ML20085D947

Application for Amend to License NPF-38,consisting of TS Change Request NPF-38-118,modifying SRs for ESFAS Subgroup Relays to Extend Test Frequency for ESFAS Initiation & Subgroup Relays to Once a Quarter & Once a Yr,Respectively

ML20085D947
Person / Time
Site:	Waterford
Issue date:	10/11/1991
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20085D950	List: ML20085D947 ML20085D952
References
W3F1-91-0428, W3F1-91-428, NUDOCS 9110170292
Download: ML20085D947 (8)

Text

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W3 F1 0-128 A4.05 QA October 11, 1991 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Subject : Waterford 3 SES Docket No. 50-382 hicense No. NPP-38 Technical Specification Change Request NPF-38-ll8 Gentlemen:

The attached amendment requests a change to the Waterford 3 Technical Specifientions that modifies surveillance testing requirements for the Engineered Safety Features Actuation Signal (ESFAS) subgroup relays, Under the proposed change, the test frequency for the ESFAS initiation and subgroup relays will be extended to once a quarter and once a year, respectively. CEN .103, ESPAS Subgroup llelay Test Interval Extension, has been recently submitted to the Commission by the Combustion Engineering Owners' Group to support this change. If this request is approved, Technical Specification Table >l.3-2, Engineered Safety Features Actuation System Instrumentation Surveillance Requirements, will be changed to reflect this extended frequency. Although submitted under a separate change request number, this is essentially a continuation of NPF-38-103, submitted October 16, 1989.

Please direct any questions or comments to Tim Gaudet on (501) 739-GGGG.

Very truly yours, Yna RPII/ DAR/ssf

>w Attachments: Affidavit NPF-38-ll8 cc: R.D. Martin, NRC Region IV D.L. Wigginton, NRC-NRR R.B. McGehee N.S. Reynolds NRC Resident luspectors Office Administrator Radiation Protection Division (State of Louisiana)

American Nuclear Insurers

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9110170292 011011 PDR ADOCK 05000382

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_ UNITED STATES OF AMERICA ' '

NUCLEAR REGULATORY COMMISSION

'In tine matter of ).

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- Entergy Operations, Incorporated )' Docket No. 50-382 Waterford 3 Steam Electric Station )

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• AFFIDAVIT.

LR.P. Barkhurst,- 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-38-118; 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. ,

TN 3 .gi y MUlkkwucb 4 R.P. Barkhurst -

Vice President Operations -Waterford 3  ;

STATE Ol' LOUISIANA -)

) ss PARISil.0F:ST CIIARLES ) ,

Subscribed and sworn to before me, a Notary Public in and for the Parish and

. State above named this wf' day of d2_Z /* _ ,1991.

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This requests an amer.ument to change Tahle 1,3-2 of the Waterford 3 Technical .

Specifications (TS), which addresses surveillance requireinents of Engineered

afety lintures Actuation System (ESPAS) Justrumantation. The chango will extend the surveillance frequency for the automated actuation logie fo" anfety injection, contahunent spray, containment isolation, main steam lino isolabu,  !

i safety injection System recirculation and emergency feedwater femn monthly to i quarterly for the initiation relays, and semi-annually for the subgroup actuation relays.

Fxis ting Specifications See Attachment A I

Proposed Speelfications See Attachment 11 ,

Description This change modifles the required period for nueveillance testing of the ESFAS automatic actuation logic, it extends the present inonthly surveillance frequency

, Identified in Table 4.3-2 for safety injection, containment spray, contaltunent isolation, main steaua lino isolation, safety injection recirculatie'a inul emergency feedwater to quarterly fw dl automatic actuation logie excluding the subgroup relays, and send-annually for the subgroup relnys. Likewise, changes are mudo to the footnotes to reflect this extended frequency.

Extending the surveillance period to quarterly for the actuation logic excluding the subgroup relays is an issuo separate from the survellhuico extension for the subgroup relays. In Waterford 3 Techuleal Speelfication Change llequest NPF-38-103 (W3P88-1849, October 10, 1980), Entergy Operations (then, Loulalana Power and Light) requested nr. extension of the surveillance periods for Iteactor Protective System and ESFAS lustrumentation excluding the subgroup relays. .

