ML22112A151

NRR E-mail Capture - for Review: Draft RAIs to LAR to Relocate Chemical Detection Systems Technical Specifications (TS) to Technical Requirements Manual (TRM)

ML22112A151
Person / Time
Site:	Waterford
Issue date:	08/06/2021
From:	James Drake NRC/NRR/DORL/LPL4
To:	Devoe R Entergy Nuclear Operations
References
Download: ML22112A151 (4)

Text

From: Drake, Jason Sent: Friday, August 6, 2021 11:27 AM To: Devoe, Remy Cc: Dixon-Herrity, Jennifer

Subject:

FOR REVIEW: Draft RAIs to LAR to Relocate Chem Detection TS to TRM Attachments: Request for Additional Information_Waterford 3_Chemical Detection TS to TRM_Draft.pdf Importance: High

Remy, Attached are draft RAIs to the Entergy Operations, Inc license amendment request (LAR) to revise Waterford Steam Electric Station Unit 3 (Waterford 3) Technical Specifications (TS) to remove TSs 3.3.3.7.1 and 3.3.3.7.3, "Chemical Detection Systems" and references to the TS, and relocate the information to the licensee controlled technical Requirements Manual (TRM).

Please review to ensure that there is no proprietary information contained in the draft RAIs, that the questions are understandable, that the regulatory basis is clear and to determine if the information was previously docketed. Please let me as soon as possible if a clarification phone call is needed and/or if a response should be expected within 30 days from the issuance of these as final RAIs.

Regards, Jason Drake Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Phone: (301) 415-8378

Hearing Identifier: NRR_DRMA Email Number: 1606 Mail Envelope Properties (MN2PR09MB5610D8229A0762ED7C5C47DAFBF39)

Subject:

FOR REVIEW: Draft RAIs to LAR to Relocate Chem Detection TS to TRM Sent Date: 8/6/2021 11:26:50 AM Received Date: 8/6/2021 11:26:00 AM From: Drake, Jason Created By: Jason.Drake@nrc.gov Recipients:

"Dixon-Herrity, Jennifer" <Jennifer.Dixon-Herrity@nrc.gov>

Tracking Status: None "Devoe, Remy" <rdevoe@entergy.com>

Tracking Status: None Post Office: MN2PR09MB5610.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 968 8/6/2021 11:26:00 AM Request for Additional Information_Waterford 3_Chemical Detection TS to TRM_Draft.pdf 134878 Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE WATERFORD STEAM ELECTRIC STATION, UNIT 3 LICENSE AMENDMENT REQUEST TO RELOCATE THE CHEMICAL DETECTION SYSTEMS TECHNICAL SPECIFICATIONS TO TECHNICAL REQUIREMENTS MANUAL EPID L-2021-LLA-0061 DOCKET NO. 50-382 By letter dated April 5, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21095A156), Entergy Operations, Inc (Entergy or the licensee) submitted a license amendment request (LAR or the application) to revise Waterford Steam Electric Station Unit 3 (Waterford 3) Technical Specifications (TS) to remove TSs 3.3.3.7.1 and 3.3.3.7.3, "Chemical Detection Systems" and references to the TS, and relocate the information to the licensee controlled technical Requirements Manual (TRM). The TRM is part of the Final Safety Analysis Report (FSAR) and any changes to the TRM are subject to the criteria of 10 CFR 50.59. Additionally, the proposed change will relocate Surveillance Requirement (SR) 4.7.6.1.d.4 to the TRM.

The reason for the proposed changes is described in section 2.3 of the LAR, are noted below:

The proposed change relocates chemical detection system TSs that do not meet the 10 CFR 50.36 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 relocation is 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 TSs, as limiting conditions for operation. The Final Policy Statement noted that implementation of these additional criteria, as codified in 10 CFR 50.36(c)(2)(ii), may cause some requirements presently in TSs to no longer merit inclusion in TSs.

The summary of the pre-application meeting held on December 15, 2020, between the NRC staff and Entergy (ADAMS Accession No. ML21012A202) includes the following statement regarding these criteria:

The NRC staff informed the licensee that the bases for Standard Technical Specification (STS) 3.7.11, Control Room Emergency Air Cleanup System (CREACS), in NUREG-1432, Revision 4, Standard Technical Specifications Combustion Engineering Plants: Bases (ADAMS Accession No. ML12102A169),

state that the CREACS, which provides protection from smoke and hazardous chemicals to the control room occupants, satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) for requiring a TS.

Section 3.0, Technical Evaluation, of the enclosure to the LAR included the following paragraph addressing Criterion 3 of 10 CFR 50.36(c)(2)(ii):

The Chlorine and Broad Range Gas Detection Systems ensure that an accidental chlorine or toxic gas release will be detected promptly, and the necessary protective actions will be automatically initiated to provide protection for control room personnel. These detection systems do not function or actuate 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. None of the functions of the chemical detection systems to detect, alarm and isolate the control room ventilation system are credited in the chapter 15 FSAR safety analysis.

RAI 1

The discussion in Section 3.0, Technical Evaluation, of the Enclosure to the license amendment request links the statement that the chlorine and broad range detection systems do not function or actuate 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] with the lack of credit for the functions of the chemical detection systems in Chapter 15, Accident Analyses, of the Waterford 3 Final Safety Analysis Report (FSAR). However, Section 2.2.3, Evaluation of Potential Accidents, of the Waterford 3 FSAR states that the hazards associated with chemicals transported or stored in the vicinity of Waterford 3 were evaluated and the main control room design prevents the incapacitation of control room operators during toxic gas episodes. In addition, Section 2.2.3.3, Design Basis Toxic Chemicals, of the Waterford 3 FSAR includes the following statements: the probability that toxic chemicals frequently transported in the vicinity of Waterford 3 could cause a radiological release in excess of 10CFR50.67 guidelines is 6.45 x 10-7 per year, and Since the probability is below the 10-6 per year criterion, the results indicate that the protective features described in the FSAR provide adequate protection for the control room operators. Please explain how Entergy considered the information discussed in Section 2.2.3 of the Waterford 3 FSAR in determining the applicability of Criterion 3 of 10 CFR 50.36(c)(2)(ii) to TS 3.3.7.1, Chorine Detection System, and TS 3.3.7.3, Broad Range Gas Detection.

RAI 2

Surveillance requirements are defined in 10 CFR 50.36(c)(3) as those 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. SR 4.7.6.1.d.4 verifies that upon a toxic gas detection signal (chlorine and broad range gas detection systems), the control room emergency filtration system automatically switches to the isolation mode of operation. Please explain how relocation of Surveillance Requirement (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 and the impacts it would have on all related limiting conditions for operation.