Text

License Amendment Request NPF-38-267, Reactor Coolant System Leakage Detection Instrumentation, Waterford Steam Electric Station, Unit 3
	ML062720068
Person / Time
Site:	Waterford
Issue date:	09/26/2006
From:	Venable J; Entergy Nuclear South
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NPF-38-267, TAC MD0173, W3F1-2006-0052
	Download: ML062720068 (32)
	v • d • e

Entergy Nuclear South Entergy Operations, Inc.

17265 River Road Killona, LA 70057 Tel 504 739 6660 SEntergy Fax 504 739 6678 jvenabl@entergy.com Joseph E. Venable Vice President, Operations Waterford 3 W3F1-2006-0052 September 26, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request NPF-38-267 Reactor Coolant System Leakage Detection Instrumentation Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38 REFERENCES 1. Entergy letter dated August 8, 2005, "Licensee Event Report 2005-002-00" (W3F17-2005-0061)

2. Entergy letter dated January 13, 2006, "Licensee Event Report 2005-002-01" (W3F17-2006-0004)

3. Entergy letter dated February 15, 2006, "License Amendment Request NPF-38-267 Reactor Coolant System Leakage Detection Instrumentation" (W3F1-2006-0005)

4. NRC letter dated June 2, 2006, "Waterford Steam Electric Station, Unit 3 (Waterford.3) Request for Additional Information Related to Proposed Technical Specification Changes Regarding Leak Detection Instruments (TAC NO. MD0173) (ILN06-0063)

5. Entergy letter dated July 28, 2006, "Supplement to Amendment Request NPF-38-267 Reactor Coolant System Leakage Detection Instrumentation Waterford Steam Electric Station, Unit 3" (W3F1-2006-0041)

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby revises the previously requested amendment (Reference 3) to Waterford Steam Electric Station, Unit 3 (Waterford

3) Technical Specification (TS) 3.4.5.1, "Reactor Coolant System Leakage - Leakage Detection Instrumentation." The proposed change specifically credited the measurement tank weir flow instrumentation for the containment fan cooler condensate flow monitoring system in place of the one containment fan cooler condensate flow switch currently required by the TS limiting condition for operation. Based on discussions with the NRC, this method of monitoring leakage does not provide sufficient diversity. Therefore, Entergy proposes to delete the containment fan cooler condensate flow monitors from the TSs. This letter supersedes the previous amendment request (Reference 3).

As a result of investigations initiated following the issuance of Reference 1, it was determined that the containment fan cooler condensate flow switches were not capable of detecting a one

W3F17-2006-0052 Page 2 of 3 gallon per minute (gpm) Reactor Coolant System (RCS) leak in one hour. This is because the containment fan cooler condensate flow switches monitor condensate flow from individual containment fan coolers and do not sum the condensate flow from all containment fan coolers. In addition, the condensate flow switches cannot'be adjusted low enough to reliably detect a one gpm RCS leak in one hour based on a ireasonably assumed distribution of the one gpm RCS leak throughout containment. This condition has existed since the original Waterford 3 license was issued.

The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards consideration. The bases for these determinations are included in the attached submittal. The proposed change includes new commitments.

Entergy requests approval of the proposed amendment by April 30, 2007. Once approved, the amendment shall be implemented within 60 days. Although this request is neither exigent nor emergency, your prompt review is requested.

If you have any questions or require additional information, please contact Dana Millar at 601-368-5445.

I declare under penalty of perjury that the foregoing is true and correct. Executed on September 26, 2006.

Sincerely, JEV/DM/cbh Attachments:

1. Analysis of Proposed Technical Specification Change

2. Proposed Technical ~Specification

~ , ,

Changes (mark-up) 1,l H-

3. Proposed Technical Specification Changes (revised) 1:1ll*l

' 1 1 'F

4. Changes to Technical Specification Bases Pages - For Information Only

5. List of Regulatory Commitments

W3F1 -2006-0052 Page 3 of 3 cc: Dr. Bruce S. Mallett U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Senior Resident Inspector Waterford 3 P.O. Box 822 Killona, LA 70066-0751 U.S. Nuclear Regulatory Commission Attn: Mr. Mel B. Fields MS O-7E1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway Attn: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn Attn: N.S. Reynolds 1700 K Street, NW Washington, DC 20006-3817 Morgan, Lewis & Bockius LLP ATTN: T.C. Poindexter 1111 Pennsylvania Avenue, NW Washington, DC 20004 Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division P. O. Box 4312 Baton Rouge, LA 70821-4312 American Nuclear Insurers Attn: Library 95 Glastonbury Blvd.

Suite 300 Glastonbury, CT 06033-4443

Attachment I To W3FI-2006-0052 Analysis of Proposed Technical Specification Change to W3FI-2006-0052 Page 1 of 12

1.0 DESCRIPTION

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

A change is proposed to Technical Specification (TS) 3.4.5.1, "Reactor Coolant System Leakage - Leakage Detection Instrumentation," that will delete the Containment Fan Cooler (CFC) condensate flow switch currently required by the TS Limiting Condition for Operation (LCO) and included in the Actions and Surveillance Requirements (SRs).

2.0 PROPOSED CHANGE

The proposed change will delete "c" from the LCO of TS 3.4.5.1 which states:

"c. One containment fan cooler condensate flow switch."

With the deletion of the CFC condensate flow switch from the TS LCO, references to the CFC condensate flow switches will be removed from Action "a." Actions "c," "d" and "e" will be deleted. The proposed change will result in the following Actions (note no changes are proposed to Actions "b" or "f"other than re-indexing "f" as "c")

a. Required containment atmosphere particulate radioactivity monitor inoperable.

NOTE: SR 4.4.5.2.1 is not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

Analyze grab samples of the containment atmosphere once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or perform SR 4.4.5.2.1 once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; and Restore required containment atmosphere particulate radioactivity monitor to OPERABLE status within 30 days; or Be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. Required containment sump monitor inoperable.

NOTE: SR 4.4.5.2.1 is not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

Perform SR 4.4.5.2.1 once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and restore the containment sump monitor to OPERABLE status within 30 days; or Be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

to W3F1 -2006-0052 Page 2 of 12

c. All required RCS leakage detection instrumentation inoperable.

Initiate ACTION within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The proposed change will result in the deletion of SR 4.4.5.1c.

Due to the deletion of a large amount of text on page 3/4 4-17a, the text on page 3/4 4-17b will be moved to page 3/4 4-17a and page 3/4 4-17b will be deleted.

In summary, reference to the CFC condensate flow switch will be deleted from TS 3.4.5.1, the associated actions and SR.

The Technical Specification Bases will be revised to reflect the changes described above in accordance with the TS Bases Control Program (TS 6.16). Marked up TS Bases pages are attached for information only.

3.0 BACKGROUND

Waterford 3 employs four methods of leak detection:

Monitoring sump level and flow,

Monitoring airborne particulate radioactivity,

Monitoring the condensate from the containment air coolers, and

Monitoring airborne gaseous radioactivity.

