ML20058N735
| ML20058N735 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/15/1993 |
| From: | Barkhurst R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20058N739 | List: |
| References | |
| W3F1-93-0075, W3F1-93-75, NUDOCS 9310200257 | |
| Download: ML20058N735 (7) | |
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'W 504 739 6661 Ross P. Barkhurst h Nesr; eor Q,mww mmkyd 3 W3F1-93-0075 A4.05 PR October 15, 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-38-139 Gentlemen:
The; purpose-of this letter is to request the deletion of T.S. 3.6.4.2 and
'Its associated bases T.S. 3/4.6.4 from the Waterford 3 license. This T.S. amendment will eliminate the requirements to maintain operational and test the' hydrogen recombiners. The' hydrogen recombiners will remain 2
physically in the plant, but the system will not be maintained
. operational, nor will it -be tested. :The 10CFR50.92 evaluation is herein
- provided.
This;1etter should be: considered in conjunction with Waterford 3 letter i
(
W3F1-93-0073 which provides the ' detailed justification for the l
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- wik.ination of. the hydrogen recombiners, and which establishes the basis
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for'an exemption to 10CFR50.44 and 10CFR50, Appendix A, criterion 41.
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' On'May 4. at the annual Regulatory Information Conference, Dr. Murley b
announced.a pilot program,-Cost' Beneficial-Licensing Action Initiative F
- (CBLA), established _by NRR to give special consideration to licensee
' requests for changes requiring staff review that 1:2volve high cost and W
low safety benefit.
In response to Dr. Murley's initiative, Entergy by
. Operations met'with NRR staff on' June 8,1993, to present an initial list b.
of CBLAs. 'As discussed'en June.8, 1993, the proposed change to eliminate p
the: requirements. associated with the hydrogen recombiners is being i
' submitted under the CBLA program.
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- l Technical. Specification Change Request NPF-38-139 W3F1-93-0075 Page 2 October 15, 1993 Please contact me or Robert J. Murillo should there be any questions regarding this matter.
Very truly yours, h
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i R.P.'Barkhurst.
Vice President, Operations Waterford 3.
RPB/RJM/dc
Attachment:
Affidavit NPF-35-139-
-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 F
(State of Louisiana)
American Nuclear Insurers i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In.the matter of
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Entergy Operations, Incorporated
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Docket No. 50-382
. Waterford 3" Steam Electric Station
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,e AFFIDAVIT E
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 L
Commission the attached Technical Specification Change Request NPF 139; 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.
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b R.P. Barkhurst Vice President Operations - Waterford 3 c.
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 h
and State above named this
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- day of.
Oc rosart
, 1993.
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- c. b Notary Public~
My Commission expires tv 4 r a t * ' C i>
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DESCRIPTION AND SAFETY ANALYSIS
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OF PROPOSED CHANGE NPF-38-139
-This proposed change deletes Technical Specification (TS) 3.6.4.2 and its associated bases 3/4.6.4 from the'Waterford 3 license. This proposed change
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is' submitted in conjunction with a specific exemption request to 10CFR50.44 and 10CFR50, Appendix A, criterion 41, reference Waterford 3 letter W3F1 :
p 0073.
Existina Specification i.
See Attachment A Proposed Soecificatign
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See' Attachment B Deletion of T.S. 3.6.4.2.
Deletion of T.S. 3/4.6.4.
i Description The hydrogen recombiners were provided in accordance with 10CFR50.44 and
'10CFR50, Appendix A, criterion 41 to be available to maintain the hydrogen concentration within containment below its flammable limit during post-LOCA conditions. Either recombiner unit is capable of controlling the hypothetical hydrogen generation-during a DBA associated with (1) zirconium water reactions, (2) radiolytic decomposition of water, and (3) corrosion. The hydrogen control systems are consistent with the recommendations of Regulatory Guide 1.7, March 1971. The licensing basis for the hydrogen recombiners is described in FSAR section 6.2.5.
This proposed change will eliminate the requirements to maintain operational and test the hydrogen recombiners. The hydrogen recombiners wilt remain physically in the plant, but the system will not be maintained o;erational, nor'will it.be tested.. The regulatory and technical justification is
- documented in the specific exemption request, reference Waterford 3 letter W3F1-93-0073.
The exemption request is in compliance with sections (a)(2)(f f), (a)(2)(iv) and (a)(2)(vi) of 10CFR50.12..The exemption request demonstrates that: the underlying purpose of the regulation is' achieved [(a)(2)(if)], there is a benefit to the public health and safety [(a)(2)(iv)], and there are present f
-material circumstances not considered when the regulation was adopted
'[(a)(2)(vi)].
