ML19332D253

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Safety Evaluation Supporting Amend 59 to License NPF-38
ML19332D253
Person / Time
Site: Waterford 
Issue date: 11/14/1989
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML19332D252 List:
References
NUDOCS 8911300222
Download: ML19332D253 (4)


Text

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't, SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 59 TO g

FACILITY OPERATING LICENSE NO. NPF-38 LOUISIANA POWER AND LIGHT COMPANY WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382 l

1.0 INTRODUCTION

By application dated October 5,1989 as supplemented by letters dated October 23 and November 1, 1989, Louisiana Power and Light Company (LP&Lorthelicensee)requestedchangestotheTechnicalSpecifications (Appendix A to Facility Operating License No. NPF-38) for Waterford Steam Electric Station, Unit 3.

The revised Technical Specifications (TS) will permit more operable charging pumps in various shutdown modes at different k values while two boron dilution alarms are operable.

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intentionof(hischangeistoresolvetwoconcernsfromthecurrent TS 3.1.2.9.

First, the requirements of the minimum nurber of operable charging pumps are not consistent between TS 3.1.2.9 and TS 3.1.2.4 Second, the current TS 3.1.2.9 permits only one operable charging pump during Mode 3 when k is greater than 0.98.

This restriction causes operationaldifficulfffwhen entering Mode 2 fron Mode 3 and the dilution of RCS boron concentration using charging pumps is needed. Supplementary information was submitted by the licensee's letters dated October 23 and November 1, 1989 to support its proposed change of TS 3.1.2.9.

The supplemental information was to clarify the proposal in the October 5 1989 letter and did not change the staff's determinationa.f no significant hazards consideration published in the Federal Register or, October 23, 1989 (54 FR 43210).

L 2.0' EVALUATION The current TS 3.1.2.9 requires two boron dilution alarms operable or the primary make-up path to the reactor coolant system be isolated and operation is prohibited in certain configurations specified in Tables 3.1-1 through 3.1-5.

However, the requirements in these tables are based on an assumption that a 30 minute operator action for manual sampling of the boron concentration of the reactor coolant system is needtd to identify a boron dilution event. Therefore, the restrictions of the Tables 3.1-1 through 3.1-5 are intended to serve as an alternate I

means of protection for a boron dilution event when one or two boron dilution alarns are not available.

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TM licensee proposed that TS 3.1.2.9 contain two separate sets of restrictions to guard against a boron dilution event. The restrictions of Specification 3.1.2.9.a apply when two boron dilution alarms are operable. These restrictions are based on required operator response time after an alarm' consistent with SRP 15.4.6.

That is 15 minutes for Modes 3, 4, and 5 and 30 minutes for Mode 6.

When less than two boron dilutico alarms are operable. TS 3.1.2.9.b does not allow the plant to be operated in the configurations prohibited by Table 3.1-1 through 3.1-5.

These restrictions are based on the operator response time of SRP 15.4.6 plus an additional 30 minutes for sampling the boron concentration of the reactor coolant system. This part of the TS is essentially the same as the current TS 3.1.2.9.

In response to the staff request, the licensee in its letter dated f:ovember 1, 1989, provided the results of an analysis to support the revised TS 3.1.2.9.

The staff has reviewed the calculated times between alarr and 1 css of shutdown tuargin fer a postulated borch dilutien event during various operating moc'es and k values. The staff has concluded that the proposednewrestrictionsinN73.1.2.9.a meet the guidelines in SRP 15.4.6.

The revised 15 3.1.2.9.a will provide operational floxibility when the plant is trersitioning between Modes 3 and 2.

Also, it is consistent with the requirements of TS 3.1.2.4 which requires at least two charging pur.:ps crereble during Modes 1 through 4.

However, when one or two boror, dilution alarms are not operable and TS 3.1.2.9.b is in affect, the restr iction from Tables 3.1-1 through 3.1-5 was not consister,t with the requireraents of TS 3.1.2.4 Therefore, the staff recomends that ttc lice.isee (tnsider a change to TS 3.1.2.4 to define the applicability of TS 2.1.2.4 of Modes 1, 2, anc Modes 3, 4 when there are two boron diluticr.

elarrs operable.

In discussions with the licensee, this charge is not i.eeded at this tirce end a proposed amendment will te submitted in the future to correct the concern.

