ML043080365

RAI Related to Revision to Facility Operating License and TSs - Extended Power Uprate Request

ML043080365
Person / Time
Site:	Waterford
Issue date:	10/29/2004
From:	Kalyanam N NRC/NRR/DLPM/LPD4
To:	Venable J Entergy Operations
Kalyanam N,NRR/DLPM,415-1480
References
TAC MC1355
Download: ML043080365 (5)

Text

October 29, 2004 Mr. Joseph E. Venable Vice President Operations Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 (WATERFORD 3) -

REQUEST FOR ADDITIONAL INFORMATION RELATED TO REVISION TO FACILITY OPERATING LICENSE AND TECHNICAL SPECIFICATIONS -

EXTENDED POWER UPRATE REQUEST (TAC NO. MC1355)

Dear Mr. Venable:

By application dated November 13, 2003, and supplemented by letters dated January 29, March 4, April 15, May 7, May 12, May 13, May 21, May 26, July 14, July 15, July 28, August 10, August 19, August 25, September 1, September 14, October 8 (2 letters),

October 13, October 18, and October 19, 2004, Entergy Operations, Inc., requested changes to the Facility Operating License and Technical Specifications for the Waterford Steam Electric Station, Unit 3, which would allow an increase in the rated thermal power from 3,441 megawatts thermal (MWt) to 3,716 MWt.

After reviewing your request, the Nuclear Regulatory Commission staff has determined that additional information is required in the area of "Steam Generator Pressure - Low" trip setpoints to complete the review. We discussed this information with your staff by telephone and they agreed to provide the additional information requested in the enclosure within 15 days of receipt of this letter.

If you have any questions, please call me at (301) 415-1480.

Sincerely,

/RA/

N. Kalyanam, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosure:

Request for Additional Information cc w/encl: See next page

October 29, 2004 Mr. Joseph E. Venable Vice President Operations Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 (WATERFORD 3) -

REQUEST FOR ADDITIONAL INFORMATION RELATED TO REVISION TO FACILITY OPERATING LICENSE AND TECHNICAL SPECIFICATIONS -

EXTENDED POWER UPRATE REQUEST (TAC NO. MC1355)

Dear Mr. Venable:

By application dated November 13, 2003, and supplemented by letters dated January 29, March 4, April 15, May 7, May 12, May 13, May 21, May 26, July 14, July 15, July 28, August 10, August 19, August 25, September 1, September 14, October 8 (2 letters),

October 13, October 18, and October 19, 2004, Entergy Operations, Inc., requested changes to the Facility Operating License and Technical Specifications for the Waterford Steam Electric Station, Unit 3, which would allow an increase in the rated thermal power from 3,441 megawatts thermal (MWt) to 3,716 MWt.

After reviewing your request, the Nuclear Regulatory Commission staff has determined that additional information is required in the area of "Steam Generator Pressure - Low" trip setpoints to complete the review. We discussed this information with your staff by telephone and they agreed to provide the additional information requested in the enclosure within 15 days of receipt of this letter.

If you have any questions, please call me at (301) 415-1480.

Sincerely,

/RA/

N. Kalyanam, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION PUBLIC PDIV-1 r/f RidsOgcRp RidsAcrsAcnwMailCenter RidsNrrDlpmLpdiv1 (DJaffe) RidsNrrPMNKalyanam RidsNrrLADJohnson RidsRgn4MailCenter (AHowell) AMarinos/HLi RidsNrrDlpmDpr RidsNrrDeDpr RidsNrrDssaDpr Accession No.: ML043080365

• RAI input from the staff without any major change OFFICE PDIV-1/PM PDIV-1/LA DE/EEIB/A* PDIV-1/SC(A)

NAME NKalyanam DJohnson AMarinos/HLi DJaffe for MWebb DATE 10/28/04 10/28/04 10/25/04 10/29/04 OFFICIAL COPY

REQUEST FOR ADDITIONAL INFORMATION ENTERGY OPERATIONS, INC. (ENTERGY)

WATERFORD STEAM ELECTRIC STATION, UNIT 3 (WATERFORD 3)

DOCKET NO. 50-382 The NRC Staff has determined that setpoint Allowable Values (AV) established by means of Instrument Society of America (ISA) 67.04 Part 2 Method 3 do not provide adequate assurance that a plant will operate in accordance with the assumptions upon which the plant safety analyses have been based. These concerns have been described in various public meetings.

