ML20045H152
| ML20045H152 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/12/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20045H151 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 9307190135 | |
| Download: ML20045H152 (4) | |
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t SUPPLEMENTAL SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION CONFORMANCE TO REGULATORY GUIDE I.97
-l ENTERGY OPERATIONS. INC.
I WATERFORD STEAM ELECTRIC STATION. UNIT NO. 3 DOCKET NO. 50-382
1.0 INTRODUCTION
By letter dated July 6, 1983,-the licensee for Waterford Steam Electric
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Station, Unit. No 3 (Waterford'3), submitted a report on the implementation of Regulatory Guide (RG) 1.97, Revision 2.
The NRC staff's safety evaluation (SE) dated October 18, 1985, accepted the licensee's proposal for compliance with RG 1.97, Revision 2.
During the period August 20-24, 1990, Region IV conducted an inspection of the Waterford 3 facility to examine the licensee's implementation of RG 1.97.
Several deviations were found and documented in the inspection' report. dated September 19, 1990. The licensee responded to the deviations by letter dated October 18, 1990.
By letter dated February 28, 1991, the licensee changed its' commitment from RG 1.97, Revision 2, to Revision 3 and submitted information regarding the implementation of RG 1.97, Revision 3.
l 2.0 EVALUATION The staff has reviewed the licensee's submittals and has concluded that the licensee either conforms to, or is justified in deviating from, the guidance of RG 1.97, Revision 3, for each post-accident monitoring variable.
The staff also concluded that the licensee's commitment changes described below are l
acceptable:
a) Regulatory Position 1.4 of RG 1.97, Revision 2, states that Type A, B, and C instruments designated as Categories 1 or 2 should be specifically identified with a common designation on the control panels so that the operator can easily discern that they are intended for use under accident conditions.
During the August 20-24, 1990, inspection the NRC inspectors performed a walkdown of the simulator and control room to verify that the Types A, B, and C Categories 1 and 2 instrument displays.
were properly identified. The inspectors found that the appropriate instruments were not properly designated. The failure to fulfill p$hO l2 P
the comitment to comply with the RG 1.97 provision for specifically identifying the appropriate instruments was considered to be a deviation.
In responding to the staff's inspection report, the licensee described the Post Accident Monitoring Equipment labelling Program (Orange Dot Program) to uniquely identify appropriate instrumentation. The staff has reviewed the licensee's identification program and has found it to be acceptable.
b)
RG 1.97, Revisions 2 and 3, recomend Category 1. neutron flux monitoring instrumentation with a range of IE-6 to 100 percent full power. The licensee's submittal for compliance with RG 1.97, Revision 2, specified four qualified neutron monitoring devices with a range of IE-8 to 200 percent full power.
The August 20-24, 1990, NRC inspection found only two qualified channels with a range of 2E-8 to 200 percent full power.
By letter dated October 18, 1990, the licensee indicated that the original submittal was incorrect in specifying four qualified neutron flux channels. The subsequent submittal for compliance with RG 1.97, Revision 3, specifies two qualified neutron flux channels with range IE-8 to 100 percent full power. These instruments meet the recommendations of RG 1.97, Revision 3, and are, therefore, acceptable.
c)
RG 1.97, Revisions 2 and 3, recommend the use of Category 3 reactor coolant system (RCS) soluble boron concentration monitoring instruments with a range of 0 to 6000 ppm. The licensee's submittal for compliance with RG 1.97, Revision 2, specified RCS soluble boron concentration monitoring capability from 10 to 5000 ppm rather than the recommended 0 to 6000 ppm. The staff's SE stated that the licensee's justification was that the maximum boron concentration would not exceed 2300 ppm for the most demanding operating mode.
The SE further indicated that the review would be addressed as part of NUREG-0737 Item II.B.3.
However, the resolution of NUREG-0737, Item II.B.3, for Waterford 3 did not address this issue.
The licensee's submittal for compliance with RG 1.97, Revision 3, states that the new range for RCS soluble boron concentration monitoring is 0 to 5000 ppm. The licensee has provided an analysis showing that the boron concentration measured by the boronometer 1
will remain significantly lower than 5000 ppm during accident and 1
post-accident conditions.
The staff has reviewed this analysis and has found that the licensee's RCS soluble boron concentration monitoring capability meets the intent of RG 1.97, Revision 3, and is, therefore, acceptable.
d)
RG 1.97, Revision 2, recommends the use of Category 1 RCS cold-leg water temperature instrumentation with a range of 50 to 750 degrees F.
The licensee's submittal for compliance with RG 1.97, Revision 2, identified four qualified RCS cold-leg temperature 1
4 instruments with the recommended ranges. The submittal also included information concerning additional qualified cold-leg temperature instruments with a range of 0 to 600 degrees F.
The NRC inspection of August 20-24, 1990, found that these additional instrumentation channels were not properly qualified. By letter dated October 18, 1990, the licensee stated that the original submittal was in error in including the additional instrumentation channels as meeting the requirements of RG 1.97, Revision 2.
The licensee stated that the four qualified RCS cold-leg temperature instruments with a range of 50 to 750 degrees F were-sufficient to satisfy the guidance of RG 1.97, Revision 2.
The staff has reviewed the licensee's RCS cold-leg water temperature instrumentation and found it to be in compliance with RG 1.97, Revision 3 e)
RG 1.97, Revision 2, recommends the use of Category 1 RCS pressure instrumentation with a range of 0 to 4000 psig. The RCS pressure indication can be selected by the operator to be displayed on the qualified safety parameter display system (QSPDS).
That the pressure is not continuously displayed was determined by the NRC inspectors to be a deviation.
By letter dated October 18, 1990, the licensee stated that if the QSPDS screen displaying RCS_ pressure is selected, the RCS pressure will be continuously updated requiring no further operator action.
The staff agrees with the licensee's justification and finds the implementation of the QSPDS for continuous monitoring.of RCS pressure to be in compliance with RG 1.97, Revision 3.
i f) The licensee's submittal for compliance with RG 1.97, Revision 2, specified an instrument range for containment sump level wide range of 0 to 20 ft. During the August 20-24, 1990, inspection the NRC inspectors found the actual sump level wide-range indication to be O to 16 ft.
By letter dated October 18, 1990, the licensee stated that an analysis has shown that, during a loss-of-coolant accident, the containment sump level will not exceed 16 ft, and, therefore, the range of 0 to 16 ft is acceptable.
The staff has found the licensee's justification for containment sump level wide range to be acceptable and in compliance with RG 1.97, Revision 3.
g)
RG 1.97, Revision 2, recommends Category 1 steam generator level instrumentation with a range from tube sheet to separators.
The licensee's submittal for compliance with RG 1.97, Revision 2, indicated the existence of four wide-range level instruments per steam generator. During the August 20-24, 1990, inspection the NRC inspectors found only two wide-range level instruments per steam generator.
By letter dated October 18, 1990, the licensee stated that the original submittal was incorrect in specifying four separate channels. The licensee stated that the actual configuration of two wide-range level instruments per steam
' generator should have been specified.
The staff has reviewed the licensee's steam generator wide-range level instrumentation and found it to be in compliance with RG 1.97, Revision 3.
3.0 CONCLUSION
Based on our review of the licensee's submittals, we find that the Waterford 3 design is either in conformance with, or justified in deviating from, the guidance of RG 1.97, Revision 3, for each post-accident monitoring variable.
Principal Contributor:
H. Rathbun Date:
July 12, 1993 l
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