ML20198R308

Errata to Proposed TS Change Request NPF-38-196 Which Changed TS 3.1.1.1,3.1.1.2,3.10.1 & Figure 3.1.-1 by Removing Cycle Dependent B Concentration & Boration Flow Rate from Action Statements

ML20198R308
Person / Time
Site:	Waterford
Issue date:	01/21/1998
From:	Ewing E ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20198R194	List: ML20198R190 ML20198R308
References
NUDOCS 9801230279
Download: ML20198R308 (4)

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Attachment to W3F1-98-0014 4 -

Errata: Pages for NPF 38-194 -

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intervpl of 30 months is being replaced with the _ interval specified by the applicable s 9ASME code referenced in TS 4.0.5.; This would allow testing of one valve each ~

refueling outage instead of both valves every, refueling outage.

NUREG 1432, " Standard Technical Specificationsy Combustion Engineering Plants,"

uses Surveillance Requirements _of "[18) months" for power operated relief valves or

-- *In Accordance with the Inservice Testing Program" for mechanically actuated _ relief -

-_ valves. Mechanically actuated relief valves rather than power operated relief valves are used for the Shutdown Cooling System suction line relief valves at Waterford 3.

' Thereforei a test frequency consistent with the ASME code is more appropriate for these valves.cThis change would make testing of the Shutdown Cooling System

. suction line relief valves consistent with requiremen't for other relief valves in the Inservice Test Program, which are tested pursuant to Technical Specification 4.0.5

(pursuant to_ Section XI of the ASME Boller and Pressure Vessel Code). These include existing Technical Specification Surveillance Requirements 4.4.2.1 and 4.4.2.2 for the _

pressurizer code safety valves and 4.7.1.1 for the main sieam line code safety valves.

Additionally, edi+orial changes are requested for Surveillance Requirements M 4.8.3.1 -

and 4.4.8.3.1.a to allow the revised Surveillance Requirement to be consistent with the wording in NUREG 1432 and still maintain the furmat of Waterford 3's current LTechnical Specifications.

This changes 4.4.8.3.1 as follows:

From "Each SDC Sjstem suction line relief valve shall be demonstrated OPERABLE:" i i To "For each SDC Syn. tem suction line relief valve:"

_ . _ This changes 4.4.8.3.1.a as follows:

From "by verifying in the control room at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that each valve in the suction path between the RCS and the SDC relief valve is open."

To " verify in the control room at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that each valve in the

suction path between the RCS and the SDC relief valve is open."-

. This changes 4.4.8.3.1.b as follows:

From "At least every 30 months when tested pursuant to Specification _4.0.5."

~ To " verify each SDC relief valve is OPERABLE in accordance with TS 4.0.5."

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No Sionificant Hazards Evaluation 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 operation of the facility in accordance with this proposed change invcive a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change will not affect the assumptions, design parameters, or results of any accident previously evaluated. The proposed change does not add or modify any existing equipment. The proposed change will not diminish the ability of the valves to perform as required during an accident. The proposed Shutdown Cooling System suction line relief valves testing schedule will be in accordance witil Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g).

This ensures the operational readiness of the valves. Therefore, the proposed change will not involve an 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 previously evaluated? .

Response: No.

The proposed change does not involve modifications to any existing equipment.

The proposed change will not affect the operation of the plant or the manner in which the plant is operated. No new failure modes that have not been previously considered will be introduced. The net effect of the change is to allow the plant staff the option of reducing the frequency of valve testing to a level that has been acknowledged as acceptable by the applicable ASME Code. Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No

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. The proposed change does not involve a decrease in the numbcr or capacity of 4

the valves in the system, nor does it involve a change in the relief valve setpoints, operability requirements, or limiting conditions for operation. The margin of safety for the relief valves is, in part, preserved by compliance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Adder;da as required by 10 CFR 50, Section 50.55a(g). Although the proposed change will allow a slightly longer testing frequency, the proposed change will continue to preserve compliance with 10 CFR 50, Section 50.55a(g). Therefore, the proposed char <ge will not involve a reduction in a margin of safety.

Safety and Sionificant 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 10CFR50.92; and (2) there is a reasonable assurance that the health and safety of the public will not be endangered by'the proposed chango; and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC final environmental statement.

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