ML20238E932
| ML20238E932 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/31/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-98-0160, W3F1-98-160, NUDOCS 9809020315 | |
| Download: ML20238E932 (5) | |
Text
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Ent gy per;tions, inc.
Killona. LA 70066 Tel 504 739 6242 Early C. Ewing,111 Onector Naclear Safety & Regulatory Affairs W3F1-98-0160 A4.05 PR August 31,1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 Supplemental Information to Reply to Notice of Violation Gentlemen:
Waterford 3 letter W3F1-98-0118, dated July 1,1998, provided a response to the Notice of Violations identified in Inspection Report 98-08. In response to Violation 9808-03, Waterford 3 committed to submit a schedule for completion of any additional corrective actions that relate to avoiding further violations within 30 days of completing the root cause analysis. The root cause analysis has been completed and the required information is attached.
Please note that the attachment includes the original response to Violation 9808-03 with the additional corrective actions denoted by revision bars.
If you have any questions concerning this response, please contact me at (504) 739-6242.
Very truly yours, H
E.C. Ewing Director h
Nuclear Safety & Regulatory Affairs L
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ECE/GCS/rtk g902o315980831 Mog2 49 Attachment a
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cc:
E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),
j j [ 0 0 g J. Smith, N.S. Reynolds, NRC Resident inspectors Office
Atttchment to W3F1 0160 Pcga 1 of 4 ATTACHMENT 1 ENfERGkOPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 98-08 l
VIOLATION NO. 50-382/9808-03 10 CFR Part 50, Appendix B, Criterion ill states, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into procedures and instructions.
Contrary to the above, the licensee failed to correctly translate applicable regulatory requirements and the design basis into procedures and instructions in that the response time acceptance criteria contained in surveillance test procedures for the emergency feedwater system, containment fan coolers, and high pressure and low pressure safety injection systems did not ensure that the requirements of the licensing basis were met.
This is a Severity Level IV violation (Supplement 1) (50-382/9808-03).
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RESPONSE
Summary of Entergy Operations, Inc., Position Entergy Operations Inc. has carefully evaluated the information in Violation 9808-03 and believes a violation of 10 CFR Part 50, Appendix B, Criterion Ill," Design Control," did not occur.
I Basis for Entergy Operations, Inc., Position Nuclear power plants are designed to cperate according to a design basis.10 CFR 50.2 defines design basis as information which identifies the specific functions to be i
performed by a structure, system, or component (SSC) of a facility, and the specific values or ranges of values chosen for controlling parameters as reference bounds for design.10 CFR 50.2 also states, in part, that design basis values are requirements derived from analysis of the effects of a postulated accident for which a SSC must meet its functional goals. Based on this definition for design basis, Waterford considers the following position on conditions outside the design basis of the plant to be appropriate.
The functional goal of a safety-related SSC in a nuclear power plant is to perform its
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required safety function as assumed in the applicable accident analyses. The results of the accident analyses serve as the reference bound for overall plant design to ensure that the plant is capable of mitigating the consequences of a design basis L_____________
Attachment to W3F1 0160 P:ga 2 of 4 accident. In order to assure the health and safety of the public, some analysis resulp (i.e.. cladding temperature, cladding oxidation, etc.) coincide with regulatory requirements and are affected by a range of input values. EFW response time is an example of such an input value. While a failure to meet the acceptance criteria during testing of a SSC would constitute a degraded or nonconforming condition, such a condition is not necessarily outside the design basis of the plant. If changes to a model input significantly affect the ability of the SSC to perform its intended safety function, as determined through analysis, a condition would exist which is outside of the plant's design basis. For this purpose, a significant effect is one which results in exceeding regulatory requirements. This position is consistent with similar regulations, such as 10 CFR 50.46(a)(3)(i), which addresses significant changes in the application of Emergency Core Cooling System models.
As a result of the above position, transients are typically simulated over the time period that the results have a potential to approach the design or regulatory criteria.
With respect to the EFW turbine driven pump, results of UFSAR Chapter 15.2 accident analyses occur before EFW flow is initiated. Thus, an increase in response time of the magnitude seen here does not have the potential to affect the results of any cf the associated analyses. Based on this information, the condition would not result in a condition that is outside of the plant's design basis.
Waterford does believe, however, that periodic testing of the EFW turbine driven pump should be performed in accordance with adequate written procedures, as required by TS 6.8.1.c. Therefore, Waterford has developed corrective actions to address deficiencies related to operations procedure OP-903-047, " Emergency Feedwater Actuation Signal Test."
Violation 9808-03 also refers to the Containment Fan Coolers, High Pressure and Low Pressure Safety injection Systems. Based on an investigation of the issue, Waterford concluded that the actual surveillance data for these systems met the acceptance criteria and preserved the values given in the Technical Requirements Manual. Thus, no violation occurred with respect to these systems. Furthermore, NRC Inspection Report 98-08 states:
As result of this discovery, the licensee reviewed TRM Table 3.3-5 to identify any other inconsistencies of this type. Two other similar conditions were identified and documented as follows:
CR 98-0545 Start Response Time for Containment Fan Coolers
. CR 98-0558 Start Response Times for the High Pressure Safety injection (HPSI) and Low Pressure Safety injection (LPSI) Systems l
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Att: chm 5nt to W3F1 0160 l
Page S of 4 in both these cases, the acceptance' criteria contained in the
,, surveillance procedures could possibly result in the response times assumed in the FSAR and the TRM requirements being exceeded.
However, a review of the actual test results indicated that the response time was within the requirements for both these cases.
Because of this, the containment fan coolers and HPSI and LPSI
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pumps were not declared inoperable.
2 The inspectors' reviewed the above referenced. documents and l
discussed these issues with licensee personnel. Based on these reviews, it appeared.that the actions taken by the licensee were E
appropriate upon discovery of the inconsistencies.
l Corrective Steps That Have Been Taken and the Results Achieved
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- 1. Design Engineering performed an eveie ation to determine if other pumps that l
receive an ESFAS actuation have the t.sme potential condition. These pumps were identified and discussed in Condition Reports (CRs) 98-0545 and 98-0558.
- 2. Operations revised procedure OP-903-047," Emergency Feedwater Actuation Signal Test," to ensure surveillance contain an allowance for differences in automatic actuation from a setpoint on the Plant Protection System (PPS) and manual actuation from the " Initiate" test button. In addition, the procedure was revised to. change the acceptance criteria response time to a more conservative value of less than or equal to 41.3 seconds.
- 3. Emergency Feedwater Pump AB was retested and the response time was verified to be less than or equal to 41.3 seconds.
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- 4. Operations procedure OP-903-029," Safety injection Actuation Signal," was revised to change the acceptance criteria response time for the containment fan i
coolers to a more conservative value of less than or equal to 11.4 seconds.
i Review of actual response time indicates that TRM limits were not exceeded.
Corrective Steps Which Will Be Taken to Avoid Further Violations 4
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- 1. Operations procedure OP-903-029, " Safety injection Actuation Signal," will be revised to change the acceptance criteria response time for the HPSI and LPSI pumps to a more conservative value.
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- 2. Safety and Engineering Analysis will correct and clarify Technical Requirements j
Manual in regard to response time limits for the Emergency Feedwater pump.
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Att: chm:nt to 4
W3F1 0160
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Pago 4 of 4
- 3. Design Engineering Electrical will establish design basis documentation for respor)se times to verify the Technical Requirements Manual and the Safety j
Analysis are preserved.
Date When Full Compliance Will Be Achieved The above corrective actions place Waterford 3 in full compliance. The corrective measures to preclude recurrence will be completed by February 26,1999.
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