W3F1-2005-0003, Supplement to Amendment Request NPF-38-258, Modify Technical Specification (TS) 5.3.1, Fuel Assemblies and TS 6.9.1.11.1, Core Operating Limits

Supplement to Amendment Request NPF-38-258, Modify Technical Specification (TS) 5.3.1, Fuel Assemblies and TS 6.9.1.11.1, Core Operating Limits

ML050420221
Person / Time
Site:	Waterford
Issue date:	02/02/2005
From:	Dodds R Entergy Nuclear Operations, Entergy Nuclear South
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2005-0003
Download: ML050420221 (10)

Text

Entergy Nuclear South Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504 739 6379 16Entergy Fax 504 739 6698 rdodds~entergy.com R.A. (A!) Dodds, IlIl Director. Nuclear Safety Assurance Waterford 3 W3F1 -2005-0003 February 2, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Supplement to Amendment Request NPF-38-258, Modify Technical Specification (TS) 5.3.1, Fuel Assemblies and TS 6.9.1.11.1, Core Operating Limits Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCES:

1. Entergy letter to the NRC dated June 20, 2004, "License Amendment Request to Modify Technical Specification (TS) 5.3.1, Fuel Assemblies and TS 6.9.1.11.1, Core Operating Limits" (W3F1-2004-0036)

2. Entergy letter to the NRC dated October 18, 2004, "Supplement to Amendment Request NPF-38-258, Modify Technical Specification (TS) 5.3.1, Fuel Assemblies and TS 6.9.1.11.1, Core Operating Limits" (W3Fl-2004-0099)

Dear Sir or Madam:

By letters (References 1 and 2), Entergy Operations, Inc. (Entergy) proposed a change to the Waterford Steam Electric Station, Unit 3 (Waterford 3) Technical Specifications (TSs) to support the cycle 14 core reload.

On November 5, 2004 and December 6, 2004, Entergy and members of your staff held conference calls to further discuss the proposed change. Entergy's response is contained in the attachment to this letter.

A new administrative change to TS 6.9.1.11.1 item 6), "CESEC-Digital Simulation for a Combustion Engineering Nuclear Steam Supply System," is also included.

There are no technical changes proposed. The original no significant hazards consideration included in Reference 1 is not affected by any information contained in the supplemental letter. There are revised commitments contained in this letter.

If you have any questions or require additional information, please contact Dana Millar at 601-368-5445.

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W3F1 -2005-0003 Page 2 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on February 2, 2005.

Sincerely, RAD/DM/ssf Attachments:

1. Response to Request for Additional Information

2. Proposed Technical Specification Changes (mark-up)

3. List of Regulatory Commitments

W3Fl-2005-0003 Page 3 of 3 cc: Dr. Bruce S. Mallett U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Senior Resident Inspector Waterford 3 P.O. Box 822 Killona, LA 70066-0751 U.S. Nuclear Regulatory Commission Attn: Mr. Nageswaran Kalyanam MS O-7D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway Attn: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn Attn: N.S. Reynolds 1400 L Street, NW Washington, DC 20005-3502 Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division P. 0. Box 4312 Baton Rouge, LA 70821-4312 American Nuclear Insurers Attn: Library Town Center Suite 300S 2 9 th S. Main Street West Hartford, CT 06107-2445

Attachment 1 To W3F1 -2005-0003 Response to Request for Additional Information to W3F1 -2005-0003 Page 1 of 2 Question 1:

The licensee indicated that if the mFDI and measured oxide thickness from the CE lead plant utilizing ZIRLOTM correlate as expected, then Waterford 3 will no longer restrict the mFDl except as required to meet the 100 oxide limit. Please clarify whether the licensee intends to lift the restriction on fuel duty without the NRC's evaluation of the licensee submittal of the appropriate ZIRLO corrosion data from CE fuel design.

Response 1:

Entergy will not lift the ZIRLOTM modified Fuel Duty Index (mFDI) restriction without either NRC approval of a supplement to CENPD 404-P-A that includes corrosion data from two Combustion Engineering plants (not at the same plant site) or NRC approval of Waterford Steam Electric Station, Unit 3 (Waterford 3) site specific corrosion data.

By letter dated June 20, 2004 (W3Fl-2004-0036), Entergy stated that the maximum mFDI based on actual 16 X 16 Combustion Engineering designed fuel is 590. This value was based on information from Palo Verde and did not consider Waterford 3 plant specific considerations.

