Text

Proposed Tech Specs Adding Footnote to Action Statements to Allow CR Ventilation Sys to Be Unisolated Periodically Under Administrative Controls
	ML20249C790
Person / Time
Site:	Waterford
Issue date:	06/29/1998
From:	; ENTERGY OPERATIONS, INC.
To:	;
Shared Package
ML20249C787	List: ML20249C786; ML20249C790; ML20249C800; ML20249C802; ML20249C809; ML20249C813;
References
	NUDOCS 9807010201
	Download: ML20249C790 (11)
	v • d • e

INSTRUMENTATION CHEMICAL DETECTION SYSTEMS CHLORINE DETECTION SYSTEM LIMITING CONDITION FOR OPERATION 3.3.3.7.1 Two independent chlorine detection systems, with their alarm / trip setpoints adjusted to actuate at a chlorine concentration of less than or equal to 3 ppe, shall be OPERABLE.

APPLICABILITY: All MODES.

ACTION:

a. With one chlorine detection system inoperable, restore the inoperable detection system to OPERA 8LE status within 7 days or within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months initiate and maintain operation of the control room ventilation system in the isolate mode of operation. [

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b. With no chlorine detection system OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of the control room ventilation system in the isolate mode of operation.

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c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.7.1 Each chlorine detection system shall be demonstrated OPERABLE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and a CHANNEL CALIBRATION at least once per 31 days.

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WATERFORD - UNIT 3 3/4 3-47 AMENDMENT NO. 2I,53

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INSTRUMENTATION CHEMICAL DETECTION SYSTEMS BROAD RANGE GAS DETECTION LIMITING CONDITION FOR OPERATION l

3.3.3.7.3 Two independent broad range gas detection systems shall be OPERABLE with their alarm / trip setpoints adjusted to actuate at the lowest achievable IDLH gas concentration level of detectable toxic gases

providing reliable operation.

APPLICABILITY: All MODES.

ACTION:

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a. With one broad range gas detection system inoperable, restore the inoperable detection system to OPERABLE status within 7 days or within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months initiate and maintain operation of the control room ventilation system in the isolate mode of operation.

b. With no broad range gas detection system OPEPABLE, within I hour initiate and maintain operation of the control room ventilation system in the isolate mode of operation.

c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE RE0VIREMENTS 4.3.3.7.3 Each broad range gas detection system shall be demonstrated OPERABLE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a CHANNEL FUNCTIONAL TEST at least once per 31 days, and a channel calibration at least once per 7 days. Calibration will consist of the introduction of a standard gas and adjusting the instrument sensitivity based on the calibration gas relationship of the standard gas to the calibrating gas.

Including Amonia l WATERFORD - UNIT 3 3/4 3-48a AMENDMENT NO. 30,53,133,135

INSTRUMENTATION BASES monitoring instrumentation. Therefore, requiring restoration of one I inoperable channel limits the risk that the variable will be in a degraded condition should an accident occur. If the 7 day requirement is not met, the l

plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The completion time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

TS 3/4.3.3.6 applies to the following instrumentation: ESFIPI6750 A, ESFIPR6750 B, ESFIPR6755 A&B, RC ITIO122 HA, RC ITIO112 HB, RC ITIO122 CA, RC ITIO112 CB, RC IPIO102 A,B,C,&D, RC ILI0llo X&Y, SG ILIlll3 A,B,C,&D, SG ILIll23 A,B,C,&D, SG ILIll15 A2&B2, SG ILI1125 A2&B2, SI ILI7145 A, SI ILR7145 B, all CET's, all Category 1 Containment Isolation Valve Position Indicators, EFWILI9013 A&B, HJTC's, and ENIIJI0001 C&D.

1/4.3.3.7 CHEMICAL DETECTION SYSTEMS The chemical detection systems are the chlorine and broad range toxic gas detection systems.

The OPERABILITY of the chemical detection systems ensures that sufficient capability is available to promptly detect and initiate protective action in

! the event of an accidental chemical release.

l The chemical detection systems provide prompt detection of toxic gas re-leases which could pose an actual threat to safety of the nuclear power plant or significantly hamper site personnel in performance of duties necessary for the safe operation of the plant.

l The broad range toxic gas detection system operates on the principal of gas photolonization, and therefore, the system is sensitive to a broad range of gases.* The system is therefore sensitive to both atmospheric and chemical composition normal fluctuations affecting the Waterford 3 site. The setpoint for the system is thus based on testing and operating experience, and the setpoint is set at the lowest achievable IDLH gas concentr. tion providing reliable operation and the optimum detection of toxic gases. The setpoint is therefore subject to change wherein necessitated by operating experience such as a result of changes in the Waterford 3 area chemical atmospheric profile.

l The setpoint is established and controlled by procedure.

3/4.3.3.8 This section deleted 3/4.3.3.9 This section deleted l

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Including Amononia Amendment No. 14,20,50,104, WATERFORD - UNIT 3 8 3/4 3-3a 122,133,135 l

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NPF-38-205 ATTACHMENT B PROPOSED SPECIFICATIONS L-____________.

