ML061280114

ER-W3-2005-0334-001, Temporary Alteration for Reactor Vessel Gasket Leak-off Pressure High Annunciator

ML061280114
Person / Time
Site:	Waterford
Issue date:	10/19/2005
From:	Day W Entergy Nuclear South
To:	Office of Nuclear Reactor Regulation
References
ER-W3-2005-0334-001
Download: ML061280114 (9)

Text

Page 1 of 9 Facility : WATERFORD 3 Document Reviewed: ER-W3-2905-033480'!, TA-05-005 ChangeiRev.: REV 0 System Designator(s)lDescription : RC I Reactor Coolant System Description of Proposed Activity:

There is currently an indication of high pressure between the reactor vessel head gasket crying seats which is an indication that the inner o-ring seal is leaking. A Temporary Alteration will be installed to clear the locker! in annunciator alarm N-10 (H1210), "RX VESSEL GASKET LEAKOFF PRESS Hl," on CP-2 in the Control Room. The Normally Open/Normally Closed (NOINC) selector switch on Annunciator Card H1210 will be swapped from the NC position to the NO position . This temporary alteration is a compensatory action for the degraded Reactor Vessel Head Inner O-ring gasket . This safety evaluation will only address the compensatory action, not the degraded condition .

Check the applicable review(s) . (Only the sections indicated must be included in the Review.)

EDITORIAL CHANCE of a Licensing Basis Document , section I SCREENING Sections l and 11 required _-

[] 58.59 EVALUATION EXEMPTION j Sections 1, I1, and III required

~J 50.59 EVALUATION E - = << )ections 1,11 and IV required t ~~

Preparen W.E. Ira /EOIISE-EFIN1 ; -- / : -- :

3 Name (print) I Signature ompany 1 Department I Date s 1 - y t om, s ~ ~ _

Reviewer: ti. Ax, Name (print) f Signature I Company I Depart i, e~(it f Date OSRC :

Chairman's Name (print) I Signature 7 Date (Required only for PrNrammatic Exclusion Screenings and 50 .59 Evaluations .)

LI-101-01, Rev. 8; Effective Bate: 6123105

It. SCREENINGS A. licensing Basis Qqcqeqt __m_ _ Review I . Does the proposed activity impact the facility or a procedure as described in any of the following Licensing Basis Documents?

YES NO CHANGE # and/or SECTIONS IMPACTED i NRC Orders

~ If "YES," obtain NRC approval prior to implementing the change by initiating an 1_1313 change in I accordance with NMM U-113. (See LI-101 for exceptions .)

LBDs controlled under 50.59 YES NO CHANGE # (if applicable) and/or SECTIONS IMPACTED FSAR FSAR IT&I .9 TS Bases Technical Requirements Manual Core Operating U nits Report _ Lj NRC Safety Evaluation Report and ED 23 supplements for the initial FSAR' NRC Safety Evaluations for amendments to the Operating License' If "YES." perform an Exemption Review per Section Ift PR per-form a 50.59 Evaluation per Section IV QR obtain NRC approval prior to implementing the change by initiating an LBO change in accordance with NMM U-113- if obtaining NRC approval, document the 1_1313 change in Section II.A .S. However, the change cannot be Implemented until approved by the NRC_ Complete Section 11.

LBDs controlled under other YES NO CHANGE # (if applicable) and/or I regulations SECTIONS IMPACTED

{duality QSV2noe Program Manual' Emergency Ran2, 3 El Z Rre Protection Program3,4 (includes the Fire Hazards AnajySiS)

Offsite Dose Ca!rulaflons Manual . 1 If "YES," evaluate any changes in accordance with the appropriate regulation Mkt? initiate an LBD change in accordance with NMM L1-113 .

if °YES,'see U-101 . No van &ange is reWirod .

If 'YES,'notfy the res,~sonsibte department and ensure a 60.54 evaluation a performed

. Aqaji the 50,54 evakiationL Changes ip me Erneigency Ran, sire Protection Program, ancl Oftte Dose Calculation Nlanua :i :;rust be approved dy trie CSRC ;p accordance Mh WAM OM-119,

° if -YES ." evaluate the cxange :n accordance with the requirements of the faciiJy's Operating License Condition or ordef 50 .59, as ayrowk;W U-101-01, Rev. 8 ; Effective Date : 6123/05

Page 3 of 9

2. Does the proposed activity involve a test or experiment not described in the FSAR? %1 Yes No If "YES," perform a 50 .59 Evaluation per Section IV OR obtain NRC approval prior to implementing the change AND initiate an L.BD change in accordance with NMM L.I-113, if applicable. If obtaining NRC approvaI, document the change in Section ILA.5 . However, the change cannot be implemented until approved by the NRC. Complete Section It .

