ML20236M138

Recommends That Region IV Pursue Appropriate Enforcement Action Re Waterford 3 Interpretation of Surveillance Requirement 4.6.2.2 for Containment Air Coolers.Tsb Concludes That Plant in Violation of LCO 3.6.2.2

ML20236M138
Person / Time
Site:	Waterford
Issue date:	01/14/1997
From:	Charemagne Grimes NRC (Affiliation Not Assigned)
To:	Beckner W NRC (Affiliation Not Assigned)
Shared Package
ML20236J990	List: IA-98-155, Responds to 980513 Request from Duquesne Light Co to Provide Written Interpretation of Beaver Valley Power Station,Unit 1 & 2 TSs Requirements for Channel Calibration of Rtds & Thermocouples IR 05000482/1991021 ML20236J987 ML20236K746 ML20236K751 ML20236K780 ML20236K784 ML20236K803 ML20236K816 ML20236K840 ML20236K853 ML20236K883 ML20236K902 ML20236K916 ML20236K936 ML20236K963 ML20236L549 ML20236L558 ML20236L563 ML20236L580 ML20236L584 ML20236L590 ML20236L597 ML20236L653 ML20236L921 ML20236L955 ML20236L971 ML20236M014 ML20236M020 ML20236M034 ML20236M057 ML20236M117 ML20236M138 ML20236M148 ML20236M911 ML20236M924 ML20236M966 ML20236M983 ML20236M996 ML20236N007 ML20236N047 ML20236N052 ML20236N066 ML20236N221 ML20236N240 ML20236N257 ML20236N271 ML20236N288 ML20236N323 ML20236N333 ... further results
References
FOIA-98-155 TAC-M96485, NUDOCS 9807130310
Download: ML20236M138 (4)

Text

_ __ , , - - , - - , - - - - , - - _ - - - - _ _ - - - - - - - - - - - - - , - - - - - - - - - - - - - - - - - - - - - - - - , , - - - - - - - - - - - - - , - - - - - - - - - , - - - - - - - - - , - - - - -

i ,

pm%

I p 4 UNITED STATES l

, s*

] NUCLEAR REGULATORY COMMISSION wAsmworou. o.c. sness.am

%g January 14, 1997 MEMORANDUM TO: William D. Beckner, Director Project Directorate IV-1 Division of Reactor Projects III/IV, NRR FRON: Christopher I. Grimes, Chief Technical Specifications Branch Associate Director for Projects, NRR

SUBJECT:

WATERFORD 3 INTERPRETATION OF SURVEILLANCE REQUIREMENT 1 4.6.2.2 FOR THE CONTAINMENT AIR COOLERS (96 TIA 004, TAC NO. M96485)

In August 1996, a licensee self-assessment team identified a concern with an October 1995 performance of TS SR 4.6.2.2.b.2. The team identified that during a design basis component cooling water (CCW) flow test through the containment fan coolers, the CCW flow was less than the 1325 gpm specified in SR 4.6.2.2.b.2. Following the degraded flow indications in October 1995, the licensee performed an operability evaluation that demonstrated that an 1100 gpm CCW flow through a containment fan cooler could still remove the required containment heat load. The licensee operated the plant in this condition until they cleaned the coolers in January 1996, at which time they performed additional CCW flow tests which determined that the flows had improved to a point that one cooler on each train had at least 1325 gpm of flow.

l After the discovery by the assessment team, the licensee performed a reassessment of the flows and concluded that the coolers remained operable, even though it did not appear that the TS SR value had been obtained. The basis for the licensee's operability conclusion was that the flow value j provided in TS SR 4.6.2.2.b.2 is not the required flow with the CCW aligned in l the accident response mode, but was intended to be an indication that the control valve for the cooler was fully opened in response to an SIAS. The licensee also indicated that the 1325 gpm was most likely a design assumption for analysis and not intended as a minimum flow requirement through the containment fan coolers.

Region IV requested in a September 6, 1996, memorandum from J. E. Dyer to W.

