ML20236U728
| ML20236U728 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/29/1998 |
| From: | Dugger C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20236U731 | List: |
| References | |
| W3F1-98-0108, W3F1-98-108, NUDOCS 9807300402 | |
| Download: ML20236U728 (7) | |
Text
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.e Ent:rgy Operations. Inc.
Killona, LA 70066 Tel 504 739 6242 l
Early C Ewing,111 I
a afety & Regulatory Aff airs W3F1-98-0108 A4.05 PR July 29,1998 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-38-208 Gentlemen:
The attached description supports an administrative change to Waterford Technical Specification (TS) 6.9.1.11.1. The proposed change replaces a reference to the ABB Combustion Engineering (CE) Small Break Loss-of-Coolant Accident (SBLOCA)
Emergency Core Cooling System (ECCS) Performance Evaluation Model. The existing reference is Supplement 1 of the " Calculative Methods for the CE Small Break LOCA Evaluation Model." This change would replace the reference to Supp; ament 1 with a reference to Supplement 2 of the " Calculative Methods for the CE Small Break LOCA Evaluation Model."
This request is associated with a change in the methodology used to obtain the SBLOCA results. As a result of a condition described in Licensee Event Report (LER) 97-033-00, an analysis using a reduced High Pressure Safety injection (HPSI) pump flow rate was performed with a new, NRC approved model. NRC approval of
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the new model was obtained on December 16,1997, and the results of the analysis
/f using this model were submitted by Waterford for NRC review in W3F1-98-0090 on April 30,1998.
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The proposed change lias been evaluated in accordance with 10 CFR 50.91(a)(1) using the criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards consideration. The bases for these determinations 9807300402 980729 DR ADOCK 05000382' PDR l
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Technical Specification Change Request NPF-38-208 W3F1-98-0108 Page 2 July 29,1998 are included in the attached submittal. The circumstances surrounding this change do not meet the NRC's criteria for exigent or emergency review. However, due to the need to revise the Technical Specifications to the current methodology used in the SBLOCA analysis, we respectfully request an expeditious review. Waterford 3 requests that the implementation date for this change be within 60 days of NRC issuance of the amendment.
Should you have any questions or comments concerning this request, please contact Early Ewing at (504) 739-6242, Very truly yours, Ik h3 C.M. Dugger Vice President, Operations Waterford 3 l
CMD/BVRhtk Attachments:
Affidavit NPF-38-208 l
cc:
E.W. Merschoff, NRC Region IV l
C.P. Patel, NRC-NRR j
J. Smith
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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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I AFFIDAVIT Theodore R. Leonard, being duly sworn, hereby deposes and says that he is General Manager of Plant Operations - Waterford 3 of Entergy Operations, incorporated; that he is duly authori7.cd 5 sign and file with the Nuclear Regulatory Commission the attached Technical Specificata Change Request NPF-38-208; 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.
Mk Ther.Jore R. Leonard General Manager of Plant Operations - Waterford 3 STATF. 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 25'O day of b4
.1998.
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Ms Notary Public My Commission expires
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l DESCRIPTION AND NO SIGNIFICANT HAZARDS EVALUATION 3
OF PROPOSED CHANGE NPF-38-208 I
This submittal requests a change to TS 6.9.1.11.1, " Analytical Methods used to Determine the Core Operating Limits." The proposed change repl. aces a reference to the ABB Combustion Engineering (CE) Small Break Loss-of-Coolant Accident l
(SBLOCA) Emergency Core Cooling System (ECCS) Performance Evaluation Model.
The existing reference is Supplement 1 of the " Calculative Methods for the CE Small Break LOCA Evaluation Model." The proposed reference is Supplement 2 of the
" Calculative Methods for the CE Small Break LOCA Evaluation Model."
Existina Specification See Attachment A Proposed Specification See Attachment B References Sb Attachment C Backaround The SBLOCA ECCS performance analysis is performed to demonstrate conformance to the ECCS acceptance criteria for light water nuclear power reactors given in the Code of Federal Regulations, Title 10, Part 50, Section 60.46 (10 CFR 50.46). The SBLOCA ECCS analysis for Waterford 3 was performed with the Supplement 2 version (referred to as the S2M or Supplement 2 Model) of ABB's SBLOCA evaluation model.
NRC approval was obtained on December 16,1997 (P'"arence 1) for use of the S2M in licensing applications of CE design pressurized w-actors. The previous Waterford 3 SBLOCA ECCS performance analysis used the Supplement 1 version of ABB's SBLOCA evaluation model(Reference 2). The primary difference between the two versions is the introduction of a radiation-to-steam model in the hot rod heatup analysis computer code, PARCH. Improvements were also made to the PARCH model for convection heat transfer to steam and to the coupling between the fuel rod and coolant l
channel energy models, 1
Description and Safety Considerations In order to determine the impact of a reduction in HPSI flow discussed in Licensee Event Report (LER) 97-033-00, Waterford performed an analysis using the new, approved ABB CE SBLOCA model. The results of this analysis were submitted to the NRC in W3F1-98-0090 on April 30,1998. After incorporating the reduction in HPSI flow, the results of the new ECCS evaluation model remain within 10 CFR 50.46 limits.
Due to the change in methodology used to obtain the SBLOCA results, this request is being submitted to propose a change to TS 6.9.1.11.1, " Analytical Methods used to Determine the Core Operating Limits." The proposed change revises the reference given in the TS for the ABB CE SBLOCA ECCS Performance Evaluation Model.
No Significant 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 involve a significant increase in the probability or consequences of an accident previously evaluated?
Response
No I
The SBLOCA ECCS performance evaluation is conducted to demonstrate
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conformance of light water nuclear power reactors to the ECCS acceptance criteria of 10 CFR 50.46. The proposed change is associated with an analysis l
performed using t'
'w Supplement 2 version of the ABB CE SBLOCA Model I
(S2M). The prime ictive of the analysis using the new model was to determine the imp a reduction in High Pressure Safety injection (HPSI) pump flow rate due to increased surveillance test measurement uncertainty.
NRC approval of the new S2M model for use in licensing applications of CE i
design pressurized water reactors was obtained on December 16,1997 (Reference 1).
A comparison of the Waterford 3 results for 'he limiting SBLOCA scenario using the new S2M model against the criteria of 10 CFR 50.46(b) is summarized below:
i Parameter Result Criterion Peak Cladding Temperature 1929 F 2200 F l
Maximum Cladding Oxidation 8.09 %
17 %
l Core-wide Cladding Oxidation
<0.58%
1%
Coolable Geometry Maintained Yes Yes 2
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These results remain within the criteria of 10 CFR 50.46. Thus, application of the'new S2M model to the ECCS at Waterford 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 frcm any accident previously evaluated?
Response
No.
The proposed change will not create any new system connections or interactions. Thus, no new modes of failure are introduced. The revised methods used in the new SBLOCA evaluation model and their impact has been reviewed and approved by the NRC (Reference 1). Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
1 3.
Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?
Response
No I
The proposed change does not alter the ability of the ECCS to maintain i
compliance with 10CFR50.46 criteria. The revised methods used in the new
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SBLOCA evaluation model and their impact has been reviewed and approved by j
the NRC (Reference 1). Therefore, the proposed change will not involve a significant reduction in a margin of safety.
Safety and Significant Hazards Determination l
Based on the above No Significant Hazards Evaluation, it is concluded that: (1) the I
proposed change does not constitute a significant hazards consideration as defined by l
10CFR50.92; and (2) there is a reasonable assurance that the health and safety of the l
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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NPF-38-208 ATTACHMENT A EXISTING SPECIFICATIONS l
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