ML20115G180

Application for Amend to License NPF-38,consisting of TS Change Request NPF-38-129,revising Required Value of Steam Supply Pressure for turbine-driven Emergency Feedwater Pump Surveillance Test in TS 4.7.1.2.a.1

ML20115G180
Person / Time
Site:	Waterford
Issue date:	10/21/1992
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20115G184	List: ML20115G180 ML20115G193
References
W3F192-0332, W3F192-332, NUDOCS 9210260048
Download: ML20115G180 (7)

Text

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R. P. Barkhurst ~

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A4.05 i QA October 21, 1992 3

U.S. Nuclea'r Regulatory Commission

• l Attn: Document Control Desk Washington, D.C. 20555 j l

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Technical Specification Changc Request NPF-38-129 Gentlemen: ]

The attached des ription _ and safety analysis supports a proposed Technical-Specification (TS) change to revise the required value of the stedm. supply pressure for the Waterford 3 turbine-driven emergency feedwater _-(EFW). pump surveillance-test as specified in TS 4.7.1.2.a.1. - This_ change also rewords- the -

specification to clarify that the required secondary steam -supply-pressure > 1s steam generator pressure.

The' proposed change is very similar to that approved by the staff for Arkansas-Nuclear One-Unit No. 2 (Docket No, 50-313, Amendment' Request dated ' August 4, -

1992).

In order to decrease steam generator corrosion and- increase steam' generav useful life, cs discussed in the August 19, 1992 aeeting with the staff, upor.

completion of Reftel 5 Waterford 3 is planning to operate at a ' reduced hot leg-temperature value. Reducing nominal operating reactor coolant' system- (RCS)-

temperature (referred to as "T-hot Reduction") would-reduce _ the propensity for -

stress corrosion cracking and inter-granular attack of the steam generator Alloy

>600 U-tubes. Waterford-3 TS 3.2.6 requires RCS cold leg' temperature (T-cold)_ to -

be maintained between 544*F and 558'F. Nominal RCS temperature atJ100% power through tfm end -of cycle 5 is currently at a T-cold of 553*F and a T-hot of 611*F. Thus a Tl hot reduction of approximately 8*F can be' accommodated without a Technical Specification change. However, reducing hot leg temperatures will result in a secondary steam supply pressure that is belcw the value specified for-surveillance testing of the turbine-driven EFW pump. To perform the current surveillance, Waterford 3 would be required to reduce plant load or raise hot ' leg-

- temperature to raise secondary steam supply pressure to the.specified value.

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, e U.S. Nuclear Regulatory Commission Technical Specification Change Request NPF-38-129 W3F192-0332 Page 2 October 21, 1992 Currently the EFW pump test is scheduled to coincide with the power reduction-associated with turbine valve and CEA testing (TS 4.3.4.2 and 4.1.2.1.2). Ycar timely review is requested, however, to allow greater flexibility in scheduling these surveillances.

Should you have ar.y questions or comments on this matt <3r. please contact Paul Caropino at (504) 739-6692.

Very truly yours,

) wt t A).

R.P, Sarkhurst Vice President, Operations RPB/PLC/dc l

Attachment:

Affidavit l NPF-38-129 cc: J.L. Milhcan (NRC Region IV)

D.L. Wigginton (NRC-NRR)

R.C. McGehee N.S. Reynolds NRC Resident Inspectors Office Administrator Radiation Protection Division (State of Louisiana)

American Nuclear Insurers l

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f UNITED STATES OF AMERICA f1VCLEAR REGULATORY COMMISSIn" In the matter of- )

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Entergy Operations, Incorporated ) Docket No. 5'-382 Wate-ford 3 Steam Electric Station )

AFFIDAyll R.P. Barkhurst, being culy sworn, hereby deposes and says that he is Vice Pres-: dent Operations - Waterford 3 of Entergy Operations, Incorporated; thd %6 is duly autharized to sign and file with the Nuclear Regulatory Connissit: she attached Technical Specification Change Request NPF-38-129; that he is fami:Mr with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

AA t^ V IT1.h 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 2 f 'd day of Oc r o rs ut. , 1992.

. S fN- ? D 5l %

Notary Public My Convaission expires w,ra c < rs ,

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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38 129 The proposed change revises the value of the secondary steam supply pressure ,

specified in Technical- Specification 4.7.1.2.a.1 from " greater than 880 psig" to

" greater than 750 psig". This change also rewords TS 4.7.1.2.a.1 such that

" secondary steam supply pressure" is now ' steam generator pressure".

Existina SpeH fi utian Sne Attachment A Proposed Soecificat WD See Attachment B Dercriotion TS 4.7.1.2.a.,1 requires verification that the turbine-driven emergency feedwater pump develop a discharge pressure of greater than or equal to 1342 psig on recirculation flow when the secondary steam supply pressure is greater than 880 psig. The :; team-driven emergency feedwater pump is capable of delivering a total flow of 700 gpm at a pressure of 1163 psig to the entrance of the steam generators. This capacity is sufficient to ensure that adequate feedwater flow l is available to remove decay neat and reduce the Reactor Coolant System i temperature to less than 350"F at which point the shutdown cooling system may be j placed into operation.

