ML20115G282

Application for Amend to License NPF-38,consisting of TS Change Request NPF-38-127,revising Radiation Monitoring Instrumentation of Table 3.3-6 by Providing Distinction Between CCW Radiation Monitors & Altering Action Statement

ML20115G282
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
ML20115G285	List: ML20115G282 ML20115G290
References
W3F192-0088, W3F192-88, NUDOCS 9210260077
Download: ML20115G282 (7)

Text

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____. $ntergy g'gr y a ~.'a-Operations u~ u =

'ir S h 73:sfXG1 1- R. P. Darkhurat

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cw W.r.*J J W3F192-0088 A4.05 QA Oct ober 21, 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-38-127-Gentlemon:

The attached description and safety analysis supports a modification to the Waterford 3 Technical Specifications. The change affects the Radiation Monitoring Instrumentation of Table 3.3-6 by providing distinction between the component Cooling Water radiation monitors and altering the applicability and action statement associated wjth these monftors.

As discussed in the attachment Entergy Operations, Incorporated-feels that these site spocific changes will clarify the specified requirements and preclude difficulties currently experienced by plant personnel.

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

Very truly yours, 3L R.P. Barkhurst Vice President, Operations Waterford 3 RPB/PLC/dc Attachmentt Affidavit NPF-38-127 l cc J.L. Milhoan (NRC Region IV), D.L. Wigginton (NRC-NRR)',

L- R.B. McGehee, N.S. Reynolds, NRC Resident-Inspectors office, Administrator Radiation Protection Division (State c : Louisiana), American' Nuclear Insurers 1230000 =2iO260077.y2102, DR 'ADOCK 06000382-d) i l PDR

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UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMMISSION In the matter of )

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-Entorgy Operations, Incorporated ) Docket No. 50-382 Waterford 3 Stean Electric Station )

AFFIDAVIT R.P. Darkhurst, 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-38-127; that he is familiar witn the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

YW Q R.P. Darkhurst Vice President operations - Watorford 3 STATE OF LOUISIANA )

) ss PARIS!! OF ST. CHARLES )

Subscribed and sworn to before me, a Notary Public in and for the Parish and acate above named this 2 /" day of ac.ro M C , 1992. ,

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_ __T/m f. /s /v, Notary Public My Comminaion expires cv<T- c'" _.

DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-127 Technical Specification 3/4.3.3 " Radiation Monitoring Instrumentation" proscribos the operability requiromonts for the radiation monitoring instruments shown on Table 3.3-6. Items 2d and 20 of this table provido the specified limits for throo Component Cooling Water System (CCWS) radiation monitoring instrumentation channels. In ordor to easily distinguish the instrument monitors, itets 2d and 20 havo been revised to indicate " Monitors A & B" and " Monitor A/B" respectively. The applicability requiremont for item 20 (Monitor A/B) has been changed from All MODES to MODES 1 through 4 due to operational difficulties as a result of reduced CCW flow. Identical changes have boon made to Table 4.3-3 " Radiation Monitoring Instrumentation Surveillanco Requirements". In addition action statomont number 28 was modified to include the Special Report critoria of Specification 6.9.2.

Existina Soecification-Soo Attachment A Procosed Soccification Soo Attachment D Backaround This proposed technica) specification (TS) change was prompted by the following (1) Periodic difficulty in ascertaining what CCW monitors the speciflod requirements apply to due-to the inadoquate instrument description in the TS, and (2) Operational difficulties associated with CCW monitor A/B. This instrument monitors CCW on the return line from containment. During refueling this line is isolated at the containment to facilitate refueling activities. The flow in the CCW return line is reduced during this modo such that the differential pressure across the monitor samplo line tap is insufficient to create an adequate sample flow. This results in having to declare the monitor-inoperable and enter the associate 6 action which requires sampling and analysis. On September 24, 1992, an eight hour sample was missed resulting in LER 92-011. The following description and safety analysis justify relaxing the operability requirements for CCW radiation monitor A/B. In addition, Table l 3.3-6 ACTION STATEMENT 28 was observed to be incomplete and therefore modified to provide clarification.

