ML12278A331
| ML12278A331 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/20/2012 |
| From: | Kalyanam N Plant Licensing Branch IV |
| To: | Entergy Operations |
| Kalyanam N | |
| References | |
| TAC ME7614 | |
| Download: ML12278A331 (22) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 20, 2012 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 - ISSUANCE OF AMENDMENT RE: RELOCATING TECHNICAL SPECIFICATIONS TO THE TECHNICAL REQUIREMENTS MANUAL (TAC NO. ME7614)
Dear Sir or Madam:
The Commission has issued the enclosed Amendment No. 238 to Facility Operating License No. NPF-38 for the Waterford Steam Electric Station, Unit 3 (Waterford 3). This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated November 21,2011, as supplemented by letter dated November 26,2012.
The amendment relocates TS 3.4.6, "Chemistry," TS 3.7.5, "Flood Protection," TS 3.7.9, "Sealed Source Contamination," and TS 3.9.5, "Communications," to the Waterford 3 Technical Requirements Manual.
A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely, N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosures:
- 1. Amendment No. 238 to NPF-38
- 2. Safety Evaluation cc w/encls: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENTERGY OPERATIONS, INC.
DOCKET NO. 50-382 WATERFORD STEAM ELECTRIC STATION. UNIT 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 238 License No. NPF-38
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Entergy Operations, Inc. (EOI),dated November 21, 2011, as supplemented by letter dated November 26, 2012, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2
- 2.
Accordingly. the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.2 of Facility Operating License No. NPF-38 is hereby amended to read as follows:
- 2.
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A. as revised through Amendment No. 238. and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
This license amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
~(.,A.J'~
Michael T. Markley. Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Facility Operating License No. NPF-38 and Technical Specifications Date of Issuance:
December 20, 2012
ATTACHMENT TO LICENSE AMENDMENT NO. 238 TO FACILITY OPERATING LICENSE NO. NPF-38 DOCKET NO. 50-382 Replace the following pages of the Facility Operating License and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Facility Operating License REMOVE INSERT -4 Technical Specifications REMOVE INSERT 3/44-21 3/44-21 3/44-22 3/44-22 3/44-23 3/44-23 3/47-15 3/47-15 3/47-27 3/47-27 3/47-28 3/47-28 3/4 9-5 3/4 9-5
-4 or indirectly any control over (i) the facility, (ii) power or energy produced by the facility, or (iii) the licensees of the facility.
Further, any rights acquired under this authorization may be exercised only in compliance with and subject to the requirements and restrictions of this operating license, the Atomic Energy Act of 1954, as amended, and the NRC's regulations. For purposes of this condition, the limitations of 10 CFR 50.81, as now in effect and as they may be subsequently amended, are fully applicable to the equity investors and any successors in interest to the equity investors, as long as the license for the facility remains in effect.
(b)
Entergy Louisiana, LLC (or its designee) to notify the NRC in writing prior to any change in (i) the terms or conditions of any lease agreements executed as part of the above authorized financial transactions, (ii) any facility operating agreement involving a licensee that is in effect now or will be in effect in the future, or (iii) the existing property insurance coverages for the facility, that would materially alter the representations and conditions, set forth in the staffs Safety Evaluation enclosed to the NRC letter dated September 18,1989. In addition, Entergy Louisiana, LLC or its designee is required to notify the NRC of any action by equity investors or successors in interest to Entergy Louisiana, LLC that may have an effect on the operation of the facility.
C.
This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
- 1.
Maximum Power Level EOI is authorized to operate the facility at reactor core power levels not in excess of 3716 megawatts thermal (100% power) in accordance with the conditions specified herein.
- 2.
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 238, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
AMENDMENT NO. 238
THIS PAGE HAS BEEN DELETED.
WATERFORD - UNIT 3 3/44-21 AMENDMENT NO. 238
THIS PAGE HAS BEEN DELETED.
WATERFORD - UNIT 3 3/44-22 AMENDMENT NO. 238
THIS PAGE HAS BEEN DELETED.
