ML20198G231
| ML20198G231 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/23/1998 |
| From: | Dugger C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20198G238 | List: |
| References | |
| W3F1-98-0196, W3F1-98-196, NUDOCS 9812290028 | |
| Download: ML20198G231 (7) | |
Text
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y Entirgy Operations,Inc.
Killona, LA 70006-0751 Tel 504 739 6660 Charles M. Dugger Vc rcs dent, operata>ns W3F1-98-0196 A4.05 PR December 23,1998 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 Technical Specification Change Request NPF-38-213 Gentlemen:
In accordance eith 10CFR50.90, Entergy is hereby proposing to amend Operating License NPF 9 for Waterford 3 by requesting the attached changes to the Technical Specifications. The attached description and safety analysis support the proposed changes to the Waterford 3 Technical Specifications (TS). The proposed changes modify the Limiting Condition for Operation for TS 3.3.3.7.1 for the chlorine detection system. A changt, in the alarm / trip setpoint from 3 parts per million (ppm) to 2 ppm is requested. Administrative controls are currently in place to implement this more conservative change. Additionally, this request corrects a typographical error in Table 3.3-4.
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.
The circumstances surrounding this change do not meet the NRC's criteria for exigent or emergency review. Entergy Operations requests the effective date for this change be within 60 days of approval.
t 9812290028 981223 C PDR ADOCK 05000382 P
PDR;_
Technical Specification Change Request NPF-38-213 WSF1-98-0196 -
Page 2-December 23,1998 Should you have any questions or comments concerning this request, please contact Early Ewing at (504) 739-6242.
Very truly yours, y
s C.M. Dugger Vice President, Operations Waterford 3 CMD/ CWT /ssf
~ Attachments:
Affidavit NPF-38-213 cc:
E.W. Merschoff, NRC Reg'on IV l
C P. Patel, NRC-NRR J. Smith N.S. Reynolds NRC Resident inspectors Office Administrator Radiation Protection Division (State of Louisiana)
American Nuclear Insurers
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION in the matter of
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Entergy Operations, incorporated
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Docket No. 50-382 Waterford 3 Steam Electric Station
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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 fi'a with the Nuclear Regulatory Commission the attached Technical Specification Change Request NPF-38-213; that he is familiar with the content thereof; and that the matters set forth therein are true anj correct to the best of his knowledge, information and belief.
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Charles Marshall Dugger V'
Vice President Operations - Waterford 3 STATE OF LOUISlANA
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) ss PARISH OF ST. CHARLES
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Subscribed and sworn to before me, aplotary Public in and for the Parish and State above named this > / '# day of 4 J....... /f
.1998.
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Notary Public My Commission expires - /.(. %2/
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DESCRIPTION AND NO SIGNIFICANT HAZARDS CONSIDERATION j
.. DETERMINATION OF PROPOSED CHANGE NPF-38-213 The proposed change modifies the Limiting Condition for Operation for Technical Specification (TS) 3.3.3.7.1 for the chlorine detection system. A change in the
,i alarm / trip setpoint from 3 parts per million (ppm) to 2 ppm is requested in order to meet the requirements for a Type il Control Room. Additionally, this request corrects a typographical error in Table 3.3-4 for tF.a Containment Spray Actuation System from 5 218 pourds per square inch (psia) to 518 psia.
l Existina Specification See Attachment A L
Proposed Marked-up Specification f
See Attachment B Proposed Specification See Attachment C 4
l Backaround i
Redundant chlorine detectors are provided near the control room air conditioning system normal outside air intake. The chlorine detectors use diffusion-type i
electrochemical probes.
Upon detection of chlorine, the control room envelope is automatically placed in the isolated mode as dese-Md in Final Safety Analysis Report subsection 6.4.3.3 and the reactor auxiliary build, y norrnal ventilation system is automatically shut down. The l
- chlorine detectors are provided with outputs to sound an alarm in the control room. The chlorine concentration reedout is available from the plant monitoring computer and I
appears on a digital display panel in the control room.
The chlorine detectors (Sensidyne, Inc., Gas Alert Chlorine Detector, Model 1000),
while purchased as non-seismic equipment, have been seismically tested by Wyle Laboratories. In addition, the chlorine detection equipment has been installed in seismically qualified structures. The plant specific seismic response spectra as expetienced by the equipment and the as-built installation were considered in the testing.
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l Redundant chlorine detectors are powered from independent nonsafety-related uninterruptible power supplies which in turn receive power from safety related busses.
The loss of power to a detector is annunciated in the control room.
