ML20249C830
| ML20249C830 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/29/1998 |
| From: | Dugger C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20249C831 | List: |
| References | |
| RTR-NUREG-1432 W3F1-98-0044, W3F1-98-44, NUDOCS 9807010276 | |
| Download: ML20249C830 (11) | |
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O Enti gy Operations, Inc.
Killona. LA 70066-0751 Tel 504 739 6660 Charles M. Dugger V ce Pre c ent. OperaSons l
W3F1-98-0044 A4.05 l
PR l
June 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
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Technical Specification Change I
Request NPF-38-204 i
Gentlemen:
The attached description and No Significant Hazards Evaluation support changes to the Waterford 3 control room ventilation Technical Specifications (TS). The proposed changes modify TS 3.7.6.1 (Control Room Emergency Air Filtration System - Modes 1-4), TS 3.7.6.2 (Control Room Emergency Air Filtration System -
Modes 5 and 6), TS 3.7.6.3 (Control Room Air Temperature - Modes 1-4), TS 3,7.6.4 (Control Room Air Temperature - Modes 5 & 6), and TS 3.7.6.5 (Control Room -
Isolation and Pressurization), and the associated Bases.
The proposed changes to the control room ventilation TS affects the Applicability and the Actions. These changes will make the TS consistent with NUREG-1432 (Standard Technical Specifications Combustion Engineering Plants), as applicable, and the accident analysis. The proposed changes to the TS Bases make the Bases consistent with the TS and also clarify that suspending movement of irradiated fuel assemblies shall not preclude movement to a safe conservative position.
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This proposed change is a direct result of Licensee Event Report (LER) 97-022-00.
I The LER contained a corrective action to submit a TS change request to revise TS
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3.7.6 to be more in line with NUREG-1432. The LER was written because Waterford 3 provided makeup to the reactor coolant system with inventory from the refueling j
water storage pool which contained a slightly lower boron concentration while in a TS Action to suspend all operations involving positive reactivity changes.
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Technical Specification Change Request NPF-38-204 W3F1-98-0044
~ Page 2 June 29,1998 This proposed change has been evaluated in accordance with 10CFR50.91_(a)(1),
= using the criteria in 10CFR50.92(c), and it has been determined that this request involves no significant hazards consideration.
The circumstances surrounding this change do not meet the NRC's criteria for exigent or emergency review. However, suspending positive reactivity changes, when not required for the safe operation of the plant, limits the operational flexibility l
(i.e., makeup to the reactor coolant system [RCS) and RCS temperature changes).
t Therefore, it is respectfully requested that approval be granted prior to the beginning of Refuel 9 which is currently scheduled to begin in February,1999. Also, please l
make the effective date for this TSCR be within 60 days of approval.
Should you have any questions or comments concerning this request, please contact
- Early Ewing at (504) 739-6242.
' Very truly yours, d
C.M. Dugger.
l Vice President, Operations Waterford 3 CMD/CEDhtk Attachments:
NPF-38-204 L.
t cc:
E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR L
J. Smith l
N.S. Reynolds NRC Resident inspectors Office Administrator Radiation Protection Division (State of Louisiana)
American Nuclear Insurers g
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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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l AFFIDAVIT l
Charles Marshall Dugger, being duly sworn, hereby deposes and says that he is Vice President Operations - Waterford 3 of Entergy Operations, Incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached i
Technical Specification Change Request NPF-38-204; that he is familiar with the l
content thereof; and that the matters set forth therein are true and correct to the best of l
his knowledge, information and belief.'
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l Charles Marshall Dugger 1'
Vice President Operations - Waterford 3 STATE OF LOUISlANA
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Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this > #1' day of U
.4 1998.
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e c Notary Public My Commission expires -V a6}/.
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DESCRIPTION AND NO SIGNIFICANT HAZARDS EVALUATION OF PROPOSED CHANGE NPF-38-204 The proposed change revises the following Technical Specifications (TS) and the associated TS Bases:
TS 3.7.6.1, " Control Room Emergency Air Filtration System"in Modes 1-4.
TS 3.7.6.2, " Control Room Emergency Air Filtration System"in Modes 5 and 6, TS 3.7.6.3, " Control Room Air Temperature"in Modes 1-4, TS 3.7.6.4," Control Room Air Temperature,"in Modes 5 and 6, and TS 3.7.6.5, " Control Room Isolation and Pressurization."
Existina Specification See Attachment A Proposed Specification See Attachment B References See Attachment C 1
Backaround Waterford 3 TS 3.7.6.2,3.7.6.4, and 3.7.6.5 contain requirements to suspend all operations involving CORE ALTERATIONS and positive reactivity changes. These requirements are unnecessarily restrictive as currently implemented at Waterford 3.