3. s is Explain why the proposed activity does or does not impact the Operating Lfcense'Technical Specifications andior the FSAR . if the proposed activity involves a potential test or experiment not previously described in the FSAR also include an explanation . Discuss other Ms if impacted . Adequate basis must be provided within the Screening such that a third-party reviewer can reach the same conclusions . Simply stating that the change does not affect TS or the FSAR is not an acceptable basis.

There is currently indication of a leak past the inner O-ring as the main control room Rx VESSEL GASKET LEAKOFF PRESS HI annunciator is currently locked in alarm. A Temporary Aiteration will be installed to clear the locked in annunciator alarm N-10 (H1210), "RX VESSEL GASKET LEAKOFF PRESS Hl," on CP-2 in the Control Roam . The Normally Open/Normally Closed (NO/NC) selector switch on Annunciator Card i-11210 will be swapped from the NC position to the NO position_ This will clear annunciator alarm H1210 while the high pressure condition exists between the reactor vessel head gasket o-ring seals. Should the pressure drop between the a-ring seals, this would indicate that the outer o-ring seal is leaking at a higher rate than the inner o-ring seal . A low pressure condition (<1600 prig) will actuate annunciator alarm H1210 since the annunciator logic has been reversed .

With the Temporary Alteration installed, both pressure switches RC IPS1001 and RC IPS1002 contacts must close due to the low pressure condition in order to generate an alarm, which is 2 out of 2 logic . The normal configuration logic is I out of 2 for either pressure switch to sense high pressure and actuate annunciator H1210. The 2 out of 2 logic is acceptable to generate the alarm, because the same 2 out of 2 logic is required to clear the annunciator alarm in the current configuration which would indicate that the outer o-ring seal is leaking. Reversing the Annunciator Card H1210 logic actuates the annunciator alarm instead of clearing the annunciator alarm which in either case provides the same information to the Control Room Operators that a low pressure condition exists between the reactor vessel head o-ring seals which indicates that the outer o-ring seal is leaking.

It is important that Operators maintain awareness that the reactor vessel head gasket 0-ring gap is pressurized . To ensure this, Annunciator Response Procedure OP-500-008, will be changed to reflect the temporary configuration by revising the response required should annunciator H1210 alarm as it will now indicate a low pressure condition which is indicative of outer o-ring seal leakage.

FSAR 5.25.1,9 states 'The space between the double O-ring seal is monitored to detect an increase in pressure, which indicates a leak past the inner O-ring . Alarm of this condition is available in the main control room .'

This Temporary Alteration will result in a condition that is different from that described in the above statement in that the space between the double O-ring seal will now be monitored to detect a drop in pressure ; which will indicate leakage past the outer O-ring . The alarm of this condition will be available ir=

the main control room . Although the FSAR discusses leakage past the inner o-ring seal, this Temporary Alteration, while it focuses on detection of outer o-ring seal leakage, still maintains the ability to provide alarm indication for leakage through the Reactor Vesse! Head Flange seal .

This temporary alteration does not affect the Operating License or Technical Sped icatiorts and is not part of a test or experiment_

As the Reactor Vessel Head Closure Leakage system will deviate from the FSAR description by installing this temporary alteration and it may appear to be a change in a less conservative direction, a safety evaluation will be performed .

U-101-01, Rev. 8 ; Effective Date , 6123105

54 .59 REVIEW FORM Page 4 of 9

4. Refere nces Discuss the methodology for performing LBD searches. State the location of relevant licensing document inforrnation and explain the scope of the rev?ew such as electronic search criteria used {e.13 . . key ,.,4ords) or the general extent of manual searches . NOTE: Ensure that manual searches are performed using controlled copies of the documents . If you have any questions, contact your site Licensing department .

Electronic search method used : Keywords :

Autonomy, 50 .59 search Gasket NEARS leakoff 2 hits

`reactor vessel head" 47 hits "reactor coolant pump" NEAR10 ieakoff 7 hits LBC3s reviewed manually:

FSAR 5 .2 .5 .1 .9 FEAR 5 .2 .5 .1 .10 FSAR 3 .1 .10 FSAR 3 .1 .25 FSAR 15 .8 .3 .1

5. Is the validity of this Review dependent on any other change? Yes

}0 too If "YES," list the required changes/submittals

.The changes covered by this 51) .59 Review cannot be implemented without approval of the other identified changes (e.g_, license amendment request) . Establish an appropriate notification mechanism to ensure thus action is completed.

