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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217L0421999-10-21021 October 1999 Forwards Insp Rept 50-382/99-20 on 990815-0925 & Notice of Violation.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217N2111999-10-19019 October 1999 Forwards Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Licensed Operator Requalification Program, Effective,Utilized Systems Approach to Training & Showed Continued Improvements Over Previous Insp Findings ML20217L0101999-10-18018 October 1999 Provides Update of Waterford 3 Effort for Review of Ufsar. Info Listed Includes Background Mgt Expectations,Review Status & Results,Clarifications Re Review & Conclusions ML20217L0141999-10-18018 October 1999 Submits Update to NRC Staff Re Circumstances & Plans for Submitting Certification Rept on Waterford 3 Plant Specific Simulator ML20217G7051999-10-14014 October 1999 Forwards Comments on Four of NRC RO Examination Questions for Exam Administered During Week of 991004 05000382/LER-1999-014, Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal1999-10-12012 October 1999 Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal ML20217D5151999-10-0707 October 1999 Forwards Application for Renewal of SRO License for C Fugate License SOP-43039-3,IAW 10CFR55.57.Without Encls ML20217C6251999-10-0505 October 1999 Informs That NRC Reviewed Util Ltr & Encl Exercise Scenario Package for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Based on Review,Nrc Determined That Exercise Appropriate to Meet Objectives ML20212J6921999-09-29029 September 1999 Forwards Insp Rept 50-382/99-18 on 990830-0902.One Noncited Violation Identified Re Failure to Follow Procedural Instructions to Ensure That Members on Fire Brigade Shift Were Qualified ML20216G2441999-09-27027 September 1999 Forwards Insp Rept 50-382/99-19 on 990830-0903.No Violations Noted 05000382/LER-1999-013, Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form1999-09-23023 September 1999 Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form IR 05000382/19993011999-09-21021 September 1999 Informs That NRC License Exam Previously Associated with NRC Insp Rept 50-382/99-301 Will Be Incorporated Into NRC Insp Rept 50-382/99-14 ML20212D8761999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of Waterford 3.During Assessment Period,Number of Personnel Errors Occurred,Which Demonstrated Lack of Attention to Detail by Plant Personnel.Historical Listing of Issues,Encl ML20212C2471999-09-16016 September 1999 Forwards Five Final Applications for RO Licenses for G Esquival,Jm Hearn,Md Lawson,Re Simpson & PI Wood.Written Exam & Operating Test to Be Administered,Is Requested. Encls Withheld ML20212C2391999-09-16016 September 1999 Requests Cancellation of SRO Licenses for Bn Coble,License SOP-43835,due to Job Assignment Location & CA Rodgers, License SOP-43537-1,due to Resignation from Company, Effective 990901 ML20212C5881999-09-14014 September 1999 Forwards Insp Rept 50-382/99-15 on 990719-23 with Continuing in Ofc Insp Until 0819.No Violations Noted ML20211Q4421999-09-0909 September 1999 Forwards Insp Rept 50-382/99-07 on 990601-11.Three Violations Being Treated as Noncited Violations ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211M8391999-09-0303 September 1999 Forwards Revised Epips,Including Rev 25 to EP-001-020,rev 24 to EP-001-030,rev 25 to EP-001-040,rev 30 to EP-002-100,rev 22 to EP-001-010,rev 27 to EP-002-010,rev 26 to EP-002-102 & Rev 16 to EP-002-190.Listed Proprietary Revs to Epips,Encl ML20211L3681999-09-0202 September 1999 Forwards Five Preliminary Applications for Reactor Operator Licenses for Individuals Listed,Iaw 10CFR55.31.Encls Withheld ML20211K9741999-09-0101 September 1999 Forwards Insp Rept 50-382/99-16 on 990704-0814.Two Severity Level IV Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy 05000382/LER-1999-011, Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form1999-08-31031 August 1999 Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form ML20211M3641999-08-30030 August 1999 Forwards Written Examination,Operating Tests & Supporting Ref Matl Identified in Attachment 2 of ES-210,in Response to NRC .Encl Withheld ML20211G5751999-08-27027 August 1999 Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4 ML20211E3281999-08-26026 August 1999 Forwards fitness-for-duty Performance Data for Period of 990101-0630,IAW 10CFR26.71(d).Ltr Does Not Contain Commitments 05000382/LER-1999-009, Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately1999-08-26026 August 1999 Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately 05000382/LER-1999-010, Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form1999-08-26026 August 1999 Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form ML20211F5421999-08-24024 August 1999 Forwards Proposed marked-up TS Page Xviii, Index Administrative Controls, Correcting Page Number Re TS Change Request NPF-38-220.Editorial Changes for TS Change NPF-38-221 Discussed ML20211F3561999-08-24024 August 1999 Forwards CTS Pages & TS Proposed marked-up Pages for Insertion Into TS Change Request NPF-38-207 Re Efas, Originally Submitted on 980702.Original NSHC Determination Continues to Be Applicable ML20211F4611999-08-24024 August 1999 Informs That NRC Reviewed Ltr & Encl Objectives for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Exercise Objectives Appropriate to Meet Emergency Plan Requirements ML20211G1731999-08-23023 August 1999 Informs That Info Submitted in ,B&W Rept 51-1234900-00,will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20210T9791999-08-18018 August 1999 Discusses Which Responded to Reconsideration of Violation Denial (EA 98-022) Enforcement Action Detailed in .Concludes That Violation Occurred as Stated ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210S0561999-08-12012 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for NRC Fys 2000 & 2001 for Waterford 3 ML20210Q6161999-08-12012 August 1999 Forwards Corrected Copy of Monthly Operating Rept for July 1999 for Waterford 3.Original Rept,Submitted with ,Contained Typos ML20217F2661999-08-12012 August 1999 Forwards Copy of 1999 Waterford 3 Biennial Exercise Package to Be Performed Using Waterford 3 CR Simulator ML20210R9231999-08-11011 August 1999 Forwards Insp Rept 50-382/99-10 on 990719-23.Violations Noted.Nrc Has Determined That One Severity