ML20083L327

Suppl to TS Change Request NPF-38-145 to License NPF-38, Modifying SRs of TS 3.6.1.2 for Containment Leakage by Removing Specified Schedular Criteria for Type a Testing,Per Requirements of C-E Improved STS (NUREG-1432)

ML20083L327
Person / Time
Site:	Waterford
Issue date:	05/12/1995
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20083L330	List: ML20083L327 ML20083L337
References
RTR-NUREG-1432 W3F1-95-0066, W3F1-95-66, NUDOCS 9505180267
Download: ML20083L327 (7)

Text

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Khya LA 70006 075I T.s! 50a 739 %1 Ross P. Barkhurst we Nwee 0;en er y, m t v.! 3 W3F1-95-0066 A4.05 PR May 12, 1995 U.S. Nuclear Regulatory Commission Attn: Document Control Desk i Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Supplement To Technical Specification Change Request NPF-38-145 Gentlemen:

By letter dated November 16, 1993 Waterford 3 proposed the subject Technical Specification Change Request. This submittal supersedes our previous request in its entirety.

This proposed change modifies TS 3/4.6.1.2 by adopting the wording for primary containment integrated leak rate testing that is consistent with the requirements of the Combustion Engineering Improved Standard Technical l Specifications (NUREG 1432).  !

l The circumstances surrounding this change do not meet the NRC's criteria for exigent or emergency review. However, this request is directly related  !

to our 10CFR50 Appendix J, exemption request dated November 16, 1993. Due to the significant impact on our upcoming refueling outage, we respectfully l request an expeditious review. The Waterford 3 refueling outage is l currently scheduled to begin September 8, 1995.

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3 Supplement To Technical Specification Change Request NPF-38-145 W3F1-95-0066 Page 2 May 12, 1995 This proposed change has been evaluated in accordance with 10CFR50.91(a)(1) using criteria in 10CFR50.92(c) and it has been determined that the i proposed change involves no significant hazards considerations. The Plant Operations Review and Safety Review Committees have reviewed and accepted i the proposed change. l 1

Should you have any questions or comments concerning this request, please ,.

contact Paul Caropino at (504)739-6692.  !

Very truly yours, i

\Ib R.P. Barkhurst Vice President, Operations Waterford 3 i RPB/PLC/ssf

Attachment:

Affidavit I

NPF-38-145 cc: L.J. Callan, NRC Region IV C.P. Patel, NRC-NRR R.B. McGehee N.S. Reynolds NRC Resident Inspectors Office Administrator Radiation Protection Division (State of Louisiana)

American Nuclear Insurers

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

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

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 Supplement To Technical Specification Change Request NPF-38-145; 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.

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 12 " day of inh 4 , 1995.

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Ch Notary Public My Commission expires R'7" "T .

DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-145 The proposed change modifies the surveillance requirements of Technical Specification 3.6.1.2 for containment leakage by removing the specified scheduler criteria for Type A testing. In place of the specific requirements is a requirement to follow the source of this criteria that is 10 CFR 50, Appendix J.

Existina Specification See Attachment A Proposed Specification See Attachment B Eackaround The TS currently require that a set of 3 containment integrated leak (Type A) tests be performed at 40 plus or minus 10 month intervals, during each 10-year service period, with the third test of each set performed during shutdown for the 10-year plant inservice inspection. Appendix J to 10 CFR 50 requires that ,

a Type A test of the containment be performed periodically. These tests are l required to be scheduled as a set of three tests to be performed at I approximately equal intervals during each 10-year service period with the third test to coincide with the shutdown for the 10-year plant inservice inspection. The TS containment leakage rate testing requirements essentially duplicate the requirements of Appendix J; additionally, the TS require the Type A test be performed at 40 plus or minus 10 month intervals. The TS requirement to conduct Type A test at 40 plus or minus 10 month intervals is too restrictive especially for licensees on 18 month fuel cycles. This results in additional licensee amendment applications such as Waterford 3's NPF-38-135 dated May 7, 1993 that resulted in TS Amendment 85. The improved standard technical specifications resolved this problem by removing detailed schedules from the TS and simply requiring compliance with 10 CFR 50, Appendix J, except as modified by approved exemptions. The proposed change proposes to delete the detailed surveillance schedule for the Type A tests and, instead, reference performance of Type A testing in accordance with 10 CFR 50, Appendix J.

This proposed change is similar to NRC approved changes for other licensee facilities e.g., D.C. Cook granted January 5, 1995, Duke Power granted March 9, 1995, Indian Point 2 granted March 17, 1995 and Brunswick Steam Electric Plant granted February 21, 1995.

Description The proposed change modifies surveillance requirements associated with containment leakage TS 3.6.1.2 by removing scheduler requirement for Type A tests to be performed specifically at 40 plus or minus 10 month intervals and, instead, reference Type A testing in accordance with 10 CFR 50, Appendix J.

The proposed change also includes several administrative changes.

TS 4.6.1.2 is reformatted and revised to state that "The containment leakage rates shall be demonstrated as follows." The requirement to perform containment leak rate testing using ANSI N45.4-1972 has been relocated to the Bases. This requirement is also duplicated in appendix J.

The Type A testing requirements previously specified in TS 4.6.1.2 (a), (b),

and (c) are duplicated in Appendix J and, therefore, deleted and replaced with a requirement to perform Type A testing in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions.

The footnote identified by a single asterisk (applicable to Type B and C tests) no longer applies and is deleted. This is purely an administrative change.

The footnote identified by double asterisk is deleted. This footnote involved an approved exception (re; NRC Letter dated August 12,1993) to 10 CFR 50, Appendix J, and will no longer be required under the proposed change.

jiafety 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 i involve a significant increase in the probability or consequences of an l accident previously evaluated? i l

Response: No I

The proposed change will not affect the assumptions, design parameters, or results of any accident previously evaluated. The proposed change does not add or modify any existing equipment. The proposed Type A test schedule will continue to be consistent with 10 CFR 50 Appendix J.

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 does not involve modifications to any existing equipment. The proposed change will not affect the operation of the plant or the manner in which the plant 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?

I Response: No The margin of safety for the containment barrier is, in part, preserved by compliance with 10 CFR 50 Appendix J. Although the proposed change will allow greater flexibility in meeting Appendix J requirements, the TS will continue to preserve compliance with 10 CFR Appendix J. 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.

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NPF-38-145 ATTACHMENT A a

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