ML033570118

Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process

ML033570118
Person / Time
Site:	Waterford
Issue date:	12/19/2003
From:	Peters K Entergy Nuclear South
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML033570118 (16)

Text

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Entergy Nuclear South Entergy Operations, Inc.

17265 River Road Killona. LA 70066 Tel 504 739 6440 Enteroy Fax 504 739 6698 kpeterseentergy.com Ken Peters Director Nuclear Safety Assurance Waterford 3 W3F1 -2003-0093 December 19, 2003 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License Amendment Request NPF-38-252 License No. NFP-38

Reference:

Entergy Letter W3F1-2003-0074, J. Venable to USNRC, "License Amendment Request NPF-38-249, Extended Power Uprate," November 13, 2003.

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests the following amendment to the Technical Specifications (TS) for Waterford Steam Electric Station, Unit 3 (Waterford 3).

The proposed amendment will delete the TS requirements related to hydrogen recombiners and hydrogen monitors. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003 as part of the consolidated line item improvement process (CLIIP). provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. Attachment 2 provides the existing TS pages marked-up to show the proposed change. Implementation of TSTF-447 also involves various changes to the TS Bases. The TS Bases changes will be submitted with a future update in accordance with TS 6.16, Technical Specifications Bases Control Program."

W3Fl-2003-0093 Page 2 of 3 The proposed change includes a new commitment as summarized in Attachment 3.

Entergy submitted a license amendment request for an Extended Power Uprate (EPU) by the above referenced letter. The removal of the recombiners and the analyzers from the TS was considered in our evaluation of the EPU. Entergy requests approval of the proposed amendment by December 30, 2004. Once approved, the amendment shall be implemented within 120 days. This will support implementation of both the EPU and this proposed change in conjunction with Waterford 3's Spring 2005 refueling outage.

If you have any questions or require additional information, please contact Ron Byrd at 601-368-5792.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 19, 2003.

Sincerely, K BBM/cbh Attachments:

1. Analysis of Proposed Technical Specification Change

2. Proposed Technical Specification Changes (mark-up)

3. List of Regulatory Commitments

W3F1 -2003-0093 Page 3 of 3 cc: Mr. Bruce S. Mallett U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Senior Resident Inspector Waterford NPS P.O. Box 822 Killona, LA 70066-0751 U.S. Nuclear Regulatory Commission Attn: Mr. Nageswaran Kalyanam MS 0-7D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway Attn: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn Attn: N.S. Reynolds 1400 L Street, NW Washington, DC 20005-3502 Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division P. 0. Box 4312 Baton Rouge, LA 70821-4312 American Nuclear Insurers Attn: Library Town Center Suite 300S 29 th S. Main Street West Hartford, CT 06107-2445

W3F1 -2003-0093 Page 4 e-mail: Standard Distribution bcc: Waterford 3 Records Center (W-GSB-1 00)

TSCR File (NPF-38-252)

Licensing Green Folder File

Attachment 1 W3FI-2003-0093 Analysis of Proposed Technical Specification Change A

to W3F1-2003-0093 Page 1 of 3

1.0 INTRODUCTION

This letter is a request to amend Operating License NPF-38 for Waterford Steam Electric Station, Unit 3 (Waterford 3). The proposed License amendment deletes Technical Specification (TS) 3.6.4.1, Hydrogen Analyzers," and TS 3.6.4.2, "Electric Hydrogen Recombiners -W." The proposed TS changes support implementation of the revisions to 10 CFR 50.44, Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.

The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003, as part of the consolidated line item improvement process (CLIIP).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 of TSTF-447, the proposed TS changes include:

TS 3.6.4.1 Hydrogen Analyzers Deleted TS 3.6.4.2 Electric Hydrogen Recombiners - W Deleted Other TS changes included in this application are limited to renumbering and formatting changes that resulted directly from the deletion of the above requirements related to hydrogen recombiners and hydrogen monitors (analyzers).

