ML20137Z456

Safety Evaluation Supporting Amend 126 to License NPF-38

ML20137Z456
Person / Time
Site:	Waterford
Issue date:	04/21/1997
From:	NRC (Affiliation Not Assigned)
To:
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ML20137Z443	List: ML20137Z456
References
GL-93-05, GL-93-5, GL-94-01, GL-94-1, NUDOCS 9704240172
Download: ML20137Z456 (8)

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g SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.126TO FACILITY OPERATING LICENSE NO. NPF-38 ENTERGY OPERATIONS. INC.

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

1.0 INTRODUCTION

By application dated November 7,1995, as supplemented by letters dated July 17, and December 26, 1996, and February 27, March 14, April 7, and April 17, 1997, Entergy Operations, Inc. (the licensee), submitted a request for changes to the Waterford Steam Electric Station, Unit 3, Technical Specifications (TSs). The requested changes would revise TS 3/4.8.1,

" Electrical Power Systems - A.C. Sources." The purpose of the proposed changes is to incorporate recommendations and suggestions from (1) Generic Letter (GL) 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operations;" (2) GL 94-01,

" Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators from Plant Technical Specifications;" and (3) NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants."

The July 17, and December 26, 1996, and April 7, and April 17, 1997, letters provided clarifying information that did not change the initial proposed no siginficant hazards consideration determination.

February 27, and March 14, 1997, letters withdrew some of the changes requested concerning emergency diesel generator fuel discussed in previous submittals.

2.0 BACKGROUND

On September 27, 1993, NRC issued GL 93-05.

In this letter, NRC identified j

changes to TS 3/4.8.1 that would allow licensees to reduce the amount of surveillance testing required during power operations. NRC found that by reducing the amount of TS required surveillance testing during power operations, safety could be improved, equipment degradation decreased, and an unnecessary burden on personnel resources eliminated.

GL 94-01 was issued on May 31, 1994, in response to the Commission decision on SECY-93-044, " Resolution of Generic Safety Issue B-56, ' Diesel Generator Reliability'." This GL advised licensees that they could request a license amendment to remove accelerated testing and special reporting requirements for emergency diesel generators from plant TS.

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. NUREG-1432 documents the positions of NRC on Standard Technical Specifications for Combustion Engineering plants proposed by the Combustion Engineering Owners Group.

i 3.0 DISCUSSION AND EVALUATION Chanae 1 (TS 3.8.1.1. Action a): The licensee proposes to delete "If either i

diesel generator has not been successfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, demonstrate its OPERABILITY by performing Surveillance Requirement 4.8.1.1.2a.4 separately for each diesel generator (unless it is already j

operating) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

This proposed change is in accordance with the recommendations provided in GL 93-05 and NUREG-1432. The recomendations contained in these documents allow the deletion of requirements to test emergency diesel generators (EDGs) i and other related support systems not associated with an inoperable offsite ac power circuit.

Because the inoperability of an offsite ac power circuit does not affect the reliability or performance of the EDGs, deleting this requirement is acceptable.

Chanae 2 (TS 3.8.1.1. Action b): The licensee proposes to (1) add "an inoperable support system, an independently testable component, or"; (2) change "24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" to "8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />"; and (3) add "unless the absence of any i

potential comon mode failure for the remaining diesel generator is demonstrated."

These proposed changes are in accordance with the recomendations provided in GL 93-05 and NUREG-1432. The recommendations contained in these documents allow the addition of testing exclusions that eliminate the need to test an EDG when the source of its inoperability originated in a support system or an independently testable component. The inoperability of a support system or an independently testable component does not reduce the reliability of an EDG to start once the effected support system or independently testable component is

- declared operable. The proposed changes would also eliminate the requirement to test an operable EDG as long as it can be demonstrated that there is no potential for a comon mode failure of the operable EDG, its support system, or its independently testable components. The changes proposed by the licensee are acceptable because they will not affect the reliability of the EDGs. Reducing the time the licensee has to perform SR 4.8.1.1.2a.4 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> if the potential for a comon failure mode does exists is a conservative change to the TS and is therefore, acceptable.

