ML20248B744

Application for Amend to License NPF-38 to Change TS 3.7.1.2,surveillance Requirement 4.7.1.2 & Bases Change for Emergency Feedwater Sys

ML20248B744
Person / Time
Site:	Waterford
Issue date:	05/28/1998
From:	Dugger C ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20248B751	List: ML20248B744 ML20248B761
References
W3F1-98-0080, W3F1-98-80, NUDOCS 9806010374
Download: ML20248B744 (14)

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L y Entergy Operctions. Inc.

K;ilona, LA 70066-0751 Tel 504 739 6660 e Pre d[n ra orm WMerford 3 W3F1-98-0080 A4.05 j PR I

May 28,1998  !

U.S. Nuclear Regulatory Commission Attn: Document Control Desh Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Technical Specification Change Request NPF-38-206 Emergency Feedwater System Gentlemen:

The attached description and no significant hazards evaluation support a change to the Waterford 3 Technical Specifications. This submittal requests a change to Technical Specification 3.7.1.2 and Surveillance Requirement 4.7.1.2 for the Emergency Feedwater System. This Technical Specification Change Request expands and clarifies the current specification. A change to Technical Specification 1 Bases 3/4.7.1.2 has been included to support this change.

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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.

Also included in this submittalis a Bases change previously evaluated and approved in accordance with 10CFR50.59. This Bases change established the minimum

/ l Emergency Feedwater System flow as 575 gpm at 1102 psig vice the previous l minimum flow of 700 gpm at 1163 psig. Waterford 3 recognizes that this l 10CFR50.59 change is currently under review by the NRC as part of Enforcement Action (EA)98-022 (discussed during the March 26,1998 pre-decisional Enforement Conference). This request will be revised if necessary pending the NRC's decision l on this issue.  !

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9906010374 980328 PDR ADOCK 05000382 P PDR :

U Technical Specification Change Request NPF-38-206 Emergency Feedwater System W3F1-98-0080 -

Page 2 May 28,1998 The terminology of this Technical Specification Change Request is modeled after the Auxiliary Feedwater Specification in NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants". Changes were made to be consistent with the Waterford 3 Emergency Feedwater design basis and the format of the current Waterford 3 Technical Specifications.

The circumstances surrounding this change do not meet the NRC's criteria for exigent or emergency review. However, Waterford 3 is currently operating with administrative controls in place due to non-conservative Emergency Feedwater Technical Specifications. Also, portions of the change will facilitate testing during Refuel 9. Therefore, we respectfully request approval of this change prior to Refuel 9 which is scheduled to begin in February 1999. Entergy Operations requests the effective date for this change be within 60 days of approval.

Should you have any questions or comments concerning this request, please contact Mr. Early Ewing at (504) 739-6242.

Very truly yours, TRd- G7b C.M. Dugger Vice President, Operations Waterford 3 CMD/CED/rtk

Attachment:

Affidavit NPF-38-206 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 -

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )

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Entergy Operations, incorporated ) Docket No. 50-382 Waterford 3 Steam Electric Station )

AFFIDAVIT Theodore Roy Leonard being duly sworn, hereby deposes and says that he is General Manager Plant Operations - Waterford 3 of Erstergy Operations, incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Technical Specification Change Request NPF-38-206; that he is familiar with the content thereof; and that the matters s9t forth therein are true and correct to the best of his knowledge, information and belief.

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Theodore Roy Leo 6ard General Manager Plant Operations - Waterford 3 STATE OF LOUISIANA )

) ss PARISH OF ST. CHARLES )

Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this wA day of w~ .1998.

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Notary Public My Commission expires -/ ./J/ .

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e DESCRIPTION AND SAFETY ANAL.YSIS OF PROPOSED CHANGE NPF-3f,-206 This submittal requests a change to Technical Specification 3.7.1.2 and Surveillance Requirement 4.7.1.2 for the Emergency Feedwater (EFW) System. This change expands and clarifies the Specification. Technical Specif cation Bases 3/4.7.1.2 has been revised, using NUREG-1432, ' Standard Technical Specifications Combustion Engineering Plants," as guidance, to support this change: and is included with this submittal.

