ML20210B318
| ML20210B318 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/19/1999 |
| From: | Dugger C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20210B324 | List: |
| References | |
| RTR-NUREG-1432 W3F1-99-0092, NUDOCS 9907230125 | |
| Download: ML20210B318 (7) | |
Text
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- ftS%of;Oa'a"c-ph Killona, LA 70066 Tel 504 739 0000 i
Fax 504 739 0678 Charles M. Dugger
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l W3F1-99-0092 A4.05 PR July 19,1999 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Subject:
'Naterford 3 SES l
Docket No. 50-382 License No. NPF-38 Technical Specification Change Request NPF-38-219
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i Gentlemen:
i In accordance with 100FR50.90, Entergy is hereby proposing to amend Operating License NPF-38 for Waterford 3 by requesting NRC review and approval of the attached changes to the Technical Specifications. The attached description and safety analysis support the proposed changes to the Waterford 3 Technical
' Specifications (TS). The proposed changes modify TS 4.5.2.f.2 by increasing the performance requirement for the Low Pressure Safety injection (LPSI) pumps. The change revises the LPSI pump Surveillance Requirements to measure pump developed head, instead of pump discharge pressure. The change allows LPSI pump performance to be more accurately monitored because developed head is not dependent on pump suction head. The proposed change increases the minimum acceptable LPSI pump developed head. The new acceptance criteria is therefore more conservative. An associated change to the Technical Specification Bases f
(3/4.5.2) is required and is included with this submittal. The proposed Technical Specification change is modeled after the guidelines of NUREG 1432, " Standard Technical Specifications -Combustion Engineering Plants."
T This proposed Technical Specification change has been evaluated in accordance 0
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0 with 10CFR50.91(a)(1), using the criteria in 10CFR50.92(c), and it has been l
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determined that this request involves no significant hazards consideration.
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9907230125 990719 PDR ADOCK 05000382 p
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E Technical Specification Change Request NPF-38-219 W3F1-99-0092 Page 2 July 19,1999 l
The circumstances surrounding this change do not meet the NRC's criteria for
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l exigent or emergency review. Entergy Operations requests the effective date for this change be within 60 days of approval. Entergy is requesting NRC approval of the TS change prior to March 15,2000 in support of Refuel 10, which is currently scheduled to begin September 15,2000.
This submittal does not contain commitments. Should you have any questions or comments concerning the Technical Specification change request, please contact Oscar Pipkins at (504) 739-6707.
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Very truly yours, I
r C.M. Dugger l
Vice President, Operations Waterford 3 I
l CMD/ OPP /
l Attachments:
Affidavit NPF-38-219 cc:
E.W. Merschoff, NRC Region IV l
C.P. Patel, NRC-NRR I
J. Smith l
N.S. Reynolds j
l NRC Resident Inspectors Office Administrator Radiation Protection Division (State of Louisiana)
American Nuclear Insurers j
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of
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Entergy Operations, Incorporated
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Docket No. 50-382 Waterford 3 Steam Electric Station
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Charles Marshall Dugger, being duly sworn, hereby deposes and says that he is Vice President Operations - Waterford 3 of Entergy Operations, Incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Technical Specification Change Request NPF-38-219; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
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L Of Charles Marshall Dugger Vice President Operations - Waterford 3 STATE OF LOUISIANA
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) ss PARISH OF ST. CHARLES
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Subscribed and sworn to before me, a No,tay Public in and for the Parish and State above named this /96 day of VM
,1999.
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Notary Public My Commission expires d
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DESCRIPTION AND NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION OF PROPOSED CHANGE NPF-38-219 Summary of Proposed Changes The proposed change will increase the Low Pressure Safety injection (LPSI) pump minimum performance requirement. The proposed change modifies the pressure value prescribed in Technical Specification (TS) Surveillance Requirement 4.5.2.f.2 for the LPSI pump from 177 psig (pump discharge pressure) to 168 psid (pump differential pressure). This is a more restrictive performance requirement for the pump.
