ML20198L978
| ML20198L978 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/29/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-98-0193, W3F1-98-193, NUDOCS 9901050191 | |
| Download: ML20198L978 (5) | |
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Ent y per tions. Inc.
Killona, LA 70066 Tel 504 739 6242 i.
Early C. Ewing, lit ety & Regulatory Affairs W3F1-98-0193 L
A4.05 L
PR J
~ December 29,1998 U.S. Nuclear Regulatory Commission ATTN: Doc.ument Control Desk
~ Washington, D C. 20555
Subject:
- Waterford 3 SES i
Docket No. 50-382 License No. NPF-38 L
Performance improvement Plan Action item Completion Due Date Changes Gentlemen:
The purpose of this letter is to provide the NRC with changes to the docketed conipletion due dates for three Performance Improvement Plan (PIP) action items.
p The proposed change to the Broad Range Toxic Gas Monitor, PIP item No. 4.B.41, completion due date was discussed with the Waterford 3 NRR Project Manager on L
December 3,1998. Attached is a summary of these three changes and their
- associated justifications.
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- The management team at Waterford 3 remains committed to improving our
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regulatory performance. Management believes that improvements continue to be
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achieved as a result of the PIP program and is committed to complete the action i
items identified. Our goal is sustained superior performance at Waterford 3.
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c 0h 9901050191 981229 T 0
PDR.. ADOCK 05000382, p
PDR R 006029.
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I Performance improvement Plan Action item Completion Due Date Changes W3F1-98-0193 Page 2 December 29,1998 If you have any questions concerning the above information, please contact me at (504) 739-6242 or Everett Perkins at (504) 739-6379.
Very truly yours, w
E.C. Ewing Director Nuclear Safety & Regulatory Affairs ECE/RLW/ssf cc:
E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR J. Smith N.S. Reynolds NRC Resident inspectors Office u
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Attachmtnt to W3F1-98-0193 Page 1 of 3 l
PERFORMANCE IMPROVEMENT PLAN (PIP)
COMPLETION DUE DATE CHANGES PlP ltem No.: 4.B.35 (Commitment No. A-24163)
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Description:==
Implement modification (DC-3517) to change the valve operator / power supply on MS-407, Emergency Feedwater (EFW) turbine steam line emergency drain valve, to direct current (DC).
Change:
Close out this item.
Justification: This item was initiated to ensure operation of MS-407, EFW pump turbine (EFWPT) steam supply drip pot normal drain bypass valve, during a station blackout (SBO) event. To ensure valve operation the motor operator power supply would be changed from an AC to a DC power supply. MS-407 is an alternate condensate drain path from the drip pot to the main condenser. During normal EFWPT standby operation, this valve is normally closed, but will open and allow excess condensate to flow from the EFWPT steam supply line during periods of high cot,Jensation.
Further evaluation of the need for this change determined that if MS-407 was unable to open and drain off condensate from the steam supply line, other installed methods would be available to prevent standing water in the piping. These installed methods consist of: heat tracing, which is required to maintain the EFW average steam supply piping temperature above 350 F, thus reducing the initial flow of condensate during turbine start; and steam traps and low point drains, which collect the initial flow of condensate on turbine startup, remove condensate formed during turbine operation, thus minimizing moisture carryover to the turbine.
It was also analyzed that with heat tracing in service, operation of MS-407 would not be required to prevent turbine overspeed. A calculation was also performed that determined MS-407 was not required to open when EFW pump was needed to perform its safety function. Therefore, the original intent of this item to ensure operation of MS-407 during a SBO by changing the motor operator power supply to a DC power supply is no longer required. This item is considered no longer necessary.
However, it was recognized that even though MS-407 was not required to operate during a SBO event, excess condensate draining and reliability of the EFW system could be enhanced with l
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Att:chmsnt to W3F1-98-0193 Page 2 of 3 early operation of MS-407. The existing MS-407 motor operated valve will be replaced under design change DC-3517 with a fail-open air operated valve. This valve changeout will improve valve opening time and removal of condensate in the first 10 seconds following a turbine startup. In addition, the steam trap and main condenser drain piping will be reconfigured to reduce the drain loop height to allow gravity draining of drip pot durinc EFWPT standby operation.
P!P ltem No.: 4.B.41 (Commitment No. A-24169)
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Description:==
Implement modification (PC-8020) to replace Broad Range Toxic Gas Monitor.
Change:
Move due date from fourth quarter 1998 to the end of the second quarter 1999.
Justification:
Completion of this item has been delayed due to several reasons:
(1) Continued problems in resolving hardware and software items with the vendor. These problems are being satisfactorily resolved and should be completed by the end of December 1998.
(2) The performance of additional calculations and extensive safety evaluations delayed the licensing re-submittal to the NRC. The license amendment, associated with this modification, was requested to be issued mid-to-late January 1999 to support the post RFr> ccheduled installation in the second quarter 1999.
(3) Resource ilmitations are being placed on modification installation due to the upcoming RF9 outage. Insufficient time exists prior to commencement of RF9, scheduled February 19,1999, to satisfactorily install and perform post testing on the modification.
The delay of this modification to the end of the second quarter 1999 will not adversely impact the safe operation of Waterford 3.
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Attschm::nt to W3F1-98-0193 i
Page 3 of 3 i
PIP ltem No.: 4.B.42 (Commitment No. A-24170) l
==
Description:==
Implement modification to provide Component Cooling Water design pressure re-rate.
Change:
Move due date from RF9 to RF10.
Justification: This PIP item was initiated to increase the pressure margin between normal system operating pressure and the relief valve lifting setpoints for the entire CCW system below the +21 Ft Elev. The need for increasing this pressure margin was created when hydraulic pressure transients, that occurred during surveillance testing, caused pressure surges that periodically lifted these relief valves. PIP action item 4.B.44 (DC-3493) was generated to address the CCW hydraulic pressure transients. Modification DC-3493 is planned for the upcoming RF9 outage that mey result in surveillance test generated hydraulic transients being reduced below the existing system design pressures. If this modification is successful, its associated PIP item 4.B.44 would be completed and PIP item 4.B.42 could also be closed-out as no longer necessary.
The need for replacing relief valves and re-rating the CCW system below the +21 Ft Elev. would not be required. If modification DC-3493 is not completely successful, other engineering measures will be undertaken to reduce these hydraulic pressure transients under PIP item 4.B.44 during RF10.
Therefore, the significance of not installing the re-rate modification during RF9 is mitigated by the implementation of the hydraulic transient modification and the delay of PIP item 4.B.42 to RF10 will not adversely impact the safe operation of Waterford 3.
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