ML22075A102

Issuance of Amendment No. 264 to Relocate Chemical Detection System Technical Specifications to Technical Requirements Manual

ML22075A102
Person / Time
Site:	Waterford
Issue date:	04/29/2022
From:	James Drake Plant Licensing Branch IV
To:	Entergy Operations
Drake J
References
EPID L-2021-LLA-0061
Download: ML22075A102 (20)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON , D.C. 20555-0001 April 29, 2022 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. 264 TO RELOCATE CHEMICAL DETECTION SYSTEM TECHNICAL SPECIFICATIONS TO THE TECHNICAL REQUIREMENTS MANUAL (EPID L-2021-LLA-0061)

Dear Sir or Madam:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 264 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 April 5, 2021, as supplemented by letters dated September 30, 2021, and October 14, 2021.

The amendment relocates Waterford 3 TSs 3.3.3.7.1 and 3.3.3.7.3, Chemical Detection Systems and an associated Surveillance Requirement 4.7.6.1.d.4 to the licensee-controlled Technical Requirements Manual.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Jason J. Drake, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosures:

1. Amendment No. 264 to NPF-38

2. Safety Evaluation cc: Listserv

ENTERGY OPERATIONS, INC.

DOCKET NO. 50-382 WATERFORD STEAM ELECTRIC STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 264 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 April 5, 2021, as supplemented by letters dated September 30, 2021, and October 14, 2021, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions 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 paragraphs 2.C.2, 2.C.4 and 2.C.5 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. 264, 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.

4. DELETED

5. Initial Inservice Inspection Program (Section 6.6, SSER 51)

By June 1, 1985, the licensees2 must submit and initial inservice inspection program for staff review and approval.

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 Digitally signed by William T. William T. Orders Date: 2022.04.29 Orders 12:25:15 -04'00' William T. Orders, Acting Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-38 and the Technical Specifications Date of Issuance: April 29, 2022

ATTACHMENT TO LICENSE AMENDMENT NO. 264 RENEWED FACILITY OPERATING LICENSE NO. NPF-38 WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382 Replace the following pages of Renewed Facility Operating License No. NPF-38 and the 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 3-47 3/4 3-47 3/4 3-48a 3/4 3-48a 3/4 7-17 3/4 7-17

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 Commissions 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. 264, 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. 264

4. DELETED

5. Initial Inservice Inspection Program (Section 6.6, SSER 51)

By June 1, 1985, the licensees2 must submit an initial inservice inspection program for staff review and approval.

6. Environmental Qualification (Section 3.11, SSER 8)

Prior to November 30, 1985, the licensees shall environmentally qualify all electrical equipment according to the provisions of 10 CFR 50.49.

7. Axial Fuel Growth (Section 4.2, SSER 5)

Prior to entering Startup (Mode 2) after each refueling, EOI shall either provide a report that demonstrates that the existing fuel element assemblies (FEA) have sufficient available shoulder gap clearance for at least the next cycle of operation, or identify to the NRC and implement a modified FEA design that has adequate shoulder gap clearance for at least the next cycle of operation. This requirement will apply until the NRC concurs that the shoulder gap clearance provided is adequate for the design life of the fuel.

8. Emergency Preparedness (Section 13.3, SSER 8)

In the event that the NRC finds that the lack of progress in completion of the procedures in the Federal Emergency Management Agency's final rule, 44 CFR Part 350, is an indication that a major substantive problem exists in achieving or maintaining an adequate state of emergency preparedness, the provisions of 10 CFR Section 50.54(s)(2) will apply.

9. Fire Protection EOI shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c),

as specified in the license amendment request dated November 17, 2011 (and supplements dated January 26, 2012, September 27, 2012, October 16, 2012, May 16, 2013, June 26, 2013, December 18, 2013, June 11, 2014, March 12, 2015, April 10, 2015, May 14, 2015, August 27, 2015, September 8, 2015, September 24, 2015, October 13, 2015, and January 18, 2016), and as approved in the safety evaluation dated June 27, 2016. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, 1

The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

2 The license originally authorized Entergy Louisiana, LLC to possess, use, and operate the facility.

Consequently, certain historical references applicable to Entergy Louisiana, LLC as one of the "licensees" appear in these license conditions.