The surveillance requirement to verify the minimum pump discharge pressure on recirculation flow ensures that the pump performance curve has not degraded below-that used to show that the pump meets the above flow requirements.

1 The current Waterford 3 TS deviate from the Combustion Engineering Standard l Technical Specifications (NUREG 0212) by omitting verification of flow rate.

l This is due to an orifice in the puma recirculation lines which controls flow l

such that it is not subjeci to varyation. Therefore, this requirement was o removed prior to original TS issuance. l The planned reduction in hot leg temperature will result in a secondary steam I supply pressure that is below the value specified (880 psig) for surveillance l testing of the turbine-driven EFW pump.

In order to meet the specified secondary steam supply pressure in the existing l specification, Waterford 3 would be required to raise hot leg temperature or reduce plar.t load until ' secondary steam supply pressure exceeded 880 psig, perform the surveillance test, and then reduce hot leg temperature or increas-plant load until the desired plant condition is achieved. Waterford 3.has currently scheduled EFW turbine pump testing to coincide with the power reduction l associated with turbine valve and CEA testing imposed by technical specifications

4.3.4.2 and 4.1.3.1.2. This will allow n asting the EFW pump at the currant specified secondary steam supply press . .owever, this may create scheduling 1

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• 0 difficulties.- Implementing this change results in a specified secondary steam )

- supply pressure that is lower than the nominal steam generator pressure at reduced hot leg temperature conditions, and allows surveillance testing of _the J turbine-driven EFW pump in a stable reduced hot leg temperature condition.

The pump curves for the turbine-driven EFW pump indicate that a discharge pressure of 1342 psig requires a power of 300 bhp at a speed of 4400 rpm.- The turbine driver expected performance curve shows that a steam inlet pressure of 150 psia available to the trip and thr7ttle valve. of the tt'rbine driver is sufficient to develop 300 bhp. At a secondary steam supply pressure of 750 psig .

the steam pressure at the turbine driver inlet owill greatly excced 150 psia.

Therefore,- the proposed reduction -in required secondary steam supply pressure will not affect the turbine-driven EFW pump's capability to deliver the required flowrate and discharge pressure curing operation. The turbine-driven EFW pump is designed for startup from a cold condition, and will cperate with steam pressure ranging from 1135 psig to 50 psig.

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 the proposed change involve a si;nificant increasa in the probability or consequences of any accident previously evalutted?

Response: No The accident mitigation features of the plant are not .affected by the proposed amendment. No modification has been made to the pump or turbine driver. The specified value of . discharge pressure for.. surveillance.

testing of the turbine-driven EFW pump remains unchanged. The capability.

of the turbine-driven EFW pump to perform its required function is not. '

impacted by this change. Design specifications- show that the turbine--

driven EFW pump is capable of delivering required flowrate and discharge l' pressure for existing plant conditions applicable to a secondary steam supply pressure range of 50 to 1135 psig. The chaage specifying steam generator pressure as the secondary steam supply prc

:t're is purely adu.inistrative in nature and is intended to clarify the specifications.

Therefore, the proposed change will not involve a significant increase i-i the probabilitj or consequences cf any accident previously evaluated.

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

Response: No No rew possibility for an accident is introduced by modifying the specifications for the surveillance testing of the turbine-driven EFW pump. The serveillance will continue to demonstrate the pump's ability to perform its safety function. The specified value of discharge pressure for the surveillance test remains unchanged. Design specifications show that the turbine-driven EFW pump is capable of delivering required flowrate and discharge pressure for existing plant conditions applicsble to a ::econdary steam supply pressure range of 50 to 1135 psig. The change specifying steam generator pressure as the secondary steam supply pressure is purely administrative in nature and is intended to clari fy the specifications.

Therefore, the proposed change will not create the possibility of a new or different kind of accident from any previously evaluated. ,

3. Will operation of the facility in accordance with this proposed change involve a significant reduction in the margin of safety?

Response: No lhe safety function of the turbine-driven EFW pump is not altered as a result of this change. The pump's required discharge pressure is not revised as a retult of this change to secnndary steam supply pressure.

Design specifications show that the turbine-driven EFW pump is capable of delivering required flowrate and discharge pressure for existing plant conditions applicable to a secondary steam supp'y pressure range of 50 to 1135 psig. The change specifying steam generator pressure as the secondary steam supply pressure is purely administrative in nature and is -

intended to clarify the specification.

Therefore, the propcsed 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 exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to i nvolve significant hazards considerations. The proposal most closely resembles example (1):

A purely administrative change to technical specifications, (i.e., a change to achieve consistency throughout the technical specifications, corrective of an error, or a change in nomenclature);

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Safety and Sianificant Hazar(s Determination j 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 reason:ble 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

'environmeist as described in the NRC final environmental statement".

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