ML061280075

Amendment 92, Move Pressurizer Heat-up and Cooldown Limits to TRM and Remove Shutdown Requirements

ML061280075
Person / Time
Site:	Waterford
Issue date:	08/12/2004
From:	Scott G Entergy Nuclear South
To:	Office of Nuclear Reactor Regulation
References
Download: ML061280075 (19)

Text

EN-S NUCLEAR Qt1AUTY RELATED LI-101 Revision 3

_ ADMINISTRATIVE Entergy MANAGEMEN MANUAL INFORMATION USE ATTACHMENT 9 .1 50 .59 REVIEW FORM Page 1 of 16

1. OVERVIEW/ SIGNATURES Facility : Waterford 3 Steam Electric Station Document Reviewed : Technical Specification Bases, TRM and TRM Bases Change/Rev.: WA System Designator(s)/Description : NIA Dpscrlntiorn of Propog hangs The proposed changes are to :

1)Revise the Technical Specification Bases section "Pressure/Temperature Limits" to delete the reference to heatup and cooldown rates . Specifically the following paragraph "The limitation imposed on the pressurizer heatup and cooldown rates and spray water temperature differential are provided to assure that the pressurizer is operated within the design criteria assumed for the fatigue analysis performed in arcflrdnnnp with the ASME Code requirements ." will be revised to read "The limitation imposed on the pressurizer spray water temperature differential are provided to assure that the pressurizer is operated within the design criteria assumed for the fatigue analysis performed in accordance with the ASME Code requirements ."

2)Relocate the pressurizer maximum heatup and cooldown limits from the Technical Specification to the TRM . The maximum cooldown rate will be changed from a rate of 200°F per hour to a rate of 135°F per hour_ Two additional conditions . in addition to the maximum heatup and cooldown rate, will be added to the TRM LCO. They are 1) Pressure less than or equal to Psat + 100 PSIA during a PZR cooldown and

2) Pressurizer temperature greater than 90°F unless a one hour soak at 95°F +1- 5°F has occurred .

3) Lne ACTION STATEMENT and the SURVEILLANCE REQUIREMENTS associated with exceeding heatup and cooldown rates will be relocated from the TS to the TRM. The ACTION STATEMENT will be revised as stated below:

Current ACTION STATEMENT With the pressurizer temperature limits in excess of any of the above limits, restore the temperature to within the limits within 30 minutes; perfor ¬TI do engineering evaluation to determine the effects of the out of limit condition on the structural integrity of the pressurizer; determine that the pressurizer remains acceptable for continued operation or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the pressurizer presgLlre to less than 500 prig within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> .

Proposed ACTION STATEMENT change With the pressurizer limits in excess of any of the alluve limits, restore the affected parameter to within the limits within 30 minutes; perform an engineering evaluation to determine the effects of the out of limit condition on the structural integrity of the pressurizer and enter TRM LCO 3.0 .3 .

Current SURVEILLANCE REQUIREMENT The pressurizer temperatures shall be determined to be within the limits at least once per 30 minutes during system heatup or cooldown .

Proposed SURVEILLANCE REQUIREMENT change The pressurizer pressures and temperatures shall be determined to be within the limits at least once per 30 minutes during system heatup or cooldown .

4)TRM LCO 3.0 .3 will be revised by deleting the MODE requirements

EN-S NUCLEAR QUAUTY RELATED LI-101 Revision 3 MANAGEMENT ADmINISTRATIvrz MANUAL INFORMATION USE ATTACHMENT 9.1 50 .59 REVIEW FORM

5) TRM BASES will be revised to include a discussion of pressurizer pressure/temperature limits that was removed from the TS via Amendment 195 .

6) Revise TRM Index and Responsibility Matrix If the proposed activity, in its entirety, involves any one of the criteria below, check the appropriate box, provide a justificationtbasis in the Description above, and forward to a Reviewer. No further 50 .59 Review is required. If none of the criteria is applicable, continue with the 50.59 Review .

The proposed activity is editorialltypographical as defined in Section 5.2 .2.1 .

© The proposed activity represents an "FSAR-only" change as allowed in Se n 52 .2.2_

(insert item # from Section 5.2.2.2) .

If further 50.59 Review is required, check the applicable review(s) : (Only the sections indicated must be included in the Review .)

© SCREENING Sections 1, 11, 111, and IV required

© 50 .59 EVALUATION EXEMPTION Sections 1, 11, 111, IV, and V required 50.59 EVALUATION (#: Sections I, 11, 111, IV, and VI required r ~ ~r , ~- " .,-)

Preparer :

Name print)'/ Signature Company! De rtm t! Date Reviewer: *1 "\A Name (print) ! Signature ! Company! Department I Date Chairman's Signature ! Date

[Required only for Programmatic Exclusion Screenings (see Section 5.9) and 50.59 Evaluations.]

List of AssistingfContributing Personnel :

Name: Scope of Assistance:

EN-S NUCLEAR QUALITY RELATED LI-101 Revision 3

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== ' MANAGEMENT ADMINISTRATIVE MANUAL

- INFORMATION USE ATTACHMENT 9.1 - 50 .59 REVIEW FORM-.. . . .. . 16 11 . SCREENING A. Licensing BasisDocumentReview

1. Does the proposed activity impact the facility or a procedure as described in any of the following Licensing Basis Documents?

Operating License YES NO CHANGE # and/or SECTIONS TO BE REVISED Operating License i TS Cl NRC Orders Q If "YES", obtain NRC approval prior to implementing the change by initiating an LBO Change In accordance with NM IM LI-1 13 (Reference 2 .2.13). (See Section 5.1 .13 for exceptions .)