AMENDMENT NO. 264

Page 3/4 3-47 is not used WATERFORD - UNIT 3 3/4 3-47 AMENDMENT NO. 21, 53, 156, 249, 264 Correction Letter of 3-17-2000

Page 3/4 3-48a is not used WATERFORD - UNIT 3 3/4 3-48a AMENDMENT NO. 20,53,133,135,151, 249, 264

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

2. Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 0.5% when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and a relative humidity of 70%.

3. Verifying a system flow rate of 4225 cfm +/- 10% during train operation when tested in accordance with ANSI N510-1975.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 0.5%

when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and a relative humidity of 70%.

d. In accordance with the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 7.8 inches water gauge while operating the train at a flow rate of 4225 cfm +/- 10%.

2. Verifying that on a safety injection actuation test signal or a high radiation test signal, the train automatically switches into a recirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks and the normal outside airflow paths isolate, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position in Modes 5, 6, or defueled.

3. Verifying that heaters dissipate 10 +1.0, -1.0 kW when tested in accordance with ANSI N510-1975.

e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the train at a flow rate of 4225 cfm +/- 10%.

f. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the train at a flow rate of 4225 cfm +/- 10%.

g. Perform required control room envelope unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

WATERFORD - UNIT 3 3/4 7-17 AMENDMENT 115, 170, 194, 218, 249 257, 264

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 264 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 April 5, 2021 (Reference 1), as supplemented by letters dated September 30, 2021, and October 14, 2021 (References 2 and 3, respectively), Entergy Operations Inc.

(Entergy, the licensee) requested changes to the Technical Specifications (TSs) for Waterford Steam Electric Station, Unit 3 (Waterford 3).

The proposed amendment would relocate Waterford 3 TSs 3.3.3.7.1 and 3.3.3.7.3, Chemical Detection Systems and an associated Surveillance Requirement (SR) 4.7.6.1.d.4 to the licensee-controlled Technical Requirements Manual (TRM).

The supplemental letters dated September 30, 2021, and October 14, 2021, 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) staffs original proposed no significant hazards consideration determination as published in the Federal Register on May 18, 2021 (86 FR 26954).

2.0 REGULATORY EVALUATION

2.1 System Description In Section 2.1 of the Enclosure to the license amendment request (LAR) dated April 5, 2021, the licensee provided a brief description of the system design and operation as follows:

Redundant chlorine detectors are provided near the Control Room Air Conditioning System normal outside air intake. The chlorine detectors use diffusion-type electrochemical probes.

Upon detection of chlorine, the control room envelope is automatically placed in the isolated mode and the Reactor Auxiliary Building (RAB) Normal Ventilation System is shut down. The chlorine detectors are provided with outputs to sound Enclosure 2

an alarm in the main control room. The chlorine concentration readout is available from the plant monitoring computer and appears on a digital display panel in the control room.

Similarly, a Broad Range Gas Detection System which continuously monitors incoming control room air for the presence of a large variety of toxic gases is installed on the Control Room air intake duct. If toxic gas concentration equals or exceeds the high setting, the detector system sounds an alarm and automatically isolate the control room before toxic or immediately dangerous to life or health (IDLH) levels can be reached.

Each Broad Range Detection system consists of an analyzer panel that utilizes continuous scan Fourier Transform Infrared (FTIR) sensing technology. The monitor samples the air and automatically analyzes for the presence of gases and vapors of chemicals for which the computer has been programmed.

The broad range gas detectors are designed to be very sensitive to numerous gases. The control room will be isolated when the concentration of any of the monitored gases exceeds the designated setpoint. A display of the specific gases and their concentrations is provided in the control room.

