ML20217G235
| ML20217G235 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/07/1997 |
| From: | Dugger C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20217G239 | List: |
| References | |
| W3F1-97-0241, W3F1-97-241, NUDOCS 9710090268 | |
| Download: ML20217G235 (7) | |
Text
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,y En gy Operations,Inc.
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Killoria LA 70066-0761 lel 504 739 6660 Charles M. Dugger ve es @ot oteations W3F1-97-0241 A4.05 PR October 7,1997 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington,2.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 Technical Specification Change Request NPF-38-203 Gentlemen:
The attached description and no significant hazards evaluation support a change to the Waterford 3 Technical Specifications (TS). The proposed change modifies TS 3.3.3.7.3 and Surveillance Requirement 4.3.3.7.3 for the broad range gas detection system. A change to the Technical Specification Bases 3/4.3.3.7 has been included to support this change. This change to the Technical Specifications is necessary due to a potential unreviewed safety question identified during final review prior to installation of a new broad range gas detection system. In effect, Entergy Operations is requesting that the Technical Specifications and associated Bases for the broad range gas detection system that were in effect prior to Amendment 133 be retained instead of implementing the approved Amendment 133.
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. However, Waterford 3 is not able to implement Amendment 133 on or before the specified implementation date of November 17, 1997. To avoid noncompliance with the Operating License, we respectfully request an expeditious review. Waterford 3 requests the effective date for this change to be vq upon NRC approval.
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Technical Specification Change Request NPF-38-203 W3F1-97-0241 Page 2 October 7,1997 Should you have any questions or comments concerning this request, please contact Mr. Early Ewing at (504) 739-6242.
Very truly yours, 1
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C.M. Dugger Vice President, Operations Waterford 3 CMD/ CWT /ssf
Attachment:
Affidavit NPF-38-203 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 k
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In '.he matter of
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Entergy Operations, Incorporated
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Docket No. 50-382 i
Waterford 3 Steam Electric Station
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Charles Marshall Dugger, being duly swum, hereby deposes and says that he is Vice President Operations - Waterford 3 of Entergy Operations, incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Technical Specification Change Request NPF 38 203; 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.
'Ym 9'r Chailes Marshall Dugger 6' '
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
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My Commission expires
DESCRIPTION AND NO SIGNIFICANT HAZARDS EVALUATION OF PROPOSED CHANGE NPF-38-203 The proposed change requests a change to Technical Specification 3.3.3.7.3, its ACTION, and Surveillance Requirement 4.3.3.7.3 for the broad range gas detection system. A change to the Technical Specification Bases 3/4.3.3.7 has been included to support this change.
Existina Specification (Amendment 133 not yet implernented)
See Attachment A Marked-up Specification (revised Amendment 133 panes indicatina channes)
See Attachment B Proposed Specification l
See Attachment C Letter W3F197-0073 See Attachment l' Backaround License Amendment 133 was approved by the NRC and issued on August 19,1997.
The Amendment modified the Technical Specifications to accommodate a new broad range gas detection system. More detail on the operation of the new detection system can be found in license amendment request dated April 11,1997 (see Attachment D).
The Commission granted Waterford 3's request for a change to the Facility Operating License and included a requirement to implement within 90 days of issuance of the Amendment.
During the review of the design change to install the new broad range gas detection system, the potential for an unreviewed safety question was identified by the Plant Operating Review Committee on September 29,1997. Specifically, the new broad range toxic gas detection systems have a self-calibration feature that utilizes the plant instrument air system. This feature improves the system's performance, but does create a scenario, involving a slow increase in toxic gas levels that could cause detection of the toxic gas to be masked. This scenario is a low probability event that 1
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could introduce the possibility of a malfunction that was not previously reviewed and approved by the NRC Staff.
Watorford 3 requests the Technical Specifications be changed such that the current dotection system can remain in service until this issue can be resolved. As the currently installed system does not use instrument air or any other outside air source for calibration, which would be affected by this scenario, it is not susceptible to this potential vulnerability, Descriration and Safety Considerations The proposed change revises the word
- OPERABLE" to remove the two asterisks added by Amendment 133. Additionally, the two asterisks are being removed from the ACTION and the annotation for the two asterisks is being removed. The requirement for a calibration overy 7 days is being added, as the currently Installed system does not automatically perform an equivalent function. Detail sogarding the calibration is being added to the Surveillance. The Bases are being changed to reflect operation of the currently installed broad range gas detection system. The description of the system is being changed to reflect the method of operation of the current system. Additionally, the explanation of the automatic background check, which is performed instead of the CHANNEL CAi.lBRATION, is being deleted, as is the descriptive information of the CHANNEL CHECK and CHANNEL FUNCTIONAL TEST.
Until the issue can be resolved, the currently installed detection system will remain in service. Upon resolution, Waterford 3 intends to resubmit the Technical Specification Change that is Amendment 133. This is acceptable as recent improvements, such as increasing the calibration frequency, have increased the reliability of the current system.
Additionally, the ACTIONS of Technical Specification 3.3.3.7.3 require that, if one broad range gas detection system becomes inoperable, the inoperable detection system shall be restored to OPERABLE status within 7 days or the control room ventilation system must be placed and maintained in the isolate mode of operation within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. With no broad range gas detection system OPERABLE, the Waterford 3 Technical Specification Action requires that within i hour the control room ventilation system must be placed and maintained in the isolate mode of operation.
ihe impact on operator incapacitation and subsequent core damage risk of maintaining the current Technical Specification is unchanged from our Technical Specification prior to Amendment 133, as the required Actions remain the same for system inoperability.
This Technical Specification Change Request wn! retain the pre-amendment 133 Technical Specifications until the issue is resolved. Amendment 133 is in itself in compliance with the regulations, however, the design change required to implement the amendment poses a potential unreviewed safety question. This proposed Technical Specification Change is not inimical to the health and safety of the public as the 2
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Technical Spec!fications require specific Actions (i.e. control room isolation) based on d
system operability such that the impact on operator incapacitation and subsequent core damage risk is negligible.
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No Sianificant Hazards Evaluction i
The proposed change described above shall t e deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:
s 1.
Will operation of the facility in accordance with this proposed change involve a significmit inc: case in the probability or consequences of an accident i
previously evaluated?
Response
No The broad range gas detection system has no effect on the accidents analyzed j
in Chapter 15 of the Final Safety Analysis Report. The habitability of the control i
room will be unchanged by use of the currently installed monitoring system and j
this change to the Technical Specifications. Since this proposed change will 2
make operation of the facility the same as before Amendment 133, the probability and consequences of an ace' dent associated with this change have i
been previously evaluated.
3 Therefore, the proposed change will not involvo a significant increase
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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 Technical Specification change in itself does not chage the design or configuration of the plant. Since this proposed change wdt'make operation of the facility the same as it was before Amendment 133, no new or different type of accident from any accident previously evaluated will be created.
4 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 proposc.d change involve a significant reduction in a margin of safety?
Response
No
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The broad range gas detection system has no effect on a margin of safety as defined by Section 2 of the Technical Specifications. The habitability of the control room will be unchanged from the configuration of the currently installed detection system and this change to the Technical Specifications. The margin of safety remains unchanged from the originallicensing basis of the plant.
Therefore, the proposed change will not involve a significant reduction in a margin of safety.
Safety and Slanificant Hazards Determination Based on the evaluation above, 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 described in the NRC final environmental statement.
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