Text

Issuance of Amendment No. 254 Regarding Revision of Technical Specification 3/4.7.4, Ultimate Heat Sink,
	ML19164A001
Person / Time
Site:	Waterford
Issue date:	06/28/2019
From:	April Pulvirenti; Plant Licensing Branch IV
To:	; Entergy Operations
	Pulvirenti A, NRR/DORL/LPLIV, 415-1390
References
	EPID L-2018-LLA-0080
	Download: ML19164A001 (33)
	v • d • e

UNITED STATES WASHINGTON, D.C. 20555-0001 June 28, 2019 Site Vice President 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 NO. 254 RE: REVISION OF TECHNICAL SPECIFICATION 3/4.7.4, "ULTIMATE HEAT SINK" (EPID L-2018-LLA-0080)

Dear Sir or Madam:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 254 to Renewed 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 March 26, 2018, as supplemented by letters dated May 17, 2018, and February 15, 2019.

The amendment revises Waterford 3 TS 3/4. 7.4, "Ultimate Heat Sink." Specifically, the amendment corrects a discrepancy in the wet cooling tower basin level, revises requirements for cooling fan operation described in the TS 3.7.4 ACTION Statements, revises Surveillance Requirement 4.7.4, and revises Table 3.7-3, "Ultimate Heat Sink Minimum Fan Requirements Per Train."

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, April L. Pulvirenti, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosures:

1. Amendment No. 254 to NPF-38

2. Safety Evaluation cc: Listserv

UNITED STATES WASHINGTON, D.C. 20555-0001 ENTERGY OPERATIONS, INC.

DOCKET NO. 50-382 WATERFORD STEAM ELECTRIC STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 254 Renewed 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 March 26, 2018, as supplemented by letters dated May 17, 2018, and February 15, 2019, 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 license 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.

Enclosure 1

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 Renewed 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. 254, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed 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 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-38 and Technical Specifications Date of Issuance: June 2 8 , 2 O1 9

ATTACHMENT TO LICENSE AMENDMENT NO. 254 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-38 WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382 Replace the following pages of the Renewed Facility Operating License No. NPF-38 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.

Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 3/4 7-12 3/4 7-12 3/4 7-13 3/4 7-13 3/4 7-14 3/4 7-14

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 renewed 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. 254, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. Antitrust Conditions (a) Entergy Louisiana, LLC shall comply with the antitrust license conditions in Appendix C to this renewed license.

(b) Entergy Louisiana, LLC is responsible and accountable for the actions of its agents to the extent said agent's actions contravene the antitrust license conditions in Appendix C to this renewed license.

AMENDMENT NO. 254

fLANT SYSTEMS 3.l!,Z,! ULTIMATE HEAT SINK 1IMII1ttG CONDITION FOB OP(RATION 3.7 .4 Two independent trains of ultimate heat sink (UHS) cooling towers shall be OPERABLE with each train consisting of a dry cooling tower (OCT) and a wet mechanical draft cooling tower (WCT) and its associated water basin with:

a. A minimum water level in each wet tower basin of 971 (-9.77 ft MSL)

b. An average basin water temperature of less than or equal to S9*F.

c. Fans as required by Table 3.7-3.

APPLICABILITY; MODES 1, 2, 3, and 4.

ACTION:

a. With 1 UHS train inoperable, restore the inoperable train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With both UHS trains inoperable, restore at least one UHS train to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

WATERFORD - UNIT 3 3/4 7-12 Amendment No.fl, ~. ,254 FEB 1 ~ i91a1_

9

PLANT SYSTEMS LIMITING CONDITION FOR OPERATION <Comioued)

ACTION: (Continued)

c. This action applies only when UHS tornado required equipment is inoperable.

With a Tornado Watch or Warning in effect with the forecast 7 day average ambient dry bulb temperature greater than 74°F, all 6 OCT tube bundles and all 9 OCT fans associated with the missile protected portion of both trains of the OCT shall be OPERABLE. With a Tornado Watch or Warning in effect with the forecast 7 day average ambient dry bulb temperature less than or equal to 74°F, all 6 DCTtube bundles and at least 8 OCT fans associated with the missile protected portion of both trains of the OCT shall be OPERABLE. If the number of tube bundles or fans OPERABLE is less than required, restore the inoperable tube bundle(s) or fan(s) to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or be in at least HOT STANDBY within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUlDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

d. When Table 3.7-3 dry bulb temperature restrictions apply with UHS fan(s) inoperable, determine the forecast ambient temperatures and verify that the minimum fan requirements of Table 3.7-3 are satisfied (required only if the associated UHS is OPERABLE). The more restrictive fan requirement shall apply when 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and 3 day average temperatures allow different configurations.

e. With either or both wet cooling tower basin cross-connect valves not OPERABLE for makeup, restore the valve(s) to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months or COLD SHUlDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS

4. 7.4. Each train of UHS shall be determined OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by verifying the average water temperature and water level to be within specified limits.

b. In accordance with the Surveillance Frequency Control Program, by verifying that each wet tower and dry tower fan that is not already running, starts and operates for at least 15 minutes.

c. Verify that each wet tower basin cross-connect valve is OPERABLE in accordance with the INSERVICE TESTING PROGRAM.

WATERFORD - UNIT 3 3/4 7-13 AMENDMENT NO. 96, ~23,208,-24-Q, 254

TABLE 3.7-3 ULTIMATE HEAT SINK MINIMUM FAN REQUIREMENTS PER TRAIN (1>

ALLOWABLE FAN COMBINATIONS 1 hour/ 3 day average dry bulb temperature restrictions OPERABLE DCT Fans OPERABLE 15 14 13 WCT Fans 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months I 3 day 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months I 3 day 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 3 day 8 S88 °F :s;:77 °F No Temperature Restrictions 7 S87 °F S77 Of (1J With any DCT tube bundle isolated, at least 14 DCT fans and 7 WCT fans shall be OPERABLE.

WATERFORD - UNIT 3 3/4 7-14 AMENDMENT NO. 95, 123, 139,237,254

UNITED STATES WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 254 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-38 ENTERGY OPERATIONS, INC.

WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382

1.0 INTRODUCTION

By letter dated March 26, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18085B196), as supplemented by letters dated May 17, 2018 and February 15, 2019 (ADAMS Accession Nos. ML18137A494 and ML19046A418, respectively),

Entergy Operations, Inc. (the licensee) requested changes to the Technical Specifications (TSs) for Waterford Steam Electric Station, Unit 3 (Waterford 3). The changes would revise TS 3/4.7.4, "Ultimate Heat Sink" (UHS), to address several non-conforming conditions.

Specifically, the amendment would revise TS 3/4.7.4 to address

wet cooling tower basin level discrepancy

dry cooling tower and wet cooling tower recirculation impacts, and

wet cooling methodology for determining fan requirements.

The supplemental letter dated February 15, 2019, 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 or the Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on July 31, 2018 (83 FR 36976).

Enclosure 2

2.0 REGULATORY EVALUATION

The NRC staff identified the following regulatory and guidance documents applicable to the review of this license amendment request (LAR) to revise TS 3/4.7.4.

2.1 Regulatory Requirements

Section 182a of the Atomic Energy Act of 1954, as amended, requires applicants for licenses to operate nuclear power plants to include TSs as part of the license application. These TSs become part of any license issued.

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, "Application for amendment of license, construction permit, or early site permit."

The regulations under 10 CFR 50.36, "Technical specifications," contain the requirements for the content of TSs.

The regulation under 10 CFR 50.36(b) requires, in part, "technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto .... "

The regulation under 10 CFR 50.36(c), requires TSs to include items in the following categories: (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 regulation under 10 CFR 50.36( c)(2)(ii) lists four criteria used to determine whether LCOs must be established in the TSs for items related to plant operation. If the item meets one or more of the four criteria listed below, an LCO must be established in the TSs to ensure the lowest functional capability or performance level of equipment required for safe operation of the facility will be met. The following four criteria state:

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.

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.

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.