Based on the above evaluation, the staff concludes that proposed TS 3.1.2.9 is acceptable.

3.0 EX1 GENT CIRCUMSTANCES The conflict with the TS issued by Amendment No. 48, which would preclude reactor startup by deboration, was first discovered by reactor operators.

Discussions within the licensee organization began on correcting the conflict by license amendment but no immediate action was deemed necessary at that time. During a subsequent managerc.ent review, the licensee staff learned that the upcoming startup following the outgoing refueling would use deboration to reach criticality.

This method is best for determinirig certain physics parcneters for operation in Cycles 3 and 4 The license notified ttt i:PC staff cf the urgent need for the license amendment, arrenged a special Safety Review Cor.raittee meeting to approve the request, anc subraitted the proposed TS change promptly thereaf ter.

The licensee currently pier.s to

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enter Mode 2 on November 15, 1985 which will net allow the full 30 cays for con.n.ents on the proposed action. A delay in issuing the amendment will, on the current restart schedule, delay the restart.

4.0 FINALNO$1GNIFICAQHAZARDSCONSIDERATION The Commission's regulations in 10 CFR 50.92 state that the Connission nay make a final detern.ination that a license amendment involves no significant hazards consideration if the operation of the facility in accordance with the amendment would 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 f roni any accident previously evaluated; or (3)

Involve a significant reduction in a margin of safety.

The original analysis of the boren dilution accident for Weterford 3 and the Technical Specifications under which the facility was licensed incluttd provisions for operation with twc dilutior, elarms operable. Thit allowed initial reactor startup using baron dilution to establish physics paranteters.

Amendment 48 was issued in December 1988 to reduce conservatism and clarify monitoring frequencies but it in6dvertently dcleted the provisior.s which woulc' elicw startup by boron dilution, llith the dilution alares operable, the provisions change for charging pumps operable in going from l' ode 3 to Mode 2.

The staff's ar alysis and evaluation confirms that the proposed charges are within the bouncs of the eralysis that the plant was licensed under end that the accident ar.alysis with alarms operable does support the proposed changirg plant operations frorn liode 3 te flode 2.

Therefore, the change in Technical Specifications returned the plant tc the original licensing basis and preserves the analysis frcm Amendment a8.

The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. The borcn dilution accident has been evaluated and the change to return original license provisior.s tces not create the possibility of a new or different kind of accident from any accident previously evaluated.

Operation with dilution alarms operable and charging purrps in operation from Mode 3 to Mode 2 was approved for the original licensing of Waterford 3.

Amendment 48 inadvertently altered this provision. This proposed change corrects the Technical Specifications, preserves the SRP guidelines, and therefore, does not involve a significant reduction in a margin of safety.

On the basis of the above, the change to allow changing plant operation from Mode 3 to Mode 2 with dilution alarms operable does not involve a significant hazards consideration.

5.0 CONTACT WITH STATE OFFICIAL The NRC staff has advised the Administator, Nuclear Energy Divisict.,

Office of Environmental Affairs, State of Louisiana of the proposed deterr.ination of no significant hazards consideration.

No corrents were received.

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4 6.0 EllV1RON!! ENTAL CONSIDERATION The amendment relates to changes in requirements with respect to installaticn i

or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has determined that the amende.ent involves no significant increase in the amounts and no significant change I

in the types of any effluents tht.t may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Consnission has previously issued a proposed finding that this arnendment involves no significant hazards consideration i

and there has been no public comment on such finding. Accordingly, the L

arnendraent ineets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environraental irrpact stater.ent or environmental assesst.1ent need be prepared in connection with the issuance of this ame.ndment.

7.0 MgtllS10N Based upon its evalvetion of the proposed changes to the Waterford 3 Technical Specifications, the staff has concluded that:

there is reasen.

abit assurance that the health and safety of the public will not be endangered by operation in the proposed ear.ner,s regulations and the and such attivities will be conducted in cor..pliance with the Com.ission issuance c.f the amendtrent will not be ininical to the comn.on defenst and security or to the health and safety of the public. The staff, therefore, concluces that the proposed changer, are acceptable, and are hereby incorporated into the Waterford 3 Technical Sptcificaticris.

Dated:

November 14, 1989 Principal fontributor:

C. Liang D. Wigginton l

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