This request was based an information provided in CEN-327, "ItPS/ESPAS Extended Test Interval Evahmtion," which was submitted.by the Combustion '

Engineering (CE) Owners' Group to the NitC, who later approved this report.

l Entergy Operatians has received verbal confirmation that the Waterford 3 speelfic request has been approved. Addressed in CEN-327, yet omitted from request I NPF-38-103 was the surveillanco extension for the ESFAS actuation logic paths to ninety days. As stated in CEN-327, Section 5.0, "ltecommendations":

i For the ESPAS, it is recommended that the technical specifleations be i modified to change the surveillance test interval for the ESFAS l

actuation logic paths from 30 days to 90 days with sequential testing.

The affected components include the bistables, and bistablo relays, l the logie matrix relays or coincidence logie modules, actuation logic l circuits and manual netuation devices. The surveillance test interval .

for the process measurement sensors and the subgroup relays should l

remain as currently required in tius Tecl.nleal Speelfications.

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Theivfore, Entergy Operativen is re<piesting an extenulon from monthly to  ;

qtuirterly of the surveillanco frequency for the ESI'AS nutomatic netuation logie, '

, exchiding the subgroup netuation relays. As sech, tin.so components will bo identified separately in the TS table from the subgroup retnys with a quarterly ,

channel functional test frequency.

P Extension of the anhgroup actuation relay surveillances is a selmente issue. 4 These surveillances are dono on a staggered test Interval (l.o. , each surveillanco is on a train opposite to that tested in the previous surveillance). As such, it will take two months to test both subgroup relay trains under the present monthly 1 survellinnee frequency. Ily extending this frequency to once every six months, each relay will be tested, nunually. lustifiention to extetal these surveillance frequeneles la basett on the reliability of thosc rolays and the overtesting of other 1 pinut coniponents resulting f rom these survellinn is. Justifiention for this is Imsed on information contained hi CEN-103, "Est'AS Subgroup Test Interval Extension." This report huu been sulanitttui to the Commission to support such a t requeat . Ilused on the conclusions in this stinly, a twelve month relay test i interval (i.e. , a six month staggered survellhmco interval) is justified for each of f these relays.

> __ As an outcomo of the TS Improvement program, NitC sinff performed a comprehensive study of techulent upeelflention survelllance re<pdrements (as  !

recomm"nded in NUlt):01021, " Technical Speelfientions - Enhanelng the Safety l Impact . ") liesu;ts of this work were presented in NUlt EU 1360. This study examined ludividual typon of components for falhare history and the consequences ,

of teathig. This examination was based on threo of five reeammendations sieted in NUltEG 1021. Tirn.o are summnelzod as follows: ,

Iteconmusndation 1: l'requencies should be reviewed to assure they are adequately supported on a technical basis and risk to '

the public is minhnized.

It ecommenda t ion __2 : Surveillance tests should bo reviewed to assure safety equil nnent is not degraded as a result of testing.  ;

Testing should be performed in a safe tunnner, and in the approprinto MODI:.

Iteconunendation 1: Itequirements should be reviewed to assure no unnecessary consumi tlon of plant personnel timo or undue radiation exposure.

These led to four criterin hi NUltl:G 130'0 used to judge what surveillance requirements would be suitable for extension. These criterin were further  ;

developed in CEN-103 Section 1.2, l'SI'AS Subgroup 1(elay Test Interval Extension, to justify extending the subgroup relay testing interval.  ;

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" Criterlon 1 Extension of tho surveillance interval is warranted if a large disparity exists between the munber of tests being in rformed and the number of failures being revealed.

" Criterion 2 Extension of the surveillanco intervnt should not significantly incronse the unavailabl!!!y of n system to perform its safety function.

• Criterion 3 Extensloa of the surveillonee Interval may be warr, ited if it is enusing unnecessary wear to other plant equipment.

