ML061280102

Core Operating Limits Report and Startup and Setpoint Transmittal for Cycle 14, Changes to Moderator Temperature Coefficient, Linear Heat Rate, Departure from Nuclear Boiling Rate Margin, Axial Shape Index, Revised Core Operating Limit

ML061280102
Person / Time
Site:	Waterford
Issue date:	05/10/2005
From:	Wiegert E Entergy Nuclear South
To:	Office of Nuclear Reactor Regulation
References
Download: ML061280102 (14)

Text

50.59 REVIEW FORM

l. OVERVIEW 1 SIGNATURES Facility: Waterford 3 Steam Electric Station Document Reviewed : Change/Rev .: N/A Waterford 3 Cycle 14 Core Operating Limits Report (COLR) [Westinghouse Letter NF-WTFD-05-25, ref. 4] and Startup Test and Set Points Transmittal for Waterford-3 Cycle 14 [Westinghouse Letter LTR-TAS-05-25, R1, ref.

5] described herein .

System Designator(s)/Description , NIA Description of Proposed Change:

Proposed Change Evaluated :

The COLR [ref. 4] and set points transmittal [ref. 5] document the operating limits and COLSSICPC set points that are necessary to preserve the design basis analyses and evaluations .

The impacted COLR sections are 3.1 .1 .3, Moderator Temperature Coefficient ; 3.2 .1, Linear Heat Rate; 3.2.4, DNBR Margin; and 3.2 .7, Axial Shape Index.

Changes to OP-903-001 and OP-500-010 to update AS[ limit information contained therein to the limits specified in the Waterford 3 Cycle 14 COLR .

Proposed Change Exempted:

The Technical Specification 6.9. 1 .11 .1 change, reflected in COLR Section III Methodologies, is listed in section II .A.5 of this 50.59 .

These changes were made to allow for alternate calculation methods for new fuel designs that are not yet incorporated into the Waterford 3 core. These methods would be required for the use of the Westinghouse APA neutronics code package to accommodate future fuel design features, like Zirconium Diboride (ZrB2) coating as the integral fuel burnable absorber (IFBA) and ZirloTm fuel rod cladding . This exemption depends on issuance of a T.S. based on License Amendment Request NPF-38-258 [ref. 8].

License Amendment 199 added two new methodologies that were utilized for Extended Power Uprate (EPU)

[ref. 7].

Cycle 14 Reload Changes The licensing basis impacts due to the fuel reload and analyses are covered under 50 .59 Evaluation 05-012.

This 50.59 evaluates the Core Operating Limit Report and COLSS/CPC set points required to preserve the design basis analyses and evaluations_

Core Operating Limits Report (COLR) Changes As a result of the Extended Power Uprate (EPU) [ref. 9] and Cycle 14 analyses, the COLR is being revised for Cycle 14 . The Cycle 14 COLR meets the requirements of Waterford 3 Technical Specification 6.9. 1 .11, The changes to T.S, 6_9 .1 .11 are methodology changes already approved for EPU or adopted for future cycles. The methodologies for future cycles are not used for the Cycle 14 set point analysis . The changes to the COLR for Cycle 14 are consistent with the requirements of ref . 4, which supports the analyses documented in the Reload Analysis Report (RAR) [ref. 3]. The changes for Cycle 14 are listed below:

Cycle 13 COLR Section or Figure CvcIe Section I List changes made to COLR for Cycle 14 Introduction 3.1 .1 .3 Figure 2 was changed to limit the most-negative hot Moderator Temperature Coefficient full power MTC to less ne ative than -3.9 x 10-4 A p/ °F LI-101-01, Rev . 7 Effective Date: 213105

50.59 REVIEW FORM Rage 2 of 14 Section 3 .2 .1 Section 3,2 .1 was revised to list the Linear Heat Rate Linear Heat Rate with COLSS in service as 12 .9 kwlft and the Linear Heat Rate with COLSS out of service as 13.2 kwlft Figure 6 Figure 6 was updated since the Linear Heat Rate for Allowable Peak Linear Heat Rate Versus To (COLSS Cycle 14 is 12 .9 kwlft and constant with temperature in Service with COLSS in Service Figure 7 Figure 7 was updated since the Linear Heat Rate for Allowable Peak Linear Heat Rate Versus To (COLSS Cycle 14 is 13.2 kwfff and constant with temperature Out of Service with COLSS Out of Service Section 3.2.4 Section 3.2.4_c was revised to allow use of Figure 9A DNBR Margin and notes below the text of Section 3 .2.4 for use with Figures 8, 8A, 9 & 9A were updated and new notes were added Figure 8 Figure 8, was revised to incorporate cycle-specific Allowable DNBR with Any CEAC Operable (COLSS limits for Cycle 14 Out of Service Figure 8A Figure 8A, was revised to provide better resolution for Subset of Allowable DNBR with Any CEAC Operable the four power ranges in the lower portion of Figure 8 COLSS Out of Service Figure 9 Figure 9, was revised to incorporate cycle-specific Allowable DNBR with No CEAC(s) Operable (COLSS limits for Cycle 14 Out of Service Figure 9A Figure 9A, was added to provide better resolution for Subset of Allowable DNBR with No CEAC(s) Operable the four power ranges in the lower portion of Figure 9 COLSS Out of Service Section 3.2.7 Section 3 .2.7 was revised to incorporate the new Axial Axial Shape Index Shape Index (ASI) limits required to support extended