LI-141-Q1, Rev. 8; Effective Date : 6123145

B. ENVIRONMENTAL SCREENING If any of the following questions is answered "yes," an Environmental Review must be performed in accordance with NMM Procedure EV"115 and attached to this 50,59 Review . Consider both routine and non-routine (emergency) discharges when answering these questions.

Will the proposed activity being evaluated :

YES NO.

Involve a land disturbance equal to or in excess of one acre (i .e ., grading activities, construction of buildings. excavations, reforestation, creation or removal of ponds)?

2. [] Involve any land disturbance of undisturbed land areas (i .e ., grading activities, construction, excavations, reforestation, creating, or removing ponds)?

3. ED [0 Involve dredging activities in a lake, river, pond, ditch, or stream?

4, [1 Increase the amount of thermal heat being discharged to the river or lake?

5. 1E] increase the concentration or quantity of chemicals being discharged to the river, lake, or air?

B. E] E Discharge any new or different chemicals that are currently not authorized far use by the state regulatory agency?

7. 0 N, Change the design or operation of the intake or discharge structures?

Modil~r the design or operation of the cooling tower that will change water or air flow characteristics?

9. Q !N Modify the design or operation o¬ the plant that will change the path of an existing water discharge or that will result in a new water discharge?

10 . C] E Modify existing stationary fuel burning equipment (i .e ., diesel fuel oil, butane, gasoline, propane, and kerosene)?`

11 . (] Z, Involve the installation of stationary fuel burning equipment or use of portable fuel burning equipment (i .e., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

12. Ej M involve the installation or use of equipment that will result in a new or additional air emission discharge?

13 . C ~N Involve the installation or modification of a stationary or mobile tank?'

14 . 1E] IE Involve the use or storage of oils or chemicals that could be directly released into the environment?

involve burial or placement of any solid wastes in the site area that may affect runoff, surface water, or groundwater?

NNA1 Procedure EV-117 fOr guidance in answering this question .

Li-101-01, Rev. 8; Effective Rate : 6(23105

C. SECURITY PLAN SCREENING if any of the following questions is answered "yes, a Security Plan Review must be perforated by the Security Department to determine actual impact to the Plant and the need for a change to the Plan.

Could the proposed activity being evaluated:

YES NO

1. E] Add, delete, modify, or otherwise affect Security department responsibilities (e .g .,

including fire brigade, fire watch, and confined space rescue operations)?

2 u Result in a breach to any security barrier(s) (e .g ., HVAC ductwork, fences, doors, wails, ceilings, floors, penetrations, and ballistic barriers)?

3. [1 N Cause materials or equipment to be placed or installed within the Security Isolation Zone?

4. Affect (block, move, or alter) security fighting by adding or deleting lights, structures, buildings, or temporary facilities?

El 0 Modify or otherwise affect the intrusion detection systems (e .g ., E-fields, microwave, fiber optics)?

6. E] 0 Modify or otherwise affect the operation or field of view of the security cameras?

7. C Z Modify or otherwise affect (block, move, or alter) installed access control equipment, intrusion detection equipment, or other security equipment?

8. C Modify or otherwise affect primary or secondary power supplies to access control equipment, intrusion detection equipment, other security equipment, or to the Central Alarm 5tafion or the Secondary Alarm Station?

9. [~ Modify or otherwise affect the facility's security-related signage or land vehicle barriers, including access roadways?

10 . [] 0 Modify or otherwise affect the facility's telephone or security radio systems?

The Security Department answers the following question if one of questions C.1 through C.10 above was answered "yes ."

Is a change to the Security Plan required? [Q Yes

[] No Attach to this 50 .59 Review or reference below documentation for accepting a "yes" answer for any of Questions C.1 through C.10, above .

Name of Security Plan reviewer (print 1 Signature f Data LI-101-01, Rev . 8 ; Effective Date : 6123105

50.59 REVIEW FORM Page 7of9 IV. 50.59 EVALUATION endment Deter irjgtion Does the proposed Change being evaluated represent a change to a method of evaluation Yes ONLY? If "Yes,  Questions I - 7 are not applicable, answer only Question 8. If "No," answer No all questions below .