Level IV Violation of NRC Requirements Occurred ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams 05000382/LER-1999-008, Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl1999-07-29029 July 1999 Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl ML20210H4291999-07-29029 July 1999 Forwards Response to NRC Rai,Associated with TS Change Request NPF-38-208,proposing to Replace Ref to Supplement 1 with Ref to Supplement 2 of Calculative Methods for CE Small Break LOCA Evaluation Model, in ACs Section of TSs ML20210F9451999-07-27027 July 1999 Forwards Proprietary & non-proprietary Version of Rev 29 to EPIP EP-002-100, Technical Support Ctr Activation,Operation & Deactivation. Proprietary Info Withheld,Per 10CFR2.790 ML20210D3171999-07-23023 July 1999 Submits Proposal for Final Resolution of Reracking Spent Fuel Pool at Plant,Per License Amend 144,issued by NRC in .No New Commitments Are Contained in Ltr 05000382/LER-1999-007, Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached1999-07-23023 July 1999 Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached ML20210D8701999-07-23023 July 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Plan Requests for Relief ISI-018 Through ISI-020 for Entergy Operations,Inc,Unit 3 ML20210B1521999-07-15015 July 1999 Forwards Insp Rept 50-382/99-13 on 990523-0703.Three Violations Being Treated as Noncited Violations ML20209G9771999-07-13013 July 1999 Forwards Objectives & Guidelines for Waterford 3 Emergency Preparedness Exercise Scheduled for 991013.List of Objectives cross-referenced Where Applicable to Relevant Sections of NUREG-0654 IR 05000382/19990081999-07-12012 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-08 Issued on 990503 ML20209E5231999-07-0909 July 1999 Informs That as Result of NRC Review of Util Responses to GL-92-01,rev 1 & Suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes Staff Efforts Re TAC MA0583 ML20209D4051999-07-0707 July 1999 Forwards Revised TS Pages to Replace Attachment C,Entirely in Original TS Change Request NPF-38-207,per 990519 Discussion with C Patel of Nrc.Changes to Action 20 Delete Word Requirement & Revise Word Modes to Mode 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217L0101999-10-18018 October 1999 Provides Update of Waterford 3 Effort for Review of Ufsar. Info Listed Includes Background Mgt Expectations,Review Status & Results,Clarifications Re Review & Conclusions ML20217L0141999-10-18018 October 1999 Submits Update to NRC Staff Re Circumstances & Plans for Submitting Certification Rept on Waterford 3 Plant Specific Simulator ML20217G7051999-10-14014 October 1999 Forwards Comments on Four of NRC RO Examination Questions for Exam Administered During Week of 991004 05000382/LER-1999-014, Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal1999-10-12012 October 1999 Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal ML20217D5151999-10-0707 October 1999 Forwards Application for Renewal of SRO License for C Fugate License SOP-43039-3,IAW 10CFR55.57.Without Encls 05000382/LER-1999-013, Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form1999-09-23023 September 1999 Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form ML20212C2391999-09-16016 September 1999 Requests Cancellation of SRO Licenses for Bn Coble,License SOP-43835,due to Job Assignment Location & CA Rodgers, License SOP-43537-1,due to Resignation from Company, Effective 990901 ML20212C2471999-09-16016 September 1999 Forwards Five Final Applications for RO Licenses for G Esquival,Jm Hearn,Md Lawson,Re Simpson & PI Wood.Written Exam & Operating Test to Be Administered,Is Requested. Encls Withheld ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211M8391999-09-0303 September 1999 Forwards Revised Epips,Including Rev 25 to EP-001-020,rev 24 to EP-001-030,rev 25 to EP-001-040,rev 30 to EP-002-100,rev 22 to EP-001-010,rev 27 to EP-002-010,rev 26 to EP-002-102 & Rev 16 to EP-002-190.Listed Proprietary Revs to Epips,Encl ML20211L3681999-09-0202 September 1999 Forwards Five Preliminary Applications for Reactor Operator Licenses for Individuals Listed,Iaw 10CFR55.31.Encls Withheld 05000382/LER-1999-011, Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form1999-08-31031 August 1999 Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form ML20211M3641999-08-30030 August 1999 Forwards Written Examination,Operating Tests & Supporting Ref Matl Identified in Attachment 2 of ES-210,in Response to NRC .Encl Withheld ML20211E3281999-08-26026 August 1999 Forwards fitness-for-duty Performance Data for Period of 990101-0630,IAW 10CFR26.71(d).Ltr Does Not Contain Commitments 05000382/LER-1999-010, Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form1999-08-26026 August 1999 Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form 05000382/LER-1999-009, Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately1999-08-26026 August 1999 Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately ML20211F3561999-08-24024 August 1999 Forwards CTS Pages & TS Proposed marked-up Pages for Insertion Into TS Change Request NPF-38-207 Re Efas, Originally Submitted on 980702.Original NSHC Determination Continues to Be Applicable ML20211F5421999-08-24024 August 1999 Forwards Proposed marked-up TS Page Xviii, Index Administrative Controls, Correcting Page Number Re TS Change Request NPF-38-220.Editorial Changes for TS Change NPF-38-221 Discussed ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20210Q6161999-08-12012 August 1999 Forwards Corrected Copy of Monthly Operating Rept for July 1999 for Waterford 3.Original Rept,Submitted with ,Contained Typos ML20210S0561999-08-12012 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for NRC Fys 2000 & 2001 for Waterford 3 ML20217F2661999-08-12012 August 1999 Forwards Copy of 1999 Waterford 3 Biennial Exercise Package to Be Performed Using Waterford 3 CR Simulator 05000382/LER-1999-008, Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl1999-07-29029 July 1999 Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl ML20210H4291999-07-29029 July 1999 Forwards Response to NRC Rai,Associated with TS Change Request NPF-38-208,proposing to Replace Ref to Supplement 1 with Ref to Supplement 2 of Calculative Methods for CE Small Break LOCA Evaluation Model, in ACs Section of TSs ML20210F9451999-07-27027 July 1999 Forwards Proprietary & non-proprietary Version of Rev 