INSTRUMENTATION CHEMICAL DETECTION SYSTEMS

, CHLORINE DETECTION SYSTEM l

l LIMITING CONDITION FOR OPERATION 3.3.3.7.1 Two independent chlorine detection systefas, with their alarm / trip setpoints adjusted to actuate at a chlorine concentration of less than or equal to 3 ppm, shall be OPERABLE.

l APPLICABILITY: All MODES.

ACTIONh

a. With one chlorine detection system inoperable, restore the inoperable detection system to OPERABLE status within 7 days or within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months initiate and maintain operation of the control room ventilation system in the isolate mode of operation. [ {

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b. With no chlorine detection system OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of the control room ventilation system in the isolate mode of operation. l i

l c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS , 4.3.3.7.1 Each chlorine detection system shall be demonstrated OPERA 8LE by

, performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and a CHANNEL CALIBRATION at least once per 31 days.

4 The c.nM co.m ve.n&dat**^ asb ma' L w a5

d " d udte sk&strative c..tr.\s 4r f: 2. h. e s p e 2A boe period . 0%*e R ACTtW5 Sh regJet. % c Ar.\ room + b, plaud

' Iso \Et. or redrc= lake t% Ae. d op,c dion el. nd .

I APPh sde. oper % is ac.cor dena Ji%, -% bokfre.,

WATERFORD - UNIT 3 3/4 3-47 AMEN 0 MENT NO. 2Z,53

INSTRUMENTATION CHEMICAL DETECTION SYSTEMS BROAD RANGE GAS DETECTION l LIMITING CONDITION FOR OPERATION j l

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, 3.3.3.7.3 Two independent broad range gas detection systems shall be OPERABLE with their alare/ trip setpoints adjusted to actuate at the lowest achievable IDLH gas concentration level of detectable toxic gases

providing reliable operation.

, APPLICABILITY: All MODES.

ACTION: l l a. With one broad range gas detection sy' stem inoperable, restore the inoperable detection system to OPERABLE status within 7 days or within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months initiate and maintain operation of the i control room ventilation system in the isolate mode of operation. l i

b. With no broad range gas detection system OPERABLE, within I hour !

initiate and maintain operation of the control room ventilation .

I system in the isolate mode of operation. !

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c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE-REQUIREMENTS 4.3.3.7.3 Each broad range gas detection system shall be demonstrated OPERABLE by performance of a CHANNEL CHECK at least ons:e per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a CHANNEL FUNCTIONAL TEST at least once per 31 days, and a channel calibration at least once per 7 days. Calibration will consist of the introduction of a standard gas and adjusting the instrument sensitivity based on the calibration gas-relationship of the standard gas to the calibrating gas.

The c.a h .\ roo m v e d il*+'*n s e 4 * * * *1 k *^i5' ""

con 4rds Ge$ g Lc3 pe :L4 Le pw. A . che T5 Actio A **Y t% set ~k caskre\ cosm ve64.\ Aa n ps% ko & o t*'d \^ %

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m. Ae. 9 op.c.4 on cb m4 acek Me owaby in a ce . e c1 * ^ ut. g4 m kde.de.

Including Ammonia l' W

WATERFORD - UNIT 3 3/4 3-48a AMENDMENT NO. 20,53,133,135

INSTRUMENTATION BASES monitoring instrumentation. Therefore, requiring restoration of one inoperable channel limits the risk that the variable will be in a degraded condition-should an accident occur. If the 7 day requirement is not met, the i plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The completion time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

TS 3/4.3.3.6 applies to the following instrumentation: ESFIPI6750 A, ESFIPR6750 B, ESFIPR6755 A&B, RC ITIO122 HA, RC ITI0112 HB, RC ITIO122 CA, RC ITI0112 CB, RC IPIO102 A,B,C,&D, RC ILIO 110 X&Y, SG ILI1113 A,B,C,&D, SG ILI1123 A,B,C,&D, SG ILI1115 A2&B2, SG ILI1125 A2&B2, SI ILI7145 A, SI ILR7145 B, all CET's, all Category 1 Containment Isolation Valve Position Indicators, EFWILI9013 A&B, HJTC's, and ENI!JI0001 C&D.

3/4.3.3.7 CHEMICAL DETECTION SYSTEMS The chemical detection systems are the chlorine and broad range toxic gas detection systems.

, The OPERABILITY of the chemical detection systems ensures that sufficient l capability is available to promptly detect and initiate protective action in the event of an accidental chemical release.

The chemical detection systems provide prompt detection of toxic gas re-leases which could pose an actual threat to safety of the nuclear power plant

or significantly hamper site personnel in performance of duties necessary for

! the safe operation of the plant.

The broad range toxic gas detection system operates on the principal of gas photoionization, and therefore, the system is sensitive to a broad range I

of gases.* The system is therefore sensitive to both atmospheric and chemical composition normal fluctuations affecting the Waterford 3 site. The setpoint !

for the system is thus based on testing and operating experience, and the setpoint is set at the lowest achievable IDLH gas concentration providing-reliable' operation and the optimum detection of toxic gases. The setpoint is therefore subject to change wherein necessitated by operating experience such

! as a result of changes in the Waterford 3 area chemical atmospheric profile.

