ML20128G129

TS Change Request NPF-38-131 to License NPF-38,revising Applicability of TS Section 3.0 & 4.0 of STS Per Recommendations in GL 87-09, Sections 3.0 & 4.0 of STS on Applicability of LCO & Sr

ML20128G129
Person / Time
Site:	Waterford
Issue date:	02/09/1993
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20128G134	List: ML20128G129 ML20128G135
References
GL-87-09, GL-87-9, W3F1-92-0476, W3F1-92-476, NUDOCS 9302120162
Download: ML20128G129 (5)

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W3ft-92-0476 A4.05 QA i february 9, 1993 U.S. Nuclear Regulatory Commission- (i ATTH: Document Control Desk Washington, D.C. 20555  ;

Subject:

Waterford 3 SES .

Docket No. 50-382 License No. NPF-38 Technical Specification Change Request NPT-38-131 Gentlement Please find attached Technical Specification Change Request NPF-38-131.

The proposed change would revise the appilcability of Technical

. Specification Sections 3.0 and 4.0 in accordance with the recommendations

" Sections 3.0 and 4.0 of the Standard Technical of Generic Letter Specifications (STSD87-09, on t he Applicability of Limiting Conditions for Operation and Survelliance Requirements."

Should you have any questions or comments on this matter, please feel free-to contact T.W. Gates at. (504) 739-0697.

Very truly.yours,

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8 u Vice President, Operations Waterford 3 RPD/TWG/ssf Attachments: Affidavit-NPF-38-131 cc J.L. Milhoan (NRC Region IV), D.L. Wigginton (NRC-NRR),

N.S. Reynolds, R.B. McGehee, NRC Resident. Inspectors Office, Administrator Radiation Protection Division (State of Louisiana), American Nuclear Insurers L

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

Entergy Operations, Incorporated Docket No. 50-382 ,

Waterford 3 Steam Electric Station -

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. AfrIDAVIT 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 Raquest NPF-38-131; 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, f n OVUJb 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 ?.he Parish and State above named this 9 " day of F C 6 a v A <t y , 1593.

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. i.ii i DESCRIP110N AND SAFETY ANALYSIS Of PROPOSE 0 CHANGE-NPf-38-131 This is a request to revise Technical Specification Sections 3.0 and 4.0, Limiting Conditions for Operation and Surveillance Requirements.

Existing Specifications See Attachment A Proposed Specifications

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See Attachment B Description Generic Letter 87-09 dated June 4, 1987 encouraged licensee submittal of changes to Sections 3.0 and 4.0 of the Technical Specifications on the applicability of limiting conditions for operation and surveillance requirements. Specifically, the generic letter addressed three problems encountered in applying the criteria of Sections 3.0 and 4.0:

1. Specification 3.0.4 places unnecessary restrictions on modo changes and leads-to inconsistent application of-exceptions to its

.equirements,

2. When surveillance intervals are inadvertently exceeded, Specification 4.0.3 can lead to unnecessary shutdowns, and-

3. Conflicts between Specifications 4.0.3 and 4.0.4 could prevent-passage through-or to operational-modes as required to comply with Action requirements, or lead to plant shutdowns when an exception-to Specification 4._0.4 is allowed but the appropriate Surveillance Requirements are not performed within the allowed surveillance interval.

In resolving these problems Generic Letter 87-09 provided acceptable changes to Technical Specifications 3.0.4, 4.0.3, and 4.0.4. 11he generic 1ctter recommended changes have been adopted verbatim in the-proposed changes of Attachment .B with the single exception of the basis for Specification 4.0.2.-

In that particular case, the Waterford 3' Technical Specification is' in accordance with the recommendations'of NRC Generic Letter 89-14, incorporated as Amendmerit- 62 to the operating license.

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With respect to Technical Specification 3.0.4, Attachment 1 to Generic letter 87-09 contains the following discussion:

"As a consequence of the modification described above to Specification 3.0.4, individual specifications with Action Requirements permitting continued operation no longer need to indicate that Specification 3.0.4 does not apply. They should be revised to delete the noted txception to avoid confusion about the applicability of Specification 3.0.4.

However, except. ions to Specification 3.0.4 should not be deleted for individual specifications if a mode change would be precluded by Specification 3.0.4 as revised. for example, some specifications would not satisfy the provisions under which mode changes are permitted by the revision to Specification 3.0.4 and, therefore, the exception to Specification 3.0.4 need not be deleted. It is not the staff's intent that the revision of Specification 3.0.4 should result in more restrictive requirements for individual specifications."

The Waterford 3 Technical Specifications were reviewed to identify those specifications which contained an exception to Specification 3.0.4 whose Action Statement permitted continued operation of the plant for an unlimited period of time. In accordance with the guidance of Generic letter 87-09 the exception to Specification 3.0.4 contained in the following Technical Specifications is proposed for deletion:

3.3.3.2 -

Incore Detectors 3.3.3.3 -

Seismic instrumentation 3.3.3.4 -

Meteorological instrumentation 3.3.3.7.1 -

Chlorine detection system 3.3.3.7.3 -

Broad range gas detection 3.3.3.9 -

Loose-part detection instrumentation 3.3.3.11 -

Explosive Gas Monitoring System 3.4.9 -

Structural integrity 3.7.9 -

Scaled source contamination 3.9.7 -

Crane travel - fuel handling building 3.9.9 -

Containment purge valve isolation system 3.9.12 -

fuel handling building ventilation system 3.11.1.4 -

Liquid holdup tanks 3.11.2.5 -

Explosive gas mixture 3.11.2.6 -

Gas storage tanks Safety Analysis Generic Letter 87-09 presents a detailed review of the safety significance of the proposed changes to Technical Specifications 3.0.4, 4.0.3 and 4.0.4. The staff has concluded that the changes as proposed are acceptable and do not require additional review. Therefore, no significant hazards consideration exists.

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The proposed changes to delete exceptions to Specification 3.0.4, in lechnical Specifications which allow continued operation of the plant for an unlimited  ;

-period of time, are administrative changes directed by Generic tetter 87 09. i The proposed change to Specification 3.0.4 is such that the-deleted exceptions Li continue to apply.

, Safety and Signif f cant flazards Detennination Based on the above Safety Analysis, it is concluded that (1)theproposed }

changes do not constitute a significant hatards consideration as defined by 10CIR50.92; (2) there is a reasonabic assurance that the health and safety.of the public will not be endangered by the proposed changes; and (3) this action-will not result in a condition which significantly alters the impact of the .i station of' the environment as described in the NRC lInal Environmental j Statement.

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