ML20210M976
| ML20210M976 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/04/1999 |
| From: | Dugger C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20210M982 | List: |
| References | |
| W3F1-99-0023, NUDOCS 9908100248 | |
| Download: ML20210M976 (13) | |
Text
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J EntIrgy Operttions. Inc.
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17265 River Road Killona LA 70066 Tel 504 739 6660 Fax 504 739 6678 i
Vice re eder$t O ons Waterford3 W3F1-99-0023 l
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. August 41999.
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Cubject:
. Waterford 3 SES Docket No. 50-382 License No. NPF-38
' 'hnical Specification Change Request NPF-38-222 hs Pressure Safety Injection Allowed Outage Time increase Gentlemen:
In accordance with 10CFR50.90, Entorny is hereby proposing to amend Operating License NPF-38 for Waterford 3 by rewesting the attached changes to the Technical Specifications. The attached description and safety analysis supports a change to the Waterford 3 Technical Specifications (TS). The proposed change modifies TS 3.5.2 to extend the allowed outage time to seven days for one high pressure safety injection (HPSI) train inoperab's and T3 3.5.3 to change the end-state to HOT i
- SHUTDOWN with at least one OPERABLE shutdown cooling train in operation.
Additionally, an allowed outage time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in TS 3.5.2 is imposed for other conditions where the equivalent of 100% Emergency Core Cooling System subsystem flow is available. If 100% ECCS flow is unavailable due to two inoperable
- HPSI trains, an ACTION has been added to restore at least one HPSI train to OPERABLE status within one hour or place the plant in HOT STANDBY in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to exit the MODE of applicability in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. In the event ;he equivalent of 100% ECCS subsystern flow is not available due to other conditions, TS 3.0.3 is entered. The Limiting Condition for Operation terminology is being changed for consistency with the ECCS requirements. Attachment C also contains the remainder of the Bases pages for Section 3/4.5 to include page renumbering.
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' Technical Specification Change Request NPF-38-222 High Pressure Safety injection Allowed Outage Time Increase W3F1-99-0023
. Page 2 August 4,1999 This proposed change is a collaborative effort of participating Combustion
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Engineering Owners Group (CEOG) members based on an integrated review and assessment of plant operations, deterministic / design basis factors and plant risk, i
Joint Application Report CE NPSD-1041," Joint Applications Report for High Pressure Safety injection System Technical Specification Modifications," referenced herein in support of this change has been submitted to the Staff for review and approval under separate letter dated March 11,1998, by the CEOG. A change to the TS Bases 3/4.5.2 and 3/4.5.3 has been included to support this change.
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Additionally, this proposed change adds a Section 6.16 " Configuration Risk Management Program" to the Administrative Controls of the TS. The purpose of the Configuration Risk Management Program (CRMP) is to ensure that a proceduralized Probabilistic Risk Assessment-informed process is in place that assesses the overall impact of plant maintenance on plant risk. Implementation of the CRMP will enable appropriate actions to be taken or decisions to be made to minimize and control risk when performing on-line maintenance for Systems, Structures, and Components with a risk-informed Completion Time. TS 6.16 will be applicable to TS 3.5.2 for the HPSI train because the Completion Time for TS 3.5.2 is a " risk-informed Completion Time." The CRMP is consistent with the Amendment Application approved for San Onofre Nuclear Generating Station.
This proposed change has been evaluated in accordance with 10CFR50.91(a)(1),
using the criteria in 10CFR50.92(c), and it has been determined that this request involves no significant hazards consideration. This TS and Bases change is modeled after the guidelines of NUREG 1432, " Standard Technical Specifications -
Combustion Engineering Plants."
The circumstances surrounding this change do not meet the NRC Staff's criteria for exigent or emergency review. However, Entergy is requesting NRC Staff approval of the TS change prior to May 31,2000 to allow on-line maintenance in support of Refuel 10, which is currently scheduled to begin September 15,2000. Entergy Operations requests the effective date for this change be within 60 6 air of approval.