LBDs controlled under 50 .58 YES NO CHANGE N and/or SECTIONS TO BE REVISED C=SAR © FSAR Table 3 .9 .1, FSAR 5.4 .10 .1

~.

TS Bases Z © 83144 .8 Technical nequiromonts Manual © 3 14 .01 . 3 .4 .5.2, 8 3 1 4.4 8 Core Operating Limits Report NRC Safety Evaluation Reports If "YES", perform an Exemption Review per Section V OR perform a 50.59 Evaluation per Section VI AND initiate an LBD change in accordance with NMM LI-113 (Reference 2.2.13).

LBDs controlled under other regulations YES NO CHANGE # and/or SECTIONS TO BE REVISED Quality Assurance Program Manual2 [l 0 Emergency Plant d

© . ..

Fire Protection Program a (includes the fire Hazards Analysis)

Offsite Dose Calculation Manual3 El 0 If "YES", evaluate any changes in accordance with the appropriate regulation AND initiate an LBD change In accordance with NM M LI-113 (Reference 2 .2 .13) .

2. Does the proposed activity involve a test or experiment not described in the D Yes FSAR? No If "yes, perform an Exemption Review per Section V OR perform a 50 .59 Evaluation per Section VI .

3. Does the proposed activity potentially impact equipment, procedures, or facilities © Yes utilized for storing spent fuel at an Independent Spent Fuel Storage Installation? No (Check "N/A" if dry fuel storage is not applicable to the facility.) NIA If "yes, perform a 72 .48 Review in accordance with NMM Procedure LI"112.

(See Sections 1 .5 and 5 .3 .1 .5 of the EOI 10CFR5t3 .59 Review Program Guidelines .)

' if "YES," see Section 5 .1 .4 . No LBD change is required .

2 If -YES,' notify the reaponsibla department and ensure a 50.54 Evaluation is pr:rfnrmed . Attach the 50 .54 Evaluation .

3 If "YES," evaluate the change in accordance wish the requirements of the facility's Operating License Condition .

_ EN-S NUCLEAR QUALITY RELATED LI-101 Revision 3 ADMINISTRATIVE nteW MANAGEMENT MANUAL INFORMATiON USE ATTACHMENT 9 .1 50 .59 REVIEW FORM Page 4 of 16 B. Basis Provide a clear, concise basis for the answers given in the applicable sections above. Explain why the proposed activity does or does not impact the Operating License/Technical Specifications and/or the FSAR and why the proposed activity does or does not involve a new test or experiment not previously described in the FSAR . Adequate basis must be pruvidGd within the Screening such that a third-party reviewor can reach the same conclusions . Simply stating that the change does not affect TS or the FSAR is not an acceptable basis. See EOI 50 .59 Guidelines Section 5.6 .6 for guidance .)

See Attached pages, 4a, 4b, and 4C C. References Discuss the methodology for performing the LBD search . State the location of relevant licensing document information and explain the scope of the review such as electronic search criteria used (e .g ., key words) or the general extent of manual searches per Section 5.3 .6 .4 of LI-101 . NOTE. Ensure that electronic and manual searches are performed using controlled copies of documents. If you have any questions, contact your site Licensing department.

LBDsIDocuments reviewed via keyword search : Keywords :

FSAR, Autonomy, LRS(LBDS50 .59) pressurizer heatup, pressurizer cooldown, pressurizer shutdown LBDs/Documents reviewed manually :

Technical Specification, Technical Requirements Manual, OP-010-005, OP-010-014, OP-901-202, OP-901-602, FR-W3-2001-1211 13 . Is the validity of this Review dependent on any other © Yes change? (See Section 5.3 .4 of the EOI 10CFR50.59 Program © o Review Guidelines)

If "Yes," list the required changes.

ATTACHMENT 9.1 50.59 REVIEW FORM Page 4a Change 1 Revise the Technical Specification Basis section "Pressure/Temperature Limits" to delete the reference to heatup and cootdown rates. Specifically the following paragraph "The limitation imposed on the pressurizer heatup and cootdown rates and spray water temperature differential are provided to assure that the pressurizer is operated within the design criteria assumed for the fatigue analysis performed in accordance with the ASMF Code requirements ." will be revised to read "I he limitation imposed on the pressurizer spray water temperaturc differential are provided to assure that the pressurizer is operated within the design criteria assumed for the fatigue analysis performed in accordance with the ASMF Code requirements ."

Basis Change 1 The NRC approved in TS Amendment 195 Waterford 3's request to remove the pressurizer heatup and cootdown limits from the Technical Specifications and placed them in the TRAM Based on the removal of these limits from the TS, the reference to them in the TS BASES are not required .

Change 2 2)Relocate the pressurizer maximum haatiip 2nd cootdown limits from the Technical Specification to the TRIM . The maximum cootdown rate will be changed from a rate of 200°F per hour to a rate of 135°F per hour . Two additional conditions, in addition to the maximum heatup and cootdown rate, will be added to the TRM LCO. They are 1) Pressure _< Psat + 100 PSIA during a Pressurizer cootdown and 2) Pressurizer temperature - 90°F unless a one hour soak at 95°F +!- S°F has occurred .

Basis Change 2 The NRC approved in TS Amendment 195 Waterford 3's request to remove the pressurizer heatup and cootdown limits from the Technical Specifications and placed them in the TRM.