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f DescriD112D l The CCWS is a closed loop cooling water system that supplios cooling to plant systems And components. During normal, ,

snutdown, and refueling operating conditions two operating CCW pumps are connected on the pump suction and discharge, to common hradors serving safety and non-safety equipment by means of ossantial, non-essential, and non-essential non-seismic loops.

Each loop or vices specified equipment and radiation monitoring is provided to detect leakage into the system from components that may contain radioactivity. A continuously operating radiation monitor is provided in each of the redundant headers on tho discharge side of the CCW pumps. These monitors (CCW Honitor e A and CCW Monitor D) are the safety related instruments specified on Table 3.3-6 item 2d. A third non-safety related monitor is provided on the return line from containment in the nonessential seismically qualified loop. This instrument (item 2e CCW Monitor A/B) monitors the cooling water from the components insido the containment (i.e., the four reactor coolant pump seals and motor control clamont drive mechanism (CEDM) coolors).

The purpose of this radiation monitor is to provide early detection of Reactor Coolant System (RCS) leakage from the Ranctor Coolant Pump (RCP) seals The current specification  ;

requires thib monitor to be operable during ALL MODES of operation. Waterford 3 proposos to revise this requirement to exclude Mode 5 Cold Shutdown and Modo 6 Refueling, due to reduced RCS pressure and reduced CCW flow. In mode 5 reactor coolant pressure is far lower, resulting in lower stressou and reduced potential for RCP seal leakago. In Mode 6 CCW flow through the non-essential seismically qualified loop is reduced and isolated at the containment to facilitate refueling operations (i.e., CEDM disassembly and containment isolation valve-testing). Tha reduced flow does not allow for maintaining a continuous fluid .

sampla for CCW monitor Afd and poses operability problems. While it is possible t'it the RCP seals could leak during Mode 5 depressurization, any leakage would still be identified by the two continuous CCW radiation monitors A and D.

In addition component cooling water pressure and temperature is monitored at each of the reactor coolant pump seal. water outlate.

A high temperature or pressure signal annunciates an alarm in the control room with high temperature actuating automatic isolation of the affected RCP soal cooler.

Based on x..e above, we feel that relaxing the applicability requirements for CCW monitor A/B is justified and will poso no threat to safety.

Tablu 3.3-6 7.CTION STATEMENT numbcr 28 states "With the number of channels OPERABLE less than rr. quired by the Minimum Channels OPERABLE requirements, operation of the plant may continue for up to 30 days provided grab samples are taken once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and l 2 i..,..- . , , . .- - . -n -,c - - ~ ~ n v-- ---n-nn~_- - <- ~

these samples are analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

This action statement applies to the three CCW monitors described earlier and item 2C Steam Generator Blowdown (SBG) Monitor.

Action 28 was evaluated and determined to be incomplete as there is no direction provided should operability not be restored within 30 days. Therefore, action 28 was modified to include the following statement: "If the monitor is not restored to OPERABLE status within 30 days after the failure, continue sampling and prepare and submit a special Report to the Commission pursuant to Specification 6.9.2 witnin 14 days outlining the action taken, the caune of the inoperability and the plans and schedule for restoring the system to OPERABLE status". Imposing the special report criteria'of u.9.2 is sinilar to other radiation monitor remedial action requirements such as those required by Generic Letter 83-37, "HUREG 0737 - Technical Specifications." The special report vill ensure that in the unlikely event that these monitors are out of service beyond 30 days a schedule for returning the monitor to service will be established and submitted to the staff. The CCW and SGB radiation monitors are procers monitors that serve a primary function to provide for early detection of radioactivity leakage into normally nonradioactive systems, including primary-to-secor:dary leakage.