Waterford 3 applies all four methods of leak detection; however, no credit is taken in the Waterford 3 Technical Specifications for monitoring airborne gaseous radioactivity (Reference 6.4).

The RCS leakage detection instrumentation is not a part of plant control instruments or engineered safety feature actuation circuits and is used for monitoring RCS leakage.

3.1 Containment Sump Level and Flow (Rate of Level Change) Monitor Containment sump level instrumentation channels, SP IL6705A and SP IL6705B, are used to monitor the level of the containment sump. SP IL6705A provides a level indication on the Qualified Safety Parameter Display System (QSPDS) and a control board indicator in the main control room. SP IL6705B provides a level indication on the Plant Monitoring Computer (PMC) and a recorder in the main control room. The time rate of change in sump level is automatically converted to an in-leakage flow rate by the PMC based on level changes from SP IL6705B only. The containment sump level transmitters are safety related, seismically qualified and have the sensitivity to detect a one gallon per minute (gpm) leak within one hour as required by Regulatory Guide (RG) 1.45, Reactor Coolant Pressure Boundary Leakage Detection Systems.

The PMC is non-safety related and is not seismically qualified. Therefore, guidance to perform this level rate of change conversion manually using either level loop (i.e., SP IL6705A or SP IL6705B) is included in operating procedures should the PMC be to W3FI-2006-0052 Page 3 of 12 unavailable. Plant Monitoring Computer alarms are set at one gpm and 10 gpm. The containment sump level rate of change instrumentation was approved as an acceptable containment sump monitoring method via Amendment 197. Refer to References 6.3, and 6.4 for additional information regarding the containment sump level rate of change instrumentation for the containment sump monitoring method.

3.2 Containment Buildinq Airborne Monitor The containment atmosphere is monitored for airborne radiation by a Particulate -

Iodine - Gas (PIG) monitor (PRMREOIOOY) and provides indications to the main control room of particulate, iodine, and gaseous radioactivity in the containment. The PIG is comprised of three channels, each providing potential indication of RCS leakage. However, only the particulate channel has the required sensitivity and response time to detect a one gpm leak within one hour as specified in RG 1.45 at the RCS activity levels normally seen during power operation. The containment atmosphere radiation monitor is safety-related, seismically qualified, and provides a continuous indication in the main control room of the particulate, iodine and gaseous radioactivity levels inside the containment. Each PIG channel provides an alert and high alarm indication in the main control room. The particulate channel alert alarm annunciates on a rising radiation level that corresponds to about 0.1 gpm RCS leakage. The high alarm annunciates on a rising radiation level that corresponds to about 1.0 gpm RCS leakage.

3.3 Air Cooler Condensate Flow Switch Containment Fan Cooler (CFC) condensate flow switches detect flow through the CFC drains that are piped to the containment sump measuring tank weir inlet pipe. CFC A and C have two drain lines each and CFC B and D have one drain line each. The presence of flow in the lines is detected by six flow switches (one per drain line) which are monitored by the PMC. Each switch is set to provide a PMC alarm when approximately 1 gpm of flow is present in its associated drain line.

Prior to Amendment 197 (Reference 6.4), which was approved on July 30, 2004, the TS required containment air cooler condensate flow switches on at least three coolers or a containment gaseous radioactivity monitoring system. Currently, the TS LCO requires at least one CFC condensate flow switch associated with an operable and operating CFC.

Following the issuance of Licensee Event Report (LER) 2005-002-000 dated August 8, 2005, (Reference 6.5), it was determined that the CFC condensate flow switches, as required by TS, prior to and following the approval of Amendment 197, were and are not capable of detecting a one gpm RCS steam leak (Reference 6.6). The CFC condensate flow switches potentially would not detect a one gpm increase in aggregate CFC condensate drain flow ifthe flow was split between two or more drains. When it is assumed that the steam is condensed by multiple operating CFCs or a single CFC containing two drains/switches, a one gpm RCS steam leak may go undetected because the CFC condensate switches provide discrete flow/no-flow indication at a one gpm water flow setting, and cannot provide an indication of the to W3F1-2006-0052 Page 4 of 12 aggregate CFC condensate drain flow. Waterford 3 normally runs multiple CFCs during power operation. Refer to Reference 6.6 for additional details.

3.4 Measurement Tank Weir Flow Instrumentation The measurement tank weir flow instrumentation was the containment sump monitoring method prior to Amendment 197 and is one of two containment sump monitoring methods as allowed by Amendment 197. (See the containment sump level and flow (rate of level change) monitor discussion in Section 3.1 above for a description of the other containment sump monitoring method.)

The following sources are routed to the measuring tank prior to entering the containment sump:

" air cooler condensate drains,

equipment drains (-30) (e.g., instrument cabinets, valve leakoff, etc.),

" reactor building floor drains (-28), and

safety injection tank drain lines.

The following discharge directly to the containment sump without passing through the measurement tank:

two shutdown cooling system suction line relief valves (TS 3.4.8.3), and

reactor drain tank relief valve.

The measurement tank weir flow instrumentation consists of a measurement tank with a triangular notch weir through which water leaving the measurement tank flows; the water then gravity drains to the containment sump. The measurement tank is fitted with a level transmitter. Level measured in the tank is a function of the flow through the measurement tank weir. Increased level in the tank indicates increased flow through the weir. The measurement tank weir flow instrument (SP IL671 0), is non-safety related and seismically qualified. The weir transmitter SP ILT671 0 is non-safety related and is qualified seismic class 2.

The measurement tank weir flow instrumentation is capable of detecting a one gpm RCS leak within one hour as specified in RG 1.45. An alarm, with an adjustable setpoint, is available that is normally set at one gpm above normal flow through the measurement tank.

3.5 Amendment 197 Amendment 197 (Reference 6.4) approved changes to TS 3.4.5.1 and was issued on July 30, 2004. Amendment 197:

" deleted the containment atmosphere gaseous radioactivity monitor,

incorporated a second containment sump level and flow monitoring method (i.e., continuing to credit the measurement tank weir flow instrumentation and adding the containment sump level rate of change instrumentation), and

clarified the actions statements consistent with NUREG-1432.

Attachment 1 to W3F17-2006-0052 Page 5 of 12

4.0 TECHNICAL ANALYSIS

The proposed change will eliminate the use of the CFC condensate flow switch as a TS required RCS leakage monitoring device due to its inability to detect a 1 gpm leak in one hour.

Regulatory Guide 1.45 states in Regulatory Position C.3:

3. At least three separate detection methods should be employed and two of these should be (1) sump level and flow monitoring and (2) airborne particulate radioactivity monitoring. The third method may be selected from the following:

a. monitoring of condensate flow rate from air coolers,

b. monitoring of airborne gaseous radioactivity.

