ML20101A798

TS Change Request NPF-38-124 to License NPF-38,changing TS Section 6.0, Administrative Controls, Re Crack Surveillance of Basemat Monitoring Program

ML20101A798
Person / Time
Site:	Waterford
Issue date:	04/24/1992
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20101A801	List: ML20101A798 ML20101A802
References
W3F192-0026, W3F192-26, NUDOCS 9204300347
Download: ML20101A798 (5)

Text

l 3GBbh i W Ent:rgy gipvyrau=x Operations - . -

i i4 ? D-i a :J1 R. P. Barkhurst

--1  ;

W3F192-0026 A4.05 QA April 24, 1992 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-38-124 Gentlemen:

Entergy Operations Incorporated, is a requesting a change to the Waterford 3 Technical Specifications section 6.0 " Administrative Controls". This site specific administrat've change concerns the crack surveillance of the Basemat Monitoring Program and is being submitted to accurately reflect currently approved program requirements.

Should you have any questiens or comments on this matter, please contact-Paul Caropino at (504) 739-6692.

Vory truly yours, RPB/PLC/dc

Attachment:

Affidavit NPF-38-124 cc: R.D. Martin, NRC Region IV D.L. Wigginton, NRC-NRR R.B. McGehee

.N.S. Reynolds NRC Resident Inspectors Office Admin!.strator Radiation Protectic7 Division (State of ,

Iouisiana) l American Nuclear Insurers

'.2 i 1

I phk DO K O O g2 [00/

e .- Its

. l UNITED STATFS OF AMERICA NUCLEAR REGULATORY COMMISSION -

In thr aatter of )

)

Entergy 01 irations, 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 Tcchnical Specification Change Request NPF-38-124; 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.

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

) ss PARISH OF ST. CIIARLES )

Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this 2.'1'78, day of A P c6L- , 1992.

-~

kN N Notary Public My Commission expires v iTN LiFL ,

DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CIIANGE NPF-38-124 The proposed change affects Technical Specification 6.8.4.e(4)

"Basemat Monitoring Program" b removing reference to " adjacent walls" from the crack surveillance.

Existino Snecifications See Attachment A Proposed SDecificationg See Attachment B Descriution Technical Specification 6.8.4.e provides the requirements for the L Waterford 3 Basemat sionitoring Program. The requested change l revises item 4 by removing the wall crack surveillance. This plant specific change is necessary to reflect the current NRC approved program.

L The Basemat Monitoring Program resulted from License Condition j 2.C.17 which required Waterford 3 to initiate a survaillance program and perform confirmatory analyais to establish the adequacy of the common foundation basemat. This license condition was satisfied as documented in the NRC's Safety and Technical Evaluation Reports / letter dated October 27, 1987.

Waterford 3 submittal dated June 26, 1987 provided Revision 1 to the Basemat Monitoring Program which was accepted by the staff as documented'in the Technical Evaluation Report listed above. This submittal discussed in detail the wall crack surveillance which j consisted of a photographic survey, of the lower portion of the Shield Building and selected exterior walls-in the east and west cooling tower areas. The analysis stated that the survey would continue for_two additional cycles (based on 18 month curveillance intervals) and then the survey would be discontinued provided no significant changes were noted. By letter dated I

January 26, 1990 Waterford 3 informed the staff that the photographic survey had been dincontinued in accordance with the approved program.

Safety Ana?vsis 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

l. Will operction of tho fccility in cccordenco with thia proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: No The Confirmatory Analysis demonstrated that the wall cracks were insignificant and that no correlation was found between the wall crscks and the basemat cracks. Based on the above no design basis accidents are affected. Therefore, the proposed change will not involve a significant increase in the probability of consequ eces of any accident previously evaluated.

2. Hill operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Responses Nc I Cracks in the basemat wall have been determined l insignificant. The proposed change will not modify or change the plant in any way nor will it alter the operation or the manner in which the plant is operated. Therefore, the proposed change will not create the possibility of a new cr different hind 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 j

of saiety?

! Responsa: No Eliminating the wall crack surveillance in justified by the current program requirements. Thus, no adverse impact on the protective boundaries, safety limits or margin to safety exists. Thereforc, the proposed change will-not involve a significant reduction in a margin of safety.

"The Commission has provided guidance concerning the application of standards for determining whether a significant hazards consideration existe by providing certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazards considerations. This proposal most cloeoly resembles example (f):

(i) A purely administrative change to technical specifications, (i.e., a change to achieve consistency through the technical specifications, correction of an f arror, or a change in nomenclature) ;

i . Safety and Sianificant Hazards Determination t

" 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 2

l

!- *: ressenablo accurenco that- tho hsalth cnd cafoty of ths public -

will not-be-endangered by_the proposed change:-and'(3)-this-

=

action will-not result in=a: condition:which significantly alters thei-impact lof the station-en the. environment-as described'in the NRC--final environmental statement."

k 9

e o

5 l

a 3

.= _ . _ - - - - - - . - . . .: