W3F1-2005-0075, License Amendment Request NPF-38-266, Remove Limitation to Perform Various Surveillance Only During Shutdown

License Amendment Request NPF-38-266, Remove Limitation to Perform Various Surveillance Only During Shutdown

ML053040461
Person / Time
Site:	Waterford
Issue date:	10/27/2005
From:	Walsh K Entergy Nuclear South, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NPF-38-266, W3F1-2005-0075
Download: ML053040461 (27)

Text

Entergy Nuclear South ergy tKillona, CJ17265 Entergy Operations, Inc.

River Road LA 70057 Tel 504 464 3178 Kevin T. Walsh General Manager, Plant Operations Waterford 3 W3F11-2005-0075 October 27, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request NPF-38-266 Remove Limitation to Perform Various Surveillances Only During Shutdown Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests the following amendment for Waterford Steam Electric Station, Unit 3 (Waterford 3). Revisions to the Technical Specification (TS) Surveillance Requirements (SR) 4.5.2e (Safety Injection),

4.6.2.1d (Containment Spray), and 4.7.3b (Component Cooling Water/Auxiliary Component Cooling Water) are requested to remove the words "during shutdown." This will provide flexibility allowing components required to be tested by these SRs to be tested online.

Additionally, a revision to delete TS SR 4.7.12.1c (Essential Services Chilled Water) is requested. A modification permanently separating the safety and non-safety portions of the Essential Services Chilled Water system has eliminated the need for automatic isolation valves and thus this SR.

The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards consideration. The bases for these determinations is included in the attached submittal.

The proposed change does not include any new commitments.

Entergy requests approval of the proposed amendment by 30 September 2006 in order to support the fall 2006 refueling outage. Once approved, the amendment shall be implemented within 60 days. Although this request is neither exigent nor emergency, your prompt review is requested.

t~ I

W3F1-2005-0075 Page 2 of 3 If you have any questions or require additional information, please contact D. Bryan Miller at 504-739-6692.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 27, 2005.

KTW/DBM/cbh Attachments:

1. Analysis of Proposed Technical Specification Change

2. Proposed Technical Specification Changes (mark-up)

W3F11-2005-0075 Page 3 of 3 cc: Dr. Bruce S. Mallett U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Senior Resident Inspector Waterford 3 P.O. Box 822 Killona, LA 70066-0751 U.S. Nuclear Regulatory Commission Attn: Mr. Nageswaran Kalyanam MS O-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 1700 K Street, NW Washington, DC 20006-3817 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 2 9 th S. Main Street West Hartford, CT 06107-2445 Morgan, Lewis & Bockius LLP ATTN: T.C. Poindexter 1111 Pennsylvania Avenue, NW Washington, DC 20004

Attachment I W3Fl-2005-0075 Analysis of Proposed Technical Specification Change to W3Fl-2005-0075 Page 1 of 18

1.0 DESCRIPTION

This letter is a request to amend Operating License NPF-38 for Waterford Steam Electric Station, Unit 3 (Waterford 3).

The proposed changes will revise the Operating License to remove the words 'during shutdown" from Technical Specification (TS) Surveillance Requirements (SR) 4.5.2e (Safety Injection), 4.6.2.1 d (Containment Spray), and 4.7.3b (Component Cooling Water/Auxiliary Component Cooling Water). This will allow testing to be performed online. Additionally, a change to delete TS SR 4.7.12.1c (Essential Services Chilled Water) is requested as a result of a plant modification that eliminated the automatic isolation valves tested by this SR.

2.0 PROPOSED CHANGE

TS SR 4.5.2e currently states:

e. At least once per 18 months, during shutdown, by:

1. Verifying that each automatic valve in the flow path actuates to its correct position on SIAS and RAS test signals.

2. Verifying that each of the following pumps start automatically upon receipt of a safety injection actuation test signal:

a. High pressure safety injection pump.

b. Low pressure safety injection pump.

3. Verifying that on a recirculation actuation test signal, the low pressure safety injection pumps stop, the safety injection system sump isolation valves open.

Proposed TS SR 4.5.2e will state:

e. At least once per 18 months by:

1. Verifying that each automatic valve in the flow path actuates to its correct position on SIAS and RAS test signals.

2. Verifying that each of the following pumps start automatically upon receipt of a safety injection actuation test signal:

a. High pressure safety injection pump.

b. Low pressure safety injection pump.

3. Verifying that on a recirculation actuation test signal, the low pressure safety injection pumps stop, the safety injection system sump isolation valves open.

TS SR 4.6.2.1d currently states:

d. At least once per 18 months, during shutdown, by:

1. Verifying that each automatic valve in the flow path actuates to its correct position on a CSAS test signal.

2. Verifying that upon a recirculation actuation test signal, the safety injection system sump isolation valves open and that a recirculation mode flow path via an OPERABLE shutdown cooling heat exchanger is established.

