ML19324C139

Application for Amend to License NPF-38,consisting of Tech Spec Change Request NPF-38-105,adding Operability Requirements for Stated Valves in Tech Specs 3/4.7.1.5.1 Through 3/4.7.5.5

ML19324C139
Person / Time
Site:	Waterford
Issue date:	11/03/1989
From:	Dewease J LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19324C140	List: ML19324C139 ML19324C141
References
W3P88-1287, NUDOCS 8911150061
Download: ML19324C139 (7)

Text

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,q- 7 I. Loulalana Power & Light Company

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P 'O, Box 60340 Now Orloana, LA 70160-0340 Tot. 504 605 2781 J. G. Dewease L.

o Sena vec Presutant-Nuckw Oswatsons W3P88-1287

, , A4.05 November 3, 1989 9^

U.S. Nuclear Regulatory Commission

' ATTN:. Document' Control Desk Washington, D.C. 20555' Sub,)ects Waterford 3 SES 1 L Docket No. 50-382 License No. NPF-38 Technical Specification Change Request NPF-38-105 -

. Gentlemen:

The proposed change adds a series of Technical Specificationc to include explicit operability requirements for the main f eedwater isolation valves, main feedwater, control valves (consisting of one feedwater regulating valve and one associated startup feedwater regulating valve for each stcam generator), and feedwater regulating bypass valves, along with the main

-steam-isolation valves currently addressed by Technical Specification 13/4.7.1.5. Proposed Technical Specification 3/4.7.1.5.1 through p 3/4.7.1.5.5. provide specific measures to address valve inoperability.

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

Very truly yours, i

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J.p. Dewcase Mnior Vice President Nuclear Operations i I

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Attachments: NPF-38-105 cc: R.D. Martin F.J. Hebdon D.L. Wigginton NRC Resident inspectors Office E.L. Blake '

W.M. Stevenson Administrator Nuclear Energy Division (State of Louisiana)

American Nuclear Insurers 8911150061 891103 l' i

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,9 UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION.

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4 In'the matter of )

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$ Louisiana Power &' Light Company ) Docket No. 50-382-Waterford 3 Steam Electric Station .)

s-h wi U . AFFIDAVIT J.G. Dewease, being duly sworn, hereby deposes and says that he is Senior Vice President - Nuclear Operations'of Louisiana Power & Light Company;

>- that he is duly authorized to. sign and file with-the. Nuclear Regulatory

, J: Commission,the attached. Technical Specification Change; Request NPF-38-105;.

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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, 4

information and belief. ,

Al\^ D% S

' J.f. DWeasi V pnior Vice President Nuclear Operations

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STATE OF LOUISIANA)

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Subscribed and sworn to before me, a Notary Public in and for the Parish and.Statt above named this dM h day of 7/17&ido/A.J ,

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u b' DESCRIPTION AND SAFETY ANALYSIS

[ia 0F PROPOSED CHANGE NPF-38-105-P-

The proposed change shown in-Attachment B replaces, in its entirety, Technical. Specification 3/4.7.1.5: Main' Steam Line Isolation Valves, with L

new technical specifications:

h i 3/4.7.1.5.1-and 3/4.7.1.5.2: Main Steam Isolation Valves 3/4.7.1.5.3 and 3/4.7.1.5.4 Feedwater Isolation Valves t I

3/4.7.1.b.5 ' Feedwater Control- Valves 7

Existing Specifications See Attachment A Proposed Specifications > I L

See Attachment B Description L

4 'The proposed change adds a series of Technical Specifications to include explicit operability requirements for the main f eedwater isolation valves, main feedwater control valves (consisting of one feedwater regulating valve and one associated startup feedwater regulating valve for each steam e generator), and feedwater regulating bypass valves, along with the main

[ steam isolation valves currently addressed by Technical Specification i:

3/4.7.1.5.

The proposed change adds new technical specification requirements explicitly addressing operability, action and surveillance requirements for main feedwater isolation valves, main feedwater control valves, and

' f eedwater regulating bypass valves. The addition of LCOs, action ,

statements, and surveillances for main f eedwater control and isolation  ;

, valves provides assurance that conservative plant conditions exist with ,

respect to the FSAR Chapter 15 safety analysis. The new inclusions in Technical Specifications highlight the importance of main feedwater control valves and f eedwater regulating bypass valves.

Technical Specification 3/4.7.1.5 currently (re Attachment A) defines operability requirements for MSIVs and actions when one or both MSIVs are inoperable. The operability requirements for the MSIVs ensure no more than one steam generator blows down in the event of a main steam line rupture, assuming a single failure. Ensuring only one steam generator blows down prevents exceeding the containment design pressure and limits positive reactivity addition during reactor coolant system cooldown. Equally important in mitigating the consequences of these events are the main feedwater isolation valves (MFIVs) and the feedwater regulating and startup feedwater regulating valves. These valves close on a main steam isolation signal (MSIS) and limit the amount of water entering the steam generator.

Response times for main steam isolation and main feedwater isolation are part of the overall engineered safety features actuation system response times in Technical Specification 3/4.3.2 Table 3.3-5: Engineered Safety Features (ESF) Response Times. Technical Specification 3/4.3.2 actions address only instrumentation inoperability.

