ML20058B572

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Forwards Affidavit NPF-38-135 Re Request for one-time Exemption to TS 4.6.1.2 Which Requires 3 Type a Containment Ilrt.In Accordance w/10CFR50.91(a)(1),request Involves NSHC
ML20058B572
Person / Time
Site: Waterford 
Issue date: 05/07/1993
From: Barkhurst R
ENTERGY OPERATIONS, INC.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20058A860 List:
References
W3F1-93-0034, W3F1-93-34, NUDOCS 9312020127
Download: ML20058B572 (2)


Text

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W Entcrgy Operations A. P. Bartnurst W3F1-93-0034 A4.05 i

PR i

May 7, 1993 U.S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, D.C.

20555 l

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Technical Specification Change Re.9:est NPF-38-135 Gentlemen:

The attached description and safety analysis support a change to the Waterford 3 Technical Specifications.

This proposal requests a one-time exemption to Specification 4.6.1.2.a, which requires three Type A Containment i

Integrated Leakage Rate Tests to be performed at 40 10 month intervals during each 10-year service period. This one-time exemption would allow the third test of the first 10-year service period to be performed during Refuel i

7 at approximately a 54 month interval instead of the current maximum interval of 50 months.

This amendment application supplements our request for exemption to 10 CFR Part 50 Appendix J Section III.D.1(a) submitted via W3F1-93-0041 dated May 7, 1993.

I This proposed change has been evaluated in accordance with 10 CFR i

50.91(a)(1), using the criteria in 10 CFR 50.92(c) and it has been determined that this request involves no significant hazards consideration.

We respectfully request a timely review due to the potential impact on our refueling outage schedule. Refuel 6 is currently projected to begin on March 18, 1994.

The attached proposed change is similar to a change recently approved by the NRC for the Callaway Plant, Unit 1, Facility Operating License No. NPF-30.

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l Technical Specification Change Request NPF-38-135 W3F1-93-0034 Page 2 May 7,1993 Should you have any questions or comments, please contact Paul Caropino at (504) 739-6692.

Very truly yours, t.N, t

R.P. Barkhurst Vice President, Operations Waterford 3 t

RPB/PLC/dc

Attachment:

Affidavit NPF-38-135 cc:

J.L. Milhoan (NRC Region IV), D.L. Wigginton (NRC-NRR),

i R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office, Administrator Radiation Protection Division (State of l

Louisiana), American Nuclear Insurers l

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UNITED STATES t

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WASHINGTON. o.C. 20EEE 0001 4

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j August 12, 1993 Docket No. 50-382 RECBVED 4

Mr. Ross P. Barkhurst Aug 16 W Vice President Operations ILN 93 -CIL,5 Entergy Operations, Inc.

Post Office Box B K111ona, Loutsiana 70066

Dear Mr. Barkhurst:

4

SUBJECT:

EXEMPTION TO 10 CFR PART 50, APPENDIX J SECTION III.D.I.(a)

WATERFORD STEAM ELECTRIC STATION, UNIT NO. 3 (TAC NO. M86485)

The Consnission has issued the enclosed Exemption for the Waterford Steam Electric Station, Unit 3, from a certain requirement of Appendix J to 10 CFR Part 50, in response to your letter dated May 7,1993.

The Exemption removes the requirement that the third Type A test (Containment Integrated Leak Rate Test, or CILRT) far the first 10-year service period be performed at the regular interval during the first 10-year service period.

The one-time exemption would extend the third service period by approximately f

4 months within the normal 10-year service period.

I The Exemption is enclosed. A copy of the Exemption is being filed with the Office of the Federal Register for publication.

Sincerely, r.

David L.

igginton, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation

Enclosure:

Exemption cc w/ enclosure:

See next page Gy&)

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Mr. Ross P. Barkhurst Entergy Operations, Inc.

Waterford 3 cc:

Mr. Hall Bohlinger, Administrator Regional Administrator, Region IV Radiation Protection Division U.S. Nuclear Regulatory Connission Office of Air Quality and Nuclear Energy 611 Ryan Plaza Drive, Suite 1000 Post Office Box 82135 Arlington, Texas 76011 Baton Rouge, Louisiana 70884-2135 Resident Inspector /Waterford NPS Mr. John R. McGaha Post Office Box 822 i

Vice President, Operations Killona, Louisiana 70066 Support Entergy Operations, Inc.