. power u prate and the Cycle 14 COOS analysisSection I I I Section 111 .6 was revised to correct the document Methodologies number. Sections 111 .9 and 111 .10 were added in accordance with License Amendment 199 and sections 111 .11, 111 .12 and 111 .13 were added in accordance with License Amendment Request NPF-38-258 to support eventual adoption of Zirconium Diboride as an integral fuel burnable absorber and ZIRLOTM fuel rod cladding COLSSICPC Set Point Changes Certain events (such as Anticipated Operational Occurrences (AOOs) like CEA drops, single CEA deviations within the CPC dead band, and Excess Load with Loss of AC power) are analyzed to obtain the required overpower margin that needs to be set aside in COLSSICPC to prevent fuel failure . Requirements resulting from the transient analyses are input into the COLSSJCPC set points process and cycle-specific addressable constants are derived . The constants are modified prior to cycle startup to ensure that the provisio0s of the safety analyses are implemented for cycle operation . Ref. 5 transmitted the required COLSS/CPC addressable constant changes for Cycle 14, Summary of Major Reload Topics The Cycle 14 RAR (ref. 3) documents the analyses and assessments performed to demonstrate the acceptability of the Cycle 14 core design . This report was reviewed by Entergy personnel as required by NOECP-702, Waterford 3 Reload Process. Below are brief summaries of the purpose and results for the major areas of evaluation that require changes to the COLSSICPC set points or the COLR. Cited references are located at the end of this evaluation.

Physics Assessment Checklist (PAC)

LI-107-01, Rev . 7 Effective Date: 213105

The purpose of the physics assessment is to confirm that the physics parameters used in the Analyses of Record (AOR's) are applicable to Cycle 14. The primary elements that impact the physics assessment are the Cycle 14 specific core design characteristics .

There were three parameters that did not meet the PAC assessment and are resolved through the set point analysis and COLR.

1) The single CEA withdrawal parameters were not met in the PAC assessment. Sufficient margin (when the reactor is at 20%) to accommodate the single CEA withdrawal within dead band event was reserved as part of the Cycle 14 set point process. The Single CEA Withdrawal within Deadband impacted the DNBR COLR curves .

2) The core octant power asymmetry was not met in the PAC assessment. The impact of the cycle-maximum octant power asymmetry was addressed during the set point process .

3) The maximum pin burnup at MOC was not met. The COLR limit on linear heat rate was reduced to12.9 kW/ft for the entire cycle because of the presence of high exposure batch U assemblies that exceed 50,000 MWDIT at BOC. The linear heat rate with COLSS in service is limited to 12,9 kwift by the COLR.

Revised COLSS and CPC set points were determined in the set point analysis and are evaluated in this 50 .59 and will be implemented following approval per station procedures prior to the startup of Cycle 14.

Fuel Performance Analysis The purpose of the fuel performance analysis is to demonstrate acceptable fuel performance (e.g . rod internal pressure, power-to-melt, axial densification factor, etc.) for the Cycle 14 design and operating conditions. The reload process evaluates the applicability of the Fuel Performance AOR to Cycle 14. The fuel performance AOR supports a LOCA peak linear heat rate of 13.2 kW/ft through a rod average burnup of 50 GWd/MTU and a linear heat rate of 12.9 kWlft for rod average burnup above 50 GWd/MTU [section 4.5 ref. 3]. Due to bundles reaching this burnup during the beginning of the Cycle 14 the 12.9 kW/ft was used for the entire cycle .

