ML19351A357

Application for Amend to License NPF-38,consisting of Tech Spec Change Request NPF-38-102,revising Tech Spec 3/4.3.1. Amend Reduces Nonconservatism Allowed in Power Level Measurements & Frequency of Adjusting Measured Power

ML19351A357
Person / Time
Site:	Waterford
Issue date:	10/16/1989
From:	Dewease J LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19351A358	List: ML19351A357 ML19351A359
References
W3P89-3092, NUDOCS 8910200112
Download: ML19351A357 (6)

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'4 Loussiene Power & Light C4pny

. < ' 1,_;,_ s 317 Baror.ta Sumt P. O. Box 60340

• - New Orlanna, LA 70160 0340

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Tel. 604 696 2781 l

J.G.Dowesee Sonus Vee Presulord-

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f W3P89-3092 A4.05 QA October 16, 1989 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 Technical Specificacion Change Request NPF-30-102 Gentlemen This document proposes revising Technical Specification 3/4.3.1: Reactor Protective Instrumentation Surveillance Requirements, notation (2). The proposal reduces non-conservatism allowed in power level measurements and eliminates the present requirement to adjust the safety system power indications when they are in the conservative direction. The proposal reduces the frequency of adjusting the measured power to match calculated secondary power.

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Should you have any questi.nis or comments on this matter, please feel free to contact Steven Farkas et (504) 464-3383.

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/ Very truly ycurs.

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Qg,usent  ;

SfiorVicePrecident.

Nuclear Operations .

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JGD/SEF/ssf Attachmente: NPF-38-102

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cc: Messrs. R.D. Martin, NRC Region IV j F.J. Hebdon, NRC-NRR D.L. Wiggie ., NRC-NRR t i E.L. Blake W.M. Stevenson

,. NRC Resident Inspectors Office L

Administrator Nuclear Energy Division (State of Louisiana)

American Nuclear Insurers hDR9202OO112 p ADOCK 03 coo 891o14 3gy PDC

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UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION ,

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! In~the matter of ) [

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Louisians Power & Light Company ) Docket No. 50-382 '

Waterford 3 Steam Electric Station )

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AFFIDAVIT  !

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J.G. Dewease, being duly sworn, hereby deposes and says that he is Senior

• Vice President - Nuclear Operations of Louisiana Power & Light Company; i

that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Technical Specification Change Request NPF-38-102; 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, information and belief. ,

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/G l $ W CE 4.f J/ .'Deweasc~

ior Vice President-Nuclear Operations ,

STATE OF LOUISIANA)

) ss PARISH OF ORLEANS )

Subscribed and sworn to before me, a Notary Publi n nd for the Parish and State above named this /4 M day of A ,

1989.

M/]U Notary Public'

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My Commission expires . .

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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANCE NPF-38-102 p

t This document proposes revising Technical Specification 3/4.3.1 Reactor Protective Instrumentation Surveillance Requirements, notation (2). The proposal reduces non-conservatism allowed in power level sensurements and eliminates the present requirement to adjust the safety system power indications when they are in the conservative direction. The proposal reduces the frequency of adjusting the measured power to match calculated

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secondary power.

Li I: Existing Specifications See Attachment A r-Proposed Specifications

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See Attachment B Description LP&L proposes to reword Table 4.3-1 notation (2) such that calibrating PPS Linear Power Level, CPC Thermal Power, and CPC Nuclear Power occurs when those measurements exceed a -l% error (error in the non-conservative direction).

'This proposed amendment allows changing the philosophy for calibrating PPS

' Linear Power, CPC Thermal Power, and CPC Nuclear Power indications. At present, technical specifications and operating procedures require calibrating those indications to agree with the calorimetric power anytime the difference.between them is >i2%. The proposed wording requires calibrating the indications if the error between calorimetric power and safety system indicated power is more than 1% in the non-conservative direction, i.e., if PPS indicates less than calorimetric power by more than 1%. This proposed amendment also eliminates the limit on how much PPS and l CPC measured plant power exceeds actual core power. PPS automatically <

scrams the plant if the power it measures becomes too high. '

I The most accurate calibration of the PPS Linear Power, CPC Thermal Power j and CPC Nuc1 car Power is accomplished at high power levels (>80% Rated '

Thermal Power (RTP)) where the main feedwater flow, which is an input to the secondary calorimetric calculation, is more stable than at lower power levels. In addition, because the feedwater flow differential pressure transmitter error is constant, it constitutes a smaller fraction of the  !

measured feedwater differential pressure signal at high power levels, thereby, improving the secondary calorimetric power accuracy. Following a power reduction, the possibility exists that the PPS Linear Power and CPC l powers may differ tilgnificantly from the calorimetric power as a result of higher uncertainty in the secondary calorimetric power because of lower and more unstabic feedwater flow rates.