The setpoint is established and controlled by procedure.

-3/4.3.3.8 This section deleted 3/4.3.3.9 This section deleted

Including Amononia Amendment No. 10,20,50,100, WATERFORD - UNIT 3 8 3/4 3-3a 122,133,135

INSERT BASES 3/4.3.3.7 When the control room ventilation system is placed in the isolate mode of operation for a prolonged period of time, carbon dioxide levels in the control room envelope increase, i as described in calculation EC-M96-002. Carbon dioxide can affect operator performance as described in The ASHRAE Handbook, Environmental Control For Survival. Therefore, the control room ventilation system may be unisolated under administrative controls for s; 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period to purge the control room envelope. The administrative controls shall consist of requirements to:

1) prohibit unisolating the ontrol room envelope if a toxic chemical release is in progress and is a direct threat to Waterford 3,

2) isolate the control room envelope if Waterford 3 is alerted to a toxic chemical release that is a direct threat to Waterford 3,

3) contact the St. Charles Parish Emergency Operations Center within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to unisolating the control room envelope to ensure there is no toxic chemical release in progress that is a direct threat to Waterford 3, and

4) verify the St. Charles Parish Industrial Hotline is operational within i hour prior to unisolating the control room envelope.

The administrative controls provide reasonable assurance that while the control room envelope is unisolated, when both trains of the broad range gas or the chlorine monitors are out !

of service, Waterford 3 will be alerted of a toxic chemical event and take action to limit the exposure to the control room staff. Contacting the St. Charles Parish Emergency Operations Center prior to unisolating the control room envelope provides assurance that a toxic chemical release that is a direct threat to Waterford 3 is not taking place prior to unisolating the control room envelope. Verifying the St. Charies Parish Industrial Hotline is operational provides a means of rapid notification in the event of a toxic chemical event in the vicinity of Waterford 3.

The administrative controls will also preclude unisolating the control room envelope if a toxic chemical release is a direct threat to Waterford 3.

The basis for allowing the control room to be unisolated for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period is that it allows for at least one exchange of air in the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months period the control room i envelope can be unisolated. This is a result of an air exchange rate of 0.6 exchanges per hour usihg the normal control room outside air intake. When the control room envelope is in recirculation (using the emergency outside air intakes), it takes approximately 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months for one complete air exchange (at an air exchange rate of 0.06 exchanges per hour). Therefore, the control room normal outside air intake is the preferred method of purging the control room while it is unisolated.

The footnote also allows the control room envelope to be unisolated for purging while not being required to comply with other TS ACTIONS that require the control room ventilation system to be placed in the isolate of recirculate mode of operation (i.e., TS 3.3.3.1, Table 3.3-6 ACTION 26 [ Control Room Intake Radiation Monitor] and TS 3.7.6.2 ACTION a [ Control Room Emergency Air Filtration System] to place the control room ventilation system in the recirculate mode of operation, and the requirement of TS 3.7.6.5 ACTION a [ Control Room isolation and Pressurization) to place the control room ventilation system in the isolate mode of operation).

Therefore, the control room ventilation system can be unisolated without having to imm ediately be placed in the isolate or recirculate mode of operation to comply with other TS ACTIONS.

However, upon indication of any event that would require the control room ventilation system to be in the isolate or recirculate mode, the control room ventilation system will be placed in the isolate mode of operation.

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NPF-38-205 ATTACHMENT C REFERENCES

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NPF-38-205

, LIST OF REFERENCES l 1

-1. Letter to U.S. NRC Document Control Desk from J. G. Dewease (LP&L) dated l December 23,1988.

2. Letter to J. G.~ Dewease (LP&L) from D. L. Wigginton (U.S. NRC) dated March 23, 1989.

3. .1991 ASHRAE Handbook; Applications; Chapter 11; Environmental Control For f

Survival; Pages 11.3,11.4, & 11.5.

4. Regulatory Guide 1.78; " Assumptions for Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release,"

dated June 1974.

5. Calculation No. EC-M96-002, Revision 1; " Carbon Dioxide Generation / Oxygen Depletion in Control Room."

6. Letter to J. G. Dewease (LP&L) from J. H. Wilson (U.S. NRC) dated July 21,1987.

. 7. LDCR # 98-0054; Change to FSAR Sections 6.4.4.2 and 2.2A.1.3.

8. FSAR Section 2.2A.1;" Analysis of the Possible Consequences of the Livingston, l Louisiana Derailment Accident on the Waterford 3 Plant."

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i NPF-38-205 1

REFERENCE 1 !

l LETTER To U.S. NRC DOCUMENT CONTROL DESK FROM J. G. DEWEASE (LP&L) :

. DATED DECEMBER 23,1988 l l

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t LOUISIANA e P. O. 80X 60340 P O W E R & L i G H T/NEW 317 BARONNE ORLEANS, STREET LOUISIANA 70160 . (504) 595 2781

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J. G. DE WE A $ E ssnnon vwt **sseskr.

