W3P88-0100, Application for Amend to License NPF-38,consisting of Tech Spec Change Request NPF-38-72,adding Containment Isolation Valve.Fee Paid

Application for Amend to License NPF-38,consisting of Tech Spec Change Request NPF-38-72,adding Containment Isolation Valve.Fee Paid

ML20147D382
Person / Time
Site:	Waterford
Issue date:	01/13/1988
From:	Dewease J LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20147D387	List: ML20147D398 W3P88-0100, Application for Amend to License NPF-38,consisting of Tech Spec Change Request NPF-38-72,adding Containment Isolation Valve.Fee Paid
References
W3P88-0100, W3P88-100, NUDOCS 8801200160
Download: ML20147D382 (6)

Text

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LOUISIANA 317 BARONNE STREET . P. O. BOX 60340 POWE R & LIG HT f NEW ORLEANS, LOUISIANA 70160 . (504) 595-2781

$T00!?sM J. G. DEWE ASE ssNon ynt estsetNr.

NUGLAt OPERA TONS January 13, 1988 W3P88-0100 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

SUBJECT:

Waterford SES Unit 3 Docket No. 50-382 Technical Specification Change Request NPF-38-72 Gentlemen:

Louisiana Power & Light hereby files an application for an amendment to the Waterford 3 Technical Specifications. The amendment involves the addition of a containment isolation valve to the appropriate Technical Specification Tables.

The physical plant modifications necessary to support the ameadment will be implemented during the upcoming second refueling, outage. We would appre-ciate your timely review to support plant startup in approximately late May, 1988.

The proposed change does not involve an unreviewed safety question nor a significant hazards consideration. Should you have any questions or require additional information, please contact Mike Meisner at (504) 595-2832.

Yours very truly, l

x r A

.G. ewease

/SeniorVicePresident Nuclear Operations 1

JGD/MJM/plu l

Enclosures:

NPF-38-72 l Filing fee - LP&L check 12-5211 cc: E.L. Blake, W.M. Stevenson, J.A. Calvo, J.H. Wilson, R.D. Martin, L

NRC Resident Inspector's Office (W3), Administrator Nuclear Energy Divi- ~

sion (State of Louisiana), American Nuclear Insurers j l

, #\ 4"Y 8801200160 880113 \\

PDR ADOCK 05000382 'AN EQUAL OPPORTUNITY EMPLOYER

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UNITED STATES OF AMERICA' NUCLEAR REGULATORY COMMISSION In the matter of )

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Louisiana Power & Light Company ) Docket No. 50-382 Waterford 3 Steam Electric Station )

AFFIDAVIT J.G. Dewease, being duly sworn, hereby deposes and says that he is Senior Vice President, Nuclear Operations of Louisiana Power & Light Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Technical Specification Change Request; 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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)

J.V. Dewcase

. Senior Vice President Nuclear Operations -

STATE OF LOUISIANA)

) ss PARISH OF ORLEANS )

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Subscribed and sworn to before me, a Notary Publ % in and for the Parish ,

and State above named this /O d ___ day of YM_ , i 1988. (/ -

P t

I N ary Public I

1 My Commission expires _) .

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e DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-72 This is a request to revise Technical Specification Table 3.6-2, Containment Isolation Valves, and Table 3.6-1, Containment Leakage Paths.

Existing Specification See Attachment A.

Proposed Specification See Attachment B.

Description For the containment isolation valves listed in Table 3.6-2, Technical Specification 3.6.3 ensures that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment etmosphere or pressurization of the containment, as required by 10CFR50 Appendix A, GDC 54 through GDC 57. Containment isolation within the time limits specified for isolation valves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the LOCA analyses assumptions. The proposed change will add a new containment isolation valve to the automatic isolation section of Table 3.6-2, and move an existing valve from the manual isolation section of Table 3.6-2 to the automatic isolation section while changing its valve identification number.