The maximum Pressurizer cootdown rate of 200°F per hour is currently contained in FSAR Table 3.9-1 and FSAR Section 5 .4 .10.1 .

ER-W3-2001-121 1 provides the basis for the change to the cootdown rate . The ER, written to address the nozzle repair on the pressurizer during RF 10, makes the following statement:

As a result of the re-analysis of the Pressurizer bottom head fracture mechanics for this ER and CR W3-20033-02863, it is necessary to limit the Pressurizer cootdown rate to 135'F per Iluur in order for the analysis to meet ASME Code . Technical Specification 3.4 .8 .2 limits the Pressurizer to a maximum cootdown rate of 200°F per hour, and it is recognized that the 135 F per ltuur cootdown rate imposed by this ER and CR W3-2003-02863 is mare restrictive and therefore T .S . 3.4 .8 .2 is non-conservative for this condition. Corrective actions for CR W3-2003-2863 will ultimately result in changes to the FSAR and T,S . 3.4 .8 .2, however in the interim, the following Operations Procedures will be changed as return to service, compensatory actions to incorporate the new 135F per hour Pressurizer cootdown rate :

a OP-01 ¬1-0035, Plant Shutdown OP-9(71-2032, Steam Generator Tube Leakage or t ligh Activity

" OP-901-502, Evacuation of Control Room and Subsequent Plant Shutdown

ATTACHMENT 9 .1 50.59 REVIEW FORM Page 4b Pressurizer cooldown rates shall not exceed 135 F per hour, between 653F and 90 F. Upon reaching 90'F, the temperature shall be maintained at 95F (95*17 _+ 5'F) for at least one hour, before any subsequent cooling not to exceed 135 Flhr commences. At all times during the cooldown, pressure in the Pressurizer shall not exceed saturation pressure (P:.) + 100 psia . The P,,,t + 100 psia restriction would obviously only be a concern when the Pressurizer is solid, since otherwise Pressurizer pressure is maintained at P ','t due to the bubble in the Pressurizer.

Canoe-3 The ACTION STATEMENT and the SURVEILLANCE REQUIREMENTS associated with exceeding heatup and cooldown rates will be relocated from the TS to the TRM. The ACTION STATEMENT will be revised as stated below :

Current ACTION STATEMENT With the pressurizer temperature limits in excess of any of the above limits, restore the temperature to within 30 minutes ; perform an engineering evaluation to determine the effects of the out of limit condition un the structural integrity of the pressurizer; determine that the pressurizer remains acceptable far continued operation or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the pressurizer pressure to less than 500 psig within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Proposed ACTION STATEMENT change With the pressurizer limits in excess of any of the above limits, restore the affected parameter to within the limits within 30 minutes; perform an engineering evaluation to determine the effects of the out of limit condition on the structural integrity of the pressurizer and enter TRM 1 cn 1.1 .0 .1 .

Current SURVEILLANCE REQUIREMENT The pressurizer temperatures shall be determined to be within the limits at least once per 30 minutes during system heatup or cooldown .

Proposed SURVEILLANCE REQUIREMENT The pressurizer pressures and temperatures shall be determined to be within it -ie limits at least once per 30 minutes during system heatup or cooldown .

BasisChange 3 The NRC approved in TS Amendment 195 Waterford 3"s request to remove the pressurizer heatup and cooldown limits along with the ACTION STATEMENT and applicable SURVEILLANCE REQUIREMENTS from the Technical Specifications and placed them in the

ATTACHMENT 9.1 50 .59 REVIEW FORM Page 4c The TRM is a Licensee Controlled Document and it not required to include the shutdown statements as the Technical Specifications . Maintaining shutdown statements in the TRM can cause unnecessary plant shutdowns and a plant shutdown will cause a transient to the plant. The revised ACTION STATEMENT allows the plant to evaluate the extent of the impact to exceeding pressurizer heatup and cooldown rates and take appropriate actions.

Change 4 TRM LCO 3.0 .3 will be revised by deleting the MODE requirements from TRM LCO 3 .0 .3 .

Basischange 4 This is a more conservative change that requires the TRM LCO 3.0 .3 to be applicable at all times.

Ghan_qe 5 TRM BASIS will be revised to include a discussion of pressurizer pressure/temperature limits that was remnvp(i from the TS via Amendment 195.

Basis change 5 This is an administrative change that captures the text of the basis that was remuvud rrum the TS in Amendment 195 .

Chan e. . 6 Revise the TRM Index and Responsibility Matrix Rnsis change 6 These are administrative changes in that they are made to be consistent with changes to the TS and TRM Specifications .

4ftEn tew EN-S NUCLEAR MANAGEMENT QUALITY RELATED ADMINISTRATIVE 1-I-101 Revision 3 MANUAL INFORMATION USE ATTACHMENT 9.1 50 .59 REVIEW FORM - Page. .... . .

Ill . ENVIRONMENTAL SCREENING If any of the following questions is answered "yes," an Environmental Review must be performed in accordance with NMM Procedure EV-115, "Environmental Evaluations," and attached to this 50.59 Review . Consider both routine and non-routine (emergency) discharges when answering these questions .

Will the proposed Change being evaluated :

Yes No

© El Involve a land disturbance of previously disturbed land areas in excess of one acre (i .e .,

grading activities, construction of buildings, excavations, reforestation, creation or removal of ponds)?

2. © Involve a land disturbance of undisturbed land areas (i .e ., grading activities, construction, excavations, reforestation, creating, or removing ponds)?