3. Verifying that each spray pump starts automatically on a CSAS test signal.

Proposed TS SR 4.6.2.1d will state:

d. At least once per 18 months by:

1. Verifying that each automatic valve in the flow path actuates to its correct position on a CSAS test signal.

to W3F11-2005-0075 Page 2 of 18

2. Verifying that upon a recirculation actuation test signal, the safety injection system sump isolation valves open and that a recirculation mode flow path via an OPERABLE shutdown cooling heat exchanger is established.

3. Verifying that each spray pump starts automatically on a CSAS test signal.

TS SR 4.7.3b currently states:

b. At least once per 18 months, during shutdown, by verifying that each automatic valve servicing safety-related equipment actuates to its correct position on SIAS and CSAS test signals.

Proposed TS SR 4.7.3b will state:

b. At least once per 18 months by verifying that each automatic valve servicing safety-related equipment actuates to its correct position on SIAS and CSAS test signals.

TS SR 4.7.12.1c currently states:

c. At least once per 18 months during shutdown, by verifying that each automatic valve servicing safety-related equipment actuates to its correct position on a safety injection actuation test signal.

Proposed TS SR 4.7.12.1 c will state:

c. Deleted In summary, TS SR 4.7.12.1c (Essential Services Chilled Water) is being deleted and the

'during shutdown" limitation is being removed from TS SRs 4.5.2e (Safety Injection), 4.6.2.1d (Containment Spray), and 4.7.3b (Component Cooling Water/Auxiliary Component Cooling Water).

TS Bases changes are not planned in support of this License Amendment Request.

3.0 BACKGROUND

3.1 Safety Injection System The safety injection system (SIS) is designed to provide core cooling in the unlikely event of a loss of coolant accident (LOCA). The SIS fluid must contain sufficient neutron absorbers to maintain the core subcritical for the duration of a LOCA. In addition, the SIS functions to inject borated water into the reactor coolant system (RCS) to add negative reactivity to the core in the unlikely event of a steam line rupture. Safety injection is also initiated in the event of a steam generator tube rupture or a control element assembly ejection incident. Additional information on the SIS can be found in Final Safety Analysis Report (FSAR) Section 6.3.

The SIS is automatically initiated upon the receipt of a safety injection actuation signal (SIAS). The contents of the reactor water storage pool (RWSP) are injected into the RCS by two sets of full capacity pumps. Each set contains one high-pressure safety injection (HPSI) pump and one low-pressure safety injection (LPSI) pump. Long-term core cooling is accomplished by recirculating the water in the SIS sump using the HPSI pumps upon receipt of a recirculation actuation signal (RAS). The switchover to W3Fl-2005-0075 Page 3 of 18 from injection to recirculation occurs automatically when the level of RWSP reaches the RAS setpoint.

Simplified flow diagrams are provided below for HPSI and LPSI.

TS SR 4.5.2e verifies that each automatic valve in the SIS flow path from the RWSP to RCS actuates to its correct position and that the HPSI and LPSI pumps start on an SIAS test signal. Additionally, TS SR 4.5.2e verifies that the LPSI pump stops and the SIS sump isolation valves open on an RAS test signal. This surveillance provides a level of assurance that the SIS will align and respond as assumed in the safety analysis. The following components are tested in accordance with TS SR 4.5.2e:

Component Description K-Relay Function S10002A HPSI Pump A K110A start on SIAS S10002B HPSI Pump B K11 OB start on SIAS S10002AB HPSI Pump AB K11 OA or start on SIAS*

K110B S10001A LPSI Pump A K1 10A start on SIAS S10001A LPSI Pump A K104A trip on RAS S0i001 B LPSI Pump B K11OB start on SIAS S10001 B LPSI Pump B K104B trip on RAS SI-106A RWSP Outlet Valve K11OA open on SIAS SI-106B RWSP Outlet Valve K1 10B open on SIAS SI-1 38A LPSI Flow Control Valve to Loop 2B K302A open on SIAS SI-1 38B LPSI Flow Control Valve to Loop 1B K401 B open on SIAS SI-1 39A LPSI Flow Control Valve to Loop 2A K409A open on SIAS SI-1 39B LPSI Flow Control Valve to Loop IA K403B open on SIAS Si-225A HPSI Flow Control Valve to Loop 1A K403A open on SIAS SI-225B HPSI Flow Control Valve to Loop IA K403B open on SIAS SI-226A HPSI Flow Control Valve to Loop 1B K301A open on SIAS SI-226B HPSI Flow Control Valve to Loop 1B K401 B open on SIAS Sl-227A HPSI Flow Control Valve to Loop 2A K409A open on SIAS to W3F1-2005-0075 Page 4 of 18 Component Description K-Relay Function SI-227B HPSI Flow Control Valve to Loop 2A K302B open on SIAS S-228A HPSI Flow Control Valve to Loop 2B K302A open on SIAS Sl-228B HPSI Flow Control Valve to Loop 2B K409B open on SIAS SI-301 RCS Loop 1 Hot Leg Injection Drain K403A close on SIAS