2.2 Description of the Proposed Changes The licensee proposed to delete the following Chemical Detection Systems from the Waterford 3 TSs in their entirety (including limiting condition for operation (LCO), associated Actions, surveillance requirements (SRs), and Bases):

TS 3.3.3.7.1, Chlorine Detection System TS 3.3.3.7.3, Broad Range Gas Detection In addition, the licensee proposed deletion of SR 4.7.6.1.d.4 from TS 3/4.7.6, Control Room Emergency Air Filtration System. The purpose of this SR is to verify that upon a toxic gas detection signal, the control room emergency air filtration system automatically switches to the isolation mode of operation. In the supplement dated October 14, 2021, the licensee stated that the TS page markup showing the deletion of SR 4.7.6.1.d.4 on the Amendment No. 249 version of TS page 3/4 7-17 provided with the LAR is incorrect. The licensee provided a revised markup and a clean TS page 3/4 7-17, which reflects the changes made in Amendment No. 257.

Waterford 3 SR 4.7.6.1.d.4 applies to Waterford 3 TS 3.7.6.1. The SR verifies that upon a toxic gas detection signal, the control room emergency air filtration system switches to the isolation mode of operation, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position in Mode 5, 6, or defueled. The deletion of this SR from the TSs and its relocation to TRM is a logical progression of the deletion of the chemical detection system LCOs 3.3.3.7.1 and 3.3.3.7.3 from the TSs and their relocation to the TRM. The licensee stated that all the requirements proposed for deletion from the TSs including SR 4.7.6.1.d.4 will continue to be performed under the TRM.

In its supplement dated October 14, 2021, the licensee informed the NRC staff that it identified an additional conforming change and proposed to delete License Condition 2.C.4, which

requires the licensee to propose TSs for the Broad Range Toxic Gas Detection System to be added to the Waterford 3 TSs prior to startup after the first refueling outage. The licensee stated that this license condition would not be applicable if the proposed change to relocate TS 3.3.3.7.3 to the TRM is approved.

2.3 Reason for the Proposed Change In Section 2.3 of the Enclosure to the LAR, the licensee stated the following in support of the request to relocate the requirements of the chlorine and broad range gas detection out of the TSs:

The proposed change relocates chemical detection system TSs that do not meet the 10 CFR 50.36 [Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.36, Technical specifications] requirements for retention in TS and are not included in the NUREG-1432 Revision 4, Standard Technical Specifications - Combustion Engineering Plants. This proposed change establishes consistency with the NUREG-1432, Revision 4.

The basis for the [proposed] relocation is [consistent with] the NRCs Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors (58 FR 39132) issued in July 1993, which provided a specific set of four (4) objective criteria to determine which of the design conditions and associated surveillances should be located in the TSs as limiting conditions for operation (LCOs). The Final Policy Statement noted that implementation of these additional criteria, as [amended] to 10 CFR 50.36(c)(2)(ii), may cause some requirements presently in TSs to no longer merit inclusion in TSs.

The NRC codified the four criteria in 10 CFR 50.36(c)(2)(ii) in Technical Specifications Final Rule, published in the Federal Register on July 19, 1995 (60 FR 36959).

2.4 Regulatory Review The regulations in 10 CFR 50.36 establishes the regulatory requirements related to the contents of the TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls. The regulation does not specify the particular requirements to be included in a plants TSs.

The regulation in 10 CFR 50.36(c)(2)(i) states, in part:

Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the LCO can be met.

The regulations in 10 CFR 50.36(c)(2)(ii) list the following four criteria that require the establishment of an LCO:

(A) Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

(B) Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

(C) Criterion 3: A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

(D) Criterion 4: A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The regulation in 10 CFR 50.36(c)(3) states that:

Surveillance 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 to 10 CFR Part 50, General Design Criteria for Nuclear Power Plants, Criterion 19, Control room, states, in part, that:

A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents.

Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem [roentgen equivalent man] whole body, or its equivalent to any part of the body, for the duration of the accident.

Generic Letter (GL) 95-10, "Relocation of Selected Technical Specifications Requirements Related to Instrumentation," (Reference [4]) states, in part, that:

The release of chlorine or other hazardous chemicals is not part of an initial condition of a design basis accident or transient analysis that assumes a failure of or presents a challenge to the integrity of a fission product barrier.

The staff has concluded that requirements for this system do not meet the 10 CFR 50.36 criteria and need not be included in TSs. Licensees may propose to relocate the chlorine detection system requirements to the Updated Final Safety Analysis Report (UFSAR) and control changes to those provisions in accordance with 10 CFR 50.59, Changes, tests, and experiments.

The NRC staff also considered plant-specific licensing basis information as well as generically approved guidance in NUREG-1432, Standard Technical Specifications [STSs], Combustion Engineering Plants, Revision 4.0, Volume 1, Specifications, and Volume 2, Bases, dated April 2012 (Reference 5) in determining the acceptability of the proposed change to relocate TS 3.3.3.7.1 and TS 3.3.3.7.3 to the TRM.

3.0 TECHNICAL EVALUATION

3.1 NRC Staff Evaluation The NRC staff reviewed the current licensing basis for the chemical detection systems provided in the following chapters of the Waterford 3 UFSAR to determine if the proposed changes are compatible with the descriptions in the UFSAR (Reference 6).

Waterford 3 UFSAR Section 2.2.3.3, Design Basis Toxic Chemicals, states in part: there are several sources for release of toxic chemicals which have a potential for adversely affecting main control room habitability. Chlorine detectors and a broad range gas detection system were provided to detect the presence of chemicals at the control room air intakes that would trip the detectors, sounding an alarm and the automatic isolation of the control room. This section further states that the accidental releases of toxic gases from onsite and offsite facilities have been analyzed in detail and determined to pose no threat to control room operators.

Waterford 3 UFSAR Section 2.2.3.3.6, Results of the analyzed/evaluated accidents states, in part: the probability that toxic chemicals frequently transported in the vicinity of Waterford 3 could cause a radiological release in excess of 10 CFR 50.67 [Accident source term]

guidelines is 6.45 x 10-7 per year, and [s]ince the probability is below the 10-6 per year criterion, the results indicate that the protective features described in the UFSAR provide adequate protection for the control room operators.

Section 6.4, Habitability Systems, of the Waterford 3 UFSAR contains the following statements: The habitability systems provide the capability to detect and protect the main control room personnel from smoke and gases and Based on the evaluation of potential accidents in Subsection 2.2.3, redundant chlorine and broad range detectors are provided at the normal outside air intake. Waterford 3 UFSAR Section 6.4.3.3 describes two modes of emergency operation, one of which is safety injection actuation signal and the other is toxic gas emergency or high radiation signal at the normal outside air intake.

The NRC staffs review of the accidents described in Waterford 3 UFSAR Chapter 15, Accident Analyses, found many references to the control room habitability from a radiological aspect, however no references were noted in this chapter regarding toxic gas protection systems or the impact on control room habitability from exposure to toxic gases.

The NRC staffs review of the Waterford 3 UFSAR concluded there was a significant quantity of information devoted to the toxic gas detection systems in Chapters 2 and 6. In consideration of the location of Waterford 3 in a highly industrialized surroundings and within close proximity of road and waterway transportation, which could potentially be carrying toxic chemicals, the NRC staff determined that requests for additional information (RAIs) were necessary to fully understand and evaluate the proposed relocation of the chemical detection systems from the Waterford 3 TSs to the TRM.

