ML20058B689

Affidavit of RP Barkhurst to File W/Nrc Encl TS Change Request NPF-38-135

ML20058B689
Person / Time
Site:	Waterford
Issue date:	05/07/1993
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20058A860	List: ML20058A857 ML20058B572 ML20058B689
References
NUDOCS 9312020170
Download: ML20058B689 (14)

Text

r1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION In the matter of

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i Entergy Operations, Incorporated

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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 Operations - 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-38-135; 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.

M R.P. Barkhurst i

Vice President Operations - Waterford 3 STATE OF LOUISIANA

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) ss PARISH OF ST. CHARLES

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Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this

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, 1993.

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Notary Public hw G

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DESCRIPTION AND SAFETY ANALYSIS 1

0F PROPOSED CHANGE NPF-38-135 l

The proposed change requests a one-time schedular exemption to Technical i

j Specification (TS) Surveillance Requirement 4.6.1.2.a' and its associated Bases, that requires three Type A (Containment Integrated Leakage Rate Tests) i CILRT be performed at 40 10 month intervals during each 10-year service 1

period. This one-time exemption would allow the third test of the first 10--

year service period to be performed during Refuel 7 at approximately a 54 j

month interval instead of the current maximum interval of 50 months.

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Existina Soecifications See Attachment A i

Prooosed Soecifications I

i See Attachment B i

Type A tests are defined in 10 CFR Part 50 Appendix J Section II.F as " tests i

intended to measure the primary reactor containment overall integrated j

leakage rate (1) after the e.ontainment has been completed and is ready for i

operation, and (2) at periodic intervals thereafter.". The periodic retest schedule for Type A tests is' prescribed by 10 CFR Part 50 Appendix J Section III.D.l(a) "After the preoperational leakage rate tests, a set of three Type A tests shall be performed, at approximately equal intervals during each 10-year service period. The third tests of each set shall be conducted when the plant is shutdown for the 10-year plant inservice inspections."

TS 4.6.1.2.a requires that three Type A test be conducted at 40 10 month intervals.

This Surveillance incorporates the requirements of Appendix J Section III.D.1(a).

The time required to perform the CILRTs necessitates 1

that they be performed during refueling outages. The time interval between CILRTs should be about 40 months based on performing three such tests at approximately equal intervals during each 10-year service period.

Since refueling outages do' not necessarily occur coincident with a 40 month interval, a permissible variation of 10 months (i.e., a 25 percent variation) is authorized in the TS to permit flexibility in scheduling.

Per ASME Section XI IWA-2400(a), the 10-year service period begins with the inservice date.

The first and second CILRTs of the first 10-year service period for Waterford 3, were conducted in May 1988 and May 1991 respectively.

This represents testing intervals of 32 and 36 months based on an inservice date of September 1985. This would indicate that the third of the first set of three CILRTs be performed during Refuel 6 (scheduled for March 1994) which will be 34 months after the preceding test. However, this would not meet the TS and CFR requirement ~ to perform the third CILRT during shutdown for the 10-year inservice inspection interval. ASME Section XI IWA-2400(c) allows the 10-year inspection interval to be decreased or extended by as much as' one year. Thus, performing the third CILRT during Refuel 6 would not meet this criteria while the Refuel 7 projected start date of Octoberil995'is well within these bounds. In order to comply with the 40 i 10 month criteria and CFR requirements Waterford 3 would be forced to perform an extra CILRT within the first 10-year service period.

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i To avoid performing this fourth CILRT, we are proposing that the third CILRT for the first 10-year service period be performed in November 1995 during i

Refuel 7.

This will allow compliance with all other criteria and represents a one-time extension of approximately four months beyond the maximum permitted CILRT test interval.

j The benefit of not performing an additional CILRT is a reduction in personnel radiation exposure.

A dose savings will be realized from eliminating i

contamination, reducing exposure for venting and draining, and from setup and i

restoration of instrumentation required to perform the test.

The NRC has l

previously approved a similar amendment request as indicated in NRR Safety Evaluation related to Amendment 77 to Facility Operating License No. NPF-30, Callaway Plant Unit 1, dated February 22, 1993.

