ML20138L129
| ML20138L129 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/19/1997 |
| From: | Gaudet T ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-97-0021, W3F1-97-21, NUDOCS 9702210074 | |
| Download: ML20138L129 (6) | |
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E P.o ' Box B S
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o W3F1-97-0021 PA.05 PR l
February 19,1997 i
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington,' D.C. 20555 j
Subject:
Waterford 3 SES l
Docket No. 50-382 License No. NPF-38.
10 CFR 50 Appendix R Exemption Request Gentlemen:
i In accordance with 10 CFR 50.12(a)(2)(ii), Entergy is hereby requesting an exemption from verbatim compliance with Appendix R, Section Ill.O requirements.
An exemption is being requested to allow for not extending the Reactor Coolant Pump (RCP) oil collection system to include the remote' oil fill lines that were added in plant modifications. The specific requirement states in part that, "... Leakage points t
to be protected shall include lift pump and piping, overflow lines, lube oil cooler, gifill and drain lines and plugs, flanged connections on oil lines, and lube oil reservoirs where such features exist on the reactor coolant pumps."
Waterford 3 has an Oil Collecti.on System which serves the four Reactor Coolant Pumps. The Oil Collection System was designed and installed to comply with the above regulatory requirement. The system received NRC acceptance in SSER-8.
Subsequently, two phases of plant modifications (SM-1353 and DC-3318) were
[I initiated in 1986 and 1990 that installed remote RCP oil fill lines. Supported by evaluations performed at that time, the decision was made not to extend the permanent Oil Collection System to include the remote fill lines. These lines, which h')h,
. extend from outside the secondary shield ring wall (D-ring) in the containment building to the oil fill line connections on the RCPs, were installed to reduce dose to E
- workers who periodically add oil to the RCP lobe oil systems during power operation.
- The Engineering evaluation performed, prior to implementation of the modification, F
technically justified not providing an oil collection system for these lines. The 9702210074 970219 W
- PDR - ADOCK 05000382h F
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~ 10CFR50 Appendix R Exemption Request W3F1-97-0021 L
Page 2 February 19,1997 i.
evaluation determined that the modification met the intent of Appendix R. However, results of recent reviews by plant staff identified that, while the design meets the intent of Appendix R, Section Ill.0, it is not in verbatim compliance with Appendix R.
j Therefore, Entergy is hereby submitting the justification (attached) that was applied i
to the station modification (in 1986) and is requesting that an exemption be granted for the lack of an oil collection system for the remote oil fill line installations. The i
remote oil fill lines do not contain standing oil and are infrequently used on an as needed basis _. Addition of oilis administratively controlled via task cards and a g
procedure that controls the use of combustibles (FP-001-017). Therefore, the 2
exemption being requested meets the circumstances delineated in 10 CFR 50.12(a)(2)(ii), in that the application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule, if you have any questions or nquire additional information, please contact me at (504) 739-6666 or Oscar Pipkirjs at (504) 739-6707.
Very truly yours,
//
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T.J. Gaudet Acting '- Director Nuclear Safety & Regulatory Affairs TJG/ OPP /ssf Attachment cc:
L.J. Callan, NRC Region IV C.P. Patel, NRC-NRR R.B.- McGehee N.S.' Reynolds NRC Resident Inspectors Office a.
i Attrchm::nt to W3F1-97-0021 Page 1 of 4 ATTACHMENT JUSTIFICATION FOR EXEMPTION REQUEST How the Discrepancy was identified:
Following a fire at the Arkansas Nuclear One, Unit 1 (ANO) facility on October 17, l
1996, that facility was evaluating potential conditions of non-compliance with 4
Appendix R, Section Ill.O involving the Reactor Coolant Pump oil collection system.
i Recognizing the similarities of the oil collection systems at ANO and Waterford 3, the Engineering Staff at Waterford 3 under took a data acquisition and investigation effort to assure compliance at Waterford 3. During the course of that investigation, it was determined that there was a discrepancy with verbatim compliance with Appendix R, Section 111.0 at Waterford 3 associated with the modification that installed remote oil fill lines for the RCPs. It was further determined (based on earlier evaluations) that no operability or safety concerns exist as a result of not having oil collection facilities for the remote fill lines.
RCP Oil Collection and Remote Addition System Description
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j A Reactor Coolant Pump Oil Collection System is provided for each pump to direct lube oil from pressurized and unpressurized leakage sites such as lift pump and piping, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections in oillines and lube oil reservoirs to a collection tank. The RCP Oil Collection System is designed, engineered, and installed such that failure wil1 not lead to a fire during normal or design basis accident conditions and that the system will withstand a safe shutdown earthquake. The RCP Oil Collection System consists of oil drip pan enclosures mounted oa each reactor coolant pump motor. A gravity 1
drain piping system transports any accumulated oil from the drip pan enclosures to
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an oil collection tank. There are two 200 gallon oil collection tanks. One tank serves j
pumps RCP 1 A and RCP 1B. The other tank serves pump RCP 2A and RCP 28.
The tanks are located inside the reactor containment building outside the biological shield wall at EL. -4.00 ft msl. Each tank is vented and provided with a flame arrester. Each tank is furnished with a glass liquid level gauge to provide tocal indication of existence of oilin the tank. Each tank is capable of collecting oil from one RCP oillube System (195 gallons). SSER-8 contains NRC approval of an exemption from the Appendix R requirement associated with capacity of RCP oil collection tanks. Each RCP motor lube oil system has an alarm which will sound in the Control Room to alert operators if a significant amount of oil is lost from the lube oil reservoirs.