NUREG-1432 contains requirements to suspend all operations involving CORE j
t ALTERATIONS or movement of irradiated fuel assemblies. This change proposes to i
revise the Waterford 3 TS to be consistent with NUREG-1432, as applicable, and ensure the Waterford 3 accident analyses are preserved.
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l The Actions contained in the control room ventilation TS to " suspend all operations involving CORE ALTERATIONS or positive reactivity changes," has caused some confusion at Waterford 3 with respect to performing normal plant operations (i.e.,
makeup to the reactor coolant system [RCS), changing RCS temperature, etc.) and the requirement to suspend all operations involving positive reactivity changes.
Specifically, an event occurred at Waterford 3 during Refuel 8 which caused a positive reactivity change to occur when both control room emergency filtration units were inoperable and Actions were entered to suspend positive reactivity changes. Licensee Event Report (LER) 97-022-00 was sent to the NRC on July 18,1997, describing this event (Reference 1).
The event began when a valve in the boric acid makeup (BAM) system was removed from service for repair. This disabled the ability for the control room staff to makeup to the RCS or refueling water storage pool (RWSP) from the BAM Tanks. Consequently, the RWSP was designated as the operable boration flow path. The next day both trains of the control room emergency filtration units and the emergency outside air intakes were declared inoperable to install gravity dampers (which requires both trains to be l
l declared inoperable at the same time). This placed Waterford 3 in an action to suspend positive reactivity changes. Two days later, during the safety injection with concurrent loss of offsite power diesel generator test (OP-903-115), boric acid was added to the RCS. This resulted in the RCS boron concentration being slightly greater l
than the RWSP boron concentration. Finally, during a routine plant operation to reduce l
Ammonia in the RCS, makeup was added to the RCS from the RWSP which contained a lower boron concentration than the RCS.
Operations determined incorrectly that the addition of inventory into the RCS from the l
RWSP would still meet the intent of the Action to suspend positive reactivity changes because the RWSP was the operable boration flow path source, the shutdown margin (SDM) requirements would not be violated, and the Boration Flow Path TS requirements would still be met. This resulted in the LER being written because a positive reactivity change was made. As part of the corrective measures, Waterford 3 l
committed to change the control room ventilation TS to be consistent with NUREG-l 1432," Standard Technical Specifications Combustion Engineering Plants." The control room ventilation TS Actions in NUREG-1432 do not contain the requirement to suspend positive reactivity changes.
l As outlined above, the Action to suspend all operations involving positive reactivity changes can cause confusion. It is clear in the case above that it was not unsafe to makeup from the RWSP; however, the TS prohibited all operations involving positive reactivity changes. Adding lower boron concentration water from the RWSP to a higher boron concentration RCS constituted a positive reactivity change.
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This TS change request proposes to delete the TS Action to suspend all operations involving positive reactivity changes in TS 3.7.6.2,3.7.6.4, and 3.7.6.5, consistent with
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NUREG-1432 and as committed to in LER 97-022-00. Also, an Applicability and Action i
will be added to be consistent with NUREG-1432. The TS Bases will be changed to clarify the Actions and to be consistent with the TS. The applicability of TS 3.7.6.1 and
- 3.7.6.3 will be changed to reference the applicability of TS 3.7.6.2 and 3.7.6.4, respectively, during the movement of irradiated fuel assemblies.
I Description and Safety Considerations -
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-Technical Specifications 3.7.6.2 and 3.7.6.4 Applicability is " MODES 5 and 6," and TS 3.7.6.5 Applicability is "All MODES." The proposed change revises the Applicability I
for TS 3.7.6.2 and 3.7.6.4 to " MODES 5, 6, and during movement ofirradiated fuel l
assemblies," and for TS 3.7.6.5 to "All MODES and during movement ofirradiated fuel
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assemblies." Also, "during movement ofirradiated fuel assemblies" was added to the
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- Applicability for TS 3.7.6.5, Action d.3. These more restrictive changes make the control room ventilation TS Applicability consistent with NUREG-1432.
1 Technical Specifications,3.7.6.2, 3.7.6.4, and 3.7.6.5 contain the Action statement to
" suspend all operations involving CORE ALTERATIONS or positive reactivity changes" when both control room emergency filtration trains are inoperable (TS 3.7.6.2), when both control room air conditioning units are inoperable (TS 3.7.6.4),' or when the control room envelope is inoperable (TS 3.7.6.5). The proposed change revises the Action statements to " suspend all operations involving CORE AL TERATIONS and movement ofirradiated fuel assemblies." This change corrects the Action to ensure the appropriate actions are taken to suspend activities that could result in the control room being exposed to a radioactive release. ' The "or" was changed to "and" in the Action to ensure that both the Actions are suspended and not just one of the two. These changes are cor sistent with NUREG-1432.
l These changes are the result of LER 97-022-00, which was described earlier. In the LER Waterford 3 committed to change TS 3.7.6 to be consistent with NUREG-1432.