" Criterion 1 The surveillance should not lead to plant transients. ,

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m An exception to the application of this analysis to Waterford 3 is the discussion regarding the overtesting of the diesel generators and its relevaneo to Criterion

. 3. 'To minimite emergenoy diesel generator (EDG) starts, Untergy Operationn has recently been granted an tunendment to the Waterford 3 TSs to allow the combi.mtion of EDG operability testing with USl'AS testing such that surveillances can be performed concurrently, producing only one diesel generator start. This eliminated unumeessary starta that occurred when these surveillances wero performed individually. llegardless, Criterion 3 s:llt hm. Ihalted application since these ESFAS surveillances still result in unnecessary actuation of other safety related equipment auch as high pressure safety injection pumps. Although this may not be as harsh to the equipment as an EDG start can be, eyeling this equil unent can still result in unnecessary wear.

Criterion 1 requires the surveillance to detect the failures it is intended to, and do so within a reasonable ratio to the number of surveillances performed. This test does perform its function since, as shown in CFN-103, it detected twenty-five failed relays at CU plants. Ilowever, it took approxhuntely 157,000 relay tests to !dentify the twenty-five failures. This gives an average of one failed relay being discovered per 0280 tests. Normalized to a twelve month interval, a falluto would have been detected every 751 tests. Similarly, on an eighteen month interval, a failure would be detected every 500 tests. Consequently, such

! frequent testing is unnecessary. Given that the failure will be detected despite test interval sire, and the proven ineffectiven?ns of a shorter monthly interval, a twelvo month interval is warranted. An annual relay testing frequency satisfies Criterion 1.

Criterion 2 addresses system unavailability. Extendhig the surveillance frequency from monthly to semi-annually (meaning the relay tent frequency from bimonthly to annually) will increase the time a failed relay could go undetected by ten months. This could make the system potentially unavailable during this pe riod . Ilowever, an analysis of the failure history for tue CE plants in CEN-103 sufficiently addresses this concern. liased on this, a semi-annuni surveillance frequency (i.e. , au nimual relay test interval) satisfies the requirements of Criterion 2.

Criterlon 1 discusses plant transients or potential plant transients resulting from testing. Due to the serious consequences, it is undesirable to have any inadvertent ESFAS actuations. CEN-403 discusses three instances of plant transients or possible plant transients resulting from surveillance testing. These are as follows:

San Onofre Unit 2, January 10, 1981: The subgroup rehiy test resulted in a train A containment purge isolation signal. All containment purge ,

isolation system valves actuated, f Palo Verde Unit 2, March 25,1980: While in Mode 4, a main steam isolation system actuation occurred on both trains A and 11. This was attributed to a personnel error. During the subject surveillance test, the relay test switch was turned to the next selection before the previous relays were ,

reset. .

o Waterford 3, July 28,1989: While performing a subgroep relay test, it was discovered that the surveillanco could result in water hammer in the steam generator blowdown lines. The ESFAS test procedure was revised. .

Since reducing the testing (and therefore increasing the surveillance inte: val) will decrease the probability of plant transients, this satisfies the requirements of -

Criterion 4.

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. I As discussed in the CE reports, t.ho wear on plant equipment, the low fu81ure i rato, the little to no resulting lucreas9 in system unavailability, and a reduction

. In the potential for plant transients all warrant the extension of the surveillimeo intervals. Operating experience Ims demonstrated the present intervula to be excessively short. hengthening this surveillance test interval may slightly  ;

increase the probability of equljunent not automatically actuating when required, l but it will also decrease the number of eyeles of plant equiganent due to testing.

J Overall, reducing tho testing and therefore lucreasing the surveillance interval t

wlil decrease the probability of plant transients. .

