W3F1-2002-0073, Application for Technical Specification Change Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process

Application for Technical Specification Change Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process

ML022410021
Person / Time
Site:	Waterford
Issue date:	08/19/2002
From:	Venable J Entergy Nuclear South, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2002-0073
Download: ML022410021 (19)

Text

Entergy Nuclear South Entergy Operations, Inc 17265 River Road Killona, LA 70066 l' Entergy Tel 504 739 6660 Fax 504 739 6678 jvenabl@entergy com Joseph E. Venable Vice President, Operations Waterford 3 W3F1-2002-0073 August 19, 2002 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License Amendment Request NPF-38-242 Application for Technical Specification Change Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process

REFERENCES:

Federal Register Volume 66, Number 189, pages 49714-49717 dated September 28, 2001

Dear Sir or Madam:

Pursuant to 10CFR50.90, Entergy Operations, Inc. (Entergy) hereby requests the following amendment for Waterford Steam Electric Station, Unit 3 (Waterford 3). The proposed amendment would modify Technical Specification requirements for missed surveillances in Specification 4.0.3.

Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing Technical Specification page marked up to show the proposed change while Attachment 3 provides the revised (clean) Technical Specification page. The proposed change includes a new commitment as summarized in Attachment 4. Attachment 5 provides the existing Technical Specification Bases pages marked up to show the proposed change for information only.

The NRC has approved similar Technical Specification changes for other plants.

The proposed change has been evaluated in accordance with 10CFR50.91(a)(1) using criteria in 10CFR50.92(c) and it has been determined that this change involves no significant hazards considerations. The bases for these determinations are included in the attached submittal.

This application is made under the provisions of the Consolidated Line Item Improvement Process (CLIIP) as stipulated in the referenced Federal Register Notice dated September 28, 2001. The proposed change meets the requirements and content of the model application published in the Federal Register.

W3F1-2002-0073 Page 2 of 2 August 19, 2002 Entergy is respectfully requesting review and approval of this request by July 31, 2003. Once approved, the amendment will be implemented within 60 days.

If you have any questions or require additional information, please contact D. Bryan Miller at 504-739-6692.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August 19, 2002.

Sincerely, Joseph E. Venable Vice President, Operations Waterford Steam Electric Station, Unit 3 JEV/DBM/cbh Attachments:

1. Analysis of Proposed Technical Specification Change

2. Proposed Technical Specification Changes (mark-up)

3. Proposed Technical Specification Page

4. List of Regulatory Commitments

5. Changes to Technical Specification Bases Pages (Mark-up for Information Only) cc: E.W. Merschoff, NRC Region IV N. Kalyanam, NRC-NRR J. Smith N.S. Reynolds NRC Resident Inspectors Office Louisiana DEQ/Surveillance Division American Nuclear Insurers

W3F17-2002-0073 Page 3 August 19, 2002 e-mail: Standard Distribution H.A. Brodt (W-GSB-320)

SRC Secretary (C. E. Brooks)(M-ECH-414) bcc: R.L. Williams (W-GSB-318)

Waterford 3 Records Center (W-GSB-100)

TSCR File (NPF-38-242)

Licensing Green Folder File

Attachment I W3FI-2002-0073 Analysis of Proposed Technical Specification Change to W3F1-2002-0073 Page 1 of 3

1.0 DESCRIPTION

This letter is a request to amend Operating License NPF-38 for Waterford Steam Electric Station, Unit 3 (Waterford 3).

The proposed amendment modifies Technical Specifications (TS) requirements for missed surveillances in Specification 4.0.3. The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard TS (STS) change TSTF-358 Revision 5, as modified by Federal Register Notice 66FR32400, of June 14, 2001, and in response to public comments. The availability of this TS improvement was published in the Federal Register on September 28, 2001 as part of the Consolidated Line Item Improvement Process (CLIIP). In conjunction with the TSTF-358 incorporation, the wording of Specification 4.0.3 and its associated Bases is modified to obtain consistency with the STS of NUREG 1432, Revision 2.

