ML20046C584

TS Change Request NPF-38-138 to License NPF-38,removing Requirements Associated w/loose-part Detection Instrumentation from TS to Further Goal of TS Improvements as Delineated in NRC Policy Statements

ML20046C584
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
ML20046C585	List: ML20046C584 ML20046C588
References
W3F1-93-0074, W3F1-93-74, NUDOCS 9308110184
Download: ML20046C584 (9)

Text

-

&=E ntergy ra g y e a.iam

. Operations - me.

' ";m2 U361 .

R. P. Bar khurst

-: n sk- (

W3F1-93-0074 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 License No. NPF-38 Technical Specification Change Request NPF-38-138 Gentlemen:

The attached description and safety analysis support a change to the Waterford 3 Technical Specification (TS). This request constitutes a proposal to remove the requirements associated with Loose-Part Detection Instrumentation (i.PDI) i from the TS to further the goal of Technical Specification improvements Es  !

delineated in NRC policy statements. In addition, as part of the Burden )

Reduction Program for long-term economic savings, the proposed change is the -l initial step in support of a specific cost beneficial licensing action (CBLA). l On May 4 at the annual Regulatory Information Conference, Dr. Murley annount .d a pilot program established by NRR to give special consideration to licensee requests for changes requiring staff review that involves high cost and low safety benefit. In response to Dr. Murley's initiative, Entergy Operations i met with NRR staff on June 8,1993, to present an initial list of CBLAs.

As discussed on June 8,1993, upon approval of this request the LPDI controls :1 removed from the TS will be relocated in the Updated Final Safety Analysis Report (UFSAR). An engineering evaluation will then be performed in accordance with 10CFR50.59 to determine whether a more cost effective approach exists to comply with regulatory requirements.

100059 f3 s

l 9308110184-930805 PDR ADOCK 05000392 P PDR ))l A

Technical Specification Change Request NPF-38-138 W3F1-93-0074 Page 2 August 5, 1993 1.

This submittal includes an evaluation in accordance with 10CFR50.91(a)(1) using criteria in 10CFR50.92(c) that determined the proposed change involves no significant hazards consideration. The Plant Operating Review and Safety Review Committees have reviewed and accepted this proposed change based on the foregoing evaluation.

Should you have any questions or comments concerning this request, please contact Paul Caropino at (504) 739-6692.

Very truly yours, 1

, \. JM ,\O N R.P. Barkhurst Vice President, Operations Waterford 3 RPB/PLC/dc

Attachment:

Affidavit NPF-38-138 cc: J.L. Milhoan, NRC Region IV 0.L. Wigginton, NRC-NRR R.B. McGehee N.S. Reynolds NRC Resident Inspectors Office Administrator Radiation Protection Division (State of Louisiana)

American Nuclear Insurers

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

)

Entergy Operations, Incorporated ) Docket No. 50-382 Waterford 3 Steam Electric Station )

AFFIDAVIT R.P. Barkhurst, being duly sworn, hereby deposes and says that he is Vice President Operations - Waterford 3 of Entergy Operations, Incorporated; that j he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Technical Specification Change Request NPF-38-138; that he is 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, t

. M..\ . O 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 5'7" day of MvGus> , 1993.

$b. I f5 %

Notary Public My Commission expires M 7" 2 " T ,

___--_-___._________---_--_----_--------_-----_____---_------___J

y DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-138 -

The proposed change removes the Limiting Condition for Operation, Surveillance Requirements and Bases for Loose-Part Detection Instrumentation from the Technical Specifications (TS). .

Existina Specification See Attachment A Proposed Specification See Attachment B Backaround The loose-part detection instrumentation ensures that sufficient capability is available to detect loose metallic parts in the primary system and avoid or mitigate damage to primary system components.

The loose-part detection instrumentation is part of the " Valve and Loose-Parts Monitoring System" (V&LPMS) as described in UFSAR subsection 4.4.6.1. The V&LPMS equipment monitors the Reacter Coolant System for loose parts in the reactor internals. Loose parts are a concern because they may cause fuel damage by reducing coolant flow by blocking reactor coolant channels or jamming the reactor coolant pump impellers. In addition, the V&LPMS equipment is also used to detect primary safety valve position in accordance with NUREG 0737 Item II.D.3.

Loose parts become detectable when they are driven or waited against the inner walls of a pressure vessel or piping. A steady flow of coolant within the reactor vessel will wedge the loose part in a fixed position until flow is changed. When a loose part is driven from its position it hits the inner walls: the impact produces the sound waves radiating in the metal walls.

The V&LPMS consists of sixteen high-temperature sensor assemblies, eight in Train A and eight in Train B, and a signal processing and recording cabinet.

The sensors are accelerometers that detect noise of any loose parts colliding with the piping or vessels.

SENSOR LOCATIONS CHANNEL (S) LOCATION 1A(B) Bottom of Reactor Vessel 2A(B) Head of Reactor Vessel 3A(B) RCP 1A ,

4A(B) RCP IB 5A(B) RCP 2A 6A(B) RCP 2B 7A(B) Top of Steam Generator 1 8A(B)A Top of Steam Generator 2 The accelerometer consists of a mass mounted piezoelectric crystal. As the component vibrates, the crystal converts the vibration into an electrical charge signal. The signal is converted to a de voltage signal via the pre- -

ampl ifier. From the pre-amplifier the signal is processed by a computer. t The V&LPMS meets the requirements of Regulatory Guide 1.133 Rev.1, May 1991. 3 In accordance with RG 1.133 paragraph C.5 the V&LPMS is included in the Technical Specifications. The TS LCO requires that the system to be operable ,

in Modes 1 and 2. With one or more system channels inoperable for more than 30 days, a Special Report shall be submitted to the NRC outlining the cause of i the malfunction and plans for restoring the channel (s) to operable status.

