ML20149E161

Safety Evaluation Supporting Amend 132 to License NPF-38

ML20149E161
Person / Time
Site:	Waterford
Issue date:	07/11/1997
From:	NRC (Affiliation Not Assigned)
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ML20149E160	List: ML20149E154 ML20149E161
References
NUDOCS 9707180124
Download: ML20149E161 (6)

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UNITED STATES p

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NUCLEAR REGULATORY COMMISSION i

t WASHINGTON, D.C. 20566 4001 i

• • • • • ,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 132 TO FACILITY OPERATING LICENSE N0. NPF-38 l

ENTERGY OPERATIONS. INC.

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

1.0 INTRODUCTION

By application dated July 10, 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 delete Surveillance Requirement (SR) 4.8.1.1.2.h.2 in TS 3/4.8.1 " Electrical l

Power Systems-AC Sources."

2.0 DISCVSSION AND EVALUATION On July 8,1997, the licensee determined that at Waterford 3, SR 4.8.1.1.2.h.2 was missed and resulted in both emergency diesel generators (EDG) being declared inoperable in accordance with TS 3.8.1.2.

The licensee noted that testing of the EDG fuel oil system components has been performed at Waterford 3 in accordance with Section XI of the ASME Code.

In addition, Code Case N-498-1 has been approved for use at Waterford 3 in an NRC Saff.'y Evaluation dated March 29, 1995, and has been employed for portions of ' e sting and the system has been tested in accordance with the ASME Code requL vments.

By letter dated July 10, 1997, the licensee requested to delete SR 4.8.1.1.2.h.2.

SR 4.8.1.1.2.h.2 requires the performance of a pressure test of those portions of the diesel fuel oil system designed to Section III, subsection ND of the ASME Code at a test pressure equal to 110 percent of the system design pressure at least once every 10 years.

The licensee provided the following justifications for its proposed TS change:

1.

The changes requested are consistent with (a) the guidance provided in NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants," (b) industry and Waterford 3 plant operating experience, and (c) l the licensing basis for Waterford 3.

I 2.

The appropriate testing for the diesel fuel oil system will be controlled by ASME Code Section XI and approved Code Case N-498-1 as provided for in the Waterford 3 Inservice Inspection Program.

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3.

As required by 10 CFR 50.55a(g), the Waterford 3 Inservice Inspection L

Program directs that the ASME Code Class 1, 2, and 3 components be tested in accordance with ASME Code,Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components." The approved ASME Code Case N-498-1 allows nominal operating pressure (NOI, tests in lieu of Code required hydrostatic testing. Visual examinations (VT-2) are performed while the t

system is maintained at NOP.

a 4.

Testing of the EDG fuel oil system components has been performed at Waterford 3 in accordance with Section XI of the ASME Code. Code Case N-498-1 has been approved for use at Waterford 3 and has been employed for portions of testing. Therefore, the system has been tested in 3

accordance with the ASME Code requirements.

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5.

Based on the conduct of approved testing in accordance with the Waterford 3 Inservice Inspection Program and ASME Code Section XI, there is no added safety benefit by performing hydrostatic testing at 110 3

i percent of design pressure.

' Code Case N-498-1 requires a VT-2 be performed in conjunction with a system leakage test in accordance with paragraph IWA-5000. A system leakage test may l

be conducted to demonstrate that leaks from pressure boundary that may originate from through-wall flaws do not exist. This would meet the intent.of the hydrostatic test as noted in SR 4.8.1.1.2.h.2.

Information prepared in conjunction with ASME Code. Case N-498-1 notes that the system hydrostatic test is not solely a test of the structural integrity of the system but also provides a means to enhance leakage detection. That this was the original intent is indicated in a paper by S.H. Bush and R.R. Maccary,

" Development of In-Service Inspection Safety Philosophy for U.S.A. Nuclear i

Power Plants," ASME 1971.

Piping components are designed for a number of loadings that would be postulated to occur under the various modes of plant i

operation.. Hydrostatic testing only subjects the piping components to a small i

increase in pressure over the design pressure and therefore does not present a j

significant challenge to pressure boundary integrity since piping dead weight, i

thermal expansion, and seismic loads, which may present far greater challenge to the structural integrity of a system than fluid pressure, are not part of the loading imposed during a hydrostatic test. Water is used as a test medium in.the hydrostatic test.

