ML081820010

Request for Additional Information License Amendment Request to Modify Requirements Regarding Control Room Envelope Habitability

ML081820010
Person / Time
Site:	Waterford
Issue date:	07/11/2008
From:	Kalyanam N NRC/NRR/ADRO/DORL/LPLIV
To:	Entergy Operations
Kalyanam N, NRR/DORL/LPL4, 415-1480
References
TAC MD6547
Download: ML081820010 (5)

Text

July 11, 2008 Vice President, Operations Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST (LAR)

TO MODIFY REQUIREMENTS REGARDING CONTROL ROOM ENVELOPE HABITABILITY (TAC NO. MD6547)

Dear Sir/Madam:

By letter dated August 16, 2007, Entergy Operations, Inc. (Entergy, the licensee), submitted an application for a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) to modify requirements regarding control room envelope habitability.

The NRC staff has reviewed the application and has determined that:

• The proposed amendment is not consistent with the NRC approved Industry/Technical Specification Task Force (TSTF) change to the Standard Technical Specifications (STS), TSTF-448, Revision 3, "Control Room Habitability."

• The additional information contained in the enclosure is needed to complete the review:

NRC discussed the need for additional information with Entergy staff by telephone and Entergy agreed to provide a response within 30 days of the receipt of this letter.

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

Sincerely,

/RA Jack Donohew for/

N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382 cc: See next page

ML081820010 *No major change from Staff provided RAI OFFICE NRR/LPL4/PM NRR/LPL4/PM NRR/DIRS/ITSB NRR/LPL4/BS (A) NRR/LPL4/PM NAME NKalyanam JND for GLappert RElliott (*) BSingal NKalyanam JND for DATE 7/11/08 7/10/08 6/23/08 7/11/08 7/11/08 Waterford Steam Electric Station, Unit 3 (2/25/08) cc:

Senior Vice President Mr. Timothy Pflieger Entergy Nuclear Operations Environmental Scientist - Supervisor P.O. Box 31995 REP&R-CAP-SPOC Jackson, MS 39286-1995 Louisiana Department of Environmental Quality Vice President, Oversight P.O. Box 4312 Entergy Nuclear Operations Baton Rouge, LA 70821-4312 P.O. Box 31995 Jackson, MS 39286-1995 Parish President Council St. Charles Parish Senior Manager, Nuclear Safety P.O. Box 302

& Licensing Hahnville, LA 70057 Entergy Nuclear Operations P.O. Box 31995 Chairman Jackson, MS 39286-1995 Louisiana Public Services Commission P.O. Box 91154 Senior Vice President Baton Rouge, LA 70825-1697

& Chief Operating Officer Entergy Operations, Inc. Mr. Richard Penrod, Senior Environmental P.O. Box 31995 Scientist/State Liaison Officer Jackson, MS 39286-1995 Office of Environmental Services Northwestern State University Associate General Counsel Russell Hall, Room 201 Entergy Nuclear Operations Natchitoches, LA 71497 P.O. Box 31995 Jackson, MS 39286-1995 Resident Inspector Waterford NPS Manager, Licensing P.O. Box 822 Entergy Operations, Inc. Killona, LA 70057-0751 Waterford Steam Electric Station, Unit 3 17265 River Road Regional Administrator, Region IV Killona, LA 70057-3093 U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011

OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION WATERFORD STEAM ELECTRIC STATION, UNIT 3 TSTF-448 LICENSE AMENDMENT REQUEST

1. Please explain how partial adoption of U.S. Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force (TSTF)-448, Rev. 3, will ensure that the Technical Specifications (TS) will contain adequate Surveillance Requirements (SR) per Title 10 of the Code of Federal Regulations (10 CFR) 50.36(d)(3).

Background:

10 CFR 50.36(d)(3) states that TS will include SR which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

Proposed SR 4.7.6.1.g is equivalent to SR 3.7.11.4 (CE Plants) in NRC approved TSTF-448, Rev. 3, Control Room Habitability. SR 3.7.11.4 in TSTF-448, Rev. 3 contains a Bases discussion that provides amplifying information on the evaluation criteria used for the SR and also provides amplifying information on the TS actions that are carried out when the evaluation criteria is not met. This amplifying information ensures that the SR is conducted in a manner such that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met per 10 CFR 50.36(d)(3). The proposed SR 4.7.6.1.g does not contain the Bases discussion as found in TSTF-448, Rev. 3, therefore it is unclear how SR 4.7.6.1.g will meet 10 CFR 50.36(d)(3).

