ML20046C574

TS Change Request NPF-38-137 to License NPF-38,modifying TS 3/4.6.2, Depressurization & Cooling Sys - Containment Spray Sys, to Clarify Requirements for Applicability in Mode 4

ML20046C574
Person / Time
Site:	Waterford
Issue date:	08/05/1993
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20046C575	List: ML20046C574 ML20046C577
References
W3F1-93-0069, W3F1-93-69, NUDOCS 9308110170
Download: ML20046C574 (8)

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Tei 5G4-73%6M I R. P. Barkhurst

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e u lj .1 W3F1-93-0069 t A4.05 PR August 5, 1993 '

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

Subject:

Waterford 3 SES Docket No. 50-382 i License No. NPF-38 Technical Specification Change Request NPF-38-137 Gentlemen:

The attached description and safety analysis support a change to the Waterford 3 Technical Specifications. This amendment request modifies  ;

specification 3/4.6.2, "Depressurization and Cooling Systems - Containment -

Spray System," to clarify the requirements for Applicability in Mode 4 and to increase the testing interval associated with the surveillance '

requirement for verifying that each containment spray nozzle is unobstructed.

This proposed change is consistent with the Technical Specification Improvement Program and supported in part by NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants."

The proposed change has been evaluated in accordance with 10CFR50.91(a)(1) ,

using criteria in 10CFR50.92(c) and it has been determined that the proposed change involves no significant hazards considerations.

We respectfully request a timely review due to the impact on our refueling outage schedule. This proposed change includes increasing the testing interval of Surveillance Requirement 4.6.2.1. e from "once per 5 years" to "once per 20 years."

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Technical Specification Change Request NPF-38-137 -

W3F1-93-0069 Page 2 August 5, 1993 f

In accordance with the current surveillance requirement, this test must be performed during Refuel 6 that is scheduled to begin in March 1994. Thus, in order to avoid this unnecessary task and adverse outage scheduling impacts, we '

request the staff conduct an expeditious review of this proposed change with respect to the above listed outage date.

Should you have any questions or ccmments, please contact Paul Caropino at (504) 739-6692.

Very truly yours,

)U k \

R.P. Barkhurst Vice President, Operations Waterford 3 RPB/PLC/dc

Attachment:

Affidavit l NPF-38-137 cc: J.L. Milhoan, NRC Region IV D.L. Wigginton, NRC-NRR ,

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

American Nuclear Insurers

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )

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Entergy Operations, Incorporated ) Docket No. 50-382 ,

Waterford 3 Steam Electric Station )

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AFFIDAVIT R.P. Barkhurst, being duly sworn, hereby deposes and says that he is Vice President Oprations - Waterford 3 of Entergy Operations, Incorporated; that  ;

he is duly authorized to sign and file with the Nuclear Regulatory Commission -

the attached Technical Specification Change Request NPF-38-137; that he is i familiar with the content thereof; and that the matters set forth therein are -

true and correct to the best of his knowledge, information and belief. -

V uf N R.P. Barkhurst Vice President Operations - Waterford 3 STATE OF LOUISIANA )

) ss PARISH OF ST. CHARLES ) <

Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this S Th day of [)v Gus r , 1993.

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Notary Public My Commission expires N'"F'~ .

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DESCRIPTION AND SAFETY ANALYSIS  ;

0F PROPOSED CHANGE NPF-38-137 l This proposed Technical Specification (TS) change modifies TS 3/4.6.2, "Depressurization and Cooling Systems Containment Spray System," as follows:

a) The footnote per LC0 3.6.2.1 which clarifies Applicability for the Containment Spray System (CSS) in Mode 4 has been revised to link this provision to Reactor Coolant System (RCS) pressure vs.

placing shutdown cooling in operation.

b) Surveillance Requirement 4.6.2.1.e, which requires verifying each spray nozzle to be unobstructed via an air / smoke flow test "at least once per 5 years..." is revised to "at least once per 10 years...".  :

In addition the associated Bases information impacted by the subject change has been updated as appropriate.

Existino Specification See Attachment A  ;

Proposed Specification i

See Attachment B i

Description During normal operation, the containment spray pumps are aligned to discharge I through the shutdown cooling heat exchangers. This is the required alignment  !

for emergency operation (i.e., operation following a LOCA). During the recirculation mode, the shutdown cooling heat exchangers function to cool the containment spray. Throughout shutdown cooling (which is initiated during the latter portion of Mode 4), the Low Pressure Safety Injection pumps are aligned ,

to discharge through the shutdown cooling heat exchangers and the CSS is taken out-of-service. Taking CSS out-of-service is necessary to avoid RCS ,

depressurization and inadvertent spraying of containment due to a single  :

failure of the isolation valve (CS-125 A or B) located between the CSS pump j and the containment spray headers. LCO TS 3.6.2.1 recognizes this situation j by defining Mode 4 Applicability for the CSS with a footnote that states "When shutdown cooling is in operation, no independent containment spray systems are ]

i required to be Operable" However, the time between removing the CSS and placing the Shutdown Cooling System (SDCS) in service is usually 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

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Thu:, TS 3.6.2.1 requires briefly entering the associated ACTION during each [

shutdown.

