ML20199A103
| ML20199A103 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/13/1997 |
| From: | Dugger C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20199A105 | List: |
| References | |
| W3F1-97-0238, W3F1-97-238, NUDOCS 9711170060 | |
| Download: ML20199A103 (10) | |
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cg'"y3L W3F1-97-0238 A4.05 PR November 13,1997 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 I
Subject:
Waterford 3 SES Docket No. 50 382 License No. NPF-38 Technical Specification Change Request NPF-38-202 Gentlemen:
The attached description and No Significant Hazards Evaluation support a change to the Waterford 3 Technical Specifications (TS). The proposed change modifies TS 6.8.4.a (Primary Coolant Sources Outside Containment) to add portions of the containment vacuum relief (CVR) system and the primary sampling system to the program.
The addition of the CVR system to the Primary Coolant Sources Outside Containment Program is the result of the discovery that the CVR lines do not terminate in an area exhausted by the Controlled Ventilation Area System (CVAS).
The CVR lines were mistakenly identified as terminating in an area serviced by CVAS during the initial licensing phase of Waterford 3. This change has taken into consideration the new CVR penetration arrangement previously reviewed by the NRC in an NRC letter from C P. Patel to C. M. Dugger dated May 20,1997 (Reference 1).
The addition of the primary sampling system to the program is the result of a g
modification that connected the primary sampling system to the post accident
)j sampling system outside containment. This modification ensures samples can be f
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taken downstream of Engineered Safety Features (ESF) pumps following an accident if the Reactor Coolant System (RCS) is depressurized.
Y N E N 382 Will,II,lqql@pilli e
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Technical Specification Change Request NPF-38-202 W3F1-97-0238 Page 2 November 13,1997 The Primary Coolant Sources Outside Containment Program requires preventive maintenance and periodic visualinspection requirements, and integrated leak testing at refueling cycle intervals at a minimum. These requirements will ensure the added systems are adequately tested to limit the potentialleakage of highly radioactive fluid
- outside containment and to ensure the overall leakage will not exceed the leakage limits assumed in the safety analysis.
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.
In addition to the above change, several unrelated changes to the TS Bases have been included. Waterford 3 requests issuance of replacement pages for these TS Bases changes. These changes to the TS Bases have been evaluated in accordance with 10CFR50.59 requirements, reviewed by the Plant Operations Review Committee, and approved by the General Manager, Plant Operations. This request to change the Bases has been discussed with the NRR Project Manager for Waterford 3.
Should you have any 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/CED/ssf
Attachment:
- Affidavit NPF-38-202 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
UNITED STATES OF AMERICA
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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; inat he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Technical Specification Change Request NPF 38 202; 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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) ss PARISH OF ST CHARLES
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Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this eeh day of /W ~ o. i
.1997.
~ rt Notary Pabl4 My Commission expires d s'#/ '
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DESCRIPTION AND NO SIGNIFICANT HAZARDS EVALUATION OF PROPCSED CHANGE NPF 38-202 The proposed change revises Technical Specification (TS) 6.8.4.a, Primary Coolant Sources Outside Containment. This change adds portions of the containment vacuum relief (CVR) system and the primary sampling system to the Primary Coolant Sources Outside Containment Program. In addition, changes were made to TS Bases Sections 3/4.4.1, 3/4.6.1.7, 3/4.6.3, 3/4.7.12, and 3/4.8.4.
Existing Specification See Attachment A Marked up Specification See Attachment B Proposed Specification See Attachment C References See Attachmeit D
Background
The addition of the CVR system to TS 6.8.4.a is a result of Waterford 3 mistakenly identifying the CVR system as terminating in an area serviced by controlled ventilation area system (CVAS). On August 21,1996 Waterford 3 informed the NRC (via a letter from M. B. Sellman to the U.S. NRC Document Control Desk; Reference 2) of its proposed solution to problems identified in a July 23,1996 condition report (CR). The CR identified a discrepancy between the cunent plant configuration of the CVR system and information provided to the NRC review staff during the initiallicensing phase at Waterford 3. Information provided to the NRC during the initiallicensing phase justified the test method for instrument sensing lin6s penetrating the primary containment, pursuant to 10 CFR 50 Appendix J, by stating that the CVR sy' tem terminated in an area serviced by the CVAS. However, the CR identified that portions of the CVR system do not terminate in an area serviced by the CVAS.
