, and surveillance requirements. The most significant chan the creation of an allowed outage time for the control room envelope,ge was which the staff found to be acceptable based on the low probability of an event requiring control room isolation during the period the control room envelope is degraded, and the reasonable assurance that the operators would be adequately protected if an event requiring control room isolation occurred with a degraded control room envelope.

4.0 STATE CONSULTATIM In accordance with the Commission's regulations, the Louisiana State official was notified,of tha issuance of the amendment. The State official had no commutMJ..

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5.0 The amindeshgrc d

trement with respect to installation or use of a

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facility component Tocat within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significantThange in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Comeission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (56 FR 43808 and 60 FR 29875).

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' Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22 environmental impact statement or environmental assessment need be pr(b) no epared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that:

(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 compilance with the Commission's 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 tho' public.

Principal Contributor:

S. Jones Date: October 4, 1995 1

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