ML20137R939

Safety Evaluation Supporting Amend 124 to License NPF-38

ML20137R939
Person / Time
Site:	Waterford
Issue date:	04/10/1997
From:	NRC (Affiliation Not Assigned)
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ML20137R936	List: ML20137R931 ML20137R939
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NUDOCS 9704140302
Download: ML20137R939 (6)

Text

7 UNITED STATES y

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NUCLCAR REGULATORY COMMISSION WA$MINGTON, D.C. 30seH001

• s.,...../e SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.124 TO FACILITY OPERATING LICENSE NC. NPF-38 ENTERGY OPERATIONS. INC.

I WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382

1.0 INTRODUCTION

On September 12, 1995, the U.S. Nuclear Regulatory Commission (NRC) approved issuance of a revision to 10 CFR Part 50, Appendix J, " Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors" which was subsequently published in the Federal Reaister on September 26, 1995, and became effective on October 26, 1995. The NRC added Option B, " Performance-Based Requirements," to allow licensees to voluntarily replace the prescriptive testing requirements of 10 CFR Part 50, Appendix J, with testing requirements based on both overa71 performance and the performance of i

individual components.

By application dated Decc..ber 2,1996 as supplemented by letters dated February 4 and March 14, 1997, Entergy Operations, Inc. (the licensee),

submitted a request for changes to the Waterford Steam Electric Station, Unit 3 (WAT-3), Technical Specifications (TSs). 'The proposed TS changes would i

permit implementation of 10 CFR Part 50, Appendix J, Option B, and reference Regulatory G91de (RG) 1.163, " Performance-Based Containment Leak Test Program," dated September 1995, which specifies a method acceptable to the NRC 4

for complying with Option B.

The February 4 and March 14, 1997, letters provided clarifying information that did not change the initial proposed no siginficant hazards consideration determination.

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2.0 BACKGROUND

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Compliance with 10 CFR Part 50, Appendix J, provides assurance that the primary containment, including those syst:;o and components which penetrate the primary containment, do not excecd the allowable leakage rate specified in

'the TS and Bases. The allowable leakage rate is determined so that the 1eakage rate assumed in the safety analyses is not exceeded.

On February 4,1992, the NRC published a notice in the Federal Reaister (57 FR 4166) discussing a planned initiative to begin eliminating requirements 9704140302 970410 PDR ADOCK 05000382 i

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marginal to safety which impose a significant regulatory burden.

10 CFR Part 50, Appendix J, " Primary Containment Leakage Testing for Water-Cooled Power Reactors," was considered for this initiative and the staff undertook a study of possible changes to this regulation. The study examined the previous performance history of domestic containments and examined the effect on risk of a revision to the requirements of Appendix J.

The results of this study are reported in NUREG-1493, " Performance-Based Leak-Test Program".

Based on the results of this study, the staff developed a performance-based approach to containment leakage rate testing. On September 12, 1995, the NRC approved issuance of this revision to 10 CFR Part 50, Appendix J, which was subsequently published in the Federal Reaister on September 26, 1995, and became effective on October 26, 1995. The revision added Option B,

" Performance-Based Requirements" to Appendix J to allow licensees to voluntarily replace the prescriptive testing requirements of Appendix J with testing requirements based on both overall and individual component leakage rate performance.

j RG 1.163 was developed as a method acceptable to the NRC staff for implementing Option B.

This RG states that the Nuclear Energy Institute (NEI) guidance document NEI 94-01, Rev. O, " Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," provides methods acceptable to the NRC staff for complying with Option B with four exceptions which are described therein.

Option B requires that the RG or other implementation document used by a licensee to develop a performance-based leakage rate testing program must be included, by general reference, in the plant TS. The licensee has referenced RG 1.163 in the proposed WAT-3 TS.

RG 1.163 specifies an extension in Type A test frequency to at least one test in 10 years based upon two consecutive successful tests. Type B tests may be i

extended up to a maximum interval of 10 years based upon completion of two consecutive successful tests and Type C tests may be extended up to 5 years based on two consecutive successful tests.

By letter dated October 20, 1995, NEI proposed TS to implement Option B.