The presentation used in public meetings in June and July 2004 to describe the staff concerns is available on the public website under ADAMS Accession Number ML041810346. (Note:

Public access to ADAMS has been temporarily suspended so that security reviews of publicly available documents may be performed and potentially sensitive information removed. Please check the NRC Web site for updates on the resumption of ADAMS access.)

Staff is currently formulating generic action on this subject. It is presently clear, however, that staff will not be able to accept any requested Technical Specification (TS) changes that are based upon the use of Method 3, unless the method is modified to alleviate the staff concerns.

In particular, each setpoint limit in the TSs must ensure at least 95 percent probability with at least 95 percent confidence that the associated action will be initiated with the process variable no less conservative than the initiation value assumed in the plant safety analyses. In addition, the operability of each instrument channel addressed in the setpoint-related TSs must be ensured by the TSs. That is, conformance to the TSs must provide adequate assurance that the plant will operate in accordance with the safety analyses. Reliance on settings or practices outside the TSs and not mandated by them is not adequate.

Staff has determined that AV computed in accordance with ISA Method 1 or 2 do provide adequate assurance that the safety analysis limits will not be exceeded. Staff has also determined that an entirely different approach, based upon the performance of an instrument channel rather than directly upon the measured trip setting, can also provide the required assurance. This alternative approach, designated Performance-Based TSs, sets limits on acceptable nominal setpoints and upon the observed deviation in the measured setpoint from the end of one test to the beginning of the next. This approach has been accepted for use at R. E. Ginna Nuclear Power Plant, and is discussed in a Safety Evaluation (SE) available via ADAMS Accession Number ML041180293. The referenced SE is specific to Ginna, and is cited here only as a general example for other plants. It is up to the licensee to modify the approach as necessary to meet the indicated objectives for the particular plant(s) in question. In addition, licensees are welcome to propose alternative approaches that provide the indicated confidence, but such tentative approaches must be presented in detail and must be shown explicitly to provide adequate assurance that the safety analysis assumptions will not be violated.

The Nuclear Energy Institute (NEI) has indicated an intent to submit a white paper concerning this matter for NRC consideration. Receipt of that white paper is anticipated in late October or early November 2004. Licensees may choose to endorse whatever approach and justification is described in that white paper, or to act independently of the NEI. If the NEI approach is

found to be acceptable to the staff, it will be necessary for each licensee who chooses to use it to affirm that the salient conditions, practices, etc. described in it are applicable to their individual situations.

Please indicate how you wish to proceed in regard to the "Steam Generator Pressure - Low" trip setpoint because this parameter has setpoint changed due to power uprate application.

Following are some examples of acceptable actions:

1. Demonstrate that the approach that you have used to develop the proposed limits provides adequate assurance that the plant will operate in accordance with the safety analyses. Show that Operability is ensured in the TS.

2. Suspend consideration of setpoint-related aspects of your request pending generic resolution of the staff concern.

3. Revise your request to incorporate Method 1, Method 2, or Performance-Based TS.

4. Revise your request to incorporate some other approach that you demonstrate to provide adequate confidence that the plant will operate in accordance with the safety analyses and show that Operability is ensured in the TSs.

Waterford Steam Electric Station, Unit 3 cc:

Mr. Michael E. Henry, State Liaison Officer Regional Administrator, Region IV Department of Environmental Quality U.S. Nuclear Regulatory Commission Permits Division 611 Ryan Plaza Drive, Suite 1000 P.O. Box 4313 Arlington, TX 76011 Baton Rouge, Louisiana 70821-4313 Parish President Council Vice President, Operations Support St. Charles Parish Entergy Operations, Inc. P. O. Box 302 P. O. Box 31995 Hahnville, LA 70057 Jackson, MS 39286-1995 Executive Vice President Director & Chief Operating Officer Nuclear Safety Assurance Entergy Operations, Inc.

Entergy Operations, Inc. P. O. Box 31995 17265 River Road Jackson, MS 39286-1995 Killona, LA 70066-0751 Chairman Wise, Carter, Child & Caraway Louisiana Public Services Commission P. O. Box 651 P. O. Box 91154 Jackson, MS 39205 Baton Rouge, LA 70825-1697 General Manager Plant Operations Waterford 3 SES Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751 Licensing Manager Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751 Winston & Strawn 1400 L Street, N.W.

Washington, DC 20005-3502 Resident Inspector/Waterford NPS P. O. Box 822 Killona, LA 70066-0751 July 2003