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Entergy Operations, Inc. (Entergy) has reviewed the safety evaluation dated June 14, 2001 as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-358. Entergy has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Waterford 3 and justify this amendment for the incorporation of the changes into the Waterford 3 TS.

The modification of Specification 4.0.3 and the Specification 4.0.3 Bases wording to be consistent with that of NUREG 1432, Revision 2 provides for consistent incorporation of TSTF 358 and results in only a minor difference in the requirement. The current Waterford 3 TS requires that upon discovery of a missed surveillance the associated Limiting Condition for Operation (LCO) be declared not met but delays implementation of the Action Statement requirements of the LCO. Modifying the wording to be consistent with NUREG-1432 allows the declaration of the LCO not being met to be delayed. Effectively, both wordings provide the same flexibility, i.e., the allowance to delay implementing actions required by a LCO when a surveillance has been missed.

2.2 Optional Changes and Variations Entergy is not proposing any variations or deviations from the TS changes described in the fully modified TSTF-358 Revision 5 or the NRC staff's model safety evaluation dated June 14, 2001, except as required to incorporate terminology of the current Waterford 3 TS. Revising the current Specification 4.0.3 and Specification 4.0.3 Bases wording, to be consistent with NUREG 1432, Rev. 2, does not affect the incorporation of the approved TSTF.

to W3F1-2002-0073 Page 2 of 3

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Entergy has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. Entergy has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Waterford 3 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a). The revision of the current Specification 4.0.3 and Specification 4.0.3 Bases wording to be consistent with the Standard Technical Specifications (STS) of NUREG 1432, Rev. 2 does not add or remove flexibility in station operation, except in the administrative application of the requirement and, therefore, is not evaluated under the NSHCD.

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on September 28, 2001 for this TS improvement, plant-specific verifications were performed as follows:

Entergy has established TS Bases for Specification 4.0.3 which state that use of the delay period established by Specification 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals, but only for the performance of missed surveillances.

The modification will also include changes to the Bases for Specification 4.0.3 that provide details on how to implement the new requirements. The Bases changes provide guidance for surveillance frequencies that are not based on time intervals, but on specified unit conditions, operating situations, or requirements of regulations. In addition, the Bases changes state that Waterford 3 is expected to perform a missed surveillance test at the first reasonable opportunity, taking into account appropriate considerations, such as the impact on plant risk and accident analysis assumptions, consideration of unit conditions, planning, availability of personnel, and the time required to perform the surveillance. The Bases also state that the risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risks Before Maintenance Activities/ at Nuclear Power Plants," and -that the missed surveillance should be treated as an emergent condition, as discussed in Regulatory Guide 1.182. In addition, the Bases state that the degree of depth and rigor of the evaluation should be commensurate with the importance of the component and that missed surveillances for important components should be analyzed quantitatively. The Bases also state that the results of the risk evaluation determine the safest course of action. Furthermore, the Bases state that all missed surveillances will be placed in the licensee's Corrective Action Program. Finally, Waterford 3 has a Bases Control Program consistent with Section 5.5 of the STS.

4.0 ENVIRONMENTAL CONSIDERATION

S Entergy has reviewed the environmental evaluation included in the model safety evaluation dated June 14, 2001 as part of the CLIIP. Entergy has concluded that the staff's findings presented in that evaluation are applicable to Waterford 3 and the evaluation is hereby incorporated by reference for this application. The revision of the current Specification 4.0.3

Attachment I to ,,

W3FI-2002-0073 Page 3 of 3 and Specification 4.0.3 Bases wording to be consistent with NUREG 1432, Rev. 2 does not affect any environmental onsiderations.

