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Docket No.: 50-382 MEMORANDUM FOR: Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation FROM:
Harry Road, Project Manager Licensing Branch No. 3, DL Victor Nerses, Project Manager Licensing Branch No. 3, DL
SUBJECT:
EVALUATION OF WATERFORD 3 OPERATIONAL READINESS Per your request, we attended the Waterford Operational Readiness meeting at the plant site on May 21 and 22, 1984 At the meeting we discussed with the applicant about 40 issues that we have found to be of concern in our experience as Project Managers for the staff review of several CE plants, i.e., St. Lucie 1 and 2, San Onofre 2 and 3, and Calvert Cliffs 2.
The following is, a sumary of those issues discussed at the meeting that we believe to be relevant to operational readiness at Waterford 3.
1.
REACTOR TRIP BREAKERS - Waterford has the standard CE RPS design using eight GE AK2-25 reactor trip breakers. Surveillance testing of the under-.
voltage coils was conducted by LP&L for the first time on May 9, 1984 They used the procedures and trip time acceptance criteria that had been developed at San Onofre 2 and 3.
Two of the Waterford RTBs failed to meet the UV coil trip time acceptance criterion of 80 msec. One RTB tripped at 840 msec. and one failed to trip. Following maintenance (lubrication with WD-40, etc.) the two breakers performed satisfactorily. LP&L stated that under present staff reporting requirements, such failures are not reportable.
2.
AFW TURBINE OVERSPEED PROTECTION DEVICE - Waterford appears to have the same type of mechanical overspeed protection device as San Onofre 2 and 3 on the Terrf turbine used to drive one AFW pump. The overspeed device consists of a latching mechanism and a collar that fits around the valve stem of the normally closed stop valve in the steam line that feeds the turbine. This stop valve opens on an emergency feedwater actuation signal, but the collar will prevent the valve from remaining open if it is in the tripped position.
The latching mechanism requires local manual reset after a trip. At San blAWVoll fff s
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Onofre 3 on October 31, 1983, the steam driven AFW pump ' failed to open on demand due to the collar on this valve steam being in the tripped position, unbeknownst to the plant operators'. The valve position is indicated in the San Onofre control room, and there is also indication in the control room when the overspeed protection system goes into trip. However, if the trip is reset and the latch / collar is not reset locally, there is no way the operators can tell from the control room that the Terry turbine is inoperable prior to its failure on demand. The San Onofre licensee has never determined whether the October 31, 1983 event resulted from failure to reset af ter a trip or from inadvertent unlatching of the mechanism for some other reason.
As a fix, the San Onofre licensee visually inspects the overspeed protection device once per shift to verify that is is not tripped. Waterford appears to be susceptible to this problem.
Perhaps other Terry turbines are also susceptible.
3.
T0XIC GAS ISOLATION SYSTEM - The Waterford broad-range hydrocarbon detector will be 'used to isolate the control room in the event of hazardous concentration of any of several toxic gasses. The detector is not required to be operable until the first refueling. The probability of a toxic gas release in the vicinity of Waterford is higher than at most other nuclear plants due to the presence of several chemical plants nearby. There are measures in effect that partially compensate for the lack of automatic toxic gas isolation capability for the first cycle. Specifically, the St. Charles Parish Emergency Preparedness / Industrial Hotline is in frequent use due to the high frecuency of chemical spills, etc. in the plant vicinity..If a hazardous release occurs, the control room can be isolated manually if the operators are notified over the Hotline. However, other nuclear plants have broad-range detectors in operation and have had them in operation for some time, although these detectors may not be as complex devices as the Waterford broad-range detector.
It is our opinion that the staff should consider one or more of the following as an alternative to simply waiving all regulatory requirements for broad-range detection until the end o# the first cycle of operation (18 to 24 months from now).
We could require that the broad-range detector be operable before exceeding 5% power, or at some other time before the first refueling. We might consider allowing, initially, the use of higher setpoints than we ultimately hope to see in use. We might consider requiring isolation on some but not all of the toxic hydrocarbons that will eventually be required. We under-stand that the Waterford broad-range detector has been operated, but that it is prone to outages and spurious isolations. We note that spurious isolations are a. nuisance, but are not a safety hazard. San Onofre, for example, averages one or two spuricus control room isolations per week, most of which are due to the chlorine and ammonia detectors rather than the broad-range hydrocarbon detector.
I'n addition, we probably should develop a better regulatory basis for deferring full operability of the TGIS. Specifically, what regulations, SRP sections, and Regulatory Guides will be met in the interim before full operability? Is an exemption from the regulations required for the interim period?
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BASEMATE CRACXING - Since the NRR staff is actively persuing this issue we have no recommendations except to note this as an item requiring resolution.
5.
EMERGENCY SHUTDOWN PANEL - Same comment as 4., above.
6.
PLANT OPERATING, MAINTENANCE, AND SURVEILLANCE PROCEDURES - Same comment as 4., above. Region IV is conducting the review of procedures.
7.
FUEL FAILURES / CONTAINMENT PURGE - We note that Waterford has no 8" mini-purge system, only a 48" diameter purge system which is limited by the Tech.
Specs. to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> of operation per year.
If the Waterford fuel experiences the same failure rate as the San Onofre 3 fuel, and if the Waterford RCS activity escapes into containment at the same rate, Waterford may be faced with the need to purge more than 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year. We conclude this based on the San Onofre 3 experience, where the licensee recently requested and was' allowed to use their mini-purge system 3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br /> per year rather than the original limit of 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> per year (1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> per year for the mini-purge system approximately corresponds to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year for the 48" purge system). We questioned LP&L on this subject, and they stated that they did not anticipate a problem because they intended to keep RCS leakage to a very low level.
8.
VALVE LINEUPS / WATER HAMMER - Because u* recent instances of improper valve lineups at several operati g plants we discussed this issue with the Waterford Plant Manager and key operating personnel. They appea' red to be well aware of this potential problem, as Waterford has experienced two water hammer events in the steam generator blowdown system in the last week. The events were attributed to improper valve lineup and/or operator error. LP&L fndicated that they were addressing the issue by emphas' zing it during operator traning and by administrative controls, i.e., gooo procedures.
9.
PLANT SECURITY - LP&L has subdivided the plant into more than 30 vital areas, and the security computer is programmed to keep track of about 20 categories of plant staff / contractor personnel.
Each category has access to a different set of vital areas depending on their work assignments. We questioned LP&L regarding the impact of the security system on operator access to the plant during a fire or other emergency.
They assured us that emergency access could be obtained on a timely basis if required. However, we note that this plant has been compartmentalized to a greater extent than most other plants, and it appears that no one on the NRC staff has evaluated the emergency access provisions to verify that plant safety would not be compromised by the security program.
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- 10. TECHNICAL SPECIFICATIONS - We discussed the process used by LP&L to generate the information needed for the Technical Specifications, and reviewed a few selected Tech. Specs. with LP&L operations personnel.
It appeared to us that the process used should result in a better-than-average set of Tech. Specs., primarily because of the continuing involvement of operations personnel and the extensive review process that was used.
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Harry Road, Project Manager Licensing Branch No. 3 Division of Licensing N
Victor Nerses, Project Manger Licensing Branch No. 3 Division of Licensing 4
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