ML23059A259

Correction to Issuance to Amendment No. 270 Adoption of TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b

ML23059A259
Person / Time
Site:	Waterford
Issue date:	03/07/2023
From:	James Drake Plant Licensing Branch IV
To:	Entergy Operations
Klett A
References
EPID L-2021-LLA-0014
Download: ML23059A259 (1)

Text

March 7, 2023 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 - CORRECTION TO ISSUANCE OF AMENDMENT NO. 270 RE: ADOPTION OF TSTF-505, REVISION 2, PROVIDE RISK-INFORMED EXTENDED COMPLETION TIMES -

RITSTF INITIATIVE 4b (EPID L-2021-LLA-0014)

Dear Sir or Madam:

By letter dated February 17, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22322A109), the U.S. Nuclear Regulatory Commission (NRC) issued Amendment No. 270 to Renewed Facility Operating License No. NPF-38 for the Waterford Steam Electric Station, Unit 3. The amendment consists of changes to the technical specifications (TSs) in response to your application dated February 8, 2021, as supplemented by letters dated April 8, 2021, May 16, 2022, August 19, 2022, and October 13, 2022. The amendment revised the TS requirements to permit the use of risk-informed completion times in accordance with Technical Specifications Task Force (TSTF) Traveler (TSTF-505), Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF [Risk-Informed TSTF]

Initiative 4b.

After the issuance of the amendment, the NRC staff was notified by Entergy Operations, Inc.

(the licensee) of typographical errors, unrelated to the license amendment, that had been inadvertently introduced in TS pages 3/4 3-4a, 3/4 3-18, and 3/4 7-12, and on page 14 of the safety evaluation (SE).

The NRC staff determined that these errors were introduced during the preparation of the license amendment and are entirely typographical in nature. The corrections do not change any of the conclusions in the SE associated with the amendment and do not affect the associated notice to the public.

The enclosure to this letter contains the corrected TS pages 3/4 3-4a, 3/4 3-18, and 3/4 7-12 and page 14 of the SE. The revised SE page 14 contains a marginal line indicating the area of change. Please replace the corresponding pages issued by Amendment No. 270 for Waterford Steam Electric Station, Unit 3.

If you have any questions, please contact me at 301-415-8378 or via email at Jason.Drake@nrc.gov.

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

Enclosure:

Corrected TS pages 3/4 3-4a, 3/4 3-18, and 3/4 7-12; and safety evaluation page 14 cc: Listserv

ENCLOSURE CORRECTED TECHNICAL SPECIFICATION PAGES 3/4 3-4a, 3/4 3-18, 3/4 7-12; AND SAFETY EVALUATION PAGE 14 TO AMENDMENT NO. 270 ENTERGY OPERATIONS, INC.

RENEWED FACILITY OPERATION LICENSE NPF-38 WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382

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a. Verify that one of the inoperable channels has been bypassed and

• place the other inoperable channel in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

b. All functional units affected by the bypassed/tripped channel shall also be placed in the bypassed/tripped condition as listed below.

Process Measurement Circuit Functional Unit Bypassed/Tripped

1. Containment Pressure Circuit Containment Pressure - High (ESF)

Containment Pressure - High (RPS)

2. Steam Generator Pressure - Steam Generator Pressure - Low Low Steam Generator 6P 1 and 2 (EFAS)

STARTUP and/or POWE~ OPERATION and/or operation in the other applicable MODE(S) may continue until the performance of the next required CHANNEL FUNCTIONAL TEST. Subsequent STARTUP and/or POWER OPERATION and/or operation in the other applicable MODE(S) may continue if one channel is restored to OPERABLE status and the provisions of ACTION 13 are satisfied.

ACTION 15 - With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channels to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or in accordance with the Risk Informed Completion Time Program or be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

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PLANT SYSTEMS 3/4.7.4 ULTIMATE HEAT SINK LIMITING CONDITION FOR OPERATION

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

ACTION:

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Tier 3: Risk-Informed Configuration Risk Management Tier 3 stipulates that a licensee should develop a program that ensures that the risk impact of out-of-service equipment is appropriately evaluated prior to performing any maintenance activity. The proposed RICT program establishes a CRMP based on the underlying PRA models. The CRMP is then used to evaluate configuration-specific risk for planned activities associated with the RMTS extended CT, as well as emergent conditions that may arise during an extended CT. This required assessment of configuration risk, along with the implementation of compensatory measures and RMAs, is consistent with the principle of Tier 3 for assessing and managing the risk impact of out of service equipment.

Paragraph 50.36(c)(5) of 10 CFR identifies administrative controls as the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. In enclosure 8, Attributes of the CRMP Model, to the LAR, the licensee confirmed that future changes made to the baseline PRA models and changes made to the online model (i.e., CRMP) are controlled and documented by plant procedures. In enclosure 10, Program Implementation, to the LAR, the licensee identified the attributes that the RICT program procedures will address, which are consistent with NEI 06-09-A. In response to APLA RAI 03.b in the LAR supplement dated May 16, 2022, the licensee committed to update licensee procedure EN-DC-151, PRA Maintenance and Update, to include criteria to perform an interim update to the PRA models used in the RTR model specific to the RICT application. The NRC staff finds that the licensee has identified appropriate administrative controls consistent with NEI 06-09-A and that it will continue to meet 10 CFR 50.36(c)(5).

Based on the licensees incorporation of NEI 06-09-A in the TSs, as discussed in LAR attachment 1; use of RMAs as discussed in LAR enclosure 12, Risk Management Action Examples; and because the proposed changes are consistent with the Tier 3 guidance, the NRC staff finds the licensees Tier 3 program is acceptable and supports the proposed implementation of the RICT program.

Key Principle 4: Conclusions The licensee has demonstrated the technical acceptability and scope of its PRA models and alternative methods, including consideration of the impact of seismic events, non-seismic external hazards, and other hazards, and that the models can support implementation of the RICT program for determining extensions to CTs. The licensee has made proper consideration of key assumptions and sources of uncertainty. The risk metrics are consistent with the approved methodology of NEI 06-09-A and the acceptance guidance in RGs 1.174 and 1.177.

The RICT program will be controlled administratively through plant procedures and training and follows the NRC-approved methodology in NEI 06-09-A. Based on the above, the NRC staff concludes that the RICT program satisfies the fourth key principle and is, therefore, acceptable.

Key Principle 5: Performance Measurement Strategies - Implementation and Monitoring RGs 1.174 and 1.177 establish the need for an implementation and monitoring program to ensure that extensions to TS CTs do not degrade operational safety over time and that no adverse degradation occurs due to unanticipated degradation or common cause mechanisms. 1, Monitoring Program, to the LAR states that the SSCs in scope of the RICT program are also in scope of 10 CFR 50.65 for the Maintenance Rule. The Maintenance Rule monitoring programs will provide for evaluation and disposition of unavailability impacts, which

ML23059A259 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME JDrake PBlechman JDixon-Herrity JDrake DATE 3/1/2023 3/6/2023 3/6/2023 3/7/2023