29 to EPIP EP-002-100, Technical Support Ctr Activation,Operation & Deactivation. Proprietary Info Withheld,Per 10CFR2.790 ML20210D3171999-07-23023 July 1999 Submits Proposal for Final Resolution of Reracking Spent Fuel Pool at Plant,Per License Amend 144,issued by NRC in .No New Commitments Are Contained in Ltr 05000382/LER-1999-007, Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached1999-07-23023 July 1999 Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached ML20209G9771999-07-13013 July 1999 Forwards Objectives & Guidelines for Waterford 3 Emergency Preparedness Exercise Scheduled for 991013.List of Objectives cross-referenced Where Applicable to Relevant Sections of NUREG-0654 ML20209D4051999-07-0707 July 1999 Forwards Revised TS Pages to Replace Attachment C,Entirely in Original TS Change Request NPF-38-207,per 990519 Discussion with C Patel of Nrc.Changes to Action 20 Delete Word Requirement & Revise Word Modes to Mode ML20209B6081999-06-30030 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl 05000382/LER-1999-005, Forwards LER 99-005-00,providing Details of Discovery of Untested Electrical Contacts in safety-related Logic Circuits1999-06-24024 June 1999 Forwards LER 99-005-00,providing Details of Discovery of Untested Electrical Contacts in safety-related Logic Circuits ML20196G5731999-06-24024 June 1999 Forwards Operator Licensing Exam Outlines Associated with Exam Scheduled for Wk of 991004.Exam Development Is Being Performed in Accordance with NUREG-1021,Rev 8 ML20212J4121999-06-23023 June 1999 Responds to NRC Re Reconsideration of EA 98-022. Details Provided on Actions Util Has Taken or Plans to Take to Address NRC Concerns with Ability to Demonstrate Adequate Flow Availability to Meet Design Requirements ML20196E9371999-06-22022 June 1999 Forwards Revs Made to EP Training Procedures.Procedures NTC-217 & NTC-217 Have Been Deleted.Procedure NTP-203 Was Revised to Combine Requirement Previously Included in Procedures NRC-216 & NTC-217 ML20196A1021999-06-17017 June 1999 Provides Supplemental Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, Per 990513 Request of NRC Project Manager ML20195F3671999-06-0909 June 1999 Forwards Rev 21,Change 0 to EP-001-010, Unusual Event. Rev Reviewed in Accordance with 10CFR50.54(q) Requirements & Determined Not to Decrease Effectiveness of Emergency Plan ML20195C7801999-06-0303 June 1999 Submits Response to Violations Noted in Insp Rept 50-382/99-08.Corrective Actions:All Licensee Access Authorization Personnel Were Retrained Prior to Completion of Insp ML20195C2951999-05-28028 May 1999 Forwards Annual Evaluation of Changes & Errors Identified in Abb CE ECCS Performance Evaluation Models Used for LOCA Analyses.Results of Annual Evaluation for CY98 Detailed in Attached Rept,Based Upon Suppl 10 to Abb CE Rept ML20195C0241999-05-28028 May 1999 Notifies NRC of Operator Medical Condition for Waterford 3 Opertaor Sp Wolfe,License SOP-43723.Attached NRC Form & Memo Contain Info Concerning Condition.Without Encls ML20196L3281999-05-24024 May 1999 Informs That Entergy Is Withdrawing TS Change Request NPF-38-205 Re TS 3.3.3.7.1, Chlorine Detection Sys & TS 3.3.3.7.3, Broad Range Gas Detection Submitted on 980629 ML20206S4691999-05-17017 May 1999 Requests Waiver of Exam for SRO Licenses for an Vest & Hj Lewis,Iaw 10CFR55.47.Both Individuals Have Held Licenses at Plant within Past Two Year Period,But Licenses Expired Upon Leaving Util Employment.Encl Withheld 05000382/LER-1999-004, Forwards LER 99-004-00 Re Discovery That Response Time Testing Had Not Been Performed for ESFAS Containment Cooling Function,As Required by TS SR 4.3.2.31999-05-14014 May 1999 Forwards LER 99-004-00 Re Discovery That Response Time Testing Had Not Been Performed for ESFAS Containment Cooling Function,As Required by TS SR 4.3.2.3 ML20206N1921999-05-10010 May 1999 Provides Revised Attachment 2 for Alternative Request IWE-02,originally Submitted 990429 Re Bolt Torque or Tension Testing of Class Mc pressure-retaining Bolting as Specified in Item 8.20 of Article IWE-2500,Table IWE-2500-1 ML20206J1471999-05-0606 May 1999 Requests That Implementation Date for TS Change Request NPF-38-211 Be within 90 Days of Approval to Allow for Installation of New Monitoring Sys for Broad Range Gas Detection Sys ML20206J1721999-05-0606 May 1999 Notifies That Proposed Schedule for Plant 1999 Annual Exercise Is Wk of 991013.Exercise Objective Meeting Scheduled for 990513 at St John Baptist Parish Emergency Operations Ctr ML20206G8021999-05-0404 May 1999 Provides Revised Response to NRC Re Violations Noted in Insp Rept 50-382/99-01.Licensee Denies Violation as Stated.Change Made Is Denoted by Rev Bar & Does Not Materially Impact Original Ltr ML20206E7811999-04-29029 April 1999 Proposes Alternatives to Requirements of ASME B&PV Code Section XI,1992 Edition,1992 Addenda,As Listed.Approval of Alternative Request on or Before 990915,requested ML20205T2531999-04-22022 April 1999 Forwards LER 99-S02-00,describing Occurrence of Contract Employee Inappropriately Being Granted Unescorted Access to Plant Protected Area ML20205R2611999-04-20020 April 1999 Forwards Rev 19 to Physical Security Plan,Submitted in Accordance with 10CFR50.54(p).Plan Rev Was Approved & Implemented on 990407.Rev Withheld,Per 10CFR73.21 ML20205Q3241999-04-16016 April 1999 Submits Addl Info Re TS Change Request NPF-38-215 for Administrative Controls TS Changes.Appropriate Pages from New Entergy Common QA Program Manual Provided as Attachment to Ltr 1999-09-07
[Table view] Category:UTILITY TO NRC