Non-LOCH Safety Analysis The purpose of the non-LOCA safety analyses is to demonstrate that, for the Cycle 14 design and operating conditions, the consequences of various postulated Design Basis Events (DBE's) are acceptable . The reload process evaluates the applicability of the AOR's for the various DBE's to Cycle 14. The evaluation documents the key analysis inputs from the safety analysis ground rules [refs . 1 & 2], the bounding physics analysis, the bounding fuel performance analysis and the bounding thermal hydraulic analysis needed to validate the bounding non-LOCA analyses. The non-LOCA safety analysis impacts the DNBR COLR limits in order to ensure Required Over-Power Margin (ROPM) is preserved . The non-LOCA safety analysis credited the reduced operating range for ASI that is included in the COLR and set point evaluation.

Emergency Core Cooling System (ECCS) Performance Analysis An ECCS performance evaluation was performed for Cycle 14 to demonstrate conformance to the ECCS Acceptance Criteria for Light Water Nuclear Power Reactors. The ECCS performance analysis is comprised of the Large Break Loss of Coolant Accident (LBLOCA), Small Break Loss of Coolant Accident (SBLOCA) and post-LOCA Long Term Cooling (LTC) analyses. The ECCS performance analysis required that the linear heat rate be limited to less than 12.9 kw/ft when a rod average burnup exceeds 50 GWd/MTU . Also, the peak linear heat rate for the Large Break LOCA was revised to less than or equal to 12.9 kW/ft for extended power uprate.

The LOCA safety analysis credited the reduced operating range for ASI .

Check the applicable review(s) : (Only the sections indicated must be included in the Review.)

©' EDITORIAL CHANGE of a Licensing Basis Document Section I

© SCREENING Sections I and 11 required 50.59 EVALUATION EXEMPTION Sections 1, 11, and III required 50.59 EVALUATION (#: " C% ) Sections 1, 11, and IV required LI-101-01, Rev. 7 Effective Date; 213105

50 .59 REVIEW FORM Page 4 of 14 Preparer : E. C. Wie ertl fEOI-W31Nuclear Engineering/ ~-

Name (print) i Signature l Company 1 Department f Date Reviewer: D . E. Barr/ JEOI-ECH/HEAD PWR Fue ls/

Name (print) l Signaty;45-/ Compa OSRC: (;t C h Chairman's/Name rent) l Sign

[Required only for Programmatic, s and 5(3 .59 Evaluations .]

EI-101-01, Rev. 7 Effective Date: 213105

50.59 REVIEW FORM Page 5 of 14 I1. SCREENINGS A. Licensing Basis Document Review

1. Does the proposed activity impact the facility or a procedure as described in any of the following Licensing Basis Documents?

Operating License YES NO CHANGE # and/or SECTIONS IMPACTED E Operating License © N/A

© 1". , I NIA - License Amendment Request NPF-38-258 (ref. 8) has been submitted for change in TS 6 .9. 1 .111 NRC Orders U I0II NIA If "YES", obtain NRC approval prior to implementing the change by initiating an LBD change in accordance with NMM ENS-LI-113 . (See Section 5.2[131 for exceptions.)

LBDs controlled under 50.58 YES NO CHANGE # (if applicable) andlor SECTIONS IMPACTED FSAR © I N/A TS Bases [) NIA li Technical Requirements Manual © N/A Core Operating Limits Report 11 © Cycle 14 COLR Update NRC Safety Evaluation Report and [] NIA supplements for the initial FSAR' NRC Safety Evaluations for © N NIA amendments to the Operating License' If "YES", perform an Exemption Review per Section III OR perform a 30.59 Evaluation per Section IV OR obtain NRC approval prior to implementing the change . If obtaining NRC approval, document the LBD change in Section II.A.6; no further 50.59 review is required . However, the change cannot be implemented until approved by the NRC. AND initiate an LBD change in accordance with NMM ENS-LI-113.

LBDs controlled under other YES NO CHANGE # (if applicable) and/or SECTIONS regulations IMPACTED Quality Assurance Program Manual © 1ti NIA Emergency Plan' 2,3

© NIA Fire Protection Program 3A '11 N/A (includes the Fire Hazards Analysis)

Offsite Dose Calculations Manual3' 4 © II N/A If "YES", evaluate any changes in accordance with the appropriate regulation AND initiate an LBD change in accordance with NMM ENS>>LI-113. No further 50.59 review is required .

' If "YES," see Section 5 .2[5] . No LBD change is required .

Z If "YES," notify the responsible department and ensure a 503 .54 Evaluation is performed . Attach the 50.54 Review.

3 Changes to the Emergency Plan, Fire Protection Program, and Offsite Dose Calculation Manual must be approved by the OSRC in accordance with NMM OM-119.

If "YES," evaluate the change in accordance with the requirements of the facility's Operating License Condition or under 50 .59, as appropriate .