NUCLIAR 09ttaino,'s December 23, 1988 W3P88-1855 A4.05 QA U.S. Nuclear Regulatory Commission t 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-38-94 Gentlemen:

The proposed change to Technical Specifications 3.3.3.7.1 and 3.3.3.7.3 incorporates correct terminology for toxic gas event protective action.

Both specifications require the Control Room Air Conditioning System to operate in recirculation. In the terminology of the plant, recirculation pressurizes the Control Room Envelope with filtered outside air. During toxic gas events, no outside air should enter the Control Room Envelope.

The system mode called " isolate" performs that function. Both modes recirculate the bulk of the Control Room Envelope Air, but one pressurizes the envelope, one does not. This change clarifies this subtlety while agreeing with control panel labeling.

Should you have any questions or comments on this matter, please feel free to contact Steven Farkas at (504) 464-3383.

Very truly yours,

$ca .G. Dewease Senior Vice President -

Nuclear Operations JGD E sf Attachments: NPF-38-94 Filing Fee, LP&L L..eck - $150.00 cc: R.D. Martin, J.A. Calvo, D.L. Wigginton, NRC Resident Inspectors Office, E.L. Blake, W.M. Stevenson, Administrator Nuclear Energy Division (State of Louisiana), American Nuclear Insurers gfgI C )$ "AN EOUAL OPPORTUNITY EMPLOYER"

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l UNITED STATES OF AMERICA '

NUCLEAR REGULATORY COMMISSION l l

In the matter of )

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Louisiana Power & Light Company ) Docket No. 50-382 j Waterford 3 Steam Electric Station ) i l

l AFFIDAVIT R.P. Barkhurst, being duly sworn, hereby deposes and says that he is Vice l President-Nuclear Operations of Louisiana Power & Light Company; that he is '

duly authorized to sign and file with the Nuclear Regulatory Commission ' ae attached Technical Specification Change Request NPF-38-94; that he is familiar with the content thereof; and that the matters s6t forth therein are true and correct to the best of his knowledge, information and belief.

O \}L s R.P. Barkhurst Vice President-Nuclear Operations STATE OF LOUISIANA)

) as PARISH OF ORLEANS )

Subscribed and sworn to before me, a Notary Publ in and for the Parish and State above named this SAA J day of /m - ,

1988.

lotary Public My Commission expires ; .

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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-94 This document justifies revising Technical Specification 3.3.3.7.1,

" Chlorine Detection System"; and 3.3.3.7.3, " Broad Range Gas Detection".

The revision replaces the term " recirculation-mode" with the proper-

" isolation-mode".

Existing Specifications See Attachment A Proposed Specifications See Attachment B Description The Control Room Air Conditioning' System operates in three distinct modes:

(1) normal, (2) pressurized to protect against high-radiation, and (3) isolated to protect against toxic gas.

The Control Room Envelope air supply comes through four potential paths, two air handling units for cooling, and two fan / filter trains. 'The Control Room Envelope contains three exhaust fans. The air handling units also recirculate air from the return registers in the various rooms of the envelope not exhausted. The air handling units' intake is separate from the two intakes for the fan / filter trains. Each fan / filter train can draw

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i on either emergency outside air intake. Air can enter the envelope from

! three places and exhaust in one.

In normal operation, one air handling unit and two exhaust fans operate.

The normal outside air intake passes through the cooling coils, heaters.

l one of two air handlers, the envelope rooms, and a small part to one of two l

operating exhaust fans. The second air handling unit starts automatically, via Class 1E instrumentation, if the primary unit becomes out-of-service.

A majority of the air recirculates to the cooling coil again, conserving the energy required to initially cool the air.

In the high-radiation protection mode (SIAS or high intake radiation), one air handling unit.and one fan / filter train operate. The air handling unit recirculates and cools all of the envelope air. The fan / filter unit processes all outside air from the emergency intakes. Outside air allows the envelope air pressure to increase above atmospheric. The fan / filter unit reduces the radioactivity of potentially contaminated post-accident i intake-air. Th4 high-radiation protection mode closes the normal air intakes. In t.he high-radiation protection mode (or recirculation-mode),

all of the envelope air recycles through the air handler. Air replacing any leakage cut of the envelope comes through the fan / filter unit.

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In tho toxic-gee protection nodo. only cns cir handling unit operates. The

, toxic-gas protection mode isolates all envelope intake and exhaust paths.

L The. toxic-g.as protection (isolation) mode overrides the high-radiation protection (recirculation) mode. During isolation, some of the envelope air can move through a fan / filter unit for radioactivity reduction;

-however, without outside air, the system cannot create a positive pressure of 1/8 inch W. G. in the envelope. The toxic-gas protection mode (or isolation-mode) prevents communication with outside air.

The Control Room Air Conditioning System uses either automatic, or manual transfer from its normal operating mode to either the pressurized, or isolated modes, as necessary. FSAR 6.4.1 askes a distinction between normal, pressurized (high-radiation protection or recirculation), and l isolated (toxic-gas protection) modes of operation.