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The response time of the chlorine detectors is a function of the instantaneous chlorine l
concentration. The original study of the concentration build-up at the outside air intake l
following a hypothetical design basis chlorine release accident verified that the effective isolation time was less than 4 seconds, which is the isolation time stipulated by Regulatory Guide 1.95 for a Type il control room.
Description and Safety Considerations TS 3.3.3.7.1 requires an alarm / trip setpoint for the chlorine detection system to be less l
than or equal to 3 ppm. Waterford 3 requests that the limit be changed to less than or equal to 2 ppm.
As part of Waterford 3's effort to improve the design basis documentation, Waterford 3 initiated a reanalysis of the chlorine analysis. The analysis used the air flow balance l
tolerance (i 10%) in the normal outside air intake flow rate, since the air intake flow rate could be set to any value within the tolerance. The air intake flow rate is a key parameter in the analysis and the original calculation had used the nominal flow rate from the HVAC flow diagram. Including the flow tolerance was an improvement over the original vendor analysis, which used the nominal flow rate.
The reanalysis showed that the chlecine setpoint should be 2 ppm chlorine, not the 3 ppm as indicated in the existing arialysis and implemented in TS 3.3.3.7.1. Waterford 3 is located in a highly industrialized area. Based on the amount of chlorine stored in the area, Waterford 3 is required by Regulatory Guide 1.95 to have a Type 11 control room with an isolation time of less than 4 seconds. Based on the new analysis, a 3 ppm chlorine setpoint will provide e.n isolation time of greater than 4 seconds. A 2 ppm setpoint will, howeve,r, ensure an isolation time of less than 4 seconds. A setpoint change for the instrument has been approved and implemented to reflect the new allowable value for chlorine.
There were two reasons for the change in the results of the analysis: 1) the inclusion of the tolerance on air intake flow and 2) correction of a poor assumption in the original vendor analysis regarding meteorological conditions (air temperatures) to be included in 4
the analysis. When the analysis is performed with the air intake flow rate at the upper range of the tolerance, chlorine would be transported faster through the air duct than originally assumed. Lower air temperatures would increase the response time of the sensors to a value greater than the time assumed in the original calculation. The combination of neglecting the flow uncertainty and not using enough meteorological cases meant that the original analysis erroneously concluded that a 3 ppm setpoint for the chlorine detector provided the required isolation time of less than 4 seconds, when in fact, the isolation time would have been greater than 4 seconds, not meeting the i
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Type ll control room requirement. With a 2 ppm setpoint, the 4 second isolation time is met..
The typographical error on TS page 3/4 3-19, Table 3.3-4, involved the Containment Spray Actuation System (CSAS) allowable value for " Containment Pressure - High-High". The present value listed in Table 3.3-4 of 5 218 psia was introduced during issuance of Amendment 136, deted November 20,1997. Changes were made to TS page 3/4 3-19, Table 3.3-4 for the Containment Pressure - High-High value, but were not requested by Entergy.' Thus, this is considered the correction of a typographical error.
No Sianificant Hazards Consideration Determination The proposed c? Inge 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 operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of an accident l
previously evaluatad?
Response
The chlorine detection system has no effect on the accidents analyzed in Chapter 15 of the Final Safety Analysis Report. Its only effect is on habitability of the control room, which will be enhanced by specifying a more conservative setpoint in the Technical Specifications (TS). Analysis using more conservative assumptions show that a setpoint of 2 parts per million (ppm) chlorine is acceptable.
Correcting the typographical error on TS page 3/4 3-19 has no effect on the probability or consequences of an accident previously evaluated.
Therefore, the proposed change will not involve a significant increase in the probability or consequences of any accident previously evaluated.
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 j
previously evaluated?
Response
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The proposed Technical Specification change in itself does not change the l'
design or configuration of the plant. Using a more conservative setpoint performs the same function as the old setpoint, but it accomplishes this function with increased conservatism.
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. Correcting the typographical error on TS page 3/4 3-19 will not create the l
possibility of a new or different type of accident from any accident previously evaluated.
Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
I 3.
Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?
Response
L The chlorine detection system has no effect on a margin of safety as defined by l
Section 2 of the Technical Specifications. Its only effect is on habitability of the control room, which will be enhanced by a more conservative setpoint provided by this change to the Technical Specifications.
Correcting the typographical error on TS page 3/4 3-19 does not involve a significant reduction in a margin of safety.
Therefore, the proposed change will not involve a significant reduction in a margin of safety.
I Safety and Sianificant Hazards Determination Based on the above No Significant Hazards Evaluation, it is concluded that: (1) the proposed change 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 which significantly alters the impact of the station on the environment as l
i described in the NRC final environmental statement.
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