Attachment to W3F1-97-0021 I
Page 2 of 4
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i The oil collection system was installed in compliance with 10CFR50, Appendix R during original construction. Modifications or alterations to the system over the years have been conducted in accordance with plant configuration control proce'dures and have included appropriate Fire Protection safe shutdown evaluations completed by a qualified Fire Protection Engineer, i
In 1986 and 1990, Waterford 3 provided the RCPs with remote fill lines for the upper and lower oil reservoirs. This effort was completed under Station Modification SM-l 1353 (Phase I/ upper RCP reservoirs) and Design Change DC-3318 (Phase ll/ lower
. RCP reservoirs). The remote oil fill lines were not provided with oil collection equipment.' This decision was supported by justification provided in the modification packages in the Fire Protection / Safe Shutdown Evaluation. The station modification and design change provided a means to safely add oil to the upper and
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lower reservoirs on the Reactor Coolant Pump Motors from outside the D-ring during l
all modes of reactor operation. The modification consisted of routing 1 inch diameter stainless steel tubing from the existing fill connections on the motors up the ins!Je of l
the D-rings,' through the feedwater piping penetratior.s in the shield wall and terminated adjacent to an installed hand pump. The tubing is non-safety class and seismically supported. Flexible stainless steel hose was provided at the connection to the RCP motor to allow for thermal movement and vibration. Compression type i
tube fittings were used. A functional leak test was performed after installation using portable containers to check for leaks.
1 The existing RCP Oil Collection System will collect any leakage or overflow at the j
connection to the RCP Motor and route it to the applicable Oil Collection Tank located outside the D-Ring.
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Justification For Exemotion:
The following is an excerpt from the evaluation in SMP-1353, which constitutes the justification applied at that time (in 1986) and which remains valid today:
" Appendix R, Section ll.C provides the following general requirements (among others) for " fire prevention features" which, presumably, include the RCP oil collection system:
"C.
Fire prevention features. Fire protection features shall meet the following general requirements for all fire areas that contain or prese t a fire hazard to structures, systems, or components important to safety.
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i Attrchmsnt to W3F1-97-0021
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Page 3 of 4 4
i 1.
In situ fire hazards shall be identified and suitable protection
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provided.
j 2.
- Transient fire hazards associated with normal operation, maintenance, repair, or modification activities shall be identified i
and eliminated where possible. Those transient fire hazards that
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- cannot be eliminated shall be controlled and suitable protection provided."
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The fire hazard presented by the RCP lube oil fill lines proposed in SMP-1353 is clearly not from the lines themselves, but from the combustible lube oil which will occasionally be fed through these lines. Except for the duration of the fill activity, these lines will be empty during normal operation. This is 4
based on the following: a) the existing RCP oil reservoir configurations i
include overfill drain and vent lines situated below the entry points of the proposed fill lines; these overfill provisions route excess oil to the oil collection systems, and b) the proposed extension of the oil fill lines will be capped when not in use, such that no vent path will exist in the fill lines. This will cause any l
oil which might be forced from the reservoirs to flow out of the overfill provisions instead of flowing back up the tubing. It is Ebasco's position, l
therefore, that the fire hazard resulting from use of these lines will be a transient fire hazard associated with a maintenance activity, which is covered i
by the general requirements of item C.2 above. Although both C.1 and C.2 l.
contain the identical language regarding the provision of " suitable protection" for the type of fire hazard involved, it is Ebasco's interpretation that what constitutes " suitable protection" for a transient fire hazard need not be identical to that which shouid be provided for an in situ fire hazard. In other words, it would be consistent with the above general requirements to provide temporary fire protection measures for transient fire hazards and permanent fire protection measures for in situ fire hazards.
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Viewed in this context, the specific RCP Oil Collection System requirements of Appendix R, Section 111.0 should be considered as protection against the in l
situ fire hazard associated with RCP lube oil during normal operation.
Although Section Ill.O does specify that it applies to lube oil fill lines, Ebacco believes, based on the above rationale, that the intent of Section 111.0 is to protect against the insitu fire hazards, such as those posed by existing fill lines which normally hold oil, and that the transient fire hazard associated with the oil fill lines proposed in SMP-1353 does not call for the installation of i
additional permanent oil collection provisions. However, " suitable" (i.e.
i temporary) protection measures should be taken during the fill period.
Supplemental protection measures as well as administrative control measures
Attachm:nt to W3F1-97-0021 Page 4 of 4 to limit the quantity of transient combustibles to the amount which is required, are ccmmitted to in FSAR Section 9.5.1 (page Vill-221), are recommended in the SMP nuclear safety and fire protection evaluations, and would be consistent with the intent of Appendix R."
Administrative Controls:
Waterford 3 employs administrative controls to ensure that maintenance activities for adding oil maintain a suitable level of fire protection and to ensure that no new hazards are introduced. Among the administrative controls are conduct of oil addition under a Repetitive Task Work Authorization (WA), control of combustibles under procedure (FP-001-017), and draining any excess oil leakage from the RCP Oil Collection System storage tanks upon completion of the oil addition task. The collection tank is accessible during operation. Tank level monitoring allows for immediate determination if leakage has or is occurring and is an important feature of the system. During communications between the technician in the field and the control room, it is verified that a level increase change occurs in the reservoir. These J
controls provide assurance that the oil is reaching its intended destination.
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Conclusions:==
Based on the above discussed analysis and justification, Entergy concludes that there is no technical or safety need for the design and installation of an oil collection system for the RCP remote oil fill lines. Therefore it is requested that an exemption be granted for this specific departure from the requirements of Appendix R.
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