_____ _____ V alve _ _ _ _ _ _

SI-302 RCS Loop 2 Hot Leg Injection Drain K302B close on SIAS

_________ SValve IeiTk La e_ con_

SI-303A Safety Injection Tank 1A Leakage K302A close on SIAS

____ _ SafetyDrain Tn2Lke__len_

SI-303B Safety Injection Tank I B Leakage K401 B close on SIAS

_____ _____ D rain _ _ _ _ _ _

SI-304A Safety Injection Tank 2A Leakage K409A close on SIAS

_____ _____ D rain_ _ _ _ _ _ _

SI-304B Safety Injection Tank 2B Leakage K403B close on SIAS

_____ _____ D rain _ _ _ _ _ _

SI-602A SI Sump Outlet A KI110A close on SIAS SI-602A SI Sump Outlet A K309A open on RAS SI-602B SI Sump Outlet B K11 OB close on SIAS SI-602B SI Sump Outlet B K309B open on RAS SI-6011 LPSI Header Auto Vent Isolation K302A close on SIAS SI-6012 LPSI Header Auto Vent Isolation K302B close on SIAS SI-14023A LPSI Vent Isolation K302A close on SIAS SI-14024A LPSI Vent Isolation K302A close on SIAS

• Starts if AB pump is aligned to replace either the A or B pump.

3.2 Containment Spray System The containment spray system (CSS) is one of two containment heat removal systems credited in the safety analysis. The function of the containment heat removal systems under accident conditions is to remove heat from the containment atmosphere, thus maintaining the containment pressure and temperature at acceptably low levels. The containment heat removal systems also serve to limit offsite radiation levels by reducing the pressure differential between the containment atmosphere and the external environment, thereby decreasing the driving force for fission product leakage across the containment. Additional information on the containment heat removal systems can be found in FSAR Section 6.2.2.

Containment spray is automatically initiated by the containment spray actuation signal (CSAS). The CSS has two modes of operation which are: a) the injection mode, during which the system sprays borated water from the RWSP into the containment, to W3Fl-2005-0075 Page 5 of 18 and b) the recirculation mode, which is automatically initiated by the RAS after low level is reached in the RWSP. During the recirculation mode of operation, suction for the spray pumps is from the SIS sump.

A simplified flow diagram of the CSS is provided below. Note that while shown separately, HPSI, LPSI, and CSS share common RWSP and SIS sump suctions.

TS SR 4.6.2.Id verifies that each automatic valve in the CSS flow path actuates to its correct position, the CSS pumps start on a CSAS and the SIS sump isolation valves open on a RAS test signal. This surveillance provides a level of assurance that the CSS will align and respond as assumed in the safety analysis. The following components are tested in accordance with TS SR 4.6.2.1d:

Component Description K-Relay Safety ID A _ContanmentprayPupA______staFunction CS0001A Containment Spray Pump A K111A start on CSAS CS0001 B Containment Spray Pump B KillB start on CSAS CS-125A Containment Spray Header A Isolation K304A open on CSAS CS-i 25B Containment Spray Header B Isolation K304B open on CSAS Sl-602A Si Sump Outlet A K309A open on RAS ISI-602B ISI Sump Outlet B K309B Iopen on RAS 3.3 Component Cooling Water / Auxiliary Component Cooling Water The component cooling water system (CCWS) and its corresponding auxiliary component cooling water system (ACCWS) ensure that sufficient cooling capacity is available for continued operation of safety-related equipment during normal and accident conditions. The CCWS is a closed loop cooling water system. The CCWS includes two CCW heat exchangers (tube side), three 100 percent capacity pumps, two dry cooling towers, one surge tank (baffled) and one chemical addition tank. The demineralized cooling water is pumped by the CCW pumps through the dry cooling towers and the tube side of the CCW heat exchangers, through the components being cooled and back to the pumps. The CCWS supplies cooling water to four paths: a nonessential seismically qualified loop, a nonessential non-seismic loop, and two redundant safety-related essential loops. The ACCWS is a separate system that provides cooling water to the CCW heat exchangers, and pumps it to the wet cooling towers for heat dissipation to the atmosphere. Additional information on the CCWS and ACCWS can be found in FSAR Section 9.2.