Because water is highly incompressible, a small leak i

decline in system pressure, or by continual pumping required to maintain the from a high pressurized water solid system can be readily detected by a sharp i-system pressure. As such, hydrostatic pressure testing is primarily regarded as a means to enhance leakage detection during the examination of components under pressure since such a test provides good indication of any system leakages, especially those that might originate from small through-wall cracks of the. pressure boundary. Consequently, this in-service hydrostatic pressure test required by the Code enhances the possibility of timely discovery of small through-wall flaws which, because of a tiny leak size, might not be readily detected by any other means such as system walkdowns or installed leak-detection systems.

. Currently, licensees expend considerable time, radiation dose, and dollar resources carrying out hydrostatic test requirenents. A significant amount of effort may be necessary (depending on system, plant configuration, Code class, etc.) to temporarily remove or disable code safety and/or relief valves to 1

meet test pressure requirements. The safety assurance provided by the enhanced leakage detection gained from a slight increase in system pressure i

during a hydrostatic test are offset or negated by the following factors:

having to gag or remove code safety and/or relief valves, placing the system in an off-normal state, erecting temporary supports in steam lines, possible extension of refueling outages, and resource requirements to set up testing with special equipment and gages.

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Class 3 systems do not normally receive the amount or type of non-destructive examinations that Class I and 2 systems receive. While Class 1 and 2 system failures are relatively uncommon, Class 3 system leaks occur more frequentl' and the failure mode typically differs. Based on a review of Class 3 system failures requiring repair for the last five years in Licensee Event Reports and the Nuclear Plant Reliability Data System databases, the most common j

causes of failures are erosion-corrosion (EC), microbiologically induced i

corrosion (MIC), and general corrosion.

Licensees generally have' programs in place for prevention, detection, and evaluation of EC and MIC.

Leakage from general corrosion is readily apparent to inspectors when performing a VT-2 examination during system pressure tests.

Giving consideration to the minimal amount of increased assurance provided by the increased pressure associated with a hydrostatic test versus the pressure for the system leakage test and the hardship associated with performing the ASME Code required hydrostatic test, the staff finds that compliance with the L

Section XI hydrostatic testing requirements results in hardship and/or unusual difficulty for the licensee without a compensating increase in the level of quality and safety.

Therefore, the staff determined that the licensee's 1

proposed TS change to delete SR 4.8.1.1.2.h.2 is' acceptable. The Code Case N-498-1 provides an acceptable level of quality and. safety, and reasonable assurance of structural integrity of the subject system.-

Based on the information submitted, the staff concluded that the licensee's proposal to delete SR 4.8.1.1.2.h.2. and the alternative to use Code Case N-498-1 in lieu of hydrostatic tests is acceptable.

3.0 EMERGENCY CIRCUMSTANCES On November 7,1995, a. Technical Specification Change Request, NPF-38-172, was submitted to amend TS 3.8.1.

Among the changes requested in NPF-38-172 was a request to delete SR 4.8.1.1.2.h.2.

At the request of Waterford 3, NRC focused on the changes identified as being needed for-the refuel 8 outage.

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l At that time, Waterford 3 believed that an adequate grace period existed such that delaying the request.to delete SR 4.8.1.1.2.h.2 was an acceptable compromise to ensure the higher priority changes were made prior to the refuel 8 outage. The request to delete SR 4.8.1.1.2.h.2 and lower priority items was withdrawn on March 14, 1997.

On July 7, 1997, preparations were started to resubmit the change to delete

-SR 4.8.1.1.2.h.2.

On July 8,1997, while trying to determine the end date for the 25 percent grace period allowed by Specification 4.0.2, questions were l

asked to determine when the interval started and how the start of the interval l

was justified.

Waterford 3 personnel had considered this SR to be the same as the pressure testing requirements of Section XI of the ASME Code as invoked by TS 4.0.5 and '

l implemented by the Inservice Inspection Program.

Based on this, it had previously been determined that the start of the interval for this SR was the same as the start of the-interval for the Inservice Inspection Program which began at commercial operations on September 24, 1985, as provided for by ASME Code Section XI, Subsection IWA-2420, 1980 Edition through 1981 Addenda. This interval start date would have had a 10 year end date of September 24, 1995, and a 10 year plus 25 percent end date of March 24, 1998.