In RAI-1, the NRC staff requested that the licensee explain how the hazards associated with chemicals transported or stored in the vicinity of the site and the design of the control room to address toxic gas discussed in Section 2.2.3 of the UFSAR was considered in determining the applicability of Criterion 3 of 10 CFR 50.36(c)(2)(ii) to TSs 3.3.3.7.1 and 3.3.3.7.3. In RAI-2, the NRC staff requested the licensee to explain how relocation of SR 4.7.6.1.d.4 was assessed relative to ensuring the necessary quality of the control room emergency air filtration system actuation instrumentation would be maintained as defined in 10 CFR 50.36(c)(3) and the impacts it would have on all related LCOs. The licensee responded to the RAIs in the supplement dated September 30, 2021.

The NRC staff reviewed the historic information presented by the licensee regarding the chemical detection systems as it relates to its inclusion in the Waterford 3 TSs originally and the current request in the LAR to relocate them from the TSs to the TRM.

TS 3.3.3.7.1 requirements were originally included in the Waterford 3 TSs consistent with NUREG-0212. The Broad Range Gas Detection requirements in TS 3.3.3.7.3 were added to the Waterford 3 TSs in License Amendment No. 20, in accordance with License Condition 2.C.4 of the Waterford 3 License and due to the need for an additional reliable diverse means of toxic gas detection.

The NRC authorized relocation of Chlorine Detection Systems, from the Combustion Engineering Standard Technical Specifications (CE-STS) as requested in CE Owners Group letter CEN-355 dated December 11, 1987, and approved in a letter dated May 9, 1988. The Chlorine Detection Systems in CE-STS LCOs were listed as authorized for relocation.

The NRC staff reviewed the NRC Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors (58 FR 39132) and Technical Specifications Final Rule. The NRC staff also reviewed the precedent quoted by the licensee for South Texas Project, Units 1 and 2 (Reference 7) and concluded that the primary reason for acceptance of the removal of chemical detection systems was based on the Final Policy Statement.

The licensee previously added TS for the Broad Range Gas Detection system as a result of License Condition 2.C.4. This system is similar to a chemical detection system, except for higher capabilities such as an analyzer panel that utilizes continuous scan FTIR sensing technology that can monitor and automatically analyze for the presence of gases and vapors of chemicals for which the computer has been programmed. The broad range gas detectors are designed to be very sensitive to numerous gases. The discussion in this safety evaluation is applicable to both chemical detection and broad range detection systems as it relates to relocation of the TSs to the TRM.

The NRC staff performed an independent assessment of the licensees bounding risk assessment for the broad range gas monitors and chlorine monitors provided in Enclosure 3 of the LAR. The NRC staff determined that special circumstances, as discussed in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis; General Guidance (Reference 8),

which would have necessitated additional risk information be provided, did not exist. As such, the staff did not request any additional risk information associated with the review of this LAR.

The NRC staff also identified, with respect to Enclosure 3, that the chemical detection systems are not explicitly modeled in the licensees probabilistic risk assessment or the NRC Waterford 3

standardized plant assessment risk model. The NRC staff performed a review of the licensees assumptions, inputs, and estimated system failure information used to assess the potential risk associated with the hazards. The NRC staff concludes that the licensees assumptions, inputs used, and estimated system failure information support the traditional engineering analysis conclusions. Furthermore, the available risk insights do not challenge the engineering conclusions that the proposed changes maintain defense-in-depth and safety margin.

3.2 NRC Staff Conclusion

Based on the staffs review of the information in the LAR and other documents (e.g. UFSAR, Federal Register notices, GL, STSs), the NRC staff concludes that the licensee presented adequate justification in support of the LAR, which includes:

Section 50.36 of 10 CFR does not require the Waterford 3 chlorine and broad range gas detection systems to be included in the facilitys TS.

GL 95-10 supports the removal of the chlorine and broad range gas detection systems from the Waterford 3 TSs.

The current STSs for Combustion Engineering Plants do not contain an LCO for chemical detection systems.

GDC 19 continues to be satisfied as the radiological aspects of the control room are not impacted by the proposed changes.

