ML20069P663

Application for Amend to License NPF-38,consisting of TS Change Request NPF-38-154,replacing Generic Control Room Outside Air Intake Radiation Monitor Alarm/Trip Setpoint W/ Site Specific Setpoint

ML20069P663
Person / Time
Site:	Waterford
Issue date:	06/22/1994
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20069P669	List: ML20069P663 ML20069P670
References
W3F1-94-0113, W3F1-94-113, NUDOCS 9406270066
Download: ML20069P663 (8)

Text

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K#ra LA 700f40751 Te! 504 739 0661 Ross P. Barkhurst Ae Mc ei+n O cavn we tec 3 W3F1-94-0113 A4.05 PR June 22, 1994 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 ,

Subject:

Waterford 3 SES Docket No. 50-3d2 License No. NPF-38  ;

Technical Specification Change Request NPF-38-154 Gentlemen:

The attached description and safety analysis supports a change to the Waterford 3 Technical Specifications. The proposed change replaces the generic Control Room Outside Air Intake radiation monitor alarm / trip setpoint with a site specific setpoint. This propo. sed change is an effort to reduce the number of unplanned actuations of the Engineered Safety <

Feature portion of the Control Room Ventilation System.

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i Technical Specification Change Request NPF-38-154 ,

W3F1-94-Oll3 l Page 2 June 22, 1994  :

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

1 Very truly yours,

)S5 ^ hb R.P. Barkhurst Vice President, Operations Waterford 3 4

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Attachment:

Affidavit NPF-38-154 r Reference List cc: L,J. Callan, NRC Region IV D.L. Wigginton, NRC-NRR ,

R.B. McGehee ,

N.S. Reynolds NRC Resident Inspectors Office  !

Administrator Radiation Protection Division (State of Louisiana) '

American Nuclear Insurers i

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

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

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-38-154; 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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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 2 2'"' day of J u.v ct _ 1994.

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Iiotary Public My Commission expires W , m ' "" ' .

DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-154 The proposed change revises the alarm / trip setpoint for the Control Room .

Intake Monitors in Technical Specification (TS) Table 3.3-6 item 2b.  ;

3 Existina Specification See Attachment A Proposed Specification See Attachment B i pescription TS Table 3.3-6 currently specifies the alarm / trip setpoint for the Control i Room Outside Air Intake (CROAI) radiation monitors as s 2x background. The proposed change replaces the current CR0AI setpoint with a set value of s 4.09 x 10-5 micro curies per cubic centimeter, which is not dependent on background radiation. ,

The CROAI radiation Monitors play a vital role in Control Room Habitability and therefore are subject to requirements appearing in General Design Criteria (GDC) 19 of Appendix A 10CFR50, NUREG 0800 (Standard Review Plan) Section 6.4, NUREG 0737 III.D.3.4, and 10CFR20.

As part of the Control Room Ventilation System, the CROAI radiation monitors help to insure that during normal operation and design bases accident l conditions, the maximum airborne radioactive concentrations in air breathed by l control room personnel is as low as is reasonably achievable and within the i limits specified in Appendix B Table 1 of 10CFR20.

l The CROAI radiation monitors measure airborne activity levels in the CR0AI ducts. In the event high airborne activity is detected, a signal is generated to isolate the normal CROAI ducts, place the Control Room Ventilation System in recirculation mode, and start the Control Room Emergency Ventilation System.

The current setpoint of s 2x backgroand is the generic setpoint recommended in the Combustion Engineering Standard Technical Specifications, NUREC-0212 (Reference 1). The intent of this setpoint is to establish a trip setpoint 4

that is high enough to avoid spurious actuations yet low enough to protect plant operators fro.n excessive occupational radiation exposure.

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The proposed setpoint of s 4.09 x 10-5 Ci/cc is a plant specific setpoint derived from an engineering calculation (Reference 2). Expected annual quantities and concentrations of released radioactive materials were obtained from FSAR Tables 11.3-5, 11.3-6 and 11.3-8 (Reference 3). This data was used to calculate the activity rate at the CROAI monitor locations and inside the control room.

The new alarm / trip setpoint is based on radioactive material concentrations in the control room not exceeding the Derived Air Concentration (DAC) occupational values listed in 10CFR20, Appendix B, Table 1, Column 3. The proposed setpoint has been conservatively adjusted to account for instrument uncertainty and drift.

This proposed TS change is part of an effort to reduce unplanned actuations of the Engineered Safety Feature (ESF) portion of the Control Room Ventilation +

System. Since 1984, Waterford 3 has experienced numerous Control Room Emergency Filtration System actuations due to the high alarm trip on the CR0AI monitors (Reference 4 lists 22 Licensee Event Reports). While the root cause for most of these events has been determined and corrective action taken, 2 events remain indeterminate. It is hoped that by changing the CROAI monitor alarm setpoint to a fixed value, independent of background radiation, spurious Control Room Ventilation System actuations can be reduced and thus improve plant safety.

The word " Water" was inadvertently omitted from Table 3.3-6 item 2.e, when replacement page 3/4 3-29 was issued pursuant to Amendment 91 (Reference 5).  :

This minor editorial fix has been flagged on Attachment B.

Safety Analysis 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 areas:

1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change replaces the current CROAI radiation monitor alarm / trip setpoint of s 2x background with a fixed value independent of background radiation. The new setpoint will continue to provide protection to plant personnel such that occupational radiation exposure is maintained within the limits of 10CFR20 during normal plant operations, anticipated operational occurrences or design basis accidents.

Therefore, 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 type of accident from any accident previously evaluated? ,

Response: No.

The proposed change will replace the generic CROAI radiation monitor alarm / trip setpoint with a setpoint derived from a site specific calculation. 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 change involve a significant reduction in a margin of safety?

Response: No The proposed change will replace the current CROAI radiation monitor setpoint with a new setpoint that will ensure occupational radiation exposure will not exceed the DAC limits of 10CFR20. The proposed change has no adverse impact on protective boundaries, safety limits, or margin of safety.

Therefore, the proposed change will not involve a significant reduction in a margin of safety.

Safety and Sianificant 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 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. l 1

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References

1. Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors, NUREG-0212.

2. Control Room Outside Air Intake Radiation Monitor Setpoint Calculation HP-CALC-93-004 dated 8/20/93. ,

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3. Waterford 3 Final Safety Analysis Report Table 11.3-5 Source Term (No Continuous Gas Stripping of Volume Control Tank) Noble Gases and lodines Table 11.3-6 Source Terms (No Continuous Gas Stripping of Volume Control Tank)

Table 11.3-8 Average Annual Airborne Radionuclide Concentrations (yCi/cc)

4. Licensee Event Reports84-001, 85-002,85-005 85-030,85-036, 85-039, i 85-043,85-045, 85-048,86-003, 86-020,86-022, 86-029,87-015, 87-022,88-003, 90-011,90-014, 90-015,91-002, 92-003,92-005.

5. NRC Letter dated November 22 1993,

Subject:

ISSUANCE OF AMENDMENT NO. 91 TO FACILITY OPERATING LICENSE NPF WATERFORD STEAM ELECTRIC STATION, UNIT 3 (TAC NO. M84791).

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4 NPF-38-154 ATTACHMENT A L

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