Parish President Council P. O. Box 31995 St. Charles Parish Jackson, Mississippi 39286 P. O. Box 302 Hahnville, Louisiana 70057 William A. Cross Bethesda Licensing Office Mr. Donald C. Hintz, President 3 Metro Center and Chief Executive Officer Suite 610 Entergy Operations, Inc.

Bethesda, Maryland 20814 P. O. Box 31995 Jackson, Mississippi 39286 Mr. Robert B. McGehee Wise, Carter, Child & Caraway Chairman P.O. Box 651 Louisiana Public Service Commission Jackson, Mississippi 39205 One American Place, Suite 1630 Baton Rouge, Louisiana 70825-1697 General Manager Plant Operations Mr. R. F. Burski, Director Entergy Operations, Inc.

Nuclear Safety P. O. Box B Entergy Operations, Inc.

Killona, Louisiana 70066 P. O. Box B Killona, Louisiana 70066 Mr. L. W. Laughlin, Licensing Manager Entergy Operations, Inc.

P. O. Box B Killona, Louisiana 70066 Winston & Strrwi Attn:

N. S. Reynolds 1400 L Street, N.W.

Washington, DC 20005-3502

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UNITED STATES

'i.! W ) j NUCLEAR REGULATORY COMMISSION ih jf WASHINGTON. D.C. 208554001

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August 12, 1993 Docket No. 50-382 RECEnfE0 Mr. Ross P. Barkhurst Vice President Operations Entergy Operations, Inc.

AUg 1 6 1993 Post Office Box B K111ona, Louisiana 70066 ILN 9 5 -O/td i

Dear Mr. Barkhurst:

SUBJECT:

ISSUANCE OF AMENDMENT NO. 85 TO FACILITY OPERATING LICENSE 4

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NPF WATERFORD STEAM ELECTRIC STATION, UNIT 3 (TAC NO. M86484) i The Commission has issued the enclosed Amendment No. 85 to Facility Operating l

License No. NPF-38 for the Waterford Steam Electric Station, Unit 3.

The amendment consists of changes to the Technical Specifications (TSs) in l

response to your application dated May 7, 1993.

The amendment changes the Appendix A Technical Specifications by allowing the third Type A Containment Integrated Leakage Rate Test in the first 10-year service period to be conducted at Refuel 7.

This exceeds the interval by i

approximately 4 months.

A copy of our related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's next biweekly Federal Reoister notice.

Sincerely l, n

~

David L. Wigginton, Senior Project Manager l

Project Directorate IV-1 l

Division of Reactor Projects III/IV/V l

Office of Nuclear Reactor Regulation

Enclosures:

1. Amendment No. 85 to NPF-38
2. Safety Evaluation n -7 noa f om "i70*'m # /

i cc w/ enclosures:

See next page l

l Mr. Ross P. Barkhurst Entergy Operations, Inc.

Waterford 3 l

cc:

Mr. Hall Bohlinger, Administrator Regional Administrator, Region IV Radiation Protection Division U.S. Nuclear Regulatory Commission Office of Air Quality and Nuclear Energy 611 Ryan Plaza Drive, Suite 1000 Post Office Box 82135 Arlington, Texas 76011 Baton Rouge, Louisiana 70884-2135 1

Resident Inspector /Waterford NPS Mr. John R. McGaha Post Office Box 822 Vice President, Operations Killona, Louisiana 70066 Support Entergy Operations, Inc.

Parish President Council P. O. Box 31995 St. Charles Parish Jackson, Mississippi 39286 P. O. Box 302 Hahnville, Louisiana 70057 William A. Cross Bethesda Licensing Office Mr. Harry W. Kaiser, Executive Vice-i 3 Metro Center President and Chief Operating Officer Suite 610 Entergy Operations, Inc.

l Bethesda, Maryland 20814 P. O. Box 31995 Jackson, Mississippi 39286-1995 Mr. Robert B. McGehee Wise, Carter. Child & Caraway Chairman P.O. Box 651 Louisiana Public Service Commissi.,i, Jackson, Mississippi 39205 One American Place, Suite 1630 Baton Rouge, Louisiana 70825-1697 Mr. D. F. Packer General Manager Plant Operations Mr. R. F. Burski, Director Entergy Operations, Inc.

