ML20203A917

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Application for Amend to License NPF-38,consisting of Tech Spec Change Requests NPF-38-24,-25,-26,-27 & -28 Re Revs to Axial Shape Index Allowable Ranges,Moderator Temp Coefficient Allowable Ranges & Insertion Limits.Fee Paid
ML20203A917
Person / Time
Site: Waterford Entergy icon.png
Issue date: 07/15/1986
From: Muench G
LOUISIANA POWER & LIGHT CO.
To: Knighton G
Office of Nuclear Reactor Regulation
Shared Package
ML20203A921 List:
References
W3P86-2313, NUDOCS 8607170362
Download: ML20203A917 (10)
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e P. O. BOX 60340 LO UISI POWER AN HT

& LIG A/ 317 NEWBARONNE STREET ORLEANS, LOUISIANA 70160 + (504) 595-3100 bis N sts N July 15, 1986 W3P86-2313 3-A1.01.04 A4.05 Mr. George W. Knighton, Director QA PWR Project Directorate No. 7 Division of PWR Licensing-B Office of Nuclear Reactor Regulation Washington, D.C. 20555

SUBJECT:

Waterford SES Unit 3 Docket No. 50-382 Technical Specification Change Requests NPF-38-24, NPF-38-25, NPF-38-26, NPF-38-27, NPF-38-28

Dear Mr. Knighton:

Louisiana Power & Light hereby files an application for five amendments to the Waterford 3 Technical Specifications. The amendments involve:

1. A revision to the axial shape index allowable ranges (h7F-38-24),
2. A revision to the moderator temperature coefficient allowable ranges (NPF-38-25),
3. A revision to the insertion limits for part length CEAs (NPF-38-26),
4. An exception to proposed change NPF-38-26 to allow suspension of the limitations on part length CEAs during certain startup testing (NPF-38-27), and
5. Addition of the Reactor Vessel Level Monitoring System to the Technical Specifications (NPF-38:-28) .

LP&L has previously provided a summary of the Technical Specification change requests expected to be submitted prior to the first refueling outage. Attached, for your information, is an updated schedule of the proposed changes. Items 1-5, above constitute the Group E changes, all of which are reload related.

Your timely attention to these changes is appreciated. Also enclosed is LP&L check number 07-5135 for $150 to cover the required filing fee.

The proposed changes do not involve an unreviewed safety question nor a significant hazards consideration. Should you have any questions or require additional information concerning the requested changes, please contact Mike Meisner at (504) 595-2832.

8607170362 860715 PDR ADOCK 05000382 P

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. . Muench Acting Director, Nuclear Operations GW@MW "AN EQUAL OPPORTUNITY EMPLOYER" s i

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Enclosures:

Listing of Potential Technical Specification Changes (Revision 1)

NPF-38-24 NPF-38-25 NPF-38-26 NPF-38-27 hTF-38-28 Filing Fee, LP&L Check Number 07-5135 cc: B.W. Churchill, W.M. Stevencon, R.D. Martin, J.H. Wilson, NRC Resident Inspector's Offit.a (W3), Administrator Nuclear Energy Divison (State of Louisiana), American Nuclear Insurers

. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION a

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

AFFIDAVIT G.W. Muench, being duly sworn, hereby deposes and says that he is Acting Director, Nuclear Operations of Louisiana Power & Light Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Technical Specification Change Requests; that he is familiar with 4

the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief, t

1 G.W. MuencH Acting Director, Nuclear Operations STATE OF LOUISIANA) a

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PARISH OF ORLEANS )

Subscribedandsworntobeforeme,aNotaryPublicJnandfortheParish and State above named this /6 fA day of LJ IM ,

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POTENTI AL TECliNICAL SPECIFICATIONS CIIANGES -

Revision 1, 7/15/86 i3) CROUP A

( 7/01/80 (2) ( 8/2I/8(2) ( 9/25/80 (10/01/86)

(10/01/86) GROUP 11 (7) CROUP C (5) CROUP D (11/21]86) i (12 [25/86) (01]_01/87)

TECH SPEC NATURE OF TECH SPEC NATURE OF _.TECll SPEC NATURE OF TECll SPEC NATURE OF SECTION CllANGE SECTION CitANGE SECTION CilANGE SECTION CilANGE 4

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3 4. .$ . 4 CEA Drop Time 3.1.2.7 May Require Change 3.1.1.1 Shutdown Margin for 2.1.1.1 Redefine the Limit.

