ML20080Q791

Safety Evaluation Supporting Amend 103 to License NPF-38

ML20080Q791
Person / Time
Site:	Waterford
Issue date:	03/02/1995
From:	Office of Nuclear Reactor Regulation
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ML20080Q783	List: ML20080Q781 ML20080Q791
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NUDOCS 9503090055
Download: ML20080Q791 (4)

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LSAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION:

a RELATED TO AMENDMENT NO.103 TO FACILITY OPERATING LICENSE NO.' NPF-38 K

'l ENTERGY OPERATIONS. INC.

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'2-WATERFORD STEAM ELECTRIC STATION. UNIT 3

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DOCKET NO. 50-382

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1.0 INTRODUCTION

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By application dated August 19,1994, as supplemented by letter dated October 14,' 1994, Entergy Operations, Inc. (the" licensee), submitted a request.

j for changes to the Waterford Steam Electric. Station, Unit 3, Technical E

u Specifications (TSs). The requested changes would. remove the Limiting Condition.For Operation (LCO) 3/4.3.4, the associated surveillance requirements, and Bases information from the TSs. This information and requirements will be incorporated into the Waterford 3; Updated FinaliSafety-l Analysis Report (UFSAR) and maintained under the. provisions of R

10 CFR 50.59.

The October 14, 1994, letter provided clarifying.information that did not change the initial proposed no -significant hazards consideration determination.

2.0 BACKGROUND

Section 182a of the Atomic Energy Act (the "Act") requires applicants:for.

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nuclear power plant operating licenses to state TSs to be included as part of.

the license. Such TSs are to. include "information of the amount, kind, and source of special nuclear. material required, the. place of the' use, and the specific characteristics of the facility,".from which the Commission can find that the facility's operation "will be in accord with the common defense and.

security and will provide. adequate protection to the health-and safety of the publ i c. " The Commission's regulatory requirements related to the content of ~

.TSs are set forth in_10 CFR 50.36. That regulation requires that the Tss include items'in five specific categories,-including (1) safety limits; limiting safety system settings and limiting control settings; (2) limiting (conditions for operation; (3) surveillance requirements;.(4) design features; and (5)-' administrative controls.. However, the regulation does:not specify the particular requirements to be included in a plant's TSs.

1 The Commission has provided guidance for the contents of TSs in its " Final '

Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (" Final Policy Statement"), 58 FR 39132 (July 22,1993), in which 1

the Commission indicated that compliance with the Final Policy Statement 4

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! satisfies-Section'182a of the Act.

In particular, the Commission indicated J

lthat.certain items could be relocated from the TSs to licensee-controlled

~ documents, consistent with the standard enunciated in Portland Genera?

Electric Co. (Trojan ~ Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979)._. In th'at'

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case,; the Atomic Safety.and Licensing Appeal Board indicated that " technical 4

specifications are to be reserved for those matters ~as to which the imposition j

of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event'giving rise to an immediate threat to the public health and safety."'

Consistent with this approach, the Final Policy Statement' identified four.

criteria to be used in determining whether an-LCO-is required to be. included

-in the TSs, as follows:- (1)-Installed instrumentation that is used to detect, and indicate'in the control room,' a 'significant abnormal degradation' of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a design basis accident

- or transient analysis that either assumes the failure of or presents a j

challenge to the integrity of a fission product barrier; (3) a-structure, system, or component that is part of the primary success path and which functions or actuates to. mitigate a design basis accident.or-transient that i

either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (4) a structure, system, or component which operating experienceorprobabilistjesafetyassessmenthasshowntobesignificantto public health and safety. 'As a result, existing TSs requirements which fall.

within or satisfy any of the criteria in the Final Policy Statement must be retained in the TSs, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other, licensee-controlled l

documents.

3.0 EVALUATION The licensee has proposed changes to TS 3/4.3.4 to remove the requirements related to the operability of the turbine overspeed controls, and related surveillance requirements.

In the mendment application, the' licensee i

committed to include this requirements in the Updated Safety Analysis Report (UFSAR).

The turbine is equipped with control valves and stop' valves which control turbine speed during normal plant operation and protect it from overspeed during abnormal conditions. The turbine overspeed protection system consists of separate mechanical and electrical sensing mechanisms which are capable of initiating fast closure of the steam valves. Currently, TS 3/4.3.4 requires particular operability and surveillance requirements for these steam control j

The Commission recently promulgated a proposed change to 550.36,

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pursuant to which the rule would be amended to codify and incorporate these criteria (59 FR 48180, September 20,1994). The Commission's Final Policy Statement specified that LCOs for Reactor Core Isolation Cooling, Isolation

' Condenser, Residual Heat Removal, Standby Liquid Control, and Recirculation Pump Trip are included in the TS under Criterion 4 (58 FR 39136).

