ML20095L585

TS Change Request NPF-38-122 to License NPF-38 for Removal of Tables 3.6-1,3.6-2,3.8-1 & 3.8-2 from Tss,Per GL 91-08, Removal of Component Lists from Tss

ML20095L585
Person / Time
Site:	Waterford
Issue date:	05/05/1992
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20095L586	List: ML20095L585 ML20095L591
References
GL-91-08, GL-91-8, W3F191-0618, W3F191-618, NUDOCS 9205070148
Download: ML20095L585 (8)

Text

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R. P. Bar k hurst W3F191-0618 A4.05 QA May 5, 1992 U.S. Nuclear Regulatory Commission ATTN: Docusent Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Technical Specification Change Request NPF-38-122 Gentlemen:

Pursuant to Generic Letter 91-08 " Removal of Component Lists From Technical Specificatior.s" dated May 6, 1991, Entergy Operations, Incorporated is requesting an amendment to remove the following component lists from the Technical Specifications.

Table 3.6-1 " Secondary Containment Bypass Leakage Paths" Table 3.6-3 " Containment Isolatin Valves" Tabl e 3.8-1 " Containment Penetra*;1on Conductor Overcurrent Protective Devices" Table 3.8-2 " Motor-operated Valves Thermal overload Protection and/or Bypass Devices" The proposed change is consistent with the guidance provided by Generic Letter 91-08, Enclosures 1 and 2. L'pc a approval, the component lists identified above will have been incorporated into  ;

a plant prs'edure subject to the change control provisions of Technical f recification 6.8. Any fut.re change to these component lists wil taen be governed by 50.59 thus relieving the NRC and Entergy Operations Incorporated of the administrative burdens i required to update TS component lists. l l

Please note that this request, which in part affects Limiting Condition For Operation (LCO) 3.6.3, will need to be coordinated with our previous request NPF-38-105 dated November 3, 1989 which

-also affects LCO 3.5.3.

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l Technical Specification Change Request NPP-38-122 W3F191-0618 Page 2 May 5, 1992 Should you have any questions or comments on this matter, please contact Paul Caropino at (504) 739-6692.

Very truly yours, o aj RPB/PLC/dc

Attachment:

Affidavit NPF-38-122 cc: R.D. Martin, 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

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UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION '

l In the matter of- ) l

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Entergy Operations, Incorporated ) Docket No. 50-332 Waterford 3 Steam Electric Station ) i l

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AFFIDAVIT l 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 l Change Request NPF-38-122 ; that he is familiar with the content thereof; and that the matters set >rth therein are true and correct to the best of his knowledge aformation and belief.

l Uv vvd,3J N ~

l R.P. Barkhurst Vice President Operations - Waterford 3 STATE OF LOUISIANA )

) ss PARISH OF ST. CHARIES )

Subscribed and sworn to before me, a Notary Public in and for the t Parish and State above named this S I" day of l /77fl V , 1992.

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Notary Public My Commission expires wi7" FC .

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DESCRIPTION AND SAFETY ANALYSIS

.0F PROPOSED CIIANGE NPF-38-122  !

This proposal requests a change to _ Waterford 3 Technical Specification (TS) in accordance with the _ guidance provided in Generic Letter (GL) 08.

Existina Soecificati2DR See Attachment A Proposed Soecificatipmg Cae Attachment B Descriotion Generic Letter 91-08 provides guidance to licensees for preparing an amendment request to remove component lists from the technical specifications. The change is described as a line-item TS improvement which will allow for maintaining component lists in appropriately controlled plant procedures.

The guidance requires amendment requests to address the following three elements:

1). Each TS should include an appropriate description of the scope of the components to which the TS requirements apply. '

2) If the removal of a component list results in the loss of notes that modify or provide an exception to the requirrments the specification should be revised to incorporate that modification or exception.

3) Licensees should confirm that the' list of components removed from the TS are located in appropriately controlled plant procedures.

Generic Letter- 91-08 Mclosure 1 provides guidance on the TS changes for specific lists.of components. Enclosure " provides the applicable sections of the current standard technical ;pecification requirements with the TS changes to allow the removal of component lists. The following describes changes to the Waterford-3 TS to remove those specific component lists addressed by Generic Letter 91-08 in conformance with Enclosures 1 and 2.

Containment Isolation Valves LCO 3/4.6.3 for containment isolation valves was revised to state l "Each containment isolation valve shall be Operable"; The reference j to valves "specified in table 3.6-2" was removed from the LCO and i

~ the action statement. Similarly, the surveillance requirements for

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(1) post-maintenance testing, (2) demonstrating automatic closure on isolation signals, and (3) confirming the isolation time of power-operated or automatic valves, were revised to remove the reference valve to Table and shall..." 3.6-2 "and to state "Each containment isolation

...each power-operated or automatic containment isolation valve shall..."

Footnotes appearing in Table 3.6-2 were incorporated in the LCO.