MONTHYEARW3P90-1505, Forwards Proposed Operator Licensing Exam Schedule & Proposed Requalification Exam Schedule,Per Generic Ltr 90-071990-09-17017 September 1990 Forwards Proposed Operator Licensing Exam Schedule & Proposed Requalification Exam Schedule,Per Generic Ltr 90-07 W3P90-1163, Forwards Relief Requests Associated w/10-yr Inservice Insp Program Per Section 50.55a(g)(6)(i) of 10CFR501990-09-0606 September 1990 Forwards Relief Requests Associated w/10-yr Inservice Insp Program Per Section 50.55a(g)(6)(i) of 10CFR50 W3P90-1191, Responds to Violations Noted in Insp Rept 50-382/90-15. Corrective Actions:Tech Spec Surveillance Procedure PE-005-004 Will Be Revised to Ensure That Normally Closed Valves Opened & Verified to Close for Toxic Gas Signal1990-08-31031 August 1990 Responds to Violations Noted in Insp Rept 50-382/90-15. Corrective Actions:Tech Spec Surveillance Procedure PE-005-004 Will Be Revised to Ensure That Normally Closed Valves Opened & Verified to Close for Toxic Gas Signal W3P90-1194, Submits Fitness for Duty Performance Data for 6-month Period from Jan-June 19901990-08-29029 August 1990 Submits Fitness for Duty Performance Data for 6-month Period from Jan-June 1990 W3P90-1184, Responds to Violations Noted in Insp Rept 50-382/90-14. Corrective Actions:Local Leak Rate Test Activities Shall Be Administratively Controlled to Require Use of Test Method Other than Pressure Decay1990-08-20020 August 1990 Responds to Violations Noted in Insp Rept 50-382/90-14. Corrective Actions:Local Leak Rate Test Activities Shall Be Administratively Controlled to Require Use of Test Method Other than Pressure Decay W3P90-1187, Forwards Booklet Entitled, Safety Info - Plans to Help You During Emergencies, Recently Distributed to General Public1990-08-17017 August 1990 Forwards Booklet Entitled, Safety Info - Plans to Help You During Emergencies, Recently Distributed to General Public W3P90-1189, Forwards Waterford 3 Steam Electric Station Emergency Preparedness Exercise for 901024. Annual Exercise Will Be Performed Using Control Room Simulator1990-08-17017 August 1990 Forwards Waterford 3 Steam Electric Station Emergency Preparedness Exercise for 901024. Annual Exercise Will Be Performed Using Control Room Simulator W3P90-1162, Forwards Rev 4 to 10-Yr Inservice Insp Program First Interval 1985-19951990-08-16016 August 1990 Forwards Rev 4 to 10-Yr Inservice Insp Program First Interval 1985-1995 W3P90-1174, Forwards Rev to Emergency Plan & QA Program,Consisting of Chart Indicating Changes to Util Organization1990-08-0707 August 1990 Forwards Rev to Emergency Plan & QA Program,Consisting of Chart Indicating Changes to Util Organization W3P90-1177, Forwards Revised Objectives for Emergency Preparedness Exercise Scheduled for 9010241990-08-0303 August 1990 Forwards Revised Objectives for Emergency Preparedness Exercise Scheduled for 901024 W3P90-1164, Forwards Waterford Steam Electric Station Unit 3 Basemat Monitoring Program Special Rept 3. Rept Documents Continued Integrity of Basemat as Verified by Program from Time of Inception of Monitoring in 1985 Through Mar 19901990-08-0303 August 1990 Forwards Waterford Steam Electric Station Unit 3 Basemat Monitoring Program Special Rept 3. Rept Documents Continued Integrity of Basemat as Verified by Program from Time of Inception of Monitoring in 1985 Through Mar 1990 W3P90-1167, Forwards Rev 12 to Emergency Plan Implementing Instruction EP-001-001, Recognition & Classification of Emergency Conditions, Reflecting Name Change of State Agency to Louisiana Radiation Protection Div1990-07-19019 July 1990 Forwards Rev 12 to Emergency Plan Implementing Instruction EP-001-001, Recognition & Classification of Emergency Conditions, Reflecting Name Change of State Agency to Louisiana Radiation Protection Div W3P90-1148, Responds to NRC 900503 Submittal Concerning Review of Util Rev 6,Change 1 to Inservice Testing Program for Pumps & Valves1990-07-17017 July 1990 Responds to NRC 900503 Submittal Concerning Review of Util Rev 6,Change 1 to Inservice Testing Program for Pumps & Valves W3P90-1143, Advises That 900404 Request for Addl Info Re Tech Spec Change Request NPF-38-103 Will Be Provided by 900803.Change Will Extend Test Frequency of Channel Functional Tests for ESF Actuation Sys & Reactor Protection Sys Instrumentation1990-07-0606 July 1990 Advises That 900404 Request for Addl Info Re Tech Spec Change Request NPF-38-103 Will Be Provided by 900803.Change Will Extend Test Frequency of Channel Functional Tests for ESF Actuation Sys & Reactor Protection Sys Instrumentation W3P90-1379, Provides Notification That Util Has Consolidated Operation of All Nuclear Facilities,Effective 9006061990-07-0202 July 1990 Provides Notification That Util Has Consolidated Operation of All Nuclear Facilities,Effective 900606 ML20044A5541990-06-26026 June 1990 Forwards Response to Generic Ltr 90-04 Requesting Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements or Corrective Actions ML20044A5551990-06-22022 June 1990 Describes Changes Required to Emergency Plan as Result of Transfer of Operations to Entergy Operations,Inc. Administrative Changes to Plan Necessary to Distinguish Support Functions to Be Retained by Louisiana Power & Light W3P90-1365, Provides Notification of Change in Operator Status Per 10CFR50.74 Due to Entergy Corp Consolidating Operation of All Nuclear Generating Facilities,Including Plant Under Util1990-06-19019 June 1990 Provides Notification of Change in Operator Status Per 10CFR50.74 Due to Entergy Corp Consolidating Operation of All Nuclear Generating Facilities,Including Plant Under Util ML20043G3431990-06-14014 June 1990 Requests That All NRC Correspondence Re Plant Be Addressed to RP Barkhurst at Address Indicated in 900523 Ltr ML20043F5121990-06-0808 June 1990 Forwards List of Directors & Officers of Entergy Operations, Inc.Operation of All Plants Transferred to Entergy on 900606 ML20043F2621990-06-0606 June 1990 Requests Withdrawal of 900504 Request to Extend Implementation Date of Amend 60 Re Transfer of Operations to Entergy,Inc.All Necessary Regulatory Approvals Obtained & License Conditions Implemented ML20043C1861990-05-29029 May 1990 Submits Response to 900426 Comments Re Investigation Case 4-88-020.Util Issued P.O. Rev Downgrading Order of Circuit Breakers & Eliminating Nuclear Requirements ML20043E5441990-05-24024 May 1990 Forwards Public Version of Change 1 to Rev 2 to EPIP EP-002-015, Emergency Responder Activation. Release Memo Encl ML20043B3501990-05-23023 May 1990 Forwards Response to Concerns Noted in Insp Rept 50-382/90-02.Response Withheld ML20043B3781990-05-23023 May 1990 Requests Change in NRC Correspondence Distribution List, Deleting Rt Lally & Adding DC Hintz,Gw Muench & RB Mcgehee. All Ref to Util Changed to Entergy Operations,Inc.Proposed NRC Correspondence Distribution List Encl W3P90-1314, Requests NRC Concurrence That Design/Controls/Testing to Minimize Potential for Common Header Blockage Acceptable Per 900510 Meeting.Tap Alternatives for Shutdown Cooling Level Indication Sys Discussed1990-05-21021 May 1990 Requests NRC Concurrence That Design/Controls/Testing to Minimize Potential for Common Header Blockage Acceptable