WATERFORD - UNIT 3 3/44-23 AMENDMENT NO. 238
THIS PAGE HAS BEEN DELETED.
WATERFORD - UNIT 3 3/47-15 AMENDMENT NO. 238
THIS PAGE HAS BEEN DELETED.
WATERFORD - UNIT 3 3/47-27 AMENDMENT NO. 238
THIS PAGE HAS BEEN DELETED.
WATERFORD - UNIT 3 3/47-28 AMENDMENT NO. 238
THIS PAGE HAS BEEN DELETED.
WATERFORD - UNIT 3 3/4 9-5 AMENDMENT NO. 238
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 238 TO FACILITY OPERATING LICENSE NO. NPF-38 ENTERGY OPERATIONS, INC.
WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382
1.0 INTRODUCTION
By application dated November 21,2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11326A283), as supplemented by letter dated November 26, 2012 (ADAMS Accession No. ML12332A069), Entergy Operations, Inc. (the licensee), requested changes to the Technical Specifications (TSs) for Waterford Steam Electric Station, Unit 3 (Waterford 3). Specifically, the proposed amendment would relocate TS 3.4.6, "Chemistry," TS 3.7.5, "Flood Protection," TS 3.7.9, "Sealed Source Contamination," and TS 3.9.5, "Communications," to the Waterford 3 Technical Requirements,Manual (TRM).
The supplemental letter dated November 26,2012, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on April 17, 2012 (77 FR 22814).
2.0 REGULATORY EVALUATION
Section 182a of the Atomic Energy Act of 1954, as amended (the Act), requires applicants for nuclear power plant operating licenses to incorporate TSs as part of the license. The NRC's regulatory requirements related to the content of TSs are set forth in Section 50.36, "Technical specifications," of Title 10 of the Code of Federal Regulations (10 CFR), which states that TSs are required to include items in the following five specific categories related to station operation:
(1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) deSign features; and (5) administrative controls. The regulations in 10 CFR 50.36(b) state that TSs will be derived from the analyses and evaluation included in the safety analysis report.
- 2 The regulations in 10 CFR 50.36(c)(2)(ii) state that A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria:
(A) Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
(8) Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
(C) Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
(D) Criterion 4. A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
The NRC's guidance for the content of TSs is stated in its "Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors" (Final Policy Statement) published in the Federal Register on July 22, 1993 (58 FR 39132). In the Final Policy Statement, the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a of the Act. In particular, the Commission indicated that certain items could be relocated from the TSs to licensee-controlled documents.
The NRC's guidance for the format and content of licensees' TSs are stated in NUREG-1432, Revision 3, "Standard Technical Specifications Combustion Engineering Plants" (STS),
June 2004 (ADAMS Accession No. ML041830597).
3.0 TECHNICAL EVALUATION
3.1 Proposed TS Changes
In its letter dated November 21, 2011, the licensee proposed to relocate the following TSs to Waterford 3's TRM:
TS 3.4.6, "Chemistry" TS 3.7.5, "Flood Protection" TS 3.7.9, "Sealed Source Contamination" TS 3.9.5, "Communications"
- 3 3.1.1 TS 3.4.6, "Chemistry" The licensee proposed to replace the current contents of TS pages 3/44-21, 3/44-22, and 3/44-23 with a statement that reads "This page has been deleted."
3.1.2 TS 3.7.5, "Flood Protection" The licensee proposed to replace the current contents of TS pC1ge 3/4 7-15 with a statement that reads "This page has been deleted."
3.1.3 TS 3.7.9, "Sealed Source Contamination" The licensee proposed to replace the current contents of TS pages 3/4 7-27 and 3/4 7-28 with a statement that reads "This page has been deleted."
3.1.4 TS 3.9.5, "Communications" The licensee proposed to replace the current contents of TS page 3/4 9-5 with a statement that reads "This page has been deleted."