1-1-101 -01, Rev . 7 Effective Date: 2/3/05

50 .59 REVIEW FORM Page 6 of 14

2. Does the proposed activity involve a test or experiment not described in the FSAR? © Yes No If "yes," perform a 50.59 Evaluation per Section IV OR obtain NRC approval prior to implementing the change AND initiate an LBD change in accordance with NMM I..I-113.

If obtaining NRC approval, document the change in Section II.A.6; no further 50.58 review is required . However, the change cannot be implemented until approved by the NRC.

3. Basis Explain why the proposed activity does or does not impact the Operating License/Technical Specifications and/or the FSAR and why the proposed activity does or does not involve a new test or experiment not previously described in the FSAR. Discuss other LBDs if impacted. Adequate basis must be provided within the Screening such that a third-party reviewer can reach the same conclusions . Simply stating that the change does not affect TS or the FSAR is not an acceptable basis .

Operat 4 License (Operating License, Technical Specifications, NRC Orders)

The Cycle 14 COLR and COLSS/CPC set points ensure that adequate margin is maintained to address the accident AOR's for the Cycle 14 core. A review of the proposed EPU Waterford 3 Operating License determined that the information in the license is not impacted by the Cycle 14 COLR or COLSS/CPC set points. The Cycle 14 core design and analyses results meet the EPU Technical Specification requirements. Safety Limits, Limiting Safety Settings and Limiting Conditions of Operation governing the operation of the EPU design core [ref. 91 are bounding for the Cycle 14 core.

A License Amendment Request (NPF-38-258) to revise 6.9.1 .11 .1 will be incorporated to allow future flexibility in core designs and will be addressed under Section III for 50.59 exemptions.

License Amendment 199 requires the addition of two methodologies to Section 5.9.1 .11 .1 and is addressed under Section III for 50 .59 exemptions.

NRC Confirmatory Orders and Immediate Orders were reviewed and determined that these documents do not address core reload details or other specific information addressed in the Cycle 14 COLSS/CPC set points or COLR.

LBDs Controlled Under 50 .58 (FSAR, TS Bases, TRM, COLR, NRC SERs)

Revisions to the Waterford 3 Updated FSAR (UFSAR) were identified and made under the closely related Reload Analysis Report 50.59 Evaluation [ref. 6] for Cycle 14 changes .

No TS Bases changes or TRM changes were necessary due to Cycle 14 reload activities .

The Cycle 14 COLR provides the spedfic reload related operational limits for the Cycle 14 core. Technical Specification 6.9-1 .11 requires that the COLR be revised for each core reload .

The results of the Cycle 14 COLSS/CPC set points and COLR are consistent with the requirements in NRC SERs for Waterford 3_ The changes to COLSSICPC set points and COLR ensure the core is operated such that the AOR requirements are met .

LBDs Controlled Under Other Regulations Reload analyses inputs and results are not addressed in the QAPM, E-Plan, Fire Protection Program and the ODCM. Based on this, no changes to these documents are required to support the Cycle 14 RAR .

TEST OR EXPERIMENT LI-101-01, Rev . 7 Effective Date: 2/3105

The determination and adoption of Cycle 14 COLSS/CPC set points and the COLR will be implemented in accordance with station procedures and Technical Specifications . Therefore, the Cycle 14 COLSSICPC set points and COLR do not constitute a test or experiment.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION Waterford 3 does not have an Independent Spent Fuel Storage Facility.

4. References Discuss the methodology for performing LBD searches . State the location of relevant licensing document information and explain the scope of the review such as electronic search criteria used (e.g ., key words) or the general extent of manual searches per Section 5.5 .1[5](d) of Ll-1©1 . NOTE : Ensure that manual searches are performed using controlled copies of the documents. If you have any questions, contact your site Licensing department .

LBDsfDocuments reviewed via keyword search : Keywords:

LBDS-50_59 (Group) Reload (47 hits), safety analysis (221 hits), safety analyses (8¬l hits), nuclear fuel (25 hits), region T (6 hits), region U (1 hit), region W (0 hits), batch (56 hits),

batches (56 hits), active core (8 hits), core height (7 hits), Cycle 13 (9 hits), lead test assemblies (0 hits),

moderator temperature coefficient (0 hits), MTC (32 hits), COLR (26 hits), Core Operating Limits Report (21 hits), COLSS (60 hits), CPC (104 hits)

LBDsfDocuments reviewed manually :

Performed a manual review of UFSAR Chapters 4, 6, 7, 9 and 15; Technical Specifications; the Operating License ; Technical Requirements Manual ; and EPU documentation associated with License Amendment Request NPF-38-249

5. Is the validity of this Review dependent on any other change? Yes

© No If "YES", list the required changes/submittals . The changes covered by this 50.59 Review cannot be implemented without approval of the other identified changes (e.g., license amendment request) . Establish an appropriate notification mechanism to ensure this action is completed .