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l The proposed technical specification change reduces the need to calibrate

• f, the excore linear power and CPC powers, particularly at lower power levels I'

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(>80% RTP), when these power indications are conservative relative to the calorimetric power calculation. This eliminates unnecessary changes to the

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PPS excore detector gain settings and the CPC addressable constants, especially changes tlet result in a non-conservative reduction in the PPS f Linear and/or CPC p wer indications. Appropriate adjustments of the PPS b Linear Power and C/C powers will be made however, if they are found to

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indicate a power level greater than -1.0% RTP below the calorimetric power

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indication. Ps110 wing adjustment, the PPS Linear Power and/or CPC powers I will be verified to indicate a power level equal to or greater than the calorimetric power calculation.

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The proposed modiff. cation of the permissible calibration tolerances increases the If*>,sithood, i.e., a greater percentage of the titue, that the power inputs'to the plant protection system and CPC algorithms are equal to or more conservative than the. power indications which would result from calibrations performed using the present 12% RTP Technical Specification calibration tolerance. The proposed change is, therefore, conservative because it ensures that faster protective action occurs, if required, to mitigate the consequences of an anticipated operational occurrence or postulated accident.

TH.s proposal achieves two objectives. One, reduce the frequency of power indication adjustments. And two, retain consistency with Combustion Engineering setpoint methodology.

Safety Analysis The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:

1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequence'of any accident previously evaluated?

Response: No The. proposed change reduces the amount of non-conservative error  ;

presently allowed in the PPS and CPC power indications. Requiring PPS i and CPCs to have more conservative settings does not increase the probability or consequences of any accident.

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Therefore, the proposed change will not involve a significant increase in the probability or consequences of any accident previously evaluated. i

2. Will operation of the facility in accordance with this proposed change l create the possibility of a new or different kind of accident from any I accident previously evaluated?

Response: No 2 '

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• This proposal tightens limits on how far estimated secondary power and  !

g measured core power can differ. Operators use calorimetric power as  ;

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the reference to set PPS and CPC power indications. Calorimetric  ;

power calculations at lower power have greater uncertainty compared to i those made at high power levels. Any calorimetric power calculation ,

uncertainty.In the non-conservative direction magnifies as power L increases.. Adjusting PPS and CPC power indications at low power

• I forces an additional adjustment at high power should the uncertainty r be non-conservative.

The proposed change reduces the amount of non-conservative error.

presently allowed in the PPS and CPC power indications. This g

eliminates some effects caused by the uncertainties in secondary ,

p calorimetric power calculations at low power levels.

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F The proposal also eliminates the 2% limit on how conservatively PPS f and CPC indicate power. That is. PPS can assume plant power is more

than 2% higher than it actually is. Actual power level comes from the calorimetric power calculation. This means that the PPS could

( activate sooner than it presently would, well within the power level assumptions made in the FSAR.

l Therefore, the proposed change will not create the possibility of a

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new or different kind of accident from any accident previously U evaluated.

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3. Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Response: No  ;

The plant safety margins come from limiting conditions for operation,

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limiting safety system settings, and safety limits presently given in the technical specifications.

-This change affects the amount of time spent matching the power

measured by PPS and CPCs to the secondary calorimetric power L calculation, i.e., the power calibration standard. Upon implementing this proposal, the plant trips on or before the time it trips with our current procedures. This results in staying as far or farther from the safety limits specified in Technical Specifications.

Therefore, the proposed change will not involve a significant reduction in a margin of safety.

The Commission has provided guidance concerning the application of j standards for determining whether a significant hazards consideration  !

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exists by providing certain examples (48 FR 14870) of amendments that are l'

considered not likely to involve significant hazards considerations. This change most closely resembles (ii) a change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications; for example, a more stringent surveillance requirement.

This proposal alters the band around the calorimetric power calculation kept by PPS and CPCs from 12% to 2-l%. Reducing the non-conservative error  ;

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is an additional limitation on plant operations, 3 {

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, Safety and Significant Hazards Datermination

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f.1 J ," Based:on the above Safety Analysia, it is concluded that: (1) the proposed

[, change does not constitute a significant hazards consideration as defined

} 'by 10 CFR.50.92 and (2) there.is a reasonable' assurance that the health

% and. safety of the public'wil1~not be endangered by the proposed change; and

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.c(3) this action will not result-in.a condition which significantly alters f, .the impact of the station on the environment as described in the NRC Final

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Environmental Statement. 'l e

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