After some discussion, the staff and NEI agreed on final TS which were transmitted to NEI in a letter dated November 2, 1995.

These TS are to serve as a model for licensees to develop plant-specific TS in preparing amendment requests to implement Option B.

In order for a licensee to determine the performance of each component, factors that are indicative of or affect performance, such as an administrative leakage limit, must be established. The administrative limit is selected to be indicative of the potential onset of component degradation.

Although these limits are subject to NRC inspection to assure that they are selected in a reasonable manner, they are not TS requirements.

Failure to meet an administrative limit requires the licensee to return to the minimum value of the test interval,

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. Option B requires that the licensee maintain records to show that the criteria for Type A, B and C tests have been met.

In addition, the licensee must maintain comparisons of the performance of the overall containment system and the individual components to show that the test intervals are adequate. These records are subject to NRC inspection.

3.0 EVALUATION The licensee's December.2,1996, letter to the NRC proposes to establish a

" Primary Containment Leakage Rate Program" and proposes to add this program to the technical specifications. The program references RG 1.163 which specifies methods acceptable to the staff for complying with Option B.

This requires a change to TS 3/4.6.1.1, " Containment Integrity," 3/4.6.1.2, " Containment Leakagg," 3/4.6.1.3, " Containment Air Locks," 3/4.6.1.6, " Containment Vessel Structural Integrity," and 3/4.6.1.7, " Containment Ventilation System," and r

adds Specification 6.15, " Containment Leakage Rate Testing Program," to implement the performance-based leakage rate testing program as permitted by 10 CFR Part 50, Appendix J, Option B.

Option B permits a licensee to choose Type A; or Type B and C; or Type A, B and C; testing to be done on a performance basis. The licensee has elected to perform Type A, B and C testing on a performance basis.

The staff has reviewed the licensee's proposed TS changes and finds them t

consistent with the requirements of 10 CFR Part 50, Appendix J, Option B, in that the changes include general reference in the TS to the regulatory guide used by the licensee to develop the performance-based leakage-testing program for WAT-3. The staff has also compared the proposed TS with the model TS in the November 2,1995, letter to NEI, and finds them to be consistent with the intent of the model TS, with several exceptions, noted below.

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3.1 EXCEPTION TO THE MODEL TS GUIDANCE 1

3.1.1 Containment Intearity TS 3.6.1.1 action statement requires containment integrity to be restored within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The Model uses I hour, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

This difference is due to the Model being written to the Improved TS and the 4

licensee using the Standard TS. This is not a deviation from Option B, but a difference between the Standard TS and the Model TS. The licensee's ACTION is d

more conservative than the Model and is therefore, acceptable.

Surveillance Requirements (SRs) 4.6.1.1.a and 4.6.1.1.b are retained as these are requirements outside of Option B and should be retained in the TS. The annotation for SR 4.6.1.1.a is likewise applicable to the licensee's current format. While the proposed format is somewhat different from the Model, it preserves the structure of the current TS and is consistent with RG 1.163 and l

.is, therefore, acceptable.

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3.1.2 Containment Leakaae TS 3.6.1.2, action statement requires that with containment leakage rates not within limits, restore the leakage rates to within the limits " prior.to increasing the reactor coolant temperature above 200*F."

The licensee desires to maintain this wording, since most leak rate tests are performed while shutdown. Model TS 3.6.1.1 requires returning containment to operable condition within I hour, or placing the unit in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. While the Model TSs correct a deficiency in the current TS, which does not recognize that containment leakage rates can be determined during plant operation (Modes 1 through 4), keeping the current TSs ACTION is still adequately restrictive. This is because limiting condition for operation (LCO) 3.0.3 of the current TSs, which is entered when an ACTION of a particular TS cannot be entered because of circumstances in excess of those addressed in the TS, would apply if leakage were determined to be exceeded during plant operations.

LCO 3.0.3 requires initiating action within I hour to place the unit in hot standby in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in hot shutdown in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in cold shutdown within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The required actions in the licensee's current TSs are more conservative than the Model TSs, therefore, the proposed changes are acceptable.

Additionally, the specific value for bypass leakage has been moved to the Administrative Controls section of the TS, consistent with other specific values listed for containment leakage and air lock leakage.