. Technical Specification Change Request NPF-38-222 High Pressure Safety injection Allowed Outage Time Increase W3F1-99-0023 Page 3 August 4,1999 There are no commitments associated with this request. Should you have any questions or comments concerning this request, please contact Everett Perkins at (504) 739-6379 or Gene Wemett at (504) 739-6692.
Very truly yours, C.M. Dugger Vice President, Operations Waterford 3 CMD/ CWT /rtk Attachments:
Affidavit NPF-38-222 cc:
E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR J. Smith N.S. Reynolds NRC Resident Inspectors Office Administrator Radiation Protection Division (State of Louisiana)
American Nuclear Insurers
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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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I AFFIDAVIT 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-38-222; 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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Cliaries Marshall Dugger
/J Vice President Operations - Waterford 3 j
STATE OF LOUISIANA
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Subscribed and sworry)6 before me, ag/4Llol tary Public in and for the Parish and State above named this Y day of 9W
.1999.
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~ Notary PubE p My Commission expires fn 80-d@.
DESCRIPTION AND NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION OF PROPOSED CHANGE NPF-38-222 Summary of Proposed Changes The proposed change requests a change to Technical Specifications (TS) 3.5.2 and 3.5.3. The purpose of this Technical Specification Change Request is to extend the allowed outage time (AOT) to seven (7) days for the high pressure safety injection (HPSI) train for TS 3.5.2 and to change the end-state to HOT SHUTDOWN with at least one OPERABLE shutdown cooling train in operation for TS 3.5.3. An AOT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is imposed for other conditions in TS 3.5.2 where the equivalent of 100% Emergency Core Cooling System (ECCS) subsystem flow is available. If 100% ECCS flow is unavailable due to two inoperable HPSI trains, an ACTION has been added to 3.5.3 to restore at least one HPSI train to OPERABLE status within one hour place the plant in HOT STANDBY in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to reduce pressurizer pressure to less than 1750 psia and RCS average temperature to less than 500*F in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. In the event the equivalent of 100% ECCS subsystem flow is not available due to other conditions, TS 3.0.3 is entered. The end state for 3.5.2 ACTIONS is being changed to " reduce pressurizer pressure to less than 1750 psia and RCS average temperature to less than 500 F" for consistency with the Applicability for 3.5.2. The Limiting Condition for Operation for both 3.5.2 and 3.5.3 is being changed from referencing HPSI and LPSI
- pumps to referencing HPSI and LPSI trains. A change to the TS Bases 3/4.5.2 and 3/4.5.3 has been included to support this change. Furthermore, this proposed change adds a Section 6.16 " Configuration Risk Management Program" to the Administrative Controls of the TS and the index.
Existing Specification See Attachment A Proposed Marked-up Specification See Attachment B Proposed Specification See Attachment C 1
Background
- The HPSI trains, in combination with the low pressure safety injection system (LPSI) trains form two redundant ECCS subsystems. The three HPGl pumps are high head centrifugal pumps designed to supplement safety injection tank (SIT) inventory in reflooding the reactor vessel to ensure core cooling during the early stages of a loss of coolant accident (LOCA). Additionally, the HPSI system may be used for long term L
core cooling in conjunction with the containment spray (CS) pumps.
The HPSI pumps take suction from the refueling water storage pool (RWSP), during the injection phase of a LOCA event, and pump the water through individual discharge headers. Before penetrating containment, the HPSI headers split into four injection paths with individualinjection valves. Once inside containment, the HPSI headers combine with LPSI and SIT discharge piping that directs flow through a common injection header into each of the reactor coolant cold legs. The HPSI pumps start and valves open upon receipt of a safety injection actuation signal. When RWSP levelis drawn down by inventory transfer during the injection phase, a low-low RWSP level actuates the recirculation actuation signal (RAS) which stops the LPSI pumps and opens the safety injection system sump isolation valves. This ensures adequate net positive suction head remains available for the HPSI pumps and CS pumps, which remain running for long term core cooling.