3. CI Involve dredging activities in a lake, river, pond, or stream?

4. Increase the amount of thermal heat being discharged to the river or lake?

5. © Increase the concentration or quantity of chemicals being discharged to the river, lake, or air?

0, Cf Discharge any chemicals new or different from that previously discharged?

7. d Z Change the design or operation of the intake or discharge structures?

8. 0 Modify the design or operation of the cooling tower that will change water or air flow characteristics?

9. Q ED Modify the design or operation of the plant that will change the path of an existing water discharge or that will result in a new water discharge?

10 . Cl 0 Modify existing stationary fuel burning equipment (i .e ., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

11 . Cl 22 Involve the installation of stationary fuel burning equipment or use of portable fuel burning equipment (i .e,, diesel fuel oil, butane, gasoline, propane, and kerosene)?'

12 . © 0 Involve the installation or use of equipment that will result in an air emission discharge?

13, Involve the installation or modification of a stationary or mobile tank?

14 . C Involve the use or storage of oils or chemicals that could be directly released into the environment?

15, © Involve burial or placement of any solid wastes in the site area that may affect runoff, surface water, or groundwater?

' See NMM Procedure EV-11T, "Air Emissions Management Program," for guidance in answering this question,

EN-S NUCLEAR QUAUTYRELRTED LI-1(31 Revision 3

. =MEN MANAGEMENT AOAAINI5TRATIVE MANUAL INFORMATION USE ATTACHMENT 9.1 50.59 REVIEW FORM  :: Page 6 of 16 IV. SECURITY PLAN SCREENING If any of the following questions is answered "yes,  a Security Plan review must be performed by the Security Department to determine actual impact to the Plan and the need for a change to the Plan.

A. Could the proposed activity being evaluated:

Yes No

1. O (~ Add, delete, modify, or otherwise affect Security department responsibilities (e .g., including fire brigade, fire watch, and confined space rescue operations)?

2. © Result in a breach to any security barrier(s) (e .g., HVAC ductwork, fences, doors, walls, ceilings, floors, penetrations, and ballistic barriers)?

3. © 0 Cause materials or equipment to be placed or installed within the Security Isolation Zone?

4. Affect security lighting by adding or deleting lights, structures, buildings, or temporary facilities?

5. O l Modify or otherwise affect ttw intrusion detection systems (e .g ., E-fields, microwave, fiber optics)?

6. 3 0 Modify or otherwise affect the operation or field of view of the security cameras?

7. © Modify or otherwise affect (block, move, or alter) installed access control equipment, intrusion detection equipment, or other security equipment?

& © Modify or otherwise affect primary or secondary power supplies to access control equipment, intrusion detection equipment, other security equipment, or to the Central Alarm Station or the Secondary Alarm Station?

9. © 0 Modify or otherwise affect the facility's security-related signage or land vehicle barriers, including access roadways?

lo, © Modify or otherwise affect the facility's telephone or security radio systems?

The Security Department answers the following questions if one of the questions was answered "yes".

B. Is the Security Plan actually impacted by the © Yes proposed activity? © No Is a change to the Security Plan required? © Yes Change 9 (optional)

Name of Security Plan reviewer (print) f Signature 1 Date

EN-S NUCLEAR QUALITY RELATED LI>>101 Revision 3

'" ew MANAGEMENT ADMINISTRATIVE MANUAL INFORMATION Lt5E ATTACHMENT 9.1 50.59 REVIEW PORN! Page 7 of 16 V. 50 .59 EVALUATION EXEMPTION Enter this section only if a "yes" box was checked in Section ILA, above, A. Check the applicable boxes below . If any of the boxes are checked, a 50.59 Evaluation is not required . If none of the boxes are checked, perform a 50.59 Evaluation in accordance with Section V. Provide supporting documentation or references as appropriate.

© The proposed activity meets all of the following criteria regarding design function per Section 5.6 .1 .1 .

The proposed activity does not adversely affect the design function of an SSC as described in the FEAR ; AND The proposed activity does not adversely affect a method of performing or controlling <

design function of an SSC as described in the FEAR; AND The proposed activity does not adversely affect a method of evaluation that demonstrates intended functions of an SSC described in the FSAR will be accomplished .

© An approved, valid 50 .59 Review(s) covering associated aspects of the proposed change already exists per Section 5.6.1 .2 . Reference 50 .59 Evaluation # - (if applicable) or attach documentation. Verify the previous 511.59 Review remains valid .

C1 The NRC has approved the proposed activity or portions thereof per Section 5.6 .1 .3 .

Reference:

© The proposed activity is controlled by another regulation per Section 5.6 .1 .4 .

B. Basis Provide a clear, concise basis for determining the proposed activity may be exempted such that a third-party reviewer can reach the same conclusions . See Section 5.6 .6 of the i=C3i 10CFR5©.59 Review Program Guidelines for quidance .

Not Applicable . A50.59 Evaluation was performed. See Section Vl.

QUALITY RELATED Revision 3 Oft EN-S NUCLEAR LI-101 MANAGEMENT ADMINISTRATIVE Entffgy MANUAL INFORMATION USE . . . ..

ATTACHMENT 9 .1 50 .59 REVIEW FORM Page 8 of 16 VI . 50.59 EVALUATION A. Executive Summary (Serves as input to NRC summary report . Limit to one page or less. Send an electronic copy to the site licensing department after CJSRC approval, if available.)