Chanae 3 (TS 3.8.1.1. Action c): The licensee proposes to (1) add "an inoperable support system, an independently testable component, or"; and (2) add "unless the absence of any potential comon mode failure for the remaining diesel generator is demonstrated."

These proposed changes are in accordance with the recomendations provided in GL 93-05 and NUREG-1432. The recommendations contained in these documents allow the addition of testing exclusions that eliminate the need to test an

i EDG when the source of its inoperability originated in a support system or an independently testable component. The inoperability of a support system or an independently testable component does not reduce the reliability of an EOG to start once the effected support system or independently testable component is

. declared operable. The proposed changes would also eliminate the requirement to test an operable EDG as long as it can be demonstrated that there is no potential for a common mode failure of the operable EDG, its support system, or its independently testable components. The changes proposed by the licensee are acceptable because they will not affect the reliability of the EDGs.

Chanae 4 (TS 3.8.1.1. Action e): The licensee proposes to delete " demonstrate the operability of two diesel generators by performing Surveillance Requi.rement 4.8.1.1.2a.4 separately for each diesel generator within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 4

unless the diesel generators are already operating;".

l This proposed change is in accordance with the recommendations provided in GL 93-05 and NUREG-1432. The recommendations contained in these documents allow the deletion of requirements to test emergency diesel generators (EDGs) and other related support systems not associated with an inoperable offsite ac power circuit.

Because the inoperability of an offsite ac power circuit does not affect the reliability or performance of the EDGs, deleting this requirement is acceptable.

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Chance 5 (TS 4.8.1.1.2a): The licensee proposes to (1) add "At least once per 31 days," and delete "In accordance with the frequency specified in Table 4.8.1."

These proposed changes are in accordance with the recommendations provided in GL 94-01 and are acceptable. The recommendations in this document allow the deletion of specific reporting requirements for EDG failures and accelerated testing requirements due to EDG failures. Because the licensee is required to monitor and maintain EDG performance in accordance with the provisions of 10.CFR 50.65, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," there is no longer a need to maintain these requirements in TS.

{hanae 6 (TS 4.8.1.1.2a.4): The licensee proposes to (1) delete "and accelerates to at least,600 rpm (60 1 1.2) in less than or equal to 10 seconds"; (2) add ". ; (3) add "at least 3920"; (4) delete "4160 + 420,

- 240"; (5) add "58.8"; (6) delete "60 1 1.2"; (7) add "The steady state voltage and frequency shall be maintained at 4160 + 420, -240 volts and 60 i,,1.2 Hz."; and (8) add the following note to the bottom of page 3/4 8-3:

" A modified diesel generator start involving idling and gradual acceleration to synchronous speed may be used for this surveillance requirement as recommended by the manufacturer. When modified start procedures are not used, i

the time, speed, voltage, and frequency tolerances of this surveillance must be met."

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The licensee has proposed changes to clarify when the timed start required by this TS is satisfied (generator voltage and frequency at least 3920 volts and 1-58.8 Hz within 10 seconds) and to allow the EDGs to be tested using slow j

starts during monthly surveillance testing. These proposed changes are in' l

accordance with NUREG-1432. The use of slow starts during monthly-surveillance testing is intended to improve the reliability and availability i

of the EDGs by reducing the unnecessary stress and wear caused by fast starts.

In lieu of a time constraint in the surveillance requirement, the licensee will monitor and trend the actual time needed to reach steady state operation l

in order to ensure there is no voltage regulator or governor degradation which 1

could cause the diesel generator to become inoperable. Deleting the 600 rpm reference is acceptable because it is redundant to the frequency reference, j

and the existing steady state voltage and frequency requirements have been moved to a new sentence. These proposed changes are acceptable because they l

are intended to clarify the requirements of the TS and to improve the reliability and availability of the EDGs.

Chanae 7 (TS 4.8.1.1.2a.5):

The licensee proposes to (1) replace j

" synchronized (10 seconds), subsequentjy" loaded to an indicated 4200-4400 Kw,

.in less than or equal to 176 seconds, with " synchronized, loaded to an i

indicated 4000-4400 Kw in accordance with the manufacturer's recommenda-tj*ons"; (2) delete the following note at the bottom of TS page 3/4 8-4:

" The diesel generator fast loading requirement (176 sec) shall be performed 4

at least once per 184 days in these surveillance tests.