Descri tion and Safety Considerations p
The current Waterford 3 TS address the HPSI pumps and suction flow paths as a portion of the ECCS subsystem. TS 3.5.2 requires that two independent ECCS subsystems be OPERABLE. With one ECCS subsystem inoperable, based on any 4
component inoperability, the subsystem must be returned to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant placed in HOT STANDBY within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The proposed change will allow up to seven (7) days to restore operability to a HPSI train st ould that be the cause of the ECCS subsystem inoperability. An AOT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is imposed for other conditions where the equivalent of 100% ECCS subsystem flow is available consistent with NUREG 1432. If 100% ECCS flow is unavailable due to two inoperable HPSI trains, an ACTION has been added to restore at least one HPSI train to OPERABLE status within one hour or place the plant in HOT STANDBY in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce pressurizer pressure to less than 1750 psia and RCS average temperature to less than 5005 in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. These time requirements are consistent with the requirements of TS 3.0.3. In the event the equivalent of 100% ECCS subsystem flow is not available due to other conditions, TS 3.0.3 is entered. The end j
state for 3.5.2 is being changed to " reduce pressurizer pressure to less than 1750 psia and RCS average temperature to less than 500 F" for consistency with the Applicability n
for 3.5.2. This corrects an error in the current TS, in that the ACTION's end state does 2
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not exit the MODE of Applicability. Further, the end-state for TS 3.5.3 is being changed
. to HOT SHUTDOWN with one OPERABLE shutdown cooling train in operation.
Additionally, the current TS 3.5.2 and 3.5.3 Limiting Conditions for Operation (LCO) items "a" and "b" refer to the operability of HPSI pumps and LPSI pumps. In actuality, the LCO should refer to HPSI and LPSI trains as being required for operability, since item "c" requires only the suction flow path to be OPERABLE. This request changes the LCO to the correct terminology from pumps to trains. The Bases for the TS will provide a definition of trains. Where a HPSI train, a LPSI train and an OPERABLE suction flowpath (as specified in the LCO) is referenced, the term ECCS subsystem is
, retained and defined in the Bases.
The Bases contains a statement that below 350'F one OPERABLE ECCS subsystem is acceptable. This value is being changed to 500 F and the RCS pressure below 1750 psia. This change is administrative in nature as TS Amendment 34 changed the TS requirement for one ECCS subsystem from 350 F to 500*F. This change to the Bases
. to reflect the change in the TS requirement is thought to have been omitted from the
. Amendment 34 Bases change.
The Combustion Engineering Owners Group (CEOG) report CE NPSD-1041, " Joint Applications Report for High Pressure Safety Injection System Technical Specification i
Modifications," explores the proposed 7 day allowed outage time utilizing current probabilistic safety assessment (PSA) methodologies to address the changes in risk when compared to current TS time limitations.
This study of the risk factors that are impacted by extending the AOT for a single HPSI train from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to seven (7) days demonstrates a negligible to small increase in
- risk. In order to perform a more complete assessment of the overall change in risk, an accounting for avoided risks associated with reducing power and going to HOT SHUTDOWN must be considered. This " transition risk" is important in understanding the trade-off between shutting down the plant compared with restoring the HPSI train to operability while at power.
The results of this study concluded that the change in core damage frequency due to increasing the HPSI AOT from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to seven (7) days is insignificant. In addition, when transition risks are considered, it can be shown that there is insignificant change in plant risk by adding four (4) days to the HPSI AOT. Thus, it is the conclusion of the study that the overall plant impact is that of a negligible to small increase in risk.
Risk associated with plant operation in low pressure HOT STANDBY and HOT
. SHUTDOWN is less than at power since LOCA risks are decreased by an order of magnitude. Furthermore, at the lower MODES equipment recovery actions and use of f.
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i backup equipment to provide inventory control (e.g., low pressure safety injection pump)is more likely.
4 If the qualified MODE 4 end state is used rather than using MODE 5 as the end state, several risk-related factors will be avoided. In particular, if the shutdown cooling system can be operated without placing low temperature overpressure protection (LTOP) systems in operation, the risk of a loss of inventory event via LTOP interfaces is avoided. Additionally, the use of this end state rather than MODE 5 avoids the potential that other systems that do not have MODE 5 requirements will be deliberately or inadvertently placed in a degraded condition while repairs are being performed on the inoperable HPSI subsystems. These other systems include the steam generators.
