ML20029B398
| ML20029B398 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/05/1991 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-79116, W3F1-91-0003, W3F1-91-3, NUDOCS 9103070201 | |
| Download: ML20029B398 (4) | |
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Entergy r y y - ~.w.
Operations W3F1-01-0003 A4.05 QA March 5, 1991 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555
Subject:
Waterford 3 SES Docket No. 50-382 Licenso No. NPP-38 Technical Speelfication Change Itequest NPF-38-111 (TAC 70110)
Gentlemen t fly lotter W3P90-1182 dated November 9,1990. Entorgy operations, Inc.
proponed a licenso amendment to remove the Movable incore Detection System from the Technical Speelflentions for Waterford Steam Electric Station, Unit 3.
The proposal also removed requirements for over-current protectivo devices fa.' containment penetrations associated with the movablo incore detectora.
On December 7,1000, the Commission requestod additional luformation verifying that the disconnection of the drivt, machines, the sparing of the breaker and fuso for each electrical penetration and the alterations necessary for the elimination of the Movabio incore Detection System will not compromiso plant safety.
At the time of the origituti amendment request, these mod!fications woro in the developmental stage and po 'manent changes woro still under consideration.
Now that the details are behg finalized, the coquested information can be supplied.
The attached inft.rmation supplements the original submittal and supports the existing safety analysis which cortifies that those lasues do not represent a signifleant hazard, if there are any questions, please direct them to David Rothrock on (504) 730-0003.
Very truly yours, md'
- ~
R.F. Burski Director, Nuclear Safety RFB/DAR/ssf
Attachment:
Supplement to NPF-38-111 cc:
Messrs. H.D. Martin (NRC Region IV), D.L. Wigginton (NRC-NRR),
E.L. Blake, R.B. McGohoo MD' Resident inspectors Offico, Administrator Nuclear Energy Division (State of Loulslann), /.merican Nuclear Insurors
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9103070201 910305 l
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SUPPLEMENTAL IN1'OltMAT10N TO PltOPOSED CilANGE NPF 38-111 This Information is supplemental to that accompanying the request to remove the movable incoro detectors from the Waterford 3 Technical Specifications as documented in W3P90-1182.
This luformation does not change the conclusion of the original safety analysis that there Is no significant hazard associated with the submittal.
Dineussion By letter W3P90-1182 dated November 9,1990, Entergy Operations, Inc.
pro})osed an amendment removing both the movable incore detectors and the requirements for the associated containment ponetration devices from the Waterford 3 Technical Specifications.
In their preliminary review, the Commission identlfled certain aspects of the requested change and related modification that were not addressed in the original submittal.
This supplemental information responds to these concerns.
A modification, scheduled for the upcoming refueling outago, will permanently disabla the Movablo Incore Detection System.
As part of this effort, power will be disconnected from the detector drive machines, and the associated breakers and fusos will be spared.
At the power supplios, the cables will be disconnected from the load side of the fuses.
Those cables will then be relabelled as "sparo", coiled, and secured in the Motor Control Center cable trough.
Theso cables will not be disturbed at the penetration.
Inside containment, a length of each cable will be removed to isolate the drive machines from the penetrations.
With the power sourco removed, over-current inc! dents will not occur.
Plant configuration control (l.o., the design change process) ensures that any modifications to existing design and/or equipment receive the appropriate reviews and approvals.
This will include any future modifications to the cable penetrations that require an amendment to this technical specification.
Therefore, the electrical penetrations for those cables will remain protected and controlled.
As stated in W3P90-1182, a temporary alteration that removed a section of each gtuuc tube and capped. each calibration tube was performed to eliminato a potential leakage path.
These calibration tubes provido a path for the movable incore detectors to relocate throughout il 3 core.
The tubes are contained in the housing for the fixed incore detectors.
During the upcoming refueling outage, new fixed incoro detectorn are to be installed.
The calibration tubes of the now fixed detectors are scal-welded within the instrument heads.
There are no external projections from the instrument head for the calibration tubes; therefore, no external leak path exists.
Since this will eliminate the potential leakago path, the correction to the
. original problem becomes permanent.
This correction, ovaluated under the station modification. process and independent of the temporary alteration, will ascura long-term Integrity to the Reactor Coolant System.
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j As stated in the previous safety analysis, incore detector operability is not required for any accident.
Therefore, all accidents remain unaffected by the proposed change to the technical speelfications.
The modification associated with the change will not reduce the protection of the containment penetrations or the long-term integrity of the Reactor Coolant System, power sources will be removed from the cables preventing over-cur
- cut incidents at the penetrations, and potential Reactor Coolant System enkage j
paths (via the calibration tubes) will be eliminated.
As determined in the original safety analysis, the disconnection of the drive machines, the sparing of the breaker and fuse for each penetration, and the elimination of the calibration tubes will not increase the probability or consequence of any j
accidents previously evaluated.
As pointed out in the original nafety analysis, the deletion of the Movable incoro Detection System from the definition for " operable incore detector" requires any mapping to be performed by the Fixed Incore Detector System, i
This provides the same information and satisfies the existing technical i
specification.
As such, the protection affordeci by the hmiting condition for operation remains unchanged.
Over-current protection to the cablo containment penetration remaina assured.
Outside of containment, the cables will be disconnected at the load side of the fuses, removing the power source.
The cables will be relabelled as " spare", coiled and secured in the Motor Control Center cable trough.
The cables will not be diuturbeci at the penet ration, inside containment, a length of each enole will be removed to isolate the drive machines from the penetrations.
Future alterations to th!s equipment arrangement are regulated by the design control process.
l Therefore, the electrical penetrations for these cables will remain protected and controlled.
The modification replacing the fixed incore detectors chminates a potential Iteactor Coolant System leakage path.
These changes do not represent any new failure path.
As determined in the original safety analysis, the requested amendment and the related modification will not create the possibility of a new or different kind of accident from any accident previously evaluated.
As discussed above, the modif; cations necessary to disable.the Movable incore Detection System will not reduce any protection from over-current incidents at the containment penetration, iteactor-vessel integrity will not be jeopardized but enhanced by the mimination of a potential loakage path.
As determined in the safety analysis documented in W3P90-1182, these aspects of the modification and the amended technical specifications do not:
I a) affect any of the assumptions or results of the safety analyses, l
b) diminish the protection provided by the limiting condition for operation in the technical specifications, nor c) change the bases.
Consequently, the conclusion that there will be no reduction in the margin of safety is still valid.
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The above infortnation does not change the original conclusion that t (1) the proposed changes do not constitute a significant hazards consideration as defined by 10CFR50.92; (2) there is a reasonable assurance that the health and-sufety of the public will. tot be endangered by the proposed changes; and (3) this action will no'. result in a condition which significantly alters the impact of the station of the environinent as described in the NRC Final Environmental Statement, i
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