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 regulation under 10 CFR 50.36(c)(2) further requires that, "[w]hen a limiting condition for operation of a nuclear reactor plant is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met."

The regulation under 50.36(c)(3) states that "[s]urveillance requirements 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."

Appendix A, "General Design Criteria [GDC] for Nuclear Power Plants," to 10 CFR Part 50, GDC 38, "Containment heat removal," insofar as it requires that a containment heat removal system be provided, and that its function shall be to rapidly reduce the containment pressure and temperature following a loss-of-coolant accident (LOCA) and maintain them at acceptably low levels;

Appendix A to 10 CFR Part 50, GDC 50, "Containment design basis," insofar as it requires that the containment and its associated heat removal systems be designed so that the containment structure can accommodate, without exceeding the design leakage rate and with sufficient margin, the calculated pressure and temperature conditions resulting from any LOCA.

Appendix A to 10 CFR Part 50, GDC 44, "Cooling water," requires that "[a] system to transfer heat from structures, systems, and components important to safety, to an ultimate heat sink shall be provided. The system safety function shall be to transfer the combined heat load of these structures, systems, and components under normal operating and accident conditions."

Appendix J to 10 CFR Part 50, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors," as being applicable to the review insofar as it describes containment leakage rate testing pressure requirement, Pa.

2.2 Regulatory Guidance

Regulatory Guide (RG) 1.27, Revision 3, "Ultimate Heat Sink for Nuclear Power Plants,"

dated November 2015 (ADAMS Accession No. ML14107A411 ), describes a basis acceptable to the NRC that may be used to implement GDC 44 and defines the regulatory basis for the UHS. In summary, RG 1.27 requires the UHS to provide cooling for at least 30 days where design basis temperatures of safety-related equipment are not exceeded. Meteorological conditions evaluated should be the worst combination of controlling parameters. For evaporation and drift losses, use the 30-day average combination of controlling parameters. For cooling, use the worst combination of controlling parameters, including diurnal variations where appropriate for the critical time periods. The following is an acceptable method for selecting these conditions: Select the most severe observation for the critical time period for each controlling parameter or parameter combination, based on at least 30 years of representative data, with substantiation of the conservatism of these values for site use.

Waterford 3 Updated Final Safety Analysis Report (UFSAR), Section 9.2.5, "Ultimate Heat Sink," Section 9.2.5.1, "Design Basis" states, in part:

The ultimate heat sink has sufficient capacity to dissipate heat removed by the CCWS [component cooling water system] and ACCWS [auxiliary component cooling water system] after a design basis accident, assuming a single active failure coincident with a loss of offsite power and the historically worst combination meteorological condition of 102 °F [degrees Fahrenheit] dry bulb temperature and associated 78 °F wet bulb temperature.

NUREG-1432, Revision 4, "Standard Technical Specifications, Combustion Engineering Plants," Volume 1, Specifications, dated April 2012 (ADAMS Accession No. ML12102A165), provides guidance for the format and content of licensees' TSs.

The format of the Waterford 3 TSs differs from that in NUREG-1432 in that Waterford TSs follow previous NRC guidance. For the purposes of this evaluation, the difference in format is administrative.

2.3 System Description Section 9.2.5 of the Waterford 3 UFSAR states that "[t]he function of the ultimate heat sink is to dissipate the heat removed from the reactor and its auxiliaries during normal unit operation, during refueling, or after a design basis accident."

The UHS system at Waterford 3 includes two independent trains, each consisting of one dry cooling tower (DCT) and one wet cooling tower (WCT) and the water stored in the WCT basins.

The DCTs and WCTs transfer heat from plant components served by the CCWS and ACCWS to the ambient atmosphere.

2.3.1 System Components 2.3.1.1 WCTs and Basins Each WCT consists of two cells. Each cell has four induced draft fans discharging vertically up and can operate at a reduced capacity in a natural draft operating mode without fan operation.

Each WCT basin contains sufficient water for UHS operation without makeup after a LOCA.

Basins are interconnected by a 4-inch line with manual isolation valves to allow substantial margin backup should one or the other WCT not be functional. At the design maximum ambient dry bulb temperature of 102 °F, with a wet bulb temperature of 78 °F, the WCTs were designed to dissipate about 40 percent of the maximum LOCA heat load.

Each WCT has a basin capable of storing sufficient water to bring the plant to safe shutdown under all design-basis accident (DBA) conditions. This minimum WCT basin capacity contains enough volume to account for water evaporation and drift losses expected during a LOCA.

Additional volume is needed from the second WCT basin to handle the non-essential load of fuel pool cooling during a LOCA. The WCTs can be manually interconnected through a Seismic Category I line. The WCT basin is also credited as a source of emergency feedwater. The WCT minimum capacity bounds the amount of emergency feedwater required from the WCT basin for all DBAs.

Each WCT consists of two cells, with each cell serviced by four induced draft fans, for a total of eight per WCT. There is a concrete partition between the cells that prevents air recirculation between the fans of each cell.

2.3.1.2 DCTs and Fans Each DCT consists of five separate cells. Cooling air for each cell is provided by 3 fans, for a total of 15 fans per DCT.

Each cell contains two 40-foot long vertical cooling coils configured in a "V' with three fans blowing into the "V" from different elevations of the cell intake plenum. During normal operations the DCT fans can be started and shut off automatically to maintain the CCWS temperature, leaving the DCT between 88 °F and 92 °F. The CCWS transfers heat from systems and components important to safety during normal operation and during a LOCA. At the design maximum ambient dry bulb temperature of 102 °F, the DCTs were designed to dissipate about 60 percent of the maximum LOCA heat load.

2.3.1.3 CCWS and ACCWS The CCWS is a closed-loop system that supplies cooling water for the reactor auxiliaries. Heat is removed by the dry cooling towers and the component cooling water (CCW) heat exchangers.

The system uses demineralized water buffered with a corrosion inhibitor. The CCWS consists of two CCW heat exchangers, three 100 percent capacity pumps, two dry cooling towers, one surge tank, and one chemical addition tank.

The WCTs remove heat from the ACCWS, which in turn removes heat from the CCWS via a CCWS tube and shell heat exchanger when the DCT cannot provide enough cooling to maintain the required supply temperature to CCWS served components. A temperature control valve in the ACCWS outlet line from the CCW heat exchanger to the WCT will modulate flow to limit the CCWS supply temperature to the heat loads. The UHS system operation during a DBA LOCA is optimized by having the DCTs transfer as much heat as they can and conserving as much WCT basin water as possible for mission time margin while providing all heat loads with an acceptable cooling supply temperature. With the WCT fans in automatic, the fans will start when the basin temperature exceeds the set point temperature.

2.3.2 Site Layout The auxiliary and turbine buildings are immediately adjacent to the south side of the shield building. The five Train A DCT cooling tower cells are located along the west side of the fuel handling building and shield building with a gap to their south between them, and the two Train A WCT cells are located on the west side of the shield building. The five Train B DCT cells are located along the east side of the fuel handling building and shield building, and the two WCT Train B cooling towers are located immediately to their south on the east side of the shield building.

2.4 Description of TS Changes 2.4.1 Current TS Proposed Change The current LCO statement for TS 3.7.4 is applicable in MODES 1, 2, 3 and 4 and states:

Two independent trains of ultimate heat sink (UHS) cooling towers shall be OPERABLE with each train consisting of a dry cooling tower (DCT) and a wet mechanica.1 draft cooling tower (WCT) and its associated water basin with:

a. A minimum water level in each wet tower basin of 97% (-9.86 ft MSL

[mean sea level]).

b. An average basin water temperature of less than or equal to 89 °F.

c. Fans as required by Table 3.7-3.

There are four ACTION conditions, which describe how long plant operation may continue during certain circumstances when the LCO is not met. The current ACTIONS state:

a. With 1 UHS train inoperable, restore the inoperable train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With both UHS trains inoperable, restore at least one UHS train to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c. With a Tornado Watch in effect, all 9 DCT fans under the missile protected portion of the DCT shall be OPERABLE. If the number of fans OPERABLE is less than required, restore the inoperable fan(s) to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

d. With any UHS fan inoperable, determine the outside ambient temperature at least once every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and verify that the minimum fan requirements of Table 3. 7-3 are satisfied (required only if the associated UHS is OPERABLE).