2. Describe which portions of the Control Room Air Conditioning System are applicable to the limiting conditions of operations (LCO) 3.7.6.1, Control Room Emergency Air Filtration Trains (S-8), and which portions are applicable to proposed LCO 3.7.6.5, Control Room Air Isolation and Intake Valves, in order to ensure that actions listed in the LCOs continue to meet 10 CFR 50.36(d)(2)(i).

Background:

10 CFR 50.36(d)(2)(i) states TS will include LCO which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the condition can be met. LCO 3.7.6.1, Control Room Emergency Air Filtration Trains (S-8) and LCO 3.7.6.5, Control Room Isolation and Pressurization Boundaries, are retained in the TS in order to ensure that 10 CFR 50.36(d)(2)(i) is met.

LCO 3.7.6.1, Control Room Emergency Air Filtration Trains (S-8) currently applies to only the Control Room Emergency Air Filtration Trains (S-8) of the Control Room Air Conditioning System. LCO 3.7.6.5, Control Room Isolation and Pressurization Boundaries, applies to the Control Room Envelope (CRE) and also applies to portions of the Control Room Air Conditioning System that provide isolations for the CRE.

The LAR proposes to modify LCO 3.7.6.5, Control Room Isolation and Pressurization Boundaries, by changing it to LCO 3.7.6.5, Control Room Air Isolation and Intake Valves, and moves the CRE operability requirements (except the isolation valves) to LCO 3.7.6.1, Control Room Emergency Air Filtration Trains (S-8). LCO 3.7.6.1, Control Room Emergency Air Filtration Trains (S-8), now has operability requirements for the CRE, but the LCO still only states two Control Room Emergency Air Filtration Trains (S-8) shall be operable. Based on LCO 3.7.6.1 remaining the same, it is unclear if the portion of the Control Room Air Conditioning System that consists of the Control Room Emergency Air Filtration Train (S-8) has now been expanded. Referring to FSAR figure 9.4-3, Reactor Auxiliary Building Ventilation Systems, or figure 6.4-1, Control Room Air Conditioning System Normal Operating Mode, discuss which portions of the Control Room Air Conditioning System are applicable to LCO 3.7.6.1, Control Room Emergency Air Filtration Trains (S-8), and which portions are applicable to LCO 3.7.6.5, Control Room Air Isolation and Intake Valves. Having an understanding of how portions of the Control Room Air Conditioning System are divided between LCOs 3.7.6.1 and 3.7.6.5 is needed in order to ensure that actions listed in the LCOs are appropriate, thereby ensuring that the lowest functional capability or performance levels of equipment required for safe operation of the facility is met per 10 CFR 50.36(d)(2)(i).

3. It is unclear as to whether approval of this amendment would ensure that 10 CFR 50.36(d)(2)(i) would continue to be met. Explain how actions a, b, and c of LCO 3.7.6.5 will result in immediate or steady state conditions with unfiltered air inleakage lower than the assumed flow rate in the licensing basis analyses of DBA consequences.

Background:

The LAR proposes to modify LCO 3.7.6.5, Control Room Isolation and Pressurization Boundaries, by changing it to LCO 3.7.6.5, Control Room Air Isolation and Intake Valves, and modifies and moves the CRE operability requirements (except the isolation valves) to LCO 3.7.6.1, Control Room Emergency Air Filtration Trains (S-8). The proposed actions for an inoperable CRE that are modified and relocated to LCO 3.7.6.1 are consistent with TSTF-448, Rev. 3. The proposed actions and SR verify that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, mitigating actions are taken.

However, actions a, b, and c of LCO 3.7.6.5 remain the same. It is unclear if actions a, b, and c will result in immediate or steady state conditions with unfiltered air inleakage greater than the assumed flow rate in the licensing basis analyses of design basis accidents (DBA) consequences, which could result in the lowest functional capability or performance levels of equipment required for safe operation of the facility not being met per 10 CFR 50.36(d)(2)(i).