ML080560080

Waterford, Unit 3, Technical Specification Bases Update to the NRC for the Period June 2, 2007 Through February 15, 2008

ML080560080
Person / Time
Site:	Waterford
Issue date:	02/20/2008
From:	Murillo R J Entergy Nuclear South
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2008-0016
Download: ML080560080 (7)

Text

Entergy Nuclear South Entergy Operations, Inc.17265 River Road Killona, LA 70057-3093 Tel 504-739-6715 Fax 504-739-6698 ff rmurill@entergy.com Robert J. Murillo Licensing Manager Waterford 3 W3F1-2008-0016 February 20, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Technical Specification Bases Update to the NRC for the Period June 2, 2007 through February 15, 2008 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

Dear Sir or Madam:

Pursuant to Waterford Steam Electric Station Unit 3 Technical Specification 6.16, Entergy Operations, Inc. (EOI) hereby submits an update of all changes made to Waterford 3 Technical Specification Bases since the last submittal per letter W3F1 -2007-0031, dated June 13, 2007. This TS Bases update satisfies the requirement listed in 10 CFR 50.71(e).There are no commitments associated with this submittal.

Should you have any questions or comments concerning this submittal, please contact Ron Williams at (504) 739-6255.Very truly yours, RJM/RLW/Attachment Waterford 3 Technical.Specification Bases Revised Pages A001 W3F1-2008-0016 Page 2 cc: Mr. Elmo E. Collins, Jr.Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U.S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS O-7D1 Washington, DC 20555-0001 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 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 ATTACHMENT 1 To W3F1-2008-0016 Waterford 3 Technical Specification Bases Revised Pages Attachment 1 to W3F1-2008-0016 Page 1 of 1 T.S. Bases Implementation Affected TS Bases Pages Topic of Change Change Date No.53 10/11/07 Pages B 3/4 4-4d Change No. 53 to TS Bases section 3/4.4.5.2 B 3/4 4-4e was implemented by EC-3173. TS Bases Section 3/4.4.5.2 was changed to clarify the NOTE contained in SR 4.4.5.2 section. The NOTE, "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation," was added to SR 4.4.5.2 section, via TS Amendment 197, to provide an exception to the performance of the required reactor coolant system (RCS) water inventory balance surveillance test requirement 4.4.5.2.1.

TECHNICAL SPECIFICATION BASES CHANGE NO. 53 REPLACEMENT PAGE(S)(2 pages)Replace the following pages of the Water-ford 3 Technical Specification Bases with the attached pages. The revised pages are identified by Change Number 53 and contain the appropriate EC number and a vertical line indicating the areas of change.Remove Insert B 3/4 4-4d B 3/4 4-4d B 3/4 4-4e

> (DRN 04-1223, Ch, 33)REACTOR COOLANT SYSTEM BASES (continued)

Monitorinq Containment Sump In-Leakage Flow During automatic operation of the containment sum p pumps (after a containment sum p 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 sum p 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 m onitoring 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 sum p level instrumentation and the corresponding flow calcul ation is considered to remain operable.References

3. 10 CFR 50, Appendix A, Section IV, GDC 30.4. Regulatory Guide 1.45, Revision 0, dated May 1973.5. UFSAR, Sections 5.2.5 and 12.3.* (ORN 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.> (EC-3173 Ch. 53)For reactor coolant system operational leakage determination, steady state operation is required to perform a proper water balance since calculations during maneuvering are not useful and cannot ensure an accurate measurement is obtained (e.g. when operating in the shutdown cooling mode). The RCS water inventory balance must be performed with the reactor at stable operating pressure and steady state conditions (stable temperature, power level, pressurizer and makeup tank levels, makeup and" letdown, and RP seal injection and return flows). Therefore, a Note is added allowing that this surveillance is required to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> at stable operating pressure after' establishing steady state operation.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established.

The SR 4.4.5.2.1 performance after establishing steady state operation is consistent with the use and application guidance of section 1.4, F requency, of N UREG-1 432 Rev. 3.0,"Improved Standard Technical Specification Combustion Engineering Plants," March 31, 2004.In accordance with this guidance, the NO TE modifies the required performance of the Surveillance and it is construed to be part of the surveillance interval.

Even though the SR is not annotated with a 4.0.4 exemption, the SR is not required to be performed prior to entering a< (EC-3173 Ch. 53)WATERFORD

-UNIT 3 B 3/4 4-4d CHANGE NO. 33,L-36, 5&- 53 REACTOR COOLANT SYSTEM BASES (continued) 3/4.4.5.2 OPERATIONAL LEAKAGE> (EC-3173 Ch. 53)MODE in the Applicability of the associated LCO if any of the following conditions are satisfied:

(1) the SR has been performed within the surveillance interval (i.e. it is current) and is known not to be failed or (2) the SR is required to be met, but not performed, in the MODE to be entered and is known not to be failed. T he initial surveillance performance will be completed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> once the plant is at stable operating pressure following the establishment of steady state conditions.

Other instruments such as those contained in T S 3/4.4.5.1 can be utilized to determine whether RCS operational leakage limits are being exceeded prior to initial performance.

Once the plant establishes steady state operation, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed for completing the SR. If the SR was not performed within this 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval, there would then be a failure to perform the SR within the specified interval, and the provisions of 4.0.3 would apply. Should the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> interval be exceeded while steady state operation has not been established, this NOTE allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after steady state operation has been established to perform the SR. The SR is still considered to be performed within the surveillance interval.

Therefore, if the Surveillance was not performed within the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (plus the extension allowed by 4.0.2) interval, but steady state operation was not established, it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of 4.0.4 occurs when changing M ODES, even with the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> surveillance interval not met, provided operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with the establishment of steady state operation.

< (EC-3173 Ch. 53)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;06-916, Ch. 48)The primary to secondary leakage limit of 75 gallons per day through any one SG is based on the operational leakage performance criterion in NEI 97-06. The Steam Generator Program operational leakage performance criterion in NEI 97-06 states, "The RCS operational primary to secondary leakage through any one SG shall be limited to 150 gallons per day.'1 The NEI 97-06 limit is based on operating experience with SG tube degradation mechanisms that result in tube leakage. The operational leakage rate criterion (since it is less than 150 gpd through any one SG) in conjunction with the implementation of the Steam Generator Program is an effective measure for minimizing the frequency of steam generator tube ruptures.S(DRN 04-1243, Ch. 38;06-916, Ch. 48)WATERFORD

-UNIT 3 B 3/4 4-4e CHANGE NO. 53