ML20114D150
| ML20114D150 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/25/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20114D142 | List: |
| References | |
| NUDOCS 9209040213 | |
| Download: ML20114D150 (4) | |
Text
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p LAFETY EVALU1110N SY THE OFFICE OF NGCLEAR RrACTOR REGULAJ10N RELATED TO AMEN 0 MENT NO. 75 TO
[ACILITY OPERATING LICENSE NO. NPF-38 ENTERGY OPERATIONS. INC2 WATERFORD.STE_AMlLECIRIC STATION. UNIT 3 DOCKET NO. 50-382
1.0 INTRODUCTION
By letter dated May 5, 1992, Entergy Operations, Inc. (the licensee) requested an amendment tc Facility Operating License No NPF-38 for Waterford Steam Electric Station, Unit 3.
The proposed amendment would iemove the technical specification (TS) tables that incluue lists of cc:.ponents referenced in individual specifications.
In addit'on, tl.0 TS requirements have been modified such that all references to these tables have been removed.
Finally, the TS have been modified to state requirements in general terms that i
ir.:1ude the components listed in the tables removed from the TS.
Guidance on the Proposed TS changes was provided by Generic Letter 91-08, dated Miy 6 1991.
2.0 f_VALUATIOJ The licensee has proposed the removal of Table 3.6-1, " Secondary Containment i
Bypass Leakage Paths," that is referenced in TS 3.6.1.2.
With the removal of this table, the licensee has proposed to modify the limiting condit'.on for operation (LCO) on containment leakage rates to state the limit specified by TS 3.6.1.2.c as the following:
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i A combined leakage rate of less than or equal tv 0.06 L for all penetrations that are secondary containment bypos; leak, age patas when pressurized to Pa.
The licensee has proposed the removal of Table 3.6-2, " Containment Isolation Valves." that is referenced in TS 3/4.6.3.
With the removal of this table, the licensee has proposed to include th! following stetement of the LCO under TS 3.6.3:
f Each containment isolation valve shall be OPERABLE.
In addition, the licensee has revised the Jcfinition of Containment Integrity, TS 4.6.1.1, the action requirements under TS 3.6.3, and TS 4.6.3.1 through 4.6.3.3 to remove all references to Table 3.6-2.
The definition of Contain-ment Integrity and TS 4.6.1.1 refer to TS 3.6.3 for an exception that is now covered by a footnote to the LCO rather than by the table removed from the TS.
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- With the removal of the reference to Table 3.6-2, the licensee has proposed to state this exception as:
...., except for valves.h:.t ce open under administratim control as permitted by Spc'.fication 3.6.3.
The surveillance requirements of TS 4.6.3.1 through 4.6,3.3 have been revised to statu "Each containment isolation shall..." or "..
each power-operat ad or automatic containment isolation valu shall..." rather than stating the requirements in relation to the <alves specified in Table 3.6-2.
Because Table 3.6-2 notes that the provisions of Specification 3.0.4 are not applic-able to specific valves, the following statement has been added to the LCO for TS 3.6.3:
The provisions of Specification 3.0.4 do not apply.
This is a change in the application of this exception, from specific valves to all containment isolation valves, and i*., acceptable because it is consistent with the guidance provided in Generi: Letter 87-09 and as noted in Generic Letter 91-08.
The table of cuntainment isolation valves identified specific manually-operated locked or sealed closed valves with a footnote stating that these valves may be cuened on an intermittent basis under administrative control.
These valves are locked or sealed closed consistent with the regulatory requirements for manually-operated valves that are used as containment isola-tion valves. Because opening these valves would be contrary to the operability requirements of these valves, the following_ footnote to the LC0 has been proposed:
Locned or sealed closed valves may be opened on an intermittent basis under administrative control.
This change is consistent with the guidance in Generic Letter 91-08 and is, therefore, acceptable.
The licensee has proposed the removal of Table 3.8-1, " Containment Penetration Conductor Overcurrent Protective Devices" that is referenced in TS 3/4.8;4.
3 With the removal of this table, the licensee has proposed to include the following statement for the LC0 under TS 3.8.4.1:
I Primary and backup containment penetration conductor overcurrent protective devices associated with each containment electrical penetration circuit shall be OPERABLE.
The scope of these protective devices excludes those for which credible fault currents would not exceed the electrical penetration design rating.
In addition, the licensee has proposed to revise TT 3,3 4.1 to remove the ref-erence to Table 3.8-1.
The surveillance requireme!.c h been revised to state the followina:
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, The above noted primary and backup containment penetration conductor overcurrent protective devices shall be demonstrated OPERABLE:
The licensee has proposed to replace the reference to Table 3.8-1 in the surveillance requirements of TS 4.8.4.1.a.2 to state " Testing of these circuit i
breakers, except for those breakers with external protective relays *, shall
.... The licensee has proposed, and by letter dated July 23, 1992 revised, the related footnote to state "* Testing of these circuit breakers (i.e., the l
480 volts power from low voltage switchgear) shall be performed in accordance l
with the manufacturer's recommendations." Since the revision to the original l
proposed footnote is a clarification of wording and represer.ts no change in testing or procedures, it does not affect the original No Significant Hazards i
consider 2'. ion.
The licensee has proposed the removal of Table 3.8-2, ' Motor-0perated Valves lhermal Overload Protection," that provides a list of valves with bypass devi-ces that is referenced in TS 3.8.4.2.
With the removal of this table, the licensee has proposed to include the following statement of the LCO under TS 3.8.4.2:
The thermal overload protection and bypass devices, integral with the motor starter, of each valve used in safety systems shall be OPERABLE.
l The licensee has proposed changes to the above TS that are consistent with the i
guidance provided in Generic totter 91-08.
In addition, the licensee has pro-l vided an updated copy of Bases Section of TS 3.6.3 that addresses appropriate l
considerations for opening locked or sealed closed valves on an intermittent basis.
Finally, the licensee has confirmed that component lists removed from l
the TS have been updated to identify all co.nponents for which the TS-require-l ments apply and are located in controlled plant procedures.
On the basis of its review of this matter, the staff finds that the proposed l
changes to the TS for Waterford Steam Electric Station, Unit 3 are primarily l
an administrative change that ooes not alter the requirements set forth in the existing TS.
However, the applicability of the operability requirements will extend to all containment isolation valves as noted in this evaluation.
Overall, these changes will allow the licensee to make corrections and updates to the list of components for which these TS requirements apply, under the provisions that control changes to plant procedures as specified in the Administrative Controls Section of the TS.
Therefore, the staff finds that the proposed TS changes are act.eptable.
3.0 STATE CONS])LTATION In accordance with the Commission's regulations, the Louisiana State official was notified of the proposed issuance of the amendment. The State official had no comments.
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>FI 4.0 ENilRORMENTAL CONSIDERATION The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 ard changes in surveillance requirements.
The NRC staff has determined that the amendment involves no significant increase in the anounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (57 FR 30248). Accordingly, the amendment meets the eligibility criteria for categurical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact ststement or environmental assessment need be prepared in connection with the issuance of the amendment.
5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuar.ce of the amencment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
Thomas G. Dunning, OTSB Howard J. Rathbun, PD-IV-1 Date: August 25, 1992 a
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