The technical specifications need to reflect the proper action for inoperable toxic-gas detectors. Both Specification 3.3.3.7.1 and 3.3.3.7.3 require the Control Room Air Conditioning System to operate in its recirculation-mode after various levels of toxic-gas detection i

inoperabilities. Specifically, LP&L proposes to change the phrase i " recirculation mode" to " isolation mode" in ACTION a and b of Specification

! 3.3.3.7.1, as well as ACTION a and b of Specification 3.3.3.7.3.

While this change applies to the ammonia detection system as well, LP&L i

requested the deletion of Specification 3.3.3.7.2 (ammonia protection) in NPF-38-88, sent to the NRC on September 21, 1988.

Safety Analysis General Design Criterion (GDC) 19 requires a control room from which actions can be taken to operate the unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including

loss-of-coolant accidents. GDC 19 does not mention toxic-gas protection specifically, although the list of analyzed plant accidents includes toxic-gas releases. The Control Room Air Conditioning System includes radiation and toxic chemical detectors and alaras. The Control Roon l isolates during postulated toxic chemical accidents. Provisions in the design allow Control Room air to recirculate through high-efficiency particulate and charcoal filters following any accident. FSAR 3.1.15 fully i discusses LP&L's implementation of GDC 19.

The SRP guides revieweru through the Control Room Air Conditioning System.

l SRP 6.4 III.3.d (3) dircusses_the advantages of " pressurization" versus

" isolation and recircu.ation". Isolation limits the entrance of noble gases (not filterable) and, in addition, isolation is a better approach when a " puff-release" of either radiation or toxic-gas occurs. The SRP considers Control Room envelope automatic isolation with subsequent manual control of pressurization the proper response to a toxic-gas release. The SRP considers either: (1) automatic isolation with subsequent manual control of pressurization, or (2) automatic isolation with immediate automatic pressurization; the proper response to a radiological release while meeting GDC 19.

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Upon datoction of chlorins, the Control Roca envelops automatically isolates as described in FSAR 6.4.3.3. The automatic isolation renders the system's ability to pressurize the envelope inoperable. If toxic-gas relative concentration equals or exceeds the Broad Range Gas Detection System high setting, an alarm sounds, and the system automatically isolates the Control Room before toxic gas reaches work inhibiting levels.

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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: i

1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequence of any accident previously evaluated?

I l Response: No. l' FSAR Chapter 6 reviews the design features which mitigate toxic-gas releases. This change involves two toxic chemical detection systems.

For chlorine gas events, the effective isolation time (including detector response plus valve closure time minus travel time) is approximately four seconds (the isolation time stipulated by Regulatory Guide 1.95 for a Type II control room). Many non-toxic gases, as well as toxic gases, may register on the Broad Range Detection system photoionization detector. The Broad Range Gas detectors' design, although sensitive to many gases, is calibrated to protect against the most dangerous toxic gases. A separate gas chromatograph allows the Control Room operator to judge what gas isolated the Control Room and whether to return to the normal mode.

, The consequences of accidents foreseen in Chapter 6 remain unchanged l because the. intention of plant design includes isolating the Control i Room envalope from all external sources of air during a toxic-gas

! event. The technical specification change brings compensatory actions in-line with the Chapter 6 description.

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 l

create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

Plant operating procedure OP-03-014 describes the steps to start and stop the Control Room Air Conditioning System and place it in the three operating modes. Control Room personnel direct the use of the procedure. Plant off-normal procedure OP-901-047, " Toxic Chemical Release" directs the operators to isolate the Control Room and establish 100% recycling of air. Control Roon personnel decide which procedure steps to use when complying with an ACTION statement, specifically ACTION a or b of 3.3.3.7.1 and 3.3.3.7.3.

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l Plent opsretor training includes the Control Room Air Conditioning System design and the proper response to a toxic-ges release. The !

plant operators correctly isolate the envelope from outside air during j a toxic-gas event or sometime after declaring a toxic-gas detector inoperable. Correcting the inconsistent terminology used in Specification 3.3.3.7.1 and 3.3.3.7.3 does not change how the plant operates. This technical specification change does not coincide with any physical change to giant hardware, so failure modes for the system remain unchanged.

Therefore, the proposed change will not create the possibility or 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 OPERABILITY of the chemical detection systems ensures sufficient capability exists to promptly detect and initiate protective action after an accidental chemical release. The chemical detection systems provide prompt detection of tox'Lc-gas releases which could either pose -

an actual threat to safety of f.he nuclear power plant, or significantly hamper personnel performing duties necessary for safe plant operation.

The plant design predicates on isolating the Control Room envelope for toxic-gas protection. This feature is retained by the revised specifications.

i Therefore, th'a proposed change will not involve a significant reduction in a margin of safety.

