ML041750549

Issuance of Amendment Relocation of Pressurizer Maximum Heatup and Cooldown Limits

ML041750549
Person / Time
Site:	Waterford
Issue date:	06/16/2004
From:	Kalyanam N NRC/NRR/DLPM/LPD4
To:	Venable J Entergy Operations
Kalyanam N,NRR/DLPM,415-1480
References
TAC MC2334
Download: ML041750549 (10)

Text

June 16, 2004 Mr. Joseph E. Venable Vice President Operations Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 (WATERFORD 3) -

ISSUANCE OF AMENDMENT RE: RELOCATION OF PRESSURIZER MAXIMUM HEATUP AND COOLDOWN LIMITS (TAC NO. MC2334)

Dear Mr. Venable:

The Commission has issued the enclosed Amendment No. 195 to Facility Operating License No. NPF-38 for Waterford 3. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated March 15, 2004.

The amendment removes the pressurizer heatup and cooldown limits, and the associated action and surveillance requirements from the TSs and places them in the Technical Requirements Manual.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice.

Sincerely,

/RA/

N. Kalyanam, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosures:

1. Amendment No. 195 to NPF-38

2. Safety Evaluation cc w/encls: See next page

June 16, 2004 Mr. Joseph E. Venable Vice President Operations Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 (WATERFORD 3) -

ISSUANCE OF AMENDMENT RE: RELOCATION OF PRESSURIZER MAXIMUM HEATUP AND COOLDOWN LIMITS (TAC NO. MC2334)

Dear Mr. Venable:

The Commission has issued the enclosed Amendment No. 195 to Facility Operating License No. NPF-38 for Waterford 3. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated March 15, 2004.

The amendment removes the pressurizer heatup and cooldown limits, and the associated action and surveillance requirements from the TSs and places them in the Technical Requirements Manual.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice.

Sincerely,

/RA/

N. Kalyanam, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosures:

1. Amendment No. 195 to NPF-38

2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC PDIV-1 Reading RidsNrrDlpmLpdiv (HBerkow)

RidsNrrLADJohnson RidsNrrPMNKalyanam RidsNrrDlpmLpdiv1 (RGramm)

RidsOgcRp RidsAcrsAcnwMailCenter RidsNrrLADBaxley GHill(2) RidsNrrDripRorp (TBoyce) JWermiel KKavannaugh RidsRgn4MailCenter (AHowell)

Accession No.:ML041750549

• See prior concurrence OFFICE PDIV-1/PM PDIV-1/LA DSSA/SRXB* DIPM/IROB* OGC* PDIV-1/SC NAME NKalyanam DBaxley JUhle KKavannaugh TSmith RGramm DATE 6/4/04 6/4/04 05/25/04 06/03/04 06/04/04 6/10/04 OFFICIAL RECORD COPY

ENTERGY OPERATIONS, INC.

DOCKET NO. 50-382 WATERFORD STEAM ELECTRIC STATION, UNIT 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 195 License No. NPF-38

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Entergy Operations, Inc. (EOI) dated March 15, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.2. of Facility Operating License No. NPF-38 is hereby amended to read as follows:

2. Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 195, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: June 16, 2004

ATTACHMENT TO LICENSE AMENDMENT NO. 195 TO FACILITY OPERATING LICENSE NO. NPF-38 DOCKET NO. 50-382 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert VI VI 3/4 4-33 3/4 4-33

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 195 TO FACILITY OPERATING LICENSE NO. NPF-38 ENTERGY OPERATIONS, INC.

WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382

1.0 INTRODUCTION

By application dated March 15, 2004, Entergy Operations, Inc. (the licensee), requested changes to the Technical Specifications (TSs) for Waterford Steam Electric Station, Unit 3 (Waterford 3).