As described in NRC-approved Revision 1 of TSTF-447, the changes to TS requirements results in changes to various TS Bases sections. The TS Bases changes will be submitted with a future update in accordance with TS 6.16, Technical Specifications Bases Control Program."

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

5.0 TECHNICAL ANALYSIS

Entergy has reviewed the safety evaluation (SE) published on September 25, 2003 (68 FR 55416) as part of the CLIIP Notice of Availability. This verification included a review of the NRC staffs SE, as well as the supporting information provided to support TSTF-447. Entergy has to W3Fl-2003-0093 Page 2 of 3 concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to Waterford 3 and justify this amendment for the incorporation of the changes to the Waterford 3 TS.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on September 25, 2003 (68 FR 55416) for this TS improvement, Entergy is making the following verifications and regulatory commitments:

1. Entergy has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at Waterford 3 and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be included in the Technical Requirements Manual (TRM). This regulatory commitment will be implemented within 120 days of amendment issuance.

2. Waterford 3 does not have an inerted containment.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION Entergy has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416) as part of the CLIIP. Entergy has concluded that the proposed determination presented in the notice is applicable to Waterford 3 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

8.0 ENVIRONMENTAL EVALUATION Entergy has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416) as part of the CLIIP. Entergy has concluded that the staffs findings presented in that evaluation are applicable to Waterford 3 and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. Entergy is not proposing variations or deviations from the TS changes described in TSTF-447 or the NRC staff's model SE published on September 25, 2003 (68 FR 55416).

to W3F1 -2003-0093 Page 3 of 3

10.0 REFERENCES

Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003 (68 FR 55416).

Attachment 2 W3FI-2003-0093 Proposed Technical Specification Changes (mark-up) to W3FI-2003-0093 Page 1 of 5 LIMTNG CON IQNS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3'4.6 CONTAINMENTSYSTEMS 34.0.1 PRIMAARY CONTAINMENT CONTAINMENT INTEGRITY. . . 314 6-1 CONTAINMENT LEAKAGE . ............................... 314 62 CONTAINMENT AIR LOCKS. 314 6-9 INTERNAL PRESSURE .3 4 611 AIR TEMPERATURE. 314 6-13 CONTAINMENT VESSEL STRUCTURAL INTEGRITY 34 6-14 CONTAINMENT VENTILATION SYSTEM........................ 34 6-15 314.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY SYSTEM . ........................... 3'4 6-16 CONTAINMENT COQUNG SYSTEM ........................... 3!4 6-18 3!4.6.3 CONTAINMENT ISOLATION VALVES ............................ 314 6-19 3!4.6.4 G9t.!UZTiILbE SAS CCIfTR3L (e I, e, E .

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3/4.6.5 VACUUM RELIEF VALVES . . .34 6-36 314.6.6 SECONDARY CONTAINMENT SHIELD BUILDING VENTILATtON SYSTEM 314 6-37 SHIELD BUILDING INTEGRITY ................... 314 640 SHIELD BUILDING STRUCTURAL INTEGRITY 314 6-41 3f4.7 PLANT SYSTEMIS 3f4.7.1 TURBINE CYCLE SAFETY VALVES.. 34 7-1 EMERGENCY FEEDWATER SYSTEM . . 34 7-4 CONDENSATE STORAGE POOL . . 314 7-6 WATERFORD - UNIT 3 Vi AlvENDMENT NO. 188 to W3Fl-2003-0093 Page 2 of 5 INDEX BASES SECTION PAGE 314.4 REACTOR COOLANT SYSTEM (Continued) 3/4.4.5 REACTOR COOLANT SYSTEM LEAKAGE ....................... B 3/4 4-4 314.4.6 CHEMISTRY ............................................ B 3/4 44 3/4.4.7 SPECIFIC ACTIVITY ............................................ B 3/4 4-5 3/4.4.8 PRESSURE/TEMPERATURE LIMITS ................................. B 3/4 4-6 3/4.4.10 REACTOR COOLANT SYSTEM VENTS ............................ B 3/4 4-11 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3/4.5.1 SAFETY INJECTION TANKS .B 3/4 5-1 314.5.2 and 3/4.5.3 ECCS SUBSYSTEMS .B 3/4 5-1b 3/4.5.4 REFUELING WATER STORAGE POOL .B 3/4 5-3 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT ............................................ B 3/4 6-1 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS ................ B 3/4 6-3 3/4.6.3 CONTAINMENT ISOLATION VALVES .................................... B 3M4 6-5