The Commission provided guidance concerning the application of standards I for determining whether a significant hazards consideration exists by listing certain examples (48 FR 14870) of amendments considered not likely j to involve significant hasards considerations. This technical specification change most closely resembles (1) A purely administrative change to technical specification; for )

example, a change to achieve consistency throughout the technical j specifications, correction of an error, or a change in nomenclature. '

Th' proposed change in Specification 3.3.3.7.1 and 3.3.3.7.3 ACTION iurninology corrects a problem with naming the proper response to a toxic-gsa detector inoperability. Therefore, this change is similar to example (1). ,

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. 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 10 CFR 50.92; 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 Ffnal Environmental Statement, l

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ATTACHMENT A i

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INSTRUMENTATION l

! CHEMICAL DETECTION SYSTEMS CHLORINE DETECTION SYSTEM l

LIMITING CONDITION FOR OPERATION I

l 3.3.3.7.1 Two independent chlorine detection systems, with their alarm / trip l

setpoints adjusted to actuate at a chlorine concentration of less than or j equal to 4 ppm, shall be OPERABLE.

e j.

- APPLICABILITY: All MODES.

l ACTION:

! With one chlorine detection system inoperable, restore the

! a. l inoperable detection system to OPERABLE status within 7 days or 4

within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months initiate and maintain operation of the l l

control room ventilation system in the recirculation mode of l operation.

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b. With no chlorine detection system OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of the control room ventilation system in the

! recirculation mode of operation. l l

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c. The provisions of Specification 3.0.4 are not applicable, j

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l SURVEILLANCE REQUIREMENTS i

4.3.3.7.1 Each chlorine detection system shall be demonstrated OPERABLE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and a CHANNEL CALIBRATION at least once per 31 days. ,

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WTERFDM - INIT 3 M N# U L ___ ___ - . __

INSTRUMENTATION I CHENICAL DETECTION SYSTEMS l

. BROAD RANGE GAS DETECTION LIMITING CONDITION FOR OPERATION 3.3.3.7.3 Two independent broad range gas detection systems shall be operable with their alare/ trip setpoints adjusted to actuate at the lowest achievable IDLH gas concentration level of detectable toxic gases providing reliable operation.

APPLICA8ILIITY: All M00ES.

ACTION: ,

s. With one broad range gas detection system inoperable, restore the inoperable detection system to OPERABLE status within 7 days or within l the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months initiate and maintain operation of the control room ventilation system in the recirculation mode of operation.

b. With no broad range gas detection systa; OPERA 8LE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of the control room ventilation system in the recirculation mode of operation.

( c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.7.3 Each broad range gas detection system shall be demonstrated OPERABLE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a CHANNEL FUNCTIONAL TEST at least once per 31 days and a channel calibration at least once per 7 days. Calibration will consist of the introduction of a standard gas and adjusting the instrument sensitivity based on the calibration gas relationship of the standard gas to the calibrating gas.

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I WATERFORD - UNIT 3 3/4 3-48a AMENDMENT N0. 20 l

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ATTACHMENT B NPF $8 - 984 1

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INSTRUMENTATION

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CHEMICAL DETECTION SYSTEMS CHLORINE DETECTION SYSTEM LIMITING CONDITION FOR OPERATION 3.3.3.7.1 Two independent chlorine detection systems, with their alarm / trip setpoints adjusted to actuate at a chlorine concentration of less than or equal to % ppm, shall be OPERABLE.

APPLICABILITY: All MODES.

ACTION:

a. With one chlorine detection system inoperable, restore the inoperable detection system to OPERABLE status within 7 days or within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months initiate and maintain operation of the control room ventilation system in the(ficirculation) mode of operation. g a ,cse m a

b. With no chlorine detection system OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of the control room ventilation system in the rfFcirculatios mode of operation.

g$gg Atsl> t I set.AT E.

( c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.7.1 Each chlorine detection system shall be demonstrated OPERABLE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and a CHANNEL CALIBRATION at least once per 31 days. ;

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utERFgED - AMIT 3 M NenENT m. D l

INSTRUMENTATION CHEMICAL DETECTION SYSTEMS BROAD RANGE GAS DETECTION LIMITING CONDITION FOR OPERATION 3.3.3.7.3 Two independent broad range gas detection systems shall be operable with their alara/ trip setpoints adjusted to actuate at the lowest achievable IDLH gas concentration level of detectable toxic gases providing reliable l operation. t APPLICA81LIITY: All MODES.

ACTION:

a. With one broad range gas detection system inoperable, restore the inoperable detection system to OPERABLE status within 7 days or within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months initiate and maintain operation of the control room ventilation system in thecrecirculatiog node of operation.

h.sve e T.sewe

b. With no broad range gas detection system OPERA 8LE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of the control roce ventilation systes in the recirculatiorDoode of operation.

Se ado' 55 * *T* l

c. Theprovisionsoir$ specification 3.0.4arenotapplicable. '

SURVEILLANCE REQUIREMENTS l

l 4.3.3.7.3 Each broad range gas detection system shall be demonstrated OPERABLE l by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a CHANNEL FUNCTIONAL TEST at least once per 31 days and a channel calibration at least once per 7 days. Calibration will consist of the introduction of a standard gas.and adjusting the instrument sensitivity based on the calibration gas relationship of the standard gas to the calibrating gas.