This 5(3.59 is dependent on:

1 . Approval of License Amendment Request NPF-38-258 to TS 6.9.1 .11 .1 . (Commitment Management System A26697)

LI-101-01, Rev . 7 Effective Date: 213105

50.59 REVIEW FORM Page 8of14 B. ENVIRONMENTAL . SCREENING if any of the following questions is answered "yes, an Environmental Review must be performed in accordance with NMM Procedure ENS-EV-115, "Environmental Evaluations," and attached to this 50.59 Review . Consider both routine and non-routine (emergency) discharges when answering these questions .

Will the proposed Change being evaluated :

Yes No

1. © Z Involve a land disturbance of previously disturbed land areas in excess of one acre (i.e.,

grading activities, construction of buildings, excavations, reforestation, creation or removal of ponds)?

2. 0 Involve a land disturbance of undisturbed land areas (i .e., grading activities, construction, excavations, reforestation, creating, or removing ponds)?

3. © Involve dredging activities in a lake, river, pond, or stream?

4. Increase the amount of thermal heat being discharged to the river or lake?

5. Increase the concentration or quantity of chemicals being discharged to the river, lake, or air?

6. Discharge any chemicals new or different from that previously discharged?

7. Change the design or operation of the intake or discharge structures?

8. Modify the design or operation of the cooling tower that will change water or air flow characteristics?

9. © Modify the design or operation of the plant that will change the path of an existing water discharge or that will result in a new water discharge?

Modify existing stationary fuel burning equipment (i .e., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

11 . © involve the installation of stationary fuel burning equipment or use of portable fuel burning equipment (i.e., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

12. Q Involve the installation or use of equipment that will result in a new or additional air emission discharge?

13. © Involve the installation or modification of a stationary or mobile tank?

Involve the use or storage of oils or chemicals that could be directly released into the environment?

Involve burial or placement of any solid wastes in the site area that may affect runoff, surface water, or groundwater?

' See NMM Procedure ENS-EV-117, "Air Emissions Management Program," for guidance in answering this question .

LI-101-01, Rev . 7 Effective Date: 213105

50 .59 REVIEW FORM Page 9 of 14 C. SECURITY PLAN SCREENING If any of the following questions is answered "yes,  a Security Plan Review must be performed by the Security Department to determine actual impact to the Plan and the need for a change to the Plan.

Could the proposed activity being evaluated :

Yes No

© Add, delete, modify, or otherwise affect Security department responsibilities (e.g .,

including fire brigade, fire watch, and confined space rescue operations)?

2. 94 Result in a breach to any security barrier(s) (e .g ., HVAC ductwork, fences, doors, walls, ceilings, floors, penetrations, and ballistic barriers)?

3. Q 0 Cause materials or equipment to be placed or installed within the Security Isolation Zone?

4. FOR Affect (block, move, or alter) security lighting by adding or deleting lights, structures, buildings, or temporary facilities?

5. ot Modify or otherwise affect the intrusion detection systems (e .g ., E-fields, microwave, fiber optics)?

6. © Modify or otherwise affect the operation or field of view of the security cameras?

7. © Modify or otherwise affect (block, move, or alter) installed access control equipment, intrusion detection equipment, or other security equipment?

8, © Modify or otherwise affect primary or secondary power supplies to access control equipment, intrusion detection equipment, other security equipment, or to the Central Alarm Station or the Secondary Alarm Station?

9. F Modify or otherwise affect the facility's security-related signage or land vehicle barriers, including access roadways?

10. © Modify or otherwise affect the facility's telephone or security radio systems?

Documentation for accepting any "yes" statement for these reviews will be attached to this 50.59 Review or referenced below .

L1-101-01, Rev. 7 Effective Date: 213/05

50.59 REVIEW FORM Page 1 0 of 14 Ill . 50 .59 EVALUATION EXEMPTION Enter this section only if a "yes" box was checked in Section II.A.1 .

A. Check the applicable boxes below. If any of the boxes are checked, clearly document the basis in Section 111 .13, below . If none of the boxes are appropriate, perform a 50.59 Evaluation in accordance with Section IV. Provide supporting documentation or references as appropriate.

The proposed activity meets all of the following criteria regarding design function per Section 5.5[1](a) :

The proposed activity does not adversely affect the design function of an SSC as described in the FEAR; AND The proposed activity does not adversely affect a method of performing or controlling a design function of an SSC as described in the FSAR; AND The proposed activity does not adversely affect a method of evaluation that demonstrates intended design function(s) of an SSC described in the FSAR will be accomplished.