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Deleting tbs requirement to suspend positive reactivity changes is a less restrictive change. However, this' change is acceptable, because although adding positive j
l reactivity, via a boron dilution event, may result in the release of radioactivity, the instrumentation (which is credited in the safety analysis) to detect a criticality event is l
. required to be Operable and capable of alerting the control room. After being alerted of l
the event, the control room will terminate it prior to any release of radioactivity l
(Reference 2). These instruments, credited in the safety analysis, are required to be Operable and if or.e is inoperable, positive reactivity changes are required to be 1
suspended. If both instruments become inoperable, along with suspension of positive reactivity changes, boron concentration is required to be determined at frequencies 3
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specified in the Core Operating Limits Report (only when source range neutron flux monitors are inoperable). - Also, the SDM is required to be met. If the SDM requirements are not met, action must be taken to borate (addition of negative reactivity) until the SDM is restored. Therefore, the Actions to suspend positive reactivity are not required when the control room ventilation systems (ventilation, temperature, or envelope) are inoperable.
The added Applicability, during movement of irradiated fuel assemblies, and Action, to suspend the movement of irradiated fuel assemblies, are more restrictive changes.
These changes ensure the suspension of the activity (movement of irradiated fuel
. assemblies) that is the precursor to a fuel handling accident. The fuel handling
' accident is an event that assumes a release of radioactivity (Reference 3) with the potential to expose control room personnel. These changes are being made solely to be consistent with NUREG-1432. Waterford 3 analysis shows an acceptable exposure i
to control room personnel during the worst case fuel handling accident with both control l
room ventilation trains inoperable.
. The proposed footnote, "During movement of irradiated fuel assemblies, TS 3.7.6.2 is i
also applicable," will be added to Technical Specification 3.7.6.1 Applicability. The proposed footnote, "During movement of irradiated fuel assemblies, TS 3.7.6.4 is also applicable," will be added to Technical Specification 3.7.6.3 Applicability. These changes ensure operations personnel in the control room are aware of the applicability l
of TS 3 7.6.2 and TS 3.7.6.4 during movement of irradiated fuel assemblies in Modes 1, 2, 3, and 4 when the control room ventilation system is inoperable.
The following statement is being added to Technical Specification Bases Sections -
3/4.7.6.1 and 3/4.7.6.2,3/4.7.6.3 and 3/4.7.6.4, and 3/4.7.6.5:
The ACTION to suspend all operations involving movement ofirradiated fuel assemblies shall not preclude completion of movement to a safe conservative position.
This verbiage was added to clarify that irradiated fuel assemblies must be placed in a safe conservative position to minimize events that may cause a radioactive release.
l This clarification is consistent with the Waterford 3 definition of Core Alteration which states the suspension of Core Alterations does not preclude completion of movement of
- a component to a safe conservative position. This is a less restrictive change to the bases to clarify the TS Actions. However, this change enables the irradiated fuel
' assembly to be placed in a position such that the precursor to a fuel handling accident is precluded. This change is similar to clarifying verbiage in the Bases for Actions in NUREG-1432.
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The following statement is being deleted from Technical Specification Bases Section 3/4.7.6.1 and 3/4.7.6.2 for the control room emergency air filtration system:
Because the consequences of a fullpower design basis LOCA are more severe than those occurring during COLD SHUTDOWN and REFUELING, a' separate specification, 3/4.7.6.2, requires only one OPERABLE S-8 unit to guard against accidents during Modes 5 and 6.
This statement is being deleted because Waterford 3 TS require two trains to be Operable. This proposed change makes the Bases consistent with the TS. The Bases statement was not deleted when the TS were changed by a supplement (Reference 4)
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to a previous TSCR (TSCR NPF-38-116 approved as Amendment 115 [ Reference 5]).
The numbering of the titles in Bases Sections 3/4.7.6.3 and 3/4.7.6.4 was changed to
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3/4.7.6.3 and 3/4.7.6.4, and 3/4.7.6.5, respectively. Again, these changes were not j
made as part of the Supplements to NPF-38-116. One typographical error was corrected in the third paragraph of Bases Section 3/4.7.6.4; position was changed to positive.
j The changes to the TS and TS Bases, as discussed above, contain administrative, more restrictive, and less restrictive changes. These changes clarify Waterford 3 TS 3.7.6.1,3.7.6.2,3.7.6.3,3.7.6.4, and 3.7.6.5 with respect to the current TS Actions to suspend positive reactivity changes. These changes are justified based on instrumentation required to be Operable that detect boron dilution events, the 1
requirements for SDM to be met, and the added Applicability and Action which preclude j
the precursor to an accident in the safety analysis. These changes are also consistent with NUREG-1432, as applicable.