Nuclear Safety P. O. Box B Entergy Operations, Inc.

i Killona, Louisiana 70066 P. O. Box B i

Killona, Louisiana 70066 Mr. L. W. Laughlin, Licensing Manager Entergy Operations, Inc.

P. O. Box B Killona, Louisiana 70066 Winston & Strawn Attn:

N. S. Reynolds 1400 L Street, N.W.

Washington, DC 20005-3502 4

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UNITED STATES y

NUCLEAR REGULATORY COMMISSION 2

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j ENTERGY OPERATIONS. INC.

l DOCKET NO. 50-382 l

WATERFORD STEAM ELECTRIC STATION. UNIT 3 P

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AMENDMENT TO FACILITY OPERATING LICENSE l

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Amendment No. 85 l

License No. NPF-38 4!

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1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Entergy Operations, Inc. (the

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licensee) dated May 7, 1993, complies with the standards and i

requirements of the Atomic Energy Act of_1954, as amended (the Act),

j and the Commission's rules and regulations set forth in 10 CFR j

Chapter I; i

B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the j

Commission; C.

There is reasonable assurance (1) that the activities authorized by this amendment can be conducted without endangering the health and 1

safety of the public, and (ii) that such activities will be conducted in compliance with the Comeission's regulations;

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D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 I

of the Commission's regulations and all applicable requirements have been satisfied.

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Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Facility Operating License No. NPF-38 is hereby amended to read as follows:

(2) Technical Soncifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 85, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license.

The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance.

FOR THE NUCLEAR REGULATORY Co MISSION g

g Harry Rood, Acting Director Project Directorate IV-I Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical l

Specifications 1

l Date of Issuance: August 12, 1993 i

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ATTACHMENT TO LICENSE AMENDMENT NO. 85 TO FACILITY OPERATING LICENSE NO. NPF-38 DOCKET NO. 50-382 Replace the following pages of the Appendix A Technical Specifications with l

the attached pages.

The revised pages are identified by Amendment number and contain vertical lines indicating the areas of change.

The corresponding

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overleaf pages are also pro.vided to maintain document completeness.

j REMOVE PAGES INSERT PAGES 3/4 6-2 3/4 6-2 3/4 6-3 3/4 6-3 3/4 6-4 3/4 6-4 B 3/4 6-1 B 3/4 6-1 I

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3/4.6 CONTAINMENT SYSTEMS a

l 3/4.6.1 PRIMARY CONTAIMENT i

l CONTAINMENT INTEGRITY t

I LIMITING CONDITION FOR OPERATION I

3.6.1.1 Primary CONTAIMENT INTEGRITY shall be maintained.

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APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTION:

Without primary CONTAINMENT INTEGRITY, restore CONTAIMENT INTEGRITY within I hour or be in at least NOT STAND 8Y 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 />.

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SURVEILLANCE REQUIREMENTS i

4. 6.1.1 Primary CONTAINMENT INTEGRITY shall be. demonstrated:

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a.

At least once per 31 days by verifying that all penetrations

  • not l

capableofbeingclosedbyOPERABLlcontainmentautensticisolation valves and required to be closed durir!g accident conditions are closed by valves, blind flanges, er deactivated automatic valves secured in their positions, except~for valves that are open under administrative control as pemitted by Specification 3.6.3.

b.

By verifying that each containment air lock is in compliance with i

the requirements of Specification 3.6.1.3.

After each closing of each penetration s*llowing a Type A or Blect to T c.

except containment air locks, if opened fo l

test, by leak rate testing the seal with gas at p, 44 psig, and verifying that when the measured leakage rate for these seals is added to the leakage rates determined pursuant to Specifica-tion 4.5.1.2d for all other Type B and C penetrations, the combined leakage rate is less.than or equal to 0.60 L,.

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"Except valves, blind flanges, and deactivated outsestic valves which i

are located inside the containment and are locked, sealed er otherwise 4

secured in the closed positten. These penetrations shall be verified closed during each COLD SWTDOWN except that such verification need not be perfomed more often than once per 92 days.