© An approved, valid 50.59 Review(s) covering associated aspects of the proposed activity already exists per Section 5.5[1](b) . Reference 50.59 Evaluation # (if applicable) or attach documentation. Verify the previous 50.59 Review remains valid .

The NRC has approved the proposed activity or portions thereof per Section 5 .511](c) .

Reference:

License Amendment Request NPF-38-258 for TS 6.9.1 .1 1 .1 fret: 8], License Amendment 199

[ref. 7] .

B. Basis LI-101-01, Rev. 7 Effective Date: 213/05

50 .59 REVIEW FORM Page 11 of 14 Provide a clear, concise basis for determining the proposed activity may be exempted such that a thin[-party reviewer can reach the same conclusions .

Changes to Section iii of the COLR to add new methodologies are exempted from 50.59 due to NRC review and approval of this change . The License Amendment Request (NPF-38-258) explicitly requests that three methodologies be approved and the title for one existing methodology be revised for Waterford 3:

"Implementation of ZIRLO Material Cladding in CE Nuclear Power Fuel Assembly Designs," CENPD-444-P-A (Methodology for Specification 3 .1 .1 .3 for MTC, 3.2.1 for Linear Heat Rate, 3.2.3 for Azimuthal Power Tilt, and 3 .2.7 for ASI).

"Qualification of the PHOENIX-P/ANC Nuclear Design System For Pressurized Water Reactor Cores," WCAP-11596-P-A ; "ANC: A Westinghouse Advanced Nodal Computer Code," WCAP-14965-P-A, and "ANC: A Westinghouse Advanced Nodal Computer Code: Enhancements to ANC Rod Power Recovery," WCAP-10965-P-A Addendum 1 . (Methodology for Specifications 3 .1 .1 .1 and 3.1 .1 .2 for Shutdown Margins, 3.1 .1.3 for MTC, 3.1 .3 .6 for Regulating and group P CEA Insertion Limits, 3.1 .2.9 Boron Dilution (Calculation of CBC and IBW), and 3.9.1 Boron Concentration) .

° Qualification of the Two-Dimensional Transport Code PARAGON," WCAP-76045-P-A (Methodology for Specifications 3.1 .1 .1 and 3 .1 .1 .2 for Shutdown Margins, 31 for MTC, 3.1 .3.6 for Regulating and group P CEA Insertion Limits, 3.1 .2.9 Boron Dilution (Calculation of CBC & IBW), and 3 .9.1 Boron Concentration) .

Revise TS 6_9 .1 .11 .1 item 6 to correct the title of the analytical method, "CESEC - Digital Simulation for a Combustion Engineering Nuclear Steam Supply System,"

License Amendment 199 requires the addition of the following methodologies :

"Technical Description Manual for the CENTS Code, WCAP-15996-P-A. (Methodology for Specification 3 .1 .1 .1 and 3 .1 .1 .2 for Shutdown Margins, 3 .1 .1 .3 for MTC, 3.1 .3.1 for Movable Control Assemblies - CEA Position, 3.1 .3 .6 for Regulating and Group P CEA Insertion Limits, and 3.2 .3 for Azimuthal Power Tilt) .

"Calculatioe Methods for the CE Nuclear Power Large Break LOCA Evaluation Model," CENPD-132, Supplement 4-P-A. (Methodology for Specification 3.1 .1 .3 for MTC, 3.2 .1 for Linear Heat Rate, 3.2 .3 for Azimuthal Power Tilt and 3 .2.7 for ASI).

LI-101-01, Rev. 7 Effective Date: 2/3105

50 .59 REVIEW FORM Page 12 of 14 IV. 50 .59 EVALUATION icense Amendment Determination Does the proposed Change being evaluated represent a change to a method of evaluation © Yes ONLY? If "Yes, Questions 1 - 7 are not applicable; answer only Question 8. If "No," answer No all questions below.

Does the proposed Change:

1. Result in more than a minimal increase in the frequency of occurrence of an accident © Yes previously evaluated in the FSAR? No BASIS : (references cited are at the end of the evaluation)

The COLR and COLSSICPC set points are not accident initiators . The COLR and set points ensure that the plant is operated in a manner that is consistent with the Cycle 14 safety analysis. Therefore, the frequency of occurrence of an accident previously evaluated in the FSAR will not be increased due to the installation and operation of the Cycle 14 core using the updated COLR and COLSS/CPC set points .