It is this erroneously determined start and associated end date that had led Waterford 3 personnel to believe that withdrawal of the deletion request would not impact the ability to comply with the TS. Almost a year would have been available to perform the testing required by the SR (which was assumed to be the requirements of ASME Code Section XI) or to resubmit the deletion request.

At 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> on July 8,1997, it was determined that the actual interval should have started at receipt of the operating license on December 18,1984, and that Waterford 3 had, therefore, exceeded the specified interval of 10 years plus the 25 percent allowed by Specification 4.0.2.

The 10 year interval plus the 25 percent allowance of Specification 4.0.2 was exceeded on June 18, 1997.

The emergency was created when the error was identified with the determination of the appropriate start date of the interval applicable to SR 4.8.1.1.2.h.2.

Although both EDGs are fully functional, application of the correct interval has resulted in Waterford 3 having no EDGs technically operable at this time.

This situation results in the inability to resume startup.

Waterford 3 is preparing to restart following refuel outage 8.

Requiring literal compliance testing will preclude resumption of power operations until the SR is met. This may require as many as 34 days. Accordingly, the Commission finds that an emergency situation exists pursuant to 10 CFR 50.91(a)(5). Throughout this process, the licensee acted promp)1y and kept the staff informed regarding the status of its activities. The staff finds j

that the licensee did not create the emergency situation and acted promptly l

once it became aware of the errors made in interpretation of the requirements.

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f 4.0 FINAL NO SIGNIFICANT HAZARD CONSIDERATION DETERMINATION The Commission's regulations in 10 CFR 50.92 state that the Commission may make a final determination that a license amendment involves no significant hazards considerations, if operation of the facility, in accordance with the l

amendment would not:

.(1)

Involve a significant increase in the probability or consequences of l

any accident previously evaluated; or I

(2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3)

Involve a significant reduction _in a margin or safety.-

This amendment has been evaluated against the standards in 10 CFR 50.92.

It does not involve a significant hazards consideration because of the following.

l The ASME Code,Section XI, including applicable ASME Code Cases as authorized by the NRC, provides alternate test methods to use in lieu of a 110 percent hydrostatic pressure. test that is not practical to perform on the EDG fuel oil system as currently designed. With the proposed deletion of SR 4.8.1.1.2.h.2, i

the provisions of SR 4.0.5 and the ASME Code, along with NRC-authorized Code Cases, would be utilized as an equivalent testing requirement to ensure the continued integrity of the EDG fuel oil system. Therefore, since the reliability of the EDG fuel oil system will not be reduced, the probability j

and consequences of any accident previously evaluated is not increased. The proposed change has no effect on the ability of the EDGs to perform their design function. The proposed change does not affect the availability or the testing requirements of the offsite circuits.

i Therefore, the proposed change will not involve a significant-increase in the probability or consequences of any accident previously evaluated.

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The proposed change to TS 3/4.8.1 does not introduce any new modes of plant operation or new accident precursors,: involve any physical alterations to 1

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plant configurations, or make any changes to system setpoints which could initiate a new or different kind of accident. The proposed change does not 4

affect the design or performance characteristics of any EDG or its ability to perform its design function. No new failure modes have been defined and no l

new system interactions have been-introduced for any plant system or.

-component.

In' addition, there have not been any new limiting failures d

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identified as a result of the proposed change. Accidents concerning loss of offsite power and a single failure (e.g., loss of an EDG) have previously been evaluated. This change will result in testing of the diesel fuel oil system in accordance with ASME Code Section XI and will avoid unnecessary out of l

service time.

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i Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

l Under the proposed change to TS 3/4.8.1, the EDGs will remain capable of l

performing their safety function. The change does not affect the design or performance of the EDGs.

The ability of the EDGs to perform their safety function will not be degraded. The change affects the manner in which the 3

diesel fuel oil system is tested. The testing will be performed in full compliance with the ASME Code,Section XI and approved Code Case N-498-1.

i This. testing has previously been approved by the NRC for Waterford 3 for other j

ASME Code systems.

j-i Therefore, the proposed change will not involve a significant reduction in a margin of safety.

5.0 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.

6.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a j

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 Commission has made a final no significant hazards consideration finding wfth respect to this amendment.

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.

7.0 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 Contributors:

T. McLellan C. Patel Date: July 11, 1997