Per 900510 Meeting.Tap Alternatives for Shutdown Cooling Level Indication Sys Discussed ML20043B3271990-05-21021 May 1990 Forwards Justification for Continued Operation Re Taped Splice for Use in Instrument Circuits,Per 900517 Request ML20042F5251990-05-0404 May 1990 Requests Extension of 90 Days to Implement Amend 60 to License NPF-38 in Order to Provide Securities & Exchange Commission Time to Review Transfer of Licensed Activities to Entergy Operations,Inc ML20042E5501990-04-17017 April 1990 Responds to Request for Addl Info Re Feedwater Isolation Valve Bases Change Request Dtd 891006 ML20012F4551990-04-10010 April 1990 Forwards Rev 10,Change 4 to Physical Security Plan.Encl Withheld ML20012F5491990-04-0606 April 1990 Advises That Util Installed Two Addl Benchmarks for Use as Part of Basemat Surveillance Program to Increase Efficiency of Survey Readings.New Benchmarks Will Be Shown on FSAR Figure 1.2.1 as Part of Next FSAR Rev ML20012F3181990-04-0606 April 1990 Forwards Util,New Orleans Public Svc,Inc & Entergy Corp 1989 Annual Repts ML20012E8971990-03-30030 March 1990 Submits Results of Evaluation of Util 900414 Response to Station Blackout Rule (10CFR50.63).Station Mod May Be Required to Change Starting Air Sys to Accomodate Compressed Bottled Air ML20012E2551990-03-27027 March 1990 Responds to Violation Noted in Insp Rept 50-382/90-01. Corrective Actions:Qa Review of Licensed Operator Medical Exam Records Conducted & Sys Implemented to Track Types & Due Dates of Medical Exams Required for Operators ML20012E0511990-03-27027 March 1990 Forwards Rev 10,Change 3 to Physical Security Plan.Rev Withheld ML20012D5461990-03-22022 March 1990 Forwards Documentation from Nuclear Mutual Ltd,Nelia & Nuclear Electric Insurance Ltd Certifying Present Onsite Property Damage Insurance ML20012D4911990-03-21021 March 1990 Responds to NRC 900208 Ltr Re Violations Noted in Investigation Rept 4-89-002.Corrective Action:Proper Sequence of Insp Hold Point Placed in Procedure Under Change Implemented on 880425 ML20012C0691990-03-14014 March 1990 Advises That Util Intends to Address Steam Generator Overfill Concerns (USI A-47) Utilizing Individual Plant Exam Process,Per Generic Ltr 89-14 ML20012C0421990-03-12012 March 1990 Forwards Questionnaire in Response to Generic Ltr 90-01, Request for Voluntary Participation in NRC Regulatory Impact Survey. Results Not Reflective of Particular Calendar Yr ML20012B6731990-03-0707 March 1990 Responds to NRC Bulletin 88-011,Action 1.a Re Insp of Surge Line to Determine Discernible Distress or Structural Damage & Advises That Neither Surge Line Nor Affiliated Hardware Suffered Any Discernible Distress or Structural Damage ML20006F5321990-02-22022 February 1990 Forwards Payment for Order Imposing Civil Monetary Penalty in Response to Enforcement Action EA-89-069 ML20011F1401990-02-21021 February 1990 Responds to Violations Noted in Insp Rept 50-382/89-41. Corrective Action:Review of Independent Verification Requirements Re Maint Activities Performed ML20006F1731990-02-19019 February 1990 Forwards Corrected Pages 9.2-21 & 9.2-22 of Rev 3 to FSAR, Per 891214 Ltr ML20006E5781990-02-13013 February 1990 Forwards Third Refueling Inservice Insp Summary Rept for Waterford Steam Electric Station Unit 3. ML20006D0571990-02-0202 February 1990 Responds to SALP Rept for Aug 1988 - Oct 1989.Contrary to Info Contained in SALP Rept,Civil Penalty Not Assessed by State of Nv for Radioactive Matl Transport Violations.Issue Resolved W/State of Nv W/O Issuance of Civil Penalty ML20006C1631990-01-30030 January 1990 Requests Extension of Commitment Dates in Response to Violations Noted in Insp Repts 50-382/89-17 & 50-382/89-22 to 900222 & 19,respectively.Violations Covered Use of Duplex Strainers & Missing Seismic Support for Cabinet ML20006C1581990-01-29029 January 1990 Forwards Response to Generic Ltr 89-13 Re safety-related Open Svc Water Sys.Instruments in Place on Component Cooling Water Sys/Auxiliary Component Cooling Water Sys HXs Which Connect to Plant Monitor Computer ML20006C1611990-01-29029 January 1990 Responds to NRC Bulletin 89-003 Re Potential Loss of Required Shutdown Margin During Refueling Operations. Instructions for Determining Acceptable Refueling Boron Concentration Provided in Procedure RF-005-001 ML20006B4121990-01-26026 January 1990 Informs That Photographic Surveys Discontinued,Per Basemat Monitoring Program.Monitoring Program Implementing Procedure Will Be Revised to Reflect Change ML20006A7091990-01-22022 January 1990 Forwards List of Individuals That No Longer Require Reactor Operator Licenses at Plant 1990-09-06
[Table view] |
Text
. s LOUISIANA u2 onAnoNos sineer P O W E R & L I G H T! R O. BOX 6008
- (504) 366-2345 UTiuSN SYSSE March 16, 1984 W3P84-0577 Q-3-A29.20 Director of Nuclear Reactor Regulation Attention: Mr. G.W. Knighton, Chief Licensing Branch No. 3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
SUBJECT:
r Waterford SES Unit 3
? Docket No. 50-382
) Technical Specifications: 10CFR50
. -_ Appendix J Leak Rate Testing and Containment Isolation Valves ATTACHMENTS: (1) .Tustification for exemption from Type C Testing
'(2) List of isolation valves within essential system (3) Penetration Isometric Drawings
Dear Mr. Knighton:
Louisiana Power and Light is currently finalizing and making plant-specific the Technical Specifications in preparation for an operating license. The development and review process has generally proceeded in a very productive manner, however we have reached an impasse on three critical issues under Containment Systems Branch cognizance. These issues potentially impact the fuel loading schedule and subsequent power operation of Waterford 3 if-not satisfactorily resolved.
TYPE C TESTING l
The first issue concerns Type C leakage testing pursuant to 10CFR50, Appendix J.
During the Technical Specification Proof and Review phase, the Containment Systems Branch (CSB) indicated that penetrations subject to Appendix J Type 2 and C testing should be explicitly identified in the Technical Specifications.
Consequently, LP&L proposed an update to the Technical Specifications that added applicable penetraticus for Type B and C testing as previously identified in the FSAR. However, the CM has indicated that additional penetracions should be subject to Type C testing. There are two points which we believe are relevant to this issue.