I WATERFORD - UNIT 3 3/4 3-48a AMENDMENT NO. 20

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l NPF-38-205 1

REFERENCE 2 I i

LETTER To J. G. DEWEASE (LP&L) FROM D. L. WlGGINTON (U.S. NRC)

DATED MARCH 23,1989 L

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pa nauq'o, UNITED STATES

! s. ( 7 NUCLEAR REGULATORY COMMISSION - -

3 I wasmwoTow.o.c. oses .

March 23, 1989 RECBVED

'% ,', , , . J,8 W RAMEypagg Docket he. 50-382 APR 4 1989 Mr. J. G. Dewease Y Senior Vice President - Nuclear Operations RECE!VED Louisiana Power and Light Company 317 Baronne Street, Mail Unit 17 ON SITE LICENSING h=w Orleans, Louisiana 70122 APR 4 1333

Dear Mr. Dewease:

I Sl'PJECT: ISSUAACE OF AMENDMENT NC. 53 TO FACILITY OPERATING LICENSE NPF-38.- WATERFORD STEAM ELECTRIC STATION, UNIT 3 (TAC NO. 71802)

The Cosalission has issued the enclosed Amendment No. 53 to Facility Operating License No. hPF-38 fcr the Waterford Steam Electric Station, Unit 3.- The amer.drert cu.sists of charges to the Technical Specifications (TSs) in response l to yobr application dated December 23, 1988.

The arendment char.ges the Appendix A Technical Specifications by correcting the; terminology of control rocr isolation for toxic gas protection action.

A copy of the Safety Evtluation suppcrting the arenanant is tiro enclosed.

Notice of Issuance will be inclucea in the Cosmission's next biweekly Federal Register notice. ]

Sincerely, ky/J'V David L. W on, Project Har.ager I Project Directorate - IV l

Division of Reactor Projects - III, ,

IV, Y and Special Projects !

Office of Nuclear Reactor Regulation

.I Enclosuns:

1. Amendment No. 53 to NPF-38

2. Safety Evaluation j cc w/ enclosures: l See next page i i

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Pr. Jerrold G. Dewease Waterford 3 Louisiana Power & Light Company CC:

W. Malcolm Stevenson, Esq. Regional Administrator, Region IV Pcnroe & Lerar U.S. Nuclear Regulatory Conr.ission 1 C Ltitne builoing Office of Executive Director for New Orleans, Louisiana 70103 Operations 611 Ryan Plaza Drive. Suite 1000 tir. E. Blake Arlington, Texas 76011 i Show, Pittman, Potts & Trowbridge !

2300 N Street, NW Hr. William t . Spell, Administrator Washington, D.C. 20037 Nuclear Energ Division Office of Environmental Affairs

! Residei.t Inspector /Waterford NPS Post Office Box 14690 l Post Office Box 822 Baton Rouge, Louisiana 70898 Killena, Louisiana 70066 l

Mr. Ralph T. Lally Reesident, Police Jury 1 Manager of Quality Assurance St. Charles Parish Piddle South Services, Inc. Hahnville, Louisiana 70057 i Post Office Box 61000 New Orleans, Louisiana 70161 Chairman William A. Cross

, Lcuisiana Public Service Connission Bethesda Licensing Office i l Cre American Place, Suite 163C 3 Metro Center

Baton Rouge, Louisiana 70825-1697 Suite 610 l

Bethesda, Maryland 20814 i Mr. R. F. Burski .

Nuclear Safety and Regulatory Affairs Panager l' Lcuisiana Pcwer & Light Company 317 Baronne Street few Crleans,.Lcuisiana 70112 l

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license atendrent, ar.d paragraph 2.C(2) of Facility Operating License No.

j NFF-35 is hereby amended te reed es follevs:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications containec in Appendix A, as revised l through Amendment No.53 , ar.d the Environmental Protection Plan contair,ec in Appendix B, are hereby incorporated in the license, The licensee ste.11 operate the facility in accordance with the Technical Specifications anc the Environmental Protection Plan.

l 3. THs license amendment is effective as of its date of issuance.

FOR THE NUCLEAR REGULATORY COM;ISSION l

K 'G. [xAW

/m Jose A. Calvo, Director i

Project Directorate - IV Division cf Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: March 23, 1989 l

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ATTACHEENT TO LICENSE AMENDMENT NO. 53 TO FACILITY OPERATING LICENSE NO. NPF-38 DOCKET NO. 50-382 Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by Amendment number and contain vertical lines indicating the areas of change.

Remove Insert 3-47* 3/4 3/47 3/4 3-48a 3/4 3-48a l

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Page 3-47 was incorrectly numbered by Amendment No. 21; it should have been numbered 3/4 3-47.

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INSTRUMENTATION CHEMICAL DETECTION SYSTEMS CHLORINE DETECTION SYSTEM LIMITING CONDITION FOR OPERATION l l

3.3.3.7.1 Two independent chlorine detection systems, with their clarm/ trip setpoints adjusted to actuate at a chlorine concentration of less than or equal to 3 ppm, shall be OPERABLE.