The footnote involving valves that are exempt from the requirements of TS 3.0.4 was added to the LCO by stating "The provisions of specification 3.0.4 do not apply". The footnote that addressed the operational consideration for specific valves which may be opened on an intermittent basis was added to the LCO by stating " Locked or sealed closed valves may be opened on an intermittent basis under administrative control". In addition, the definition of Containment Integrity (section 1.7) and surveillance requirement 4.6 1. 1.a for demonstrating containment integrity were revised to remove that are the reference to table 3.6-2 and state. . . " except for valves open under administrative control as Specification 3.6.3." permitted by A footnote appearing in Table 3.3-10 referring to Table 3.6.2 was revised to state " Containment isolation valves governed by specification 3.6.3".

TS Basis 3/4.6.3 was revised in accordance with administrative control considerations GL 91-08 to include which constitute acceptable for opening locked or sealed closed containment isolation valves.

The above listed changes identify specific valves (containment isolation) by function rather than component number and therefore removal of the component list Table 3.6-2 is alternative. an acceptable Secondary Containpent Bynass Leakage Paths The definitions of " secondary containment bypass leakage paths" and

" penetrations and valves subject to type B and C tests" are adequately defined by the plant licensing basis such that the TS requirements do not require further clarification. Therefore references to Table 3.6-1 appearing in 3.6.1.2 removed. Specification 3.6.1.2.C was revised to (b) and (c) were state... "for all penetrations that are secondary containment bypass leakage paths. "

Containment Penetration Conductor Overcurrent Protection Devices The list of containment penetration conductor overcurrent protective devices includes those primary and backup fusos and breakers that preclude faults of a magnitude and duration that could compromise the integrity of electrical penetrations. Because the number of overcurrent protective devices associated with electrical circuits penetrating containment may exceed the basic requirements these for primary components has beenand backup protection, the description of stated which tha TS requirements apply.

to clarify those components to Also, these requirements exclude circuits for which credible fault currents would not exceed the 2

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roting. For oxamplo, theco penstration docign signal electrical requirements excludefollowingthermocouple and other low-power-level

3. 8.4.1 and The statement replaces 100 3/4 circuits.

I removes previous reference to Table 3.8-1: t Primary and backup containment penetration conductor overcurren protective devices associated with each The containment scope of these electrical penetration circuit shall be OPERABLE. fault protective devices excludes those circuits for which credi (a) was removed The without reference impactingtothe Table 3.8-1 inrequirements.

surveillance Action statement to Surveillance requirement 4.8.4.1 was revised to removeand noted primary reference backup "The above Table 3.8-1 and state containment penetration..." " . . .and as The statement appearing in surveillance was removed 4.8.4.1.A.1B without impact on the specified in Table 3.8-1" requirements.

"as noted on l

The statement appearing in surveilluce 4.8.4.1. A.2 Table 3.8 protective relays *...". the A footnote stating "* Testing of these circuit breakers (i.e., in d 480 volts power from low voltage switchgear) shall be performed.

accordance with the vendor's calibration procedures" was adde The change stated above incorporates an exception to the TS requirements in terms consistent with those recommended in GL 91-*

08.

Motor-Ocerated Valves Thermal Overload Protection tion TS Table 3.8-2 lists valves that have thermal overloM protec The table and bypass devices integral with the motor starter.f'c0 Lion andLCO the bypass devic and lists the valves by number. 3.8-2, 3/4 define3.8.2 thewas scoperevised to remove of valves reference that include thesetofeatures Table integral by w!'h stating '

"The thermal overload protection and bypass devices, systems shall be the motor starter, of each valve used in safety operable".

will be removed from With the above changes the associated single page tablesthat notes the affected the TS and replaced with a index has likewise been updated to The TS pages as "Not Used". remove all references to the associated Tables.

SAFETY ANALYSLS ii Generic Letter 91-08 presents a review of the safety sign f cance component lists from the technical of proposals to remove The staff concluded that " specifications may be to specifications. stated in general terms Thisthat an acceptable describe the types of components provides which the requirements apply.

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alternativo to identifying co:1ponsnts by their plant idsntification number as they are currently listed in tables of TS components.

The removal of component lists is acceptable because it does not alter existing TS requirements or those components to which they apply." Therefore, no significant hazards consideration exists.

The Commission provided guidance concerning standards for ,

determining whether a significant hazards consideration exists by l providing certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazards considerations. This proposal most closely resembles example (iv) .

"(iv) A relief granted upon demonstration of acceptable operation from an operating restriction that was imposed because acceptable operation was not yet demonstrated. This assumes that the operating restriction and the criteria to be applied to a request for relief have been established in a prior review and that it is l justified in a satisfactory way that the criteria have been met." i l

Generic Letter 91-08 describes a lina item improvement to technical l specifications applicable to Waterford. Thia f roposal suggests incorporating the exact words used from Generis ?.t.tter 91-08 where applicable.

Safetv_And Sionificant 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 10 CFR 50.92; 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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ATTAC1 DENT A NPF-38-122

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