W3P88-1212, Application for Amend to License NPF-38,consisting of Tech Spec Change Request NPF-38-81,revising Number of Fans Which Must Be Operable in Tech Spec 3.6.2.2, Containment Cooling Sys. Fee Paid
| ML20154Q708 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/31/1988 |
| From: | Dewease J LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20154Q712 | List: |
| References | |
| W3P88-1212, NUDOCS 8806070102 | |
| Download: ML20154Q708 (8) | |
Text
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l LOUISIANA POWE R & LIG H T / INTER-OFFICE CORRESPONDENCE EnYS SYS May 31, 1988 W3P88-1212 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 Technical Specification Change Request NPF-38-81
Reference:
W3P88-1213 to NRC from R.F. Burski Gentlemen:
Louisiana Power & Light files this application for an emergency amendment to the Waterford 3 Technical Specifications in accordance with 10CFR50.91(a)(5). The amendment, which does not involve an unreviewed sefety question nor a significant hazards consideration, would revise the number of Containuent Cooling Fans which must be operable in Technical Specification 3.6.2.2, Containment Cooling System.
The referenced letter discussed the need for a Temporary Waiver of Compliance until such time as an emergency Technical Specification change could be processed by the NRC. The need for this waiver, and this emergency change, became evident when plant personnel discovered that the C Containment Cooling Fan was inoperable due to the sudden failure of the f an motor wine'ings. At the time of discovery (May 28, 1988 at approxi-mately 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br />) Waterford 3 was in the process of entering mode 2 to perform Low Power Physics Testing following i refueling outage. The inoperability of the C fan, therefore, would have prevented Waterford 3 from performing Low Power Physics Testing and would have required a plant cocidown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
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d Page 2 W3P88-1212 Upon discovery, LP&L contacted vendors _and utilities throughout the country, as well as Canada, for a fan motor which would meet the design requirements.of this particular application. When this proved fruitless, LP&L immediately began searching for a similar motor which, with minor design changes, could be substituted for the damaged motor.
In parallel with this, maintenance personnel began removing the motor in order to send it to the manufacturer for work.
In' addition, LP&L engineers contacted Ebasco Services in an effort to determine if a reanalysis of the limiting design basis accidents with respect to Containment cooling and depressurization would be feasible.
Upon receiving enforcement discretion, Waterford 3 entered mode 2 on May 29, 1988 to begin Low Power Physics Testing. Throughout May 29 and 30, LP&L continued to search for alternative motors. In addition, LP&L and Ebasco engineers continued work on the reanalysis. At approximately 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> on May 31, 1988 LP&L was informed by Ebasco engineers that the reanalysis would support a Technical-Specification change to allow less than the currently required cooling fans to be operable in modes 1 through 4.
The failed motor has been disassembled and inspected at Westinghouse's Spartanburg facility. This inspection showed the condition and lubri-cation of the bearings were satisfactory, and there was no evidence of foreign material intrusion into the stator area. Westinghouse engineers are currently working on a failure analysis. Preliminary results indi-cate that the motor experienced an electrical problem which resulted in a short circuit of an area of the windings several inches in diameter.
It is impossible, in this short time frame, to have a more conclusive evaluation.
Since there is no evidence to the contrary at this time, it is assumed that the motor experienced a random failure.
At approximately 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> on May 31, 1988 LP&L is scheduled to complete Low Power Physics Testing and, therefore, will complete the necessary requirements to proceed to mode 1.
The LP&L and Middle South Utilities systems experience the highest demand for electrical power during the upcoming summer months. The unavailability of Waterford 3 would require the operation of more costly fossil fired units or the open market purchase of who1.euale electricity at prices much higher than Waterford 3 electricity. The alternatives to nuclear generated electricity repre-sents an undue economic burden upon LP&L and its ratepayers.
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1 Page 3 W3P88-1212 The Ebasco/LP&L evaluation, which was completed a matter of hours prior to the completion of Low Power Physics Testing, forms the basis for the enclosed Technical Specification change request.
Should there be any questions, please contact Larry Laughlin at (504) 464-3499.
Very truly yours, M U3
,. Dewease nior Vice President-Nuclear Operations JGD:LWL:ssf Attachments:
NPF-38-81 LP&L Check $150.00 cc:
R.D. Martin, J.A. Calvo, D.L. Wigginton, NRC Resident inspectors Of f ice, E.L. Blake, W.M. Stevenson bec:
R.P. Barkhurst, R.F. Burski, T.F. Gerrets, F.J. Drummond, S.A. Alleman, N.S. Carns, D.F. Packer, P.V. Prasankumar, J.R. McGaha, E.J. Senac, M.J. Meisner, G.E. Wuller, R.J. Murillo, G.E. Wilson, R.W. Prados, L.W. Laughlin, C.E. DeDeaux, G.W. Muench, R.T. Lally, Jr., W.A. Cross Records Center, Administrative Support, Licensing Library, Site Licensing Support File Ebasco - J.B. Houghtaling, M r,.
norrell CE - R.P. O'Neill NS90015AA
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of
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. Louisiana Power & Light Company
) Docket No. 50-382 Waterford 3-Steam Electric Station
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AFFIDAVIT J.G. Dewease, being duly sworn, hereby deposes and says that he is Senior Vice President-Nuclear Operations of Louisiana Power & Light Company; that he is duly au*horized to sign and file with the Nuclear Regulatory Commission the attsched Technical Specification Change Request NPF-38-81; that he is familiar with the content thereof; and that the matters set forth'therein are true and correct to the best of his knowledge, infor-mation and belief.