Existina Specification See Attachment A Marked-up Specification See Attachment B l

References '

See Attachment C Backaround The EFW system automatically supplies feedwater to the steam generators to remove heat from the Reactor Coolant System (RCS) uron the loss of the normal feedwater supply. The EFW pumps take suction from a cc>mmon suction header, which is supplied by two separate and independent lines from the condensate storage pool, and discharge to a common discharge header. From the common discharge header, EFW is supplied to the steam generator's secondary side via separate and independent connections to the main feedwater piping outsi:le containment. The steam generators function as a heat sink for core decay heat, reactor coolant pump heat, and other residual heat. The heat load is dissipated by releasing steam to the atmosphere from I the steam generators via the main steam safety valves or atmospheric dump valves. If i' j the main condenser is available, steam may be released via the steam bypass valves.

l l The EFW system consists of two (50% capacity) motor-driven pumps, one (100% capacity) l steam turbine-driven pump, and two diverse flow paths. (Refer to the EFW simplified flow path figure provided in Reference 1). One flow path supplies steam generator 1 and the second flow path supplies steam generator 2. A flow path consists of piping, valves, and  !

components from the common pump discharge header through two parallel !egs to the respective steam generator. Each parallel leg contd.ns a flow control valve and an isolation 1

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valve in series. One flow path supplying one steam generator is capable of cooling the unit to shutdown cooling entry conditions. Either of the two parallellegs in a steam generator flow path is capable of supplying 100% of the flow required for the heat removal safety function.

Each motor-driven EFW pump is powered from an independent Class 1E power supply.

The motor-driven EFW pumps supply a common header which is connected to each steam generator flow path. Each flow path contains DC powered pneumatic control valves actuated to provide flow to the appropriate steam generator by the Emergency .

Feedwater Actuation System (EFAS). Each motor-driven EFW pump is capable of i feeding either steam generator.

The EFW pump-turbine receives steam from both main steam headers upstream of the main steam isolation valves (MSIV). Each of the steam feed lines will supply 100% of the requirements of the EFW pump-turbine. The turbine-driven EFW pump supplies the common header which is connected to each steam generator flow path. Each flow path contains DC powered pneumatic control valves actuated to provide flow to the appropriate steam generator by EFAS. The steam turbine-driven EFW pump is capable of feeding either steam generator.

As stated above, each steam generator flow path contains two parallel flow legs either of which is capable of supplying 100% of the flow required for the heat removal safety function.

Each parallel leg contains a flow control valve and an isolation valve in series. These valves 3 are fail open pneumatic valves. Safety-related nitrogen accumulators serve as a backup to the instrument air system for these valves. Each nitrogen accumulator supplies a pair of EFW valves (one flow control valve and one isolation valve in redundant parallel legs to the same steam generator).

The EFW system is capable of delivering sufficient fle,w to remove decay heat and reduce the RCS temperature to a point at which shutdown r,ooling may be placed into service. The EFW System is operated for emergency situatione, during surveillance testing, and infrequently during shutdown conditions to fill the steam generators. The non-safety related auxiliary feedwater system supplies feedwater b the steam generators during normal unit startup, shutdown, and hot standby conditions.

The EFW System actuates automatically on low steam generator level by the EFAS.

The EFAS logic is designed to feed either or both steam generators with low levels.

The Main Steam isolation System (MSIS) in conjunction with EFAS will isolate the EFW System from a steam generator having a significantly lower steam pressure than the other steam generator to ensure EFW is supplied only to the intact steam generator.

The EFAS automatically actuates the EFW pumps and associated valves and controls l when required to ensure an adequate feedwater supply to the steam generators. DC powered pneumatic valves are provided for each EFW line to control the EFW flow to '

each steam generator.