3.2
NRC Staff Evaluation
3.2.1 TS 3.4.6, "Chemistry" In support of its conclusion that current TS 3.4.6 does not meet 10 CFR 50.36(c)(2)(ii)
Criterion 1, the licensee stated in its letter dated November 21, 2011, in part, that:
Criterion 1 refers to installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. While poor chemistry control can lead to a more rapid degradation of the primary materials, this type of degradation is a long-term process; furthermore, poor Reactor Coolant System (RCS) chemistry control is a cause of, not a detector or indicator of RCS degradation. The inservice inspections required by 10CFR50.55a and the RCS leakage limits are examples of requirements provided to monitor degradation of the RCS boundary materials.
Therefore, TS 3.4.6 does not meet Criterion 1 for inclusion in the TSs.
While the NRC staff agrees with the licensee's conclusion that TS 3.4.6 does not meet Criterion 1 for inclusion in the TSs, the staff disagrees with the licensee's reasoning. The licensee asserts that poor RCS chemistry control is the cause of, but not a detector of, corrosion. However, the staff concludes that the corrosion is a chemical reaction between materials of construction and the environment and occurs with absolute certainty when all conditions are fully known. Therefore, RCS water, which is outside the specification limits, is both the cause of, and an indicator of, corrosion.
The NRC staff does, however, agree with the licensee's conclusion that corrosion monitoring instrumentation is not normally installed so as to continuously "indicate in the control room" and, when compared to other issues which merit LCOs, corrosion occurs at a suffiCiently slow rate so
-4 as not to meet the criterion of "a significant abnormal degradation of the reactor coolant pressure boundary." Based on the above, the NRC staff concludes that TS 3.4.6 does not meet Criterion 1 for inclusion in the TSs.
In support of its contention that current TS 3.4.6 does not meet 10 CFR 50.36(c)(2}(ii)
Criterion 2, the licensee stated in its letter dated November 21, 2011, in part, that:
Criterion 2 refers to a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. Neither reactor coolant chlorides, fluorides, nor dissolved oxygen are assumed as initial conditions for any design basis accident that would present a challenge to the integrity of any fission product barrier. While reactor coolant chemistry is important to the maintenance of the integrity of the RCS, the degradation caused by poor water chemistry control occurs long term.
Therefore, TS 3.4.6 does not meet Criterion 2 for inclusion in the TSs.
Because the chemistry of the reactor coolant is not an initial condition for any design-basis accident, the NRC staff agrees with the licensee's statements and analysis in support of its conclusion that TS 3.4.6 does not meet Criterion 2 for inclusion in the TSs. Based on the above, the NRC staff concludes that TS 3.4.6 does not meet Criterion 2 for inclusion in the TSs.
In support of its conclusion that current TS 3.4.6 does not meet 10 CFR 50.36(c)(2)(ii)
Criterion 3, the licensee stated in its letter dated November 21, 2011, in part, that:
Criterion 3 refers to a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. Reactor coolant system chemistry is not part of the primary success path in the mitigation of a design basis accident or transient. Therefore, TS 3.4.6 does not meet Criterion 3 for inclusion in the TSs.
The chemistry of the reactor coolant is not a part of the primary success path in the mitigation of a design-basis accident or transient, the NRC staff agrees with the licensee's statements and analysis in support of its contention that TS 3.4.6 does not meet Criterion 3 for inclusion in the TSs. Based on the above, the NRC staff concludes that TS 3.4.6 does not meet Criterion 3 for inclusion in the TSs.
In support of its conclusion that current TS 3.4.6 does not meet 10 CFR 50.36(c)(2)(ii)
Criterion 4, the licensee stated in its letter dated November 21, 2011, in part, that:
Criterion 4 refers to a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. Neither of these criteria are applicable to limits on reactor coolant chlorides, fluorides, or dissolved oxygen. Therefore, TS 3.4.6 does not meet either Criterion 4 for inclusion in the TSs.
- 5 Because neither the operating experience nor probabilistic risk assessment is applicable to the limits on the reactor coolant chemistry, the NRC staff agrees with the licensee's statements and analysis in support of its conclusion that TS 3.4.6 does not meet Criterion 4 for inclusion in the TSs. Based on the above, the NRC staff concludes that TS 3.4.6 does not meet Criterion 4 for inclusion in the TSs.