Brief description of change, test, or experiment ;

The proposed change adds a new specification to the TRM (TRM 3.4 .8 .2) for the pressurizer heatup and cooldown rates; reduces the pressurizer cooldown rate from 200°F to 135°F; revises TRM LCO 3.0.3 by deleting the MODE requirements and adds two LCOs (PZR pressure less than or equal to Psat +100 PSIA during a PZR cooldown and PZR temperature is greater than 90°F unless a one hour soak at t36°F +l- 6 A F has occur) . The change also deletes the requirement in the new TRM specification to determine that the pressurizer remains acceptable for continued operation or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the pressurizer pressure to less than 5110 psig within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and replaces it with a requirement to enter TRM LCO 3.0 .3 .

This change will also add a Bases section for TRM 314.4 .8 and delete reference to the heatup and cooldown rates in TS Bases Section 314.8 .4 .

Reason for proposed Change :

The proposed change, to add a new specification to the TRM (TRM 3.4 .8 .2) for the pressurizer heatup and cooldown rates is consistent with TS Amendment 195 (letter from N. Kalyanam to Joseph E. Venable dated June 16, 2¬)04), which allowed relocating these requirement from TS 3.4 .8 .2 to the TRM. The change to reduce the pressurizer cooldown rate from 200°F to 135°F and add the two LCOs indicated above is more restrictive and was a result of a reanalysis of the pressurizer hottom head for repairs to the heater sleeves as documented in W3 ER 2001-1211 .

It is justified to not include in the TRM the specific shutdown requirement previously in the TS because tire TRIM a5auuidlud with Lite 33C> have been bl-iown to not meet the criteria of 10 CFR 50 .36 and are subsequently not required to satisfy the safety analysis .

The proposed change that deletes the MODE requirements from TRM LCO 3.0 .3 is a more restrictive change . This is consistent with the addition of TRM Specification 3.4 .8 .2 because it is applicable at all times. Changes to the TS and TRM Bases, and the TRM Index and Responsibility Matrix are administrative in that they are made to be consistent with changes to the TS and TRM Specifications.

50 .59 Evaluation summary and conclusions The proposed changes do not:

(1) Result in more than a minimal increase in the frequency of occurrence of an accident previnamlyevAltated in the FSAR_

(2) Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component important to safety previously evaluated in the FSAR.

(3) Result in more than a minimal increase in the consequences of an accident previously evaluated in the FSAR .

(4) Result in more than a minimal increase in the consequences of a malfunction of a structure, system, or component important to safety previously evaluated in the FSAR.

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1NFaRh4ATlON 115E ATTACHMENT 9.1 50 .59 REVIEW FORM Page 9 of 16 (5) Create a possibility for an accident of a different type than any previously evaluated in the FSAR.

(6) Create a possibility for a malfunction of a structure, system, or component important to safety with a different result than any previously evaluated in the FSAR .

(7) Result in a design basis limit for a fission product barrier as described in the FSAR being exceeded or altered.

(8) Result in a departure from a method of evaluation described in the FSAR used in establishing the design bases or in the safety analyses .

These conclusions are based on the fact that changes associated with the removal of pressurizer heat and cooldown limits have been evaluated and approved by the NRC in TS Amendment 195.

The change to the cooldown rate from 200°F to 135°F per hour, the addition of the two LCOs are conservative changes that have been previously evaluated and approved in ER-W3-2001-1211 . In addition, the change being made to the TRM ACTION STATEMENT allows the plant to Pvalunte operability of the pressurizer following an event when the cooldown or heatup limits have been exceeded and then determine if the plant should continue operation or shutdown . The proposed change to eliminate the shutdown statement is justified. The proposed change will require an evaluation to determine any restriction to continued operation which could include a shutdown . It is justified to eliminate the specific shutdown requirement because the TRM associated with the SSCs have been shown to not meet the criteria of 10 CFR 50 .36 and are subsequently not required to satisfy the safety analysis .

EN-S NUCLEAR QUALITY RELATED LI-101 Revision 3 ADMINISTRATIVE EnteW MANAGEMENT MANUAL INFORMATION USE ATTACHMENT 9.1 50.59 REVIEW FORM Page 10 of 16 B. License Amendment Determination Does the proposed Change being evaluated represent a change to a method of © Yes evaluation ONLY? if "Yes, Questions 1 - 7 are not applicable ; answer only No Question 8. If "No," answer all questions below.

Goes the proposed Change;

1. Result in more than a minimal increase in the frequency of occurrence of an accident CI Yes previously evaluated in the FSAR? No BASIS:

The proposed change adds a new specification to the TRM (TRM 3.4 .8 .2) for the pressurizer heatup and cooldown rates; reduces the pressurizer cooldown rate from 20WF to 135'F; revises TRM LCO 3.0 .3 by deleting the MODE requirements and adds two LCOs (PZR pressure less than or equal to Psat x-100 PSIA during a PZR cooldown and PZR temperature is greater than 90°F unless a one hour soak at 95°F *1- 5°F has occur) . The change also deletes the requirement in the new TRM specification to determine that the pressurizer remains acceptable for continued operation or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the pressurizer pressure to less than 500 psig within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and replaces it with a requirement to enter TRM LCO 3.(1.3 . This change will also add a Bases section for TRM 314.4 .8 and delete reference to the heatup and cooldown rates in TS Bases Section 314.8 .4 .

The proposed changes will not result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the FSAR .