Attachment 2 W3FI-2002-0073 Proposed Technical Specification Changes (mark-up)

W3FI-2002-0073 Page 1 of 2 APPLICABILITY SURVEILLANCE REOUIREMENTS 4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed twenty-five percent of the specified surveillance intervalt 4.0. n O T Me o t s be made un essnthe *rSurveillance Requirementss as at Ls n havobeCa p2 on inoperable equipment.

arormed 4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(s) associated wath the Limiting Condition for Operatior inaccoancperformed wwthin the stated surveillance intervalSor as otherwise specified. This provision shall not prevent passage through or to operational modes as requrred to comply with ACTION requirements.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class n,,2, and 3 components shall be applicable as follows:

a. Inservlce inspection of ASME Code Class 1, 2, and 3 components and inservice testing ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, granted 50.55a(g),

Section except where by the Commission pursuant to 10 written specific Section has been CFR 50, relaef 50.55a(g) (6)().

b. Surveillance intervals specified in Section X] of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications:

99 WATERFORD UNIT 3 3/4 0-2 AMENDMENT NO. 6 2 T W3F17-2002-0073 Page 2 of 2 TECHNICAL SPECIFICATION INSERT If it is discovered that a Surveillance was not performed within its specified interval, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable ACTION(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable ACTION(s) must be entered.

Attachment 3 W3FI-2002-0073 Proposed Technical Specification Page

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed twenty-five percent of the specified surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified interval, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable ACTION(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable ACTION(s) must be entered.

Surveillance Requirements do not have to be performed on inoperable equipment.

4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to operational modes as required to comply with ACTION requirements.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, and 3 components shall be applicable as follows:

a. Inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i).

b. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications:

WATERFORD UNIT 3 3/4 0-2 AMENDMENT NO. 62-99

Attachment 4 W3F1 -2002-0073 List of Regulatory Commitments J

W3F1-2002-0073 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED COMPLETION COMMITMENT DATE (If Required)

ONE- CONTINUING TIME COMPLIANCE ACTION The modification will also include changes to the X Implementation Bases for Specification 4.0.3 that provide details on how to implement the new requirements.

____________________________________ J. _______ I ___________ a

Attachment 5 W3F1 -2002-0073 Changes to Technical Specification Bases Pages (Mark-up for Information Only) to W3Fl-2002-0073 Page 1 of 4 b P BCvh 1.

ur4 estblihe th tszveup~ enfowatis vo'r1 ea r hi a eIMoed ier. ev,-nod en is7 o 1 Is be ed.

ion ,i asctystoc nqes arI t ar ft or oYwn o Ltno obn 1o g str me n hd tr vie ur nt Th spefic on so arins at ue b Be e u Iacab h Su ill e umen hi nt be coa hi ot alci dn nt e ar no t ne Id if t ae rn ned as in aft dIa heoats oesr t a sin orv asn ce d. tno mep Sue cae q uir nt thl the 01 uta tilts ataC qu es e .eap cab h Su 11i n of mcn ha on b i vertI coo asAwO n tedi91 t pei ct at ef ui a in rfd e rid incf t ral ha svn bn In a0 dno ad tht pr sow ofr clcat r 4.. aa e 1 ond tiop e 6uir mnt Wr fas es1 dion Opate i nh ofsubi ca.

• nf e~ ac n.u , if ur- a fo a s vet anc:wit nt pvls sS0pe ic 0 .0. S Id onl a hn al ocl cat n equ me and s. e ore, ret rab v t u er ire ire nt f t al abi out att Ii of a a sa I*

Sq th 24 our or shu wn re red c y h ION qu ama s, oni ACT..3 re241-ur owas provuad pe tt del In.g9.p-Peent ic t re ts. Is roveas ad@ atei Ialo c ttlet ur lai eRe ir ts t en be per roe a Pu 050 t Ia anc 3 t peru th cou tio Of sury 11 ce or utdnht equedC vitACT real nts r ore the re laIleas s w d requedtt p ud mtlo of rye anc . Th ast for Is ova 0 1 ud cc derlo aria can tion ,ad ate ann ,a ilab ityf son , t r ut dt fo he rvei ance andaes ty gni can of sa n er ulr su Su -]a 11 cc qul is ovi on so avisz ti 11 t ftin the ompi on camp .