RCS chemistry TS 3.4.6 describes an acceptable method for maintaining water purity levels in the reactor coolant in order to ensure that degradation of the reactor coolant pressure boundary is not exacerbated by poor chemistry conditions. However, degradation of the reactor coolant pressure boundary is generally a long-term process and other direct means to monitor and correct reactor coolant pressure boundary degradation exist, which are controlled by regulations and other plant TSs. For example, inservice inspection of components and primary coolant leakage limits are regulatory requirements that provide direct means to identify degradation of the reactor coolant pressure boundary. Therefore, requirements related to the chemistry program do not constitute initial conditions that are assumed in any design-basis accident or transient related to RCS integrity.
Additionally, the NRC staff notes that this TS is absent from the STS in NUREG-1432, Revision 3, which have been approved by the staff, for Combustion Engineering plants and from all but two (St. Lucie and Waterford 3) of the individual plant TSs for Combustion Engineering plants.
Based on the above, the NRC staff concludes that current TS 3.4.6 does not meet any of the four technical criteria set forth in 10 CFR 50.36(c)(2)(ii) and, as the screening criteria have not been satisfied, the Reactor Coolant System Chemistry LCO and Surveillances may be relocated to the Waterford 3 TRM.
3.2.2 TS 3.7.5, "Flood Protection" The LCO, Applicability, and SR in TS 3.7.5 ensure that facility protective actions will be taken in the event of flood conditions. The LCO is when the water level in the Mississippi river exceeds
+27.0 feet Mean Sea Level (MSL).
The NRC staff has reviewed whether there is a regulatory basis to approve the licensee's request if it fails to meet the four criteria contained in 10 CFR 50.36(c)(2)(ii). Consideration of whether TS 3.7.5 meets these criteria is discussed below.
The flood protection ensures that the safety-related equipment is protected. The flood protection is not a detector or indicator of RCS degradation. The abnormal degradation of the reactor coolant pressure boundary is monitored by other means such as inservice inspection and RCS leakage limits. Therefore, TS 3.7.5 does not meet Criterion 1 for inclusion in the TSs.
The Final Policy Statement defines the design-basis accident or transients as that contained in the Updated Final Safety Analysis Report (UFSAR) Chapters 6 and 15.
During its review, the NRC staff noticed that the application mentioned a non-conservatism related to flooding but it did not provide any details. Concerned that the current level of flood protection that was based on older analysis may no longer be adequate, the NRC staff issued a
- 6 request for additional information (RAI) on November 5, 2012 (ADAMS Accession No. ML12310A458) regarding the non-conservative flood related issue The licensee in its response dated November 21, 2012, stated that the non-conservatism mentioned in the application was with respect to the implementation of flood protection actions.
This issue was previously identified in the NRC Problem Identification and Resolution (PI&R)
Inspection Report dated July 12, 2010 (ADAMS No. ML101930439). The licensee clarified that the issue of non-conservatism was not related to any changes in the flood analysis. The licensee also clarified that there were no changes in the flood analysis which would have required re-evaluating flood protection.
Based on this clarification, the NRC staff concludes that the flood protection actions are not an initial condition for any design-basis accident and, therefore, would not present a challenge to the integrity of any fission product barrier. Additionally, the flood-related issues are in UFSAR Chapters 2 and 3. Therefore, TS 3.7.5 does not meet Criterion 2 for inclusion in the TSs.
The mitigation of a design-basis accident or transient is not dependent on the flood protection.
Therefore, TS 3.7.5 does not meet Criterion 3 for inclusion in the TSs.