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i The August 21,1996 letter proposed a solution which required the CVR instrument
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sensing lines to be pressurized and leak tested at refueling intervals in accordance with plant operating procedures. The acceptance criteria in the procedure will ensure the leakage is in compliance with the TS requirements and other requirements associated with containment integrity. Further, the FSAR was revised to specifically describe the l
basis for meeting BTP CSB 6 3 Section 9.b as it applies to the applicable portions of the CVR system (Reference 3).
The addition of the primary sampling system to TS 6.8.4.a is a result of a modificatiori i
I performed at Waterford 3 that connected the primary sampling system to the post-accident sampling system (PASS) outside of containment. Specifically, the i
modification connected the two existing primary sampling system lines from the high pressure safety injection (HPSI) pumps recirculation lines to the PASS safety injection l
system sump sample pump discharge line. This modification will enable PASS samples to be obtained from downstream of the Engineered Safety Features (ESF) pumps after an accident if the RCS is depressurized.
The Bases changes (described in the next Section) were the result of design changes, inconsistencies between the TS and Bases, the addition of information for clarification, and a change in a reference document, Descriotion and Safety Considerations Current Technical Specification 6.8.4.a (Primary Coolant Sources Outside Containment) requires a program to reduce leakage from those portions of the systems outside containment that could contain highly radioactive fluids during a serioJs transient or accident to as low as practical levels. The systems include the containment spray, safety injection, hydrogen analyzer and the post-accident sampling system. The program requires the following:
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Preventive main:anance and periodic visual inspection requirements, and 2.
Integrated leak test requirements for each system at refueling cycle intervals orl ass.
The proposed change will revise the Primary Coolant Sources Outside Containment Program to add the CVR system and the primary sampling system.
Both of these systems have the potential to produce leakage from containment to j
outside containment during a serious transient or accident. The program requires reduction of leakage from those portions of systems outside containment that could conta!n highly radioactive fluids during a serious transient or accident, to as low as practical. Therefore, the CVR system and primary sampling system are being added to
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Technical Specification 6.8.4.a which will require these systems to comply with the requirements of the program.
The addition of the CVR system to the Primary Coolant Sources Outside Containment Program specified in the TS was not specifically stated as a proposed solution in the August 21,1996 letter which informed the NRC that the CVR system does not exhaust to an area serviced by the CVAS. However, placing the CVR system in the program along with the other proposed solutions that were proposed in the letter will ensure the appropriate portions of the system are tested at least every refueling. The addition of the primary sampling system to the program will ensure appropriate portions of this system are also tested at least every refueling.
Adding the CVR system and the primary sampling system to the Primary Coolant Sources Outside Containment Program in the TS will ensure any leakage associated with these potential bypass leakage paths will not exceed the limits used in the Waterford 3 safety analysis or result in a significant increase in the analyzed dose consequences. This is ensured because each refueling local leak rate testing (LLRT) is performed on appropriate portions of the CVR system. The leakage rate resulting from this test is accounted for in the overall containment leakage rate acceptance criteria. Also, every refueling integrated leak testing is performed on the appropriate portions of the primary sampling system. Any leakage from this system is kept to a minimum by performing required maintenance.
This is an administrative change to add two systems to a program located in the TS Administrative Controls Section. The CVR system is being added to correct a mistake made during the initial licensing phase of Waterford 3 and the primary sampling system is being added based on a plant modification. These systems are both required to be included in the program because there is a potential these systems could contain highly radioactive fluids outside containment.
I The change to TS Bases 3/4.4.1, ' Reactor Coolant Loops and Coolant Circulation," is a i
resu:t of a recently identified inconsistency between the TS and the TS Bases. The TS limit the RCS cold leg temperature to 272 F, the TS Bases lists the temperature as 285 F. An evaluation of this discrepancy revealed that Waterford 3 should have revised the 285'F temperature value as part of the change package for Amendment 106, which was approved by the NRC on May 8,1995. Letter W3F1-93-0099, dated December 14,1993, transmitted the TS change request (approved in Amendment 106) and identified 272*F as the low temperature overpressure protection (LTOP) alignment temperature. During the effort to revise the original value of 285*F that was included in several discussions within the Bases, Waterford 3 failed to change the 285'F value on page B 3/4 4-1. This revision corrects an oversight that was not included in the TS change request for Amendment 106 and makes the TS Bases consistent with the footnote for Specification 3.4.1.3 (Reference 4).