2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a © Yes structure, system, or component important to safety previously evaluated in the FSAR? No BASIS : (references cited are at the end of the evaluation)

The nuclear design for Cycle 14 was accomplished using NRC approved analysis methodologies under approved quality assurance programs . The Cycle 14 fuel and core designs will not degrade the performance of any safety system assumed to function in the safety analyses, nor will these changes decrease the reliability of safety systems .

The Cycle 14 COLR and COLSS/CPC set points do not involve a change in seismic requirements, separation criteria, environmental qualification, or single failure criteria for any plant system, structure, or component. Equipment redundancy and independence will not be affected, and no physical protection features will be modified . Additional loads will not be imposed on any safety or support system .

The analyses used to determine the margin requirements that need to be preserved by the COLR for Cycle 14 were evaluated under Extended Power Uprate [5] and the Cycle 14 Reload Analysis Report [6] . The changes in the COLR and COLSS/CPC set points are required to ensure that the plant is operated in a manner consistent with the Cycle 14 safety analyses . Operation of the plant in accordance with the assumptions used for the safety analysis will not increase the likelihood of occurrence of a malfunction previously evaluated in the SAR .

Based on the discussion above, there is no characteristic of the Cycle 14 COLR or COLSS/CPC set points that would increase the probability of a malfunction of equipment important to safety_ Therefore, the likelihood of an occurrence of a malfunction of an SSC important to safety is not increased .

3. Result in more than a minimal increase in the consequences of an accident previously © Yes evaluated in the FSAR? No BASIS : (references cited are at the end of the evaluation)

As a result of the Cycle 14 core reload, there will be no new pathways to the environment created for radioactive material release . The equipment designed to either mitigate the radiological consequences of an accident, or control the release of radioactive material will not be affected .

The increase in thermal power and the increase in energy content of the core were addressed as part of EPU and are included in the PU AOR's . All LOCH and non-LOCA transients have been evaluated for Cycle 14 [ref. 3] and the results were found acceptable . The evaluations included the Next Generation Fuel (NGF) Lead Test Assemblies (LTA's) in non-limiting core locations . All events were found to be bounded by the EPU AOR's . The COLR and set points established by the set point analysis ensure that the previously evaluated accidents remain bounding so that there is not an increase in consequences.

LI-101-01, Rev . 7 Effective Date: 213/05

50.59 REVIEW FORM Page 13 of 14 The functions of equipment designed to either mitigate the radiological consequences of an accident, or control the release of radioactive material, will not be adversely affected . The COLR and COLSS/CPC set points were determined to ensure that the consequences of an accident are bounded by the AOR's.

Based on the above, the consequences of accidents previously evaluated in the FSAR will not be increased due to installation and operation of the Cycle 14 core using the updated COLR and COLSS/CPC set points .

4. Result in more than a minimal increase in the consequences of a malfunction of a structure, © Yes system, or component important to safety previously evaluated in the FSAR? No BASIS : (references cited are at the end of the evaluation)

The Cycle 14 COLR and CPCICOLSS set points require no physical equipment modifications . The Cycle 14 COLR and COLSS/CPC set points do not involve a change to events associated with missiles or flooding . Equipment important to safety will function in the same manner with the Cycle 14 reload core using the updated COLR and COLSS/CPC set points as with the EPU design core. The function and duty of the equipment important to safety is not altered . No changes in the assumptions concerning equipment availability or failure modes have been made.

The update of the COLR and COLSS/CPC set points ensure that the AOR's remain bounding .

Thus, the consequences of a malfunction of a SSC important to safety are not increased by the changes associated with the Cycle 14 reload .

5. Create a possibility for an accident of a different type than any previously evaluated in the © Yes FSAR? No BASIS : (references cited are at the end of the evaluation)

Installation and operation of the Cycle 14 core using the Cycle 14 COLR and COLSSICPC set points does not introduce an accident initiator or potential single failure not already considered in the Updated FSAR.

The nuclear design was accomplished using NRC-approved analysis methodologies under approved quality assurance programs . The Cycle 14 reload core will not result in changes to the radiological release rate/duration, will not create new release mechanisms, and will not impact radiation release barriers . There are no new system interactions or connections resulting from the Cycle 14 COLR and COLSS/CPC set points nor is it necessary to modify the design, function, or operation of any equipment or to install new equipment.

There were no changes in the failure modes of equipment important to safety as a result of the design and analyses associated with the Cycle 14 COLR and COLSS/CPC set point update. No initiators for any of the accidents already postulated are impacted by the Cycle 14 COLR and COLSS/CPC set points .

Therefore, operation of Waterford 3 with the Cycle 14 COLR and COLSS/CPC set points will not cause an accident of a different type than any previously evaluated in the FSAR.