Thus, MODE 4 provides the most resource rich plant state with heat removal available via the steam generators and shutdown cooling system.
This TS and Bases change is consistent with the guidelines of NUREG 1432, " Standard Technical Specifications - Combustion Engineering Plants."
i This proposed change adds a new Section 6.16," Configuration Risk Management Program"(CRMP) to the TS. The purpose of the CRMP is to ensure that a proceduralized Probabilistic Risk Assessment-informed process is in place that assesses the overall impact of plant maintenance (planned and unplanned) on plant risk. Implementation of the CRMP will enable appropriate actions to be taken or decisions to be made to minimize and control risk when performing on-line maintenance for Systems, Structures, and Components with a risk-informed Completion Time. TS
' 6.16 will be applicable to TS 3.5.2 for the HPSI subsystem because the Completion Time for TS 3.5.2 is a " risk-informed Completion Time."
, To ensure plant safety is maintained and monitored, Entergy will implement a Configuration Risk Management Program at Waterford 3, which is to be applicable to TS 3.5.2 for the HPSI subsystem.
1.
Purpose of CRMP The purpose of the Configuration Risk Management Program is to ensure that a proceduralized Probabilistic Risk Assessment (PRA)-informed process is in place that assesses the overall impact of plant maintenance (planned and unplanned) on plant risk. Implementation of the CRMP will enable appropriate actions to be taken or decisions to be made to minimize and control risk when performing on-line maintenance for Systems, Structures, and Components (SSCs) with a risk-informed Completion Time.
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Scope of CRMP l:
The scope of the SSCs included in the CRMP are all SSCs modeled in the plant PRA, in addition to all SSCs considered to be of High Safety Significance per the Maintenance Rule Regulatory Guide (Regulatory Guide 1.160, Rev. 2).
The CRMP includes the following components and key elements:
Components j
a.
Risk Assessment Tool i
b.
Tier 2 restrictions c.
Level 2 and Extemal Events d.
Decision Making Process e.
Associated Procedures Key Element 1. Implementation of CRMP l
The intent of the CRMP is to implement a(3) of the Maintenance Rule (10CFR50.65) with respect to on-line maintenance for risk-informed technical specifications, with the following additions / clarifications:
a.
The scope of SSCs to be included in the CRMP will be all SSCs modeled in the plant PRA, in addition to all SSCs considered to be l
of High Safety Significance per Regulatory Guide 1.160, Rev. 2.
b.
The CRMP assessment tool is PRA informed, and may be in the form of either a risk matrix, a risk monitor, an on-line assessment, or a direct PRA assessment.
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CRMP will be invoked as follows for:
Risk-informed inoperability: A risk assessment will be performed prior to entering the LCO Condition for preplanned activities. For unplanned entry into the LCO Condition, a risk assessment will be performed in an appropriate timeframe.
Additional SSC Inoperahility and/or Loss of Functionality:
When in the risk-informed Completion Time, if an additional high l
safety significant SSC becomes inoperable /non-functional, a risk assessment shall be performed in an appropriate timeframe.
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Any applicable Tier 2 commitments apply for planned maintenance only, but will be evaluated as part of the Tier 3 assessment for unplanned occurrences.
Key Element 2. Control & Use of the CRMP Assessment Tool a.
Plant modifications and procedure changes will be monitored, l
assessed, and dispositioned.
Evaluation of changes in plant configuration or PRA model e
features can be dispositioned by implementing PRA model changes or by the qualitative assessment of the impact of i
the changes on the CRMP assessment tool. This qualitative assessment recognizes that changes to the PRA take time to implement and that changes can be effectively compensated for without compromising the ability to make j
sound engineering judgments.
Limitations of the CRMP essessment tool are identified and understood for each specific Completion Time extension.
b.
Procedures exist for the control and application of CRMP assessment tools, including description of the process when outside the scope of the CRMP assessment tool.