The current SR 4. 7.4 states:

Each train of UHS shall be determined OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by verifying the average water temperature and water level to be within specified limits.

b. In accordance with the Surveillance Frequency Control Program, by verifying that each wet tower and dry tower fan that is not already running, starts and operates for at least 15 minutes.

The current TABLE 3. 7-3 states:

TABLE 3.7-3 ULTIMATE HEAT SINK MINIMUM FAN REQUIREMENTS PER TRAIN DRY COOLING TOWER AMBIENT CONDITION DRY BULB~ 97 °F < 97 °F DRY BULB~ 91 °F < 91 °F DRY BULB Fan 15 14* 12*

Requirements< 1>

WET COOLING TOWER Fan Requirements - 8

<1> With any of the above required OCT Fans inoperable comply with ACTION d.

With a tornado watch in effect, all 9 OCT fans under the missile protected portion of the OCT shall be OPERABLE.

Dry cooling tower fan operability is maintained by operating in fast or auto mode. The cooling coils on three cells of each OCT (i.e., 60 percent) are protected from tornado missiles by a grating located above the coils and capable of withstanding tornado missile impact. With a Tornado Watch in effect and the number of fans OPERABLE within the missile protected area of a OCT less than that required by Table 3.7-3, ACTION c requires the restoration of inoperable fans within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or plant shutdown as specified. This ACTION is based on an analysis of UFSAR Subsection 9.2.5.3.3, "Site Related Phenomena," that assumes the worst case single failure as, one emergency diesel generator coincident with a loss of offsite power. This failure occurs subsequent to a tornado strike and 60 percent cooling capacity of a OCT is assumed available.

Item a of LCO 3.7.4 currently requires a minimum water level in each WCT basin of 97 percent

(-9.86 ft MSL). When the WCT basin water level is maintained at -9.86 ft MSL, each basin has a minimum capacity of 174,000 gallons.

Table 3.7-3 specifies increased or decreased fan OPERABILITY requirements based on outside air temperature. The table provides the cooling tower fan OPERABILITY requirements that may vary with outside ambient conditions. Fan OPERABILITY requirements are specified for each controlling parameter (i.e., dry bulb temperatures) for OCT fans. The calculated temperature values described in the Licensee Report EC-M95-009, Calculation No. ECM95-009, Revision 2, "Ultimate Heat Sink Fan Requirements Under Various Ambient Conditions" (ADAMS Accession No. ML12023A082), associated with fan requirements, have been rounded in the conservative direction and lowered at least one full degree to account for minor inaccuracies. Failure to meet the OPERABILITY requirements of Table 3.7-3 requires entry into the applicable action.

Because temperature is subject to change during the day, ACTION d requires periodic temperature readings to verify compliance with Table 3.7-3 when any cooling tower fan is inoperable.

The limitations on minimum water level and maximum temperature are based on providing a 30-day cooling water supply to essential equipment without exceeding the design basis temperature and is consistent with the recommendations of RG 1.27, Revision 3.

2.4.2 Licensee's Proposed Changes The licensee proposed revised Item a of LCO 3.7.4, which would state, A minimum water level in each wet tower basin of 97 percent (-9. 77 ft MSL).

The licensee proposed replacing ACTIONS c and d as well as adding new Condition e.

The licensee proposed the following revised and new conditions, which would state:

c. This action applies only when UHS tornado required equipment is inoperable. With a Tornado Watch or Warning in effect with the forecast 7 day average ambient dry bulb temperature greater than 74 °F, all 6 OCT tube bundles and all 9 OCT fans associated with the missile protected portion of both trains of the OCT shall be OPERABLE. With a Tornado Watch or Warning in effect with the forecast 7 day average ambient dry bulb temperature less than or equal to 74 °F, all 6 OCT tube bundles and at least 8 OCT fans associated with the missile protected portion of both trains of the OCT shall be OPERABLE. If the number of tube bundles or fans OPERABLE is less than required, restore the inoperable tube bundle(s) or fan(s) to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or be in at least HOT STANDBY within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

d. When Table 3.7-3 dry bulb temperature restrictions apply with UHS fan(s) inoperable, determine the forecast ambient temperatures and verify that the minimum fan requirements of Table 3.7-3 are satisfied (required only if the associated UHS is OPERABLE). The more restrictive fan requirement shall apply when 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and 3 day average temperatures allow different configurations.

e. With either or both wet cooling tower basin cross-connect valves not OPERABLE for makeup, restore the valve(s) to OPERABLE status within 7 days or be in at least HOT STAND BY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months or COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The licensee proposed adding SR 4.7.4.c, which would state, Verify that each wet tower basin cross-connect valve is OPERABLE in accordance with the INSERVICE TESTING PROGRAM.

The licensee proposed deleting the current TABLE 3.7-3 and replacing it with the following:

TABLE 3.7-3 ULTIMATE HEAT SINK MINIMUM FAN REQUIREMENTS PER TRAIN (1l ALLOWABLE FAN COMBINATIONS 1 hour/ 3 day average dry bulb temperature restrictions OPERABLE DCT Fans OPERABLE 15 14 13 WCT Fans 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months I 3 day 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months I 3 day 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 3 day 8 S88 °F S77 °F No Temperature Restrictions 7 S87 °F S77 °F

<1lWith any DCT tube bundle isolated, at least 14 DCT fans and 7 WCT fans shall be OPERABLE.

3.0 TECHNICAL EVALUATION

The changes in allowable ambient temperatures and in fan operability requirements, as reflected by the revised TS 3/4.7.4, may impact UHS operation, which in turn may affect multiple systems at Waterford 3. Therefore, the licensee's LAR dated March 26, 2018, was evaluated for each of the following technical areas of impact:

Impact of CCW temperature on the current containment analysis of record;

Effect of meteorological factors such as ambient and dry bulb temperature, wind speed and direction, and tornado watches and warnings;

Effect of temperature and component operability on the heat transfer capacity of the UHS; and

Ability of revised TS 3/4.7.4 to ensure that the lowest functional capability for safe operation of the facility will be met.

3.1 Potential Impact of the CCW Temperature on the Current Containment Analysis 3.1.1 Background Waterford 3 is a Combustion Engineering pressurized water reactor (PWR) with a dry ambient containment. The licensee's LAR incorporates a change to the CCW temperature. A change in CCW temperature can impact containment pressure, temperature, and sump temperature response analyses. Specifically, the licensee proposes to change the CCW supply temperature after a safety injection actuation signal from 115 °F to 117.4 °F.

3.1.2 Evaluation Section 4.5.5, "Component Cooling Water Supply Temperature Setpoint," of the Enclosure to the LAR dated March 26, 2018, states, in part:

The design basis calculations were updated to demonstrate that component cooling water supplied at up to 120 °F in the accident lineup adequately cools all safety related equipment, including the emergency diesel generators, containment fan coolers, shutdown cooling heat exchanger, high pressure safety injection pumps, low pressure safety injection pumps, containment spray pumps, system piping, and fuel pool cooling heat exchanger and maintains their design basis temperatures.

Section 4.5.5, further states, in part:

The design basis calculations demonstrate that the ultimate heat sink is capable of supplying required component cooling water flow to all components at temperatures less than or equal to 120 °F during peak accident heat load under bounding ambient conditions. Therefore, the supply temperature to safety related components after a design basis accident with a safety injection actuation signal will be controlled less than or equal to 120 °F.