Upon receipt of an SIAS, the two redundant safety loops will be automatically isolated from each other and the nonessential, nonseismically qualified loop will be automatically isolated from both. The CCW pump suction and discharge header cross connect isolation valves will also close on SIAS. On an SIAS, the outlet valve on the "A" shutdown heat exchanger remains closed but may be opened manually from the control room, the outlet valve on the "B" shutdown heat exchanger goes fully open to W3F1 -2005-0075 Page 6 of 18 automatically. The A loop also continues to provide cooling, upon SIAS, to the reactor coolant pumps via the nonessential seismically qualified loop.

Following isolation, on SIAS, separate CCWS trains are formed, and each supplies cooling water in sufficient quantity and at the required temperature to remove 100 percent of the heat necessary to shutdown the reactor.

Upon CSAS, the containment isolation valves on the supply and return lines of CCW to the reactor coolant pumps and control element drive mechanism coolers are automatically isolated, and the outlet valve on the A shutdown heat exchanger goes fully open automatically.

A simplified flow diagram of the CCWS is provided below.

TS SR 4.7.3b verifies that each automatic valve in the CCWS/ACCWS servicing safety-related equipment actuates to its correct position on an SIAS and CSAS test signal. This surveillance provides a level of assurance that the CCWS/ACCWS will align to provide cooling to the safety-related reactor auxiliaries assumed to operate post accident. The following components are tested in accordance with TS SR 4.7.3b:

Component Description K-Relay Safety Function ID _ _ _ _ _

ACCW Header A CCW Heat Temperature ACC-126A Exchanger Outlet Temperature Control K41 OA irsetpoint Valves ValvesSIAS increases on ACCW Header B CCW Heat Temperature ACC-126B Exchanger Outlet Temperature Control K41 OB irsetpoint Valves -increases on Vanecs lSIAS CC- 14A CCW Pump A to AB Suction Cross K41 OA close on SIAS*

Connect Isolation _____loen___

CC-I 14B CCW Pump B to AB Suction Cross K41 OA close on SIAS*

Connect Isolation ____coen___

CC-1l 5A CCW Pump A to AB Suction Cross K41OB close on SIAS*

Connect Isolation CC-I 15B CCW Pump B to AB Suction Cross K41 OB close on SIAS*

Connect Isolation CC-I 26A CCW Pump A to AB Discharge Cross K41OA close on SIAS*

Connect Isolation ______

CC-I 26B CCW Pump B to AB Discharge Cross K41 OA close on SIAS*

Connect Isolation Spyee___len_

CC-127A CCW Pump A to AB Discharge Cross K41 OB close on SIAS*

Connect Isolation__ _ _ _ _ _ _ _ _ _ _ _ _

CC-I 27B CCW Pump B to AB Discharge Cross K41 OB close on SIAS*

Connect Isolation _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

CC-200A CCW Header A to AB Supply Isolation K304A close on OSAS CC-200B CCW Header B to AB Supply Isolation K41 OB close on SIA CC-501 CCW Non-Safety Supply Header K41 OA close on SIAS

_____ _____ Isolation _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

to W3Fl-2005-0075 Page 7 of 18 ID Description K-Relay Safety Function CC-562 CCW Non-Safety Return Header Isolation _ _

K41 OB close on SIAS CC-563 CCW Header AB to B Return Isolation K41 OB close on SIAS CC-620 Fuel Pool Heat Exchanger K41 OA close on SIAS Temperature Control CC-641 CCW to Containment Outside K1 14B close on CSAS Containment Isolation CC-710 Containment CCW Return Header K 14A close on CSAS Inside Containment Isolation CC-713 CCW Return Header Outside K1 14B close on CSAS Containment Isolation__ _ _ _ __ _ _ _ _ _ _ _

CC-727 CCW Header AB to A Return Isolation K304A close on CSAS CC-807A CFC CCW Containment Isolation K101A open on SIAS Valves _ _ _ __oamnIlin__pnn _

CC-807B CFC CCW Containment Isolation K101B open on SIAS Valves _ __ __oamtsao__onn _

CC-808A CFC CCW Containment Isolation K101A open on SIAS Valves _ __ __oamtsao__onn _

CC-808B CFC CCW Containment Isolation K101B open on SIAS Valves _ _ _ _ _ _ _ _ _ _ _ _ _

CC-822A CFC CCW Containment Isolation K101A open on SIAS Valves _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

CC-822B CFC CCW Containment Isolation K101B open on SIAS Valves _ _ _ _ _ _ _ _ _ _ _ _ _

CC-823A CFC CCW Containment Isolation K101A open on SIAS Valves _ _ _ _ _ _ _ _ _ _ _ _ _

CC-823B CFC CCW Containment Isolation K1O1B open on SIAS

_______ ___ V alves _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

CC-963A Shutdown Heat Exchanger A CCW K304A full open on

_ __ _ _ Flow Control __ _ _ _ _CSAS CC-963B Shutdown Heat Exchanger B CCW K41 08 full open on

_ _ _ _ _ _ Flow Control __ _ _ _ _ _SIAS

• Dependent on AB pump alignment. (e.g., If the AB pump is aligned to replace the A pump then the A to AB isolation valves will remain open.)