Existing Specification See Attachment A Proposed Marked-up Specification 1
See Attachment B Proposed Specification See Attachment C l
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Background
Two independent LPSI trains in combination with two independent high pressure safety injection (HPSI) trains form two independent Emergency Core Cooling System (ECCS) subsystems. The two LPSI pumps are high volume, low head centrifugal pumps designed to supplement the safety injection tank (SIT) inventory in reflooding the reactor vessel to ensure core cooling during the early stages of a large break loss of l
coolant accident (LOCA).
The LPSI pumps take suction from the refueling water storage pool (RWSP) during the injection phase of a LOCA event and pump the water through two separate discharge headers. Prior to penetrating containment, each LPSI header splits into two injection paths, with individual injection valves. Each supply header has a motor operated flow control valve. Once inside containment, the LPSI headers combine with HPSI and SIT discharge piping and direct the flow through a common injection header into each of the four reactor coolant system cold legs. The LPSI system pumps start and valves open upon receipt of a safety injection actuation signal. When RWSP levelis drawn down by 1
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inventory transfer during the injection phase, a low RWSP level actuates the recirculation actuation signal (RAS) which stops the LPSI pumps and opens the Safety injection System sump isolation valves. The HPSI pumps and containment spray pumps remain running for long term containment and core cooling.
The LPSI system is also used in conjunction with a portion of the containment spray system for decay heat removal in the shutdown cooling alignment.
The proposed TS change revises the LPSI pump surveillance acceptance criteria from 177 psig discharge pressure to 168 psid developed head. The change allows LPSI pump performance to be more accurately monitored since developed head is not dependent on pump suction pressure. The proposed developed head minimum acceptance criteria is greater than previously required. That is, LPSI pump suction pressure is nominally 20 psig. Therefore, the LPSI pumps are currently required to develop approximately 157 psid in order to meet the 177 psig discharge pressure acceptance criteria. The new acceptance criteria is therefore more conservative.
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Description and Safety Considerations Currently, TS Surveillance Requirement 4.5.2.f.2 prescribes a LPSI Pump discharge pressure of greater than or equal to 177 psig. This value is dependent on pump developed head, as well as the pump suction pressure. The available suction head is nominally 20 psig (from Reactor Water Storage Pool level). Therefore, the pumps are currently required to develop only 157 psid in order to meet the TS requirement. The TS change will require 168 psid developed head, increasing the margin between the TS performance requirements and the analyticallimit. This change has no negative impact on nuclear safety.
No Significant Hazards Consideration Determination The proposed change 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 an accident previously evaluated?
Response
Increasing the LPSI pump performance requirements will not increase the probability or consequences of any accidents. There are no physical changes to the pump. The only procedure changes required are to Surveillance Procedure OP-903-030, " Safety injection Pump Operability Evaluation". The changes do 2
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not impact plant operating procedures. The LPSI system is primarily designed to mitigate the consequencen of a large break Loss of Coolant Accident (LOCA).
These proposed changes do not affect any of the assumptions used in the deterministic LOCA analysis. Hence the consequences of accidents previously evalua+.ed do not change.
Therefore, the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated.
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Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response
The proposed change does not alter plant operations, nor does it alter the physical plant. The change only increases existing equipment performance requirements. No different accidents result from the increase in performance requirements. No change is being made to the parameters within which the plant is operated. The setpoints at which protective or mitigative actions are initiated are unaffected by this change. No alteration in the procedures which ensure the plant remains within analyzed limits is being proposed, and no change is being made to the procedures relied upon to respond to an off-normal event. As such, no new failure modes are being introduced. The proposed change will only increase the performance requirements of the LPSI pumps.
Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?
Response
To the contrary, the change increases LPSI pump performance requirements, increasing the margin between the TS performance requirements and the ana4tical limit.
Therefore, the proposed change will not involve a significant reduction in a margin of safety.
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Safety and Significant Hazards Determination Based on the above No Significant Hazards Evaluation, 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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