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L WATERFORD - UNIT 3 3/4 6-1 AMENDMENT No. 75 1

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CONTA MiENT SYSTEMS i

j SURVEILLANCE REQUIREMENTS (Continued) 1 a.

Three Type A tests (Overall Integrated Containment Leakage Rate) shall be conducted at 40 i 10 month intervals ** during shutdown at l

i either P 44 psig, or at P period..,The third test of, 22 psig, during each 10-year service each set shall be conducted during the shutdown for the 10-year plant inservice inspection.-

b.

If any periodic Type A test fails to meet either 0.75 L or 0.75 L,

the test schedule for subsequent Type A tests shall be, reviewed an*d J

approved by the Commission.

If two consecutive Type A tests fail to meet either 0.75 L or 0.75 L,, a Type A test shall be performed at leastevery18monIhsuntiltwoconsecutiveTypeAtestsmeeteither l

0 5 or 0.75 L, at which time the above test schedule may be i

c.

The accuracy of each Type A test shall be verified by a supplemental test which:

1.

Confirms the accuracy of the test by verifying that the supple-mental test result, L,, minus the sum of the Type A and the superimposed leak, L., are equal to or less than 0.25 L,.

2.

Has a duration sufficient to establish accxrately the change in leakage rate between the Type A test and the supplemental test.

3.

Requires the quantity of gas injected into the containment or blod from the containment during the supplemental test to be between 0.75 L, and 1.25 L.

d.

Type B and C tests shall be conducted with gas at P, 44 psig, at intervals no greater than 24 months

  • except for teds involving:

1 1.

Air locks, i

2.

Purge supply and exhaust isolation valves with resilient material seals.

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  • Testing for the first cycle of operation shall be done during the first refueling outage.
    • A one time extension of the test interval is allowed for the third Type A test of the first 10-year service period, provided that performance of the Type A test occurs prior to unit restart following Refuel 7.

WATERFORD - UNIT 3 3/4 6-3 AMDDiENT NO. 4, 85

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3/4.6 CONTAIMENT_ SYSTEMS i

BASES I

3/4.6.1 PRIMARY CONTAlfetENT i

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3/4.6.1.1 CONTAlfetENT INTreRITY j

Primary CONTAINMENT INTEGRITY ensures that the release of radioactive i

materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the safety analyses.

This 4

restriction, in con. junction with the leakage rate limitation, will limit the i

SITE B0UNDARY radiation doses to within the limits of 10 CFR Part 100 during l

accident conditions.

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3/4.6.I.2 CONTAIPO4ENT LEAKAGE l

The limitations on containment leakage rates ensure that the total containment leakage volume will not exceed the value assumed in the safety analyses at the peak accident pressure, P i

measured overall integrated leakage rate I.

As an added conservatism, the s further limited to less than or equal to 0.75 L or less than or equal to 0.75 L performance of I.he periodic tests to account for, as applicable during i

i possible degradation of the containment leakage barriers between leakage tests.

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The surveillance requirements for measuring leakage rates are consistent I

with the requirements of Appendix J of 10 CFR Part 50.*

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i Secondary containment bypass leakage paths previously Table 3.6-1, have I

been incorporated into plant procedure UNT-005.026.

3 /4.6.1.3 CONTAllelENT AIR LOCKS The limitations on closure and leak rate for the containment air locks j

are required ta meet the restrictions on CONTA1101ENT INTEGRITY and containment leak rate. Surveillance testing of the air lock seals provides assurance that i

the overall air lock leakage vi 1 not become excessive due to seal damage i

during the intervals between air lock leakage tests.

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  • A one time extension of the test interval is allowed for the third Type A test of the first 10-year service period, as required by Surveillance Requirement 4.6.1.2.a and by Section III.D.(a) of Appendix J to 10 CFR Part 50, provided the performance of the Type A test occurs prior to unit restart following Refuel 7.

i WATERFORD - UNIT 3 8 3/4 6-1 AMEleMENT NO. M, R5

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4 UNITED STATES m

E NUCLEAR REGULATORY COMMISSION i

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j WASHINGTON, D.C. almW 031 NTC /

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 85 TO l

FACILITY OPERATING LICENSE NO. NPF-38 l

ENTERGY OPERATIONS. INC.

l WATERFORD STEAM ELECTRIC STATION. UNIT 3 DOCKET N0. 50-382 I

1.0 INTRODUCTION

By application dated May 7,1993, Entergy Operations, Inc. (the licensee) submitted a request for changes to the Waterford Steam Electric Station, Unit 3, Technical Specifications (TS).

