ML20086M385

Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3/4 8.1, A.C. Sources Operating

ML20086M385
Person / Time
Site:	Waterford
Issue date:	04/01/2020
From:	April Pulvirenti Plant Licensing Branch IV
To:	Entergy Operations
Pulvirenti A
References
EPID L-2020-LLA-0230
Download: ML20086M385 (6)

Text

April 1, 2020 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 -REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 3/4 8.1, A.C. SOURCES OPERATING (EPID L-2020-LLA-0230)

Dear Sir or Madam:

By Letter dated October 24, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19297H543), Entergy Operations, Inc. (the licensee) submitted a license amendment request for Waterford Steam Electric Station, Unit 3. The proposed amendment would revise surveillance requirements in Technical Specification 3/4.8.1, A.C.

[Alternating Current] Sources Operating.

After reviewing your request, the U.S. Nuclear Regulatory Commission staff has determined that additional information is required to complete its review. The additional information needed to complete the review is delineated in the enclosure to this letter.

During a clarification call held on March 26, 2020, with Maria Zamber and others of your staff, it was agreed that a response would be provided by 60 days after the date of this letter. Please note that if you do not respond to this letter by the agreed-upon date or provide an acceptable alternate date in writing, we may deny your application for amendment under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108, Denial of Application for failure to supply information.

If you have any questions, please contact me at 301-415-1390 or via e-mail at April.Pulvirenti@nrc.gov.

Sincerely,

/RA/

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

Enclosure:

Request for Additional Information cc: Listserv

REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST REGARDING REVISION OF SURVILLANCE RQUIREMENTS IN TECHNICAL SPECIFICATION 3/4 8.1 ENTERGY OPERATIONS, INC.

WATERFORD STEAM ELECTRIC STATION UNIT 3 By Letter dated October 24, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19297H543), Entergy Operations, Inc. (the licensee) submitted a license amendment request (LAR) for Waterford Steam Electric Station, Unit 3 (Waterford 3).

The proposed amendment would revise surveillance requirements in Technical Specification 3/4.8.1, A.C. [Alternating Current] Sources Operating).

After reviewing your request, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required to complete its review. The request is described below.

Regulatory Basis Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) states, in part, that Each license authorizing operation of a production or utilization facility of a type described in § 50.21 or § 50.22 will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to § 50.34.

The NRC also considered the following General Design Criteria of 10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants.

General Design Criterion (GDC) 17, Electric power systems, states in part, that:

An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety.

GDC 34, Residual heat removal, states that:

A system to remove residual heat shall be provided. The system safety function shall be to transfer fission product decay heat and other residual heat from the reactor core at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded.

GDC 35, Emergency core cooling, states that:

A system to provide abundant emergency core cooling shall be provided.

The system safety function shall be to transfer heat from the reactor core Enclosure

following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts.

Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

GDC 38, Containment heat removal, states that:

A system to remove heat from the reactor containment shall be provided.

The GDC also requires, in part, that containment capabilities shall be provided to assure that for onsite electric power system operation, (assuming offsite power is not available) the system safety function can be accomplished, assuming a single failure.

NRC Generic Letter 89-10, Safety-Related Motor-Operated Valve [MOV] Testing and Surveillance (ADAMS Accession No. ML031150300), dated June 28, 1989, requested that licensees consider the performance of MOVs during degraded voltage conditions.

Request for Additional Information

1. For the emergency diesel generator lube oil pump and jacket water pump on the emergency diesel generator skid, and the fuel oil transfer pump, discuss whether or not the proposed diesel generator under-frequency limit of 59.7 hertz (Hz) has any effect on the flow rates for these pumps.

2. Section 3.2, Current Licensing Basis and Evaluation, of the LAR states, in part, that the diesel generator under-frequency limit of 59.7 Hz is needed to ensure that the minimum low-pressure safety injection and high-pressure safety injection safety analysis delivery assumptions are met. The proposed changes to the surveillance requirements identify considerations in the performance of pumps within the high-pressure safety injection and the low-pressure safety injection systems, as documented in Waterford 3 Condition Report CR-WF3-2008-5183 (Reference 12 of the LAR).

The effects of diesel generator frequency variations and the performance of all pumps associated with emergency core cooling systems were described in the LAR and reviewed for conformance with associated regulatory requirements (e.g., GDC 17, 34, 35, 38). However, the NRC staff notes that performance capabilities of other equipment, such as MOVs, heaters, and fans associated with emergency core cooling systems or related heating and ventilation systems are also susceptible to voltage and frequency variations. This equipment in these systems is not discussed in the LAR. Typically, licensees evaluated the performance of MOVs during degraded voltage conditions in their responses to NRC Generic Letter 89-10.

Therefore, provide a discussion of how all of the safety-related equipment that could be impacted by the voltage limits and frequency variations proposed in the LAR, such as MOVs, heaters, fans, or pumps, was evaluated for conformance using the assumptions in the accident analyses for Waterford 3. Provide confirmation that the voltage limits and frequency variations proposed in the LAR will not adversely impact the assumptions in the safety analysis.

ML20086M385 *by email dated OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DEX/EEOB/BC*

NAME APulvirenti PBlechman BTitus DATE 03/31/2020 03/27/2020 03/31/2020 OFFICE NRR/DEX/EMIB/BC(A)* NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*

NAME TScarbrough JDixon-Herrity APulvirenti DATE 04/01/2020 04/01/2020 04/01/2020