Humidity, temperature, or pressure monitoring of the containment atmosphere should be considered as alarms or indirect indication of leakage to the containment.

The Regulatory Guide further states that RCS leakage detection instrumentation must:

1. be capable of a sensitivity and response time adequate to detect a leak rate, or its equivalent, of one gpm in less than one hour (C.5),

2. perform its functions following seismic events that do not require a plant shutdown (C.6),

3. provide indicators and alarms in the main control room (C.7),

4. be equipped with provisions to readily permit testing for operability and calibration during plant operation (C.8), and

5. be addressed in technical specifications (C.9).

The proposed change is taking an exception to the Regulatory Guide. While Waterford 3 utilizes four separate methods of RCS leakage detection instrumentation, only two of the instruments meet the sensitivity requirements of Regulatory Guide position c.5. Therefore, Waterford 3 will take exception to Regulatory Guide position c.5. Waterford 3 will include the two detection methods that meet the Regulatory Guide in the Technical Specifications.

Consistent with the current licensing basis Waterford 3 will credit the sump level and flow monitoring system; this is comprised of either the Containment Sump Level and Flow (Rate of Level Change) Monitor or the Measurement Tank Weir Flow Instrumentation. Also consistent with the current licensing basis, Waterford 3 will credit the particulate channel of the Containment Building Airborne Monitor. The gaseous radioactivity monitor, although not included in the TSs, will be maintained functional and available.

The CFC condensate flow switches are not capable of quantifying a one gpm RCS leak in one hour. This is because the containment fan cooler condensate flow switches monitor condensate flow from individual containment fan coolers and do not sum the condensate flow from all containment fan coolers. This condition has existed since the original Waterford 3 license was issued.

The deletion of the CFC condensate flow switch does not significantly decrease the ability to detect RCS leakage. Separate means, as described above, are available to assist in detecting RCS leakage. An RCS water inventory balance is required at least once per

Attachment 1 to W3F1-2006-0052 Page 6 of 12 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months by the performance of SR 4.4.5.2.1. Performance of the water inventory balance is also required when containment sump monitoring instrumentation is inoperable. If the containment particulate monitor is inoperable, either grab samples are analyzed or an RCS water inventory balance is performed once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The water inventory balance can provide indication of a one gpm leakage change (identified or unidentified). Waterford 3 also monitors containment internal pressure and containment average air temperature in accordance with TS 3.6.1.4 and TS 3.6.1.5, respectively. Containment building humidity is also monitored. Each of these provides additional means of identifying RCS leakage.

5.0 REGULATORY ANALYSIS

5.1 Applicable Regulatory Requirements/Criteria General Design Criterion 30, "Quality of Reactor Coolant Pressure Boundary," of Appendix A to 10 CFR Part 50, "General Design Criteria for Nuclear Power Plants," requires that means be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant system leakage. Regulatory Guide (RG) 1.45 describes acceptable methods of implementing this requirement with regard to the selection of leakage detection systems for the reactor coolant pressure boundary. The means by which the Waterford Steam Electric Station, Unit 3 (Waterford 3) leak detection systems conforms to each Regulatory Position of RG 1.45 is provided below.

Regulatory Position C.1:

The source of reactor coolant leakage should be identifiable to the extent practical. Reactor coolant pressure boundary leakage detection and collection systems should be selected and designed to include the following:

Leakage to the primary reactor containment from identified sources should be collected or otherwise isolated so that:

a. the flow rates are monitored separately from unidentified leakage, and

b. the total flow rate can be established and monitored.

Justification for Conformance with Regulatory Position C.1:

Identified Reactor Coolant System (RCS) leakage as defined in RG 1.45 Section B is (1) leakage into closed systems, such as pump seal or valve packing leaks that are captured, flow metered, and conducted to a sump or collecting tank, or (2) leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of unidentified leakage monitoring systems or not to be from a flaw in the reactor coolant pressure boundary. The original Waterford 3 Safety Evaluation Report (NUREG-0787) cites the identified leakage sources and their adherence to the RG 1.45 recommendations. The cited identified leakage sources are described in further detail in the Waterford 3 Final Safety Analysis Report (FSAR) Section 5.2.5.1. Waterford 3 TS define identified leakage as leakage (except controlled leakage) into closed systems, such as pump seal or valve packing leaks that are captured, and conducted to a sump or collecting tank, or leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary leakage, or reactor coolant system leakage through a steam generator to the secondary system. Controlled leakage is defined in TS as the seal water flow supplied

Attachment 1 to W3FI-2006-0052 Page 7 of 12 from the reactor coolant pump seals. Unidentified leakage is defined in TS as all leakage which is not identified leakage or controlled leakage.

As described in FSAR 5.2.5.1, unidentified and identified leakage rates are discernable, quantifiable, and easily totaled to derive RCS total leakage.

Requlatory Position C.2:

Leakage to the primary reactor containment from unidentified sources should be collected and the flow rate monitored with an accuracy of one gallon per minute (gpm) or better.

Justification for Conformance with Regulatory Position C.2:

All leakage to the primary reactor containment from unidentified sources is collected in the containment sump after passing through a measurement tank. The flow rate is monitored, as described in FSAR 5.2.5.1.1, by the measurement tank weir flow instrumentation or the sump level rate of change instrumentation with an accuracy of better than one gpm.

Requlatory Position C.3:

At least three separate detection methods should be employed and two of these methods should be (1) sump level and flow monitoring and (2) airborne particulate radioactivity monitoring. The third method may be selected from the following:

a. monitoring of condensate flow rate from air coolers,

b. monitoring of airborne gaseous radioactivity.

Humidity, temperature, or pressure monitoring of the containment atmosphere should be considered as alarms or indirect indication of leakage to the containment.

Justification for Conformance with Regulatory Position C.3:

The sump level and flow monitoring (first required detection method) is described in detail in FSAR section 5.2.5.1.1. The method is comprised of redundant containment sump level instrumentation and flow indication and is derived from the change in level over time.

The airborne particulate radioactivity (second required detection method) is monitored by a dedicated particulate radiation monitor as described in FSAR section 5.2.5.1.2.

The condensate flow from the containment air coolers (third method) is drained collectively, along with other containment drainage sources, to common discharge piping at the containment sump, which is monitored by the measurement tank weir flow instrumentation.

FSAR section 5.2.5.1.1 describes this indication and that all of the air cooler drain flow is detected by the measurement tank weir flow instrumentation. The containment fan cooler (CFC) condensate flow switches are not capable of quantifying a one gpm RCS leak in one hour. This is because the containment fan cooler condensate flow switches monitor condensate flow from individual containment fan coolers and do not sum the condensate flow from all containment fan coolers. This condition has existed since the original Waterford 3 license was issued. Due to the inability of these monitors to detect a one gpm leak within one hour, they will be removed from the Technical Specifications (TS).

