W3P88-1916, Forwards Compliance W/10CFR50.62,Reduction of Risk from ATWS Events. Design & Function of Diverse Scram Sys & Turbine Trip Described
| ML20155H296 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/07/1988 |
| From: | Burski R LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20155E135 | List: |
| References | |
| W3P88-1916, NUDOCS 8810190394 | |
| Download: ML20155H296 (2) | |
Text
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LOUISI AN A / 317 BARONNE STREET P. O. BOX 60340 POWER & LIGHT NEW ORLEANS, LOUtslANA 70160 (504)595-3100 Wb??sil0 October 7, 1988 W3P88-1916 A4.05 QA U.S. Nuclear Regulatory Commission ATTN Document Control Desk Washington, D.C. 20555
SUBJECT:
Waterford SES Unit No. 3 Docket No. 50-382 Compliance with 10CFR50.62 Reduction of Risk From Anticipated Transients Without Scram Events REFERENCES :
- 1) W3P85-2696, dated October 10, 1985
- 2) CEN-380, dated September, 1988
- 3) CEN-380 Supplement 1, dated September, 1988
- 4) W3P87-0916, dated March 17, 1987 Gentlement By References 1 and 4, LP6L committed to the installation of a diverse scram system (DSS) and turbine trip (TT) in accordance with 10CFR50.62 (the ATWS Rule) by the end of the 3rd refueling outage at Waterford 3.
This report describes the design and function of the DSS and TT, including a detailed comparison with the requirements of the ATVS Rule and its under-lying regulatory guidance, in order to establish Waterford 3 compliance with 10CFR50.62 for the DSS and TT.
The ATWS Rule also requires equipment diverse from the reactor trip system (RTS) to automatically initiate the emergency feedwater actuation system (EFAS) under conditions indicative of an ATWS. As you know. Waterford 3 and several other CE plants have consistently taken the position that diver-sity already exists between the RTS and the present EFAS sufficient to meet the requirements of the ATWS Rule.
Several years of technical discussions on this issue between the CE Ovners Group and the NRC Staf f culminated in l
a Staff decision that certain of the EFAS relays for Waterford 3 do not meet I
the diversity requirements of the ATWS Rule. At the same time, the Staff suggested that submittal of a request for exemption to the EFAS requirements of 10CFR50.62 was an acceptable alternative to EFAS hardware changes.
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Consequently, based on References 2 and 3 included in the attached report, LP&L requests an exemption to the ATWS Rule EFAS diversity requirements.
Our original position on the adequacy of EFAS diversity remains unchanged, however, and is reiterated for completeness.
t We recognize that there is some potential for an exemption review to delay l
issuance of a safety evaluation report. Therefore, we request your timely review of the DSS and TT design (separately from the exemption request) in order to support design finalization, procurement and construction of the DSS /TT during t'c..' 3rd refueling outage (tentatively scheduled to begin l
in September, 1989).
l Should we be able to provide you with additional information to assist in your review, please do not hesitate to contact Roy Prados at (504) 595-2806.
l Yours very truly, Y'
R.F. Burski Manager j
Nuclear Safety 6 Regulatory Affairs RFB/MJM/ple i
cci E.L. Blake, W.H. Stevenson, J. A. Calvo, D.L. Wigginton, R.D. Martin, j
NRC Resident Inspector's Office (W3) l 4
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