ML20137G471
| ML20137G471 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/27/1997 |
| From: | Dugger C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20137G477 | List: |
| References | |
| W3F1-97-0054, W3F1-97-54, NUDOCS 9704010403 | |
| Download: ML20137G471 (9) | |
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EntIrgy Operstlons,Inc.
O Po. sox e Kittona, LA 70066-0751 Tel 504 739 E60 i
Charles M. Dugger
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nt. Operanons W3F1-97-0054 i
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March 27,1997 1
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
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Technical Specification Change Request NPF-38-192 Gentlemen:
The attached description and safety analysis support a change to the Waterford 3 Technical Specifications. The proposed change modifies Specification 3/4.5.2, "ECCS Subsystems Modes 1,2, and 3." The proposed change adds a surveillance requirement to verify the ECCS piping is full of water at least once per 31 days. A change to the Technical Specification Basis 3/4.5.2 and 3/4.5.3 has been included to support this change.
This proposed change has been evaluated in accordance with 10CFR50.91(a)(1),
using the criteria in 10CFR50.92(c), and it has been determined that this request involves no significant hazards consideration.
This proposed change is based on the ECCS Specification in NUREG 1432,
" Standard Technical Specifications - Combustion Engineering Plants".
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i Technical Specification Change Request NPF-38-192 l
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The circumstances surrounding this change do not meet the NRC's criteria for -
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exigent or emergency review. However, due to the significant impact on plant operations, we respectfully requet,t an expeditious review. Entergy Operations l
requests the effective date for this change be within 60 days of approval.
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t Please note that Technical Specification Change Request NPF-38-191 also requesting changes to Technical Specification 3/4.5.2 and its bases has been submitted under separate letter, W3F1-97-0053.
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Should you have any questions or comments concerning this request, please contact P.L. Caropino at (504) 739-6692.
Very truly yours, I
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C.M. Dugger Vice President, Operations
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Waterford 3 l
CMD/DBM/ssf i
Attachment:
Affidavit NPF-38-192 cc:
E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR R.B. McGehee N.S. Reynolds NRC Resident inspectors Office Administrator Radiation Protection Division (State of Louisiana)
American Nuclear Insurers 3
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION in the matter of
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Entergy Operations, incorporated
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Docket No. 50-382 Waterford 3 Steam Electric Station
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AFFIDAVIT Charles Marshall Dugger, 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-38-192; 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.
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/ W WW Charles Marshall Dugger 01 Vice President Operations - Waterford 3 t
STATE OF LOUISIANA
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Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this G" day of M R4Lc>+
,1997.
J hebkb Notary Public
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My Commission expires L~ '" F E-i
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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-192 i
The proposed change requests a change to Technical Specification 3/4.5.2, "ECCS Subsystems - Modes 1,2, and 3." The proposed change adds a surveillance i
requirement to verify the ECCS piping is full of water at least once per 31 days. A i
change to the TS Basis 3/4.5.2 and 3/4.5.3 has been included to support this change.
l Existina Specification i
See Attachment A-Proposed Specification
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See Attachment B l
Backaround i
During the original licensing of Waterford 3 it was noted that the Refueling Water Storage Pool (RWSP) is higher than the ECCS piping and therefore it was assumed I
that no air could enter the system unless maintenance or draining of the system j
occurred. Based on this assumption, the surveillance requirement for venting the j
system on a monthly basis was omitted from the original Waterford 3 Technical Specifications. A surveillance requirement to vent the system following maintenance or i
draining was included in the original Technical Specifications.
Events in December 1996 and January 1997, documented in Condition Reports 96-1965 and 97-0200, have revealed that small pockets of gas (voids) are accumulating in the Low Pressure Safety injection (LPSI) system piping at the containment penetrations. Operability evaluations were performed following the discovery of the voids during each of the December and January events. The voids were the result of nitrogen gas coming out of solution once nitrogen laden water contained in the Safety injection Tanks leaked back past the inboard containment isolation check valves.
These evaluations determined that the LPSI system was operable for the existing conditions. Based on the results of these evaluations, Waterford 3 has established administrative controls to monitor the LPSI piping for voids using ultra-sonic examination methods and initiated work authorization packages to install vents. Vents were not provided in this portion of the LPSI piping during the original Waterford 3-i design. Continuing difficulties in eliminating these voids have resulted in the decision to install vents in this portion of the LPSI piping during Refueling Outage (RFO) 8.
Similar events have not been identified in the High Pressure Safety injection (HPSI) system. However, due to similar piping configurations, vents will also be added to the j
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Description This submittal requests a change to Technical Specification 3/4.5.2, "ECCS Subsystems - Modes 1,2, and 3." The proposed change adds a surveillance requirement to verify the ECCS piping is full of water at least once per 31 days. A change to the TS Basis 3/4.5.2 and 3/4.5.3 has been included to support this change.
The ECCS or Safety injection System (SI) is not an individual system but is comprised of the following three separate subsystems:
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The High Pressure Safety injection System (HPSI)
The Low Pressure Safety injection System (LPSI)
The Safety injection Tanks (SITS)
The components of these subsystems are arranged in two redundant trains, each of which is capable of performing 100 percent of the systems design requirements j
following any accident. Each train is capable of being powered from both normal and j
emergency power supplies to ensure their operability under all conditions.