To resolve this concern, the proposed change appropriately defines CSS  ;

Mode 4 Applicability by revising the preceding footnote to read "With Reactor  !

Coolant System pressure > 400 psia." This change is consistent with the current TS Bases that allows this configuration based on the reduced RCS ,

pressure and temperature associated with entry into shutdown cooling.

Normally, shutdown cooling is entered when RCS temperature is approximatEly 350 F and RCS pressure is less than 392 psia. In order to enter Mode 4 the TS requires RCS temperature to be less than 350 F. This restriction is retained t under the proposed change. Allowing for the removal of containment spray at 400 psia in lieu actual shutdown cooling entry pressure provides for some operational flexibility and the slight pressure increase is conCdered ,

insignificant. Actually, the Waterford 3 long-term cooling analysis (FSAR ,

6.3.3.4.3) assumes the maximum RCS shutdown cooling entry pressure is 400 psig. Therefore, the proposed change is ansistent with FSAR analysis and previous licensing bases. The associattd TS Bases has been updated to reflect the proposed change described above.

TS Surveillance Requirement 4.6.2.1.e requires testing each CSS header and

,erifying that each spray nozzle is unobstructed by performing an air or smoke '

flow test at least once per 5 years. In NUREG-1366, " Improvements to f Technical Specifications Surveillance Requirements", the NRC staff searched t for problems involving the CSS that had been uncovered by means of this testing. Only three cases were found and in all three cases the problem involved a construction error. Therefore, the staff concluded that this test interval should be extended to 10 years.

Nozzle clogging associated with coating materials applied to carbon steel CSS piping, that has caused problems at other nuclear facilities, is not a concern at Waterford 3; the containment spray piping and header assemblies are constructed of stainless steel. The last unobstructed spray nozzle test at Waterford 3 was performed in April 1988. The test results verified the i nozzles to be clear and capable of performing their safety related function. l Restructured Standard Technical Specifications (RSTS) for Combustion  !

Engineering Plants NUREG-1432, supports the 10 year CSS nozzle test interval. ,

The RSTS unlike the Waterford 3 TS, combine C(;ntainment Spray and Cor.tainment Cooling Systems into a single LCO. However, the RSTS do not provide operational constraints more restrictive than the Waterford 3 TS for containment spray excluding the Mode 4 Applicability previously discussed.

One difference in NUREG-1432, which is less restrictive, involves the surveillance requirement (SR 3.6.6.A.4) that verifies the containment spray

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header (riser) piping is full of water every 31 days. The Waterford 3 TS (4.6.2.1.a) require this surveillance to be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. At the present time we are evaluating performance data for the containment spray i riser level indicator instrument. Once this evaluation is complete, we may submit an amendment request to increase this surveillance interval.

Safety Analysis The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following .

areas:

1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability cr consequences of any accident previously evaluated?

Response: No The proposed change that modifies the footnote defining the CSS Applicability during Mode 4 does not affect any design basis accidents.

The CSS is maintained available to mitigate the effects of a LOCA or .

MSLB and also to provide a mechanism for removing iodine from the containment atmosphere under post-LOCA conditions. However, at the  :

reduced temperatures and pressures associated with the latter portion of :

Mode 4, the probability and consequences of the events identified above are greatly reduced. In addition the Containment Cooling Systems is required to be operable in Mode 4 per LC0 3.6.2.2 and is available to i provide oepressurization and cooling of containment.  !

Increasing the CSS spray unobstructed nozzle test interval from 5 years ,

to 10 years does not affect any design basis accident. Performing this .

surveillance provides assurance that spray coverage of the containment  ;

during an accident has not degraded and based on the passive design of )

the nozzles, testing at 10 year intervals is considered adequate. l Therefore, based on the above the proposed change will not involve a  !

significant increase in the probability or consequences of any accident i previously evaluated.

2. Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No i

l No new accident initiators or failure modes are created by modification to the footnote associated with CSS Mode 4 Applicability or by extending the CSS nozzle test interval. In addition the proposed change will not i alter the operation of the plant or the manner in which it is operated.

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

3. Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety? ,

Response: No The proposed change will involve no adverse impacts on the protective boundaries, safety limits or margins to safety. The modification ,

concerning CSS Mode 4 Applicability is consistent with the current I licensing bases and extending the CSS nozzle surveillance test is in j agreement with NUREG-1432 " Standard Technical Specifications Combustion Engineering Plants" and NUREG-1366 " Improvements of Technical Specifications Surveillance Requirements". Therefore, the proposed change will not involve a significant reduction in a margin of safety.

Safety and Sionificant Hazards Determination Based on the above safety analysis, it is concluded that: (1) the proposed change does not constitute a significant hazards consideration as defined by 10 CFR 50.92; and (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed changes; and (3)_

this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC final environmental statement.

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