For all other surveillance tests, load the diesel generator at a rcte consistent with the manufacturer's recommendations."; (3) add the following note at the bottom of j

the page 3/4 8-4:

"This surveillance requirement shall be proceeded by and immediately follow without shutdown a successful performance of 4.8.1.1.2a.4 or 4.8.1.1.2d and (4) add new surveillance requirement, TS 4.8.1.1.2d, which reads "At least once per 184 days a diesel generator fast start test shall be performed in accordance with TS 4.8.1.1.2a.4.

Performance of the 184 day fast start test satisfies the 31 day testing requirements specified in TS l.

4.8.1.1.2a.4."

These proposed changes are in accordance with the recommendations in GL 93-05 and NUREG-1432. These proposed changes will revise the loading range of the EDGs, delete the requirement to perform a fast loading test, and add a i

requirement to perform a fast start test of the EDGs once every 184 days in a i

new TS 4.8.1.1.2d.

The revised loading range of the EDGs is intended to avoid inadvertent overloading of the EDGs.

Because industry experience has shown that EDGs that operate properly when tested at 90 percent of their continuous j

design ratings will also operate properly at 100 percent of their design ratings, and because avoiding inadvertent overloads increases the reliability of EDGs, these proposed changes are acceptable. Deletion of the fast loading I

requirement is acceptable because NRC has determined that this test did not provide useful information about the ability of an EDG to perform its safety function.

Performance of fast start test of EDG once per every 184 days is j

recommended by the staff.

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d Chance 8 (TS 4.8.1.1.2c):

This request was withdrawn by February 27, 1997 letter.

Chanae 9 (TS 4.8.1.1.2d.1):

The licensee proposes to delete "(HPSI pump)."

The licensee has proposed to eliminate the words "(HPSI pump)" so that alternate methods of rejecting a load ;t 498 kW may be used to satisfy the requirements of this TS surveillance.

Because there is no decrease in the amount of load (real or reactive) to be rejected by the alternate testing methods proposed by the licensee, this change is acceptable.

Chanae 10 (TS 4.8.1.1.2d.2):

The licensee proposes to add "an indicated 4000."

This proposed change is in accordance with the recommendations in GL 93-05 and i

NUREG-1432. This proposed change will revise the loading range of the EDGs and is intended to avoid inadvertent overloading of the EDGs.

Because industry experience has shown that EDGs that operate properly when tested at 90 percent of their continues design ratings will also operate properly at 100 percent of their design ratings, and because avoiding inadvertent overloads increases the reliability of EDGs, the proposed change is acceptable.

Chanae 11 (TS 4.8.1.1.2d.3a): The licensee proposes to delete "# SEE NOTE" related to startup until refuel 7.

This proposed change is acceptable because the note is no longer applicable.

Chance 12 (TS 4.8.1.1.2d.3b): The licensee proposes (1) to replace "with" with "and the"; and (2) to delete "# SEE NOTE" related to startup until refuel 7.

4 These proposed changes are acceptable because they are editorial and the note is no longer applicable.

Chanae 13 (TS 4.8.1.1.2d.5a): The licensee proposes to delete "# SEE NOTE" related to startup until refuel 7.

This proposed change is acceptable because the note is no longer applicable.

Chanae 14 (TS 4.8.1.1.2d.5b): The licensee proposes (1) to replace "with" j

with "and the"; (2) to delete "# SEE NOTE"; and (3) to delete the following note at the bottom of page 3/4 8-6:

"# NOTE: UNTIL STARTUP FOLLOWING REFUEL 7 In lieu of the prescribed integrated tests (i.e., actual demonstration of shedding, connection, and loading of loads) testing and analysis that shows the capability of the diesel generator to perform these functions will be considered acceptable for train AB A.C. ESF busses. This provision will apply to the associated train AB ESF loads with the exception of Motor Control Center 3AB311 S that has been verified acceptable via analysis."

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t These ptc.;,osed changes are acceptable because they are editorial and the note is no longer applicable.