No Significant Hazards Evaluation The proposed change descpbed above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:
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Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response
No The proposed changes revise the control room ventilation Technical Specifications (TS) Actions to delete the Action statement to suspend all operations involving positive reactivity changes, and adds an Applicability 5
and Action related to the movement of irradiated fuel assemblies. The changes also add an Applicability footnote and revise the Bases to allow irradiated fuel assemblies to be placed in a safe conservative position when movement is required to be suspended. Other changes to the Bases are being made to be consistent with the TS. These changes do not affect the probability of an accident. The control room ventilation systems (ventilation, temperature, or envelope) do not affect the initiators of an accident; therefore, the changes do not alter the initiators of any analyzed events.
l The administrative and more restrictive changes do not affect the consequences of an accident. The administrative changes add an Applicability footnote and revise the TS Bases to make them consistent with the TS. This will ensure the applicable control room ventilation system TS are entered during movement of irradiated fuel assemblies and that there is no confusion associated with the Bases being inconsistent. The more restrictive change of adding the Applicability during movement of irradiated fuel assemblies and the Action to suspend movement of irradiated fuel assemblies eliminates the precursor to the I
fuel handling accident which prevents the fuel handling accident from occurring l
when the control room ventilation systems are inoperable. The addition of this Action ensures the event that may release radioactivity is precluded when the control room ventilation systems are inoperable.
The less restrictive changes (deleting the requirement to suspend positive L
reactivity changes and a Bases change which allows irradiated fuel assemblies 1
to be placed in a safe conservative position when movement has been l
suspended) do'not affect the consequences of an accident because no accident u
mitigator is affected. The safety analysis credits instrumentation to detect a boron dilution accident and alert the control room staff. After the control room staff is alerted, the accident is terminated without a radioactive consequence.
These instruments are required to be Operable and if one is inoperable, positive reactivity changes are required to be suspended, if both instruments become i
inoperable, along with suspension of positive reactivity additions, boron l
concentration is required to be determined at frequencies specified in the Core Operating Limits Report (only when source range neutron flux monitors are inoperable). Also, the shutdown margin (SDM)is required to be met. If the SDM requirements are not met, action must be taken to borate (addition of negative reactivity) until the SDM is restored. Therefore, if the control room ventilation systems are inoperable, suspension of positive reactivity changes are not required. The added statement in the Bases allows irradiated fuel assemblies to be placed in a safe conservative position to preclude a fuel handling accident from occurring. These Actions ensure that appropriate measures are taken to preclude events that would require the control room to be isolated when any of the control room ventilation systems are inoperable.
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Therefore, the proposed changes will not involve a significant increase in the probability or consequences of any accident previcusly evaluated.
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. 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?.
Respons'e:. No.
The proposed changes revise the control room ventilation TS Actions to delete
- the Action statement to suspend all operations involving positive reactivity changes, and adds an Applicability and Action related to the movement of irradiated fuel assemblies. The changes also add an Applicability footnote and revise the Bases to allow irradiated fuel assemblies to be placed in a safe conservative position when movement is required to be suspended. Other changes to the Bases are being made to be consistent with the TS. These
. changes do not alter the design or 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 (AOOs) or accidents.
Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.
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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 revise the control room TS Actions to delete the Action statement to suspend all operations involving positive reactivity changes, and adds an Applicability and Action related to the movement of irradiated fuel.
i assemblies. The changes also add an Applicability footnote and revise the 1
Bases to allow irradiated fuel assemblies to be placed in a safe conservative position when movement is required to be suspended. Other changes to the Bases are being made to be consistent with the TS. The margin of safety is not j
affected because the proposed changes to delete one Action and add an Applicability and Action ensures the assumptions of the accident analysis are being met. The administrative changes ensure the applicable TS are entered and eliminate confusion associated with the discrepancies between the TS and Bases. The more restrictive changes of adding an Applicability and Action eliminates the precursor to an event (fuel handling accident) that may release radioactivity when the control room ventilation systems are inoperable. The less restrictive changes revises the TS to rely on the instrumentation'n credited in the
. accident analysis and to allow irradiated fuel assemblies to be placed in a safe 7
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position to preclude a fusi handling accident. The instruments are required to be operable per TS. Comp:iance with these TS and also the SDM TS ensures that boron dilution event is precluded or can be mitigated. Therefore, suspension of positive reactivity changes is not required when the control room ventilation systems are inoperable. These Actions ensure that appropriate measures are taken to preclude events that would require the control room to be isolated when any of the control room ventilation systems are inoperable. Therefore, 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 J
proposed change does not constitute a significant hazards consideration as defined by 10CFR50.92; and (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC final environmental statement.
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