3.4 Essential Services Chilled Water System The purpose of the Essential Services Chilled Water System (CHWS) is to provide chilled water for those air handling systems which cool spaces containing equipment required for safety- related operations. The CHWS is a closed loop system consisting of three 100 percent capacity subsystems, each consisting of one chiller; one chilled water pump; one chilled water expansion tank; instrumentation and controls; and piping and valves. These subsystems are piped such that the AB subsystem can be manually aligned to circulate chilled water through either of the two loops (A or B) which serve safety-related equipment in various parts of the Reactor Auxiliary Building.

to W3F1 -2005-0075 Page 8 of 18 Original plant design also included a third loop which supplied non-safety related equipment. This third loop was isolated on an SIAS by automatic isolation valves. In an effort to improve chilled water chemistry, a modification was implemented that permanently removed the non-safety related loop from the CHWS and negated the need for the automatic isolation valves. The non-safety related loop is now supplied chilled water from a physically separate non-safety supplemental chilled water system and the automatic isolation valves which closed on SIAS have been deleted.

TS SR 4.7.12.1c was originally placed in the TS to verify that each essential services chilled water automatic valve actuates to its proper position on an SIAS. With the elimination of the automatic isolation valves originally used to isolate the non-safety related portions of the CHWS, there are no automatic valves remaining in the CHWS that receive an SIAS.

3.5 Technical Specification Surveillance Requirement Testing Surveillance testing at Waterford 3 is performed in accordance with written procedures. These procedures address the prerequisites, precaution and limitations, and initial conditions for performing the test. Testing required by the TS SRs discussed above are primarily performed in accordance with operating procedures OP-903-029, "Safety Injection Actuation Signal Test," OP-903-036, "Containment Spray Actuation Signal Test," and OP-903-091, "Recirculation Actuation Signal Test."

Currently, these procedures require the plant to be shutdown in accordance with TS.

Individual sections of these procedures contain "notes" and "cautions" that stand out and provide important information or cautions regarding the next few steps in the procedure.

On an SIAS, CSAS, and RAS, the engineered safety features actuation system de-energizes a series of sub-group relays (K-relays) which actuate plant equipment as required by plant design. K-relays actuate one or more components when de-energized. Actuation logic is described in FSAR Section 7.3.1.1.1 (SIAS), 7.3.1.1.2 (RAS), and 7.3.1.1.3 (CSAS).

The actuation system is designed to allow the K-relays to be de-energized one at a time on a test signal to verify proper actuation of the associated equipment. Additional information regarding individual sub-group relay testing is discussed in FSAR Section 7.3.1.1.1.9 (SIAS), 7.3.1.1.2.9 (RAS), and 7.3.1.1.3.9 (CSAS). The K-relays are tested online at least every 62 days in accordance with TS SR 4.3.2.1 with exceptions as noted in the TS (reference Note 3 on TS Table 4.3-2). The exceptions are for those K-relays that actuate equipment that should not be actuated while online.

3.6 Need for Technical Specification Change By deleting the "during shutdown" limitation, testing of many of these components can be performed online and combined with testing currently required by TS SR 4.3.2.1.

This will result in the work (i.e., testing) scope during a refueling or other plant outage being reduced, potentially reducing outage duration, and reducing the number of actuations on actuated components.

to W3F1-2005-0075 Page 9 of 18 3.7 Simplified System Diagrams The simplified flow diagrams below are provided for information only to facilitate a general understanding of the relationship of the various components within their associated systems, as discussed above. Not all valves discussed above are shown on the simplified flow diagrams.