Does the proposed Change :

2

1. Result in more than a minimal increase in the frequency of occurrence of an accident 7 Yes previously evaluated in the FSAR? No BASIS:

THIS CHANGE DOES NOT AFFECT ANY PLANT EQUIPMENT OTHER THAN THE POSITION OF AN ANNUNCiATOR CARE}

SELECTOR SWITCH WHICH DETERMINES WHETHER AN ANNUCIATOR WILL ALARM DUE T'O AN OPEN OR CLOSED FIELD CONTACT. THE AFFECTED ANNUNCIATOR H1210 NORMALLY PROVIDES INFORMATION TO CONTROL ROOM OPERATORS AS TO THE POSSIBLE SOURCE OF RCS LEAKAGE IN CONTAINMENT BEING FROM THE REACTOR VESSEL HEAD INNER O-RING SEAL . THE REACTOR VESSEL HEAD INNER O-RING SEAL CURRENTLY HAS INDICATION OF LEAKAGE AS EVIDENCED BY THE LOCKED IN ANNUNCIATOR ALARM H1210 THAT INDICATES PRESSURE BETWEEN THE O-RING SEALS >1600 PSIG . I N THE TEMPORARY CONFIGURATION THIS ANNUNCIATOR ALARM WILL BE RESET AND IT WILL NOW ALARM IF THE OUTER O-RING SEAL IS LEAKING AT A HIGHER RATE THAN THE INNER O-RING SEAL .

THE ANNUNCIATOR RESPONSE PROCEDURE, OP-5OO-00$. WILL BE CHANGED TO REFLECT THE CHANGED RESPONSE REQUIRED NOW THAT THE ALARM INDICATES A LOW PRESSURE CONDITION INSTEAD OF A HIGH PRESSURE CONDITION BETWEEN THE INNER AND OUTER O-RING SEALS. THIS CANNOT AFFECT THE FREQUENCY OF OCCURRENCE OF AN ACCIDENT .

2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a Yes structure, system, or component important to safety previously evaluated in the FSAR? No BASIS=

THE POSITION OF ANNUNCIATOR CARD H1210 NORMALLY OPENINORMALLY CLOSED (NO/No) SELECTOR SWITCH WILL BE CHANGED FROM THE NC POSITION TO THE NO POSITION . THIS WILL ONLY AFFECT THE ALARM INDICATION CIRCUIT FOR THE REACTOR VESSEL HEAD LEAKOFF SYSTEM. NO OTHER PLANT STRUCTURES, SYSTEMS OR COMPONENTS WILL BE AFFECTED BY THIS CHANGE .

3. Result in more than a minimal increase in the consequences of an accident previously Yes evaluated in the FSAR? No BASIS:

THERE ARE NO ACCIDENTS THAT WILL BE AFFECTED BY THIS CHANGE . THIS CHANGE WILL PROVIDE OPERATORS INDICATION OF LEAKAGE PAST THF REACTOR VESSEL OUTER O-RfNG SEAL iF IT EXCEEDS THE INNER O-RING SEAL LE AKRATE . THE ALARM FUNCTION IS NOT REQUIRED FOR SAFE SHUTDOWN OF THE PLANT AND IS NOT A TECHNICAL SPECIFfCATiON REQUIRED LEAKAGE DETECTION SYSTEM . THIS ALARM IS NOT REQUfRED FOR REG . GuIDE 1,97 REQU'REMENTS . THIS ALARM IS ALSO NOT AN EOP iNSTRUNIENT AS DOCUmEtdTED IN ECS98-00 1 .

LI-101-©1, Rev . 8 ; Effective Date : 6123/05

0.59 REVIEW FORM

4. Result in more than a minimal increase in the consequences of a malfunction of a structure, Yes system, or component important to safety previously evaluated in the FSAR?

BASIS; THIS TEMPORARY ALTERATION ONLY AFFECTS INDICATION OF THE CONDITION OF THE SPACE BBET'VVEE .i THE REACTOR VESSEL HEAD O-RING SEALS . CURRENTLY, T HE SPACE BETWEEN THE O-RING SEALS }S ¬ N AN ABNORMAL HIGH PRESSURE CON'S#T?ON ;THIGH HAS RESULTED IN ANNUNCIATOR H1210 BEING LOCKED ;^d AN ALARM STATE.

THE ANNUNCIATOR LOGIC WILL BE REVERSED SO THAT THE ALARM WILL. BE CLEARED WHILE THERE 1S HIGH PRESSURE BETWEEN THE O-RING SEALS, SHOULD THE OJTEq O-RING SEAL BEGIN TO LEAK AT A HIGHER RATE THAN THE INNER O-RING SEAL, THE H1210 ALARM WILL ANNUNCIATE . THE ALARM FUNCTION ITSELF HAS NC) AFFECT ON THE CONDITION OF THE REACTOR VESSEL O-RING SEALS.