The airborne gaseous radioactivity (fourth method) is monitored by a dedicated gaseous radiation monitor. Note that this fourth method (i.e., gaseous radiation monitor) was removed

Attachment 1 to W3F1 -2006-0052 Page 8 of 12 from the TS via Amendment 197 (Reference 6.4) because it was not capable of detecting a one gpm RCS leak within one hour due to the plant's improved nuclear fuel performance.

Various other leak detection methods, not included in TS 3.4.5.1, and described above are employed for diversity and to aid in identifying the potential leak source.

ReQulatory Position C.4:

Provisions should be made to monitor systems connected to the [Reactor Coolant Pressure Boundary] RCPB for signs of intersystem leakage. Methods should include radioactivity monitoring and indicators to show abnormal water levels or flow in the affected area.

Justification for Conformance with Recqulatory Position C.4:

The RCS connects to the Chemical Volume Control System (CVCS), Primary Sample System (PSL), Safety Injection (SI), and Steam Generator (SG) systems. Intersystem leaks would be indicated by a change in volume control tank level (control room alarm and indication is provided) and decrease in letdown flow to maintain pressurizer level (control room indication and a high pressurizer level deviation is provided). Refueling Water Storage Pool (RWSP) level, Safety Injection Tank (SIT) level and pressure, and SG level control room alarms and indications are provided. Process radiation monitors are also provided to detect intersystem leakage. Details of these systems are described in FSAR 5.2.5.1.

Re.gulatory Position C.5:

The sensitivity and response time of each leakage detection system in regulatory position 3 above employed for unidentified leakage should be adequate to detect a leakage rate, or its equivalent, of one gpm in less than one hour.

Justification for Conformance with Regulatory Position C.5:

The basis for compliance for regulatory position C.5 includes the sensitivity for detecting a one gpm unidentified leak. The sump level and flow monitoring (first required detection method) is capable of readily detecting a one gpm leak as indicated by a sump level change of 0.22 ft (2.7 inches) within one hour via level transmitters and level indication available in the control room. The measurement tank weir flow instrumentation may also be used to monitor sump level and flow. The adjustable alarm set point is set for the current normal leak rate plus one gpm in order to detect an increase of one gpm of unidentified leakage above the previously identified normal leakage within one hour.

The airborne particulate radioactivity (second required detection method) is monitored by a dedicated particulate radiation monitor. The monitor provides a continuous indication in the main control room for particulate radioactivity levels inside the containment and alarms within one hour at an equivalent activity that would be expected for one gpm RCS unidentified leakage.

The condensate flow from the air coolers, along with other containment drainage, is drained collectively to a common discharge at the containment sump, which is monitored by the measurement tank weir flow instrumentation. Because the containment fan cooler condensate flow switches, which monitor condensate flow from individual containment fan coolers, do not sum the condensate flow from all containment fan coolers, the condensate to W3F1-2006-0052 Page 9 of 12 flow switches are not capable of detecting a one gpm leak. The proposed TS change will delete the condensate flow switch.

The airborne gaseous radioactivity (fourth method) is monitored by a dedicated gaseous radiation monitor, which alarms at an equivalent activity that would be expected for one gpm RCS unidentified leakage per the assumptions and bases described in FSAR question 211.21 item 6. At extremely low RCS activity values, the airborne gaseous radiation monitor sensitivity and response time may be adversely impacted; however, the monitor would remain an available diverse indication of RCS unidentified leakage. Because the sensitivity of the gaseous radiation monitor is adversely impacted by extremely low RCS activity, it was removed from the Technical Specifications via Amendment 197 (Reference 6.4).

Regqulatory Position C.6:

The leakage detection systems should be capable of performing their functions following seismic events that do not require plant shutdown. The airborne particulate radioactivity monitoring system should remain functional when subjected to the safe shutdown earthquake (SSE).

Justification for Conformance with Regulatory Position C.6:

The sump level and flow monitoring (first required detection method) is described in detail in FSAR section 5.2.5.1.1. The method is comprised of redundant containment sump level instrumentation and flow indication and is derived from the change in level over time either automatically (B train only) on the Plant Monitoring Computer (PMC) or manually by the control room operator. The containment sump level loops are seismically qualified and, therefore, expected to remain functional following seismic events that do not require a plant shutdown. The containment sump weir flow indication, which may be used to monitor sump inlet flow, would be expected to remain functional following seismic events that do not require plant shutdown.

The containment particulate radiation monitor flow indication (second required detection method) and containment gaseous radiation monitor are designed to remain functional when subjected to the SSE.

The drain flow from the air coolers via the containment sump weir flow indication (third method) would be expected to remain functional following seismic events that do not require plant shutdown.

Regulatory Position C.7:

Indicators and alarms for each leakage detection system should be provided in the main control room. Procedures for converting various indications to a common leakage equivalent should be available to the operators. The calibration of the indicators should account for needed independent variables.

Justification for Conformance with Regulatory Position C.7:

Sump level and flow monitoring (first required detection method), airborne particulate radioactivity monitoring (second required detection method), condensate flow from air coolers, and airborne gaseous radioactivity all have indicators and alarms (annunciators and/or PMC alarms) provided in the main control room. Indicator calibration is performed and accounts for needed independent variables. Operating procedures include the necessary guidance for

Attachment 1 to W3F1-2006-0052 Page 10 of 12 converting gaseous activity and containment sump level change over time to a RCS unidentified leak rate. Converting particulate activity to RCS unidentified leakage is a linear function between the alert activity level (equivalent to 0.1 gpm) and the alarm activity level (1 gpm). The measurement tank weir flow indication reads out in flow rate and therefore requires no conversion.

Regulatory Position C.8:

The leakage detection systems should be equipped with provisions to readily permit testing for operability and calibration during plant operation.

Justification for Conformance with Regulatory Position C.8:

All leak detection equipment that is likely to require testing for operability and calibration during plant operation can be calibrated during plant operation, however the measurement tank weir flow transmitter may require a downpower to reduce personnel exposure to as low as reasonably achievable. Consistent with the post Amendment 197 licensing basis, the level transmitters for the sump and weir cannot be calibrated during plant operation. Plant procedures provide the needed guidance for calibrating and testing the containment sump level indication, weir flow indication, and radiation monitors. Operations procedures "Technical Specification and Technical Requirements Compliance" and "Technical Specification Surveillance Logs" provide guidance for assuring operability of the leak detection systems.

Regulatory Position C.9:

The technical specifications should include the limiting conditions for identified and unidentified leakage and address the availability of various types of instruments to assure adequate coverage at all times.

Justification for Conformance with Regulatory Position C.9:

Waterford 3 TS 3.4.5.1 includes the limiting conditions for RCS leakage detection instrumentation and TS 3.4.5.2 includes the limiting conditions for RCS leakage.

Entergy has determined that the proposed changes do not require any exemptions from the regulatory requirements, other than the Waterford 3 Technical Specifications. Waterford 3 is taking an exception to Regulatory Guide 1.45, position c.5. The proposed change does not negatively affect conformance with any General Design Criterion (GDC).