The above statements indicate that the temperature of CCW supply to containment fan coolers, shutdown cooling heat exchangers, and several pumps and heat exchangers may increase from 115 °F to 120 °F. Because it was expected that this change could impact the containment pressure, temperature, and sump temperature response, the NRC staff requested supplemental information regarding the CCW supply temperature by letter dated May 4, 2018 (ADAMS Accession No. ML18122A097). In order for the staff to start its review to determine the containment analysis impact as a result of a change in CCW supply temperature, the NRC requested that the licensee provide the following information:

(a) The inputs and assumptions in the containment pressure, temperature, and sump temperature analysis with justification in case the conservatism in any of the inputs and assumptions has been reduced from the analysis of record.

(b) The inputs and assumptions for the net positive suction head analysis for the pumps that draw water from the sump in the recirculation mode, with justification, in case the conservatism in any of the inputs and assumptions has been reduced from the analysis of record.

(c) The graphical results of the analysis in (a) and (b) and the peak values.

In its response by letter dated May 17, 2018, the licensee first clarified that the safety injection actuation signal setpoint for the CCW supply will be changed from 115 °F to 117.4 °F. The temperature of 117.4 °F is below the current containment pressure and temperature analysis of record, which was performed using a setpoint value of 120 °F for the CCW supply. The 117.4 °F temperature is also within the stated design basis instrument uncertainty range of 2.6 °F. Since the requested change in safety injection actuation signal setpoint for the CCW supply temperature is within the bounds of the analysis of record and the design basis instrument uncertainty, the staff concludes that the analysis remains acceptable and no change is required.

In the May 17, 2018, supplement, the licensee described the input values with and without uncertainty, per request (a), above. The licensee stated that there are no changes from the analyses of record and therefore, there was no need to update the analyses of record for the containment pressure, temperature, and sump temperature. The licensee further stated that there is no reduction in the conservatism in any of the inputs and assumptions from the analyses of record. The NRC staff finds it acceptable that there are no changes in analyses of record for containment pressure, temperature, and sump temperature given that there were no input or conservatism changes. The current value of the 10 CFR Part 50, Appendix J containment leakage test pressure Pa of 44 pounds per square inch gauge (psig) stated in Waterford 3 TS 6.15, "Containment Leakage Rate Testing Program," bounds the limiting containment peak pressure of 55.2 pounds per square inch absolute (41.06 psig) determined for a hot leg break with CCW water temperature of 120 °F, as stated in the licensee's response to Sufficiency Item 3 in the letter dated May 17, 2018.

The licensee also stated that the analysis of record for the net positive suction head (NPSH) of the pumps that draw water from the sump in the recirculation mode is not impacted by a change in the setpoint for the safety injection actuation signal of the CCW supply temperature. The inputs and assumptions for the NPSH analysis for the pumps that draw water from the sump in the recirculation mode, relative to the containment analysis, are containment pressure and sump water temperature. There are no changes from the analysis of record because the CCW supply temperature is not an input. Therefore, the NRC staff finds this acceptable.

The licensee plans to revise the Waterford 3 UFSAR to incorporate annotation of the figures for the analyses for containment pressure and temperature and NPSH peak values for the cold and hot leg breaks. The peak containment pressure and temperature and NPSH values for the cold and hot leg breaks do not differ from the analyses of record. This is an acceptable change to the UFSAR.

3.1.3 Conclusion The NRC staff confirmed that the licensee's proposed changes do not impact the analyses of record for the containment analyses. As such, GDC 38 and GDC 50 continue to be met and the safety determination of the plant does not change. There is no impact on the 10 CFR Part 50, Appendix J containment leakage test pressure Pa. Therefore, the NRC staff concludes that the proposed changes are acceptable from the standpoint of containment analysis for Waterford 3.

3.2 Impact of Meteorological Events on UHS 3.2.1 Background The proposed changes to TS 3/4.7.4 establish dry cooling fan and tube bundle requirements based on 1-hour and 3-day average ambient temperature limits. The NRC staff evaluated each of the TS changes with respect to (1) tornado watches and warnings, (2) ambient temperature dry bulb temperature restrictions, and (3) bounding relationships between wind speed, wind direction, and ambient temperature, as well as the supporting studies on which the changes are based.

By letter dated January 28, 2019 (ADAMS Accession No. ML19018A010), NRC staff issued a request for additional information (RAI) requesting details of meteorological data and calculations. The licensee provided a response by letter dated February 15, 2019. The

response included several engineering reports, which provided descriptions and summary data of meteorological data and calculations. A majority of the met~orological evaluation is based on data provided in those engineering reports.

3.2.2 Evaluation 3.2.2.1 TS 3. 7.4 ACTION c Section 2.2, "Technical Specification 3.7.4 ACTION c," to the LAR dated March 26, 2018, states that the TS will be revised to read as follows (all text in bold is revised text):

This action applies only when UHS tornado required equipment is inoperable. With a Tornado Watch or Warning in effect with the forecast 7-day average ambient dry bulb temperature greater than 74 °F; all 6 DCT tube bundles and all 9 OCT fans associated with the missile protected portion of both trains of the OCT shall be OPERABLE. With a Tornado Watch or Warning in effect with the forecast 7 day average ambient dry bulb temperature less than or equal to 74°F, all 6 DCT tube bundles and at least 8 DCT fans associated with the missile protected portion of both trains of the DCT shall be OPERABLE.

In the RAI dated January 28, 2019, the NRC staff requested details on how tornado warnings and watches are received and monitored to ensure that the correct number of OCT tube bundles and OCT fans associated with missile protection are operable. In its response to the RAI dated February 15, 2019, the licensee stated that tornado watches and warnings are received from the National Weather Service (NWS), which is constantly monitored in the control room. The RAI response also included a reference to Procedure OP-901-521, Revision 327, "Severe Weather and Flooding," that directs Operations personnel to verify operability of required OCT fans located within the missile protected area once the NWS issues a tornado watch or warning. Based on the provided information, the NRC staff finds the response to RAI Request 1 to be acceptable.

The licensee explained in the LAR that the proposed changes to the text regarding forecast ambient dry bulb temperature are intended to allow for reduced dry cooling tower fan requirements for the missile protected portion when the established ambient temperature limits are not exceeded. As part of the RAI response dated February 15, 2019, the licensee included : Engineering Report WF-3-ME-00008, Revision O "National Weather Service Forecast Accuracy Study for Waterford 3 Ambient Temperature." This engineering report provides details on the methods used to determine conservative 1-hour, 3-day, and 7-day average temperatures for establishing the TS 3. 7.4 UHS fan operability requirements.

According to Engineering Report WF-3-ME-00008, the 7-day average ambient dry bulb temperature of 74 °Fis calculated using temperature forecasts from the NWS Forecast Office in New Orleans/Baton Rouge, Louisiana. The NWS is a part of the National Oceanic and Atmospheric Administration (NOAA), under the U.S. Department of Commerce. The NWS forecasts temperature for up to 6 days that can be obtained for the Waterford 3 site location.

The engineering report states that:

To conservatively determine the upcoming seven day average temperature, take the average of the hourly temperature forecasts for the upcoming six day period

(Tave_6day} and then take the forecasted high temperature for the seventh day out

{ThighJday) and perform a weighted average of those two values:

Tave_7day = {6

Tave_6day + Thigh_7day} / 7 Waterford 3 collects meteorological measurements via the onsite tower at an elevation of +30 feet MSL. The meteorological tower is located approximately 1700 feet east of the cooling tower and is representative of the atmospheric conditions on the Waterford 3 site as described in the Waterford 3 UFSAR (ADAMS Accession No. ML16256A150).

Waterford 3 performed a comparison between the NWS forecast data and the temperatures recorded by the onsite meteorological monitoring system. The comparison between NWS forecast and onsite data showed that there were only 23 instances, out of 163 trials, when one of the forecast average temperatures was lower than the actual average onsite temperatures.

According to the Waterford 3 calculation, the 24-hour high temperature forecast was conservative 93 percent of the time, the 3-day average forecast was conservative 91 percent of the time, and the 7-day average forecast was conservative 95 percent of the time.

Based on the information provided in the RAI response dated February 15, 2019, and the associated calculation packages, the NRC staff finds the revised text in TS 3. 7.4 ACTION c to be acceptable.