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A concern was raised at Waterford 3 over the need to enter Technical Specification ACTION 3.7.1.2.a when a steam supply to the turbine-driven EFW pump is either out of service or inoperable. The current Technical Specification Limiting Condition for Operation (LCO) requires that the pump be " capable of being powered from an OPERABLE steam supply system." Because there are separate steam supplies (one from each steam generator), a literal application of the Technical Specification resulted in not entering the Technical Specification ACTION when only one steam supply was either out of service, or inoperable. The cause of this event was the misleading wording in Technical Specification LCO 3.7.1.2.b. This event was described in Licensee Event Report (LER) 96-002-00 (Reference 2). In LER 96-002-00, Waterford 3 committed to adopt an EFW Technical Specification similar to that in NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants."

On September 25,1996, it was identified that testing performed may not have conclusively demonstrated the normal flow path from the condensate storage pool through each EFW pump to each of the steam generators was available, as required by Surveillance Requirement 4.7.1.2.d. Although this condition was deemed not to be reportable, it represented a weakness in the Waterford 3 EFW Technical Specification and Bases.

On November 12,1996, an issue was raised concerning the EFW flow control and isolation valves. Upcoming testing required the respectivo nitrogen accumulators to be isolated from these valves. Technical Specification 3.7.1.2 did not clearly specify the ACTION to be entered with these EFW valves inoperable. While the Technical Specification discussed pumps and flow paths in the LCO, it only provides ACTIONS for inoperable pumps. The flow paths are not readily associated with individual pumps or trains.

Description and Safety Considerations This submittal requests a change to Technical Specification 3.7.1.2 and Surveillance Requirement 4.7.1.2 for the EFW system. This change expands ano clarifies the Specification by:

. Rewording the Limiting Condition for Operation (LCO) to require "three EFW pumps and two flow paths" OPERABLE and moving specific pump descriptions to the Bases.

. Including new ACTION "a" to address EFW steam supply system inoperability similar to NUREG-1432.

. Changing old ACTION "a" to new Action "b" and incorporating ACTION for an inoperable flow path (capable of delivering 100% flow.)

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. Changing old ACTION "b" to new Action "c" and incorporating ACTION for an inoperable flow path (not capable of delivering 100% flow.) ,

e Changing old ACTION "c" to new Action "d" and incorporating ACTION for two flow paths not capable of delivering 100% flow.

• Reformatting and rewording Surveillance Requirement "a" similar to NUREG- q 1432.

• Revising Surveillance Requirement "b" to remove test specific acceptance criteria, specify EFW pumps be demonstrated OPERABLE pursuant to Specification. 4.0.5, and replace the 4.0.4 exception with the applicable exception from NUREG-1432.

. Revising Surveillance Requirement "c" to remove the words "during shutdown," change "... emergency feedwater actuation test signal" to "... actual or simulated actuation signal," and add the applicable exception from NUREG-1432 for turbine-driven EFW pump related testing. These changes are all similar to NUREG-1432.

• Revising and rewording Surveillance Requirement "d" to require performance prior to entering Mode 2 and deleting the Specification 4.0.4 exception similar I to NUREG-1432.

Technical Specification Basos 3/4.7.1.2 has been completely revised, using NUREG-1432 as guidance.

The OPERABILITY of EFW ensures that the RCS can be cooled down to SDC entry conditions from normal operating conditions in the event of a loss of feedwater. The OPERABILITY of EFW also ensures this function is performed in the event of a totalloss-of-offsite power and a single active failure.

The design basis of the EFW system is to supply water to the steam generator to remove decay heat, reactor coolant pump heat, and other residual heat by delivering at least the minimum required flow rate to the steam generators at pressures corresponding to the lowest main steam safety valve set pressure plus 3% (1102 psig).

The limiting accident for EFW flow is the feedwater line break (FWLB). The FWLB requires an EFW flow of 575 gpm be delivered to the intact steam generator at a pressure of 1102 psig. The two motor-driven pumps combined or the turbine-driven i pump alone are capable of supplying 575 gpm to the steam generators at 1102 psig.

