W3F1-2024-0042, License Amendment Request to Extend Allowable Outage Times for One or More Control Room Air Conditioning Units Inoperable

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License Amendment Request to Extend Allowable Outage Times for One or More Control Room Air Conditioning Units Inoperable
ML24290A141
Person / Time
Site: Waterford Entergy icon.png
Issue date: 10/16/2024
From: Couture P
Entergy Operations
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
W3F1-2024-0042
Download: ML24290A141 (1)
v • d • e


Text

Phil Couture Senior Manager Fleet Regulatory Assurance - Licensing 601-368-5102

Entergy Operations, Inc. 1340 Echelon Parkway, Jackson, MS 39213 W3F1-2024-0042 10 CFR 50.90 October 16, 2024 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

License Amendment Request to Extend Allowable Outage Times for One or More Control Room Air Conditioning Units Inoperable Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 As required by 10 CFR 50.90, Entergy Operations, Inc. (Entergy), hereby requests Nuclear Regulatory Commission (NRC) approval to extend the allowable outage times (AOTs) associated with specific Waterford Steam Electric Station, Unit 3 (WF3), Technical Specification (TS) Action requirements. As described in enclosure to this letter, the AOT for one inoperable control room air conditioning unit is proposed to be extended from 7 days to 30 days and the AOT when both control room air conditioning units are inoperable extended from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In addition, the current WF3 TSs separate control room air conditioning unit requirements into specifications governing operation in Modes 1, 2, 3, and 4, and operation in Modes 5 or 6, and during load movements with or over irradiated fuel assemblies. This amendment request combines these separate specifications into a single specification. The proposed AOTs and combination of all control room air conditioning unit Mode requirements into one specification are consistent with those presented in NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants," Revision 5 (Reference 1).

The enclosure provides a description and assessment of the proposed change.

of the enclosure provides the existing TS pages marked up to show the proposed changes.

provides, for information only, existing TS Bases pages marked to show the proposed changes.

provides retyped (clean) TS pages.

Entergy requests approval of the proposed license amendment by October 1, 2025, in order to support an essential services chiller replacement project. The proposed changes would be implemented within 90 days of issuance of the amendment.

W3F1-2024-0042 Page 2 of 3 This request is similar, in part, to that approved for Arkansas Nuclear One, Unit 2 (ANO-2) on December 29, 2016 (Reference 2), which adopted Technical Specification Task Force (TSTF)

Traveler TSTF-426, Revision 5 (Reference 3).

This letter contains no new regulatory commitments.

Should you have any questions concerning this issue, please contact John R. Twarog, Manager, WF3 Regulatory Assurance, at 504-739-6747.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), a copy of this license amendment request, with enclosure, is being provided to the designated State Officials.

I declare under penalty of perjury, that the foregoing is true and correct.

Executed on October 16, 2024.

Respectfully, Phil Couture PC/dbb/chm

Enclosure:

Evaluation of the Proposed Change Attachments to

Enclosure:

1.

Technical Specification Page Markups

2.

Technical Specification Bases Page Markups (For Information Only)

3.

Technical Specification Pages Retype

References:

1.

NRC, "Standard Technical Specifications - Combustion Engineering Plants," NUREG-1432, Revision 5, Volume 1, Specifications, ML21258A421, September 2021

2.

NRC Letter to Arkansas Nuclear One, Unit 2, "Issuance of Amendment Re: Revise Technical Specifications to Adopt TSTF-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c," ML16267A139, December 29, 2016

3.

NRC Notice of Availability - TSTF-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c,"

ML13036A381 as published in the Federal Register (78 FR 32476) on May 30, 2013 Digitally signed by Philip Couture DN: cn=Philip Couture, c=US, o=Entergy, ou=Regulatory Assurance, email=pcoutur@entergy.com Date: 2024.10.16 12:46:42 -05'00' Philip Couture

W3F1-2024-0042 Page 3 of 3 cc:

NRC Region IV Regional Administrator NRC Senior Resident Inspector - WF3 NRC Project Manager - WF3 Designated State Official - Louisiana

Enclosure W3F1-2024-0042 Evaluation of the Proposed Change

W3F1-2024-0042 Enclosure Page 1 of 10 TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION............................................................................................... 2 2.0 DETAILED DESCRIPTION................................................................................................ 2 2.1 System Design and Operation........................................................................................ 2 2.2 Current TS Requirements............................................................................................... 2 2.3 Reason for the Proposed Change.................................................................................. 3 2.4 Description of the Proposed Change.............................................................................. 3

