ML20078B621

TS Change Request NPF-38-164 to License NPF-38,adding New TS 3.0.5,establishing Allowance of Equipment Removed from Svc or Declared Inoperable to Comply W/Actions to Returned to Svc Under Administrative Controls to Perform Testing

ML20078B621
Person / Time
Site:	Waterford
Issue date:	01/19/1995
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20078B623	List: ML20078B621 ML20078B626
References
W3F1-95-0007, W3F1-95-7, NUDOCS 9501250453
Download: ML20078B621 (8)

Text

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Km.na L A 700f>6-0751 TM 504 739 f461 Ross P. Barkhurst vrc he<tr Ge w.na Wmw 3 W3F1-95-0007 A4.05 PR '

January 19, 1995 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-38-164 l l

Gentlemen:

The attached description and safety analysis support a change to the -

Waterford 3 Technical Specifications (TS).

The proposed change will modify the TS by adding a new Technical f Sr,ecification, TS 3.0.5, and the associated Bases. The new TS 3.0.5 '

establishes the allowance of equipment removed from service or declared inoperable to comply with ACTIONS to be returned to service under l administrative controls solely to perform testing required to demonstrate i its OPERABILITY or the OPERABILITY of other equipment. This proposed change is based on the Combustion Engineering improved Standard Technical Specifications (STS) approved and issued by the NRC as NUREG 1432.

At the present time, the circumstances surrounding this proposed change do not meet the NRC's criteria for exigent or emergency review. However, the additional provisions of the proposed TS 3.0.5 will allow Waterford 3 to conduct specified surveillance testing on High Pressure Safety Injection Pump A. If this surveillance testing is not performed on or before March 12, 1995, Waterford 3 will have to enter a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Action due to one Emergency Core Cooling System subsystem being inoperable (TS 3.5.2.a.).

Based on the above Waterford 3 respectfully requests an expeditious review. .

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4 Technical Specification Change Request NPF-38-164 W3F1-95-0007 Page 2 l l January 19, 1995  ;

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

l Very truly yours, l I

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R.P. Barkhurst i Vice President, Operations l Waterford 3 j RPB/RTK/ssf l

Attachment:

Affidavit  !

NPF-38-164 cc: L.J. Callan, NRC Region IV C.P. Patel, NRC-NRR -

R.B. McGehee ,

N.S. Reynolds NRC Resident Inspectors Office l

Administrator Radiation Protection Division  ;

i (State of Louisiana)

American Nuclear Insurers  ;

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l UNITED STATES GF AMERICA i

. NUCLEAR REGULATORY COMMISSION In the matter of ) ,

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

i AFFIDAVIT l R.P. Barkhurst, being duly sworn, hereby deposes and says that he is Vice i 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-38-164; 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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% h R.P. Barkhurst -

Vice President Operations - Waterford 3  ;

i STATE OF LOUISIANA )

) ss PARISH OF ST. CHARLES ) j Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this /97" day of JA A/ v A /t 7' , 1995.

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K/en b. O Notary Public My Commission expires R d M ' "* * .

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DESCRIPTION AND SAFETY ANr. LYSIS OF PROPOSED CHANGE NPF-38-164 l

The proposed change will modify the Waterford 3 Technical Specifications (TS) l by adding TS 3.0.5 and its associated Bases. This new specification will allow equipment removed from service or declared inoperable to comply with ACTIONS to be returned to service under administrative controls solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of j other equipment. This proposed change is based on the Combustion Engineering )

improved Standard Technical Specifications (STS) approved and issued by the NRC as NUREG 1432.

Existina Specification l

1 See Attachment A j i

Proposed Specification See Attachment B j Backaround i

i On October 7,1994, a leakage rain for Safety Injection Tank (SIT) 1A was identified. Leakage in excess of the allowed maximum pathway leakage for containment isolation valve SI-343 was discovered. SI-343 is a normally l

closed air operated globe valve located inside the containment building. This l valve was subsequently declared inoperable and Technical Specification 3.s '  ;

l " Containment Isolation Valves" Action "c" was entered. This Action require. l l with one or more of the isolation valves inoperable, maintain at least one l isolation valve OPERABLE in each affected penetration that is open and isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one closed manual l valve or blind flange. To comply with this Action "c", containment isolation valve SI-344 was closed.51-344 ss a normally locked closed, manually j

operated globe valve located outside the containment building. Waterford 3 l planned to repair SI-343. However, SI-343 is located in containment and after l further evaluation it was decided to repair this valve at the next refuoling interval. The function of the Containment Isolation System (CIS) is to isolate fluid systems that pass through the primary containment vessel to confine any radioactivity that may be released following a LOCA or Main Steam Line Break (MSLB) inside containment.

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l TS Surveillance 4.5.2.f requires that each of the safety injection pumps that are required to be operable performs as indicated on recirculation flow when tested pursuant to Specification 4.0.5. Containment isolation valves SI-343 and SI-344 are located within the line used to perform Surveillance 4.5.2.f and these valves must be open to establish a stable ' recirculation flow path.

The proposed change will allow SI-343 and SI-344 to be open under  !

administrative controls for the time required to perform TS Surveillance l 4.5.2.f. l Proposed Chanae Waterford 3 Technical Specifications neither specifically allow nor prohibit i re-entry into ACTION statements. The Combustion Engineering improved STS (NUREG 1432) incorporates a provision that allows systems or components to be s returned to service for the performance of testing required to demonstrate equipment OPERABILITY. This new provision enhances plant safety by providing ,

greater assurance that systems or components important to plant safety can be '

returned to and maintained in operable status.

l This change will add page 3/4 0-la to the Technical Specifications which will state the following. " Equipment removed from :,ervice or declared inoperable to comply with ACTIONS may be returned to service under administrative .

controls solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LC0 3.0.2 for the l system returned to service under administrative-control to perform the testing required to demonstrate OPERABILITY." In addition, the Technical Specification Bases section will be updated to-add the Bases for TS 3.0.5.

l Safety Analysis l

l The proposed change described above shall be deemed to involve a significant i 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 l involve a significant increase in the probability or consequences of an accident previously evaluated?

l Response: No l

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1 The proposed change will allow an orderly return to service of inoperable equipment. Specification 3.0.5 will permit equipment removed from service to comply with required Actions to be returned to service under administrative controls to verify the operability of the equipment ,

being returned to service or operability of other equipment. The  !

administrative controls will ensure the time involved will be limited to only the time required to demonstrate the component or system operability. This new specification provides an acceptable method of demonstrating the operability of TS equipment before it is returned to ,

service and allows for verifying other TS equipment is operable. '

Therefore, the proposed change will not involve a significant increase  ;

in the probability or consequences of any accident previously evaluated. 1 1

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 not alter the operation of the plant or the  ;

manner in which the plant is operated. The equipment is only being l tested in its design configuration or being returned to service to allow ]

testing of another component or system. Therefore, the proposed change j 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 i involve a significant reduction in a margin of safety?

! Response: No The proposed Specification will only allow the return to service of equipment that is expected to fulfill its safety function. The use of l Specification 3.0.5 will be limited to the performance of testing on the equipment being returned to service or on other equipment that is dependent on the equipment being returned to service. The testing is i limited to post maintenance testing and testing to prove operability.

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

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!' Safety and Sianificant Hazards Determination  !

Based on the above safety analysis, it is concluded that: (1) the proposed'

,l change does not constitute a significant hazards consideration as defined by j 10CFR50.92; and (2) there is a reasonable assurance that the. health and safety i of the public will not be endangered by the proposed change; and (3) this j 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 ,

j statement.

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NPF-38-164 l I

ATTACHMENT A I

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