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The current Waterford 3 Technical Specification LCO requires that three EFW pumps and associated flow paths be OPERABLE. Due to the unique Waterford 3 EFW design, flow paths are not readily associated to a pump or train. This LCO is being  ;

revised to require that three pumps and two flow paths be OPERABLE. Pump specific  !

details are being relocated to the Bases and reworded to eliminate the misleading 4

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,' l wording concerning ' OPERABLE steam supply system". This will ensure that the EFW system will perform its design safety function to mitigate the consequences of events that assume a loss of feedwater. This will also ensure that EFW will perform its design safety function during events involving a total loss-of-offsite power and a single active failure. This change to the LCO is considered to be administrative. Further the Bases are being expanded to include a definition of the flow paths and an explanation of the LCO, ACTIONS, and Surveillance Requirements similar to that contained in NUREG-1432.

I One new ACTION is proposed:

This new ACTION (proposed ACTION "a") provides more explidt requirements relative l to the steam supplies for the turbine-driven pump and clarifies f ae need to have both steam supplies OPERABLE. This ACTION allows one of the two steam supplies to be inoperable for up to 7 days in accordance with NUREG-14?2. This change is less restrictive in comparison to the implementation of the current Technical Specification; however, the 7 day con.pletion time is reasonable based on the redundant OPERABLE steam supply to the turbine-driven EFW pump steam turbine, the availability of redundant OPERABLE motor-driven EFW pumps, and the low probability of an event l requiring the inoperable steam supply to the turbine-driven EFW pump.

The three existing ACTIONS have been revised to include requirements for inoperable flow paths. The Bases have been revised to add explanations for the ACTION requirements utilizing NUREG-1432 as guidance.

I The ACTION for one pump inoperable (existing ACTION "a", proposed ACTION "b") I has been revised to specify one pump inoperable for reasons other than those described in new ACTION "a". This ACTION has also been expanded to include one flow path inoperable (but capable of delivering 100% flow.) This ACTION continues to provide a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time for an inoperable pump and as proposed will allow a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time for an inoperable flow path provided the inoperable flow path is capable of delivering 100% of the required EFW flow to the affected steam generator.

This change is less restrictive in comparison to the current Technical Specification but is acceptable based on the availability of two OPERABLE EFW pumps, a redundant OPERABLE flow path capable of feeding the other steam generator and the capability of the inoperable flow path to deliver 100% of the required EFW flow to the affected steam generator. A risk analysis has been performed which supports a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> l completion time for an inoperable flow path (which is incapable of passing any flow) l and shows it is risk insignificant due to the low probability of having an event requiring the inoperable flow path during this 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period. Due to the diverse design of the steam generator flow paths, the inoperable flow path will still be capable of delivering 100% of the required EFW flow to the steam generator due to the fail open design of the EFW valves and the redundant parallel legs in each flow path.

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t The ACTION for two pumps inoperable (existing ACTION "b", proposed ACTION "c")

has been expanded to include one flow path inoperable (not capable of delivering 100%

flow.) Due to the seriousness of this condition, the ACTION requires the unit be placed in HOT STANDBY in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

This chm y is considered to be more restrictive due to the immediate shutdown requirement for the inoperable flow path.

The ACTION for three pumps inoperable (existing ACT!ON "c", proposed ACTION "d")

I has been expanded to include two flow paths not capable of delivering 100% flow. With two flow paths inoperable such that neither flow path is capable of delivering 100% flow the unit is in a seriously deg.aded condition just as it is with all three pumps inoperable.

This ACTION continues to require that immediate action be taken to restore one pump OPERABLE and as proposed would require immediate action be taken to restore one flow path OPERABLE. Also, it is proposed to clarify that Technical Specification ACTIONS requiring MODE changes are suspended, until the EFW system is capable of delivering 100% flow to one steam generator, which is similar to a note in NUREG-1432. This change is consistent with the intent of the current EFW Technical Specification and is considered to be an administrative change.

The Surveillance Requirements were revised, in most cases, to be more consistent with NUREG-1432, allowing flexibility in testing, and clarifying the applicable modes by which the specified Surveillance Requirement must be performed.