18 month Surveillance in BAM Tank MODES 1-4 may change Reactor Core DNBR

(Submitted to NRC Concentration q on 6/24/86) 5.3.1 Fuel enrichment limit 3.9.1 Refueling Boron 3.1.1.2 Shutdown Margin for 2.2.1 DNBR trip limit
increases from 3.7 Concentration May MODE 5 may change I w/o to = >4.10 w/o Change (Submitted to NRC 4 on 6/24/86) i 5.6.1 Update to reflect new 3.1.2.2 See MODE 5 Shutdown 3.2.4 Revise Figure and Change f uel storage criti- Margin Change Format, DNBR Margin 4 cality analyses for

!. Cycle 2 aa ^ '

i (Submitted to NRC i

on 6/24/86) 3.1.2.4 See MODE 5 Shutdown 3.3.1 Table 3.3-1 ACTION 6b Margin Change may be revised, Reactor Protective l Instrimentation i 3.1.2.6 See MODE 5 Shutdown 3.1.3.6 Revise Insertion Margin Change Limit Figure I'

3.1.2.8 See MODE 5 Shutdown Margin Change '-

4 3.1.2.9 Table 3.1-1 may change, Shutdown

margin 4 .

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POTENTI AL TECHNICAL SPECIFICATIONS CHANGES Revision 1, 7/I5/86 4

I (7) GROUP E ( 7/l / 6)

(7) ( 01/86) I! !

CROUP F (1) GROUP G (8) GROUP H t TECH SPEC (12f_15/86) _ _(12f15/86) _ _ j y 22/86)

NATURE OF TECH SPEC NATURE OF TECH SPEC NATURE OF _ TECH SPEC NATURE OF SECTION CHANGE SECTION CHANGE SECTION CHANGE SECTION CllANCE r l 3.1.1.3 MTC will become more 2.1.1.2 Redef ine the I;LilR 2.2.2 Removal, requested, 3.3.1/3.3.2 RPS/ESFAS Surveillance j negative at EOC and limit SIFR 10465, 3/26/86 (01/01/87) Interval j more positive at POC CPC Addressable (Submitted to NRC on constant i

7/15/86) (Tech Spec change received) 3.1.3.7 Add curve and change 3.1.3.1 CEA Misalignment 3.6.3 Containment Isolation short-term and tran- ACTION statement (08/01/86) Valves sient insertion limits need to be modified (Submitted to NRC on 7/15/86) 1 3.2.7 ASI ranges will 3.2.1 KW/FT Limit may 3.8.1.1 A.C. Sources -

change change (11/01/86) DG Testing Relief (Submitted to NRC on (Tech Spec Change 1/15/86) received)

. 3.3.3.6 Add RVLMS per License 3.5.1 SIT boron concen- 6.2.2 Staffing Conditions and CEOG tration and volume (Submitted to NRC on (Submitted to NRC on requirements may 6/24/86) -

7/15/86) change 3.10.2 Add 3.1.3.7 for 3.5.4 RWSP boron concen- 3.4.8.2 PZR Spray Nozzle Usage part-length CEAs tration and volume (08/01/86) Factor .