-3..4 BUSTILE CNTROL ............................................

AS D 3'4 3/4.6.5 VACUUM RELIEF VALVES ............................................. B 314 6-6 314.6.6 SECONDARY CONTAINMENT ............................................. ,. B 3/4 6-7 314.7 PLANT SYSTEMS 314.7.1 TURBINE CYCLE .B 3/4 7-1 314.7.2 STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION .B 314 7-3d WATERFORD - UNIT 3 Xl AMENDMENT NO. 88, 1B9, to W3Fl-2003-0093 Page 3 of 5 PAGES 3/4 6-22 THROUGH PAGE 34 G6 D3*5 J NOT USED WATERFORD - UNIT 3 (Next PaTe is i/4X)-UTAn Amendment No. 75 7

to W3Fl-2003-0093 Page 4 of 5 CONTAINMENT SYSTEMS 3 4.6.4 CO$4USTIBLE GAS CONTROL HYDRREN ANALYZERS LIMITING ONDITION FOR OPERATION 3.6.4.1 Two dependent containment hydrogen analyzers shall be ERABLE.

APPLICA8ILITY: DES 1 and 2.

ACTION:

a. With one con lnient hydrogen analyzer noper 1e, restore the inoperable ana zer to OPERABLE status ithl 30 days or be in at least HOT STAND within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b. With both contai t hydrogen analyzer noperable, restore at least one analyzer OPERABLE status thin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and comply with the requirements f ACTION a, or e 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 /> SURVEILLANCE REQUIREMENTS 4.6.4.1 At least once per 31 day each Hydro n Analyzer shall be demonstrated OPERABLE by performing a CHANNE CALIBRATION u *ng sample gases containing a nominal:/\

a. Zero volume percey hydrogen, balance nit gen.

b. 9.5 volu . prnt hydrogen, balance ntroge ATERFORD - UNIT 3 3f4 6-34 Amendment No. 42 to W3F1 -2003-0093 Page 5 of 5 CONTIHPENTSYSTEMS HYDR06EN RECOMBINERS -X/

LIHI5 CODITION-FQR PERATION/

3.6.4.2 o ndependent containment hydrogen rcombiner systems sha be OPERABLE.

AELICABILI MODES 1 and 2.

AtTI0HN\:

With one hydrogen r oibInern system Inoperable, restore th Inoperable system to PERABLE status w in 30 days or be n at least OT S PDBY within the next hours.\

SURVEILLANCE REOVIREMENT 4.6.4.2 Each hydrogen recorbin system shall e demonstrated OPERABLE at least once per IS months by:

a. Performing a system funct1 I t for each hydrogen recombiner.

b. Visually examining recombiner nclosure and verifying there s no evidence of abnormal conditi C. Performing a resistance t ground est for each heater phase.

/ORD - UIT 3 3/4 6-35 Amendment o I

Attachment 3 W3FI-2003-0093 List of Regulatory Commitments to W3Fl-2003-0093 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check o e) SCHEDULED ONE- CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)

Entergy has verified that a hydrogen monitoring X Within 120 system capable of diagnosing beyond design-basis days of accidents is installed at Waterford 3 and is making a amendment regulatory commitment to maintain that capability. issuance.

The hydrogen monitors will be included in the Technical Requirements Manual (TRM).

t t +