Existing Surveillance Requirement "a"is being reworded and reformatted to be consistent with NUREG-1432. The intent of proposed Surveillance Requirement "a" continues to be to verify all valves not locked, sealed, or otherwise secured in position l are in their correct position once per 31 days. This is considered to be an administrative ch8nge.

Existing Surveillance Requirement "b" requires that a single flow point be verified for each EFW pump to ensure pump performance has not degraded below the point where it is capable of performing its safety function. Proposed Surveillance Requirement "b"is revised to test the EFW pumps pursuant to Specification 4.0.5. Specification 4.0.5 invokes the Inservice Test Program in accordance with Section XI of the ASME Boiler and Pressure Vessel Code. Specific pump acceptance criteria will also be deleted from the Surveillance Requirement in accordance with NUREG-1432. This is considered to be an administrative change and is acceptable because testing pursuant to the Inservice Test Program will continue to ensure pump performance has not degraded below the point where it is capable of performing its safety functica.

Proposed Surveillance Requirement "b" has also been modified by the removal of the exception from Technical Specification 4.0.4 provisions and the addition of the applicable exception for this Specification extracted from NUREG-1432. The current exception from the provisions of Specification 4.0.4 allows entry into the mode of applicability (MODE 3) without completion of the Surveillance Requirement. This exception is necessary because some post maintenance activities which may need to 6

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be completed prior to performing this Surveillance Requirement can not be completed until the unit is heated up sufficiently to establish the required steam generator pressure or suitable test conditions. The addition of the requirement to have the Surveillance Requirement completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after reaching a steam generator pressure of 750 psig clarifies the existing exception so that future interpretation of these requirements will no longer be necessary. Forty-eight (48) hours is considered to be adequate time for completing post maintenance activities (such as the dynamic calibration of the speed control unit) and the surveillance test on the turbine-driven EFW pump. Additional clarification of the proposed 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> grace period has been added to the Bases. The Bases clarifies that this grace period is applicable for both Section XI testing and any other required post maintenance activities on the turbine-driven pump which require steam generator pressures achievable only after entering MODE 3. This is considered to be an administrative change since this clarification is consistent with the current Waterford 3 interpretation of this Surveillance Requirement and the 4.0.4 exception.

Existing Surveillance Requirement "c" has been revised to be consistent with NUREG-932. The provision to perform the Surveillance Requirement only while shutdown has been deleted to allow performance during any MODE. The applicable exception from NUREG-1432 has been added to permit the unit to transition from MODE 4 to MODE 3 prior to completing the required testing related to the turbine-driven pump. The wording in items 1 and 2 has been changed from, "... upon receipt of an emergency feedwater actuation test signal" to " .. upon receipt of an actual or simulated actuation signal." j These changes provided increased flexibility and clarify the MODES by which testing must be completed and while less restrictive in comparison to the current Technical Specification are acceptable because testing in accordance with the proposed Surveillance Requirement will continue to ensure the EFW system will respond appropriately upon receipt of an actual actuation signal.

Existing Surveillance Requirement "d" has also been revised to be consistent with j NUREG-1432. The proposed Surveillance Requirement continues to verify EFW '

system alignment following extended outages or whenever feedwater cleaning through the EFW line has been performed. The proposed Surveillance Requirement requires this verification to be completed prior to entry into MODE 2. While this is less restrictive in comparison to the current Technical Specification, it is acceptable because EFW l system alignment will continue to be verified before sufficient core heat is generated. l l

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t 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 The proposed changes included in this amendment request are being made to the Emergency Feedwater (EFW) System Technical Specification. These changes include clarification of the LCO, a 7 day allowed outage time for an inoperable steam suppiy, additional ACTION requirements for inoperable flow path (s), a requirement to test tne pumps pursuant to Specification 4.0.5, and rewording of numerous Surveillance Requirements consistent with NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants."

The administrative and more restrictive changes will not affect the assumptions, design parameters, or results of any accident previously evaluated. The accident mitigation features of the plant are not affected by these proposed changes. The proposed changes do not add or modify any existing equipment.