3.2.2.2 TS 3. 7.4 ACTION d Section 2.3, "Technical Specification 3.7.4 ACTION d," to the LAR states that the technical specification will be revised to read as follows (all text in bold is revised text):

When Table 3.7-3 dry bulb temperature restrictions apply with UHS fan(s) inoperable, determine the forecast ambient temperatures and verify that the minimum fan requirements of Table 3. 7-3 are satisfied (required only if the associated UHS is OPERABLE). The more restrictive fan requirement shall apply when 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and 3 day average temperatures allow different configurations.

In the RAI dated January 28, 2019, the NRC staff requested that the licensee provide additional details on the methods proposed to calculate the 1-hour and 3-day average temperatures.

In its RAI response dated February 15, 2019, the licensee stated that Engineering Report WF3-ME-18-00008, Revision O (Attachment 1 to the RAI response) describes the proposed methods for calculating the 1-hour and 3-day average temperatures that would be used to determine that the minimum fan requirements of TS Table 3.7-3 are satisfied.

The licensee states in the LAR that the proposed changes to the TS establish dry cooling tower fan and tube bundle requirements based on 1-hour and the 3-day ambient temperature limits that maintain total UHS transfer capacity. Engineering Report WF3-ME-18-0008 describes the process Waterford 3 follows to calculate the 1-hour and 3-day ambient temperatures, as well as determining the conservativeness of these calculations. This information is also described in LAR Section 4.3, "Technical Specification 3.7.4 ACTION d." Based on the information provided in the RAI response dated February 15, 2019, and the associated calculation packages, the NRC staff finds the revised text in TS 3.7.4 ACTION d to be acceptable.

3.2.2.3 Meteorological Parameters Section 4.5.4, "Meteorological Parameters," to the LAR discusses the method for determining meteorological parameters for the design of the UHS as described in the Waterford 3 UFSAR, Section 2.3, "Meteorology," which establishes bounding combinations of dry bulb and wet bulb temperatures. Waterford 3 UFSAR, Section 9.2.5.3.2, "Meteorological Conditions," states that the UHS design is based on the meteorological conditions listed in UFSAR Table 2.3-2a, "Ultimate Heat Sink Meteorological Design Parameters." The licensee adopted the guidance provided in RG 1.27 for determining the most severe combinations of controlling meteorological parameters for the design of the UHS for the duration of the critical time periods. RG 1.27 recommends that regional climatological measurements should be based on a recent record of at least 30 years in length in order to demonstrate that the data are representative of the site.

The licensee used historical studies to establish bounding conditions included in Waterford 3 UFSAR Section 2.3. A constant recirculation effect was applied to both dry bulb and wet bulb temperature. As described in Engineering Report WF3-ME-15-00011, Revision 1, "Waterford 3 Ultimate Heat Sink Project Weather Investigation," included as Attachment 5 to the RAI response dated February 15, 2019, the location of the dry cooling tower exhaust regions relative to the inlet areas makes recirculation dependent on wind direction. This report determines the bounding relationship between wind speed, wind direction, and ambient temperature. This information is used in Engineering Report WF3-ME-15-00014, Revision O "Waterford 3 Ultimate Heat Sink: CFO [Computational Fluid Dynamics] Investigation of the Dry Cooling Tower Deflector Wall Modification" (Attachment 4 to the letter dated February 15, 2019), for the determination of the cooling tower maximum recirculation effects.

3.2.2.4 Wind Speed, Wind Direction, and Ambient Temperature In the RAI dated January 28, 2019, the NRC staff requested that the licensee include additional details on the data and methods used to determine the bounding combinations of the wind speed, wind direction, and ambient temperature, so that the NRC staff may determine the adequacy of the calculations. The staff requested that the information include data sources, data summaries, details on the use of historical studies, and descriptions of the methods used to compile the summary tables in the LAR. The RAI response dated February 15, 2019, provided a description of the calculation packages used to develop and explain the data sources, data summaries, details on the use of historical studies, and descriptions of the methods used to compile the summary tables in the LAR.

In Section 4.5.4.1, "Wind Speed, Wind Direction, and Ambient Temperature," to the LAR, the licensee states, in part, that, Engineering Report WF3-ME-15-00011 addresses an investigation of the Waterford 3 site meteorology, specifically the combination of wind speed, wind direction, and ambient temperature. These parameters affect the performance of the dry cooling tower and wet cooling tower, particularly with respect to recirculation effects. This report establishes the relationship between site ambient wind and temperature conditions and develops the limiting ambient wind and temperature combinations to conservatively address cooling tower recirculation.

The primary data used in the engineering report is historical meteorological tower (MET tower) data obtained for a period from 2000 to 2013. A second set of data was obtained from NOAA for the New Orleans airport to determine peak daily temperatures and daily average wind speed

for the period from 1984 to 2014. The licensee evaluated the MET tower weather data (temperature and wind) for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , 1 day, and 3-day averages for a 14-year period. The NOAA temperature data and daily average winds were obtained and compared to the MET tower data in order to meet the 30-year period specified in RG 1.27.

Engineering Report WF3-ME-15-00011 determines bounding combinations of wind and temperature data measured at the site. The report outlines a diagram (Figure 3-1 below),

illustrating potential wind and temperature combinations. In this diagram, the wind speed is on the Y-axis and the temperature on the X-axis. Data pairs form a "cloud" that can be enveloped by a curve relating wind speed and temperature. Separate curves can be generated to fit the data distribution for each cardinal wind direction (North, South, East, West). This combination of two variables is mathematically represented by a bivariate distribution. An additional diagram (Figure 3-2, below), shows the two variables X and Y with normal probability distributions p(X) and p(Y). When plotted Y vs. X, the "cloud" of data can be enveloped by an ellipse. This ellipse represents a confidence interval that provides the probability that random data will fall inside the elliptical boundary as described below.

Wind Speed 10

. . .:y. .**. :.*

:: I 80 90 100 Temperature Figure 3-1: Diagram of Wind vs. Temperature Bounding Limits (Reproduced from Figure 3-1 in Engineering Report WF3-ME-15-00011)

04

~ 02

a. -

"O X

0 4 -4 Figure 3-2: Representation of Bivariate Distribution (Reproduced from Figure 3-2 in Engineering Report WF3-ME-15-00011 )

The eng ineering report states that "a 99% confidence interval is achieved using a 96%

confidence bound of the data. The probability of exceeding this value over the quarter ellipse is

~ x 4% = 1%, producing a confidence of 99% or 1E-2 chance that a point will exceed the curve bounds for both temperature and wind ." The report presents both the 1E-2 (99 percent) and 1E-3 (99.9 percent) data and states that they represent a conservative upper bound of the data relative to the confidence interval of 95 percent used in certain NRC guidance documents.

In Engineering Report WF3-ME-15-00011 , plots of the temperature and wind speed data distribution for each cardinal direction were made. The model used to evaluate the confidence interval is based on a normal and log-normal distribution for the temperature and wind ,

respectively.

In the prediction interval plots, the plots are presented with a linear Y-axis scale. The ellipse in a log-linear scale, which defines the bounding curve, changes shape when converted to a linear-linear scale. From each bounding curve, three bounding points were selected to represent the limits of the curve. These three points are the wind and temperature pairs corresponding to: (A) the peak temperature , (8) the peak wind speed , and (C) the average temperature between the peak wind and peak temperature. The seasonal variation was then combined with the bounding curve points. T he report provides the 1-hour data for the 99.9 percent and 99 percent data, respectively, and 1-day and 3-day averages for the 99 percent data. No 1-day or 3-day data was developed for the 99.9 percent data.

The engineering report states that during the comparison of the meteorological data sets used, the equivalent NOAA data produced maximum wind and temperature points slightly higher,

+0.4 miles per hour (mph)/+0.1 °F, than the MET tower data. Therefore, the bounding MET tower data will be increased to account for the difference to the 30-year expanded data set recommended by RG 1.27.

