ML20058F578

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Safety Evaluation Supporting Amend 91 to License NPF-38
ML20058F578
Person / Time
Site: Waterford Entergy icon.png
Issue date: 11/22/1993
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20058F575 List:
References
NUDOCS 9312080184
Download: ML20058F578 (4)


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%,.....f SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 91 TO FACILITY OPERATING LICENSE NO. NPF-38 ENTERGY OPERATIONS. INC.

WATERFORD STEAM ELECTRIC STATION. UNIT 3 DOCKET NO. 50-382

1.0 INTRODUCTION

By letter dated October 21, 1992, Entergy Operations, Inc. (the licensee),

requested a revision to the Technical Specifications (TS) for the Waterford Steam Electric Station, Unit 3.

The proposed amendment would revise radiation monitoring instrumentation of Table 3.3-6 by relaxing the operability requirements for the Component Cooling Water (CCW) radiation monitors and altering the applicability and action statements associated with these monitors.

2.0 DISCUSSION The CCW system is a closed loop system that supplies cooling to plant systems and components.

Each loop services specified equipment, and radiation monitoring is provided to detect reactor coulant system (RCS) leakage from the i

reactor coolant pump (RCP) seals. A continuously operating radiation monitor is provided in each of the redundant headers on the discharge side of the pumps. These monitors (CCW monitors A and B) are the safety-related instruments specified in Table 3.3-6, item 2d. A third monitor, not safety-related, is provided on the return line from containment in the nonessential seismically qualified loop. This instrumant (item 2e, CCW monitor A/B) monitors the cooling water from the components inside the containment (i.e., the four RCP pump seals and motor control element drive mechanism (CEDM) coolers).

The purpose of the third monitor (CCW monitor A/B) is to provide early detection of RCS_ leakage from the RCP seals. The current TS requires this monitor to be operable during all modes of operation. The licensee proposes i

to revise this requirement to exclude Mode 5 cold shutdown and Mode 6

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refueling, because of the reduced RCS pressure and reduced CCW flow while in i

these modes.

In Mode 5, reactor coolant pressure is lower, resulting in lower stresses and reduced potential for RCP seal leakage.

In Mode 6, CCW flow through the nonessential seismically qualified loop is reduced and isolated at the containment to facilitate refueling operations (i.e., disassembly of the control element drive mechanism and testing of the containment isolation valve testing).

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During refueling, this line is isolated at the containment to facilitate refueling activities. The flow in the CCW return line is reduced during this mode, and the differential pressure across the monitor sample line tap is i

insufficient to create an adequate sample flow.

This results in declaring the monitor inoperable and entering the associated action that requires sampling and analysis.

(On September 24, 1992, an 8-hour sample was missed, resulting in Licensee Event Report 92-011.)

If the RCP seals should leak during Mode 5 depressurization, any leakage would still be identified by the i

two continuous CCW radiation monitors A and B.

In addition, CCW pressure and temperature are monitored at each of the RCP seal outlets. A high temperature or pressure signal annunciates an automatic isolation of the affected RCP seal cooler.

On the basis of the above and the following TS changes, the staff finds that the applicability requirements for CCW monitor A/B is justified and will not i

pose a threat to safety.

The licensee proposed to revise TS 3/4.3.3, " Radiation Monitoring Instrumentation," which prescribes the operability requirements for the radiation monitoring instruments shown in Table 3.3-6.

Items 2d and 2e of this table provide the specified limits for t'nree CCWS radiation monitoring instrumentation channels.

In order to easily distinguish the monitors, the 1

licensee proposes to revise items 2d and 2e to indicate monitor A & B and 4

monitor A/8, respectively. The applicability requirements for item 2e j

(monitor A/B) have been changed from all modes to Modes 1 through 4 because of the operational difficulties experienced from reduced CCW flow. These changes i

are as follows.

TABLE 3.3-6 1

RADIATION MONITORING INSTRUMENTATION

)

APPLICABLE INSTRUMENT MODES

2. PROCESS MONITORS
d. Component Cooling,A&B Water ALL MODES System Monitors
e. Component Cooling Water IV2h37&l4 GyMem ponitogA/B ALL MODEf Identical changes have been made to Table 4.3-3 " Radiation Monitoring Instrumentation Surveillance Requirements," as shown in the following:

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i

. r TABLE 4.3-3 RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS MODES FOR WHICH SURVEILLANCE INSTRUMENT IS REQUIRED 2.

Process Monitors d.

Component Cooling Water ALL MODES System M ITORSlA&B T

e.

Component Cooling Water U2ECF4 Sysum l40 HIT 0Q/B ALEMODE5" "

In addition, Action Statement 28 was modified to include the special report criteria of Specification 6.9.2. as follows:

TABLE 3.3-6 (Continued)

ACTION STATEMENT ACTION 28-With the number of channel 0PERABLE less than required by the Minimum Channels OPERABLE requirements, operation of the plant may continue for up to 30 days provided grab samples are taken once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and these samples are analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

I f!ihs%iill6Eli sTiisFrist6pid 7tiif0PERABl.E:l:sfifs531 tEt hy30Tdsys afterJthe;failurencontinuersampi ngl.andtprepare:and.(subm.it af.

Special Reportjto;the? Commission pursuantitoVSpecification;6.9.2 s

withins 14!-days: outlining;thelactionstakenFthe+cause of.the inoperability;andithe; plans 3ndtscheduleifkrestoringMe;s.# tem tol0PERABLE; status]

The special report will ensure that in the unlikely event that these monitors are out of service beyond 30 days a schedule for returning the monitor to service will be established.

t 3.0 EVALUATION The staff evaluated the radiological aspects of the revised TS requirements for the radiation monitoring instrumentation in Table 3.3-6 which relax the operability requirements for the CCW radiation monitors in Mode 5 and Mode 6 and finds that the licensee's TS change is acceptable based on the following:

P

. 1.

The proposed change will allow one less CCW monitor during cold shutdown and refueling modes while maintaining system integrity with two continuous radiation monitoring instruments.

2.

Adding monitors A and B to item 2d and monitor A/B to item 2e is purely administrative in nature and clarifies the specifications.

It does not involve a reduction in a margin of safety.

3.

Removing the operability requirements for Modes 5 and # from CCW radiation monitor A/B will have no effect on accident. previously evaluated.

Radiation detection will continue to be rarformed by CCW radiation monitors A and B.

The staff concludes that the primary function of these process monitors is to provide early detection (and ALARA, but no automatic isolation) of the leakage of radioactive materials into normally nonradioactive systems, and the proposed changes, therefore, are acceptable to the staff.

4.0 STATE CONSULTATION

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

The State official had no comments.

i

5.0 ENVIRONMENTAL CONSIDERATION

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 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. The Commission has previously issued a pro-posed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (57 FR 55580).

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

i 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 Commission'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:

J. Minns Date: November 22, 1993