ML20115G490

Application for Amend to License NPF-38,modifying Spec 3/4.7.1.3 Condensate Storage Pool by Increasing Minimum Required Contained Water Vol from 82% to 91% Indicated Level

ML20115G490
Person / Time
Site:	Waterford
Issue date:	07/17/1996
From:	Sellman M ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20115G494	List: ML20115G490 ML20115G495
References
W3F1-96-0045, W3F1-96-45, NUDOCS 9607190176
Download: ML20115G490 (7)

Text

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l Entsrgy Operations, Inc.

Killona. LA 70066-0751 Tel 504 739 FEE;0 J

Mike Sellman vce Presdent opvanons i

W3F1-96-0045 A4.05 PR l

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July 17,1996 U.S. Nuclear Regulatory Commission Attn: Document Control Desk l Washington, D.C. 20555 I

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Subject:

Waterford 3 SES Docket No. 50-382 i License No. NPF-38  !

! Technical Specification Change Request NPF-38-179 I

Gentlemen:  ;

l 1 l The attached description and safety analysis supports a change to the Waterford 3 Technical Specifications (TS). The subject change request modifies specification 3/4.7.1.3 CONDENSATE STORAGE POOL by increasing the minimum required l contained water volume from 82 percent to 91 percent indicated level. This l proposed change is required to ensure that the minimum useable water volume in the Condensate Storage Pool is maintained greater than or equal to 170,000 gallons. The new minimum level accounts for the minimum level required to prevent Emergency Feedwater pump suction line vortexing and instrument measurement uncertainties.

The proposed change has been evaluated in accordance with 10CFR50.91(a)(1) using criteria in 10CFR50.92(c) and it has been determined that this change involves no significant hazards considerations. The bases for these determinations i are included in the attached submittal.

I Waterford 3 requests that the implementation date for this change be within 60 days of NRC issuance of the amendment to allow for distribution and procedure revisions necessary to implement this change. Although this request is neither exigent nor emergency, your prompt review is requested.

9607190176 960717 2 DR ADOCK 0500 g i

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. e Technical Specification Change Request NPF-38-179 W3F1-96-0045 L

Page 2 July 17,1996 Should you have any questions or comments concerning this request, please contact Mr. James Fisicaro at (504) 739-6242.

l l Very truly yours, 1 f, ~

M.B. Sellman Vice President, Operations.

! Waterford 3

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Attachment:

Affidavit ]

NPF-38-179  !

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cc: L.J. Callan, NRC Region IV  !

C.P. Patel, NRC-NRR i R.B. McGehee N.S. Reynolds NRC Resident inspectors Office

! Administrator Radiation Protection Division

( (State of Louisiana) j American Nuclear insurers i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION  !

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[ l l In the matter of )

) s Entergy Operations, incorporated ) Docket No. 50-382 Waterford 3 Steam Electric Station )

AFFIDAVIT M.B. Sellman, being duly sworn, hereby deposes and says that he is Vice President Operations - Waterford 3 of Entergy Operations, Incorporated; that he is duly l authorized to sign and file with the Nuclear Regulatory Commission the attached l Technical Specification Change Request NPF-38-179; that he is familiar with the l content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

. .J -

l M.B. Sellman  !

Vice President Operations - Waterford 3 )

i i STATE OF LOUISIANA ) ,

) ss l PARISH OF ST. CHARLES )

Subscribed and sworn to before me, a Notary Public in and for the Parish and State i l above named this 1i* day of lucv .1996.

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! Notary Public l  !

My Commission expires w*"^ .

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i DESCRIPTION AND SAFETY ANALYSIS <

OF PROPOSED CHANGE NPF-38-179 l

This proposed change modifies spec!fication 3/4.7.1.3 CONDENSATE STORAGE POOL by increasing the minimum required contained water volume from 82 percent to l 91 percent indicated level. Thir, proposed change is required to ensure that the l minimum useable water volume in the Condensate Storage Pool is maintained greater than or equal to 170,000 galloris. The new minimum level accounts for the minimum level required to prevent Emergency Feedwater pump suction line vortexing and the  ;

l current instrument measurement uncertainties.

EXISTING SPECIFICATION (See Attachment A) 1 PROPOSED SPECIFICATION (See Attachment B) i BACKGROUND The Emergency Feedwater system (EFW) provides cooling water to one or both steam l generators for the purpose of removal of decay heat from the Reactor Coolant system l (RCS) in response to any event causing low steam generator level coincident with the  ;

absence of a low pressure trip.

The EFW system is comprised of two independent and redundant trains flowing from i the Condensate Storage Pool (CSP) to connections at the two main feedwater lines. i Each train is provided with one 50 percent capacity motor driven pump. One 100 I percent capacity pump driven by a noncondensing steam turbine is also provided to feed either or both trains. The purnps re-circulate back to the CSP.

! The primary source of EFW is the CSP. The CSP is a stainless steel lined reinforced concrete Seismic Category I pool located within the Reactor Auxiliary Building (RAB).