3.0 TECHNICAL EVALUATION

............................................................................................... 4 3.1 Conclusion...................................................................................................................... 6

4.0 REGULATORY EVALUATION

........................................................................................... 6 4.1 Applicable Regulatory Requirements/Criteria................................................................. 6 4.2 Precedent....................................................................................................................... 6 4.3 No Significant Hazards Consideration Analysis.............................................................. 7 4.4 Conclusions.................................................................................................................... 9

5.0 ENVIRONMENTAL CONSIDERATION

............................................................................. 9

6.0 REFERENCES

................................................................................................................. 10 7.0 ATTACHMENTS.............................................................................................................. 10

W3F1-2024-0042 Enclosure Page 2 of 10 EVALUATION OF THE PROPOSED CHANGE 1.0

SUMMARY

DESCRIPTION As required by 10 CFR 50.90, Entergy Operations, Inc. (Entergy), hereby requests Nuclear Regulatory Commission (NRC) approval to extend the allowable outage times (AOTs) associated with specific Waterford Steam Electric Station, Unit 3 (WF3), Technical Specification (TS) Action requirements. The AOT for one inoperable control room air conditioning unit is proposed to be extended from 7 days to 30 days and the AOT when both control room air conditioning units are inoperable extended from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In addition, the current WF3 TSs separate control room air conditioning unit requirements into specifications governing operation in Modes 1, 2, 3, and 4, and operation in Modes 5 or 6, and during load movements with or over irradiated fuel assemblies. This amendment request combines these separate specifications into a single specification. The proposed AOTs are consistent with those presented in NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants," Revision 5 (Reference 1), for one or more inoperable Control Room Emergency Air Temperature Control System (CREATCS) trains.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The WF3 Control Room Air Conditioning System (CRACS) provides temperature control for the control room during normal operations and following isolation of the control room. CRACS consists of two full capacity safety related redundant air conditioning units. The redundant air conditioning units are served by redundant safety related loops of the Essential Services Chilled Water System (ESCWS) such that loss of one loop of the ESCWS does not affect ability of the CRACS to control the thermal environment in the control room envelope. The redundant equipment essential for the safety functions are powered from vital electrical Divisions A and B of the Plant Electric Power Distribution System such that loss of one division does not prevent the CRACS from fulfilling its safety function.

2.2 Current TS Requirements WF3 TS 3.7.6.3 requires two control room air conditioning units to be operable in Modes 1, 2, 3, and 4. With one unit inoperable, Action a requires restoration of the inoperable unit within 7 days; otherwise, a plant shutdown is required. With both units inoperable, Action b requires restoration of at least one unit to operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> followed by a plant shutdown if this requirement is not met.

WF3 TS 3.7.6.4 requires two control room air conditioning units to be operable in Modes 5 and 6, and during load movements with or over irradiated fuel assemblies. With one unit inoperable, Action a requires restoration of the inoperable unit within 7 days; otherwise, the operable unit must be placed and maintained in service. With both units inoperable, or if the operable unit placed in service in accordance with Action a is not capable of being powered by an operable emergency power source, Action b requires suspending all operations involving core alterations and load movements with or over irradiated fuel assemblies.

W3F1-2024-0042 Enclosure Page 3 of 10 2.3 Reason for the Proposed Change To reduce redundancy and provide enhanced consistency in requirements, the two WF3 CRACS specifications are combined into a single specification (proposed TS 3.7.6.3),

consistent with the improved standard technical specifications (ISTS) of NUREG-1432, Revision 5 (Reference 1). Also consistent with the ISTS, the 7-day restoration period of both specifications is extended to 30 days in order to avoid the unnecessary risk of a unit shutdown should restoration of an inoperable unit not be possible within the current 7-day period (further discussion provided in Section 3.0 of this letter). Furthermore, the ESCWS is a required TS support system for the control room air conditioning units. As indicated in WF3 TS 3.7.12, inoperability of an ESCWS train requires restoration of the train within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time (RICT) Program. Because the AOT for a single inoperable train of ESCWS can be as long as 30 days under the RICT Program and because an inoperable ESCWS train renders the associated control room air conditioning unit inoperable, the current 7-day AOT for an inoperable control room air conditioning unit can be limiting during recovery of an inoperable ESCWS train, potentially resulting in an unnecessary plant shutdown.