Based on tho above arguments, Waterford 3 requests to ho allowed to test each l ESPAS subgroup relay on an inniual cyclo rather than the current bhnonthly cycle, i As previously na ntioned, Waterford 3 TSs were recently amended to allow the comblimtion of EDG operability testing with ESFAS testing such that surmillances i could bo performed concurrently, producing only uno diesel generator start. ,

Amendment G7 was issued to the technical speelfleations reumving the requirement [

for staggered test hitervals for thre9 relays while retalning their test frequenelen i

(see Footnoto 6 of Tablo 13-2, Attachment II). This was necessary duo to incompatibio frequenelen of the EDG and ESPAS tests. With a new, extended ,

period for the ESPAS relays, frequencies of the two tests are now compatible and coincident testing of the EDGs and the relays can be performed on a staggered t test basis. Therefore, this submittal also requests the deletion of the exclusion from the staggered test interval for relays Kilo, K110, and 10112 (l.c. , the .

removal of Footnoto O from Table 1.3-2, and the return of Footnote 1 to the channel functional test for the Safety injection [SIAS] automatic actuation logic. )

Safety Analysis The proposed changes described above shall be deemed to involvo a signifleant hazards consideration if thoro is a positive finding in any of the following aroan: ,

1. Will the operation of the facility in accorduneo with these proposed changes involve a significant :ncrease in the probability or consequence of any accident previously evaluated?  ;

lbsponse t - Ne ,

Combustion Engineering 'atmlyses show that a reduction in test frequency of these relays is expected to decrease the frequency of spurious actuations of emergency safety features equipment. While thero may be a small increase in unavailability due to relays falling durhig the longer surveillance interval, it is belloved to be negligiblo due to the high '

reliability of these relays. Furthermore, this will be offset by n larger decrease in the inadvertent actuation of equipment during testing. As l such, the overall result will be a reduction in the probability of plant t ransients. Reestablishing a staggered test interval for relays Kilo, Kilo and K'll2 will not affect this probability, at all. Therefore, the oleration of Waterford 3 in accordance with those changes will not increase the probability of any accident previously evaluated.

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The proposed changes do not involvo an Inerenso fu the consequences of ini -

necident prevlausly evnlu.ited no the uccident nimlysis assumes the most limiting single failure. The limiting singlo failuro assumod bounds tho ,

, failuro of these relays, Whatever the failure mode of the Imrticular typo of '

relay used, the consequences are neceptable. Thereforo, the operation of .

Watarford 3 in necordance with this chango will not involvo n significant inerenso In the probability or consequence of any neeldent previously  ;

ovninnted.

2. Will the operation of the facility in necordance with those proposed changes  !

create the possibility of a new or different kind of neeldent from any accident previously evaluated?

i Itosponso:- No Fallere moden for the initiation and subgroup relays remain unchanged by the extended test frequeneles and the reestablishment of staggered testing ,

. for the relays identified above. Potential consequences of failuro of one of  :

those relays,'regnedless of typo, are already considered h, the neeldent nualynou. Other than extension of test Intervals and the reestablishment of the stnggered tout requiretnant for somo relays, thero la no chango to plant -

proceduren or operation that coulu lead to such a new event. Failuro of n single relay may result in certahi 1:SFAS equipment fallhig to netunto, but .

due to the plant configuration, this will not affect more than one train. An s auch, operation of Waterford 3 in accordance with this change will not  :

evento the possibility of a new or different kind of neeldont from any acchtent previously evaluated. .

3. Will the operation of the facility hi necordance with these proposed changes involvo a significant reduction in the margin of safety?

Ilesponse: No The proposed changes will not affect the performanco of the sufoty function for the netuated equipment, Integrity of the fission product barrh,rs lu maintained by the netton of the actuated equipment. Sinco there is no inerenso in the consequonees of the ovents ugninst which this equipment protects, thoro la no chango in the margin of safety. Thoro are redundant .

trains of n!! ongineered sufoty features equipment, and thus redundant trains of all subgroup reh3 ys. Therefore, the shiglo failuro of any subgroap relay will not prevent the performance of the design sufoty function. The failure of two trains of redundant relays netuating the sumo equipment Ja not considered credible. Therefore, the operation of Waterford 3 in necordance with this change will not involve a significant reduction in the margin of safety.

Safety and Signifiennt llazards Dotermluntion llased on the above Safoty Analysis, it is concluded that: (1) the proposed -

change does not constituto a signifiennt hazneds consideration os defined by 10-CFR 50.02; and (?) thoro in a consonable 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 that signifleantly alters tho impnet of the station on the ouvironment as described in the NRC Final 1:nviro" mental Statement.

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N1'F 38-118 ATTACllMENT A l

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