SHOULD ONE OR BO T H OF THE TWO PRESSURE SWITCHES, RC IPS1001 OR RC IPS1002, FAIL SUCH THAT THEIR SWITCH CONTACTS FAIL iN THE OPEN POSITION, ANNUNCIAT OR H1210 WILL NOT ACTUATE IF PRESSURE DROPS BELOW 16¬)0 PSIG . 'IN THIS CASE, INDICATION OF OUTER O-RING SEAL LEAKAGE WOULD NOT BE DIRECTLY INDICATED. IN UKE MANNER, IF THIS TEMPORARY ALTERATION IS NOT IMPLEMENTED, ANNUNCIATOR H1210 ALARM WOULD NOT CLEAR WHEN PRESSURE DROPS BELOW 1600 PSIG SHOULD ONE OR BOTH OF THE M'O PRESSURE SWITCH CONTACTS FAIL N THE OPEN POSITION, WHICH WOULD ALSO RESULT IN NO INDICATION OF OUTER O-RING SEAL LEAKAGE . ADDITIONALLY, THERE ARE OTHER TECHNICAL SPECIFICATION REQUIRED LEAKAGE DETECTION SYSTEMS THAT WILL PROVIDE INDICATION OF RCS LEAKAGE IN EITHER CASE DISCUSSED ABOVE. AS A RESULT, THERE IS NO INCREASE IN THE CONSEQUENCES OF A MALFUNCTION OF A STRUCTURE SYSTEM OR COMPONENT IMPORTANT TO SAFETY . NOTE THAT ANNUNCIATOR H1210, "RX VESSEL GASKET LEAKOFF PRESS Hl"Is NOT A TECHNICAL SPECIFICATION REQUIRED LEAKAGE DETECTION SYSTEM .

5. Create a possibility for an accident of a different type than any previously evaluated in the D Yes FSAR? No BASIS:

CHANGING THE POSITION OF THE NO/NC SELECTOR SNITCH ON ANNUNCIAT OR CARD H1210 HAS NO AFFECT ON ANY OTHER PLANT STRUCTURES, CONIPONENTS OR SYSTEMS. ONLY INDICATION OF THE CONDITION OF THE SPACE BETWEEN THE REACTOR VESSEL HEAD O-RING SEALS IS AFFECTED . THERE ARE NO ACCIDENTS THAT CAN BE CAUSED BY THIS ANNUNCIATOR INDICATION .

6. Create a possibility for a malfunction of a structure, system, or component important to safety Yes with a different result than any previously evaluated in the FSAR? . No Z

BASIS:

THE POSITION OF ANNUNCIATOR CARD H121.0 NORMALLY OPENINORMALLY CLOSED (NOINC) SELECTOR SWITCH WILL BE CHANGED FROM THE NC POSITION TO THE NO POSITION . THIS WILL ONLY AFFECT THE ALARM INDICATION CIRCUIT FOR THE REACTOR VESSEL HEAD LEAKOFF SYSTEM . NO OTHER PLANT STRUCTURES, SYSTEMS OR COMPONENTS WILL BE AFFECTED BY THIS CHANGE .

THE MALFUNCTION O- THE ANNUNCIATOR H1210 CIRCUIT IS NOT EVALUATED IN THE FSAR .

Li-1101-01, Rev. 8; Effective Date : 6123105

7. Result in a design bass Kq W a fission produM barrier as described A the FSAR bung A Yes exceeded or altered? E] No BASIS:

THIS TEMPORARY ALTERATION ONLY ArFECTS THE ALARM MONITORING CIRCUIT FOR THE PRESSURE BETWEEIN THE REACTOR VESSEL HEAD O-RING SEALS. THE REACTOR FUEL CLADDING IS NOT AFFECTED BY Ti-?1S CHANGE . THE RCS PRESSURE BOUNDARY IS NOT AFFECTED BY TH?S CHANGE AS THtS PRESSURE MONITORING CIRCUIT CANNOT RESULT iN A RISE iN RCS PRESSURE . THE CONTAINMENT BOUNDARY IS NOT AFFECTED BY THIS CHANGE .

8. Result in a departure from a fnethod of evaluation described in the FSAR used in establishing D Yes the design bases or in the safety analyses? El No BASIS:

THIS TEMPORARY ALTERATION DOES NOT AFFECT A METHOD OF EVALUATION, If any of the above questions is checked "YES," obtain NRC approval prior to implementing the change by initiating a change to the Operating Wense in accordance with NMM Procedure LI-113 .

1-1-101-01, Rev. 8, Effective Date : 6123/05