In addition, with both control room air conditioning units inoperable in Modes 1, 2, 3, or 4, the time allowed to restore at least one unit to an operable status before further remedial action is necessary is extended from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, consistent with the ISTS. This again is intended to avoid the unnecessary risk of a unit shutdown should restoration of an inoperable unit not be possible within the current 1-hour period.

Finally, the requirement for maintaining an emergency power source to an operable control room air conditioning unit placed in service in accordance with TS 3.7.6.3, Action a, (reference TS 3.7.6.4, Action b, which is applicable in Modes 5 and 6, and during load movements with or over irradiated fuel assemblies) is eliminated because the ability of the operable control room air conditioning unit to support the control room habitability cooling function is independent of the specific source of the power, provided the power source is a qualified electrical power source.

2.4 Description of the Proposed Change As stated, when one control room air conditioning unit is inoperable in any of the current required modes or conditions for operability, the AOT to restore the unit to an operable status is extended from 7 days to 30 days.

With both units inoperable in Modes 1, 2, 3, or 4, the AOT to restore at least one unit to an operable status is extended from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This requirement is modified by a Note

  • which prohibits use of the 24-hour allowance if the second control room air conditioning unit is intentionally made inoperable, consistent with the ISTS.

The TS 3.7.6.4, Action b, statement associated with maintaining an emergency power source for a control room air conditioning unit placed in service in accordance with TS 3.7.6.4, Action a, is eliminated.

W3F1-2024-0042 Enclosure Page 4 of 10 In order to support the combining of the two mode/condition dependent specifications into one and to reduce redundancy in wording, Actions are proposed to be rearranged or added as needed, maintaining the current requirements except for the proposed changes previously described:

The shutdown statements of TS 3.7.6.3, Actions a and b, will be relocated to a new Action c to reduce redundancy.

The Limiting Condition for Operation (LCO) statement and Applicability of TS 3.7.6.4 will be included in the LCO statement and Applicability of TS 3.7.6.3.

The restoration period of TS 3.7.6.4, Action a, will now be contained in Action a of TS 3.7.6.3.

The TS 3.7.6.4, Action a, requirement to place the remaining operable control room air conditioning unit in service is relocated as TS 3.7.6.3, Action d.1.

New Action d.2 is added to TS 3.7.6.3 to address not meeting the TS 3.7.6.4, Action a, requirement to place the operable control room air conditioning unit in operation.

Consistent with TS 3.7.6.4, Action b, new TS 3.7.6.3, Action d.2, requires the suspension of all operations involving core alterations and load movements with or over irradiated fuel assemblies, when TS 3.7.6.4, Action a, is not met.

With respect to the suspension of all operations involving core alterations and load movements with or over irradiated fuel assemblies, a time of "immediately" is added to TS 3.7.6.3, Actions d.2 and e, for clarity.

With TS 3.7.6.3 "Control Room Air Temperature - Operating" and TS 3.7.6.4 "Control Room Air Temperature - Shutdown" being combined, the title of TS 3.7.6.3 is changed to "Control Room Air Temperature."

Reformatting or administrative changes required to support the combining of the two specifications are considered administrative and result in no technical changes to the requirements. With these changes, the new WF3 TS 3.7.6.3 "Control Room Air Temperature" is consistent with ISTS 3.7.12 "Control Room Emergency Air Temperature Control System (CREATCS)."

ISTS uses the acronym CREATCS whereas the WF3 TS does not uses an acronym for "Control Room Air Temperature." Entergy has determined that for the purpose of the TS changes, ISTS CREATCS is consistent with WF3 "Control Room Air Temperature."

3.0 TECHNICAL EVALUATION

The WF3 control room air conditioning requirements are contained in two separate specifications: 1) a specification governing operation in Modes 1, 2, 3, and 4 (TS 3.7.6.3) and,

2) a specification governing operation in Modes 5 and 6, and during load movements with or over irradiated fuel assemblies (TS 3.7.6.4). Both specifications require two control room air conditioning units to be operable and are being combined into a single specification, consistent with the ISTS (Reference 1).

The purpose of restoring an inoperable control room air conditioning unit to operable status within a specified time period (Action a of TS 3.7.6.3 and TS 3.7.6.4) is to provide a degree of assurance that the CRACS can provide cooling when required. Extending the specified

W3F1-2024-0042 Enclosure Page 5 of 10 restoration time from 7 days to 30 days is acceptable because the proposed AOT is consistent with safe operation under the specified condition, considering the operable status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a design basis accident (DBA) occurring during the provided AOT. The CRACS train is still required to be restored to an operable status and the CRACS function can be met without the redundant air conditioning unit.