Similarly, Table 3.6-1 of Technical Specification 3.6.1.2 lists the containment penetrations and valves subject to Type B and C leak rate testing. The proposed change will add a new containment isolation valve for Type C testing to the Table

and change the valve identification number of an existing valve.

l The Containment Atmosphere Release System (CARS), described in Section 6.2.5.2.3 of the FSAR, serves as a dual train backup to the Hydrogen Recombiner System for post-LOCA hydrogen control. Motor operated containment isolation valves inside containment (valves CAR 201A/B) are presently provided for each train of the i CARS exhaust and included in the automatic isolation (CIAS) section of Technical l Specification Table 3.6-2. Locked closed manual isolation valves outside i

containment (valves CAR 202A/B) are included for each exhaust train in the manual isolation valve section of Table 3.6-2.

l To provide a means for intermittent containment pressure control, a station modification will be implemented during the upcoming second refueling outage to cross-connect the CARS train B exhaust with the RAB Normal Ventilation System.

l The tie-in occurs between the CARS outside containment isolation valve and the CARS exhaust fan. In the course of the modification a new inside containment i

air-operated and fail-closed isolation valve (CAR 200B) will be added in parallel l with the existing CAR 201B motor-operated valve; the outside containment isolation valve (CAR 2028) will be changed from a manual valve to an air-operated and fail-closed valve.

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Two design constraints are relevant to the proposed Technical Specification change: 1) the containment pressure control line must be capable of isolation within 5 seconds following a containment isolation or high radiation signal (and valves must fail in the safe (closed) position), and 2) CARS train B must remain capable of performing its post-LOCA hydrogen removal function. Because air-operated valves are faster acting than motor-operated valves, the first constraint is met by adding the inside containment air-operated isolation valve, CAR 200B, and changing the outside containment isolation valve, CAR 202B, frcm a manual valve to an air-operator. The second constraint is met by retaining the motor-operated inside containment isolation valve, CAR 201B, so that post-LOCA credit for the instrument air system is not necessary to ensure that CARS train 8 can be unisolated when needed. In effect, CAR 201B is dedicated for hydrogen removal post-LOCA and CAR 2008 is available for containment pressure control.

The proposed change, therefore, involves: 1) the addition of CAR 2008 to Tables 3.6-1 and 3.6-2 as a new valve to automatically isolate on CIAS or high containment radiation, and 2) shifting CAR 2028 from the manual isolation section of Table 3.6-2 to the automatic isolation section. Both valves must meet a five second closure criterion during testing. Because the actual valve for CAR 202B is being replaced, the valve-specific identification number used internally by Waterford 3 will also be changed from 2HV-B192B to 2HV-F229B.

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:

1. Will the operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: No.

As a post-accident system, the CARS is not credited in the safety analyses for Waterford 3, but is assumed to function to maintain containment hydrogen concentration below 4%. The proposed change preserves this function. When controlling pressure, five second automatic isolation of the inside (CAR 200B) and outside (CAR 2028) containment isolation valves ensures that the large break LOCA analysis assumptions remain bounding. The combination of automatic isolation and the small CARS pipe diameter (4 inches) limits the total volume released from containment to well below that assumed for other analyzed releases. Type C leak rate testing of the valves in question ensures that the total containment leakage volume will not exceed safety analysis assumptions at peak accident pressure. Therefore, the proposed change will

. not involve an increase in the probability or consequences of any accident previously ev'aluated.

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2. Will operation of the facility in accordance with this proposed change create

[ the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

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l The proposed change adds a new inside containment autocatic isolation valve in parallel with an existing system and changes the existing outside containment manual isolation valve to an automatic valve. The combination of automatic inside/outside containment isolation valves is a standard design implicitly analyzed and accepted over a wide range of systems and conditions. Therefore, the proposed change does not create the possibility of a new or different kind of accident.

3. Will operation of the facility in accordance with this proposed change involve a significant reduction in the margin of safety?

Response: No.

The CARS provides added assurance that a hydrogen burn or explosion would not occur following a LOCA. The proposed change will preserve the safety function of the CARS. Similarly, the five second closure criterion for the inside/outside containment isolation valves and appropriate leak rate testing preserves the assumptions of the limitiiig LOCA evaluation to ensure that off-site dose consequences are not increased. Therefore, the proposed change does not invnive a reduction in safety margin.

Safety and Significant 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 10 CFR 50.92(c); (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 environnent as described in the NRC Final Environmental Statement.

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NPF-38-72 ATTACilMENT A 5

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