W3F1-2004-0059, Reactor Coolant System Leakage Detection

Reactor Coolant System Leakage Detection

ML041970378
Person / Time
Site:	Waterford
Issue date:	07/08/2004
From:	Peters K Entergy Nuclear South, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2004-0059
Download: ML041970378 (3)

Text

Entergy Nuclear South AEntergy Operations. Inc.

17265 River Road Entergy Kilona, LA 70066 Tel 504 739 6440 Fax 504 739 6698 kpetersQentergy.com Ken Peters Director, Nuclear Safety Assurance Waterford 3 W3Fl-2004-0059 July 8, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Reactor Coolant System Leakage Detection Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

Reference:

Entergy Letter dated May 7, 2004, "License Amendment Request NPF-38-254 Reactor Coolant System Leakage Detection

Dear Sir or Madam:

The purpose of this letter is to request that the License Amendment Request regarding the Reactor Coolant System Leakage Detection Technical Specification (Reference 1) be reviewed on an exigent basis as allowed by 10 CFR 50.91(a)(6). This request was discussed during a conference call between Entergy Operations, Inc. (Entergy) and members of the NRC staff on July 8, 2004. The circumstances that necessitate this exigent request are the following.

Technical Specification (TS) 3/4.4.5.1 requires the following to be operable:

a. A containment atmosphere particulate radioactivity monitoring system, and

b. a containment sump level and flow monitoring system, and

c. either the containment air cooler condensate flow switches on at least three coolers or a containment atmosphere gaseous radioactivity monitoring system.

In the event that one leakage detection system is inoperable, the TS action requires that the inoperable leakage detection system be restored to operable within 30 days. In the event that two leak detection systems are inoperable, the TS require that the plant be shutdown (i.e. Hot Standby).

The containment sump monitor is currently inoperable (declared inoperable at approximately 11:15 on July 7, 2004) because of an apparent zero shift in indicated level.

The preliminary apparent cause for this condition is a malfunctioning transmitter. The fyO

W3Fl-2004-0059 Page 2 transmitter can only be repaired during plant shutdown conditions due to personnel hazardous conditions in the containment sump with the reactor at power. These conditions include very high radiation area and high ambient temperature in the containment sump area. The containment atmosphere gaseous radioactivity monitoring system is currently inoperable because of uncertainty whether the system can detect a one gpm leakage in one hour in accordance with Regulatory Guide 1.45. Thus, in the event that either the particulate monitor or the containment fan cooler condensate flow switches become inoperable, Waterford Steam Electric Station, Unit 3 (Waterford 3) would be in a six hour shutdown action statement.

The failure of the containment sump monitor was detected on July 7, 2004 and, based on troubleshooting to date, may not be able to be repaired without a unit shutdown. TS actions currently require that the containment sump monitor be repaired within 30 days before requiring Waterford 3 to shutdown.

The filter paper on the particulate radioactivity monitor is replaced approximately every two weeks, requiring that monitor to be declared inoperable. With the containment sump inoperable, Waterford 3 is required to enter the six hour shutdown action whenever the filter paper is replaced. The replacement of filter paper normally takes approximately 30 minutes. The filter paper was replaced last on July 8, 2004. The potential exists that during this replacement unforeseen problems could occur, such as damage to the paper drive assembly or other installation difficulties during the replenishment of paper. Also, there is the potential for other malfunctions of the particulate monitor or containment air cooler flow switches to occur while the containment flow and level sump monitor remains inoperable.

The License Amendment Request (Reference 1), if approved, would allow two of the three required leakage detection systems to be inoperable for up to 30 days. This would alleviate the need to place Waterford 3 in a six hour shutdown action if either the particulate monitor or containment fan cooler condensate flow switches become inoperable. The approval of the referenced License Amendment Request may also obviate the need for other immediate measures by the NRC staff and Entergy, such as a request for a Notice of Enforcement Discretion (NOED), if an additional leakage detection system became inoperable. Therefore, Entergy requests that the referenced License Amendment Request be reviewed and approved on an exigent bases in accordance with 10 CFR 50.91 (a)(6).

This letter does not contain any commitments.

Sincerely SeAueters bi~coNuclear Safety Assurance KJP/RJM

W3FI-2004-0059 Page 3 cc: Mr. Bruce S. Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn ATTN: N.S. Reynolds 1400 L Street, NW Washington, DC 20005-3502