ML20154C246

CRGR Submittal Package for Approval of WCAP-11342, Mod of the Steam Generator Low-Low Level Trip Setpoint to Reduce Feedwater-Related Trips

ML20154C246
Person / Time
Issue date:	05/10/1988
From:	Committee To Review Generic Requirements
To:
Shared Package
ML20154C197	List: ML20154C193 ML20154C246
References
FOIA-87-714 NUDOCS 8805180090
Download: ML20154C246 (5)

Text

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6 CRGR SUBMITTAL PACKAGE FOR ADPROVAL OF WCAP-11342, "MODIFICATION OF THE STEAM GENERATOR LOW-LOW LEVEL TRIP SETp0 INT TO REDUCE FEE 0 WATER-RELATED TRIPS"

\q7 t NRR has identified this as a Category 2 requirement, N j

.A The items which folicw correspond to the requirements specified in the CRGR  !

Charter, Revision 3, Septecte ,1986, Paragraph IV.B.

(1) The proposed generic requirement or staff position as it is proposed to be sent out to licensees.

l o WCAP-11342 proposes a conceptual design modification which '

selectively raises the steam generator low-low level trip setpoint (reactor trip and auxiliary feedwater initiation) to include instrument errors due to a harsh environrent upon 3 detection of the onset of adverse containment conditions. '

During normal operation, the Iw-low level setpoint would not include errors associated with a harsh environment. Although currently errors due to a harsh environnent are required to be included in setpoint determination, the staff is not aware of i any known requirement or position which specifically requires  !

harsh environmental errors to be included in setpoints during norval operation. l j

o The staff plans to approve the methodology contained in WCAP-11342 and the conceptual design proposed therein for referencing by plant-specific license amendrent requests from licensees who voluntarily modify their current plant design by installation of 1 new hardware meeting the current plant-specific requirements.

- Under the normal amendment process per 10 CFR 50.90, 34 and 36

- techntcal specification changes and F AR tyttions (with supporting inforration) will be req red for the new hardware which the licensees voluntarily the se to install.

(ii) Draf t staff papers or other underlyint staff do"veents supporting the requirements or staff positions, i i

o SER on WCAp-11342, "Modification of ti., man Generator Low-Low Level Trip Setpoint to Reduce Feedwater-Related Trips."

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(iii) Each proposed requirement or staff position shall contain the sponsoring office's position as to whether the proposal would increase requirements or staff positions, irplement existing requirements or staff positions, or would relax or reduce existing requirements or staff positions.

e As statec abovc, alth# ugh currently instrueentation errors due to a harsh environment are required to be included in setpoint detemination, the staf f 15 not aware of any known requirement or position which specifically requires harsh environrental errors to be included in actual setpoints during nonnal eperation.

(iv) The proposed method of implementation along with the concurrence (and '

any coerents) of OGC on the method proposed.

e The staff would approve implementation et the concentual design, related technical specification changes ana FSAR revisions by plant-specific requests for amendment of license pursuant to 10 CFR 50.90, 34 ano 36.

e OGC has reviewed the method of ieplementation and has no objection.

(v) Regulatory analyses generally conforming to the directives and guicance of NUREG/BR-0058 and NUREG/CR-3563.

e The staff believes approval of WCAP-11342 and the conceptual design proposed therein does not involve new requirements or positions and does not involve a reduction in existing requirements or positions.

e Licensees will voluntarily choose to implenent the des'.gn concept.

5 e Design modification, when implanented, will reduce t.he frequency of inadvertent trips and thereby ir. crease plant sve11 ability and reduce challenges to reactor protection systams.

l (vi) Identification of the category of reactor plants to which the generic requitteen.t or staff position is to apply.

a This is applicable to all pressurized water reactors (PWR) designed by Westinghouse with reactor trip and automatic initiation of auxiliary feedwater on low staae 9enerator level.

!aplerentation util be on a voluntary basis. l I

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(vii) for each such category of reactor plants, an evaluation which deconstrates how the action should be prioritized and scheduled in light of other ongoing regulatory activities. The evaluation shall docusent for consideration information available concerning any of the  !

following factors as my be appropriate and any other information i relevant and material to the proposed action: l (a) Statement of the specific objectives that the proposed action i' is designed to achieve; s The objective is to permit referencing of WCAP-11342 in i plent-specific license amendment requests cowering the  !

voluntary implementation of a design modification which l is intended to reduce the frequency of inadvertent trips  :

due to feedwater transients and thereby increase plant i availability ano reduce challenges to reactor protection  !

systems. l (b) General description of the activity that would tt required by l the license or applicant in order to cosplete the action;

] I o Licensees who voluntarily choose to impleNnt tne design  ;

modification eust submit a plant-specific license arend- l eent request pursuant to 10 CFR 50.90 with supporting i documentation and changes to the plent-specific technical specifications and FSAR as discussed in the staff's SER for WCAP-11342. '

(c) Potential change in the risk to the public from the accidental I offsite release of radioactive material; }

l e No change is predicted. l

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(d) Potential iepact on radiological exposure of facility eeployees i and other onsite workers.

e No change is predicted.

(e) Installation and continuing costs associated with the action, including the cost of facility downtime or the cost of construction delay;

e Installation is on a voluntarily basis.

(f) The potential safety impact of changes in plant or operational complexity, including the relationship to proposed and existing l regulatory requirements and staff positions; I i

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-4 o Design niodification, when installed, will reduce the frequency of inadvertent trips due to feedwater transients and thereby increase plant availability and reduce challenges to reactor protection systems.

(g) The estimated esource burden on the NRC associated with the proposed action and the availability of such resources; o Plant-specific license amendment requests will refer-ence WCAP-11342 for corceptual design. Plant-specific submittals (see SER) must include design details, technical specification changes and operator procedure changes covering implenintation of the design modifi-cation. The processing of license amendments could be carried out by NRR staff and should require approximately one man week of NRC tectnical specialist staff resources.

Alternatively, an augmerted teem inspection approach with regional personnel could be used to audit selected, representative plants.

(h) The potential impact of differences in facility type, design or age on the relevancy and practicality of the proposed action; o implementation is on a voluntary basis. Although designs differ between Westinghouse PWR's, the conceptual design is applicable to most Westinghouse plants with reactor trip and auxiliary feedwnter initiation on low steam generator level, o Various fonnats exist for Westinghouse PWR plant-specific technical specifications. Changes to plant-specific tech-nical specifications to encompass the design modification should be consistent with the existing plant-specific y forv.a t.

(1) Whethtr the proposed action is interim or final, and if interim, the justification for imposing the proposed action on an interim basis, o implementation is on a voluntary basis.

(viii) For each evaluation conducted pursuant to 10 CFR 50.109, the proposing office director's determination, together with the rationale for the determination based on the considerations of paragraphs (1) through (v11) above, that (a) there is a substantial increase in the overall protection of public health and safety or the cosinon defense and security to be derived from tN proposal; and

5-(b) the direct and indirect costs of implementation, for the facilities af fected, are justified in view of this increaseo protection.

e Not applicable.

(ix) For each e. valuation conducted for proposed relaxations or decreases in current requirements or staff positions, the proposing office director's determination, together with the rationale for the determination based on the considerations of paragraphs (1) through (vii) above, that (a) the public health and safety and the common defense and

. .. security would be adequately protected if the proposed reduction in requirements or positions were implemented, and (b) the cost of savings attributed to the action would be -

substantial enough to justify the action, e Not applicable.

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