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4 E The containment isolation specification, 3/4.6.3 (shown in Attachment B),

h , ', provides specific action when listed ESF valves are mechanically i inoperable. Listed. valves include main steam isolation and main feedwater h isolation-valves. ~ Technical Specifications should cover all the operating

}. assumptions made in the plant safety analysis. However, the feedwater e control valves do not appear in 3/4.6.3 because containment isolation is L not their design basis. Neither do feedwater control valves appear in any i_ other specification. Yet,. FSAR 10.4.7.2 assumes feedwater contro', valves

!' backstop feedwater isolation valves. LP&L proposes to revise 3/4.6.3 so

- 'MSIVs and feedwater valve requirements are all in 3/4.7.1.5.

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.The MSIVs and main feedwater control valves close upon a receipt of a MSIS.

The f eedwater regulating bypass valves are normally closed. The .nain i feedwater control valves terminate feedwater flow to the associated steam generator (like the MFIVs). And, they fulfill the safety function assumed in the safety analysis for a main steam system rupture (re NUREG-0138, Issue 1). Thus, the main feedwater control valves provide a degree of redundancy to the MFIVs when the feedwater regulating bypass valves are closed (re-FSAR 10.4.7.2, page 10.4-19). Because of this redundancy, a 72-hour ACTION statement is proposed for the MFIVs main feedwater control valves and ieedwater regulating bypass valves.

The 72-hour ACTION statement matches other specifications relying on 4

redundant equipment, e.g., ECCS and diesel generators. However, LP&L l

proposes a 4-hour ACTION statement should either both MFIVs, two control valves in different trains, or a MFIV and control valves in the same train become inoperable. The MSIV ACTION statement will remain at 4-hours because it has no complementary equipment. This 4-hour ACTION matches the current containment isolation specification. This proposal also updates the containment isolation specification to refer to the new specifications for MSIVs, MFIVs, and feedwater control valves. The 72-hour feedwater o valve ACTION statements keep the plant from entering unnecessary transients when redundant equipment can complete the safety function i.e., main feedwater isolation on MSIS.

Surveillance Requirement 4.7.1.5 currently requires verification of operable MSIVs. The proposed change expands surveillances to include the MFIVs, main feedwater control valves, and feedwater regulating bypass valves. The proposed surveillances require closing each fast-acting valve on its appropriate actuation signal at least once per eighteen months. ,

The proposed change also revises the Bases to Technical Specification 3/4.7.1.5 to cover both main steam isolation and main feedwater isolation.

Specifically, the new Bases 3/4.7.1.5 clarifies the functions of the MSIVs and the valves required for main feedwater isolation following a main cteam or feedwater line rupture.

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p h .. i Safety Analysis-

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The proposed changes discussed above shall be deemed to involve a significant hazards' consideration if there is a positive finding in any one of the following areas

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

g Response: No.

' The proposed change defines the required ACTIONS for the main steam p and main feedwater isolation valves, main feedwater control valves,

(~ and feedwater regulating bypass valves .which currently exists

[ explicitly only for the MSIVs and subtly for MFIVs. These changes E increase the consistency between plant operation and accident analyses.

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assumptions, avoiding potentially unacceptable consequences for design basis steam or feedwater line breaks. Therefore, operation of the facility in accordance with this proposed change does not involve a

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significant increase in the probability or consequences of an accident previously evaluated.

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

!' Responset. No.

L The proposed change does not alter the design of the plant or equipment operation. Therefore, the proposed change does not create the pocsibility of a new or different kind of accident from any accident previously evaluated.

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

1 Response: No.

The proposed change does not reduce the effectiveness of the main steam and main feedwater isolation valves. Therefore, the proposed change will not involve a significant reduction in a margin of safer.y.

The Commission has provided guidance concerning the application of j standards for determining whether a significant hazards consideration i exists by providing certain examples (48 FR 12870) of amendments that are '

considered not likely to involve significant hazards consideration.

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, , Example (ii) . relates to a . change that' constitutes an additional limitation, h restriction..or control not presently included in the technical pg7 specifications. . In the accident analyses, the main steam and main

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feedwater isolation. valves and feedwater control valves mitigato the consequences of postulated secondary system ruptures. Currently, only the h MS1Vs have expiteit operability, action and surveillance requirements in technical specifications, . Although response times are defined for main feedwater isolation by Technical Specification 3/4.3.2: Engineered Safety Features Actuation System, the Technical Specification 3/4.3.2 operability, action and' surveillance requirements only cover instrumentation. The proposed: change adds new technical specification requirements explicitly addressing operability, action and surveillance requirements.for main feedwater isolation valves, main feedvater control valves, and feedwater regulating bypass valves. .These requirements' constitute additional limitations or restrictions not presently included in technical specifications; therefore, the proposed change is similar to example (ii) of 48.FR 14870.

Safety and Significant Hazards Determination Based on the above discussion, the proposed change does not involve a significant hazards consideration in that it does not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3)' involve a significant reduction in margin of safety. In addition, it is considered that: (1) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (2) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

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ATTACHMENT A

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NPF-38-105 l r

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