On June 28,1991, the NRC issued Generic Letter (GL) 88-20, Supplement 4, "Individual Plant Examination of External Events (lPEEE) for Severe Accident Vulnerabilities" (ADAMS Accession No. ML031150485), and NUREG-1407, "Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities:
Final Report," June 1991 (ADAMS Accession No. ML063550238). This generic letter requested all licensees to (1) perform I PEEEs to identify plant-specific vulnerabilities to external events that could lead to severe accidents, and (2) report the results to the NRC together with any licensee-determined improvements and corrective actions. By letter dated July 28, 1995 (not publicly available), the licensee submitted its response for Waterford 3, which stated, in part, that The IPEEE found no high winds, floods, or off-site industrial facility accidents that significantly alters the Waterford 3 estimate of either the core damage frequency, or the distribution of containment release categories.
The NRC's safety evaluation dated July 27,2000 (not publicly available), for the Waterford 3 IPEEE, stated, in part, that The plant's licensing basis is the 1975 SRP [standard review plan], therefore, based on the guidance in NUREG-1407, external floods can be screened out as a significant hazard. However, the licensee has reassessed the effects of...,
(2) probable maximum flood including levee failure, and (3) probable maximum precipitation (PMP). The licensee has performed a confirmatory plant outdoor walkdown to identify building doors and penetrations that might be vulnerable to postulated external floods. The three flood hazard reevaluations and the walkdown did not identify any plant vulnerability to external flooding or moisture intrusion. The licensee used the latest rainfall data in Hydro Meteorological Report No. 52 for this PMP evaluation. The licensee did not find any roof ponding or site drainage-related vulnerabilities.
- 7 Based on the above, all of the high winds, floods, transportation, and other external events were dropped from further consideration and judged to not be a significant contributor to the total core damage frequency. Based upon these current risk insights, TS 3.7.5 does not meet Criterion 4 for inclusion in the TSs. Additionally, based on the response to the RAI (letter dated November 5, 2012), there were no changes in the flood analysis which would invalidate the conclusions reached in the IPEEE report mentioned above.
Based on the above, the NRC staff concludes that current TS 3.7.5 does not meet any of the four technical criteria set forth in 10 CFR 50.36(c)(2)(ii) and. since the screening criteria have not been satisfied. the Flood Protection LCO and Surveillances may be relocated to the Waterford 3 TRM.
3.3.3 TS 3.7.9, "Sealed Source Contamination" The limitations on removable contamination for sources requiring leak testing. including alpha emitters. is based on 10 CFR 70.39(c) limits for plutonium. This limitation will ensure that leakage from byproduct. source, and special nuclear material sources will not exceed allowable intake values. These limits are not related to operation or safe shutdown of the plant.
The inservice inspections required by 10 CFR 50.55a and the RCS leakage limits are examples of requirements provided to monitor degradation of the RCS boundary materials. The limitations on removable contamination for sources do not play any part in the monitoring of the abnormal degradation of the reactor coolant pressure boundary either during operation or before a design-basis accident. Therefore, TS 3.4.6 does not meet Criterion 1 for inclusion in the TSs.
The status of a process variable or the monitoring of a process variable. design feature, or operating restriction that is an initial condition of a design-basis accident or transient is not dependent or based on the limitations on sealed sources containing radioactive material.
Therefore. TS 3.7.9 does not meet Criterion 2 for inclusion in the TSs.
The primary success path in the mitigation of a DBA or transient is not dependent on or based on the limitations on sealed sources containing radioactive material. Therefore. TS 3.7.9 does not meet Criterion 3 for inclusion in the TSs.
Neither operating experience nor probabilistic risk assessment is applicable to limitations on sealed sources containing radioactive material. Therefore, TS 3.7.9 does not meet either Criterion 4 for inclusion in the TSs.
Based on the above, the NRC staff concludes that current TS 3.7.9 does not meet any of the four technical criteria set forth in 10 CFR 50.36(c)(2)(ii) and, since the screening criteria have not been satisfied, the Sealed Source Contamination LCO and Surveillances may be relocated to the Waterford 3 TRM.
3.2.4 TS 3.9.5, "Communications" Communication between the control room personnel and personnel performing CORE AL TERA TIONS is maintained to ensure that personnel can be promptly informed of significant
- 8 changes in the plant status or core reactivity condition during refueling. The communications allow for coordination of activities that require interaction between the control room and refuel personnel. However, the fuel handling accident or transient response does not take credit for this communication.