A, a:Io I... J UA co I z --

C11 X~~~~~

-2

(

~~

14 ettlNttN r

CD -n 0 i-LPSI SYSTEM 0CD 01 120A INSIDE ° OUTSIDE CONTAINMENT 40 CONTAINMENT ,

IT lSDHX CvCS 120B 4128 1218 1161A 1161B 16A 139B i TO FCS LOOP IA 1258 1068 12B TO RCS 1298 l28B I-~ LF- LOOP Is B , 3358 412A F LOOP 2A 1425A 13 , A TO RCS 129A 336A LL i~o 28 129A ROSLOOP i

3368

CONTAINMENT SPRAY SYSTEM XM 3 An Si 121A SI t204 CS St 1s8' 1078 Si 6028 Si 6048 El TO SOC TR A FCVS to W3F1-2005-0075 Page 12 of 18 CCW PUMPS SUCTION HEADERS N

SA SB SB SA oFO IFO IFO 1M4A I 1B l 14B 114A M1A 116B 114B f5 A AB B

-w 4e L-N4 SA SB \ SB SA I FO I FO FO I FO

- x- --n-x IM,/z/=

126A 127A 127B 126B p9 N DISCHARGE HEADERS

(D co onV CCW SUPPLY AND RETURN TO AB & NNS HEADERS 00 CD cn CC-200A CC-2008 LfflseB T F.C.

SAFETY HEADER B LOADS

_F.C.

7 -

to W3F11-2005-0075 Page 14 of 18

4.0 TECHNICAL ANALYSIS

4.1 Removal of "During Shutdown" Limitation Technical Specification (TS) Surveillance Requirements (SR) 4.5.2e (Safety Injection),

4.6.2.Id (Containment Spray), and 4.7.3b (Component Cooling Water/Auxiliary Component Cooling Water) currently require that these specific SRs be performed once per 18 months during shutdown. The sub-group relays (K-relays) actuated to perform these SRs are also tested (Channel Functional Check) in accordance with TS SR 4.3.2.1 (Engineered Safety Features Actuation System Instrumentation) at least once per 62 days with an exception for specific K-relays that actuate components that cannot be actuated while the unit is online (e.g., K1 14 which would isolate component cooling water flow to the reactor coolant pumps). Note that the exception in TS SR 4.3.2.1 includes K301. With respect to the exception in TS SR 4.3.2.1 for K301, only K301 B cannot be tested online, K301A is currently tested online at least once per 62 days.

Based on the exception contained in TS SR 4.3.2.1, of all the components that are required to be tested by TS SRs 4.5.2e, 4.6.2.1d, and 4.7.3b; only the following components cannot be tested online:

Component Description K-Relay Safety Function ID Decpto CC641 CCW to Containment Outside K11 4B close on CSAS Containment Isolation CC-71 0 Containment CCW Return Header K1 14A close on CSAS Inside Containment Isolation _____loen___

CC-713 CCW Return Header Outside K11 4B close on CSAS Containment Isolation Therefore, the majority of the components required to be tested by these SRs can be safely tested online with no adverse impact on plant operations negating the need to routinely perform a specific test during shutdown. Only the components that cannot be tested online need be tested during a shutdown.

Currently, Sl-106A and B and Sl-602A and B are not actuated during the online SIAS test of the K110 subgroup relays. The Ki10 sub-group relays are tested online, in accordance with TS SR 4.3.2.1, by verifying that the HPSI and LPSI pumps start on an SIAS test signal. During the online test, the KilO subgroup relays send an open signal to already open Sl-106A and B (RWSP outlet valves) and a closed signal to already closed Sl-602A and B (SIS Sump outlet valves); therefore, these valves do not actuate during the online test. These valves are currently actuated on an SIAS test signal during shutdown. These valves are stroked online in accordance with the Inservice Testing Program indicating that they can be safely stroked online. To actuate these valves online via an SIAS test signal, it would be prudent to prevent the automatic start of the HPSI, LPSI, and CS pumps, as is done during the shutdown test, with the system initially aligned to the dry SIS sump and RWSP isolated. This would require entry into a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> shutdown allowed outage time (AOT) per TS 3.5.2, to W3F1 -2005-0075 Page 15 of 18 Action b, a 7 day shutdown AOT per TS 3.6.2.1, Action a, and a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> action to isolate the normally water filled containment spray penetration per TS 3.6.3.

With the approval of this amendment request, online component actuations currently performed per TS SR 4.3.2.1 can be used to satisfy testing requirements for the majority of the components required to be tested by TS SRs 4.5.2e, 4.6.2.1d, and 4.7.3b. Thus, no additional online component actuations would be performed except for SI-106A(B) and Sl-602A(B) on an SIAS test signal. Valves CC-641, CC-710, and CC-713 would continue to be tested during shutdowns.

Surveillance testing is implemented via written procedures which specify the plant condition in which the test can be performed. Procedural controls can be effectively utilized to ensure that testing of specific components is performed only during shutdown without the need for a "during shutdown" limitation specified in the TS SR.

The test frequency is not changed by this amendment request and remains on an 18 month frequency.

Maintenance activities, at Waterford 3, are conducted in accordance with 10 CFR 50.65(a)(4) which requires that before performing maintenance activities (e.g.,

surveillance testing) the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Thus, online testing of the components would be assessed and managed to avoid undue risk.