The administrative change to test EFW pumps pursuant to the Inservice Test Program will ensure the EFW pumps are tested against the more restrictive of the data points required by either the safety analysis or the Inservice Test Program. Therefore, the proposed administrative changes do not involve a significant increase in the probability or consequences of any accident previously evaluated.

The less restrictive changes (allowing 7 days for an inoperable pump due to an inoperable steam supply, performing Surveillance Requirements during other than shutdown conditions, allowing the use of actual actuation signals in addition to test signals, and delaying the requirement to complete Surveillance Requirement "d" to just prior to Mode 2) will not affect the assumptions, design parameters, or results of any accident previously evaluated. The accident mitigation features of the plant are not affected by these proposed changes. The proposed changes do not add or modify any existing equipment. Therefore, the proposed less restrictive changes do not involve a significant increase in the probability or consequences of any accident previously evaluated.

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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 changes included in this amendment request are being made to the EFW System Technical Specification. These changes include clarification of the LCO, a 7 day allowed outage time for an inoperable steam supply, additional ACTION requirements for inoperable flow path (s), a requirement to test the pumps pursuant to Specification 4.0.5, and rewording of numerous Surveillance Requirements consistent with NUREG-1432. These changes do not alter the design nor configuration of the plant. There has been no physical change to >

plant systems, structures, or components. The proposed changes will not reduce the ability of any of the safety-related equipment required to mitigate Anticipated Operational Occurrences or accidents. Therefore, the proposed changes 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 The proposed changes included in this amendment request are being made to the EFW System Technical Specification. These changes include clarification of the LCO, a 7 day allowed outage time for an inoperable steam supply, additional ACTION requirements for inoperable flow path (s), a requirement to test the pumps pursuant to Specification 4.0.5, and rewording of numerous Surveillance Requirements consistent with NUREG-1432.

The proposed change to the LCO requiring three pumps and two flow paths be OPERABLE maintains the functionality of the EFW such that it is capab!e of performing its design function as assumed in the Updated Final Safety Analysis Report. If the functionality of the system is not maintained, Technical Specifications require ACTIONS be taken, within specified time limitations, to restore EFW to OPERABLE status or shutdown the reactor. This action is consistent with the existing Technical Specification and NUREG-1432.

The allowed outage time for one inoperable steam supply has been increased from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days in accordance with NUREG-1432. This is acceptable due to the redundant OPERABLE steam supply, the availability of redundant OPERABLE motor-driven EFW pumps, and the low probability of an event requiring the inoperable steam supply. This change is consistent (other than format) with NUREG-1432 and has therefore been previously approved by the NRC.

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The ACTION for one flow path inoperable (but capable of delivering 100% flow) as proposed will allow a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time for an inoperable flow path.

This change is acceptable based on the availability of at least two OPERABLE EFW pumps, a redundant OPERABLE flow path capable of feeding the other steam generator and the capability of the inoperable flow path to deliver 100% of the required EFW flow to the affected steam generator.

The ACTION for one flow path inoperable (not capable of delivering 100% flow) as proposed requires a unit shutdown be initiated immediately. This change is appropriate due to the seriousness of the condition and is acceptable due to the availability of the remaining operable flow path to support the unit shut down.

The ACTION for two flow paths not capable of delivering 100% flow is the same as that for three pumps inoperable. With two flow paths inoperable such that neither flow path is capable of delivering 100% flow the unit is in a seriously degraded condition just as it is with all three pumps inoperable. The ACTION as proposed requires that immediate action be taken to restore one flow path to OPERABLE status. This change is consistent with the intent of the current EFW Technical Specification.

Testing pursuant to Specification 4.0.5 (Inservice Testing Program) as proposed for Surveillance Requirement 'b' will ensure the EFW pumps are tested against the more restrictive of the data points required by either the safety analysis or ASME Section XI. ]

The remaining changes to the EFW Technical Specification are consistent (other than format) with NUREG-1432 and have therefore been previously approved by the NRC.

Therefore, based on the above discussion, the proposed change will not involve a significant reduction in a margin of safety.

Safety and Significant 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 safsty 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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4 NPF-38-206 ATTACHMENT A Existing Specifications l

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