W3P88-1817, Requests Enforcement Discretion in Implementation of TS 3.3.1, Reactor Protective Instrumentation
| ML20117L527 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 09/30/1988 |
| From: | Carne N LOUISIANA POWER & LIGHT CO. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| W3P88-1817, NUDOCS 9609170023 | |
| Download: ML20117L527 (3) | |
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MMlfsg W3P88-1817 A4.05 QA Mr. Robert D. Hartin Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1000 611 Ryan Plaza Drive, suite Airlington, TX 76011
SUBJECT:
hf aterford 3 SES Docket No. 50-382'
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License No, NFF-38 Request For Enforcement Discretion' Dear Mr. Hartint for enforcement This letter vill serve to document LP&L's requestdiscretion in Protective Instrumentation.
29, 1988, Waterford 3 Duty Plant Manager, On the evening of September John McGahn, reviewed with your Hessrs. Callan and (CPC) cabinets.
was generated on June 15, 1988 to Condition Idantification (CI)-256700a utssing seismic restraint in the rea amplifier (FICA) drawers located in the upper portion of BaysThe document d
documents following a design change to the FICA drawers during the secon D of the CPCs.
The engineer responsible for the updata noted that refueling outage.
incorporated an old field change request Drawing 1564-5422 had not yet ld (FCR-2759 Revision 1), unrelated to the outage design change, which w have installed the missing seismic restraints.
drawer seismic verify installation and it was found that, the rear FICAAs a result, CI-256700 vos ge restraints had not been installed. identify the problem. however no Recently, Waterford 3 has been conducting a review of outstanding 29, 198 During the review, on September i s and Non-Conformance CIs.was identified as having a potential impact on plant opera brought to the attention of Waterford 3 management.
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u Page 2 W3P88-1817 September 30, 1988 Management immediately assessed the impact of the missing seismic restraints on the safe operation of the plant and the Technical Specifications. Technical Specification 3.3.1, Reactor Protective Instrumentation, requires in Table 3.3-1 that a minimum of three CPC channels be operable.
An engineering evaluation of the missing CPC cabinet seismic restraints determined that each of the four CPC channels may become inoperable as the result of a seismic event.
Consequently, at 6:20 p.m. on September 29, 1988, the CPCs were declared inoperable.
Because the Action Statements of Technical Specification 3.3.1 are silent when fewer than two CPC channals are inoperabia, Technical Specification 3.0.3 was entered.
4 As discussed by Mr. McGaha, replacement of the missing seismic restraints vae imminent. Appropriate material had been located, leaving only minor machining and installation in order to return the CPC cabinets to a seismically qualified status. We estimated that approximately 6-12 hours would be necessary to complete installation of the restrainte.
Enforcement discretion in applying Technical specification 3.3.1 was requested because the short period of time to restore the CPC cabinets to a qualified state approximated that necessary to shut down Waterford 3.
To support enforcement discretion we noted that the probability of an operating basis earthquake (OBE) was approximately 7 x 10E-8 per hour, or approximately 2 x 10E-6 in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period (FSAR 8ection 2.5.2.7 calculates an OBE probability of 2.6Z during a 40 year plant lifetime). To further reduce the already low probability of a seismic event adversely affecting the CPCs, plant operators were instructed to m'anually scram the reactor upon receipt of a seismic alarm or other indication of a seismic event in progress, until the CPC cabinets had been restored to a seismically qualified condition.
Finally, it should be noted that the CPC design and four channel configuration provide a very high level of confidency that a CPC failure induced by a setemic event would be in the fail-safe (i.e. tripped) direction.
Based upon our discussions, Waterford 3 was verbally granted enforcement discretion from the Limiting Condition For Operation of Technical Specification 3.3.1. for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The missing CPC cabinet seismic restraints have since been replaced. Restraints were installed in 3 cabinets by 6:30 a.m. on September 30. Due to minor problems, the remaining restraint was installed by 10:30 a.m.
An investigation to deterinine the cause of the missing seismic restraints is underway and will be completed by October 3.
The review of open non-conformence CIs, which led to discovery of the missing seismic restraints has been divided into two phases - the review of safety-related non-conformance CIs which could potentially involve common mode failures or potentially lead to application of Technical Specification 3.0.3 vill be completed by October 1, 19888 the remaining safety-related
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September 30, 1988 non-conformance CIs will be reviewed, and necessary. corrective action identified and scheduisd by October 7, 1988.
To ensure that non-conformance items that could impact asf a operation of Waterford 3 are properly addressed in a timaly manner in the future, all such items vill receive a prompt evaluation and management review, and will be tracked in the plan of the day meeting.
We wish to thank you and your Staff for your prompt and professional assistance in this matter.
Please let me know if we may provide you with additional information.
Very truly yours.
nd(W N.S. Carns Plant Manager - Nuclear MJM/NSC/ nam cc: HRC, Document Control Desk J.A. Calvo. NRC-NRR D.L. Wigginton NRC-NRR NRC Resident Inspectors Office E.L. Blake W.M. Stevenson