The engineering report states that since the recirculation behavior of the OCT is primarily a function of wind speed, the maximum wind speed points are selected for analysis of modifications to the OCT design. The points defining the maximum wind and temperature at the

maximum wind across the four seasons are presented in the report for each of the time averaged periods. These points are shifted +0.4 mph/+0.1 °F to account for the 30 year expanded data set and rounded to the nearest mile per hour. The set of bounding points for the hourly at 99.9 percent and 99 percent confidence interval, as well as 99 percent 1-day and 3-day average temperature and wind speeds are provided in the table in LAR Section 4.5.4.1.

Based on the information provided in the RAI response dated February 15, 2019, including Engineering Report WF3-ME-15-00011, the description provided in LAR Section 4.5.4.1, and the NRC staff's review of the analysis including the assumptions, methodology, and calculations, the staff finds the bounding temperature and wind points values listed in LAR Section 4.5.4.1 to be acceptable.

3.2.2.5 Meteorological Parameters for Critical Time Periods Section 4.5.4.2, "Meteorological Parameters for Critical Time Periods," to the LAR states that Engineering Report WF3-ME-16-00001 (Attachment 2 to the RAI response dated February 15, 2019), used historical studies for the development of bounding meteorological parameter relationships for the design of the UHS. The LAR states that this is consistent with the methods described in the UFSAR and meets the requirements of RG 1.27 in that it determines the most severe combinations of controlling parameters for the duration of the critical time periods, based on examination of regional climatological (>30 years) measurements that are demonstrated to be representative of the site.

Section 4.5.4.2 to the LAR also states that Engineering Report WF3-ME-16-00001 provided the data for the Section 4.5.4.2 table, which gives the maximum average dry bulb temperature as a function of the time of year by month. The LAR states that this information will be added to the Waterford 3 UFSAR. The LAR states that this new UFSAR table will be used to evaluate the average temperature restrictions as the forecast data when online forecast data is not available.

The LAR states that it may also be conservatively used when the time of year is such that online forecast data is not needed to demonstrate the temperature requirements will be met.

In the RAI dated January 28, 2019, the NRC staff requested that the licensee include additional details regarding the data and methods used to determine: ( 1) the bounding meteorological parameter relationships for the design of the UHS; and, (2) the maximum average dry bulb temperature as a function of month, as presented in Section 4.5.4.2 of the LAR. Engineering Report WF3-ME-16-00001 provides the details of the data and methods used to determine the bounding meteorological parameter relationships for the design of the UHS and the maximum average dry bulb temperature as a function of month as presented in Section 4.5.4.2 of the LAR. The engineering report includes data sources, data summaries, details on the use of historical studies, and descriptions of the methods used to compile the summary tables in the LAR.

The meteorological data set used in this engineering report included data points for temperature, wet bulb temperature, wind speed, and relative humidity. The data was collected from the onsite MET towers at Waterford 3. The dataset is for a 15-year period, from 2000 to 2015. Hourly and 15-minute averaged values are calculated locally at each tower and are transmitted to the Plant Monitoring Computer. As discussed in Engineering Report WF3-ME-16-00011, Revision 0, "Waterford 3 WCT Engineering Analysis Submittals," the historical data analyzed consisted of peak daily temperatures and average daily wind speeds archived by NOAA from the New Orleans International Airport. The report states that this data does not allow for meaningful relationships to be developed between 1-hour average wind and

corresponding 1-hour average temperature conditions. Therefore, the report stated that the onsite MET tower data is the most appropriate data for developing a bounding relationship for combination average wind speed and average temperature and for developing bounding wet bulb temperature and relative humidity relationships with dry bulb temperature.

The engineering report points to the Waterford 3 UFSAR, Section 2.3.1.2.7, "Dry Bulb and Wet Bulb Temperatures," discussion of using 17 years of dry bulb and wet bulb data for the original licensing basis with statistical extrapolations as justification for using 15 years of 1-hour data to develop bounding parameter relationships rather than the 30 years recommended by RG 1.27.

The report also states that the relationships established in this report bound the previously accepted dry bulb temperature -wet bulb temperature combinations described in UFSAR Table 2.3-2a, "Ultimate Heat Sink Meteorological Design Parameters," which are based on over 30 years of data.

Consistent with RG 1.27, the UHS capacity is determined using the most severe combination of controlling meteorological parameters for the critical time periods unique to the specific design of the UHS. For the Waterford 3 UHS, the controlling meteorological parameters are dry bulb temperature, wet bulb temperature, wind speed and direction, and relative humidity. The critical time periods are 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (LOCA Peak Heat Load), 1 day (Natural Circulation Cooldown), 3 days (LOCA Water Consumption), and 7 days (Tornado UHS Heat Load).

Engineering Report WF3-ME-16-00001 also examines the most severe combinations of the controlling parameters and establishes relationships to simplify selection of the parameter combinations. The bounding relationships for wet bulb temperature, wind speed, recirculation, and relative humidity will be established as functions of dry bulb temperature for various fan configurations and critical time periods associated with the design of the UHS.

The calculations for these bounding relationships are shown on the worksheet shown in .18 to the Engineering Report WF3-ME-16-00001. The worksheet provides mathematical relationships for the various meteorological parameters for design of the Waterford 3 UHS. The charts shown in Attachments 9.1 - 9.17 to Engineering Report WF3-ME-16-00001 illustrate the bounding relationships of the various parameters with dry bulb temperature. The tables presented in LAR Section 4.5.4.2 are based on the information presented in Attachments 9.1 - 9.18 of Engineering Report WF3-ME-16-00001.

3.2.3 Conclusion Based on the information provided in the RAI response dated February 15, 2019, including Engineering Report WF3-ME-16-00001, the description provided in LAR Section 4.5.4.2, and the NRC staff's review of the analysis including the assumptions, methodology, and calculations, the staff finds the bounding average inlet temperatures at critical time periods and the maximum average dry bulb temperature as a function of the time of year by month, which are presented in their respective tables in LAR Section 4.5.4.2, to be acceptable.

The NRC staff reviewed the methodology described in the LAR and RAI response to derive the ambient temperature forecasts and verifications. The NRC staff reviewed the calculation packages provided by the licensee to determine the adequacy of the data acquisition and processing. Based on this review, the staff concludes that the changes to the technical specifications described above are acceptable.

3.3 Effect of Temperature and Component Operability on the Heat Transfer Capacity of the UHS 3.3. 1 Background Section 9.2.5. 1 of the Waterford 3 UFSAR, "Design Basis," describes the UHS design basis as having the capability to transfer heat energy from within the primary containment (from radioactive decay in the reactor core), spent fuel pool and various safety system components to the ambient atmosphere following a design basis LOCA as a design basis LOCA would present the maximum potential heat load on the UHS. The UHS must be able to do so with the bounding worst historical meteorological conditions of air temperature and humidity ( 102 °F dry bulb temperature and associated 78 °F wet bulb).

Historically, ambient temperatures seldom approach this combination of temperature and humidity for a large part of the year, and a lesser capacity due to redundant components being out of service during those times can provide comparable margin, given that lower ambient temperatures result in a higher heat transfer rate for the remaining fans and cooling coils. The significant changes being requested are to allow for additional components (WCT fans, OCT tube bundles) to be out of service and to provide new forecast ambient temperature limitations for UHS train components being out of service that are based on a revised UHS calculation.

The revised calculation was provided in ECM95-008, Revision 3 (EC52043) "Ultimate Heat Sink Design Basis," included as Attachment 5 to the letter dated May 17, 2018.

The current LCO requirements were included in TS 3.7.4 with implementation of Amendment No. 237, dated October 31, 2012 (ADAMS Accession No. ML12250A435), pursuant to an LAR dated October 13, 2011 (ADAMS Accession No. ML11290A009), to reflect the impact of the additional heat energy initially released into containment from the larger hot water mass contained in the replacement steam generators in the event of a DBA LOCA and to correct non-conservatisms. Additional review of the calculation identified weaknesses, and Amendment No. 237 was approved with what were then understood to be necessary requirements regarding UHS train components allowed to be out of service. Waterford 3 identified that the UHS cooling tower air recirculation impacts were non-conservative and entered the condition into their corrective action program and implemented administrative controls in accordance with NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety," dated December 29, 1998, to require dry cooling tower fan operation with more restrictive temperature requirements.