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i The SI system is designed to operate following a LOCA. The Si system is activated by the Safety injection Actuation Signal (SIAS) which is initiated by either low pressurizer pressure or high containment pressure. The SlAS automatically starts the HPSI and LPSI pumps and opens the motor operated valves that provide a flow path from the
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discharge of these pumps to the RCS. The HPSI and LPSI pumps initially take suction from the Refueling Water Storage Pool (RWSP) and deliver borated water to the RCS for the removal of heat generated in the reactor core. When a low level is sensed in l
the RWSP, the recirculation mode is initiated by the Recirculation Actuation Signal (RAS). At this time the HPSI pump suction is diverted to the Safety injection Sump and the LPSI pumps are stopped.
When RCS pressure drops below the SIT cover pressure, the four SITS automatically discharge their contents into the RCS. This independent phase of operation does not rely on operator action or an electrical signal. Check valves inside containment isolate the SITS from the rest of the ECCS systems. From the Si flow control valves outside containment the Si piping rises before entering the containment penetrations forming local piping high points at the containment penetrations. When the SITS are pressurized, nitrogen laden water may leak past the check valves inside containment (within Technical Specification limits) and depressurize allowing the nitrogen to come out of solution forming nitrogen gas pockets at the local piping high point.
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t In addition to its accident related functions, portions of the Safety injection System are utilized as part of the Shutdown Cooling System which is used to remove heat from the t
RCS during normal plant cool down and to maintain the RCS below 140*F during refueling mode During RFO 8, vents will be installed in both the LPSI and HPSI systems. The LPSI f
vents will provide the capability to remove the nitrogen voids from the local LPSI piping high point at the containment penetrations. The new one inch vent lines and valves will be installed ASME safety class 2, seismic 1 and meet the requirements of General l
Design Criteria 55 of 10CFR50 Appendix A. The vent valves will be locked closed and be placed under administrative controls. The design and installation of the LPSI vent lines and valves have been evaluated under 10CFR50.59. This evaluation determined that no unreviewed safety question exists and the margin to safety as defined in the Safety Analysis Report and Technical Specification bases will not be reduced. The HPSI vent lines and valves will also be evaluated under 10CFR50.59 when their design is finalized.
The proposed change to Technical Specification 3/4.5.2 will verify that the ECCS is filled with water at least once per 31 days. Verifying the ECCS is full of water at least once per 31 days will minimize the likelihood of a pressure transient occurring during system startup and provide increased assurance that the ECCS will perform its design basis function when needed. This surveillance requirement and frequency are based on the ECCS Sp,>cification in NUREG 1432, " Standard Technical Specifications -
Combustion Engineering Plants".
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:-
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Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
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Response
No The proposed change will not affect the assumptions, design parameters, or -
results of any accident previously evaluated. The proposed change does not add or modify any existing equipment. The proposed change adds a new surveillance requirement which will minimize the likelihood of a pressure transient occurring during system startup and provide increased assurance that 3
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the ECCS will perform its design basis function when needed. The new LPSI 4
and HPSI vent valves which may be manipulated during this surveillance will be i
administratively controlled and will be locked close when not in use to prevent j
the possibility of a flow diversion. This surveillance requirement is consistent with NUREG 1432.
Therefore, the proposed change will not involve a significant increase in the probability or consequences of any accident previously evaluated.
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Will operation of the facility in accordance with this proposed change create the possibility of a new or difforent type of accident from any accident previousiv evaluated?
Response
No.
t While new vent lines are being installed under iOCFR50.59, this proposed l
change adds only a new surveillance requirement to Technical Specification i
3/4.5.2 and therefore does not involve modifications to any existing equipment.
The new vent valves, when required, will be operated and controlled in the same manner as existing LPSI and HPSI vent valves. The new LPSI and HPSI vent
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valves will be administratively controlled and will be locked close when not in i
use. This surveillance requirement is consistent with NUREG 1432.
l Therefore, the proposed change will not create the possibility of a new or j
different kind of accident from any accident previously evaluated..
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Will operation of the facility in accordance with this proposed change involve a i
. significant reduction in a margin of safety?
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Response
No The functionality of ECCS is maintained such that it is capable of performing its design function as assumed in the Updated Final Safety Analysis Report.
Verifying the ECCS is full of water at least once per 31 days will minimize the likelihood of a pressure transient occurring during system startup and provide increased assurance that the ECCS will perform its design basis function when 4-needed. This surveillance requirement is consistent with NUREG 1432.
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Therefore, the proposed change will not involve a significant reduction
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in a margin of safety.
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Safety and Sianificant Hazards Determination Based on the above safety analysis, it is concluded that: (1) the proposed change does not constitute a significant hazards consideration as defined by 10CFR50.92; and 1
(2) there is a reasonable 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 environment as described in I
the NRC final environmental statement.
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i NPF-38-192 ATTACHMENT A l
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