The proposed changes would remove the pressurizer heatup and cooldown limits, and the associated action and surveillance requirements (SRs), from the TSs and place them in the Technical Requirements Manual (TRM). Specifically, the proposed change relocates the pressurizer heatup and cooldown limits in TS 3.4.8.2, Reactor Coolant System - Pressurizer Heatup/Cooldown, and the associated ACTION, and SURVEILLANCE REQUIREMENTS to the TRM. The licensees application indicates that the proposed amendment is consistent with the Nuclear Regulatory Commission (NRC) approved Standard Technical Specifications, Combustion Engineering Plants (NUREG-1432).

2.0 REGULATORY EVALUATION

Criteria for Inclusion of Items in TSs Section 182a of the Atomic Energy Act of 1954, as amended, requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The NRC's regulatory requirements related to the content of TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, which requires that the TSs include items in certain specific categories, including (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls.

As set forth in 10 CFR 50.36(c)(2)(ii), the following four criteria are to be used in determining whether an LCO is required to be included in the TSs:

(A) Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

(B) Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

(C) Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

(D) Criterion 4. A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

Therefore, existing TS LCOs and related SRs that fall within or satisfy any of these criteria must be retained in the TSs, while those TS requirements that do not fall within or satisfy any of these criteria may be relocated to other documents controlled by the licensee.

The NRC staff notes that the proposed amendment is consistent with the NRC-approved NUREG-1432.

Pressurizer The pressurizer is a cylindrical carbon steel vessel with stainless steel internal surfaces. A spray nozzle on the top of the head is used in conjunction with heaters in the bottom head to provide level and pressure control. Overpressure protection is provided by two safety valves.

The pressurizer is supported by a cylindrical skirt welded to the bottom head.

The pressurizer is designed and fabricated in accordance with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) requirements. Final Safety Analysis Report (FSAR) Table 5.2-2 provides a listing of the applicable Code requirements. The interior surface of the cylindrical shell and upper head is clad with weld deposited stainless steel. The lower head is clad with a Ni-Cr-Fe alloy to facilitate welding of the Ni-Cr-Fe alloy heater sleeves to the shell. A stainless steel safe end is provided on the pressurizer nozzles, after final stress relief of the vessel, to facilitate field welds to the stainless steel piping. The structural integrity of the pressurizer is assessed by performing inservice inspections in accordance with the ASME Code,Section XI requirements.

For the design of the components in the reactor coolant system (RCS), 500 heatup and cooldown cycles, during the design life, were considered in the fatigue analysis with heating and cooling at a rate of 200 °F/hour between 70 °F and 653 °F for the pressurizer. The heatup and cooldown rate of the system is administratively limited by the licensee to assure that these limits will not be exceeded. This is based on consideration of both historical plant transient history and projections of transient lifetime occurrences for the components.

A detailed description of the operation of the pressurizer is included in section 5.4.10 of the Waterford 3, FSAR.

3.0 TECHNICAL EVALUATION

TS 3/4.4.8.2 The existing TS 3/4.4.8.2 conditions, actions, and SRs for the pressurizer temperature limits will be removed from the TSs and placed in the TRM. These requirements define the limitations on the pressurizer heatup and cooldown to assure that the pressurizer remains within the design criteria assumed for the pressurizer fatigue analysis. As discussed in Section 5.4.10.2 of the Waterford 3 Safety Analysis Report (SAR), the pressurizer is made in accordance with the requirements of the ASME Code,Section III. The related analyses show that the pressurizer is adequate for all normal operating and transient conditions expected for the life of the plant. In addition, following fabrication, the pressurizer was hydrostatically tested and then nondestructively tested in accordance with the ASME Code,Section III.

The NRC staff evaluated the existing TSs against the four LCO criteria set forth in 10 CFR 50.36(c)(2)(ii). Pressurizer temperature limits are neither a form of instrumentation nor a structure, system, or component, and therefore, do not meet Criteria 1, 3, or 4. The pressurizer temperature limits are process variables, and therefore, need to be considered under Criterion 2. However, these process variables are consistent with boundaries assumed in the structural analyses of the pressurizer and not as an initial condition for a design basis accident or transient analysis. Therefore, the pressurizer temperature limits do not meet Criteria 2 for inclusion in the TSs.

