ML20070J831

Responds to NRC 930325 RAI Re NPF-38-131 Submitted by Util to Revise Applicability of TS Sections 3.0 & 4.0, in Accordance W/Gl 87-09.Mark-up TS Page 3/4 0-3,reflecting Change to TS 3.0.4 Encl

ML20070J831
Person / Time
Site:	Waterford
Issue date:	07/22/1994
From:	Burski R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20070J840	List: ML20070J831 ML20070J851
References
GL-87-09, GL-87-9, W3F1-94--0104, W3F1-94--104, NUDOCS 9407250334
Download: ML20070J831 (6)

Text

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Kmcro, LA 70006 Tel 504 739 6774 R. F. Burski Omot Nuchy Satag 7/?Mrf0f'j 3 W3F1-94-0104 A4.05 PR i July 22, 1994 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES ,

Docket No. 50-382 ll License No. NPF-38  !

Request For Additional Information Regarding NPF-38-131 Gentlemen:

By letter dated February 9, 1993 Waterford 3 proposed a change that would revise the_ applicability of Technical Specifications (TS) Sections 3.0 and 4.0 in accordance with Generic Letter (GL) 87-09, " Sections 3.0 and-4.0 of' the Standard Technical Specifications (STS) on the Applicability of  !

Limiting Conditions For Operation and Surveillance Requirements."

By letter dated March 25,_1993, the staff requested the following additional information concerning the proposed change to TS 3.0.4: -

a. For each proposed TS exception to 3.0.4 to be granted under GL 87-09, affirm that remedial measures prescribed by the affected ACTION STATEMENTS are consistent with the Updated Safety Analysis Report (USAR) and its supporting safety analysis.

b. Identify and affirm those administrative controls (e.g., maintenance' program provisions,_ plant operating procedures, management i directives, onsite safety reviews, etc.) that have been established to limit the use of the Specification 3.0.4 exceptions granted. The ,

affirmation should address training necessary' for ensuring _that plant ,

operators are made aware of, and are instructed to exercise the

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controls promulgated in limiting the use of such exceptions.

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Request for Additional Information Regarding NPF-38-131 W3F1-94-0104 Page 2 July 22, 1994

c. Provide the response to the three criteria for a no significant hazards consideration.

To address NRC concerns, each specification containing an exception to Specification 3.0.4 whose Action Statements permitted continued operation of the plant for an unlimited period of time was reviewed. This review verified that the specified remedial Actions provide an acceptable level of safety for continued plant operation. However, Waterford 3 proposes that all specifications currently containing an exception to 3.0.4 continue to clearly state this exception. In addition, 3.0.4 is modified by specifying that additional exceptions (i.e. other than those specifically stated in individual specifications and meeting the provisions of 3.0.4 as revised) be subject to review and approval as described in plant administrative controls. This proposed change (see attached mark-up TS page 3/4 0-3 )

slightly deviates from the recommendations of GL 87-09 but is intended to:

1) incorporate the improved TS provision, 2) limit the use of additional exceptions to 3.0.4, and 3) minimize the impact on plant operators associated with implementing the proposed change.

Additional exceptions, allowed by the proposed revision to 3.0.4, will be subject to review by the Plant Operations Review Committee (PORC) and approval by the General Manager Plant Operations as discussed above.

Therefore, Attachment B to our original submittal dated February 9,1993 should be modified as follows:

. Disregard the previous proposed change to TS 3.0.4 in favor of the proposed change attached and described above.

. Disregard proposed changes to the following LCOs:

3.3.3.2 -

Incore Detectors 3.3.3.3 -

Seismic instrumentation 3.3.3.4 -

Meteorological instrumentation 3.3.3.7.1 -

Chlorine detection system 3.3.3.7.3 -

Broad range gas detection 3.3.3.9 -

Loose-part detection instrumentation 3.3.3.11 -

Explosive Gas Monitoring System 3.4.9 -

Structural integrity 3.7.9 -

Sealed source contamination

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I Request for Additional Information Regarding NPF-38-131 W3F1-94-0104 Page 3 July 22, 1994 3.9.7 -

Crane travel - fuel handling building 3.9.9 -

Containment purge valve isolation system 3.9.12 -

Fuel handling building ventilation system 3.11.1.4 -

Liquid holdup tanks 3.11.2.5 -

Explosive gas mixture 3.11.2.6 -

Gas storage tanks In support of our previous determination of "no significant hazards" the following Safety Analysis is provided as requested.

