ML20141K161
| ML20141K161 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/24/1997 |
| From: | Dugger C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20141K164 | List: |
| References | |
| W3F1-97-0123, W3F1-97-123, NUDOCS 9705280349 | |
| Download: ML20141K161 (7) | |
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Entirgy Opers.tions, Inc.
j P.O Box B i
Killona, LA 70066-0751 Tel 504 739 6G60 Charles M. Dugger j
<cs dent, orwations W3F1-97-0123 A4.05 PR May 24,1997 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-362 License No. NPF-38 Technical Specification Change Request NPF-38-196 Gentlemen:
The attached description and safety analysis support a change to the Waterford 3 Technical Specifications. The proposed change modifies Specifications 3.1.1.1, 3.1.1.2,3.10.1 and Figure 3.1-1 by removing the cycle dependent boron concentration and boration flow rate from the Action Statements and removing the
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"RWSP at 1720 ppm" curve from the figure. A change to Technical Specification Basis 3/4.1.1.1 and 3/4.1.1.2 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.
Precautiens are in place to ensure adequate Shutdown Margin, during all Modes of operation, whye this Technical Specification Change Request is being raviewed.
However, Entergy Operations respectfully requests an expedited review of the i
proposed change. Entergy Operations requests the effective date for this change be within 30 days of approval.
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Technical Specification Change Request NPF-38-196 W3F1-97-0123 Page 2 May 24,1997 Should you have a.1y questions or comments concerning this request, please contact Mr. Early Ewing at (504)739-6242.
Very truly yours, C M. Dugger Vice President, Operations Waterford 3 CMD/DBM/ssf
Attachment:
Affidavit NPF-38-196 cc:
E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR J. Smith N.S. Reynolds NRC Resident inspectors Office Administrator Radiation Protection Division (State of Louisiana)
American Nuclear insurers
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION in the matter of
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Entergy Operations, inwrporated
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Dccket No. 50-382 Waterford 3 Steam Electric Station
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i 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 Commiss,'on the attached Technical Specification Change Request NPF-38-196; 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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Charles Marshall Dugger Vice President Operations - Waterford 3 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 2 WI day of e>*
.1997.
d rY c J]Y Notary Public My Commissior, expires dM
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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-196 i
The proposed change requests a change to Technical Specifications (TS) 3.1.1.1, i
3.1.1.2,3.10.1 and Figure 3.1-1 to remove the cycle dependent boron concentration i
i and boration flow rate from the Action Statements and remove the "RWSP at 1720 ppm" curve from the figure.
i Existina Specification i
See Attachment A Proposed Specification I
l See Attachment B l
l' Backaround l
j Shutdown Margin is the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:
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- a. No change in part-length Control Element Assembly (CEA) position, and
- b. All full-length control element assemblies (shutdown and regulating) are fully
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. iriserted except for the single assembly of highest reactivity worth which is l
assumed to be fully withdrawn.
Shutdown Margin is used to ensure that the reactor can be made subcritical from all 4
j operating conditions, transients, and design basis events; the reactivity transients l
associated with postulated accident conditions are controllable within acceptable limits; 1
and the reactor will be maintained sufficiently suberitical to preclude inadvertent criticality in the shutdown condition.
I Shutdown Margin requirements vary throughout core life. The most restrictive t
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condition occurs at End of Life (EOL) with a postulated steam line break accident and d
the resulting uncontrolled Reactor Coolant System (RCS) cooldown. As T w l'
decreases, the potential RCS cooldown and the resulting reactivity transient are less severe. Below 200 *F, the inadvertent boron dilution event becomes limiting with 1
respect to the Shutdown Margin requirements. Additional events considered, to ensure adequate Shutdown Margin,' include an uncontrolled CEA withdrawal from subcritical or low power conditions, inadvertent startup of a reactor coolant pump, and a CEA ejection. The analyses of these events provide the Shutdown Margin requirement curves that are maintained in the Core Operating Limits Report (COLR).
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The cycle specific boron numbers that satisfy the Shutdown Margin requirements are provided every cycle by the Physics Data Book. The Physics Data Book is a set of l
curves that are developed based on the cycle core loading and take into account fuel reactivity depletion and RCS temperature.
The proposed change to the Action Statements of Technical Specifications 3.1.1.1, 3.1.1.2,3.10.1 and Figure 3.1-1 and associated Bases is being made to ensure that the Shutdown Margin requirements of the Cycle 9 COLR figures are maintained. In addition, this change is consistent with the intent of NUREG 1432, Standard Technical Specifications - Combustion Engineering Plants.