LCO 3.9.5, "Direct communications shall be maintained between the control room and personnel at the refueling station," is applicable only during CORE ALTERATIONS. This is conducted only with the reactor head removed and the RCS depressurized. The LCO covers components such as radios and associated power and transmission equipment which are necessary to establish and maintain communications between the control room and the refueling station and are not used for, nor capable of, detecting any degradation of the RCS pressure boundary prior to any design-basis accident. Therefore, TS 3.9.5 does not meet Criterion 1 for inclusion in the TSs.
The communication system covers components that are used to maintain communication between control room and refueling station. The system is not capable to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient. Therefore, TS 3.9.5 does not meet Criterion 2 for inclusion in the TSs.
Components used by personnel to establish and maintain communication between the control room and the refueling station does not include any systems, structures, or components that perform the design functions described in this criterion. Therefore, TS 3.9.5 does not meet Criterion 3 for inclusion in the TSs.
Neither the operating experience nor probabilistic risk assessment of the components is applicable to the communication equipment used between the control room personnel and personnel performing CORE ALTERATIONS. Therefore, TS 3.9.5 does not meet Criterion 4 for inclusion in the TSs.
Based on the above, the NRC staff concludes that current TS 3.9.5 does not meet any of the four technical criteria set forth in 10 CFR 50.36(c)(2)(ii) and, as the screening criteria have not been satisfied, the Communications LCO and Surveillances may be relocated to the Waterford 3 TRM.
3.3 NRC Staff Conclusion
The licensee based its license amendment request on the criteria in 10 CFR 50.36(c)(2)(ii) and on NRC guidance provided in the Interim and Final Policy Statements. In general, TSs are based upon the accident analyses. The accident analyses assumptions and initial conditions must be protected by the TSs. The technical evaluation demonstrated that the four criteria in 10 CFR 50.36(c)(2)(ii) were not met and that relocation of the TSs to the TRM is acceptable.
In addition, the licensee has determined that the proposed change does not require any exemptions or relief from regulatory requirements and does not affect conformance with any general design criteria. The NRC staff confirmed this assessment to be valid.
- 9 The NRC staff concludes that the licensee's relocation of specific LCOs to the licensee's TRM is acceptable because the proposed change does not meet the criteria specified in the Final Policy Statement.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Louisiana State official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on April 17, 2012 (77 FR 22814). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: David W. Alley Matthew Yoder Ravinder Grover N. Kalyanam Date: December 20,2012
December 20,2012 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 -ISSUANCE OF AMENDMENT RE: RELOCATING TECHNICAL SPECIFICATIONS TO THE TECHNICAL REQUIREMENTS MANUAL (TAC NO. ME7614)
Dear Sir or Madam:
The Commission has issued the enclosed Amendment No. 238 to Facility Operating license No. NPF-38 for the Waterford Steam Electric Station, Unit 3 (Waterford 3). This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated November 21, 2011, as supplemented by letter dated November 26, 2012.
The amendment relocates TS 3.4.6, "Chemistry," TS 3.7.5, "Flood Protection," TS 3.7.9, "Sealed Source Contamination," and TS 3.9.5, "Communications," to the Waterford 3 Technical Requirements Manual.
A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely, IRAJ N. Kalyanam, Project Manager Plant licensing Branch IV Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosures:
- 1. Amendment No. 238 to NPF-38
- 2. Safety Evaluation cc w/encls: Distribution via listserv DISTRIBUTION:
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JMcHaie SCurrie for 11/27112 11127112 2/8/12 10/11112 10/17/12 NRR/DSS/STSB/BC IDSEAlRHMB/BC OGC NLO NRR/DORLlLPL4 NRR/DORLlLPL4/PM OFFICE CCook (NChokshi for)
DCylkowski MMarkley NKalyanam RElliott NAME 12/6112 12/7112 12/18/12 12/20/12 12120112 I DATE OFFICIAL RECORD COpy