W3F1-2012-0019, Response to Request for Additional Information, License Amendment Request to Revise Technical Specification 3/4.7.4 Table 3.7-3, Ultimate Heat Sink Minimum Fan Requirements Per Train

Response to Request for Additional Information, License Amendment Request to Revise Technical Specification 3/4.7.4 Table 3.7-3, Ultimate Heat Sink Minimum Fan Requirements Per Train

ML12095A308
Person / Time
Site:	Waterford
Issue date:	04/03/2012
From:	Jacobs D Entergy Nuclear South, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2012-0019
Download: ML12095A308 (5)

Text

Entergy Nuclear South Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504 739 6660 Fax 504 739 6678 SEntergy Djacob2@entergy.com Donna Jacobs Vice President, Operations Waterford 3 W3F1-2012-0019 April 3, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to Request for Additional Information, License Amendment Request to revise Technical Specification 3/4.7.4 Table 3.7-3, "Ultimate Heat Sink Minimum Fan Requirements per Train" Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

References:

1. Waterford 3 Letter W3F1 -2011-0067, License Amendment Request, Proposed Change to Technical Specification 3/4.7.4 Table 3.7-3, "Ultimate Heat Sink Minimum Fan Requirements per Train" (ADAMS Accession No. ML11290A009) dated September 21, 2011.

2. Waterford 3 Letter W3F1-2011-0082, Supplement to License Amendment Request, Proposed Change to Technical Specification 3/4.7.4 Table 3.7-3, "Ultimate Heat Sink Minimum Fan Requirements per Train" (ADAMS Accession No. ML113290070) dated November 25, 2011.

3. Waterford 3 Letter W3F1-2012-0004, Calculations Requested for License Amendment Request, Proposed Change to Technical Specification 3/4.7.4 Table 3.7-3, "Ultimate Heat Sink Minimum Fan Requirements per Train" (ADAMS Accession No. ML12023A080) dated January 18, 2012.

4. NRC E-mail Correspondence, Request for Additional Information, Kaly Kalyanam (Project Manager) to William J. Steelman (Licensing Manager)

Waterford, Unit 3, (ADAMS Accession Nos. ML120580729 and ML120580738) dated February 28, 2012.

Dear Sir or Madam:

By letter dated October 13, 2011, as supplemented by letters dated November 25, 2011, and January 18, 2012 (References 1, 2, and 3), Entergy Operations, Inc. (Entergy) made application to amend the Technical Specifications (TS) 3/4.7.4 Table 3.7-3, "Ultimate Heat Sink Minimum Fan Requirements Per Train." of the Waterford Steam Electric Station, Unit 3 (Waterford 3).

W3F17-2012-0019 Page 2 In Reference 4, the NRC staff made a Request for Additional Information (RAI) to answer a question they had regarding the validity of an equation used in a calculation that had been provided in Reference 3.

While considering the response to the RAI regarding the proposed change to Technical Specification Table 3.7-3, Waterford 3 obtained the services of a cooling tower expert to review the NRC question and provide an independent analysis. The cooling tower expert has preliminarily confirmed that the original calculation ECM95-009 method of determining the impact of taking wet cooling tower fans out-of-service uses a Cooling Tower Institute (CTI) equation that is not intended for that purpose. The equation correlates cooling tower performance to the cube root of the ratio of actual fan horsepower to design fan horsepower.

The cooling tower industry expert confirmed that the equation is intended to be used for comparing design performance to test performance where small changes in fan horsepower were measured. It was not intended to predict tower performance where total fan horsepower is reduced by large amounts.

Waterford 3 has entered this condition into the corrective action process (Condition Report CR-WF3-2012-1395) to identify the misapplication of the CTI equation. For the current configuration with all 8 wet cooling tower fans operable, the wet cooling towers are capable of performing their design basis function. The CTI equation misapplication only impacts the calculated performance capacity of the wet cooling tower with fans out-of-service.

Waterford 3 will provide a supplement to Reference 1 to ensure a conservative revised specification within the next 30 days. The corrective action program will be utilized to correct the Waterford 3 calculations and determine if additional actions are needed.

This submittal contains one new commitment as summarized in Attachment 1.

Please contact William Steelman, Licensing Manager, at 504-739-6685 if there are any comments regarding this response I declare under penalty of perjury that the foregoing is true and correct. Executed on April 3, 2012.

Sincerely, DJ/RJA

Attachment:

1. Regulatory Commitment

W3F1-2012-0019 Page 3 cc: Mr. Elmo E. Collins, Jr. RidsRgn4MailCenter@nrc.gov Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.

Arlington, TX 76011-4125 NRC Senior Resident Inspector Marlone.Davis@nrc.gov Waterford Steam Electric Station Unit 3 Dean. Overland@nrc.gov P.O. Box 822 Killona, LA 70057-0751 U. S. Nuclear Regulatory Commission Kaly.Kalyanam@nrc.gov Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Louisiana Department of Environmental Ji.Wiley@LA.gov Quality Office of Environmental Compliance Emergency and Radiological Services Division P. 0. Box 4312 Baton Rouge, LA 70821-4312

Attachment 1 To W3F1-2012-0019 Regulatory Commitment to W3F1-2012-0019 Page 1 of 1 Regulatory Commitment The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED ONE- CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)

Waterford 3 will provide a supplement to Reference X May 2, 2012 1 to ensure a conservative revised specification with the next 30 days.