5.2 No Significant Hazards Consideration The proposed change to Technical Specification (TS) 3.4.5.1, "Reactor Coolant System Leakage - Leakage Detection Instrumentation," will delete the Condensate Fan Cooler (CFC) condensate flow switch currently required by the TS Limiting Condition for Operation (LCO).

With the approval of the proposed change, two means of monitoring Reactor Coolant System (RCS) leakage will be credited in the TS; the containment sump monitor, which can be met by either the Measurement Tank Weir Flow Instrumentation or the Containment Sump Level and Flow (Rate of Level Change) Monitor, and the Containment Atmosphere Particulate Radioactivity Monitor.

to W3FI-2006-0052 Page 11 of 12 Entergy Operations, Inc. has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The Reactor Coolant System (RCS) leakage detection systems are passive monitoring systems therefore the proposed changes do not affect reactor operations or accident analyses and have no radiological consequences. The proposed change continues to require diverse methods of monitoring leakage. The gaseous radioactivity monitor, although not included in the TSs and the CFC condensate flow switches, which are proposed for removal from the TSs, will be maintained functional and available.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change introduces no new mode of plant operation or any plant modification. The RCS leakage detection instrumentation is used solely for monitoring purposes and is not part of plant control instruments or engineered safety feature actuation circuits. The change does not vary or affect any plant operating condition or parameter.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change does not modify any of the RCS leakage detection instrumentation. The proposed change continues to require diverse methods of monitoring leakage. In addition, although not required by TS, multiple means of diverse monitoring RCS leakage will remain functional and available.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

to W3F1-2006-0052 Page 12 of 12 Based on the above, Entergy concludes that the proposed amendment present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.3 Environmental Considerations The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1. Entergy Letter dated May 7, 2004, "License Amendment Request NPF-38-254, Reactor Coolant System Leakage Detection" (W3F1-2004-0028) 6.2. Entergy Letter dated July 8, 2004, "Reactor Coolant System Leakage Detection" (W3F1-2004-0059) 6.3. Entergy Letter dated July 16, 2004, "Supplement to Amendment Request NPF 254, Reactor Coolant System Leakage Detection" (W3F1-2004-0060) 6.4. NRC Letter dated July 30, 2004, 'Waterford Steam Electric Station, Unit 3 - Issuance of Amendment RE: Reactor Coolant System Leakage Detection (TAC No. MC3085)"

6.5. Entergy Letter dated August 8, 2005, "Licensee Event Report 2005-002-00" (W3F1 -

2005-0061) 6.6. Entergy Letter dated January 13, 2006, "Licensee Event Report 2005-002-01" (W3FI-2006-0004)

Attachment 2 W3FI-2006-0052 Proposed Technical Specification Changes (mark-up) to W3F1-2006-0052 Page 1 of 3 REACTOR COOLANT SYSTEM 3/4.4.5 REACTOR COOLANT SYSTEM LEAKAGE LEAKAGE DETECTION INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.4.5.1 The following Reactor Coolant System leakage detection instrumentation shall be OPERABLE:

a. One containment atmosphere particulate radioactivity monitor, and

b. One containment sump monitor._,-and eG-One-eontainment-an-Geler-condensate4lew-switc-h7 APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

NOTE: TS 3.0.4 is not applicable.

a. Required containment atmosphere particulate radioactivity monitor inoperable.

NOTE: SR 4.4.5.2.1 is not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

Analyze grab samples of the containment atmosphere once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or perform SR 4.4.5.2.1 once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; and Restore required containment atmosphere particulate radioactivity monitor to OPERABLE status within 30 days-or-verify-ene-eentainment-fan G0IeFee Gr-eneate-flew switeh-is-QP-E-RARL-E--wmitin-3O-days; or Be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. Required containment sump monitor inoperable.

NOTE: SR 4.4.5.2.1 is not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

WATERFORD - UNIT 3 3/4 4-17 AMENDMENT NO. 4-97, to W3F1 -2006-0052 Page 2 of 3 REACTOR COOLANT SYSTEM LIMITING CONDITION FOR OPERATION (Continued)

Perform SR 4.4.5.2.1 once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and restore the containment sump monitor to OPERABLE status within 30 days; or Be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c. Reqid ntainmer44an-eeler-Oondensate flow switch inoperable.

NOTE: SR 4.4.5.2.1 is not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of operation 7, P-erform--GANNEL-GHE-GK-onthe--c-ontainment-at mosphere-patiuulater-acdiea*t*ty monitor-once-per-8-hours-or-perform.SSR 4.4;*52*-.-once ..per-24-hours; OF Be in-MO:DE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

d. Required-oitainmer*t-atrospherepati*Ulate radieat_,-iy-moniter-ineperable-and required-ntainment fan cooler condensate flo...sciteh4noperable-.

Retoree4he-required--erntainment-atmosphere-partiGiate-radaGtivity-moniter-orthe required-containment fan-cooler-,.c.e-ndensate-flow switch-to-OPERABLE-status-within-30 days, OF Be-n-MODE-31n-6-hours-and-MODE-5-in4he-following-30-hours..

e- Required--eontainm~ent sump-monitor inoperableanRd-either the required containmn atmosphereparticuLate-adioaefivity-noniteor4neperabke-er4he-require&-eontainmen-a cooler-condensate41ow-switch-ineperable.

Restore.the required -containment--sump -monitor-to-O P ERABLE -status-within4-hour7 ar Resoretherequired containme tnt-tmsphere Particulate radioactiVity monitor or the required-containment-fan-cooler-condensate-flow-switc-h-to.-OPE-RABL-E-status-within hour; Be in-MODE 3-in hours.and-MODE-5.in-the-following 30-hours, WATERFORD - UNIT 3 3/4 4-17a AMENDMENT NO. 4-97, to W3F1-2006-0052 Page 3 of 3 REACTOR COOLANT SYSTEM LIMITING CONDITION FOR OPERATION (Continued) fc. All required RCS leakage detection instrumentation inoperable.

Initiate ACTION within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.4.5.1 The leakage detection systems shall be demonstrated OPERABLE by:

a. Containment atmosphere particulate monitor system - performance of CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , CHANNEL CALIBRATION at least once per 18 months and CHANNEL FUNCTIONAL TEST at least once per 92 days,

b. Containment sump level and flow monitors - performance of a CHANNEL CHECK (containment sump level monitor only) 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 18 months,

. Containment fannsate flow switch - performance of a CHANNEL FUNCT-I0ONAL-T-E-ST-at-least-ence-per-1 8-months.-

WATERFORD - UNIT 3 3/4 4-17b AMENDMENT NO. 4-97,

Attachment 3 W3FI-2006-0052 Proposed Technical Specification Changes (revised) to W3F1-2006-0052 Page 1 of 2 REACTOR COOLANT SYSTEM 3/4.4.5 REACTOR COOLANT SYSTEM LEAKAGE LEAKAGE DETECTION INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.4.5.1 The following Reactor Coolant System leakage detection instrumentation shall be OPERABLE:

a. One containment atmosphere particulate radioactivity monitor, and

b. One containment sump monitor.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

NOTE: TS 3.0.4 is not applicable.

a. Required containment atmosphere particulate radioactivity monitor inoperable.