Extending the AOT to restore at least one control room air conditioning unit when both units are inoperable in Modes 1, 2, 3, or 4 from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is consistent with NRC-approved Technical Specification Task Force (TSTF) Traveler TSTF-426, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c," Revision 5 (Reference 3), as published in the Federal Register on May 30, 2013 (78 FR 32476), and the ISTS (Reference 1).

The acceptability of this AOT extension contained in TSTF-426 was based on WCAP-16125-NP-A, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown" (Reference 4), which demonstrated that the 24-hour AOT is acceptable based on the infrequent use of the ACTION and the small incremental effect on plant risk.

The 24-hour allowance is modified by a Note

  • which prohibits application of the AOT if the second control room air conditioning unit is intentionally made inoperable. The AOT does not apply to voluntary removal of redundant systems or components from service. The AOT is only applicable if one train is inoperable for any reason and the second train is discovered to be inoperable, or if both trains are discovered to be inoperable at the same time. In this respect, intentional removal of the second CRACS train from service would result in LCO 3.0.3 entry (i.e., the current 1-hour restoration time allowance of WF3 TS 3.7.6.3, Action b, will no longer exist).

WCAP-16125-NP-A determined that the unavailability of the CREACS (WF3 CRACS) has a negligible impact on severe accident risk, based on sufficient heat-up times given the availability of alternate cooling strategies, and alternate means to control emergency systems locally. With respect to alternate cooling strategies, Entergy confirms that plant procedures can establish temporary alternate means of Control Room cooling, as assumed in the justification of the proposed change to the "Control Room Air Temperature." (reference procedure OP-901-515, "Loss of Control Room Cooling"). Entergy has verified WCAP-16125-NP-A is applicable to WF3.

With respect to eliminating the statement from TS 3.7.6.4, Action b, associated with maintaining an emergency power source for a control room air conditioning unit placed in service in accordance with TS 3.7.6.4, Action a, the WF3 TS definition for OPERABLE simply states "electrical power" as a necessary component for operability. Each TS-required control room air conditioning unit can be powered from either its respective vital electrical train supported by either a qualified offsite power source or the train's associated emergency diesel generator.

The purpose of this statement contained in TS 3.7.6.4, Action b, is to ensure power is available to the remaining control room air conditioning unit to maintain control room habitability (ambient cooling) and to mitigate the consequences of postulated events during shutdown. WF3 TS 3.7.6.3, Action d.1, retains the requirement for the operable control room cooling unit to be placed and maintained in operation. Eliminating specific reference to an emergency power supply is acceptable since it is consistent with the definition of OPERABLE and because the

W3F1-2024-0042 Enclosure Page 6 of 10 ability of the operable control room air conditioning unit to support the control room habitability cooling function is independent of the specific source of the power, provided the power source is a qualified electrical power source.

Proposed WF3 TS 3.7.6.4, Action a (applicable in Modes 5 and 6, and during load movements with or over irradiated fuel assemblies), requires restoring an inoperable control room air conditioning unit (when only one of the two are inoperable) within 30 days or the operable control room air conditioning unit must be placed and maintained in operation. This specification does not contain a remedial action should Action a not be met. Therefore, new TS 3.7.6.3, Action d.2, is proposed, which would require the immediate suspension of all operations involving core alterations and load movements with or over irradiated fuel assemblies, consistent with current requirement of Action b when both control room air conditioning units are inoperable. Entergy considers this change necessary to address not meeting Action a, given that LCO 3.0.3 is not applicable in Modes 5 and 6.

Finally, formatting changes were made to support the combining of the two specifications.

These changes do not result in a technical change to any current WF3 TS requirement.

3.1 Conclusion Based on the above, Entergy concludes that the proposed changes conform to the current WF3 TS requirements, the ISTS, and/or TSTF-426. Attachment 1 of this enclosure includes a markup of the affected TS pages. Attachment 2 of this enclosure includes a markup of the associated TS Bases, for information only. Because the WF3 TS Bases do not contain the detail of the ISTS Bases associated with the control room air conditioning units, the WF3 TS Bases are modified only where necessary to accommodate the changes proposed in this letter. of this enclosure includes a retyped (clean) copy of the affected TS pages. The formatting of the retyped pages has been slightly modified for professional appearance and is considered administrative only (i.e., reformatting involved no technical change to requirements).