4.2 Deletion of Surveillance Requirement 4.7.12.1 c TS SR 4.7.12.1c verifies that all essential services chilled water automatic valves servicing safety-related equipment actuate to their proper position on an SIAS test signal. TS SR 4.7.12.1d, which is not being deleted, verifies that the essential services chilled water pumps and compressors start automatically on an SIAS test signal.

The original design of the essential services chilled water system at Waterford 3 included eight isolation valves that automatically closed on an SIAS to isolate the non-safety related chilled water loop from the safety-related portions of the system. The non-safety related chilled water loop was modified to physically separate it from the essential services chilled water system and it is now connected to a non-safety related supplemental chilled water system. The eight automatic isolation valves were removed from the system when the non-safety related loop was disconnected.

Therefore, the deletion of TS SR 4.7.12.1c is an administrative change and acceptable because the essential services chilled water system no longer contains any automatic valves servicing safety-related equipment that reposition on an SIAS. TS SR 4.7.12.1d will continue to require testing of the essential services chilled water system pumps and compressors which do start on an SIAS. Also, TS SR 4.7.12.1a will continue to verify that each valve (manual, power-operated, or automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position, is in its correct position.

to W3Fl-2005-0075 Page 16 of 18

5.0 REGULATORY ANALYSIS

5.1 ADplicable Regulatory Requirements/Criteria The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met.

10 CFR 50.36(cX3), Surveillance Requirements states:

Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

10 CFR 50.36 does not require that the initial conditions (in this case 'during shutdown") for performing surveillance requirements (SRs) be specified in the SR. For Technical Specification (TS) SRs 4.5.2e (Safety Injection), 4.6.2.1d (Containment Spray), and 4.7.3b (Component Cooling Water/Auxiliary Component Cooling Water) the actual surveillance requirements, to verify proper actuation on the specified actuation test signal, remain unchanged and, therefore, continue to comply with 10 CFR 50.36. In the case of TS SR 4.7.12.1c (Essential Services Chilled Water), since an SIAS signal is no longer required to reposition any automatic valves in the essential services chilled water system, the SR no longer serves to 'assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." Therefore, it is acceptable to delete the SR.

Entergy has determined that the proposed changes do not require any exemptions or relief from regulatory requirements, other than the TS, and do not affect conformance with any General Design Criterion (GDC) differently than described in the Final Safety Analysis Report (FSAR).

5.2 No Significant Hazards Consideration Technical Specification (TS) Surveillance Requirement (SR) 4.7.12.1 c (Essential Services Chilled Water), to verify that automatic valves in the system actuate on a Safety Injection Actuation Signal (SIAS), is being deleted since there are no valves in the system that actuate on an SIAS. The "during shutdown" limitation is being removed from TS SRs 4.5.2e (Safety Injection), 4.6.2.1d (Containment Spray), and 4.7.3b (Component Cooling Water/Auxiliary Component Cooling Water) to provide the flexibility to perform testing online without reducing the testing requirements or test frequency. Components required to be tested by these TS SRs, except for three component cooling water valves (CC-641, CC-71 0, and CC-713), are currently manipulated online per other TS SRs without adverse consequences.

to W3F1 -2005-0075 Page 17 of 18 Entergy Operations, Inc. has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, 'Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

Deletion of TS SR 4.7.12.1c is an administrative change since there are no valves in the essential services chilled water system for which the TS SR 4.7.12.1c is applicable. The deletion of the "during shutdown" restriction from TS SRs 4.5.2e (Safety Injection), 4.6.2.1d (Containment Spray), and 4.7.3b (Component Cooling Water/Auxiliary Component Cooling Water) does not impact system operation nor does it reduce TS SRs. Component actuations that will be allowed to be performed online for these TS SRs are either already actuated online for other TS SRs or the components to be actuated online are currently stroked online in accordance with the Inservice Testing Program. Therefore, the accident mitigation features of the plant for previously evaluated accidents are not affected by the proposed amendment.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

Deletion of TS SR 4.7.12.1c is an administrative change since there are no valves in the essential services chilled water system for which the TS SR 4.7.12.1 c is applicable. The deletion of the 'during shutdown" restriction from TS SRs 4.5.2e (Safety Injection), 4.6.2.1d (Containment Spray), and 4.7.3b (Component Cooling Water/Auxiliary Component Cooling Water) does not impact system operation nor does it reduce TS SR. Component actuations that will be allowed to be performed online for these TS SRs are either already actuated online for other TS SRs or the components to be actuated online are currently stroked online in accordance with the Inservice Testing Program. Therefore, the proposed change introduces no new mode of plant operation and no new possibility for an accident is introduced.