Data from the first (May 1988) and second (May 1991) CILRTs at Waterford 3 indicates that most of the measured leakage is from the containment penetrations and not from the containment barrier.

Penetration and valve leakage is measured by the performance of Type B and C tests (Local Leakage Rate Test or LLRT).

The LLRT program is not altered by this request, therefore, containment integrity will continue to be verified by LLRTs.

In addition, the data from the previous CILRTs illustrates that the "as-left" leakage rate was well below the acceptance limits established in 10 CFR Part 50 Appendix J, and Technical Specifications. The allowable leakate rate, L.,

is 0.5 wt. %/ day, however, Appendix J and TS require that the leakage rate be less than 75% of L, to allow for deterioration in leakage paths between tests.

Therefore, the acceptance limit is <0.375 wt. %/ day. The "as left" leakage I

rates for the first two CILRTs were 0.116 and 0.0731 wt. %/ day which is well below the acceptance limit. Additionally, there have been no modifications made to the containment structure since the last CILRT that could adversely affect the test results.

l Safety Analysis i

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 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 7 Response: No.

This one-time exemption to extend the CILRT interval approximately four months beyond the maximus TS allowance within the first 10-year service period will not adversely impact plant safety. The majority of leakage from the containment is through penetrations and isolation valves. The schedule for perfcrming the Type B and C LLRTs is not affected.

The allowable containment leakage used in accident analysis for offsite doses is L., 0.5 wt. %/ day. For conservatism the leakage is limited to 75% of L, to account for possible degradation of the containment leakage barriers between tests.

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Based on the leaktight integrity of.the containment, as l'

demonstrated by previous CILRT test results, the additional time.

i period 'added to the third testing interval will not adversely j

impact the containment leakage barriers' to a point where j

degradation would cause leakage to exceed that assumed in i

accident analysis.

l Therefore, the proposed change will not involve a significant j

increase in the probability or consequences of any accident i

j previously evaluated.

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2.

Will operation of the facility in accordance with this proposed i

change create the possibility of a new or-different type of i

accident from any accident previously evaluated?

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Response: No l

j There are no design changes being made that would create a new i

type of accident or malfunction.

The proposed change will not i

alter the plant or the manner in which it - is operated.. The j

change proposes a one-time exemption to extend the time interval for performing the third CILRT. The purpose of the CILRT is to provide periodic verification by test of the leaktight integrity of the primary reactor containment, and systems and components which penetrate containment.

The tests : assure that leakage through containment, and. systems and components penetrating containment will not exceed the allowable leakage rate values associated with unditions resulting ' from a loss'-of-coolant accident.

The addttional time period added to the third CILRT interval will not adversely affect'the containment integrity in the event of a loss-of-coolant accident. Therefore, the proposed change will not create the possibility of a new or different type 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 is a one-time request to extend a

. surveillance interval and does not reduce, the margin of safety assumed in accident analysis for release of radioactive materials from the containment atmosphere into - the ' environment, or any margin of safety preserved by the Technical Specifications.

4 Therefore, the proposed change will not involve a significant

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reduction in a margin of safety.

" 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 change; 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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l NPF-38-135 ATTACHMENT A 1

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CONTAINMENT SYSTEMS I

CONTAINMENT LEAKAGE h-LIMITING CONDITION FOR OPERATION i

3.6.1.2 Containment leakage rates snall be limited to:

a.

An overall integrated leakage rate of:

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1.

Less than or equal to L 0

containmentairper24$o,urs.50percentbyweightofthe at P,,

44 psig, or i

2.

Less than or equal to L 0

j containment air per 24 bo,urs.25 percent by weight of the at a reduced pressure of P,g l

22 psig.

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A combined leakage rate of less than or equal to 0.60 L for all penetrationsandvalvessubjecttoTypeBandCtestsw$enpressurized to P,.

t A comoined bypass leakage rate of less than or equal to 0.06 L, pa c.

for all penetrations that are secondary containment bypass leakage

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when pressurized to P,.

APPLICABILITY:

MODES 1, 2, 3, and 4.