nt th piI s a nse nce Chan S i ose y I eq s df coam etI Surv la aR re ts at ma ic a en a pti to re rm soSpec ca n4.4 al wed If seoil nc s camp ted hi ae2C all nec the 1.. limt a he T re li-ants sa CA at at me. Wh a a ancis oi thin he -houu-all anc nd 5 e1 nc a r sa the Ma itsft AC utr ntare ppl abI t a at 0 WATERFORD - UNIT 3 B 3/4 0-5 AMENDMENT NO. 99 to "

W3F1-2002-0073 Page 2 of 4 BASES Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures -that apply. However, the Surveillance Requirements have to be met to demonstrate that Inoperable equipment has been restored to OPERABLE status.

Soecification 4.0.4 establishes the requirement that all applicable surveillance must be met before entry into an OPERATIONAL MODE or other condition of operation specified in the Applicability statement. The purpose of this specification is to ensure that system and component OPERABILITY

-requirements or parameter limits are met before entry Into a MODE or condition for which these systems and components ensure safe operation of the facility.

This provision appl ies to changes in OPERATIONAL MODES or other specified conditions associated witlk plant shutdown as well as startup.

Under the provisions of this specification, the applicable Surveillance Requirements must be performed within the specified surveillance interval to ensure that the Limiting Condition for Operation are met ddring initial plant startup or following a plant outage.

When a shutdown is required to comply with ACTION requirements, the provisions of Specification 4.0.4 do not apply because this would delay placing the facility in a lover NODE of operation.

Specification 4.0.5 establishes the requirement that inservice inspection of ASKE Code Class 1, 2, and 3 components and inservice testing of ASIHE Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with a periodically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CFR 50.55a. These requirements apply except when relief has been provided in writing by'the Commission.

This specification Includes a clarification of the frequencies for performing the inservice inspection and testing activities required by Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda.

This clarification is provided to ensure consistency in surveillance intervals throughout these Technical Specifications and to remove any ambiguities relative to the frequencies for performing the required inservice inspection and testing activities.

Under the terms of this Specification, the more restrictive requirements of the Technical Specifications take precedence over the ASHE Boiler and Pressure Vessel Code and applicable Addenda. For example, the requirements of Specification 4.0.4 to perform surveillance activities prior to entry Into an OPERATIONAL MODE owr other specified applicability condition takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows pumps to be tested-up to one week after return to normal operation. And for example, the Technical Specification definition of OPERABLE does not grant a grace period before a device that is not capable of performing its specified function is declared inoperable and takes Orecedence over the ASME Boiler and Pressure Vessel Code provision which allows a valve to be incapable of performing its specified function for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before being declared inoperable.

WATERFORD - UNIT 3 B 3/4 0-6 AMENDMIENT NO0.

99 to W3FI-2002-0073 Page 3 of 4 BASES INSERT

... flexibility to defer declaring affected equipment inoperable oor an affected variable outside the specified limits when a Surveillance has not been completed within its specified interval. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4.0.2, and not at the time that the specified interval was not met.

This delay period provides an adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with required actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements. When a Surveillance with an interval based not on time intervals, but upon specified unit conditions, operational situations, or requirements of regulations (e.g, prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, Specification 4.0.3 allows the full delay period of up to the specified interval to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity. Specification 4.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by required actions.

Failure to comply with specified intervals for surveillance requirements is expected to be an infrequent occurrence. Use of the delay period established by Specification 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified interval is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 ,CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.' This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and inrcluding plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed to W3F1-2002-0073 Page 4 of 4 Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the allowed outage times of the required actions for the applicable LCO begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the allowed outage times of the required actions for the applicable LCO begin immediately upon the failure of the Surveillance.

Satisfactory completion of the Surveillance within the delay period allowed by this Specification, or within the allowed outage time of the actions, restores compliance with Specification 4.0.1.