None of the above changes affects the frequency of an accident or the capability to mitigate any Accident described in the FSAR. The addition of a new specification to the TRM was the result of a relocation from the TS per TS Amendment 195. In the NRC SER for amendment 195, it was Uauumerited that the pressurizer temperature limits are defined or, process variables which are consistent with boundaries assumed in the structural analysis of the pressurizer and not as an initial conditions for design basis accident or transient analysis The reduction of the cooldown rate is a result of reanalysis due to repairs performed on the pressurizer heater sleeves, as documented in FR 2001-1211 . The limitations imposed on the pressurizer heatup and cooldown rates are provided to assure that the pressurizer is operated within the design criteria assumed for the flaw evaluation and fatigue analysis performed in accordance with the ASME Code Section XI, subsection iWB-3600 requirements . The Waterford 3 FSAR has analyzed the conditions that would result from a thermal or pressurization transient on the Waterford 3 pressurizer . The proposed deletion of the pressurizer heatup and cooldown rates and relocation of the limits to the TRM does not change the way that the pressurizer is designed or operated . Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated .The deletion of a shutdown statement is justified because the TRM associated with the SSCs have been shown to not meet the criteria of 10 CFR 50 .36 and are subsequently not required to ensure auuidertt prevention or mitigation . The change to the applicability of LCO 3.13.3 to at all times ensures that all TRM specifications that are applicable at all times are properly dispositioned if the Actions cannot be completed.

2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction © Yes of a structure, system, or component important to safety previously evaluated in the No FSAR?

LA EN-S NUCLEAR QUALITY~ RE~nTED Li-101 [Revision 3 UALI RE YE E W MANAGEMEN

_- MANUAL INFORMATION USE ATTACHMENT 9.1 5© .59 REVIEW FORM ~

©m 16 BASIS:

The proposed change adds a new specification to the TRM (TRM 3.4 .8 .2) for the pressurizer heatup and cooldown rates; reduces the pressurizer cooldown rate from 200°F to 135°F; revises TRM LCO 3.0 .3 by deleting the MODE requirements and adds two LCOs (PZR pressure less than or equal to Psat +100 PSIA during a PZR cooldown and PZR temperature is greater than 90°F unless a one hour soak at 95°F +1- 5°F has occur). The chdrige also deletes the requirement in the new TRM specification to determine that the pressurizer remains acceptable for continued operation or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the pressurizer pressure to less than 500 psig within the fnlinwing 30 hniirs, and replaces it with a requirement to enter TRM LCO 3.0 .3 .. This change will also add a Bases section for TRM 314.4 .8 and delete reference to the heatup and cooldown rates in TS Bases Section 3/4.8 .4 .

None of the proposed changes will result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component important to safety previously evaluated in the FSAR .

The removal of the shutdown statements from the proposed new TRM specification (pressurizer heatup and cooldown limits) do not result in an increase in the likelihood of an SSC malfunction .

The proposed Action to enter TRM 3 .0 .3 upon exceeding the pressurizer parameters ensures that appropriate steps are taken to maintain SSC as previously documented in the TS .

The other changes are editorial and more restrictive and cannot affect the likelihood of occurrence of a malfunction to a SCC . These changes add additional restrictions (more restrictive) or by definition (administrative) cannot affect the likelihood of occurrence of a malfunction to a SCC.

3_ Result in more than a minimal increase in the consequences of an accident previously © Yes evaluated in the FSAR? No

EN-S NUCLEAR QUAUTY RELATED LI-101 Revision 3

SEE MANAGEMENT A NisTRATivt

12t °'Y MANUAL tNFORMAPOH USE ATTACHMENT 9.'I 50 .59 REVIEW FORM . .

BASIS :

The proposed change adds a new specification to the TRM (TRM 3.4 .8 .2) for the pressurizer heatup and cooldown rates; reduces the pressurizer cooldown rate from 200°F to 135 °F ; revises TRM LCO 3.0 .3 by deleting the MODE requirements and adds two COs (PZR pressure less than or equal to Psat +100 PSIA during a PZR cooldown and PZR temperature is greater than 90°F unless a one hour soak at 95°F +/_ 5°F has occur) . The change also deletes the requirement in the new TRM specification to determine that the pressurizer remains acceptable for continued operation or be in at least HOT STANDBY within the next fi hours and reduce the pressurizer pressure to less than 506 psiq within the following 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />s: and replaces it with a requirement to enter TRM LCO 3.0 .3 . This change will also add a Bases section for TRM 314.4 .8 and delete reference to the heatup and cooldown rates in TS Bases Section 314.8 .4 .

None of the proposed change will result in more than a minimal increase in the consequences of an accident previously evaluated in the FSAR . The probability of an accident is unchanged as a result of the proposed change to delete the Waterford 3 pressurizer heatup and cooldown rates and associated action, surveillance requirement, and bases from the TS . The cooldown and heatup rates are not initiators to any accidents or pressurizer transients discussed in the Waterford 3 Final Safety Analysis Report (FSAR) . Therefore, the probability of an accident is not changed.

The purpose of the pressurizer heatup and cooldown limits is to ensure that given transient events will not negatively affect the pressurizer structural integrity beyond Code aliowables . These limits will be maintained within ASME Code allowables in the TRM in accordance with 10 CFR 50 .59.

Therefore, the consequences of an accident are not increased .

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

The deletion of the shutdown requirement from the Pressurizer Heatup and Cooldown Specification provides overall guidance to the TRM user regarding the Individual technical iequiretiieiits contained therein . These new requirements differ from the TSs, however, in that shutdown statements do not exist. A shutdown action statement does not determine the capability for meeting a safety function or change any associated pprformance characteristics. The addition of these sections and the removal of shutdown statements will require certain plant configurations to be evaluated against continued plant operation.

The other changes are more restrictive and editorial and cannot affect the consequences of an accident previously evaluated.