NOTE: SR 4.4.5.2.1 is not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

Analyze grab samples of the containment atmosphere once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or perform SR 4.4.5.2.1 once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; and Restore required containment atmosphere particulate radioactivity monitor to OPERABLE status within 30 days; or Be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. Required containment sump monitor inoperable.

NOTE: SR 4.4.5.2.1 is not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

WATERFORD - UNIT 3 3/4 4-17 AMENDMENT NO. 497.

to W3F1 -2006-0052 Page 2 of 2 REACTOR COOLANT SYSTEM LIMITING CONDITION FOR OPERATION (Continued)

Perform SR 4.4.5.2.1 once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and restore the containment sump monitor to OPERABLE status within 30 days; or Be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c. All required RCS leakage detection instrumentation inoperable.

Initiate ACTION within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.4.5.1 The leakage detection systems shall be demonstrated OPERABLE by:

a. Containment atmosphere particulate monitor system - performance of CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , CHANNEL CALIBRATION at least once per 18 months and CHANNEL FUNCTIONAL TEST at least once per 92 days.

b. Containment sump level and flow monitors - performance of a CHANNEL CHECK (containment sump level monitor only) 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 18 months.

WATERFORD - UNIT 3 3/4 4-17a AMENDMENT NO. 4-97,

Attachment 4 W3F1-2006-0052 Changes to Technical Specification Bases Pages For Information Only to W3F1-2006-0052 Page 1 of 6 REACTOR COOLANT SYSTEM BASES 3/4.4.5 REACTOR COOLANT SYSTEM LEAKAGE 3/4.4.5.1 LEAKAGE DETECTION SYSTEMS (DRN 04-1223, Ch. 33)

Backq round GDC 30 of Appendix A 10 CFR 50 (Ref. 1) requires means for detecting and, to the extent practical, identifying the location of the source of RCS leakage. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for selecting leakage detection systems.

Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary(RCPB) degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure. Thus an early indication or warning signal is necessary to permit proper evaluation of all UNIDENTIFIED LEAKAGE.

Industry practice has shown that water flow changes of 0.5 gpm to 1.0 gpm can readily be detected in contained volumes by monitoring changes in water level or in flow rate. The containment sump used to collect UNIDENTIFIED LEAKAGE andthe-eOntainmentan-faeeelef (CFG) oGndensate-4---w-switGhes-afe-isinstrumented to alarm for increases of 0.5 gpm to 1.0 gpm in the normal flow rates. This sensitivity is acceptable for detecting increases in UNIDENTIFIED LEAKAGE.

The reactor coolant contains radioactivity that, when released to the containment, can be detected by radiation monitoring instrumentation. Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter until activated corrosion products have been formed and fission products appear from fuel element cladding contamination or cladding defects. Radioactivity detection systems are included for monitoring particulate activities, because of their sensitivities and rapid responses to RCS leakage.

Air temperature and pressure monitoring methods may also be used to infer UNIDENTIFIED LEAKAGE to the containment. Containment temperature and pressure fluctuate slightly during plant operation, but a rise above the normally indicated range of values may indicate RCS leakage into the containment. The relevance of temperature and pressure measurements is affected by containment free volume and, for temperature, detector location.

Alarm signals from these instruments can be valuable in recognizing rapid and sizable leakage to the containment. Temperature and pressure monitors are not required by this LCO.

Applicable Safety Analyses The need to evaluate the severity of an alarm or an indication is important to the operators, and the ability to compare and verify with indications from other systems is necessary. The system response times and sensitivities are described in the UFSAR (Ref. 3).

Multiple instrument locations are utilized, if needed, to ensure the transport delay time of the leakage from its source to an instrument location yields an acceptable overall response time.

The safety significance of RCS leakage varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring RCS leakage into the containment area are necessary. Quickly separating the IDENTIFIED LEAKAGE from the UNIDENTIFIED LEAKAGE provides quantitative information to the operators, allowing them to take corrective action should leakage occur detrimental to the safety of the facility and the public. RCS leakage detection instrumentation satisfies Criterion I of 10 CFR 50.36(c)(2)(ii).

3 (DRN 04-1223, Ch. 33)

WATERFORD -UNIT 3 B 3/4 4-4 CHANGE NO. 33,

Attachment 4 to W3F1-2006-0052 Page 2 of 6 (DRN 04-1223, Ch. 33)

REACTOR COOLANT SYSTEM BASES (continued)

Limiting Condition for Operation One method of protecting against large RCS leakage derives from the ability of instruments to rapidly detect extremely small leaks. This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide a high degree of confidence that small leaks are detected in time to allow actions to place the plant in a safe condition when RCS leakage indicates possible RCPB degradation.

The LCO is satisfied when monitors of diverse measurement means are available.

Thus, the containment sump monitors (either the containment sump level instrumentation / time rate of change or the containment flow instrumentation (weir)), in combination with a particulate radioactivity monitor and a C-,PC, conde te,, , w-switch, provide acceptable monitoring capability for leakage detection.

The .required CFC condensate flow-switch must be associated with-ne-ef-the4we Fequired-OPERABLE CFCs that are in Oper-atie-.

Applicability Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

In MODE 5 or 6, the temperature is <200 0 F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation is much smaller.

Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

Actions The Actions are modified by a Note that indicates the provisions of TS 3.0.4 are not applicable. This allowance is provided because other instrumentation is available to monitor RCS leakage.

Action a With the containment atmosphere particulate radioactivity monitoring instrumentation inoperable, alternative action is required. Either grab samples of the containment atmosphere must be taken and analyzed, or water inventory balances, in accordance with SR 4.4.5.2.1, must be performed to provide alternate periodic information. With a sample obtained and analyzed or an inventory balance performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the reactor may be operated for up to 30 days to allow restoration of the radioactivity monitor. Alternatively-eentinuhedoperatien atlowed4f4he-GFCGow-switGh-is-OPERABL-E-7pmderd-grab-samples-are-taken-or-water inventeoy-halance-perfonrme4-every-24-hou-Fre The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to detect leakage. A Note is added allowing that SR 4.4.5.2.1 is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishing steady state operation (stable temperature, power level, pressurizer and makeup tank levels, makeup and letdown). The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance provides sufficient time to establish stable plant conditions. The 30 day allowed outage time recognizes at least one other form or leakage detection is available.