J ACTION:

With either (a) the measured overall integrated containment leakage rate 2

exceeoing0.75L,allpenetrItionsandvalves.subjecttoTypes8andCtests or 0.75 L, as applicable, or (b) with the measured combined leakage rate for exceeding 0.60 L,the overall integrated leakage rate to less than or equ

, or (c) with the combined bypass leakage rata exceeding l

0.06 L restore to0.7$,L i

or less than or equal to 0.75 L i

leakageriteforallpenetrationsandvalvIs,asapplicable,andthecombined subject to Type 8 and C tests to j

less than or equal to 0.60 L and the bypass leakage rate to less than or equalto0.06L,priortoin8r,easingtheReactorCoolantSystemtemperature i

i above 200'F.

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SURVEILLANCE REQUIREENTS 1

i 4.6.1.2 The containment leakage rates shall be demonstrated at the following test schedule and shall be determined in conforur.ance with the critaria specified in Appendix J of 10 CFR Part 50 using the methods and provisions of ANSI N45.4-1972:

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a.

Three Type A tests (Overall Integrated Containment Leakage Rate) shall be conducted at 40 : 10 month intervals during WATERFORD - UNIT 3 3/4 6-2 AMENDMENT NO.75

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NTAINMENT SYS E'AS i

SURVEILLANCE REQUIREMENTS (C:ntinueci snuttown at either P, 22 :sig, er at P, 22 :sig, curing eacn 3

10 year service perioc.

The third test of eacn set snail be c:ncuctec curing the snutccwn for the 10 year plant inservice i

inscection.

If any periccic Type A test fails to meet either 0.75 L. Or 0.75 L.,

the test scnecule for sucsequent Type A tests snall be reviewec anc

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i aoprovec by the Ccmmission.

If two consecutive Type A tests fail to l

meet either 0.75 L i

or 0.75 L, a Type A test snall be performea at a

least every 18 months until two consecutive Type A tests meet either 0.75 L, or 0.75 L at wnicn time the acove test scnedule may be i

resumed.

1 The accuracy of eacn Type A test shall be verified by a sucplemental c.

test wnien:

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Confirms the accuracy of the test by verifying that the supple-mental test result, L, minus the sum of the Type A and the i

c superimposed leak, L, are equal to or less than 0.25 L,.

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2.

Has a duration sufficient to establish accurately the change in j

leakage rate between the Type A test and the supplemental test.

3.

Requires the quantity of gas injected into the containment or I

bled from the containment during the supplemental test to be j

between 0.75 L and 1.25 L a

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Type B and C tests shall be conducted with gas at P,, 44 psig, at d.

intervals no greater than 24 months" except for tests involving-1.

Air locks,

2. ~ Purge supply and exhaust isolation valves with resilient material seals.

Purge supply and exhaust isolation valves with resilient material e.

i seals snall be tested and demonstrated OPERABLE per Surveillance Requirement 4.6.1.7.2.

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• Testing for the first cycle of op tration shall be done during the first refueling outage.

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WATERFORD - UNIT 3 3/4 6-3 AMINDMINT NO. 4 c

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CONTAINMENT SYSTEMS SURVEILLANCE REOUIREMENTS (Continued) f.

The comoined bypass leakage rate snail be determined to be less than or equal to 0.06 L, by applicable Type B and C tests at least once per 24 months" except for penetrations which are not individually testable; penetrations not individually testable shall be determined to have no detectable leakage when tested with soED bubbles while the containment is pressurized to P,, 44 psig, during eacn Type A test.

Air locks shall be tested and demonstrated OPERABLE per Surveillance g.

Requirement 4.6.1.3.

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The provisions of Specification 4.0.2 are not applicable.

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• Testing for the first cycle of cperation shall be done during the first refueling outage.

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l WATERFORD - UNIT 3 3/4 6-4 AMENDMENT NO. 4

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l 3/4.6 CONTAINMENT SYSTEMS BASES 3/4.6.1 PRIMARY CONTAINMENT 3/4.6.1.1 CONTAINMENT INTEGRITY Primary CONTAINMENT INTEGRITY ensures that the release of racioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the safety analyses.

This restriction, in conjunction with the leakage rate limitation, will limit the SITE BOUNDARY radiation doses to within the limits of 10 CFR Part 100 during accident conditions.

