ML20100D631

TS Change Request NPF-38-176 to License NPF-38,amending Allowable Values of Parameters in Table 3.3-4 to Be Consistent W/Identical Parameters in Table 2.2-1 as Approved in Amend 113 & Adding Mode 4 to SRs of Table 4.3-2 Item 5.c

ML20100D631
Person / Time
Site:	Waterford
Issue date:	02/06/1996
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20100D634	List: ML20100D631 ML20100D636
References
W3F1-96-0006, W3F1-96-6, NUDOCS 9602080219
Download: ML20100D631 (7)

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Ross P. Barkhurst i o.. m. ,, n , .

n ,o W3F1-96-0006 A4.05 PR February 6,1996 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Subject:

Water' ford 3 SES Docket No. 50-382 License No. NPF-38 Technical Specification Change Request NPF-38-176 Gentlemen:

The attached description and safety analysis supports a change to the Waterford 3 i Technical Specifications (TS). The proposed change is necessary to correct several inconsistencies and is purely administrative in nature.

The proposed change has been evaluated in accordance with 10CFR50.91(a)(1) l using criteria in 10CFR50.92(c) and it has been determined that the proposed change involves no significant hazards considerations. The Plant Operations Review and Safety Review Committees have reviewed and accepted the proposed 1 change based on the evaluation mentioned above.

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Technical Specification Change Request NPF-38-176 W3F1-96-0006 Page 2 February 6,1996 Waterford 3 requests that the implementation date for this change be within 60 days of NRC issuance of the amendment to allow for distribution and procedural revisions necessary to implement this change.

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

Very truly yours, s

- R.P. Barkhurst Vice President, Operations Waterford 3 RPB/PLC/ssf

Attachment:

Affidavit NPF-38-176 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

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UNITED STATES OF AMERICA I

NUCLEAR REGULATORY COMMISSION in the matter of )

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

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-38-176; 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.

U R.P. Barkhurst Vice President Operations - Waterford 3 ,

1 STATE OF LOUISlANA )

) ss PARISH OF ST. CHARLES )

Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this 6" day of F sa rzu Aa1 .1996.

beu E . U L ,

Notary Public My Commission expires uiTH tieo

i DESCRIPTION AND SAFETY ANALYSIS ' l OF PROPOSED CHANGE NPF-38-176  ;

This proposed change modifies the TS to correct several inconsistencies.

The proposed change will amend the Allowable Values of parameters in Table 3.3-4 to be consistent with the identical parameters in Table 2.2-1 as approved in Amendment 113. The proposed change will add Mode 4 to the surveillance requirements of Table 4.3-2 Item 5.c (Safety injection System Automatic Actuation Logic) that was inadvertently removed. Finally, the proposed change removes a reference to TS 3.3.3.2 in Surveillance Requirements TS 4.10.2.2 and 4.10.4.2. TS 3.3.3.2 incore -

Detectors _has since been removed from the TS. These proposed changes are purely administrative in nature.

i Existina Specification See Attachment A Proposed Specification See Attachment B l l

Description l By letter dated December 9,1994, Waterford 3 proposed a change, that in part, modified the TS by revising several Allowable Values for parameters identified on Table 2.2-1 " Reactor Protective Instrumentation Trip Setpoint Limits." These values were reviewed, approved and issued as part of License Amendment 113. The proposed change failed to identify the duplicate parameters and values appearing on Table 3.3-4 " Engineered Safety Features Actuation System Instrumentation Trip Values" such that the TS is now in conflict. On Table 3.3-4 the Allowable Values for the following parameters are modified to be consistent with Table 2.2-1:

Old Value New Value Containment Pressure - High s 17.3 psia s 17.4 psia Pressurizer Pressure - Low 21644 psia 21649.7 psia Steam Generator Pressure - Low 2 748 psia 2 749.9 psia Steam Generator Level - Low 2 26.7 % 2 26.48%

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~ l This error was discovered as a result of the Waterford 3 Corrective Action Program. l Administrative controls are currently in effect that implement the more conservative of the two values.

License Amendment No.107 modified the TS by removing the incore Detection System Requirements specified in TS 3.3.3.2. Surveillance Requirements TS 4.10.2.2 and TS 4.10.4.2 of section 3/4.10 Special Test Exceptions, makes reference to the Incore Detection System and TS 3.3.3.2. The reference to the incore Detection System.

is appropriate and retained. The proposed change deletes reference to 3.3.3.2.  ;

I By letter dated December 18,1991 Waterford 3 proposed a change to extend the -

surveillance interval for the Engineered Safety Features Actuation System (ESFAS) initiation relays. The proposed change inappropriately deleted Mode 4 from the specified surveillance requirements of TS Table 4.3-2 Item 5.c (which is also inconsistent with TS Table 3.3-3 that continues to specify Mode 4 applicability). This I change was never intended to change the applicable Mode requirement. The proposed change was approved by Amendment 78. Waterford 3 has continued to  ;

ensure that the surveillance requirements for Table 4.3-2 Item 5.c are met prior to entry into Mode 4. This proposed change adds Mode 4 to TS Table 4.3-2 Item 5.c. l

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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? 1 Response: No The proposed changes described herein are administrative changes necessary to correct administrative errors. The proposed changes will have no i affect on any design basis accidents nor will these changes affect any material condition of the plant. Therefore, the proposed changes will not involve a j significant increase in the probability or consequences of any accident .

previously evaluated. j 2

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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 l previously evaluated?

l Response: No.

The proposed changes are purely administrative. There are no new system or design changes associated with this proposal. 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 have no impact on any protective boundary, safety limit, or margin to safety. The proposed change corrects inconsistencies in the TS and is purely administrative in nature. 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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