W3P90-1526, Forwards Status Update of Generic Ltr 88-17, Program Enhancements
| ML20058E230 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/01/1990 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-17, W3P90-1526, NUDOCS 9011070086 | |
| Download: ML20058E230 (5) | |
Text
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Ent rgy Cpirstirns,Inc.
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W3P90-1526 A4.05 QA November 1, 1990 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 l
Status Update of Generic Letter (GL) 88-17, Programmed Enhancements i
Gentlemen:
In W3P89-0101 (dated February 1,1989), the approach to addressing the GL 88-17 programmed enhancement recommendations at Waterford 3 was discussed.
The purpose of this letter is to update the implementation status of those recommendations, which are discussed in the attachment for each of the six programmed enhancement areas.
i The necessary programmed enhancements that did not depend on hardware changes (i.e., procedure upgrades, etc.) were implemented before the initiation of the first draindown during the September 1989 refueling 3
o outage, which demonstrated safe operation at reduced inventory conditions.
Since the September 1989 outage occurred, less than 18 months following receipt of GL 88-17, the schedular requirements for implementing hardware i
changes and associated procedure changes will be completed prior to the end of Refuel 4 (presently scheduled to begin in March 1991).
At that time Waterford 3 will have completed the GL 88-17 programmed enhancements.
However, because Waterford 3 management places particular emphasis on the importance of a safe and thoughtful approach to operation during reduced inventory conditions, refinement and the enhancement process is a continuing effort.
Better ideas and new industry experience will be evaluated and future refinements / enhancements may be necessary.
l 9011070086 901101
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W3P90-1526 Status Update of Generic Letter (GL) 88-17, Programmed. Enhancements November.1, 1990 Page 2 l
Should you have any questions about this submittal, please contact Roy Prados at (504) 739-6632.
l Very.'truly yours,
' RFB /RWP/ssf-
Attachment:
Implementation status of the six programmed enhancement areas of GL 88-17.
cc:
Messrs. R.D. Martin (NRC Region IV), D.L. Wigginton (NRC-NRR),
p E.L. Blake, R.B.- McGehee NRC Resident Inspectors Office 4:
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Attachment to W3P90-1528 Page 1 of 3 The following addresses the implementation status of the six programmed enhancement areas of GL 88-17.
- 1..
IInstrumentation Level -
For the two independent RCS level indloations, I
Waterford 3 will be using the. Refueling Water Level Indication System (RWLIS) and Reactor l
Coolant Shutdown Level Measurement System (RCSLMS) as discussed during the May 10, 1990 NRC/LP&L meeting and. described in W3P90-1314 (dated May 21; 1990) and accepted s
by. the NRC in the fune 15, 1990 letter to Mr.
R.P. Barkhurst.
As required, implementation will occur during the March 1991 refueling j
outage.
s Temperature -
When the reactor. vessel head is in place and the RCS is in a reduced inventory condition, i
two independent temperature measurements representative of the core exit conditions is achieved by use of at least two independent CETs.. Temperature monitoring will be accomplished by temporary patch cables as l
described in W3P89-0101.- Since Waterford 3 j
will not be removing the reactor vessel head i
during reduced inventory operation, i
alternatives for. temperature monitoring under l
this condition are not necessary.
4 1
e - Performance /.nd -
Consideration was given to the adequacy of
.i Abnormal performance and abnormal condition indication l
Condition instrumentation.
Concepts such 'as acoustic l
Indications monitoring for vortex detection are not feasible
[
7 at. this time.. Also,- the CE Owners Group l
(CEOG)' task, discussed in W3P89-0101, to i
survey. shutdown cooling performance Nuitoring instrumentation was -not adopted.
However, Waterford 3 did conduct its own survey of 26 nuclear plants and the conclusion
)
was that the collective array of. existing 1
Waterford 3 instrumentation, described in j
W3P89-0101, exceeded the norm.
The conclusion is that the instrumentation listed in i
W3P89-0101 and the instrumentation assodated i
with the level monitoring systems 1
(RWLIS/RCSLMS) is adequate.
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Attachment to W3P90-1526 Page 2 of 3 2.
' Procedures -
Numerous procedural enhancements have been implemented as a result of both the expeditious actions and programmed enhancements of GL 88-17.
Procedural enhancements that were necessary before Waterford 3 could enter a reduced inventory condition have been completed.
However, as previously mentioned, additional procedural changes will.
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' occur as a result of. programmed enhancement recommendations affecting
= level.
3.
' Eaulpment This' area.was addressed in W3P89-0101.
4.
Analyses l
L Extensive analyses have been conducted to supplement existing L,
information and increase the understanding of the Waterford 3 NSSS response and mitigating actions if a loss of shutdown cooling occurs.
This includes analyses performed by Waterford 3 personnel and the
'CEOG. ' Waterford 3 personnel have remained closely : informed ' of. the status 'of CEOG work and have ensured that the applicable results of that~ work have~ been accounted for at Waterford-3.
Analyses have been performed to provide the basis for operational-1 restrictions.and procedural requirements.
Concerns related to heatup rates,' time to core uncovery, RCS. pressurization and venting.
requirements, allowed. nozzle dam configurations and installation, steam l
generator heat transfer, use of safety injection to provide RCS cooling, and containment environmental conditions and closure requirements -have been addressed.
The analyses encompass the
-various thermodynamic states and possible configurations which may be Lg present.to obtain an increased understanding of plant behavior during L m.
I - non-power.. operation.
L These calculations considered various times after shutdown, different
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ini+Jal conditions, and-bound conditions and behavior during a loss of f
shutdown cooling.- They also provide a thorough basis for determining ll
. and understanding NSSS and reactor containment behavior when a loss of shutdown cooling occurs.
O In ad lition to the above, numerous other analyses have been performed in consideration of instrumentation-design changes (i.e., the p
RCSLMS).
4 There are no outstanding analyses required as a result of GL 88-17.
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c.v Attachment to W3P90-1526 I
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Page 3 of 3-L 5.
Technical Specifications p,.
As a result of the loss of shutdown cooling events caused by inadvertent closure of the automatic closure interlocks (ACI), analysis t.
and justification for removal of the ACI from the Waterford 3 design has been submitted to the NRC in Technical Specification Change Request NPF-38-108.
This is the only= technical specification change requested as a result of GL 88-17.
- 6.
' RCS Perturbations The expeditious actions associated with procedures / administrative
. controls have been re-examined ~ and refined as needed.
These refinements were-based on analyses discussed in Item 4, industry events in this area, and collective input from appropriate Waterford 3 i
. personnel. :
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