3.3.2 Evaluation 3.3.2.1 UHS Capability Design Basis Calculation The LAR dated March 26, 2018, relies on a substantial revision to the UHS design basis calculation. One issue had been the realization that, especially with the large structures immediately adjacent to the cooling towers, wind direction and speed could significantly affect cooling tower performance by contributing to recirculation of hot discharge air back to the inlet of the cooling tower cells. Initial acceptance testing of cooling tower heat transfer capability had been performed at nearly calm conditions and actual testing at various wind speeds and directions is impractical. The licensee used CFD computer modeling analyses to provide a reasonable determination of the bounding impacts of wind speed and direction on the cooling tower air recirculation. A study of historical meteorological data supported identification of bounding relationships of wind speed and ambient temperature, and of ambient temperatures

and humidity. This allowed for determining what cooling tower fans and dry cooling tower cooling coils could be out of service for maintenance while still considering the trains operable and capable of fulfilling their design function with a simple specification of ambient air temperature forecasts.

Calculation ECM95-008 was substantially revised since Amendment No. 237 was issued (included in the current LAR as ECM95-008, Revision 3 (EC52043) and the changes pertinent to the requested TS changes were reviewed for reasonableness and conservatism in assumptions and inputs. Notable changes included use of the CFO to determine the impact of wind speed and direction as well as combinations of fans and cooling coils out of service on UHS train capability. A study of historical meteorological data established a bounding wet bulb temperature corresponding to a dry bulb temperature and use of the corresponding bounding wet bulb temperature was assumed. This is conservative in that a higher wet bulb temperature for a given dry bulb temperature is a higher humidity condition with the WCTs having less potential heat transfer by water evaporation (latent heat of vaporization). The meteorological data study also shows bounding correlation of dry bulb temperature with wind speed (i.e., higher wind speeds correlate with lower air temperatures). Hardware modifications credited in the ECM95-008 markup Revision 3 (EC52043) include installation of OCT discharge to inlet air recirculation barriers and the safety injection actuation signal automatic raising of the CCWS supply temperature control valve setpoint from 115 °F to 117.4 °F. This setpoint change obtains more heat transfer from the DCTs while maintaining the same assumed CCWS supply temperature of 120 °F for the UHS calculation as the instrument uncertainty is 2.6 °F.

3.3.2.2 Computational Fluid Dynamics Modeling The CFO analyses model was provided as Attachment 4 to the RAI response dated February 15, 2019. The CFO model was reviewed for methodology as well as reasonableness of assumptions and inputs in supporting UHS design basis calculation ECM95-008. The CFO 3-dimensional software program package used was ANSYS CFX Version 14.0. ANSYS CFX has been used in support of a variety of other submittals to the NRC including dry cask storage, Generic Safety Issue 191, "Assessment of Debris Accumulation on PWR Sump Performance,"

recirculation pool flows within PWR primary containment, and spent fuel pool circulation flows and temperatures. In its LAR, the licensee stated that CFO calculations followed the general guidance for best practices in CFO modeling provided in NUREG-2152 "Computational Fluid Dynamics Best Practice Guidelines for Dry Cask Applications" (ADAMS Accession No. ML13086A202). Although NUREG-2152 addresses spent fuel dry cask storage specifically, the section on best practices is generally applicable.

The LAR described the model development as using the AutoCAD engineering software tool to set up the geometry input for the cooling towers and adjacent containment shield building, fuel handling building and auxiliary/turbine buildings. The geometry file was imported into ANSYS mechanical software for meshing. The mesh size used was 2-foot elements in the volumes of influence immediately over the cooling towers where the discharge and inlet air would interact, while 1-foot mesh size was used within the OCT cell inlet plenums. For volumes outside the zones of influence, but still nearby, 5-foot mesh size was used and expanded to larger sizes in the far field (total model volume was a little less than 2000-ft by 2000-ft square by 1000-ft high).

Although there are other buildings and structures onsite, their influence on the cooling tower recirculation flows is reasonably assumed to be minimal relative to the immediately adjacent and much larger structures. The LAR indicated that a sensitivity study of mesh size within the volumes of influence just above the cooling tower air discharges and inlets was done using 1-foot, 2-foot and 4-foot mesh sizes with the 1-foot and 2-foot meshes yielding nearly the same

amount of calculated recirculation while the coarser 4-foot mesh size showed a somewhat higher OCT aggregate recirculation air flow. The analysis used the 2-foot mesh size for the volumes of influence. The LAR indicated that the model was validated by benchmarking to the August 19, 1982, UHS Train A OCT preoperational test at 85.87 °F average ambient air temperature and a near calm 3.6 mph air speed from a northerly direction. The model showed a 9.9 °F recirculation temperature rise for these conditions, while the measured temperature rise was 7.8 °F. The model prediction in this case was reasonably close and conservative relative to the actual measured recirculation effect.

The LAR and attached documents show that the NUREG-2152 guidance was generally followed by addressing the guidance elements in the description as to how the model was set up. The staff concludes that the reasonableness and conservatisms of the inputs and assumptions, use of bounding conditions and cumulative conservatisms of the overall UHS capability calculation provide reasonable assurance that margins are maintained with the forecast temperature limitations on UHS components out of service while maintaining train operability.

The LAR indicated that in addition to verification requirements, two independent models using a separate computational fluid dynamics code (ANSYS Fluent) were evaluated to help validate the computational fluid dynamics model approach. This independent analysis performed a full transient simulation to verify the steady state conditions considered in the ANSYS CFX analysis as well as the adequacy of the ANSYS CFX software. The ANSYS CFX to Fluent comparisons showed a good correlation between results of the two models.

3.3.2.3 WCT Basin Cross Connect Valves The LAR proposes adding a new TS SR 4.7.4.c to address the wet cooling tower basin manual cross-connect valves, as described in Section 2.3.1 of this safety evaluation. The new surveillance would require that each wet tower basin cross-connect valve is verified to be operable (exercised to the open position) in accordance with the Waterford 3 lnservice Testing Program.

As stated in the LAR, the proposed changes are to clarify that the safety analyses credit the wet cooling tower basin cross-connect line for additional water inventory margin. A separate action for the wet cooling tower basin cross-connect function clarifies that both ultimate heat sink trains do not have to be considered inoperable when the wet cooling tower basin cross-connect line is inoperable. The existing inservice testing requirements for testing the open safety function of the wet cooling tower basin cross connect isolation valves satisfy the new TS SR. Because this inventory transfer would not be needed for many hours after the start of an event, this change is appropriate and the completion time of 7 days to restore this functionality is acceptable.

3.3.2.4 TS Changes The proposed changes to TS 3.7.4 also include a new UHS minimum fan combination requirement that would allow one WCT fan and one OCT fan to be inoperable without ambient temperature restriction. A UHS train would still be operable with one WCT fan and two OCT fans inoperable provided the more restrictive of the 1-hour average dry bulb temperature forecast being less than or equal to 87 °F, or the 3-day average dry bulb temperature forecast was less than or equal to 77 °F. If all 8 WCT fans were operable, two cooling tower fans could be inoperable provided the more restrictive of the 1-hour average dry bulb temperature forecast being less than or equal to 88 °F, or the 3-day average dry bulb temperature forecast being less

than or equal to 77 °F. A UHS train would also be operable with any single OCT tube bundle isolated when at least 14 OCT fans and 7 WCT fans were operable.