3/4.6.1.2 CONTAINMENT LEAKAGE The limitations on containment leakage rates ensure that the total i

containment leakage volumq will not exceed the value assumed in the safety J

analyses at the peak accident pressure, P,.

As an added conservatism, the measured overall integrated leakage rate is further limited to less than or l

equal to 0.75 L, or less than or equal to 0.75 L. Es applicable during t

performance of the periodic tests to account for possible degradation of the containment leakage barriers between leakage tests.

j The surveillance requirements for measuring leakage rates are consistent with the requirements of Appendix J of 10 CFR Part 50.

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

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been incorporated into plant procedure UNT-005.026.

1 3/4.6.1.3 CONTAINMENT AIR LOCKS The limitations on closure and leak rats for the containment air locks are required to meet the restrictions on CONTAI.1IENT INTEGRITY and containment leak rate.

Surveillance testing of the air lock seals provides assurance that the overall air lock leakage will not become excessive due to seal damage during the intervals between air lock leakage tests.

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~WATERFORD - UNIT 3 8 3/4 6-1 APENDl4ENT N0. 75

$/4.6 CONTAINMENT SYSTEMS l

BASES 3/4.6.1 PRIMARY CONTAINMENT 3/4.6.1.1 C0hTAINMEhT IhTEGRITY l

i Primary CONTAINMENT INTEGRITY ensures that the release of radioactive taterials from the conta1nment atmosphere will be restricted to those leakage l

?aths and associated leak rates assmed in the safety analyses. This restriction. in conjunction with the leatage rate limitation, will limit the SITE E7JC,RY raciation coses to within the limits of 10 UR Part 100 during i

accident conditions.

i 3/4.6.1.2 CONTAINPTNT LEAKAGE The limitations on contaiment leakage rates ensure that the total

ntainment leakage volse will not exceed the value assmed in the safety analyses at the peat accident pressure. P. As an adoed conservatism, the a

i measured overall integrated leakage rate is further limited to less than or l

e;ual to 0.75 L or less than or equal to 0.75 L 3

t as applicable during performance cf the periodic tests to account for possible degradation of the

ontoiment leakage barriers ber.een leakage tests.

1 The surveillance requirements for measuring leakage rates are consistent alth the requirements of Appendix J cf 10 CFR Part 501 ADO l

Seconcary containtnent bypass leakage paths previously. Table 3.61. have seen incorporated into plant procedure UNT.005-026.

'4.6.1.3 C0hTAINPEhT AIR LOCKS The limitations on closure and leak rate for the containment air locks e re uired to meet the restrictions on CONTAINHENT INTEGRITY and contaiment sk rate. Surveillance testing of the air lock seals provides assurance that e overall air lock leatage will not become excessive due to seal damage

. ring the intervals bet.een air lock leakage tests.

"A on2 tine extension cf the test interval is allowed for the third Type A ADD test :t tne first 10-veer service per1od, as reeJ1 red oy Survelliance Reeaire.

rent 4 6 1 2.a and oy Section Ill.0.fa) of Acoendix J to 10 CFR Part 50.

croviced tne perfont.ance cf tre Type A test occurs Drlor to un1t restart f oll%1no Ref uel 7.

4ATERF0 0 - UNIT 3 B 3/4 6-1 AMENDMENT NO. 75

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N AI M NT SYSTEMS DTAIMNT LEAKAE m!MITING CONDITION FOR OPERATION i

i L6.I.2 Contairment leakage rates shall be limited to:

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a.

An overall integrated leakage rate of:

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Less than or equal to L, 0.50 percent by weight of the l

a containment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at P. 44 psig, or a

2.

Less than or equal to L. 0.25 percent by wight of the t

containment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at a reduced pressure of P -

t 22 psig.

D.

A combined leakage rate of less than or equal to 0.60 L for all i

a penetrations and valves subject to Type B and C tests when pressurized to P -

a A combined bypass leakage rate of less than or equal to 0.06 L, for c.

all penetrations that are secondary containment bypass leakage paths when pressurized to P -

a APPLICABILITf:

MODES 1. 2. 3. and 4.

