ML20210H429

Forwards Response to NRC Rai,Associated with TS Change Request NPF-38-208,proposing to Replace Ref to Supplement 1 with Ref to Supplement 2 of Calculative Methods for CE Small Break LOCA Evaluation Model, in ACs Section of TSs

ML20210H429
Person / Time
Site:	Waterford
Issue date:	07/29/1999
From:	Dugger C ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3F1-99-0123, NUDOCS 9908030369
Download: ML20210H429 (4)

Text

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I b . .. l Enttrgy Operations, Inc.

17265 River Road I5 9 60 Fax 504 739 6678 ice re a tO a ons waterford 3 W3F1-99-0123 A4.05 PR July 29,1999 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES Oucket No. 50-382 License No. NPF-38 Response to Request for Additional Information for Technical Specifications Change Request NPF-38-208 Gentlemen:

Please find attached the response to a request for additional information, associated with Technical Specification Change Request NPF-38-208, which was forwarded to Entergy on June 23,1999 by Mr. Chandu Patel of your staff. Technical Specification Change Request NPF-38-208 was transmitted to the NRC Staff on July 29,1998.

The change proposes to replace the reference to Supplement 1 with a reference to Supplement 2 of the " Calculative Methods for the CE Small Break LOCA Evaluation Model"in the Administrative Controls Section of the Technical Specifications.

This response to the request for additional information does not effect the Technical Specification Change Request; therefore, the No Significant Hazards Evaluation remains valid.

Despite an allowance for instrument uncertainty in this application, Entergy's position j with regard to instrument uncertainty remains unchanged from the July 29,1998 and June 23,1999 letters sent to the NRC Staff.

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Response to Request for Additional Information for Technical Specification Change Request NPF-38-208 W3F1-99-0123 Page 2 July 29,1999 4

Should you have any questions or comments concerning this response, please contact Everett Perkins at (504) 739-6379 or Charles DeDeaux at (504) 739-6531.

Very truly yours,

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y C.M. Dugger Vice President, Operations Waterford 3 CMD/CEDhtk Attachments: Affidavit Request for Additional Information for NPF-38-208 cc: E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR J. Smith j N.S. Reynolds NRC Resident inspectors Office Administrator Radiation Protection Division (State of Louisiana)

American Nuclear Insurers J

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, . UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION in the matter of )

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Entergy Operations, incorporated ) Docket No. 50-382 Waterford 3 Steam Electric Station )

AFFIDAVIT Charles Marshall Dugger, being duly sworn, hereby deposes and says that he is Vice President Operations - Waterford 3 of Entergy Operations, incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Response to a Request for Additional Information for Technical Specification Change Request NPF-38-208; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

i L AW Charles Marshall Dugger 'V l Vice President Operations - Waterford 3 STATE OF LOUISIANA )

) ss PARISH OF ST. CHARLES )  ;

1 Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this 2 9 e day of CLM .1999.

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<D-Notary Public i My Commission expires d AE/ .

O RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

, , FOR PROPOSED CHANGE NPF-38-208 NRC Question Though the July 29,1998 documentation proposed by Waterford for reference of the December 1997 CE SBLOCA methodology also contains April 30,1998 analyses justifying present operation of the plant, it is not clear that the methodology is applicable to Waterford for future use. Specifically, it is not clear that all the parameters input into the model for licensing analyses either conservatively bound the actual as-operated plant values or that the ranges of data and sensitivity study values supporting the input parameter values bound or bracket the actual as-operated plant values. Please provide justification that the i proposed SBLOCA methodology is applicable to Waterford in light of regulatory requirements governing assumptions and values of input parameters. The discussion in the EA 98-022 letter sent to you may be helpful in responding to this request for information.

Entergy Response The NRC Staff SER on the revised ABB/CE SBLOCA methodology states, "the staff finds that the SBLOCA EM described in CENPD-137, Supplement 2, is acceptable for use in Combustion Engineering design'PWR licensing applications, including reference in plant technical specifications and core operating limits reports." . No concerns with applicability of the model to plants such as Waterford 3 were identified. The specific concern in the question above I relates to the assumed HPSI flow rate used in the analysis and whether it bounds actual HPSI flow rates. The assumed HPSI flow rate in the analysis includes a conservative allowance for all instrument and process flow uncertainties. Thus, the assumed HPSI flow adequately bounds the actual as-operated plant HPSI flow rate. Other selected key input parameters that have a significant effect on peak clad temperature (such as +3% tolerance on steam generator safety valve setpoints) are also conservatively biased so that actual plant values are bounded. Other conservatisms in the analysis include Appendix K required  ;

modeling assumptions (such as 1.2 times decay heat) further ensure that the analysis results are conservatively bounding. The need to include instrument i uncertainties in addition to the Appendix K conservative models is being addressed as a separate industry wide issue. j

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