4. Result in more than a minimal increase in the consequences of a malfunction of a Cl Yes structure, system, or component important to safety previously evaluated in the No FSAR?

40 EN-S NUCLEAR MANAGEMENT QUALITY RELATED ADMINISTRATIVE LI-101 Revision 3 MEN MANUAL INFORMATION U75t ATTACHMENT 9.1 50 .59 REVIEW FORM BASIS.

The proposed change adds a new specification to the TRM (TRM 3.4 .8_2) for the pressurizer heatup and cooldown rates ; reduces the pressurizer cooldown rate from 2¬30°F to 135°F; revises TRM LCO 3.0 .3 by deleting the MODE requirements and adds two LCOs (PZR pressure less than or equal to Psat +100 PSIA during a PZR cooldown and PZR temperature is greater than 90°F unless a one hour soak at 95°F +f- 5°F has occur)_ The chsngQ also deletes the requirement in the new TRM specification to determine that the pressurizer remains acceptable for continued operation or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the pressurizer pressure to less than 504 psig within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and replaces it with a requirement to enter TRM L.CO 3.0 .3 . This change will also add a Bases section for TRM 314 .4 .8 ai id delete reference to the heatup and cooldown rates in TS Bases Section 314.8 .4 .

None of the proposed changes will result in more than a rninimal increase in the consequences of a malfunction of a structure, system, or component important to safety previously evaluated in the FSAR . The probability of an accident is unchanged as a result of the proposed change to delete the Waterford 3 pressurizer heatup and cooldown rates and associated action, surveillance requirement, and bases from the TS. The cooldown and heatup rates are not initiators to any accidents or pressurizer transients discussed in the Waterford 3 Final Safety Analysis Report (FSAR) . Therefore, the probability of an accident is not changed.

The purpose of the pressurizer heatup and cooldown limits is to ensure that given transient events will not negatively affect the pressurizer structural integrity beyond Code allowables . These limits will be maintained within ASME Code allowabies in the TIM in accordance with 10 CFR 50 .59.

Therefore, the consequences of an accident are not increased.

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

The prupused change to delete the shutdown requirements from the pressurizer Heatup and Cooldown Limit Specification affect the requirements when the Actions cannot be completed within the allowed outage time or when there is no Action for the condition by eliminating a required shutdown . No change to the design or function of any SSC is proposed . Therefore, no possibility of any new malfunction of an SSC described in the SAK is created. Subsequently, tt- ie dose consequences of any malfunction or accident previously evaluated in the SAR is not altered by the proposed changes.

The other changes are more restrictive and editorial and cannot affect the consequences of a malfunction of a SSC important to safety previously evaluated. These editorial changes are being made to provide consistency to the TRM has¢d on the addition of a new TRM and the deletion of TS requirements .

5. Create a possibility for an accident of a different type than any previously evaluated in Yes the FSAR?

No

EN-S NUCLEAR auAuTy RELATEo LI-101 Revision AoMINIS~r

=OEM MANAGEMENT

. ' l? MANUAL INFORMATION use ATTACHMENT 9 . 50.59 REVIEW FORM BASIS:

The proposed change adds a new specification to the TRM (TRM 3.4 .8 .2) for the pressurizer heatup and cooldown rates; reduces the pressurizer cooldown rate from 200*F to 135°F; revises TRM LCO 3.0 .3 by deleting the MODE requirements and adds two LCOs (PZR pressure less than or equal to Psat +100 PSIA during a PZR cooldown and PZR temperature is greater than 90°F unless a one hour soak at 95°F +/- 5°F has occur) . The change also deletes the requirement in the new TRM specification to determine that the pressurizer remains acceptable for continued operation or be i at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the pressurizer pressure to less than 500 psig within the following 3¬B hours ; and replaces it with a requirement to enter TRM LCO 3.0 .3 . This change will also add a Bases section for TRM 314.4 .8 and delete reference to the heatup and cooldown rates in TS Bases Section 3/4.8 .4 .

None of the proposed changes will create a possibility for an accident of a different type than any previously evaluated in the FSAR . The limitations imposed on the pressurizer heatup and cooldvwn rates are provided to assure that the pressurizer is operated within the design criteria assumed for the flaw evaluation and fatigue analysis performed in accordance with the ASME Code Section XI, subsection IWB-3600 requirements . The Waterford 3 FSAR has analyzed the conditions that would result from a thermal or pressurization transient on the Waterford 3 pressurizer . The proposed deletion of the pressurizer heatup and cooldown rates and relocation of the limits to the TRM does not change the way that the pressurizer is designed or operated .

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

The proposed changes do not create any physical change to the plant or plant SSCs . The proposed changes act to delete shutdown requirements (modify the Actions to be taken) when an LCO cannot be met.

The other changes are more restrictive and editorial and cannot affect create the possibility for an accident of a different type than any previously evaluated. Tne editorial changes are beir iy made to provide consistency to the TRM and TS .