The system surveillance requires that each channel of the loose part detection '

system be demonstrated operable by channel check performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, a channel functional test performed at least once per 31 days, and a calibration test performed at least once per 18 months. l The proposed change requests that the LPDI be removed from the TS and  ;

incorporated in the UFSAR. Subsequent evaluation under the 10CFR50.59 process ,

may be pursued to identify and pursue changes involving high cost and low safety benefit.

Pfscription The proposed change removes TS 3.3.3.9; 4.3.3.9 and B 3/4.3.3.9. TS Index page v has been revised to remove reference to loose-Part Detection  ;

Instrumentation; TS page 3/4 3-49 has been revised to state "Pages 3/4 3-49 i through 3-59 have been deleted"; and TS Bases page B 3/4 3-3a has been revised to remove 3/4.3.3.9.  ;

I I

l

. \

On February 6, 1987, the NRC published its Interim Policy Statement on .

Technical Specification Improvements for Nuclear Power Reactors in the Federal Reaister (52 FR 3788). In late 1987, based on the interim Policy Statement, i each of the four nuclear steam supply system (NSSS) owners groups submitted )

proposals identifying requirements in the existing Standard Technical  !

Specifications (STS) that could be relocated from the TS to licensee-controlled documents. The staff reviewed these submittals and published its conclusion in the report "NRC Staff Review of Nuclear Steam Supply System i Vendor Owners Groups' Application of the Commission's interim Policy Statement Criteria to Standard Technical Specifications" (" Split Report") dated May 9, '

1988.

The NRC interim Policy Statement provides criteria to be utilized in "

determining which requirements need to be governed by TS. The goal is to assure that TS requirements are consistent with 10CFR50.36 and have a sound i safety basis. The Split Report identified which STS requirements must be retained in the new STS (having met one or more criteria) and those requirements which could be relocated (having met none of the criteria).

Following the guidance of the split report, the owners groups proposed improved STS which were subsequently approved and published by the staff as improved STS NUREG reports.

CEN-355 Vol.5 " Restructured Standard Technical Specifications, Discussion of Changes" dated May 1989, portrays the Loose-Part Detection Instrumentation LC0 ;

i as a TS that has been relocated. The CE restructured STS were approved by the staff and issued via NUREG-1432 " Standard Technical Specifications Combustion Engineering Plants." Therefore, Waterford 3 proposes to relocate Loose-Part  !

Detection Instrumentation requirements consistent with NRC approved TS improvements. Upon approval of this change, LPDI requirements currently located in TS w.11 be relocated in the Waterford 3 UFSAR and controlled through 10CFR50.59. f Safety Analysis 1

The proposed change described above shall be deemed to involve a significant j hazards consideration if there is a positive finding in any of the following i areas: ,

1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident previously evaluated? i Response: No 1 i

o w

i The proposed change relocates Loose-Part Detection Instrumentation requirements from the TS to the UFSAR consistent with the NRC interim Policy Statement on Technical Specification Improvements.

Criterion 1 of the Policy Statement indicates that the TS should include installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. This criterion is intended to ensure that the TS control those instruments specifically installed to detect excessive reactor coolant system leakage. This criterion is not interpreted to include instrumentation used to detect precursors to reactor coolant pressure boundary leakage (e.g., Loose-Part Detection Instrumentation). The proposed change does not affect any material condition of the plant that could directly contribute to causing or mitigating the effects of an accident. Therefore, the-proposed change will not involve a significant increase in the probability or consequences or any accident previously evaluated.

2. Will operation of the facility in accordance with this proposed ,

change create the possibility of a new or different type of accident from any accident previously evaluated?

Response: No The proposed change will not involve any design change. The proposed change will not 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 or different kind of accident from any accident previously evaluated.

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

)

Response: No I

The proposed change will relocate Loose-Part Detection Instrumentation requirements from the TS to the UFSAR. The i

proposed change will have no adverse impact on the reactor coolant  :

system pressure boundary nor will any other protective boundary or safety limit be affected. Therefore, the proposed change will not involve a significant reduction in a margin of safety, j i

- m f

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 10CFR50.92; and (2) there is a reasonable assurance that the health and safety of tha public will not be endangered by the proposed change; and (3) this action will not result in a condition which significantly alters the impact of f the st: tion on the environt.ent as described in the NRC final environmental statement.

1 l

J

.aeL & ar- -A w hJ- ~ J- P *'4-JC E8'"%m_ y ,& a . 4.4 4m a M..4 a ,.m, 2aL_ 4s g..ap.3 4 y, ass..5Mi=lbh.* --Ma4 a 4--- @ w e'A . ,a a n .4 N

• 9 e

9 5

?

i i

l

'( .

t R

il '

i e

N i

9

's NPF-38-138 ,

i'. 'l

~.

)

ATTACHMENT A f

i 1

( l i

4 J

r s

1 I

?

P f

h L

f s

I t

o

' b h

t N

i

(

h J i 1_ 8 2

?

.I d

- i 3e e. - e 4 -.*mr , . .+_-c-m+.a,ew. ns. - , .ww --