(DRN 04-1223, Ch. 33)

WATERFORD -UNIT 3 B 3/4 4-4a CHANGE NO. 33, to W3F1-2006-0052 Page 3 of 6

0 (DRN 04-1223, Ch. 33)

REACTOR COOLANT SYSTEM BASES (continued)

IfACTION 'a' cannot be met within the allowed outage time, the 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 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The allowed outage times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Action b If the containment sump monitor is inoperable, (L.e.,both the containment level instrumentation / time rate of change and the containment flow instrumentation (weir)), no other form of sampling can provide the equivalent information.

However, the containment atmosphere radioactivity monitor and-the--GFG4Iow-switGh-will provide indication of changes in leakage. Together with the atmosphere monitor, the periodic surveillance for RCS water inventory balance, SR 4.4.5.2.1, must be performed at an increased frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide information that is adequate to detect leakage. A Note is added allowing that SR 4.4.5.2.1 is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishing steady state operation (stable temperature, power level, pressurizer and makeup tank levels, makeup and letdown). The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance provides sufficient time to establish stable plant conditions.

Restoration of the required sump monitor to OPERABLE status is necessary to regain the function in an allowed outage time of 30 days after the monitor's failure. This time is acceptable considering the remaining OPERABLE leakage detection instrumentation and the frequency and adequacy of the RCS water inventory balance required by the ACTION.

If ACTION 'b' cannot be met within the allowed outage time, the 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 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The allowed outage times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Adtion-G lf4h-e-required-GFCcondensate-flow-switch#s-inoperable,-alternative-action-is-again required 'tther-SR-4.-,a(a--(orntai nment-atmosphere-pariculate-radiation-monitor-G.......

GdE-GK-)-must-be-perfermedor-wate&-hweJntery-baanc-esT-in-ac-Gordanoe-witb-SR-4.4A5 72 mustbe-perfermed-to-pravide-a-ternate-per-iedi-nfrrmatien--RFGvided-a-GHANNEL-GHE-GK-is performed-every-8-hours-or-an-invatorlanc e4s-peorned-eveFy-2Ayheur-&7reaGtof oper-ation-may-eontinue-while-await~ngh-esteratloa*fhe-GF-G-Gondensate4Io-switchto OPERABLE status.

The-24-hour nteFval-pmvdes-perodie4nformation4hat-is-adequate to detect RGS leakage.A-Note-is-added-wchstates-that-SR-4A-4.5.2.!is-not-required-te-bepeeformed-unfil 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establs, ,n,eedy- **operation (stable temperature, per level, p.esSUr.Ze.

and akeu-tak~evfsý ,ý ý c 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowancc provides sufficient time to-establish-s-table-ptant-c6onditio.ns 3 (DRN 04-1223, Ch. 33)

WATERFORD -UNIT 3 B 3/4 4-4b CHANGE NO. 33.

Attachment 4 to W3F1 -2006-0052 Page 4 of 6 (DRN 04-1223, Ch. 33)

REACTOR COOLANT SYSTEM BASES (continued) if ACTION Gcanno be met, whenonn -tn cannot be completed-within the Action-t irne,-the-plant-must-be-brought-to-a-MODE-in-which4he-L-GO-does-not-apply.-To ac1ehie-his,-status e-Thpla tMutb ruh oa tMD ihn6hu oMD 5 within the f,,-,l*i*, 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The-allowed eutage4imes-are-reasenable-ib.ase on operating ..

ex-per4enee,-to-reaeh4herequiiredlantGc-nditeons-frem-f uH-power-een ditieRssn-an--orderly manner-and-without-Ghallenging-lant-systems Aetion-d If-the-required-containment-atmosphere-particulate-radioaetivity--mnitor-and-the-required

. .ntainmentfan-.oo.eF o-nden'ate bw-swit.h-are-neperab...e-, the on-eans-ofdetecting RGSleakage-is-the--Gontainment-sumýpmenitor--This-oncditien-dees--not-provide4he-required diverse-means-of-R CSeakzge-deteetion--The-ACT-QN-is-to-restr-e-either-of-the-inoperable mronitors4o-OP-ERABL-E--status-wit hi-30-days-to-regain4he4ntended-4eakage eteotion diversity-The-30day-altowed-outagetime-ensures-he-plant is not-operated-n-a-reduced configuranR for a lengthy time period. Also 30 days is acseptabl e because COntingec-y actions re-required to be taken in Actien-a-or c.

F-or-exampleif4he-eontainmert-atmespherepadtieulate-radioactivity-menitor-and-the GFG-condensate-low .. itch arc declared inoperable, ACTION a, G,and d wilH.ave-to-be entered and cencyAtbins-performed per ACTION a and c. ACTION d requires-One me-n.itorete.-e-r-este .Feb-w-ithi-3 0-day*-e r-tc-e-eomme n ee-a--pl a nt-s hutdewn.-I-f-pr~ier-t4o h-30ays7 the-co.ntain ment-atmo sphere -partieulate.-radioa-tivity--menitor-4is-re.tsre -te.-C)PRERABL-E--statuus ACT4N-a-and-d-can-be-exited;--however-the-Actions-ef-ACTION-c-are-&ti-app Iicable If-ACT-ION-d-cannno-bbe-m et-wi-thin-t he-aelowed-outage-timerthe-plant-m ustbe-broeught-te a-MODE-in-which-4he-L-GO-does -- t-apply--To-achieve-this-statusr-the-plant-must-be-brought4o at-least-MO DE-3-with-6-hou rs-a nd-to-MOD E-5-within-the-ro llowing ho u rs--The-allowed outage4imesare-reasonable,-based-o peratingx-perienee-, to-reaah4he-required-plant eenditiors-f-emf4ul-power-e-nditlens4n-a--orderty-m4naner-and-withoLut-ehaýlenging-piant systemns Action-e lf4he-requi.red.-containment-sump-rmeniters4.neperabl.e-(both-the-eontain-rnent-sump levela f...low-wir i- strure.tation)

... and either the required containment atmosphere particulate-radioactivity-monito r--therFequired--containment-fan-c-ooler-endensate4lew-switch is4neper-ablet4hee-is-only-ene-meansf-defteting-RGS4eakage~n-4his-e-onditiorw4he Geotainmentsurmp-monitowbiGhs4he-best-nethod-for--deteeting-RGS4eakage s~inperable alenliw ne-cf-th ,,h-o thefleakage tkotheh-ondition-d1es-not-provide-the requireddiverse mea ns-ofRGS4eakage-deteetien-_-The-AGT4IGN4s-e-restore-either efthe inoperabte mntors to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to regain-he intended leakage-deteetion-d-iversity.-he-l---hour-allowed-outage-time-ensures-the-plant-is-not-operated-with*two RGS-teakage-deteetion-menitore-inoperable-for-a4engthy-time-period, If ACTION e cannot-be -met-within-the-allowed-outage time,--the-plant-must-be-brought-to a-MODE-in-which-the-L-GO-does.-net-apply--T-o-ac-hieve-4his-etatus --the-plant-must-be-brorught-toe at-Ieast-MQDE--3-within--6-hours-and-to-MODE-5-within-the-foleowing.-30-hour.s-The-aleowed ou-tag e4imes-are.-reasonable -based-on-operatinx-eperience*o4-reach-the-required-plant Gend-itions from full power-conditions n;an odr manner awo haleng-ng- plant systems;

-(DRN 04-1223, Ch; 33)

WATERFORD -UNIT 3 B 3/4 4-4c CHANGE NO. 33.