Safety Analysis

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 TS 3.0.4 prevents entry into an operational mode or other specified condition unless Limiting Conditions for Operations (LCOs) are met without reliance on Action Requirements. The intent of this TS is to ensure that a higher mode of operation is not entered when equipment is inoperable or when parameters exceed their specified limits.

l The proposed change clarifies TS 3.0.4 such that LCOs with Action Statements tl.d permit continued operation for an unlimited period of time are exempt from the restrictions of TS 3.0.4. This provision is ,

modified to require an additional plant safety review prior to implementing additional exceptions to 3.0.4 other than those currently stated in the individual specifications. This proposed change is consistent with existing NRC regulatory requirements for LCOs.

The proposed change to TS 4.0.3 incorporates a 24-hour delay in implementing the Action Statements due to a missed surveillance requirement when the Action Statements provide a restoration time that is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. As reflected in GL 87-09, this change is justified in that it is overly conservative to assume that systems or

I Request for Additional Information Regarding NPF-38-131 I W3F1-94-0104 l Page 4 July 22, 1994 l l

components are immediately inoperable when a surveillance requirement has not been performed. The NRC concludes in Generic Letter 87-09 )

that a 24-hour time limit balances the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Action Statements before the surveillance can be completed. The NRC further states that the potential for a plant upset and challenge to safety systems is increased if surveillances are performed during actions to initiate a shutdown to comply with Action Requirements.

TS 4.0.4 has been modified to note that its provisions shall not prevent passage through or to operational modes as required to comply with Action Requirements. This change is consistent with the intent of the existing TS and represents a clarification.

No previously analyzed accident scenario is changed by the proposed TS changes described above. Initiating conditions and assumptions remain as previously analyzed.

Therefore, the proposed changes 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 to TS 3.0.4 is administrative in nature. Entry into an operational mode or other specified condition will be allowed for those specifications not currently stating an exception to 3.0.4 when 1) the applicable LCOs Action Requirement permits continued operation for an unlimited period of time and 2) the PORC has reviewed and approved the exception.

Request for Additional Information Regarding NPF-38-131 W3F1-94-0104 Page 5 July 22, 1994 The proposed change to TS 4.0.3 will allow continued operation for an additional 24-hours after discovery of a missed surveillance. As reflected in GL 87-09, missing a surveillance does not mean that a component or system is inoperable. In most cases, surveillances provide positive verification of operability.

The proposed change to TS 4.0.4 will alleviate conflict within the TS. The change is necessary to allow the plant to proceed through or

, to required operational modes to comply with Action Statements even if applicable Surveillance Requirements may not have been performed.

These changes do not affect the operation of the plant or the manner in which it is operated.

Therefore, the proposed changes 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 to TS 3.0.4 is administrative in nature and will have no impact on any margin of safety.

The proposed change to TS 4.0.3 will allow up to 24-hours to perform a missed surveillance, in some cases this will eliminate the need for a plant shutdown. As reflected in GL 87-09, the overall effect is an increase in plant safety by avoiding unnecessary shutdowns and associated system transients due to missed surveillances.

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Request for Additional Information Regarding NPF-38-131 W3F1-94-0104 Page 6 July .22, 1994 The proposed change to TS 4.0.4 will eliminate an internal conflict

' within the TS and allow the plant to proceed througi; or to required operational modes to comply with Action Statements ev o it applicable Surveillance Pequirements for that mode may not have been performed.

The NRC staff has previously evaluated these change in Generic Letter 87-09 and determined that the TS modifications will result in improved TS.

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

If you should have any questions concerning the above, please contact Paul Caropino at (504) 739-6692.

Very truly yours,

, g).

R.F. Burski Director Nuclear Safety RFB/PLC/ssf Attachment i

cc: L.J. Callan, 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 Louisiana)

American Nuclear Insurers

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