Secondary seismic Category I sources of EFW are the Wet Cooling Tower (WCT)  ;

basins. The CSP contains adequate capacity to bring the RCS to shutdown cooling l entry conditions. j l

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' Makeup'to the CSP is from the non-seismic Condensate Storage Tank (CST). Should makeup to the CSP be disabled and the CSP inventory depleted, means are provided to pump water from the WCT basins to the EFW pump suctions using the Auxiliary l Component Cooling Water (ACCW) pumps.

l l Two redundant and independent channels of level indication are provided for the CSP l to monitor and ensure maintenance of the volume required by Technical Specifications and to provide operators with adequate information for deciding to align the EFW pump suctions to a WCT basin.

During an EFW self assessment, it was determined that the CSP level indication did l not incorporate the current instrumentation measurement uncertainties. As a result, the l CSP level may not have been in compliance with Technical Specification 3.7.1.3 with the pool level indicating 82 percent. A record search was performed and it was determined that the CSP had not been below the minimum required contained water i volume of 170,000 gallons. Subsequently, it was determined that vortexing in the EFW pump suction piping was not considered in the design basis of the CSP. At a low level in the CSP, some air ingestion could occur. This could create a condition for non-l uniform EFW flow to exist. To account for these two discoveries Waterford is requesting that the minimum CSP level be increased from 82 percent to 91 percent.

Waterford 3 is currently administrative!y maintaining the CSP level at the requested 91 l percent. This is a conservative interim corrective action pending approval of Technical Specification Amendment approval. l l

DESCRIPTION l The EFW system must remain functional during and after a design basis event to ensure the system is capable of removing decay heat from the RCS until shutdown cooling entry conditions are reached. The EFW system must also be able to perform its safety function in the event of either a sing!e active failure in the short term or an i active or passive failure in the long term.

1 The CSP plus one WCT basin provide, as a minimum, the ability to hold the RCS at hot standby for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> followed by an orderly cooldown prior to entering shutdown cooling conditions.

Each WCT basin contains a minimum supply of 170,000 gallons which can be directed to the suctions of the EFW pumps via the ACCW pumps. This is adequate capacity (along with the CSP) to allow EFW to cool the RCS for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> assuming loss of one standby diesel generator or loss of one atmospheric dump valve without outside makeup. This assumes loss of unprotected portions of the Dry Cooling Towers (DCT) to tornado missiles

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' The dSP has a total capacity of approximately 210,000 gallons. A minimum of 170,000  ;

gallons is maintained per this Technical Specification (3/4.7.1.3)  !

The indicated level specified in the current Technical Specification (82 percent) did not account for vortex phenomena or the current instrumentation measurement '

uncertainties. The proposed level of 91 percent is based on having at least 170,000 gallons available (80.71 percent), while accounting for the required level to prevent '

vortexing (5.7 percent) and instrument measurement uncertainties (4.46 percent). l l

Vortexing is a phenomena where air may be ingested into the EFW pump suction l piping during high flow conditions with low CSP levels it has been calculated that  :

vortexing can be prevented if a level allowance of 5.7 percent is provided. Additionally, j to insure a useable water volume of 170,000 gallons is maintained in the CSP, it has  !

been calculated that an allowance of 4.46 percent should be added for instrument l l measurement uncertainties. This proposed change will continue to maintain the i required 170,000 gallons in the CSP by increasing the minimum indicated level from 82 i percent to 91 percent, thus insuring an adequate supply of water will be available to  ;

supply the Emergency Feedwater system. l 1

Safety Analysis  !

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

1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

Increasing the minimum required CSP level will insure that the minimum required 170,000 gallons of water is available for supply to the Emergency Feedwater System. Maintaining the minimum required water volume will not increase the probability of any accident previously evaluated. Additionally, it will not affect the consequences of any accident. Maintaining at least 170,000 gallons of water available in the CSP will ensure that the system remains within the bounds )

of the accident analysis. Therefore, the proposed change will not involve a l significant increase in the probability or consequences of any accident previously evaluated.

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2. Will operation of the facility in accordance with this proposed change  ;

create the possibility of a new or different type of accident from any accident ,

previously evaluated?

Response: No.

increasing the minimum water volume of the CSP from 82 percent to 91 percent i does not create a possibility for a new or different kind of accident.~ The CSP will l be operated in the same manner as previously evaluated. Therefore, the i proposed change will not create the possibility of a new or different kind of I accident from any accident previously evaluated. j j 3. Will operation of the facility in accordance with this proposed change l involve a significant reduction in a margin of safety?

Response: No.

Operation in accordance with this proposed change will ensure that the minimum j contained water volume of the CSP will remain at least 170,000 gallons under all l conditions. This will maintain the present margin of safety. Therefore, the l proposed change will not involve a significant reduction in a margin of safety.

l- Safety and Sianificant Hazards Determination i

Based on the above safety analysis, it is concluded that: (1) the proposed change does not constitute a significant hazards consideration as defined by 10CFR50.92; and (2) there is a reasonable' assurance that the health and safety of the public will 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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