The requested changes would allow a one time extension of the third Type A Containment Integrated Leakage Rate Test (CILRT), by approximately 4 months in the first 10-year service period.

2.0 EVALUATION The existing TS 4.6.1.2.a. " Containment Leakage Surveillance Requirements,"

states that three Type A tests (Overall Integrated Containment Leakage Rate) shall be conducted at 40 i 10-month intervals during shutdown at P,for the (44 psig) during each 10-year service period. The 50-month maximum interval third Type A test within the first 10-year service period would be extended to approximately 54 months. This extension will prevent performing four CILRTs, one more than required, within the first 10-year service period. The benefit of not performing the additional CILRT is a reduction in personnel radiation exposure.

A dose savings will be realized from eliminating contamination, reducing exposure for venting and draining, and from setup and restoration of instrumentation required to perform the test.

Data from the first (May 1988) and second (May 1991) CILRT at Waterford 3 3

indicates that.nost of the measured leakage is from the containment penetrations and not from the containment barrier. The "as-left" leakage rate was well below the 10 CFR Part 50 Appendix J limit.

Both A gendix J and TS requires that the leakage rate be less that 755 of L to al1ow for deterioration in leakage paths between tests. The allowable leakage rate, L,,

is 0.5 wt.X/ day. Therefore, the established acceptable limit is < 0.375 wt.X/ day.

The "as-left" leakage rates for the first two CILRTs were 0.116 and 0.0731 wt.%/ day, which is well below the acceptance limit. The Type 8 and C test (Local Leakage Rate Test or LLRT) program also provides assurance that containment integrity has been maintained.

LLRTs demonstrate operability of components and penetrations by measuring penetration and valve leakage.

Additionally, there have been no modifications made to the plant that could adversely affect the test results.

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! i Since the licensee has justified the leaktight integrity of the containment based on previous leakage test results, the staff concludes that a one-time extension of approximately 4 months beyond the maximum permitted test interval will not have a significant safety impact.

The staff, therefore, concludes that the licensee's requested one-time schedular test interval extension for conducting the third CILRT of the first 10-year service period is act.eptable.

3.0 STATE CONSULTATION

In accordance with the Comm'ission's regulations, the Louisiana State official was notified of the proposed issuance of the amendment.

The State official had no comments.

4.0 ENVIROM4 ENTAL CONSIDEPATION The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes in surveillance requirements.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

Tne Commission has previously issued a pro-posed finding that the amendment involves no significant hazards consideration and there has been no public coment on such finding (58 FR 34079).

Accordingly, the amendment meets the eligibility criteria for categorical l

exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no

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environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

j 5.0 COHCluS10N The Commission has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Comeission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor:

D. Wigginton Date: August 12,1993 1

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f WSES-FSAR-UNIT-3 TABLE 6.2-3 Revision 5 (12/92)

PPlNCIPAL CONTAINMENTDESIGN PARAMETERS Parameter Design Margin (')

Containment l

Internal design pressure, psig (LOCA) 44.0 2.2 %

l (MSLB) 44.0 0.91%

External design pressure, psid 0.65 34 %

6 3 Net free volume,10 fg 2.677 Not applicable Design leak rate, percent free volume 0.5 Not applicable Per day at 44.0 psig Shield Building Extemal design pressure, peig 3.0 4.85 %

Subcompartments Reactor cavity design wall loading, peid 240.0 84 %

Skam generator compartment design wall 55.5 153 %

loading, paid Pressurizer compartment design wall 10.0 56.25 %

loading, paid NOTES.

(13Margin (%) = 100 desian value - neak calculated value peak calculated value I

Actual margra, i.e., the margin between design values and peak calculated values when using realistic or w a= parameter values would be much laver.

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