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36 provides the requirement for all licenses to contain TSs. 10 CFR 50.36(c)(2) states that when a limiting condition for operation is not met, the licensee shall shut down the plant or follow any remedial action permitted by the TSs until the condition can be met. Thus, the regulatory requirements are not specific regarding the actions to be followed when TS requirements are not met. The proposed changes to the TS Actions do not affect regulatory requirements.

4.2 Precedent The AOT extension for one inoperable control room air conditioning unit from 7 days to 30 days is relatively generic in most U.S. commercial nuclear power facility TSs. In addition, the 30-day AOT for this condition was present in the original issuance (Revision 0) of NUREG-1432.

W3F1-2024-0042 Enclosure Page 7 of 10 This proposed 24-hour AOT for two inoperable control room air conditioning units in Modes 1, 2, 3, and 4 is based on TSTF-426 as described previously and on that approved for Arkansas Nuclear One, Unit 2 (ANO-2) on December 29, 2016 (Reference 2), which adopted TSTF-426.

Both WF3 and ANO-2 are digital Combustion Engineering plants.

4.3 No Significant Hazards Consideration Analysis Entergy Operations, Inc. (Entergy) has evaluated the proposed changes to the Waterford Steam Electric Station, Unit 3 (WF3) Technical Specifications (TSs) using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

Entergy proposes to extend the allowed outage times (AOTs) permitted for restoration of affected control room air conditioning units when one or both units are inoperable. In addition, an unnecessary reference to a required emergency power source supporting a remaining operable control room air conditioning unit during operations in Mode 5 or 6, or during load movements with or over irradiated fuel assemblies, is removed. Finally, a new Action is added to address the potential for not meeting the current WF3 action associated with one inoperable air conditioning unit while operating in Modes 5 or 6, or during load movements with or over irradiated fuel assemblies.

Basis for no significant hazards consideration determination: As required by 10 CFR 50.91(a),

Entergy analysis of the issue of no significant hazards consideration is presented below:

1.

Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The WF3 control room air conditioning units are not initiators of an accident previously evaluated. Extension of the AOT for one inoperable control room air conditioning unit from 7 days to 30 days is acceptable based on the low probability of an event occurring that would require control room isolation and concurrent or subsequent failure of the remaining operable control room air conditioning unit.

The proposed change extending the AOT from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when both control room air conditioning units are inoperable during operation in Modes 1, 2, 3, or 4 provides a short time to restore an inoperable unit for conditions under which the existing TSs require a plant shutdown if the affected unit is not restored within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Entering into TS Actions is not an initiator of any accident previously evaluated. As a result, the probability of an accident previously evaluated is not significantly increased. The consequences of any accident previously evaluated that may occur during the proposed AOT are no different from the consequences of the same accident during the existing 1-hour allowance. As a result, the consequences of any accident previously evaluated are not significantly increased.

The removal of the subject emergency power source reference is unrelated to any accident initiator. In addition, there is no significant impact to the consequences of any accident because each TS-required control room air conditioning unit can be powered

W3F1-2024-0042 Enclosure Page 8 of 10 from either a qualified offsite power source or the train's associated emergency diesel generator. The purpose of this statement is to ensure sufficient power is available to the remaining control room air conditioning unit to maintain control room habitability (ambient cooling) and to mitigate the consequences of postulated events during shutdown (operation in Mode 5 and 6) or during load movements with or over irradiated fuel assemblies. WF3 TS 3.7.6.3 retains the requirement for the operable control room cooling unit to be placed and maintained in operation. Eliminating specific reference to an emergency power supply is acceptable since it is consistent with the definition of OPERABLE and because the ability of the operable control room air conditioning unit to support the control room habitability cooling function is independent of the specific source of the power, provided the power source is a qualified electrical power source.

The addition of an Action addressing the potential for not meeting the current WF3 Action associated with one inoperable air conditioning unit while operating in Mode 5 or 6, or during load movements with or over irradiated fuel assemblies, is unrelated to accident initiators or accident consequences since regulatory requirements are not specific regarding the actions to be followed when TS requirements are not met. This change is considered conservative in that an Action is being provided to address a potential condition not previously addressed.

Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No No new or different accidents result from the proposed changes. The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements that could involve a new or different kind of accident previously evaluated. The changes do not alter assumptions made in the safety analysis.

Therefore, this change does not create the possibility of a new or different kind of accident from an accident previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No Extension of the AOT for one inoperable control room air conditioning unit from 7 days to 30 days is acceptable based on the low probability of an event occurring that would require control room isolation and concurrent or subsequent failure of the remaining operable control room air conditioning unit. Any increase in station risk during the 30-day AOT when one control room air conditioning unit is offset when considering the

W3F1-2024-0042 Enclosure Page 9 of 10 potential risks associated with performance of an unnecessary plant shutdown and the availability of redundant equipment along with alternate cooling methods available.

The proposed 24-hour AOT to restore at least one control room air conditioning unit to operable status when both control room air conditioning units are inoperable increases the time the plant may operate without the ability to perform an assumed safety function.

The analyses in WCAP-16125-NP-A, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent plant Shutdown,"

Revision 2, August 2010, demonstrated that there is an acceptably small increase in risk due to a limited period of continued operation in these conditions and that this risk is balanced by avoiding the risks associated with a plant shutdown. As a result, the change to the margin of safety provided by delaying plant shutdown for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not significant.

The removal of the subject emergency power source reference (associated with operation in Mode 5 or 6, or during load movements with or over irradiated fuel assemblies) does not result in a significant impact on the margin to safety because the ability of the operable control room air conditioning unit to support the control room habitability cooling function is independent of the specific source of the power, provided the power source is a qualified electrical power source.

The addition of an Action addressing the potential for not meeting the current WF3 action associated with one inoperable air conditioning unit while operating in Modes 5 or 6, or during load movements with or over irradiated fuel assemblies, is conservative, enhancing the margin to safety, given that LCO 3.0.3 is not applicable in Modes 5 and 6 (i.e., no remedial action is currently provided for this condition).

Therefore, this change does not involve a significant reduction in a margin of safety.

Based upon the reasoning presented above, Entergy concludes that the requested change involves no significant hazards consideration, as set forth in 10 CFR 50.92(c), "Issuance of Amendment."

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed

W3F1-2024-0042 Enclosure Page 10 of 10 change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6.0 REFERENCES

1.

NRC, "Standard Technical Specifications - Combustion Engineering Plants,"

NUREG-1432, Revision 5, Volume 1, Specifications, ML21258A421, September 2021

2.

NRC Letter to Arkansas Nuclear One, Unit 2, "Issuance of Amendment Re: Revise Technical Specifications to Adopt TSTF-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c," ML16267A139, December 29, 2016

3.

NRC Notice of Availability - TSTF-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c," ML13036A381 as published in the Federal Register (78 FR 32476) on May 30, 2013

4.

WCAP-16125-NP-A, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown," Revision 2, ML110070498, August 2010 7.0 ATTACHMENTS

1.

Technical Specification Page Markups

2.

Technical Specification Bases Page Markups

3.

Retyped Technical Specification Pages

Enclosure, Attachment 1 W3F1-2024-0042 Technical Specification Page Markups (3 Pages Follow)

WATERFORD - UNIT 3 3/4 7-18a AMENDMENT NO. 115,149,188,218,235,249, PLANT SYSTEMS CONTROL ROOM AIR TEMPERATURE - OPERATING LIMITING CONDITION FOR OPERATION 3.7.6.3 Two independent control room air conditioning units shall be OPERABLE.

APPLICABILITY*: MODES 1, 2, 3, 4, 5, and 46, and during load movements with or over irradiated fuel assemblies.

ACTION:

a.

With one control room air conditioning unit inoperable, restore the inoperable unit to OPERABLE status within 730 days or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.

With two control room air conditioning units inoperable in MODE 1, 2, 3, or 4, return at least one unit to an OPERABLE status within 124 hour0.00144 days <br />0.0344 hours <br />2.050265e-4 weeks <br />4.7182e-5 months <br />s* or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

c.

With ACTION a and/or b not met in MODE 1, 2, 3, or 4, be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

d.

With ACTION a not met in MODE 5 or 6, or with ACTION a not met during load movements with or over irradiated fuel assemblies:

1.

Immediately place OPERABLE control room air conditioning unit in operation, or

2.

Immediately suspend all operations involving CORE ALTERATIONS and load movements with or over irradiated fuel assemblies.

e.

