W3P87-0958, Application for Amend to License NPF-38,creating New Tech Spec Re Auxiliary Pressurizer Spray Sys.Proposed Change Does Not Involve Unreviewed Safety Question or Significant Hazards Consideration.Util Safety Analysis Encl.Fee Paid

Application for Amend to License NPF-38,creating New Tech Spec Re Auxiliary Pressurizer Spray Sys.Proposed Change Does Not Involve Unreviewed Safety Question or Significant Hazards Consideration.Util Safety Analysis Encl.Fee Paid

ML20205J514
Person / Time
Site:	Waterford
Issue date:	03/26/1987
From:	Dewease J LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20205J517	List: ML20205J538 W3P87-0958, Application for Amend to License NPF-38,creating New Tech Spec Re Auxiliary Pressurizer Spray Sys.Proposed Change Does Not Involve Unreviewed Safety Question or Significant Hazards Consideration.Util Safety Analysis Encl.Fee Paid
References
W3P87-0958, W3P87-958, NUDOCS 8704010331
Download: ML20205J514 (7)

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LOUISIANA 317 BARONNE STREET . P. O. BOX 60340 POWER & LlGHT/ NEW ORLEANS, LOUI5 LANA 70160 . (504) 595-2781 N $ s EESiE March 26, 1987 J. G. DEWE AS E

$1NCR VKE 9RE5lOENT-NUGEAR OPERA TON 1 W3P87-0958 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

SUBJECT:

Waterford SES Unit No. 3 Docket No. 50-382 Technical Specification Change Request NPF-38-60 Gentlemen:

Louisiana Power & Light hereby files an application for an amendment to the Waterford 3 Technical Specifications. The amendment would create a new Technical Specification for the auxiliary pressurizer spray (APS) system. With this submittal, we have fulfilled our previous commitment to propose a generic Technical Specification for the APS.

The proposed change does not involve an unreviewed safety question nor a signi-ficant hazards consideration. Should you require additional information, please contact Mike Meisner at (504) 595-2832.

Yours very truly,

/ ,J w n J.p. Dewease Sfnior Vice President-Nuclear Operations JG9/MJM/p1m

Enclosures:

NPF-38-60 Filing fee - LP&L check #03-5353 cc: E.L. Blake W.M. Stevenson, G.W. Knighton, J.II. Wilson, R.D. Martin, NRC Resident Inspector's Office (W3), Administrator Nuclear Energy Division (State of Louisiana), American Nuclear Insurers i

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

AFFIDAVIT I_

J.G. Dewease, being duly sworn, hereby deposes and says that he is Senior Vice President, Nuclear Operations of Louisiana Power & Light j Company; that he is duly authorized to sign and file with the Nuclear

Regulatory Commission the attached Technical Specification Change i' Request; that he is familiar with the content thereof; and that the matters set forth herein are true and correct to the best of his knowledge, information and belief.

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J k I I 4 mmh i .G. Dewease enior Vice President-Nuclear Operations i

STATE OF LOUISIANA) j

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r DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-60 osed chan The cationprop 3 /4.4.3, Reactor "ge would revise Coolant the numbering System scheme

- Pressurizer", used in Condition add Limiting Technical Specifi-for Operation 3.4.3.2, " Auxiliary Spray" and revise Bases section 3/4.4.3 to support the addition of this LCO.

Existing Specification See Attachment A.

Proposed Specification See Attachment B.

Description The proposed amendment would change LC0 3.4.3 to LC0 3.4.3.1, revise the number-ing of the associated surveillance re proposedchangeandaddLC03.4.3.2,guirementstobeconsistentwiththeAuxiliary Spray" ACTION statements and surveillance requirements. The proposed change will also revise Bases Section 3/4.4.3 to describe some of the technical reasons for adding this LCO. The reason fcr this change is to impose a new requirement to maintain at least one auxiliary pressurizer spray valve operable when the reactor is in Modes 1, 2 or 3.

The auxiliary pressurizer spray (APS) system is used to depressurize the reactor coolantsystem(RCS)byinjectingwater,viathechargingpumps,intothepres-surizer steam space. In order to initiate auxiliary spray flow the operator closes the charging loop isolation valves and opens the auxiliary spray valves.

This redirects the charging flow that would normally enter the RCS via loops 1A and/or 2A into the pressurizer steam space; and, by adjusting the number of charging pumps that are operating, the operator can control the rate of RCS depressurization. It should be noted that even if one of the charging loop isolation valves failed to close on demand, previous tests of the APS system have shown that a more than adequate depressurization rate can be maintained.

Safety Analysis The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:

1. Will operation of the facility in accordance with this proposed change significantly increase the probability or consequences of any accident previously evaluated?

Response: No.

NS41262

The proposed numbering changes to the current Technical Specification 3/4.4.3 are strictly administrative and will have no impact on any of the accident analyses presented in Chapters 6 and 15 of the FSAR. The addition of LC0 3.4.3.2 places an additional restriction on the Operating License and will ensure that the auxiliary spray system is available whenever the plant is in operational modes 1, 2 or 3. Since the proposed change results in either administrative changes or additional restrictions and has no impact on the accident analyses, it will not result in a significant increase in the probability or consequences of any accident previously evaluated.

2. Will operation of the facility in accordance with this proposed change create the possibility of a.new or different kind of accident from any accident previously evaluated?

Response: No.

The auxiliary spray system provides an alternate means of depressurizing the primary system when the main pressurt zer sprays are not available (e.g., during natural circulation conditions). The proposed change is simply defining the operability requirements for an existing plant system and adding these o)erability requirements to the Technical Specifications.

There will be no p1ysical change to plant systems, structures or components.

The only change to plant procedures will be to check the operability of the auxiliary spray system when performing routine surveillance testing.

Since the proposed change will not affect the ability of the auxiliary spray system to perform its design function and all other changes are strictly administrative, it will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Response: No.

The intent of the proposed change is to ensure that the plant operators have a means of depressurizing the primary system when the main pres-surizer sprays are not available. It imposes new restrictions on reactor operation (i.e., ACTION statements) that must be followed when or if the system is inoperable. Since the proposed changes are either admini-strative or impose restrictions that are not now part of the operating license, the overall impact of this change should be an increase in the margin of safety.

The Commission has provided guidance concerning the application of standards for determining whether a significant hazards consideration exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazards consideration. Example (i) relates to a purely adm aistrative change to technical specifications (i.e., a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature). Example (ii) relates to a change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications (i.e., a more stringent surveillance requirement).

NS41262

In.this case the proposed change to Technical Specification 3/4.4.3 is similar to Example (i) in that the change is strictly administrative to achieve con-sistency in the technical specification numbering. The proposed addition of LC0 3.4.3.2 is similar to Example (ii) in that it constitutes an additional restriction that is not currently included in the technical specifications.

Safety and Significant Hazards Determination Based upon the above Safety Analysis, it is concluded that (1) the proposed change does not constitute a significant hazards consideration as defined by-(2) there is reasonable assurance that the health and safety of 10 the CFR public50.92;ll wi not be endangered by the proposed change; and, (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

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NPF-38-60 ATTACHMENT A I

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