(Submitted to NRC on requirements may l- 7/15/86) change i 3.10.1 ACTIONS a,b may 3.4.8 Pressure Vessel 4 have revised values (08/01/86) Surveillance Capsule j of boron concentration l

l 3.3.3.8 Change Table 3.3.3.8 3.3.1 RPS, Allow Bypass i to list smoke detector SG Level High Trip in Control Room (Submitted to NRC on 6/24/86) <

I 5.3.1 Correct mistake re- l 3 characterizing 1807 gr i

! uranium as maximum fuel

, rod loading (Submitted to NRC on i 6/24/86) i .

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NPF-38-24

DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-24 This is a request to revise Technical Specification 3.2.7, Axial Shape Index.

Existing Specification See Attachment A.

Proposed Specification See Attachment B.

Description Technical Specification 3.2.7 imposes limits on axial shape index (ASI) to ensure that the actual value of ASI is maintained within the range of values used in the safety analyses and to ensure that the peak linear heat rate and DNBR remain within the safety limits for anticipated operational occurrences.

Technical Specification 3.2.7 currently states that ASI shall be maintained between -0.23 and +0.50 when COLSS is operable and between -0.19 and +0.24 when COLSS is out of service. The proposed change would revise the ASI band to -0.23 to +0.28 when COLSS is operable and -0.17 to +0.22 when COLSS is out of service. All ASI range changes are in a more restrictive direction.

This change is proposed in order to increase the calculated thermal margin for Cycle 2. Additional thermal margin is needed to offset some of the thermal margin losses associated with the higher radial power peaking factors anticipated for Cycle 2. These higher peaking factors are caused by the increased fuel enrichments necessary for a nominal 18 month cycle and by the change from an out-in-in core loading scheme to an in-in-out loading scheme.

The modeling uncertainties associated with COLSS and CPC calculations are sensitive to ASI range because more unusual axial shapes are normally more difficult to model. As the ASI band becomes larger, the range of potential axial shapes becomes larger, leading to the increased modeling uncertainties.

Conversely, by using a narrower ASI band the uncertainty components for axial shapes applied in the COLSS and CPC calculations are reduced. Increased modeling uncertainties translate to a reduction in thermal margin in order to ensure that the p.?. ant responds conservatively to limiting events. By the same token, reducing modeling uncertainties through the narrowing of the ASI band increases thermal margin.

Approval of the proposed change is requested by December 15, 1986 in order to support Cycle 2 operation.  ;

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Safety Analysis The proposed changes 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 involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: No The reason for this change is to ensure that the actual value of ASI is maintained within the range of values used in the Cycle 2 safety analyses which ensures that the peak linear heat rate and DNBR remain within the safety limits for anticipated operational occurrences. Because the changes to the ASI band are in a more restrictive direction .the effect of this proposed change does not significantly increase the probability or consequences of any accident previously evaluated.

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

Response: No The reason for this change is to ensure that the actual value of ASI is maintained within the range of values used in the Cycle 2 safety analyses which ensures that the peak linear heat rate and DNBR remain within the safety limits for anticipated operational occurrences. Because the changes to the ASI band are in a more restrictive direction with respect to previously analyzed events, the effect of this proposed change does not create the possibility of a new or different kind of accident from those previously evaluated.

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

Response: No The reason for this change is to ensure that the actual value of ASI is maintained within the range of values used in the Cycle 2 safety analyses which ensures that the peak linear heat rate and DNBR remain within the safety limits for anticipated operational occurrences. Because the changes to the ASI band are in a more restrictive direction, which preserves key parameter safety limits, the effect of this proposed change does not involve a significant reduction in margin of safety.

t 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 considerations. Example (ii) relates to a change'that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications; for j example, a more stringent surveillance requirement.

In this case, the proposed change is similar to Example (ii) in that the change to Technical Specification 3.2.7 provides additional restriction on ASI not presently 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 i

by 10CFR50.92; (2) there is a reasonable assurance that the health and safety l of the public will not be endangered by the proposed change; and (3) this 4 action will not result in a condition which significantly alters the impact i of the station on the environment as described in the NRC Final Environmental Statement.

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