W3F1-2005-0017, Supplement to Amendment Request NPF-38-258 to Modify Technical Specification (TS) 5.3.1, Fuel Assemblies and TS 6.9.1.11.1, Core Operating Limits Report Waterford Steam Electric Station, Unit 3

Supplement to Amendment Request NPF-38-258 to Modify Technical Specification (TS) 5.3.1, Fuel Assemblies and TS 6.9.1.11.1, Core Operating Limits Report Waterford Steam Electric Station, Unit 3

ML050700215
Person / Time
Site:	Waterford
Issue date:	03/08/2005
From:	Harris A Entergy Nuclear South, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2005-0017
Download: ML050700215 (6)

Text

Entergy Nuclear South Entergy Operations, Inc.

Etr 17265 River Road Killona, LA 70057-3093

=- En~tergy Tel 504-739-6475 Fax 504-739-6698 aharris@entergy.com Alan J. Harris Director, Nudear Safety Assuranoe W3Fl -2005-0017 Waterford 3 March 8, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Supplement to Amendment Request NPF-38-258 To Modify Technical Specification (TS) 5.3.1, Fuel Assemblies and TS 6.9.1.11.1, Core Operating Limits Report Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCES:

1. Waterford 3 letter to the NRC dated June 20, 2004, License Amendment Request to Modify Technical Specification (TS) 5.3.1, Fuel Assemblies and TS 6.9.1.11.1, Core Operating Limits Report (W3F1 -2004-0036)

Dear Sir or Madam:

By letter (Reference 1), Entergy Operations, Inc. (Entergy) proposed a change to the Waterford Steam Electric Station, Unit 3 (Waterford 3) Technical Specifications (TSs) that in part included a request to delete the Index from the TSs.

On March 3, 2005, Entergy and members of your staff held a call to discuss the proposed deletion of the Index. As a result of the call, five questions were determined to need formal response. Entergy's response is contained in Attachment 1.

Entergy requests that the proposed changes to TS 5.3.1 and TS 6.9.11.1 continue to be processed to support the upcoming refueling outage and that the change to delete the Index be deferred, if required.

There are no technical changes proposed. The original no significant hazards consideration included in Reference 1 is not affected by any information contained in the supplemental letter. There are no new commitments contained in this letter.

If you have any questions or require additional information, please contact Dana Millar at 601-368-5445.

AD°I

W3Fl -2005-0017 Page 2 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on March 8, 2005.

Sincerely, r

AJH/DM/cbh

Attachment:

1. Response to Request for Additional Information I

W3F1 -2005-0017 Page 3 of 3 cc: Dr. Bruce S. Mallett U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Senior Resident Inspector Waterford 3 P.O. Box 822 Killona, LA 70066-0751 U.S. Nuclear Regulatory Commission Attn: Mr. Nageswaran Kalyanam MS 0-7D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway Attn: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn Attn: N.S. Reynolds 1400 L Street, NW Washington, DC 20005-3502 Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division P. O. Box 4312 Baton Rouge, LA 70821-4312 American Nuclear Insurers Attn: Library Town Center Suite 300S 29th S. Main Street West Hartford, CT 06107-2445

Attachment 1 To W3FI-2005-0017 Response to Request for Additional Information

. I Attachment 1 to W3F1 -2005-0017 Page 1 of 2 Response to Request for Additional Information Related to License Amendment Request to Modify Technical Specification (TS) 5.3.1, Fuel Assemblies and TS 6.9.1.11.1, Core Operating Limits Report Question 1:

The requested amendment is to delete the TS Index. The markup shows the Table of Contents (TOC) as deleted. Please clarify change request.

Response 1:

The markup shows the 'Index" will be deleted. Waterford Steam Electric Station, Unit 3 (Waterford 3) does not have a heading labeled uTable of Contents" on the pages that were proposed for deletion; "Index" is the heading on these pages. Therefore, the proposed change is to delete the uIndex."

The intent of the proposed change was to delete the Index and maintain it under a licensee controlled program such that changes could be made to the TS Index without NRC review and approval. The holders of copies of the TS will receive periodic updates of the TS Index pages. The Index update and distribution would be handled in a manner similar to the TS Bases update and distribution. The TS Bases Control Program is included in the Waterford 3 TS (TS 6.16).

Question 2:

Without a TOC, how will a user of the TS know where in the TS are the requirements that the user wants to read? How will this effect controlled copies in the control room and those distributed to plant personnel, resident inspectors and regional staff?

Response 2:

The user of the TS will continue to have an Index as outlined in the response to question 1.

Periodic updates of the Index pages will be provided as outlined in response to question 1.

Question 3:

What will be the benefit to the licensee, NRC, and general public in removing the TS Table of Contents? Are there any license amendment precedents for eliminating TS TOCs? Does the NEI Writer's Guide specify guidance for including a TOC for technical specifications?

Response 3:

Removal of the TS Index from the 10 CFR 50.90 review process will eliminate unnecessary expenses and time related to the processing and handling of these administrative / non-to W3Fl -2005-0017 Page 2 of 2 technical changes. The proposed change would be benefit neutral to the general public since they would continue to have access to an Index.

Entergy is not aware of any license amendment precedents for eliminating the TS Table of Contents or Index, however, when Grand Gulf and Arkansas Nuclear One, Unit 1 converted to the Improved Standard TSs, both were issued by the NRC without a Table of Contents.

Both plants created and maintain a Table of Contents and periodically provide updated pages to the controlled copy holders.

The Improved Standard Technical Specification Writer's guide includes guidance on how to format the Table of Contents page. The Writer's guide refers to the Table of Contents as

'Technical Specification Front Matter," which also includes the Title Page and List of Effective Pages. The Writer's guide describes the Technical Specification content as starting with Chapter 1, "Use and Application" and does not include the Table of Contents as part of the content of the TSs.

Question 4:

How would the licensee communicate to the NRC staff, Resident Inspectors, Regional staff and general public numbering changes made to TS sections in the event that the TOC is eliminated?

Response 4:

Please see the response to question 1. Additionally, any numbering changes made on any TS page in TS Sections 1 through 6 would require a license amendment request in accordance with 10 CFR 50.90 which would be distributed as previously described.

Question 6:

Did you consider only eliminating the page numbers and leaving the TOC of the TSs in place?

Response 5:

Entergy intended to maintain the pages with periodic updates and did not consider only eliminating the page numbers.