3.1.3 Containment Air Locks TS 3.6.1.3, Containment Air Locks (which is TS 3.6.1.2 in the Model), is essentially equivalent to the Model, with changes due to differences in format and ACTION times between the licensee's current TS and the Model.

LCO 3.6.1.3.a is equivalent to Note 1 of the Model and also addresses normal entry and exit.

LCO 3.6.1.3.b defines operability as including overall air lock leakage for consistency with the current TS and is equivalent to the Model, which contains this as a SR. ACTION al and a2 are equivalent to the Model with only a format change to the licensee's current TS. ACTION a3 for a-containment air lock door is more conservative than that in the Model by 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ACTION a4 is retained consistent with License Amendment 99 (see Safety Evaluation Report dated September 20. 1994). ACTION b is more conservative than the Model by 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The SRs are the same as the Model with the exception of the seal leakage and overall leakage being two separate requirements. The Model has within TS 3.6.1.3 a Note to evaluate leak rate testing against the criteria applicable to TS 3.6.1.1, whereas the licensee's proposal references the requirements of TS 3.6.1.3 in SR 4.6.1.1.

The required actions and SRs in the licensee's TSs are either equivalent or more conservative than the Model TSs, therefore the proposed changes are acceptable.

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9 3.1.4 containment Vessel Structural Intearity SR 4.6.1.6, which requires visual examination of the accessible interior and exterior surfaces of containment is being revised to reference the Containment Leakage Rate Testing Program and delete the Special Report, which is no longer required by Option B.

Note that the reporting requirements of_10CFR50.72 and 10CFR50.73 are still applicable. While the proposed format is somewhat different than the Model TSs, it preserves the. structure of the current TSs and is consistent with RG 1.163, therefore, the proposed change is acceptable.

3.1.5 Containment Ventilation System "TS 3.6.1.7 for the containment purge isolation valves is contained in the Model as part of TS 3.6.1.3.

The differences between the licensee's proposal and the Model essentially involve special testing required after the

. performance of limited purges at power. This accounts for the licensee's requirements for verifying cumulative open time in SR 4.6.1.7.1 and mechanical stop position in the LCO and SR 4.6.1.7.3.

ACTION a is required for this capacity and therefore is being retained in the TS. ACTION b is more conservative than the Model in that the option of continuing to operate with excessive leakage by use of a deactivated valve has not been incorporated into the licensee's proposal. Additionally, the completion times for required actions in the licensee's proposal are more conservative by 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The required frequency of 3 months for SR 4.6.1.7.2 is being retained rather than adopting the frequency of 184 days or within 92 days of opening the valves as specified in the Model. Since the licensee's proposal maintains previously approved features, and either conforms to or is more conservative than the Model, the proposed change is acceptable.

3.1.6 Containment Leakaae Rate Testina Proaram The proposal for the Administrative Controls section of the licensee's TS was amended to add the limits for containment bypass leakage and containment purge valves with resilient seals.

These limits are in the current TS, and are merely being moved to the Administrative Controls consistent with other limits in the current TS and are, therefore, acceptable.

3.1.7 Containment Leakaae Bases The Bases'for TS 3/4.6.1.2 were modified to explain the leakage acceptance criteria and change the plant procedure number referenced for bypass leakage to the Technical Requirements Manual. - In addition, a reference to Option B of 10 CFR Part 50, Appendix J, and Regulatory Guide 1.163 were added for clarity.

- Although the licensee's current Bases contains significantly less information than the Model Bases the staff found the additional information added acceptable.

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j i 3.2 SUPMARY In summary, the staff has revhwed the changes to the TS and associated Bases proposed by the licensee and finds that they are in compliance with the requirements of Appendix J, Option B, and are consistent with the guidance of.

- Regulatory Guide 1.163, and finds them to be consistent with the intent of the model TS except as noted above, and are therefore, acceptable.

4.0 STATE CONSULTATION

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.

ENVIRONMENTAL CONSIDERATION 5.0 The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined 1

that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in indi' idual or cumulative v

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 (62 FR 2189). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 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 issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor:

T. Polich Date: April 10,1997 4

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