With two control room air conditioning units inoperable in MODE 5 or 6, or during movement of irradiated fuel assemblies, immediately suspend all operations involving CORE ALTERATIONS and load movements with or over irradiated fuel assemblies.

SURVEILLANCE REQUIREMENTS 4.7.6.3 Each control room air conditioning unit shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that the operating control room air conditioning unit is maintaining average control room air temperature less than or equal to 80°F.

Move to new Action c.

WATERFORD - UNIT 3 3/4 7-18a AMENDMENT NO. 115,149,188,218,235,249,

b.

At least quarterly, if not performed within the last quarter, by verifying that each control room air conditioning unit starts and operates for at least 15 minutes.

  • During load movements with or over irradiated fuel assemblies, TS 3.7.6.4 is also applicable.
  • ACTION b is not applicable when the second control room air conditioning unit is intentionally made inoperable.

Moved to Applicability

WATERFORD - UNIT 3 3/4 7-18b AMENDMENT NO. 115,149,188,235, PLANT SYSTEMS CONTROL ROOM AIR TEMPERATURE - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.7.6.4 Two independent control room air conditioning units shall be OPERABLE.

APPLICABILITY: MODES 5 and 6, and during load movements with or over irradiated fuel assemblies.

ACTION:

a.

With one control room air conditioning unit inoperable, restore the inoperable system to OPERABLE status within 730 days or initiate and maintain operation of the remaining OPERABLE control room air conditioning unit.

b.

With both control room air conditioning units inoperable, or with the OPERABLE control room air conditioning unit, required to be in operation by ACTION a, not capable of being powered by an OPERABLE emergency power source, immediately suspend all operations involving CORE ALTERATIONS and load movements with or over irradiated fuel assemblies.

SURVEILLANCE REQUIREMENTS 4.7.6.4 The control room air conditioning units shall be demonstrated OPERABLE per the Surveillance Requirements of 4.7.6.3.

3.7.6.3 3.7.6.3 Applicability ACTION a ACTION d.1 ACTION e 4.7.6.3 Reference Location in TS 3.7.6.3 where items are now addressed.

FYI - ADD TS 3.7.6.3, Action d.2, addressing failure to meet TS 3.7.6.4, Action a.

All text (with exception of the footer) is being removed from this page (3/4 7-18b) as shown in the reference given in the left margin.

The following text will be added in the center of the page:

THIS PAGE HAS BEEN DELETED

Enclosure, Attachment 2 W3F1-2024-0042 Technical Specification Bases Page Markups (For Information Only)

(2 Pages Follow)

WATERFORD - UNIT 3 B 3/4 7-4b AMENDMENT NO. 115, 149, 170 CHANGE NO. W, 59, 71, 86 PLANT SYSTEMS BASES 3/4.7.6.3 and 3/4.7.6.4 CONTROL ROOM AIR TEMPERATURE Maintaining the control room air temperature less than or equal to 80°F ensures that (1) the ambient air temperature does not exceed the allowable air temperature for continuous duty rating for the equipment and instrumentation in the control room, and (2) the control room will remain habitable for operations personnel during plant operation.

The Control Room Air Conditioning System (CRACS) is designed to cool the outlet air to approximately 55°F. Then, non-safety-related near-room heaters add enough heat to the air stream to keep the rooms between 70 and 75°F. Although 70 to 75°F is the normal control band, it would be too restrictive as an LCO. Control Room equipment was specified for a more general temperature range to 45 to 120°F. A provision for the CPC microcomputers, which might be more sensitive to heat, is not required here. Since maximum outside air make-up flow in the normal ventilation mode comprises less than ten percent of the air flow from an AH-12 unit, outside air temperature has little affect effect on the AH-12s cooling coil heat load.

Therefore, the ability of an AH-12 unit to maintain control room temperature in the normal mode gives adequate assurance of its capability for emergency situations.

>(EC-38571, Ch. 71)

With one CRACS train inoperable, action must be taken to restore OPERABLE status within 30 days. In this condition, the remaining OPERABLE CRACS train is adequate to maintain the control room temperature within limits. The 30-day restoration period is reasonable based on the low probability of an event occurring requiring control room isolation, consideration that the remaining train can provide the required capabilities, and the alternate safety or nonsafety related cooling means that are available.