The NRC staff finds deletion of TSs 3.3.3.7.1 and 3.3.3.7.3 to be acceptable because the chlorine detector and the broad range gas detectors are not a primary success path which functions or actuates to mitigate a Design Basis Accident, as clarified by the Commissions Policy Statements. As such, TS 3.3.3.7.1 and TS 3.3.3.7.3 do not meet the requirement of 10 CFR 50.36(c)(2)(ii)(C) (Criterion 3) to be included in the TSs and may be relocated to the TRM. Relocating SR 4.7.6.1.d.4 is acceptable because the initiating signal to verify this SR comes from equipment no longer in the TSs and, therefore, testing is no longer necessary to demonstrate that the LCO is met per 10 CFR 50.36(c)(3). The TRM is subject to 10 CFR 50.59, which provides a controlled framework for evaluating changes. Last, because the licensee previously met License Condition 2.C.4. and since the equipment added by the license condition will no longer be in the TSs, it is appropriate to remove the license condition entirely from the License as it is no longer applicable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Louisiana State official was notified on April 14, 2022, of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no

significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, published in the Federal Register on May 18, 2021 (86 FR 26954), 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 Commissions 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.

7.0 REFERENCES

1. Gaston, R., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to the Technical Requirements Manual Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382, Renewed Facility Operating License No. NPF-38, dated April 5, 2021 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML21095A156).

2. Gaston, R., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, Response to Request for Additional Information Regarding License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to the Technical Requirements Manual Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382, Renewed Facility Operating License No. NPF-38, dated September 30, 2021 (ADAMS Accession No. ML21273A328).

3. Gaston, R., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, Supplement to License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to the Technical Requirements Manual, Waterford Steam Electric Station, Unit 3, NRC Docket No. 50-382, Renewed Facility Operating License No. NPF-38, dated October 14, 2021 (ADAMS Accession No. ML21287A122).

4. U.S. Nuclear Regulatory Commission, Relocation of Selected Technical Specifications Requirements Related to Instrumentation, Generic Letter 95-10, dated December 15, 1995 (ADAMS Accession No. ML031070178).

5. U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Combustion Engineering Plants, NUREG-1432, Revision 4.0, Volume 1, Specifications, and Volume 2, Bases, dated April 2012 (ADAMS Accession Nos. ML12102A165 and ML12102A169, respectively).

6. Waterford Steam Electric Station, Unit 3, Revision 311 to Final Safety Analysis Report, Chapter 2, Site Characteristics; Chapter 6, Engineered Safety Features; and Chapter 15, Accident Analyses (ADAMS Accession Nos. ML20258A078, ML20258A088, and ML19268A136, respectively).

7. Alexion, T. W., U.S. Nuclear Regulatory Commission, letter to W. T. Cott, Houston Lighting & Power Company, South Texas Project, Units 1 and 2 - Amendment Nos. 76 and 65 to Facility Operating License Nos. NPF-76 and NPF-80 (TAC Nos. M91611 and M91612), dated July 6, 1995 (ADAMS Accession No. ML021300234).

8. U.S. Nuclear Regulatory Commission, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance, NUREG-0800, Section 19.2, dated June 2007 (ADAMS Accession No. ML071700658).

Principal Contributor: N. Karipineni Date: April 29, 2022

ML22075A102 *via email **via memorandum NRR-106 OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DSS/SCPB/BC(A)* NRR/DSS/SNSB/BC*

NAME JDrake PBlechman BWittick SKrepel DATE 03/15/2022 03/31/2022 04/27/2022 04/25/2022 OFFICE NRR/DSS/STSB/BC* NRR/DEX/EICB/BC* NRR/DRA/APLA/BC* OGC*

NAME VCusumano MWaters RPascarelli JEzell DATE 04/29/2022 04/26/2022 04/20/2022 04/19/2022 OFFICE NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*

NAME JDixon-Herrity JDrake (WOrders for)

DATE 04/29/2022 04/29/2022