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The change to TS Bases 3/4.6.1.7,
- Containment Ventilation System,* consists of adding a discussion that the Operability considerations for purge supply and exhaust isolation valves also include the LCO Actions of TS 3.6.3,
- Containment Isolation Valves." The scope of this change is to more clearly link the Operability considerations for the two LCOs. Technical Specification 3.8.1.7 Actions are only applicable for inoperabilitlec associated with sealleakage and having the valves open for greater than the allowed time. Inoperabilities associated with the electrical or mechanical portions are not addressed in TS 3.6.1.7, therefore, the Containment Isolation Valve Technical Specification is entered (the containment purge valves are containment isolation valves).
The change to TS Bases 3/4.6.3,
- Containment Isolation Valves," and TS Bases 3/4 8.4, " Electrical Equipment Protective Devices," are necessary due to the fact Plant Procedure UNT-005 026, " Technical Specification Component Tables." has been superseded with the issuance of the Technical Requirements Manual (TRM). The TRM is a controlled document that contains Technical Requirements that were previously relocated from the TS. UNT-005-026 previously contained the relocated tables from the TS.
The change to TS Bases 3/4.7.12,
- Essential Services Chilied Water System,"is a result of a design change to the essential chilled water (ECW) system configuration.
The previous discussion within the TS Bases regarding chilled water being supplied to air handling units for nonessential spaces is no longer accurate and has been deleted.
The design change, performed during Refuel 8, re-configured the ECW system by disconnecting the non nuclear safety chilled water train from ECW and connecting it to the supplemental chilled water system.
No Significant Hazards Evaluation This No Significant Hazards Evaluation is not applicable to the above Technical Specification (TS) Bases changes. Only the TS changes are included. A 10CFR50.59 Safety Evaluation was performed for the TS Bases changes described above and concluded the changes could be implemented without prior NRC approval.
The proposed changes to TS 6.8.4.a 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 w,th this proposed change involve a significant increase in the probability or consequences of an accident previously svaluated?
Response
No l'he proposed change adds the containment vacuum relief (CVR) system and the primary sampling system to the Primary Coolant Sources Outside Containment Program in the Technical Specifications. The program will require preventative maintenance and periodic visual inspection, and leak rate testing on appropriate portions of these systems to ensure leakage of radioactive fluids are as low as practicable. The addition of these two systems to the program will not affect the probability of an accident. Neither the CVR system nor the primary sampling system are initiators of any analyzed event. The consequences of an accident are not affected by this change. The maximum allowed leakage limits are not being increased due to the addition of these two systems. Any leakage from the CVR system will be factored into the overall leakage limits and any leakage from the primary sampling system will be kept to a minimum by performing required maintenance. This change does not affect the mitigation capabilities of any component or system nor does it affect the assumptions relative to the mitigation of accidents or transients. The addition of these systems to the program also helps ensure that the systems will perform their intended function. 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 previously evaluated?
Response
No.
The proposed change adds the CVR system and the primary sampling system to the Primary Coolant Sources Outside Containment Program in the Technical Specifications. The program will require preventative maintenance and periodic visualinspection, and leak rate testing on appropriate portions of these systems to ensure leakage of radioactive fluids are as low as practical. Neither the design nor configuration of the plant is being changed due the addition of the CVR system to the program. Also, as a result of the CVR system being added to the program, there has been no physical change to plant systems, structures or components nor will the addition of the CVR system reduce the ability of any of the safety related equipment required to mitigate anticipated operational occurrences (AOOs) or accidents.
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Although the addition of the primary sampling system to the program was a result of a change to the configuration of the plant, it does not reduce the ability of any safety-related equipment required to mitigate AOOs or accidents. Any leakage from the primary sampling system will be kept to a minimum by perfonning required maintenance.
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 pioposed change involve a significant reduction in a margin of safety?
Response
No The proposed change adde the CVR system and the primary sampling system to the Primary Coolant Sources Outside Containment Program in the Technical Specifications. The program will require preventative maintenance and periodic visualinspection, and leak rate testing on appropriate portions of these systems to ensure leakage of radioactive fluids are as low as practical. This change will not affect the maximum containment leakage allowed in the Technical Specifications. The leakage from the CVR system will be added to the overall containment leakage rate. Any leakage from the primary sampling system will be kept to a minimum by performing required maintenance. The overall containment leakage requirement is required to be met and therefore, this change will not result in an increase in the analyted dose consequences assumed in the Waterford 3 safety analysis, Therefore, the proposed change will not involve a significant reduction in a margin of safety.
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 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 th( station on the environment as described in the NRC final environmental statement.
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NPF-38-202 ATTACHMENT A