Create a possibility for a malfunction of a structure, system, or component important to safety Yes with a different result than any previously evaluated in the FSAR? No BASIS : (references cited are at the end of the evaluation)

As stated previously, the Cycle 14 COLR and COLSS/CPC set points require no physical equipment modifications . The update of the COLR and COLSS/CPC set points is made to ensure that equipment important to safety will function in the same manner assumed for the Cycle 14 reload core as with the previous core. There are no new modes of failure associated with any of the changes identified previously in this evaluation for Cycle 14. The set points established by the set point analyses ensure the conclusions of the Cycle 14 RAR and necessary margin requirements are met.

Based on the above, the possibility of a malfunction of a SSC important to safety having a different result than any previously evaluated will not be created due to the fuel management, reload fuel assembly design changes, and other reload-related changes necessary to operate Cycle 14.

L.I-101-01, Rev. 7 Effective Date : 213106

50 .55 REVIEW FORM Page 1 4 of 14

7. Result in a design basis limit for a fission product barrier as described in the FSAR being © Yes exceeded or altered? No BASIS : (references cited are at the end of the evaluation)

The Cycle 14 core meets all required design and functional requirements . The design of the Cycle 14 reload was accomplished using NRC-approved analysis methodologies under approved quality assurance programs . The reload design process has considered all required postulated events and found there to be bounded by the AOR's . The COLR and COLSSICPC set points established by the set point analysis ensure the conclusions of the Cycle 14 RAR and necessary margin requirements are met.

Based on a review of the reload analysis results, the Updated FSAR, and the Waterford 3 TS Bases, no design basis limit for a fission product barrier will be exceeded for Cycle 14 .

8. Result in a departure from a method of evaluation described in the FSAR used in establishing © Yes the design bases or in the safety analyses? Z No BASIS : (references cited are at the end of the evaluation)

In accordance with Technical Specification 6.9,1 .11 .1, the Cycle 14 core was designed and evaluated using NRC-approved analysis methodology under an approved quality assurance program . For Cycle 14, the methodologies used were consistent with the EPU submittal which has been approved by the NRC [ref.

7]. No new methodologies were required to verify that the EPU AOR's are applicable to Cycle 14 or to perform any cycle-specific evaluations . In addition, the COLSS 1 CPC set points and Cycle 14 COLR required for Cycle 14 operation were determined using the same approved methods .

Therefore, there has been no deviation from the methods of evaluation described in the FSAR and Technical Specification 6.9.1 .11 .1 .

If any of the above questions is checked "YES", obtain NRC approval prior to implementing the change by initiating a change to the Operating License in accordance with NMM Procedure ENS-LI-113 .

References I. Entergy Letter W3C1-2004-0013, "Waterford-3 Cycle 14 3716 Power Uprate Groundrules,, J.B . Holman to J .M.

Betancourt, December 16, 2004.

2. Calculation ECS03-001, Rev . B, "Waterford-3 3716 MWt Power Uprate Groundrule&"

3. Westinghouse Letter NF-WTFD-05-1, "Waterford-3, Cycle 14 Final Reload Analysis Report (RAR)," J .M. Betancourt to J .B. Holman, January 24, 2005, 4, Westinghouse Letter NF-WTFD-05-25, "Waterford 3 Cycle 14 Core Operating Limits Report (COLR)," J.M.

Betancourt to D.E. Barr, April 15, 2005

5. Westinghouse Letter LTR-TAB-05-25, R1, "Startup Test and Setpoints Transmittal for Waterford-3 Cycle 14," J .M.

Betancourt to D.E. Barr,, April 15, 2005 .

6. Waterford 3 50.59 Evaluation 05-012, "Cycle 14 Reload Analysis Report and Next Generation Fuel Lead Test Assemblies."

7. NRC Letter, License Amendment 199, "Waterford Steam Electric Station Unit 3 -- Issuance of Amendment RE:

Extended Power Uprate (TAC No. MC 1355)," N. Kalyanarn to J.E. Venable, April 15, 2005.

8. Entergy Letter W317 1-2004-0036, "License 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," J.E. Venable to NRC, June 17,2004 .

9. LR-W3-2401-1149-000, "Extended Power Uprate."

10. Entergy Letter W3C12005-0016, "Refueling Boron Concentration Requirement (Mode 6)," C.L . Alday to R.J.

Madjerich, April 11, 2005.

11 . Entergy Letter CEO-2405-00057, "WSES-3 Refueling Boron Concentration during RF013," M.R. McKinney to C.L.

Alday, April 8, 2005.

LI>>101-01, Rev. 7 Effective Date: 213105