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.% Dewcase for Vice President-Nuclear Operations 4
STATE OF LOUISIANA)
) ss PARISH OF ORLEANS )
Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this d//f day of Vp m J
1988.
NW h Notary Public g/
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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CRANGED NPF-38-81 The proposed change would revise Technical Specification 3.6.2.2, Containment Cooling System.
Existing _ Specification See Attachment A.
Proposed Specification See Attachment B.
Description Waterford 3 Technical Specification (TS) 3.6.2.2 presently requires two independent trains cf containment cooling fans to be operable with two fan systems to each train for modes 1, 2, 3, snd 4.
The proposed change would revise the existing Technical Specification to allow Waterford 3 to operate with one fan in each train (i.e. only two fans, one in each train would be required to be operable).
The function of the Containment Heat Removal System, as described in Chapter 6 of the Waterford 3 FSAR, is to assist Containment Spray and heat sinks in removing heat from containment atmosphere, and thus main-tain containment pressure and temperature at acceptable levels, during a design basis accident. The most limiting condition for peak containment pressure considerations is a Main Steam Line Break (MSLB) at 75% power.
For long term pressure reduction considerations, a Loss of Coolant Accident (LOCA) from 100% power is the most limiting.
A reanalysis of these limiting events using the same computer codes and models described in Chapter 6 of the FSAR was performed. The analysis assumed only one Containment Cooling Fan per train was operable and the initial containment pressu*e was the maximum allowed by Technical Speci-fication 3.6.1.4, 1.0 psig. The reanalysis shows that for the limiting 75% MSLB with the failure of one containment cooling train (one Contain-ment Cooling Fan operates instead of two), the peak containment pressure increased by approximately 0.1 psig from approximately 43.7 psig to approximately 43.8 psig. Similarly, for the limiting 75% power MSLB with a failure of a main steam isolation valve to close (two Containment NS90015AA
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1 Cooling Fans operate instead of all four), the peak pressure increased from approximately 43.7 psig to approximately 43.8 psig. This maintains moremargin(0.2psig)tothecontainmentdesigg)pressureof44psigthan was approved in the original license analysis To assess the effect of fewer operable cooling fans on the lon; term post accident containment pressure reduction, the limiting 100% power LOCA wac reanalyzed. This analysis verified that the containment pressure can be reducad by a factor of 2 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the accident.
The proposed change, therefore, would revise TS 3.6.2.2 to require one Containment Cooling Fan per train to be operable in modes 1, 2, 3 and 4.
Safety Analysis The proposed change described above shall be deemed to involve a signifi-cant hazards conside ation if there is a positive finding in any of the following previously evaluated?
1.
Will operation of the facility in accordance with this proposed change significantly increase the probability or consequences of any accident previously evaluated?
Response
No.
As discussed previously, a reanalysis of the LOCA and MSLB events for Waterford 3 indicates that with one Containment Cooling Fan per train operable, the containment design pressure is not exceeded for the worst case design basis accident and allows a greater margin to design than that originally licensed for Waterford 3.
In addition the analysis shows that one fan per train is sufficient to reduce c ntainment pressure by a factor of 2 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the accident. This reanalysis was performed using the same computer codes and models previously evaluated by the NRC in its review of the Waterford 3 FSAR. The only inputs that changed were related to the number of Containment Cooling Fans assumed to operate for the LOCA and MSLB events.
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To put the reanalysis results in perspective, it is instrucrive to briefly review the history of the Containment pressure Technical Specification at Waterford 3.
As originally licensed, the MSLB limiting case peak pressure (calculated from the initial condition of the then maximum allowable Containment pressure) resulted in a margin of 0.04 psig to the Containment design pressure. Waterford 3 requested a change to the Containment pressure Technical Specifica-tion via W3P87-2006 dated July 29, 1987 (as supplemented by W2P87-1147 dated 11/5/87), based upon reanalyses of the limiting MSLB/LOCA cases an increase in the margin to Containment design pressure. The present limiting case discussed above (MSLB with failure of a main steam isolation valve to close) maintains a margin of 0.20 psig to Containment design pressure - more than double the originally licensed margin. NS90015AA
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b Since the reanalysis supports the proposed change, the probability or consequences of any accident previously evaluated will not significantly increase.
2..
Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident-from any accident previously evaluated?
Response
No.
The proposed change requires only one Containment Cooling Fan per train to be operable. The operation of the system, as well as plant procedures, will remain unchanged. Therefore, the proposed change will not create the possibility of a new or different kind of accident from any previously evaluated.
3.
Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin to safety?
Response
No.
The results of the reanalysis of the limiting LOCA and MSLB events show that the containment design pressure is not exceeded with only one Containment Cooling Fan per train operable.
In fact, the safety margin exceeds that availabe under the original Waterford 3 Techni-cal Specifications. Also the containment pressure is reduced by a factor of 2 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the accident. Therefore, there is no significant reduction in the margin to safaty due to this change.
Safety and Significant Hazards Determination Based upon the above Safety Analysis, it is concluded that (1) the proposed change does not constitute a significant hazards consideration as defined by 10CFR50.92; (2) there is reasonable assurance that the I
health and safety of the public will not be endangered by the proposed change; and, (3) this action will not result in a condition which signi-i ficantly alters the impact of the station on the environment as described in the NRC Final Envircnmental Statement.
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