Attachment 4 to W3F1-2006-0052 Page 5 of 6 (DRN 04-1223, Ch. 33)

REACTOR COOLANT SYSTEM BASES (continued)

Because 0-the short duration of-the-allwedw-outage time, the centingeny-Aetions-of-a, b--or-G-do-not--have-to-be-eompIeted--while.4he-req uireme nts.-of-Action-e-a re-being-followed.-f one-efe-t Gn-iots-a-re4etred teoGQERABLE statAetuien-e-may-be-e4ted-and-the requirements of Actien a, b, or c, whichever is-applicable must be compkied-Witb.

Action fc If all required monitors are inoperable, no automatic means of monitoring leakage are available and immediate plant shutdown is required. ACTION must be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . These times are consistent with TS 3.0.3.

Surveillance Requirements SR 4.4.5.1.a, 4.4.5.1.b - Channel Check SR 4.4.5.1.a requires the performance of a CHANNEL CHECK of the required containment atmosphere particulate radioactivity monitor. SR 4.4.5.1 .b requires the performance of a CHANNEL CHECK on the required containment sump level monitor/time rate of chanqe. The CHANNEL CHECK is not required to be performed on the containment sump flow monitor (weir). The check gives reasonable confidence the channel is operating properly.

The frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

(DRN 05-1333, Ch. 44)

SR 4.4.5.1.a, SR--4-A54I.-- Channel Functional Test (DRN 05-1333. Ch. 44)

SR 4.4.5.1.a requires the performance of a CHANNEL FUNCTIONAL TEST of the required containment atmosphere particulate radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string. A successful test of the required contacts of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The frequency of 92 days considers instrument reliability, and operating experience has shown it proper for detecting degradation.

(ORN 05-4333 .Ch. 44)

SR47 &1.e-equk-es-thepe Fermance ofa CHANNEL FUNCTIONAL TEST of the oontakient-fan looler-c-on de nsate flow switches. The test-veFifies the-alarmffunetkR-Gf-the channel for the instrumentsoatediside contaiiment-by- ing-ess4han-er-equal to a !

gallon-per-minute-wateFflow-to-activate-theinstrumentThefrequenGy-of-48-menths-is-a-ypital refueling cyce-and-oensiders 4anneIlreliability.QpeF ting-expernen, has shwnthis frequency is-eeptale 7 .

SR 4.4.5.1.a, SR 4.4.5.1.b - Channel Calibration (DRN 05-1333, Ch. 44)

These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The frequency of 18 months is a typical refueling cycle and considers channel reliability. Operating experience has shown this frequency is acceptable.

(DRN 04-1223, Ch. 33)

WATERFORD -UNIT 3 B 3/4 4-4d CHANGE NO. 33,

Attachment 4 to W3F17-2006-0052 Page 6 of 6 01(DRN 04-1223, Ch. 33)

REACTOR COOLANT SYSTEM.

BASES (continued)

Monitoring Containment Sump In-Leakage Flow During automatic operation of the containment sump pumps (after a containment sump pump has operated), the flow calculation performed by the plant monitoring computer based on a level change will no longer be accurate since the level in the sump will be lowering. A 20 minute time period has been conservatively determined based on engineering calculations for this equipment operation. In addition, upon reboot of the plant monitoring computer, a period of 10 minutes is required for the leak rate calculation to become available. It has been determined these time periods (independent or combined) of calculation sump in-leakage flow inaccuracies, the instrumentation remains adequate to detect a leakage rate, or its equivalent, of one gpm in less than one hour; therefore, the containment sump level instrumentation and the corresponding flow calculation is considered to remain operable.

References

1. 10 CFR 50, Appendix A, Section IV, GDC 30.

2. Regulatory Guide 1.45, Revision 0, dated May 1973.

3. UFSAR, Sections 5.2.5 and 12.3.

(DRN 04-1223, Ch. 33) 3/4.4.5.2 OPERATIONAL LEAKAGE Industry experience has shown that while a limited amount of leakage is expected from RCS, the unidentified portion of this leakage can be reduced to a threshold value of less than 1 gpm. This threshold value is sufficiently low to ensure early detection of additional leakage.

The 10 gpm IDENTIFIED LEAKAGE limitation provides allowances for a limited amount of leakage from known sources whose presence will not interfere with the detection of UNIDENTIFIED LEAKAGE by the leakage detection systems.

The Surveillance Requirements for RCS pressure isolation valves provide added assurance of valve integrity thereby reducing the probability of gross valve failure and consequent intersystem LOCA. Leakage from the RCS pressure isolation valves is IDENTIFIED LEAKAGE and will be considered as a portion of the allowable limit.

(DRN 04-1243, Ch. 38)

The 75 gallon per day (gpd) per steam generator tube leakage limit ensures that the radiological consequences, including that from tube leakage, will be limited to the 10CFR50.67 limits for offsite dose and within the limits of General Design Criterion 19 for control room dose.

For those analyzed events that do not result in faulted steam generators, greater than or equal to 75 gpd primary-to-secondary leakage per steam generator is assumed in the analysis. For those analyzed events that result in a faulted steam generator (e.g., MSLB), 540 gpd primary-to -

secondary leakage is assumed through the faulted steam generator while greater than or equal to 75 gpd primary-to-secondary leakage is assumed through the intact steam generator.

DRN 04-1243, Ch. 38)

WATERFORD -UNIT 3 B 3/4 4-4e CHANGE NO. 33,38,

Attachment 5 W3F1-2006-0052 List of Regulatory Commitments to W3F1-2006-0052 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 ONE- CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)

The gaseous radioactivity monitor and the CFC condensate flow switches, although not included in x the TSs, will be maintained functional and available.

v t e Letter Sequence Request
TAC:MD0173, (Open)
Initiation Request, Request Acceptance... Administration Questions 2 June 2006 Answers Results Approval... Other:
MONTHYEAR2006-06-02 [Table View]

W3F1-2006-0052, License Amendment Request NPF-38-267, Reactor Coolant System Leakage Detection Instrumentation, Waterford Steam Electric Station, Unit 3

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SUBJECT:

Dear Sir or Madam:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

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6.0 REFERENCES

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W3F1-2006-0052, License Amendment Request NPF-38-267, Reactor Coolant System Leakage Detection Instrumentation, Waterford Steam Electric Station, Unit 3

Text

SUBJECT:

Dear Sir or Madam:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 REFERENCES

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