Key Element 3. Level 1 Risk-informed Assessment The CRMP assessment tool is based on a Level 1, at power, internal events PRA model. The CRMP assessment may use any combination of quantitative and qualitative input. Quantitative assessments can include reference to a risk matrix, pre-existing calculations, or new PRA analyses.
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Quantitative assessments should be performed whenever necessary for sound decision-making.
l b.
When quantitative assessments are not necessary for sound decision making, qualitative assessments will be performed.
Qualitative assessments will consider applicable, existing insights from quantitative assessments previously performed.
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Key Element 4. Level 2 issues / External Events External events and Level 2 issues are treated qualitatively and/or quantitatively.
Guidance for implementing the CRMP is provided by plant procedures.
No Significant Hazards Consideration Determination The proposed change described above shall'oe 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 en accident previously evaluated?
Response
The High Pressure Safety injection System (HPSI)is part of the Emergency Core Cooling System subsystem. Inoperable HPSI components are not accident initiators in any accident previously evaluated. Therefore, this change does not involve an increase in the probability of any accident previously evaluated.
The HPSI system is primarily designed to mitigate the consequences of a Loss of Coolant Accident (LOCA). These proposed changes do not affect any of the
' assumptions used in the deterministic LOCA analyses. Hence the consequences of accidents previously evaluated do not change.
In order to fully evaluate the HPSI AOT extension, probabilistic safety assessment (PSA) methods were utilized. The results of these analyses show i
no significant increase in the core damage frequency. These analyses are detailed in report CE NPSD-1041, " Joint Applications Report for High Pressure Safety injection System Technical Specification Modifications," March,1998.
The Configuration Risk Management Program is an Administrative Program that assesses risk based on plant status. Adding the requirement to implement this program for Technical Specificahon 3.5.2 does not affect the probability or the consequences of an accident.
The proposed change allows a combination of equipment from redundant trains to be inoperable provided that at least the equivalent of a single ECCS 7
subsystem remains operable. Analyzed events are assumed to be initiated by the failure of plant structures, systems or components. Allowing equipment from redundant trains to constitute a single operable subsystem does not increase the probability that a failure leading to an analyzed event will occur. The ECCS components are passive until an actuation signalis generated. This change does not increase the failure probability of the ECCS components. This change reduces the plant's susceptibility to common cause failures. As such, the probability of occurrence for a previously analyzed accident are not significantly increased.
Therefore, the proposed change will not involve a 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 l
c.eate the possibility of a new or different type of accident from any accident previously evaluated?
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Response
The proposed change does not change the design or configuration of the plant.
No new equipment is being introduced, and installed equipment is not being operated in a new or different manner. There is no change being made to the parameters within which the plant is operated, and 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 l
being introduced. The proposed change will only provide the plant some flexibility in maintaining the minimum equipment required to be operable to perform the ECCS function while in this condition. The change does not alter assumptions made in the safety analysis and licensing basis. Therefore, the l
change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
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Will operation of the facility in accordance with this proposed change l
involve a significant reduction in a margin of safety?
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Response
The proposed changes do not affect the limiting conditions for operation or their bases used in the deterministic analysis to establish the margin of safety. PSA vvaluations were used to evaluate these changes. These evaluations demonstrate that the changes involve no significant increase in risk. These evaluations are detailed in report CE NPSD-1041. The margin of safety is established through equipment design, operating parameters, and the setpoints at which automatic actions are initiated. None of these are adversely impacted
- by the proposed change. Sufficient equipment remains available to actuate upon demand for the purpose of mitigating a transient event. The proposed change, wMch allows operation to continue for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with components inoperable in both ECCS subsystems, is acceptable based on the remaining ECCS components providing 100% of the required ECCS flow. The reduced potential for a self-induced plant transient resulting from unit shutdown required for a second inoperable ECCS train is minimized. Therefore, the change does not involve a significant reduction in the margin of safety, and is offset by minimizing the potential for a self induced plant transient.
Therefore, the proposed change will not involve a significant reduction in a margin of safety.
Safety and No Significant Hazards Consideration Determination Based on the above No Significant Hazards Consideration Determination, 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 Staff's final environmental statement.
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