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- W3P84-4577 lQ-3-A29.20 First,~apparentlyitheLCSB is maintainingLa position ~ requiring'nine (9) additional
- penetrations to be Type C tested. 'None of these penetrations are required to be AType'C tested in accordance with the definition of " Type C Tests" included in 1 Appendix J of 10CFR Part 50. In addition, all of.these penetrations are normally
~
,-water. filled land most are in operation under post _ accident-conditions. In order to postulate'leakagelfrom the containment atmosphere to the outside atmosphe *,
es aid
~
multipleLfailures or single 1f ailures plus leakage through multiple barrierr
~have;to be' assumed in addition to the postulated LOCA. The penetrations identified in the FSAR for Type C testing adequately ensure that post-accident
^
containment-leakage is less than~that assumad in the1 accident analyses. However, 7 :notwithstanding LP&L's firm-position that these penetrations.do not fit the
[ feriteria of' Appendix J or. applicable NRC guidelines'for requiring leak tests, we
. have; performed calculations which demonstrate that, even in the event of any
' single-active-failure, a water seal will be.present on each penetration thereby preventing montainment leakage. A discussion of the results of these
.: calculations is provided'in Enclosure.l.
^
Second,[ithad~beenLP&L'sunderstandingthatthetestingrequirementsof
- Appendix J of-10 CFR Part.50 had been satisfactorily resolved during the FSAR
- review. Evidence of this resolution is contained in the Waterford-3 Safety
- Evaluation Report.(NUREG-0787) Subsection 6.2.6. LP&L does recognize.that the determination of Containment bypass leakage paths remained open to be resolved as Ep art of the-Technical Specification review process as stated in SER Subsection F >
- 6 '. 2. 3. .However final determination of bypass leakage-paths should not have 3
. . identified additional penetrations for Type C testing since bypass leakage
, -penetrations are:a subset of Type B and'C penetrations.
!l TThe:nineL(9)-~ penetrations at. issue are not designed with provisions to conduct leak rate testing in accordance with Appendix J. EIt is extremely late in the
- ' licensing-~ process for/the Containment Systems: Branch-to reopen design questions
- that)had previously been accepted, and.it is inappropriate that the Technical Specification, process be used as a mechanism for reinterpreting leak testing regulations.- Being that'the CSB's concerns =do not.seem plant-specific to Waterford-3,-LP&L believes'that.these concerns, including their inconsistency with; Appendix J, may be more appropriately addressed in accordance with the
~
Commission's Backfit' Policy.
- Technical Specification 3/4.6.3 and General Design Criteria (GDC) 57 Systems 1
^ '
-The second issue of' concern to LP&L is the Containment Isolation Valve Technical TSpecification. 'LP&L's concern deals with the applicability of the Limiting y -Condition;forTperatica (LCO) toward1GDC 57 systems (closed systems penetrating
< containment)-and the appropriateness of including. isolation valves within "
essential systens under the jurisdiction of this-Technical' Specification.
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- W3P84-0577L Q-3-A29.20l
, - i g .. ;LP&L's positioniis thatjthe LCO/ Action-requirement;of this specification is inappropriate'for penetrations designed.in.accordance with General Design J
- @ Criteria (GDC) 57 of-Appendix.A of 10CFR Part 30. CDC 57 penetrations are
'neitherLpartiof the 3 reactor coolant pressure-boundary nor open to containment fatmosphere / but are connected to a_ closed-seismic Category I system inside
. / containment
- and;are- provided with a containment -isolation . valve outside the -
" containment.--Hence, the two operable isolation barriers are an active isolation
,? . valve _and.'a passive closed piping. system. LP&L's concern with the Action
~
, ; requirements of. Specification 3.6.3 ic that an inoperable-isolation valve in a
_GDC 57 penetration'would require immediate action to initiate plant shutdown
^
kbecause:the action statements do not take. credit for the second isolation
. barrier, i.e., closed systems inside containment. However, an inoperable
^
isolation barrier (valve)-in a typical GDC 55 and-56 penetration.is allowed 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> before initiation of-plant shutdown-is required. This allows expected and funexpected maintenance. activities to be performed on~ containment isolation
-systems.; Prior to revision 3.(Fall /1981) of the Standard Technical
-Specificatione,.the bases for.this specification never explicitly included GDC
^
'570 It is LP&L's position that Specification 3.6.3 should not decrease potential 1 U plant availability without a corresponding 1nerease in safety. Consequently, it !
- is requested
- that Specification 3.6.3 be revised to allow credit for the
. . containment isolation boundary intrinsic 'to a GDC 57-penetration (i.e., a closed ,
[ e s'ystem), or the~ valves in these penetrations be deleted from the specification.
^
Technical Specification-3/4.6.3 and Essential Systems
" An additional concern with Technical Specification'3/4.6.3 is the inclusion into
.this specification of valves in essential systems. Placing these valves into_.
[ 'this Technical Specification can degrade the overall safety of_the plant as well
.as limit operations. . Inclusion of essential system valves forces the plant to
~
' isolate these' penetrations within four hours if a' valve is inoperable in' order to
. seet'the. action statements of Specification 3.6.3. Isolation of these valves is I
-not'the required post-accident position nor the position of' greater importatce to plant safety. 'These: penetrations are~ designed to be open and operating post-LOCA and usually. get ESFAS Signals (SIAS, CSAS, EFAS) to open in the event of an :
accident.1.The operability of these. valves / systems is ensured by other means
~
, -including: separate Technical Specifications for each system (Safety Injection, Containment' Spray, etc.); the provisions and requirements of ASME.Section XI; and j .
jactuation during ESFAS subgroup relay testing (Technical Specification Table
.423-2). ; Inclusion of these valves does not seem to be in the best interest'of-
[^ _ .
- plant safety,or operation and is inconsistent with the requirements placed on .
. - previously ~1icensed plants. ' LP&L's position. is that the operability of the essential system containment isolation valves is ensured by other requirements -
, :and thatfthecievel of safety.being verified by the Technical Specifications should be consistent among all the Engineered Safety Feature Systems. Enclosure
-(2).-11sts those isolation valves that LP&L feels are better validated by other !
TechnicalLSpecifications'and requirements.
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Your assistance.in ensuring that these matters receive the appropriatc high level reviews will be greatly appreciated. 'Should you have any questions or comments, please do not hesitate to contact us. We are prepared to meet with the NRC staff to respond in detail to any. questions.
Very truly-yours,
/
K. W. Cook Nuclear Support & Licensing Manager KWC/RMF/W/ch Attachments
- cc: W.M. Stevenson, E.L. Blake, D.M. Crutchfield, W. Butler, J. Wilson, D.