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

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

There are no automatic valves in the essential services chilled water system that actuate on an SIAS. Deletion of the "during shutdown" limitation does not change the TS test requirements or surveillance frequency. Therefore, existing TS surveillance to W3F1 -2005-0075 Page 18 of 18 requirements are not reduced by the proposed change, thus no margins of safety are reduced.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Entergy concludes that the proposed amendment present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of 'no significant hazards consideration" is justified.

5.3 Environmental Considerations The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22(cX9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Attachment 2 W3FI-2005-0075 Proposed Technical Specification Changes (mark-up) to W3F1 -2005-0075 Page 1 of 4 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

2. A visual inspection of the safety injection system sump and verifying that the subsystem suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion.

3. Verifying that a minimum total of 380 cubic feet of granular trisodium phosphate dodecahydrate (TSP) is contained within the TSP storage baskets.

4. Verifying that when a representative sample of 13.07 +/- 0.03 grams of TSP from a TSP storage basket is submerged, without agitation, in 4+/- 0.1 liters of 120 i I0"F water borated to 3011 i 30 ppm, the pH of the mixed solution Is raised to greater than or equal to 7 within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

e. At least once per 18 m on thtby:

1. Verifying that each automatic valve in the flow path actuates to its correct position on SIAS and RAS test signals.

2. Verifying that each of the following pumps start automatically upon receipt of a safety injection actuation test signal:

a. High pressure safety injection pump.

b. Low pressure safety injection pump.

3. Verifying that on a recirculation actuation test signal, the low pressure safety injection pumps stop, the safety injection system sump Isolation valves open.

f. By verifying that each of the following pumps required to be OPERABLE performs anindicated on recirculation flow when tested pursuant to the Inservice Testing Program:

1. High pressure safety injection pump differential pressure greater than or equal to 1429 psid.

2. Low pressure safety Injection pump differential pressure greater than or equal to 168 psid.

WATERFORD - UNIT 3 314 5-5 AMENDMENT NO. 6X,-62,,

to W3F1-2005-0075 Page 2 of 4 CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS (Continued)

SURVEILLANCE REQUIREMENTS (Continued)

d. At least once per 18 monthtby:

1. Verifying that each automatic valve in the flow path actuates to its correct position on a CSAS test signal.

2. Verifying that upon a recirculation actuation test signal, the safety injection system sump isolation valves open and that a recirculation mode flow path via an OPERABLE shutdown cooling heat exchanger isestablished.

3. Verifying that each spray pump starts automatically on a CSAS test signal.

e. At least once per 10 years by performing an air or smoke flow test through each spray header and verifying each spray nozzle is unobstructed.

WATERFORD - UNIT 3 3/4 6-17 AMENDMENT NO. 69, -169 to W3F1-2005-0075 Page 3 of 4 PLANT SYSTEMS 3/4.7.3 COMPONENT COOLING WATER AND AUXILIARY COMPONENT COOLING WATER SYSTEMS LIMITING CONDITION FOR OPERATION 3.7.3 At least two independent component cooling water and associated auxiliary component cooling water trains shall be OPERABLE.

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

ACTION:

With only one component cooling water and associated auxiliary component cooling water train OPERABLE, restore at least two trains to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours.

SURVEILLANCE REQUIREMENTS 4.7.3 Each component cooling water and associated auxiliary component cooling water train shall be demonstrated OPERABLE:

a. At least once per 31 days.by verifying that each valve (manual, power-operated, or automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position, is in its correct position.

b. At least once per 18 month by verifying that each automatic valve servicing safety-related equipment actuates to its correct position on SIAS and CSAS test signals.

c. At least once per 18 months by verifying that each component cooling water and associated auxiliary component cooling water pump starts automatically on an SIAS test signal.

WATERFORD - UNIT 3 3/4 7-11 to W3F1 -2005-0075 Page 4 of 4 PLANT SYSTEMS 314.7.12 ESSENTIAL SERVICES CHILLED WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.12 Two independent essential services chilled water loops shall be OPERABLE.

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

With only one essential services chilled water loop OPERABLE, restore two loops to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 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 4.7.12.1 Each of the above required essential services chilled water loop shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position, is in its correct position.

b. At least once per 31 days by verifying that the water outlet temperature is c 42!F at a flow rate of > 500 gpm.

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d. At least once per 18 months, by verifying that each essential services chilled water pump and compressor starts automatically on a safety injection actuation test signal.

4.7.12.2 The backup essential services chilled water pump and chiller shall be demonstrated OPERABLE in accordance with Specification 4.7.12.1 whenever it is functioning as part of one of the required essential services chilled water loops.

WATERFORD - UNIT 3 3/4 7-43