ACTION:

1 ilth either (a) the measured overall integrated contairment leakage rate

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exceeding 0.75 L or 0.75 L. as applicable, or (b) with the measured combined i

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leakage rate for all penetrations and valves subject to Types B and C tests exceeding 0.60 L. or (c) with the combined bypass leakage rate exceeding a

LD6 L restore the overall integrated leakage rate to less than or equal a

o 0.75 L or less than or equal to 0.75 L. as applicab*t. and the combined a

t eakage rate for all penetrations and valves subject to Type B and C tests to i

ess than or equal to 0.60 L and the bypass leakage rate to less than or j

a r::ual to 0.06 La prior to increasing the Reactor Coolant System temperature cove 200*F.

SURVEILLANCE REQUIREENTS L6.1.2 The contairment leakage rates shall be demonstrated at the following

est schedule and shall be cetermined in conformance with the criteria

pecified in Appendix J of 10 CFR Pcrt 50 using the methods and provisions of Wil N45.4-1972:

a.

Three Type A tests (Overail Integrated Contairment Leakage Rate)

MOVE snal) be conoxted at 40 t 10 month intervals during TO Pg.

3/4 6-3 4ATERFORD - UNIT 3 3/4 6-2 AMENDMENT NO. 75

i I i CONTAlteENT SYSTEMS t

SLHVEILLANCE Requirements (Contin'.:ed) s.

Three Type A tests (Overall Integrated Contairnent Leakage Rate) f shall be conducted at 40110 month 1-tervals ". during shutdown ADD at either P. 44 psig. or at P. 22 psig. during each 10-year a

t service period. The third test of each set shall M :.onducted l

during the shutdown for the 10-year plant inservice inspection.

b.

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

t the test schedule for subsequent Type A tests shall be review and approved by the Commission. If two consecutive Type A tests fail to l

meet either 0.75 L or 0.75 L. a Type A test shall be performed at t

a least every 18 mmths until tw consecutive Type A tests meet either 0.75 L or 0.75 Lt at which time the above test schedule may be a

restned.

c.

The acct.tacy of each Type A test shall be verified by a supplemental test which:

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Confirms the accuracy of the test by verifying that the supple-l mental test result. L. minus the sta of the Type A and the c

superimposed leak. L, are equal to or less than 0.25 L -

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Has a duration sufficient to establish accurately the change in leatage rate bete the Type A test and the supplemental test.

3.

Recuires the quantity of gas injected into the contairment or l

bled from the containment d'.: ring the supplemental test to be j

bete 0.75 L and 1.25 L -

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Type B and C tests shall be conducted with gas at P. 44 psig. it a

intervals no greater than 24 months

• except for tests involving:

1.

Air locks.

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Pury supply and exhaust isolation valves with resilient material seals.

e.

Purge stoply and exhaust isolation valves with resilient material K)VE seals shall be tasted and demonstrated OPERABLE per Surveillance TO Pg.

Requirement 4.6.1.7.2.

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" Testing for the first cycle of operation shall be done during the first refuelinn outage.

"A one time extension of the test interval is allowed for the third Type A ADD test of the first 10-year service period. prov10ed that performance of the Type A test occurs prior to unit restVE tollchong Ptfuel 7.

j 4ATEPJORD - UNIT 3 3/4 6 3 MENDMENT 4 i

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l n TAINT NT SYSTEMS SURVEILLATE REQUIREENTS (Continued)

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e.

Purge supply and exhaust isolation valves with resilieat material i

seals shall be tested and demonstrated OPERABLE per Surveillance Requirement 4.6.1.7.2 f.

The ccmcined bypass leakage rate shall be determined to be less than or e:;ual to 0.06 L a y applicable Type B and C tests at least once l

b per 24 months except for penetrations which are not individually testable; penetrations not individually testable shall be determined to have no detectable leakage when tested with soap bubbles while the contairrnent is pressurized to P. 44 psig, during each Type A l

a test.

g.

Air locks shall be tested and demonstrated OPEPABLE per Surveillance Requirement 4.6.1.3.

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The provisions of Specification 4.0.2 are not applicable.

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" Testing for the first cycle of operation shall be done during the first i refueling outage.

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r lWATERFORD. UNIT 3 3/4 6-4 AMENDMENT 4 I

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NPF-38-135 4

i ATTACHMENT B l

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