Hoffman, J. Huang, G.L. Constable i
-W , , ,
a J
~ Enclosure (1)
. Justification for Exemption from' Type C Testing i The_following penetrations have not been resolved:
N '1.- l#23, #24 CCW for Reactor Coolant Pumps and CEDM Coolers
- i. ._ ? 2. #27_CVCS Charging Line
- 3. +#34,:#35 Containment. Spray (4.- .#40,'#41: Shutdown Cooling
,~
J5. #69,,#70 Hot Leg Injection For penetrations 23 and 24, the Containment Systems Branch at a meecing on l1/17/84 indicated-that an exemption from leak. testing until the first refueling f ?
- (could be granted due-to lack of testing provisions. This is acceptable at present-to LP&L, however further effort is planned to support a permanent
- exemption and to fully address CSB_ concerns.
- In regard.to thetother' penetrations, Appendix J to 10CFR Part 50 states:
. " Type ,C Tests'? means - tests intended to neasure containment isolation valve x.
-- .leakageirates. The containment isolation valves included are those that:
- 1. -Provide a direct connection between the inside and *.he outside atmosphere of the primary reactor containment under normal
-_ operation, such as' purge and ventilation, vacuum relief, and instrument valves;-
- 2. -Are required to close' automatically upon receipt of a containment
-isolation signal;in response to controls intended to effect containment-isolation;
'3. Are required to operate intermittently under post accident conditions; and
.i .
_4 . .Are in main steam and feedwater piping and other systems which penetrate containment of direct-cycle boiling vater power
= reactors.
_.The NRC staff conclusions reached in Section 6.2.6 (Containment Leakage Testing Program) in'the Waterford 3 SER (NUREG-0787_ dated 7/81) state:
~
"The. proposed reactor containment leakage-test probram complies with the
. requirements of~ Appendix ~J to 10 CFR Part 50. Such compliance provides adequate assurance that containment leak-tight integrity can be verified
~
. : periodically throughout . service lifetime _ on a timely basis' to maintain such J fleakage.within the limits of the technical speciffcations.
Maintaining containment leakage rates within such limits provides reasonable
- assurat.celthat,'in the event of any radioactivity releases within the containrent, the. loss of the containment atmosphere through the leak paths will not be in excess of acceptable limits specified for the' site.
- Compliance _with the requirements of Appendix J constitutes an acceptable basis for satisfying thel requirements of GDC 52, 53, and 54."
m None of.the disputed valves fit any of the above categories and therefore should
'not require testing. In addition, all of these penetrations are normally water filled and most are in operation under post accident conditions. In order to postulate leakage from the containment atmosphere to the cutside atmosphere, multiple failures or single failures plus leakage through multiple barriers against a water seal would have to be assumed in addition to the LOCA. This enclosure contains-a discussion of each penetratien in question.
Penetrations 34, 35, 40, 41, 69, and 70 form closed, seismic Category I, Safety Class 2 Systems outside containment, have design temperature and pressure greater than the post-LOCA containment environment, and are protected from the effects of pipe rupture and missiles. These systems are maintained full of water during normal plant operation and due to their Post Accident operation are
-subject to a system leak reduction program including periodic leak testing (with fluid) in accordance with Technical Specification 6.8.4.a and NUREG 0737 Item III.D.1.1. These leak tests are-performed at system operating pressures which are much greater than the containment post accident pressure; therefore, leakage due to containment pressure for postulated system failures will be minimal. The
~ discovery of any significant leakage identified during testing requires appropriate maintenance to reduce the leak rate. Leakage from these systems occurs within the Controlled Ventilation Area and the worst-case effects are accounted for in the annlysis of LOCA Dose Consequences (See SER 15.4.7).
~
.In addition to the above arguments, the following provides specific details (penetration isometric drawings are included as Attachment (3)) for each penetration supporting LP&L's position that post LOCA containment leakage paths are not credible for these penetrations and that it is unnecessary to perform Type C tests.
Penetration 27 CVCS Charging Line The charging system receives an automatic SIAS signal to start two charging pumps, align the system to take a suction on the Boric Acid Makeup Tanks and inject borated water into the Reactor Coolant System. Flow through this penetration is guaranteed in this line under post-LOCA conditions, and credit is taken for flow in the small break LOCA analysis. Technical Specification 4.1.2.2.b verifies the flowpath at least every 31 days.
During the subsequent post-LOCA period, the sater in the Boric Acid Makeup Tanks may be depleted. When this happens, charging will be secured and the charging isolation valves will be shut. For most RCS break locations, the charging line will not be exposed to the containment atmosphere, since flow from the Safety Injection system keeps the piping covered with fluid. In the event the break was in the RCS Cold Leg at a position which caused the charging line to be exposed to the containment atmosphere, there are still several barriers available. Inside containment there are 2 valves in series in each charging path and outside containmcnt there are check valves on each charging pump discharge in addition to the containment isolation valve. The charging pumps are positive displacement pumps further minimizing any backflow in the system. All of the piping is of high pressure design, and the valves are subject to ASME section XI testing.
- --. ., ,~ --. -- - -- - - - . _ - - - -.
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_ _ JA conservh lve calculation was performed assuming' seat leakage of the Loutboard isolation valve,ineglecting the resistance of the other valves and the'.
f l positive? displacement pumps. . The'outside' isolation valve is a gate valve, thus
~ m f,only_seatileakage has the' potential to;become stem leakage.. The result shows
'q Jthatfa water barrier can be maintained on the isolation valve for greater than 30.
1
-days even iffone and one-half times.the valve's design leakage is assumed. .This k calculation and the design leakage specification are based _on_ system design pressure which is_much higher than the relatively low Containment Post Accident
. Pressure.1 <
LP&Lifinds 'it highly tmlikely that a credible leakage path from the -
- < ' Containment--stmosphere'to'the outside atmosphere exists in this penetration.
Penetrations 34 and 35, Containment Spray
- The' Containment Spray System is an ESF system that is required to be in Loperation following a LOCA. During normal' plant operation the system is
-- maintained full of. water from.the RWSP through the pump discharge-header (riser) up to a level of-149.5 ft._MSL (See Technical Specification 3/4 6.2). After the LOCA,tthe system is automatically placed in-operation, supplying water from the RWSP or the Safety. Injection System Suinp inside containment. The outer isolation
.1 valve'is located at'the system lowpoint-(-32 ft. MSL) and thus water is.
maintained around the valve even if..the Containment Spray pump fails to start.