The NRC staff notes that the pressurizer pressure high and low trips are included as Reactor Trip System setpoints in TS 3/4.3.1, Instrumentation - Reactor Protective Instrumentation. The trip setpoints have been selected to ensure that the reactor core and RCS are prevented from exceeding their safety limits during normal operation and design-basis anticipated operational occurrences, and to assist the Engineered Safety Features Actuation System in mitigating the consequences of accidents. However, the pressurizer heatup and cooldown limits in TS 3/4.4.8.2 do not affect the pressurizer high and low pressure reactor trip setpoints in TS 3/4.3.1.

The NRC staff also notes that TS 3/4.4.3, Reactor Coolant System - Pressurizer, which requires the pressurizer to be operable, is retained in the Waterford 3 TSs. Therefore, TS 3/4.4.3 is also not affected by the proposed change.

Based on the above, the NRC staff finds that the pressurizer heatup rate and cooldown rate limits in TS 3/4.4.8.2 do not satisfy any of the four criteria used in determining whether an LCO is required to be included in the TSs. Therefore, the currently existing pressurizer heatup and cooldown rates, and associated action and SRs in TS 3/4.4.8.2 may be removed from the TSs and placed in a licensee-controlled document.

The licensee indicated that upon approval of this amendment, the currently existing the pressurizer heatup and cooldown rates, and associated action and SRs in TS 3/4.4.8.2, will be placed in the TRM. The Waterford 3 SAR, Section 13.8.2, states that the TRM is administered as part of the SAR, changes to the TRM are subject to the criteria of 10 CFR 50.59, and administrative controls for processing TRM changes are included in the site procedure.

Therefore, the NRC staff finds that sufficient regulatory controls exist for the TRM.

Accordingly, the NRC staff finds that the requirements associated with the pressurizer temperature limits in TS 3/4.4.8.2 may be removed from the TSs and placed in the TRM because: (1) the 10 CFR 50.36 TS inclusion criteria are not applicable, (2) these requirements will be appropriately placed in the licensees TRM, and (3) sufficient regulatory controls exist for the TRM.

Affected TS Pages As a result of the changes to TS 3/4.4.8.2, the licensee proposed TS changes for the affected TS pages, as follows: a revision to TS Index page VI to remove the listing for the pressurizer pressure and temperature limits in Section 3/4.4.8, and the listing for page 3/4 4-33; and the changes to TS page 3/4 4-33 (this page currently has TS 3/4.4.8.2, which is the subject of this license amendment).

The NRC staff has reviewed the revisions to the above affected TS pages and finds them to be consistent with the removal of TS 3/4.4.8.2, and therefore, acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Louisiana State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (69 FR 19569, dated April 13, 2004). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: N. Kalyanam Date: June 16, 2004

Waterford Steam Electric Station, Unit 3 cc:

Mr. Michael E. Henry, State Liaison Officer Regional Administrator, Region IV Department of Environmental Quality U.S. Nuclear Regulatory Commission Permits Division 611 Ryan Plaza Drive, Suite 1000 P.O. Box 4313 Arlington, TX 76011 Baton Rouge, Louisiana 70821-4313 Parish President Council Vice President, Operations Support St. Charles Parish Entergy Operations, Inc. P. O. Box 302 P. O. Box 31995 Hahnville, LA 70057 Jackson, MS 39286-1995 Executive Vice President Director & Chief Operating Officer Nuclear Safety Assurance Entergy Operations, Inc.

Entergy Operations, Inc. P. O. Box 31995 17265 River Road Jackson, MS 39286-1995 Killona, LA 70066-0751 Chairman Wise, Carter, Child & Caraway Louisiana Public Services Commission P. O. Box 651 P. O. Box 91154 Jackson, MS 39205 Baton Rouge, LA 70825-1697 General Manager Plant Operations Waterford 3 SES Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751 Licensing Manager Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751 Winston & Strawn 1400 L Street, N.W.

Washington, DC 20005-3502 Resident Inspector/Waterford NPS P. O. Box 822 Killona, LA 70066-0751 July 2003