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l DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-139 Page 2 l
The technical justif', cation is predicated on the following technical bases:
1.
Short term post LOCA hydrogen generation is less than 1%, well below the 4% hydrogen flammability limit.
2.
Long term' post LOCA hydrogen generation at 30 days is about 5.7% which
'is less than the flame propagation limit of 6%, which according to Regulatory Guide 1.7 would not result in effects adverse to containment system::. A time period of 30 days would provide ample time within which to mobilize resources and to implement long term recovery actions, such as containment venting,' for example, by using the Containment Atmosphere Release System, (CARS).
3.
Waterford 3 analyses establish that a hydrogen burn at 8.1%
hydrogen concentration, following a design basis LOCA without long term hydrogen control would produce-a peak pressure of 31.0 psig which is below the. containment design pressure of 44 psig. A hydrogen concentration of 8.1%. envelops the TMI burn which occurred at about 7 to 8% hydrogen concentration, reference seven (7), and produced a peak l
pressure of.28 psig. The pressure resulting from the hydrogen burn, 31.0 psig, is also below the Waterford 3 limiting design basis accident (MSLB) peak pressure of 43.6 psig. The actual containment failure pressure for Waterford 3 is expected to be in the range of 2.5 to 3.0 i
times the containment design pressure based on containment failure j
.. pressures.for containment designs similar to Waterford 3.
.4.
Recombiners have a negligible impact on reducing hydrogen generation from severe accidents. Accordingly, renoving the hydrogen recombiners
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.has a negligible impact on severe accident risks.
i Safety ' Analysis The proposed change des _cribed above shall be deemed to involve a significant
. hazards consideration if there is a positive finding in any of the following areas-d:
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DESCRIPTION AND SAFETY. ANALYSIS
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E DF PROPOSED CHANGE NpF-38-139 p
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_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?
Response: No.
_ Short term post LOCA hydrogen generation is less than 1%, well below the r
4% hydrogen flammability limit.
Long term post LOCA hydrogen generation 9
at 30 days is about.5.7% which is less than the flame propagation limit of 6% which according to Regulatory Guide 1.7 would not result in effects adverse to containment systems. A time period of 30 days would provide ample time within which to mobilize resources and to implement long term recovery actions, such as containment venting, for example, by
[
using the Containment Atmosphere Release System, (CARS). Waterford 3 analyses establish that.a hydrogen burn at 8.1% hydrogen concentration,
. following a design' basis LOCA without long term hydrogen control. would produce a peak' pressure of 31.0 psig which is below the containment F
design' pressure of 44 psig. A hydrogen concentration of 8.1% envelops the,TMI burn which occurred at about 7 to 8% hydrogen concentration, E
reference'seven_'(7), and produced a peak pres::ure of 28 psig. The pressure resulting from the hydrogen burn, 31.0 psig, is also below the Waterford 3 linitting design basis accident (MSLB) peak pressure of 43.6 e
psig. The actual containment; failure pressure for Waterford 3 is h
expected to be in the range of 2.5 to 3.0 times the containment design
- pressure based on containment failure pressures for containment designs similar.to Waterford 3.
Recombiners have a negligible impact on L
reducing hydrogen generation from severe accidents. Accordingly, removing:the hydrogen recombiners has a negligible impact on severe accident risks. Thus, there is significant assurance the proposed change will not involve a significant increase in the probability or consequences of any accident 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?
1 Response:' No p
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} DESCRIPTION:AND SAFETY ANALYSIS-.
@j lg' OFLPROPOSED CHANGE NPF-38-139:
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i LThel proposed change will. not alter the configuration. or operation of any
.,, f d.other. plant; system or component.. The change does not~ involve any change-i
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- to the " operational or design limits of any other plant-systems or.
components.. Thus;'no new failure modes are. introduced or associated yp with the proposed change. Therefore, the proposed change will not" U
create
- the possibility of a' new or different kind of accident previously
- evaluated.
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13.s Will operation of. the. facility in accordance with this proposed change l
11nvolve.a significant' reduction in a margin of safety?-
i The. proposed change will have no adverse' impact on the protective z boundaries, safety limits, or margin.or safety. There are no limits or F
margins'of safety-being revised for any systems, components,-or l protective boundaries. Therefore, the proposed' change wil1L not involve ea significant reduction in a margin of safety.
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Igfety and Stanificant Hazards' Determination 4
Basedlon.the aboveL safety analysis,.it is concluded that:
(1) the proposed
. change.does-not constitute;a'significant hazards consideration as defined by
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10CFR50.92;. and~~(2) there is reasonable assurance that the health and safety.
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lof;thelpublic will;not!be endangered by the proposed change; and (3) this W
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.
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statement.
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