.That is, a head of water willibe applied against_this_ valve from the RWSP (minimum water (level: -2 ft., MSL) and/or the Safety Injection _ Sump (bottom at -16
'ft.:MSL plus post-accident containment pressure) 'due.to their higher elevation,
, , ' Jirrespective of what single-failures are applied. .In-order for leakage to occur La check valve inside the containment and an-isolation valve outside containment
-would have to leak:through the seats under the small differential pressure across cthe valve'. A leakage calculation was performed, which neglected the check valve j . completely. .The_outside containment isolation valve is a gate valve, thus only_
O iseat leakage has.the' potential'to.become valve" stem leakage. The calculation
~
. _ conservatively assumed all seat leakage'as stem leakage. The results show that a
<- water barrier can be maintained for greater than 30 days even if 45 times the design seat leakage is' assumed..
t
=LP&L fi s'it highly unlikely that leakage can occur through these f
penetrations.
7 Penetrations 40 and 41, Shutdown Cooling The'SDC lines connect the RCS hot legs to the LPSI Pump Suction through-three normally closed isolation valves. Two of these valves are interlocked'such that they_cannot-be opened until the RCS prescure is reduced below the SDC entry fpressure'(377'psig).' Inside the Reactor Auxiliary Building, this closed system ipiping' descends'to the -35 ft. MSL' elevation where it connects to the LPSI Pump
' Suction. This system lowpoint will'be maintained under a head of water due to
- the higher elevation of the RWSP and/or the Safety Injection Sump. The SI Sump,
'due'to(the water level-in the sump and containment atmospheric pressure will i-
"E always exert a higher pressure on the RAB side of the low point piping than the l' piping from containment will if. exposed to the containment atmosphere. Should
- the SI Sump' isolation valve fail to open, the RWSP at the minimum level achieved
'p . upon RAS :(-2 f t. MSL) will exert approximately 13 psi on this piping. A higher
. pressure (44 psi peak) can. exist-inside the Containment, but this is reduced to m
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lig w, iessithan22jpsi:withini24 l hours.-(SeeSER6.2.1),'andthenisfurtherreduced.
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,In. order for:leakageito' occur,:these three11n-series valves must leak by the-
~
seats.E The-containment: isolation valves are gate valves. thus~only seat leakage-hasithe potential to becoce valve stem: leakage. :The two valves inside (Containment are!RCS boundary' valves ~and tested for leakage in accordance with 1 afechnical: Specification 4.4.5.2.'2 at: 2250 ' psia. - A calculation was performed-
~
isesuming.' seat leakage 3of the outboard-isolation valvei neglecting the isolation
. - provided by'theitwo inaseries RCPB valves inside Containment. The:results show
~
~ that f a water. barrier can be maintained on' the valve for greater than-30 days even
~
fif~9ctimes-the design leakage occurred.; Both the calculation and the design-w leakage;specificationsiare based on system' design pressure which is much greater than the~relatively low Containment Post Accident-Pressure.
~: ,
. -LP&L^ finds--it highly unlikely that post accident containment atmosphere
,eakage will occur in this penetration.
4
- Penetrations 69 and'70 Hot Leg Injection.
'. The Hot Leg Injection headers are an integral part of the ECCS system and E ?will be placed ~in operation post-LOCA. . Prior to initiation of hot leg injection.
- the~ isolation valves-outside: containment are closed with HPSI pump discharge
, pressure applied against the outermost-valve. Even if a HPSI pump failed during ,
-post-accident' conditions, pressure isEstill applied to the'RAB side of the
. outermost isolation valve due to the head-of water from the RWSP and/or the' '
= Safety Injection Sump.
Due to the dual considerations of the' water level in the LST' sump in addition to the ambient containment pressure, a higher pressure will always exist on' the RAB side'of the isolation valve'than on the containment side,
~ f thus ensuring- that any: leakage will be into cuatainment, and that in any event a
'waterzseal'is maintained-on the containment side of the valve. Should the sump ,
-isolatien . valve -fail to lopen (a second single-active-failure), the minimum RWSP
. tievel!will still? exert at_least an approximate 13 psi-against the outermost
, ' isolation valve.. Although a higher ambient pressure may exist for a short time
. inside' containment, 2 check valves -(RCS boundry valves)' and the isolation valve
~
' ~
outside containment:all present-barriers against leakage. The check valves are tested for leakage (intersystem.LOCA bases; Technical. Specification 4.4.5.2.2) at 2250 psia.ifar. greater than the small post-accident differential pressure which may. exist across the isolation valve (less:than approximately 31 psi).
'A calculation was performed assuming seat leakage and stem leakage of the
?
. outboard isolation ~ valve and neglecting the isolation provided by the series
[ check valves completely.. .The<results show that a water barrier can be maintained
~for, greater than'30' days even if double-the design leakage occurred. This l.
- calculation included stem leakage'that will-be detected and corrected under the .
-leak! reduction program.- Both the~ calculation and the design leakage R
- specifications are based on system' design pressure which is much higher than the relativelyjlow containment post-accident pressure.
o, 1LP&L' finds;it' highly unlikely;that a credible leakage path from the l containment' atmosphere to the.outside atmosphere exists in these penetrations.
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." U Enclosure (2)
Proposed Valves to be Deleted from-Technical Specification Table 3.6-2*
'1. Containment Isolation Acceptable as is
- 2. Containment PurFe ,
. Acceptable as is
- 3. -Safety Injection Actuation Signal (SIAS)**
Penetration 26 - CVCS-Letdown (Already listed under (CIAS))
~
Penetration 32 and 33 .SI Sump Isolation
- 4. Main Steam Isolation Signal (MSIS)**
. Penetration 32 and 33 - Emergency Isolation
- 5. . Manual / Remote Manual Essential Systems:
a.; . Penetration 1 and 2 - 2MS ~ V611A, 2MS - PM629A, 2MS - V612B, 2MS - PM630B
- b. Penetration 15 through 22 - CCW to Containment Fan Coolers
- c. Penetration 27 C7CS - Charging
- d. -Penetration 34 and 35 - Containment Spray
- e. Penetrations 36 through 39 - LPSI
- f. Penetrations 40 and 41 - Shu:down Cooling
- g. . Penetrations 55 through 58 - HPSI
- h. Penetrations-69 and'70 - Hot Leg injection 6.- Other a.- Essential Systems: Penetrations 27, 34, 35, 36-39, 55-58, 69 and 70
- b. Penetration 1 and 2. These valves are not required for containment f- isolation in accordance with CDC 57 (See revised FSAR Table 6.2-32, and 33).
l- . . .
'* This list is broken down 'into Subsections as shown in the February 16, 1984
- Draft version _of Technical Specifications.
- . LP&L's position is that these Subsections should not be included in this
-Technical Specification.
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