6. Create a possibility for a malfunction of a structure, system, or component important to © Yes safety with a different result than any previously evaluated in the FSAR? 19 No

~ EN-S NUCLEAR QUALITY R r..n~o L1-'it27 Revision 3 MANAGEMENT ADMINISTRATIVE OEM MANUAL INFORMATION USE ATTACHMENT 9.'t 50 .59 REVIEW FORM BASIS The proposed change adds a new specification to the TRM (TRM 3.4 .8 .2) for the pressurizer heatup and cooldown rates; reduces the pressurizer cooldown rate from 200°F to 135°F; revises TRM LCO 3.0 .3 by deleting the MODE requirements and adds two LCOs (PZR pressure less than or equal to Psat +1017 PSIA during a PZR cooldown and PZR temperature is greater than 90°F unless a one hour suak at 9517 +1- 5°f has occur). The change also deletes the requirement in the new TRM specification to determine that the pressurizer remains acceptable for continued operation or be in at least FOOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the pressurizer precsi ire to less than 500 psicl within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and replaces it with a requirement to enter TRM LCO 3 .0 .3 . This change will also add a Bases section for TRM 314.4 .8 and delete reference to the heatup and cooldown rates in TS Bases Section 3/4.8 .4 .

None of the proposed changes create a possibility for a malfunction of a structure, system, or component important to safety with a different result than aiy previously evaluated in the FSAR .

The limitations imposed on the pressurizer heatup and cooldown rates are provided to assure that the pressurizer is operated within the design criteria assumed for the flaw evaluation and fatigue analysis performed in accordance with the ASME Code Section XI, subsection IWB-3600 requirements . The Waterford 3 FSAR has analyzed the conditions that would result from a thermal or pressurization transient on the Waterford 3 pressurizer . The proposed detetion of the pressurizer heatup and cooldown rates and relocation of the limits to the TRM does not change the way that the pressurizer is designed or operated .

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

The proposed non-administrative changes only affect the applicability of when specified equipment is required and in some cases, modify the actions to be taken when certain conditions are not met.

No change to the design, operation, or function of any SSC is proposed . Therefore, no possibility of any new malfunction of an SSC described in the SAR is created and, subsequently, the evaluated results of any such malfunction described in the SAR are not affected .

The other changes are administrative and cannot by the definition of an administrative change affect create the possibility for a malfunction of a SSC important to safety with a different result than any previously evaluated . These changes are being made to provide consistency to the TRM and the TS Bases.

7. Result in a design basis limit for a fission product barrier as described in the FSAR © Yes being exceeded or altered? No 0

EN-S NUCLEAR 4unuTr RELATED LI-101 Revision 3 MANAGEMENT' ADMINISTRATIVE AT~vE

-~ i l~ RATIV """"""~."

MANUAL INFORMATION USE ATTACHMENT 9.1 50 .59 REVIEW FORM page 16 of 16 BASIS :

The proposed change adds a new specification to the TRM (TRM 3 .4.82) for the pressurizer heatup and cooldown rates ; reduces the pressurizer cooldown rate from 20t3°F to 135°F; revises TRM LCO 3 .0 .3 by deleting the MODE requirements and adds two LCOs (PZR pressure less than or equal to Psat +100 PSIA during a PZR cooidown and PZR temperature is greater than 90°F unless a one hour soak at 35th= +/- 5°F has occur) . The change also deletes the requirement in the new TRM specification to determine that the pressurizer remains acceptable for continued operation or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the pressurizer pressure to less than 500 prig within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> ; and replaces it with a rerii iirement to Antar TRM LCO 3 .0 .3 . This change will also add a Bases section for TRM 3/4.4.8 and delete reference to the heatup and cooldown rates in TS Bases Section 3/4 .8 .4 .

None of the proposed changes result in a design basis limit for a fission product barrier as described in the FEAR being exceeded or altered .

The proposed non-editorial changes to deleted shutdown requirements, when the Actions cannot be completed within the allowed outage time or if there are no Actions for the condition identified, do not impact the fuel clad, RCS pressure boundary, or the containment . Therefore, no design basis limits associated with fission product barriers are affected .

The other changes are administrative and cannot by the definition of an administrative change result in a design basis limit for a fission product barrier as described in the FEAR being exceeded or altered . These changes are being made to provide consistency to the TRM and TS Bases .

8. Result in a departure from a method of evaluation described in the FSAR used in © Yes establishing the design bases or in the safety analyses? No BASIS:

The proposed change adds a new specification to the TRM (TRM 3 .4 .8 .2 for the pressurizer heatup and cooldown rates; reduces the pressurizer cooldown rate from 200°F to 135°F ; revises TRM LCO 3 .0 .3 by deleting the MODE requirements and adding two LCOs (PZR pressure has exceeded Psat +100 PSIA during a PZR cooldown and PZR temperature is <90°F and a one hour soak time at 95°F +/- 5°F did not occur) . The change also deletes the requirement in the new TRM specification to determine that the pressurizer remains acceptable for continued operation or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the pressurizer pressure to less than 500 psig within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> ; and replaces it with a requirement to enter TRM LCO 3 .0 .3 .

This change will also add a Bases section for TRM 3/4 .4 .8 and delete reference to the heatup and cooldown rates in TS Bases Section 3/4 .8 .4 .

None of the proposed changes result in a departure from a method of evaluation described in the FSAR used in establishing the design bases or in the safety analyses .

None of the aforementioned non-editorial changes correspond to or affect any method of evaluation described within or without the FSAR . No change to any input parameter for dose assessment or design basis methodologies has resulted due to any of the proposed changes . These changes only affect the Actions to be taken following failure of the SSC . Additionally, the deletion of the shutdown requirement from the Pressurizer Heatup and Cooldown Limit Specification with a requirement to enter TRM LCO 3 .13 .3 will not affect the safety analysis or design basis requirements described in the FSAR .

The other changes are administrative and cannot by the definition of administrative changes result in a departure from a method of evaluation described in the FSAR used in establishing the design basis or in the safety analysis . These changes are being made to provide consistency to the TRM and TS Bases .