With the proposed changes, TS 3.7.4 would require all six OCT tube bundles and all nine OCT fans associated with the missile protected portion of both trains of the UHS to be operable when a tornado watch, or warning was in effect with the forecast 7-day average ambient dry bulb temperature greater than 74 °F. All six OCT tube bundles, and at least eight OCT fans associated with the missile protected portion of both trains of the UHS would be required operable with a tornado watch or warning in effect with the forecast 7-day average ambient dry bulb temperature less than or equal to 74 °F. If the inoperable fan is not restored to an operable status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the plant will be placed in hot standby within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in hot shutdown within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

3.3.3 Conclusions The licensee has shown by design calculation that, with the UHS components out of service as indicated by the requested TS change as described in the LAR, the affected UHS train remains capable of performing the UHS design function of dissipating heat removed by the CCWS and ACCWS after a design basis accident and other analyzed events coincident with a single active failure and the worst credible combination meteorological condition of ambient temperature, humidity and wind direction and speed.

The NRC staff finds that based on the preceding regulatory and technical evaluations the revised TS 3/4.7.4 as submitted in the licensee's letters of March 26, 2018, May 17, 2018, and February 15, 2019 is acceptable to meet the regulatory requirements of GOC 44, the guidelines of RG 1.27 and the licensing basis stated in UFSAR Section 9.2.5.1 and is therefore acceptable.

3.4 Evaluation of Revised TS 3.4.1 Background The licensee provided justification for the proposed changes as discussed in Section 2 of the LAR dated March 26, 2018, and as supplemented. The NRC staff evaluated the licensee's proposed changes against the applicable regulatory requirements and guidance listed in Sections 2.1 and 2.2 of this safety evaluation.

3.4.2 Evaluation 3.4.2.1 Change to Wet Tower Basis Minimum Water Level For the revision of Item a in LCO 3. 7.4, the minimum water level in each wet tower basin, the licensee stated in the LAR:

Calculation MNQ9-38 (Reference 7.27) revises the wet cooling tower basin inventory calculation and concludes that -9. 77 ft MSL is the correct basin level for 97% full. The revised analyses credit the same 174,000 gallons of wet cooling tower basin water inventory as was previously credited for a 97% full wet cooling tower basin. For the ultimate heat sink analysis, the parameter of interest is the wet cooling tower basin inventory of 174,000 gallons, since this remains the same, this change is administrative in nature.

The NRC staff reviewed the proposed change as well as the licensee's justification. The staff determined that the LCO statement will continue to be based on the analyses and evaluations provided by the licensee and to ensure the lowest functional capability or performance level of equipment required for safe operation of the facility will be met. Therefore, the staff finds that the change is acceptable.

3.4.2.2 Replacement of ACTIONS c and d and Addition of New Condition e The licensee provided initial justification for the replacement of ACTIONS c and d and addition of new Condition e in Sections 4.2, 4.3 and 4.4, respectively, of the LAR. In its RAI response dated February 15, 2019, the licensee provided further justification for the changes to Conditions c and d.

The NRC staff reviewed the proposed changes as well as the licensee's justifications. The staff determined that the remedial actions will continue to be based on the analyses and evaluations provided by the licensee. The staff determined the remedial actions are acceptable. The staff determined that, in accordance with the revised TS, when LCO 3.7.4 is not met, the licensee shall shut down the reactor or follow remedial action permitted by the technical specification until the condition can be met.

3.4.2.3 Addition of New SR 4.7.4.c The licensee provided initial justification for the addition of new SR 4. 7.4.c in Section 4.4 of the LAR. In the RAI response dated February 15, 2019, the licensee provided further justification for the addition of SR 4.7.4.c. Specifically, in its response related to the frequency of testing for the wet tower basin cross-connect valves in SR 4.7.4.c, the licensee stated:

The testing of valves ACC-138A and ACC-138B that will be required by the new SR 4.7.4.c is currently performed as part of the Waterford 3 lnservice Testing Program. Document, SEP-WF3-IST-2, "WF3 lnservice Testing Plan," Revision 7, currently requires that this test be performed at a frequency of every 2 years.

The NRC staff reviewed the proposed changes as well as the licensee's justifications. The staff determined the new SR is based on the analyses and evaluations provided by the licensee and will provide assurance that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that LCO 3.7.4 will be met. Therefore, the staff concludes that the new SR is acceptable.

3.4.2.4 Replacement of Table 3.7-3 The licensee provided initial justification for the replacement of Table 3.7-3, "Ultimate Heat Sink Minimum Fan Requirements," in Section 4.5 of the LAR. The licensee provided a revised replacement Table 3.7-3 (shown in Section 2.4.2 of this document) in the supplement to the LAR dated May 17, 2018. In the RAI responses by letter dated February 15, 2019, the licensee provided further justification for the table.

The NRC staff reviewed the proposed Table 3.7-3 as well as the licensee's justifications for the change. Since Table 3.7-3 is essentially a requirement of LCO 3.7.4, the staff evaluated the proposed table against the regulatory requirements for LCOs. The staff determined that Table

3. 7-3 will continue to be based on the analyses and evaluations provided by the licensee and ensure the lowest functional capability or performance level of equipment required for safe

operation of the facility will be met. Therefore, the staff concludes that the replacement of Table 3.7-3 is acceptable.

3.4.3 Conclusion The regulation under 10 CFR 50.36(b) requires TS to be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto. The NRC staff found that the analyses and evaluations included in the LAR and its supplements, as provided by the licensee, met this requirement and were acceptable. In the LAR, the licensee proposed revising TS 3.7.4, specifically its LCO, remedial actions and SRs. The NRC staff reviewed the proposed changes as well as the licensee's justifications for the changes. The NRC staff determined that each change to the LCO, and its remedial actions, will continue to meet the regulatory requirements of 10 CFR 50.36(c)(2). The NRC staff determined that the new SR will continue to meet the regulatory requirements of 10 CFR 50.36(c)(3). Therefore, the NRC staff concludes that the proposed changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Louisiana State official was notified of the proposed issuance of the amendment on June 12, 2019. 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 and changes SRs.

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, published in the Federal Register on July 31, 2018 (83 FR 36976), and there has been no public comment on such finding. 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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Diana Woodyatt, NRR Jerome Bettle, NRR Matthew Hamm, NRR Jason White, NRO Date: June 28, 2019

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3- ISSUANCE.

OF AMENDMENT NO. 254 RE: REVISION OF TECHNICAL SPECIFICATION 3/4.7.4, "ULTIMATE HEAT SINK" (EPID L-2018-LLA-0080)

DATED JUNE 28, 2019 DISTRIBUTION: RidsNrrLAPBlechman Resource PUBLIC RidsNrrPMWaterford Resource PM File Copy RidsRgn4MailCenter Resource RidsACRS_MailCTR Resource JGiacinto, NRO RidsNrrDorllpl4 Resource JWhite, NRO RidsNrrDssScpb Resource JBettle, NRR RidsNrrDssSrxb Resource MHamm, NRR RidsNrrDssStsb Resource DWoodyatt, NRR ADAMS Access1on No. ML19164A001 t d

B,v memo d ae t d

- B,vema1*1 d ae OFFICE NRR/D0RL/LPL4/PM NRR/DORL/LPL4/LA NRO/DLSE/EXHB/BC*

NAME APulvirenti PBlechman JGiacinto DATE 06/13/19 06/13/19 04/04/19 OFFICE NRR/DSS/STSB/BC(A)* NRR/DSS/SRXB/BC* NRR/DSS/SCPB*

NAME PSnyder JWhitman SAnderson DATE 04/24/19 04/05/19 05/16/19 OFFICE OGC NLO** NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME KGamin RPascarelli APulvirenti DATE 06/25/19 06/28/19 06/28/19 OFFICIAL RECORD COPY

v t e Letter Sequence Approval
EPID:L-2018-LLA-0080, Response to U. S. Nuclear Regulatory Commission Request for Additional Information Regarding Proposed Change to Technical Specification 3/4.7.4 for Ultimate Heat Sink Design Basis Update (Approved, Closed)
Initiation Request Acceptance, Acceptance Supplement Administration Questions 28 January 2019 Answers Results Approval Other: ML18171A040
MONTHYEAR2018-06-07 [Table View]

ML19164A001

Text

SUBJECT:

Dear Sir or Madam:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

SUBJECT:

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