D. Beckner an interpretation of the intent of TS 4.6.2.2.b.2. In particular, the Region asked whether the SR flow value was intended as a means of verifying that the required flows could be obtained with the CCW operating in  :

the accident response mode or as a means of verifying that the flow control valve for the coolers is fully open and would be capable of passing at least 1325 gpe. The Region also stated that the surveillance test that the licensee has been performing confirmed that the flow path realigned and would pass at CONTACT: R. J. Giardina, TSB 415-3152

~

9907130310 980624 PDR FOIA UNNERST98-155 PDR

. W. D. Beckner January 14, 1997 least 1325 gps, but the inspectors could not confirm whether the CCW could deliver that flow with all other accident loads aligned (i.e., a flow balance issue).

TSB concludes that Waterford Unit 3 was in violation of LCO 3.6.2.2 from October 1995 when Mode 4 was entered until at least January 1996 when the cleaned coolers were ratested and at least one cooler in each train satisfied the minimum flow requirement specified in SR 4.6.2.2.b.2.

Inspection Manual, Part 9900 " Resolution of Degraded and Nonconforming Conditions" provides guidelines for the review of licensee's operability determinations. In Section 4.2 of Part 9900, " Operable / Operability: Ensuring the Functional Capability of a System or Component," it should be clear that systems, structures and componants (SSCs) which do not meet specified acceptance criteria for surveillance requirements should immedi:tely be declared inoperable. In addition, successful su:veillance:; at the specified intervals, including an initial surveillance prior to first entry into a MODE in which OPERABILITY is required have been inc'iuded in many TS as a requirement for declaring SSCs to be OPERABLE (improved STS SR 3.0.1, SR 3.0.3 and SR 3.0.4). Waterford has these requirements specified in the Bases for TS 4.0.3 and 4.0.4.

There is no evidence that TS 4.6.2.2.b.? was intended only to verify or indicate that the control valve for the cooler is fully opened in a response to an SIAS; that capability is verified by TS 4.6.2.2.b.1 which demonstrates I the system starts automatically on an SIAS test signal. Even though the i Waterford TS Bases for LCO 3/4.6.2 is vague on the intent of TS 4.6.2.2.b.2, l it is clear that the Waterford design flow rate of 1350 gpm specified in FSAR Table 6.2-21 has been adjusted to 1325 gpm for each cooling train to account for instrument uncertainties as described in Attachment 4 to the TIA.

The purpose ' the sevaillance is also clear in the CE improved STS Bases ,

(NUREG-1432) for SR 3.6.6.3, which explains that verifying a flow rate greater i than or equal to a specific value to each cooling unit provides assurance that l the design flow rate assumed in the safety analysis will be achieved. I Finally, the operability evaluation performed by the licensee may provide a  !

technical basis for a license amendment request to change the acceptance criteria for TS 4.6.2.2.b.2 to correspond to the desired system alignment, provided that the license amendment application includes an appropriate analysis to demonstrate that the related accident analysis assumptions maintain an acceptable margin of safety over the life of the plant.

I i

O * +

t

, W. D. Beckner January 14, 1997 The Containment Systems Branch concurs in this assessment. Accordingly, we recommend that Region IV pursue appropriate enforcement action, cc: R. Zimmerman J. Roe J. Lieberman C. Patel l

l l

l I

l 1

s W. D. Bepkner January 14, 1997 The Containment Systems Branch concurs in this assessment. Accordingly, we recomend that Region IV pursue appropriate enforcement action.

cc: R. Zimmerman J. Roe J. Lieberman C. Patel QlSTRIBUTION:

FILE CENTER TSB R/F CIGrimes TSB Background Books RJGiardina TSB Staff CHBerlinger co m ut umrisn wirauc.arv [f/

OHin TSB/ADPR/NRR (A)SC/TSB/ADPR C:SCSh/D h RR C:TSB/ADPRINRR

• = RJGiardina9h JGluehman N CHBerlinger CIGrimes [ W

• • " l L /9 /96 /% / T /96 / ////97 g,; \ /lkk' 0FFICIAL RECORD COPY

'i b O '713 03 / 6