Descriotion j
The proposed change eliminates the reference to the cycle dependent boron 4
concentration and boration flow rate from the Action Statements of Technical Specifications 3.1.1.1, 3.1.1.2, and 3.10.1 and directs the operator to take immediate j
action to restore the required Shutdown Margin to within limits. This proposed change j
also removes the "RWSP at 1720 ppm" curve from Figure 3.1-1. The associated Bases i
has been expanded to provide additional clarification.
J The required amount of Shutdown Margin is determined by the safety analyses j
performed every cycle for the new core design (i.e., the Reload Analysis). The Cycle 9 Reload Analysis has determined that the current Shutdown Margin requirements described in the COLR are acceptable for Cycle 9 operation. The boron numbers that satisfy the Shutdown Margin requirements are generated each cycle based on the Reload Analysis and fuel reactivity depletion and are provided in the Physics Data i
Book. To ensure an adequate Shutdown Margin, the Cycle 9 Physics Data Book conservatively requires a boron concentration of 1833 ppm with all CEAs inserted and 2027 ppm with any CEA withdrawn at the beginning of cycle.
The current Technical Specification Action Statements require the operator to immediately initiate and continue boration at greater than or equal to 40 gpm of a solution containing greater than or equal to 1720 ppm boron. Based on the Cycle 9 Physics Data Book, boration at 1720 ppm would not be sufficient to ensure that the Shutdown Margin requirements are satisfied at the beginning of Cycle 9. ? !s important to note that Technical Specification Change Request NPF-38-189, whb. was submitted in February, increases the minimum required boron concentration for the Refueling Water Storage Pool (RWSP) and the Safety injection Tanks (SITS) from 1720 to 2050 ppm. Upon implementation of Technical Specification Change Request NPF-38-189, there will be no boration path capable of injecting less than 2050 ppm boron.
As indicated above,2050 ppm boron will be sufficient to provide adequate Shutdown Margin for Cycle 9. Furthermore, the normal source of borated water to be used for these Action Statements is the Boric Acid Makeup Tank (BAMT) which has a minimum boren concentration cf 3950 ppm.
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The proposed changes are consistent with the intent of NUREG 1432, " Standard Technical Specifications - Combustion Engineering Plants" and require the operator to immediately initiate boration to restore the Shutdown Margin to within limits. This change eliminates a cycle dependent number from several Technical Specification Action Statements and allows the operator to ute the best source avai!able for the plant conditions. Technical Specification Figure 3.1-1, "BAMT Volume versus Boric Acid Concentration" will be modified by removing the "RWSP at 1720 ppm" curve. Upon the implementation of Technical Specification Change Request NPF-38-189, this curve will no longer be required since the RWSP boron concentration will be maintained between 2050 ppm and 2300 ppm boron. The "RWSP at 2000 ppm" and "RWSP at 2300 ppm" curves will be sufficient to allow interpolation given the actual RWSP boron concentration.
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?
Response
No The Shutdown Margin requirements are determined by the reload analysis performed every cycle. The Cycle 9 reload analysis has determined that the current Shutdown Margin requirements are acceptable. The proposed change eliminates the reference to 1720 ppm in the Action Statement because 1720 is not adequate to ensure that the Shutdown Margin requirements are met at the
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beginning of cycle. The proposed Action Statement will continuo to ensure that in the event the Shutdown Margin requirements are not met, boration will be immediately initiated to restore the Shutdown Margin to within limits.
l Therefore, the proposed change will not involve a significant increase in the probability or consequences of any accident previously evaluated.
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l 2.
Will operation of the facility in accordance with this proposed change create the possibility of a new or different type of accident from any accident i
previously evaluated?
Response
No.
The proposed change does not change the design or configuration of the plant nor does it change how boration systems are operated during normal or accident conditions. It ensures that the Shutdown Margin requirements for accidents already evaluated are promptly restored in the event that the requirements are not met.
Therefore, the proposed change will not create the possibility of a new j
or 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 significant reduction in a margin of safety?
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Response
No s
The proposed change has not decreased the amount of Shutdown Margin required. The current Shutdown Margin requirements have been validated by the Reload Analysis for Cycle 9 and are adequate to ensure that the reactor can be made subcritical from all operating conditions, transients, and design basis events. The proposed change ensures that the Shutdown Margin requirements are promptly restored in the event that they are not met. As such, the proposed change ensures that the current margin of safety is maintained.
1 Therefore, the proposed change will not involve a significant reduction in a margin of safety.
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Safety and Sionificant Hazards Determination 3
Based on the above safety analysis, it is concluded that: (1) the proposed change i
does not constitute a significant hazards consideration as defined by 10CFR50.92; and (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 l
which significantly alters the impact of the station on the environment as described in j
the NRC final environmental statement.
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j NPF-38-196 ATTACHMENT A t
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