With two CRACS trains inoperable in MODE 1, 2, 3, or 4, at least one CRACS train must be returned to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The condition is modified by a Note stating it is not applicable if the second CRACS train is intentionally declared inoperable. The condition does not apply to voluntary removal of redundant systems or components from service. The condition is only applicable if one train is inoperable for any reason and the second train is discovered to be inoperable, or if both trains are discovered to be inoperable at the same time.

The restoration period is based on WCAP-16125-NP-A, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown," Revision 2, August 2010, which demonstrated that the 24-hour period is acceptable based on the infrequent use of the allowance and the small incremental effect on plant risk.

In MODE 5 or 6, or during load movements with or over irradiated fuel assemblies, when a single inoperable CRACS train cannot be restored within 30 days, the OPERABLE CRACS train must be placed in operation immediately. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure will be readily detected. An alternative to placing the OPERABLE CRACS train in service is to immediately suspend all operations involving CORE ALTERATIONS and load movements with or over irradiated fuel assemblies. This places the unit in a condition that minimizes the accident risk by reducing the potential for a release of activity that may result in control room isolation.

WATERFORD - UNIT 3 B 3/4 7-4b AMENDMENT NO. 115, 149, 170 CHANGE NO. W, 59, 71, 86 In MODE 5 or 6, or during load movements with or over irradiated fuel assemblies, with two CRACS trains inoperable, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes the accident risk.

The ACTION to suspend all operations involving load movement with or over irradiated fuel assemblies shall not preclude completion of movement to a safe conservative position.

The fuel handling accident (UFSAR Section 15.7.3.4) analysis assumes protection against load movements with or over irradiated fuel assemblies that could cause fuel assembly damage.

Examples of load movements include movement of new fuel assemblies, irradiated fuel assemblies, and the dummy fuel assembly. The load movements do not include the movement over assemblies in a transfer cask using a single-failure-proof handling system. The load movements do not include the movement of the spent fuel machine or refuel machine without loads attached. It also does not include load movements in containment when the reactor vessel head or Upper Guide Structure is still installed. Load movements also exclude suspended loads weighing less than 1000 lbm (e.g. Westinghouse analysis CN-NFPE-09-57 describes no fuel failure for loads weighing less than 1000 lbm based upon the 2000 lbm analysis for drops distributed over two assemblies).

<(EC-38571, Ch. 71)

-+(LBDCR 16-046, Ch. 86)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

+(LBDCR 16-046, Ch. 86) 3/4.7.6.4 [NOT USED]

>(EC-15550, Ch. 59) 3/4.7.6.5 [NOT USED]

<(EC-15550, Ch. 59)

Enclosure, Attachment 3 W3F1-2024-0042 Technical Specification Pages Retype (2 Pages Follow)

WATERFORD - UNIT 3 3/4 7-18a AMENDMENT NO. 115,149,188,218, 235,249, PLANT SYSTEMS CONTROL ROOM AIR TEMPERATURE LIMITING CONDITION FOR OPERATION 3.7.6.3 Two independent control room air conditioning units shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, 4, 5, and 6, and during load movements with or over irradiated fuel assemblies.

ACTION:

a.

With one control room air conditioning unit inoperable, restore the inoperable unit to OPERABLE status within 30 days.

b.

With two control room air conditioning units inoperable in MODE 1, 2, 3, or 4, return at least one unit to an OPERABLE status within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s*.

c.

With ACTION a and/or b not met in MODE 1, 2, 3, or 4, be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

d.

With ACTION a not met in MODE 5 or 6, or with ACTION a not met during load movements with or over irradiated fuel assemblies:

1.

Immediately place OPERABLE control room air conditioning unit in operation, or

2.

Immediately suspend all operations involving CORE ALTERATIONS and load movements with or over irradiated fuel assemblies.

e.

With two control room air conditioning units inoperable in MODE 5 or 6, or during movement of irradiated fuel assemblies, immediately suspend all operations involving CORE ALTERATIONS and load movements with or over irradiated fuel assemblies.

SURVEILLANCE REQUIREMENTS 4.7.6.3 Each control room air conditioning unit shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that the operating control room air conditioning unit is maintaining average control room air temperature less than or equal to 80°F.

b.

At least quarterly, if not performed within the last quarter, by verifying that each control room air conditioning unit starts and operates for at least 15 minutes.

  • ACTION b is not applicable when the second control room air conditioning unit is intentionally made inoperable.

WATERFORD - UNIT 3 3/4 7-18b AMENDMENT NO. 115,149,188,235, THIS PAGE HAS BEEN DELETED

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