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.and stop valves to minimize:the potential for fragment missiles that might be

- generated as the result of a turbine overspeed event. The licensee has proposed to relocate these provisions.to the.UFSAR such that-future changes to i

-the operation and surveillance of the turbine.overspeed features could be e

changed under 10 CFR 50.59.

Although the design basis accidents and transients include a variety of system j

failures and conditions which might result from turbine missiles striking-i various plant systems and equipment, the low likelihood of turbine missiles does not constitute a part of the primary success path to prevent or mitigate such design basis accidents and. transients. The system failures and plant W

conditions could be caused by other events as well as turbine failures.

a Similarly, the turbine overspeed control is not part of _an initial condition of a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Probabilistic safety assessments (PRA) and operating experience have demonstrated that proper maintenance of the turbine overspeed control valves is.important to minimize the potential for overspeed events and turbine

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damage; however that experience has also demonstrated that there is low likelihood of significant risk to public health and safety because of turbine overspeed events.

t The Waterford 3 turbine-generator placement and orientation is unfavorable l

with respect to the station. reactor buildings. This configuration places the reactor auxiliary building, control room, battery room, primary water condensate storage tanks, main steam lines, and intake cooling water structure, as well as the containment building, within the low trajectory i

missile (LTM) strike zone. However, there is no safety related equipment located inside the turbine building.

Westinghouse has recently reevaluated failure rates for turbine valves on BB-296 units with steam chests (Waterford 3 type turbines) based on valve reliability through May of 1994. The probability for turbine missile ejection (PI) at Waterford 3 was also calculated. The results show that for the maximum surveillance interval studied (6 months), P1 for Waterford 3 is much lower than the historical values assumed in the Waterford 3 and NRC studies used in the original licensing basis. The probability of damage to safety related equipment based on turbine manufacturer's failure data was determined to be acceptably low. The staff has reviewed the maintenance and failure histories of the turbine valves provided by the licensee and has concluded they do not conflict with the Westinghouse conclusions. The staff. has also reviewed the licensee's implementation of turbine vendor. recommendations related to overspeed and concluded that the recommendations are adequately.

evaluated and implemented as necessary to support the missile generation probability assumptions used in the analysis.

Further, the potential for and consequences of turbine overspeed events are diminished by the licensee's inservice inspection program, which must comply with 10 CFR 50.55(a), that includes provisions for basic surveillance requirements for the turbine control and stop valves in accordance with the manufacturer's recommendations. The licensee stated that the subject change request will have no negative impact on the periodic turbine generator i

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i inspections,. including inspections. and tests of-the main steam stop and.

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l control valves' and reheat stop and control valves.. Waterford 3 will. continue i to: implement these commitments with the soal of maximizing turbine generator j

reliability and efficiency.

Accordingly; the staff concluded that the requirements for turbine overspeed' l

controls _do not meet the:TS criteria in the Final Policy Statement. The limiting conditions for. operation and surveillance requirements for. turbine

- overspeed controls were; removed from the standard technical specifications.

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On this basis, the ' staff concludes that these requirements are not required to be in the TSs under 10 CFR 50.36 or Section'182a of the Atomic Energy Act;

' because they are not required to assure. adequate' protection of the public j

health and safety.

Further, they do not fall within any of the four criteria c

. set forth in the Commission's Final Policy Statement, discussed above.

In' addition, the NRC_ staff. finds that sufficient: regulatory controls exist' under 10 CFR 50.59.. Accordingly,.the staff has concluded that. these requirements 1

may be relocated from the TSs to the UFSAR. The NRC staff offers no objection' to the deletion of the Bases associated with TS 3/4.3.4.

4.0' STATE CONSULTATION In accordance with the Commission's regulations, the Louisiana State official was notified of the proposed issuance of the amendment. The StateLofficial had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a

.t facility component located within the restricted area as' defined in 10 CFR.

i Part 20 and changes surveillance requirements..The NRC staff has determined

~ that the amendment involves no significant increase in the amounts, and no-significant change in the types, of any effluents that may be released a

offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a pro-d posed finding that the amendment involves no significant hazards consideration n

and there has been no public comment on such finding (59 FR 45023)..

.j Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant tol10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared.in-connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered.by operation in the proposed manner, (2) such i

activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common i'

defense and security or to the health and safety of the public.

Principal Contributor:

C. P. Patel Date: March 2, 1995 i

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