1 APPLICABILITY: All MODES.

ACTION:

a. With one chlorine detection system inoperable, restore the inoperable detection system to OPERABLE status within 7 days or within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months initiate and maintain operation of the control room ventilation system in the isolate mode of [

operation.

b. With no chlorine detection system OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of the control room ventilation system in the isolate mode of operation. I

c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.7.1 Each chlorine detection system shall be demonstrated OPERABLE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and a CHANNEL CALIBRATION at least once per 31 days.

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!. WATERFORD - UNIT 3 3/4 3-47 AMENDMENT NO. 21,53 i

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INSTRUMENTATION CHEMICAL DETECTION SYSTEMS BROAD RANGE GAS DETECTION LIMITING CONDITION FOR OPERATION 3.3.3.7,3, Two independent broad range gas detection systems shall be operable

'with their alarm / trip setpoints adjusted to actuate at the lowest achievable IDLH gas concentration level of detectable toxic gases

providing reliable operation. I

. APPLICABILITY: All MODES.

ACTION:

a. With one broad range gas detection system inoperable, restore the inoperable detection system to OPERABLE status within 7 days or within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months initiate and maint&in operation of the control room ventilation system in the isolate mode of operation. {

b. With no broad range gas detection system OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of the control room ventilation system in the isolate mode of operation. l

c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.~3.7.3 Each broad range gas detection system shall ba demonstrated OPERABLE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ,'a CHANNEL FUNCTIONAL TEST at-least once per 31 days and a channel calibration at least

!- once per 7 days. Calibration will consist of the introduction of a standard ;

l gas and adjusting the instrument sensitivity based on the calibration gas !

relationship of the standard gas to the calibrating gas.

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Including Ammonia WATERFORD - UNIT 31 3/4 3-48a AMENDMENT No. 28,53

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/ymm'o, UNITED STATES

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NUCLEAR REGULATORY COMMISSION 3 l wash m orow,p.c.acess

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 53 TO FACILITY OPERATING LICENSE.NO. NPF 38 LOUISIANA POWER AND LIGHT COMPANY WATERFORD STEAM ELECTRIC. STATION, UNIT 3

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DOCKET NO. 50-382 i

1.0 INTRODUCTION

By application dated December 23, 1988 Louisiana Power and Light Company (LP&L or the licensee) requested changes to the Technical Specifications (Appendix A to Facility Operating License No. NPF-38) for Waterford Steam Electric Station, Unit 3. The proposed changes would correct the terminology of control room isolation for toxic gas protection action.

2.0 DISCUSSION The Control Room Air Conditioning System operates in three distinct udes: (1) normal, (2) pressurized to protect against high radiation, and (3) isolated to protect against toxic gas. In protecting against high-radiation, the system draws air from outside the control room and passes it through filters to remove the radiation. This allows the control room to be slightly pressurized as air is recirculated and prevents inleakage of radioactivity from other airborne sources. This operation is generally referred to as recirculation.

In the toxic gas protection. mode, the outside air cannot be filtered to I remove toxic gases and it is necessary to isolate the outside air. The air in the control room is circulated (or recirculated) but isolated from outside sources.

The Waterford 3 Technical Specifications were originally issued requiring l the Control Room Air Conditioning System to be placed in the " recirculation" i mode for both the radiation release and toxic gas modes. The industry has realized a problem of referring to both operations as " recirculating" and has proposed to refer to the toxic gas mode as "isolaticn'. We agree l l' with the industry and with the proposed Technical Specification change. The l change in terminology does not change an operation or affect any safety or other analysis for the facility. It does assist the operators by the distinction and is therefore an improvement to plant safety.

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~2-3.0 CONTACT WITH STATE OFFICIAL l

The NRC staff has advised the Administrator, Nuclear Energy Division, l Office of Environmental Affairs State of Louisiana of the proposed !

l determination of no significant hazards consideration. No consents

.were received.

4.0 ENVIRONMENTAL CONSIDERATION

l l 1 The amendment relates to changes in recordkeeping, reporting, or admini- l strative procedures or requirements. Accordingly, the amendment meets !

the eligibility criteria for categorical exclusion set forth in 10 CFR i 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact l l statement or environmental assessment need be prepared in connection I with the issuance of this amendment.

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5.0 CONCLUSION

Based upon its evaluation of the ' proposed changes to the Waterford 3 l l Technical Specifications, the staff has concluded that: there is reason- l able assurance that the health and safety of the public will not be ;

endangered by operation in the proposed manner, and such activities will i be conducted in compliance with the Commission's regulations and the i

. issuance of the amendment will not be inimical to the cosmon defense and I security or to the health and safety of the public. The staff, therefore, l concludes that the proposed changes are acceptable, and are hereby ;

! incorporated into the Waterford 3 Technical Specifications. I Dated: March 23, 1989 Principal Contributor: D. Wigginton m m

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ML20249C790

Contents

Text

Subject:

Dear Mr. Dewease:

Attachment:

1.0 INTRODUCTION

4.0 ENVIRONMENTAL CONSIDERATION

5.0 CONCLUSION

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ML20249C790

Text

Subject:

Dear Mr. Dewease:

Attachment:

1.0 INTRODUCTION

4.0 ENVIRONMENTAL CONSIDERATION

5.0 CONCLUSION

Navigation menu

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