Chanae 15 (TS 4.8.1.1.2d.6): The licensee proposes (1) to delete "at least";

(2) to add "an interval of not less than"; (3) to delete "the first"; (4) to delete "the remaining"; (5) to replace "4200" with "4000"; (6) to ne,, place "4.8.1.1.2.d.3b" with "4.8.1.1.2.a.4"; and (7) to replace in the "

note at the bottom of page 3/4 8-6 "4.8.1.1.2d.3b" with "4.8.1.1.2.a.4", "4200" with "4000", and "I hour" with "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />".

These proposed changes are consistent with the recommendations in GL 93-05 and NUREG-1432.

Deleting the requirement to perform the 2-hour loading test at the begining of the 24-hour run test is acceptable because the current industry practice of pre-warming and slowly loading diesel generators to reduce diesel generator stress and wear and to increase inacnire reliability has eliminated the rational for performing the 2-hour loading test during the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the run test. Operating the diesel generator for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> instead of I hour if SR 4.8.1.1.2.a.4 is not satisfactorily completed is intended to ensure machine internal operating temperr.tures have stabilized.

These proposed changes are acceptable because they are either (1) administra-tive and intended to clarify the TS or (2) intended to increase the reliability of the EDGs by eliminating unnecessary stress and wear of the EDGs 1

during surveillance testing.

1 Chanae 16 (TS 4.8.1.1.2d.7):

The licensee proposes to add "and permanently connected loads."

This proposed change is acceptable because it is an administrative change intended to clarify the requirement of this TS.

Chance 17 (TS 4.8.1.1.2f): The licensee proposes to delete "*" and to add "t."

j This change is acceptable because it will correct an administrative error i

inadvertently incorporated into an earlier licensing amendment.

Chanae 18 (TS 4.8.1.1.2a.1):

Licensee withdrew this change.by March 14, 1997, letter.

l Chanae 19 (TS 4.8.1.1.2a.2):

Licensee withdrew this change by March 14, 1997, letter.

Chanae 20 (TS 4.8.1.1.2h):

Licensee withdrew this change by March 14, 1997, letter.

Chance 21 (TS 4.8.1.1.3):

The licensee proposes (1) to add "(Not Used)"; (2) to delete "All diesel generator failures, valid or nonvalid, shall be reported in a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days.

Reports of diesel generator failures shall include the information recommended in Regulatory Position C.3.b of Regulatory Guide 1.108,

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Revision 1, August 1977.

If the number of failures in the last 20 or 100 starts (on a per diesel generator basis) exceeds the criteria in Table 4.8-1, take the appropriate action specified in Table 4.8-la and attachments 3

thereto."; (3) to delete all the information in Table 4.8-1 and the s

attachments to this table; and (4) to add the notation "Not Used" in this j

table.

These proposed changes are in accordance with the recomendations provided in GL 94-01 and are acceptable. The recomendations in this document allow the j

deletion of specific reporting requirements for EDG failures and accelerated testing requirements due to EDG failures.

Because the licensee is required to monitor and maintain EDG performance in accordance with the provisions of 10 CFR 50.65, " Monitoring the Effectiveness of Maintenance at Nuclear Power j

Plants," there is no longer a need to maintain these requirements in TS.

l Chance 22 (Proposed TS 6.8.4.h): Licensee withdrew this change by February 4

27, 1997, letter.

Chanae 23 (Bases Section): The licensee has proposed changes to the Bases Section (Page B 3/4 8-2) to clairify the changes evaluated above. The proposed changes in Bases Section were reviewed and are acceptable.

Chanae 24 (Editorial Chanaes): Addition of SR 4.8.1.1.2d required renumbering the subsequent requirements. These are strictly editorial changes and they are acceptable.

Based on the above evaluation the staff concludes that the changes proposed by the licensee are acceptable because (1) they are intended to improve the reliability and availability of the EDGs or (2) they are administrative and intended to clarify the TS.

4.0 STATE CONSULTATION

In accordance with the Comission's regulations, the Louisiana. State official was notified of the proposed issuance of the amendment. The State official had no coments.

5.0 ENVIRONMENTAL CONSIDERATION

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 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 individual or cumulative occupational radiation exposure. The Comission has previously issued a pro-posed finding that the amendment involves no significant hazards consideratian and there has been no public coment on such finding (61 FR 180).

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

, i 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:

V. Beaston Date: April 21, 1997 I

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