These monitors are not effluent monitors and serve no isolation function but rather perform a surveillance function. Therefore, continuation of the alternate sampling technique is appropriate and consistent with similar specified requirements.

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 any accident previously evaluated?

Responses No.

Removing the operability requirements for modes 5 and 6 from CCW radiation monitor A/B will have no affect on accidents previously evaluated. The purpose of the monitor is to detect RCS leakage from the RCP seals.

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Early detection of RCs seal leakage is provided by monitoring CCW pressure and temperature at each RCP seal cooler water outlet. A high temperature or pressure signal will cause an alarm in the control room and high temperature also actuates automatic isolation of the affected RCP seal cooler. In addition, radiation detection will continue to be performed by CCW radiation monitors A and D.

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The clarification of ACTION 28 has no affect on accidents previously evaluated. The current TS requires grab samples to be taken once por eight hours and analyzed for grcos activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> should one of the affected l instrumentation monitoring channels OPERABLE be loss than required. Adding the Special Roport critoria of 6.9.2 is consistant with the guidelines provido for other process monitors in Gonoric Lottor 83-37, "NUREG-0737 - "ochnical Specifications."

Adding " Monitors A and B" to item 2d and " Monitor A/D" to item 20 is purely administrative in nature and is intended to clarify the srocifications.

The radiation monitors affected by this proposed change are designed to provido early detection of radioactive leakage into normally nonradioactivo systems. Those monitors do not serve to isolato and provent a radioactive release to an unprotected area. No design basis accidents are affected by those changos. Thorofore, the proposed change will not involve a significant increase in the probability or consequences of any accident previously evaluated.

2. Will operation of the facility in accordance with this proposed chango create the possibility of a now or different kind of accident from any accident previously evaluated?

Responses No.

The proposed chango does not introduce any now or different equipment and it will not result in installed equipment being operated in a now or different manner. The chango will allow one less ccw monitor during cold 'hutdown and refueling modos due to reduced RCS pressure mad CCW flow while maintaining system integrity with two continuous radiation monitoring instruments. Adding the Special Report critoria to ACTION 28 completos this action statement in a l

manner similar to other requirements associated with process radiation monitors. Adding " Monitors A and B" to item 2d i

and " Monitor A/B" to item 20 is purely administrativo in L nature and is intended to clarify the specificationo, l Thorofore, the pr^ posed changos will not create the possibility of a now or different kind of' accident trom any accident previously evaluated.

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

Response: No.

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The proposed cbsngo completos ACTION 28 by allowing continued llant operation beyond 30 days provided the Special Roport critoria of 6.9.2 is complitd with. The change will heva no adverso impact on the protective boundarios, safety limits or margin of safety. The margin of satety associated with CCW radiation monitors and RCP seal leakage is established in FSAR Subsection 5.2 5.1.5.

This analysis only tc%es credit for rafety related CCW radiation monitors A and B and does not tako credit for CCW radiation monitor A/B. Adding "Mositors A and B" to item 2d and " Monitor A/B" te item 20 is purely administrative in nature ar*! is intended to clarify the epocifications. j Thorofore, the proposed chango will not involve a significant reduction in a margin of safety.

The Commission has provided guidanco concerning the application of standards for datormining whether a significant hazards considoration exists by providing certain exar.plos (48 FR 14870) of amoddments that are considered not likely to involve ,

significant hazards considerations. The changos identified in '

this submittal closoly match oxamplo (1). I (1) A purely administrativo chango to technical specifications (i.e., a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclaturo);

Although the proposed change inc1.udos a relaxed applicability requiremont, we fool the chango clearly

, accounts for plant conditions not previously considered and l thorofore in administrative in nature.

Safety and Sionificant Hazards Datormination Based on the above Safety Analysis, it is concluded thatt (1) the proposed changes do not constituto 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 ondangered by the propo:ed changes; and (3) this action will not result in a conditlan that significantly altors the impact of the station on the environment an desciibed in the j NRC Final Environmental Statomont.

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