The calculated Waterford 3 plant specific mFDI is 570. To provide adequate margin to account for variations in core design, Entergy will restrict the mFDI for each ZIRLOTM clad fuel pin to 110% of the established Waterford 3 plant specific mFDI limit of 570 (i.e., 627). For a fraction of ZIRLOTM clad fuel pins in a limited number of fuel assemblies (no more than eight fuel assemblies), the fuel duty will be restricted to 120% of the Waterford 3 plant specific mFDI limit of 570 (i.e., 684). The basis for the 110% and 120% multiplier was supplied by letter to the NRC dated October 18, 2004 (W33F1-2004-0099).

The basis for the mFDI limit of 570 for Waterford 3 is that the ZIRLOTM fuel rod cladding would be allowed to operate within the current (OPTIN')fuel rod cladding operational limits (of less than 100 microns best estimate maximum oxide thickness and with no more than minor spallation). A survey of actual Waterford 3 reactor cycles resulted in selection of a particular set of cycles resulting in relatively adverse corrosion performance for identifying the ZIRLOTM mFDI experience limit of 570. The calculation to derive the mFDI experience limit was based on an actual multiple cycle fuel management for the Waterford 3 plant, but modified analytically to push the current (OPTINTM) fuel rod cladding beyond its expected performance for the fuel management, but not beyond the current cladding's operational limits. This was accomplished with an increase in power level to the new uprate power level for two consecutive cycles along with an increase in the reactor coolant temperature and decrease in vessel flow rate, both in an adverse direction for fuel rod corrosion but within the current Technical Specification limits.

Proposed Change The proposed change corrects the title of the analytical method referenced in Technical Specification (TS) 6.9.1.11.1 item 6. The phrase uCENPD-107' will be removed. UCENPD-107' is a Topical Report that supports CESEC-1 and CESEC-Il. The approved analytical method used at Waterford 3 is CESEC-Ill, which is titled, "CESEC - Digital Simulation for a Combustion Engineering Nuclear Steam Supply System." CESEC-Ill was approved for Waterford 3 in the NRC Safety Evaluation Report (TAC No.:01142). Waterford 3 inappropriately included "CENPD-1 07" in a requested change to the TSs (Waterford 3 letter to the NRC dated August to W3FI -2005-0003 Page 2 of 2 11, 1994 and supplemented December 2, 1994), NRC approval of which is reflected in TS amendment number 102. The proposed change is an administrative change and as such no changes are needed to the No Significant Hazards Analysis that was submitted in support of the license amendment request to modify TS 5.3.1, Fuel Assemblies and TS 6.9.1.11.1, Core Operating Limits (Entergy letter to the NRC dated June 20, 2004, W3Fl-2004-0036). A markup of page 6-20a is included in Attachment 2 to this letter. No changes are proposed to any of the other marked up TS pages or to the inserts included in the original submittal dated June 20, 2004.

Attachment 2 To W3FI-2005-0003 Proposed Technical Specification Changes (mark-up) to W3Fl-2005-0003 Page 1 of 1 ADMINISTRAMiVE CONTROLS CORE OPERATING LIMITS REPORT COLR (Continued)

6) -CESEC.-Digqtlinmulation for a Combustion Engineering Nuclear-6team Supply FxSyste2 j3 (Methodology for Specification 3.1.1.1 and 3.1.1.2 for Shutdown Lins, 3.1 for MTC, 3.1.3.1 for Movable Control Assemblies - CEA Position, 3.1.3.6 for Regulating and group P CEA Insertion Limits, and 3.2.3 for Azimuthal Power Tilt).

7) "Qualification of Reactor Physics Methods for the Pressurized Water Reactors of the Entergy System," ENEAD-01-P. (Methodology for Specifications 3.1.1.1 and 3.1.1.2 for Shutdown Margins, 3.1.1.3 for MTC, 3.1.3.6 for Regulating and group P CEA Insertion Limits, 3.1.2.9 Boron Dilution (Calculation of CBC & IBW), and 3.9.1 Boron Concentration).

8)'Fuel Rod Maximum Allowable Gas Pressure," CEN-372-P-A. (Methodology for Specification 3.2.1, Linear Heat Rate).

6.9.1.11.2 The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal limits, core thermal-hydraulic limits, ECCS limits, nuclear limits such as shutdown margin, and transient and accident analysis limits) of the safety analysis are met.

6.9.1.11.3 The CORE OPERATING LIMITS REPORT, including any mid-cycle revisions or supplements thereto, shall be provided upon Issuance, for each reload cycle, to the NRC Document Control Desk with copies to the Regional Administrator and Resident Inspector.

SPECIAL REPORTS 6.9.2 Special reports shall be submitted in accordance with 10 CFR 50.4 within the time period specified for each report.

6.10 Not Used AMENDMENT NO. 402 1 4 6,8, 8 2, WATERFORD - UNIT 3 6-20a 480,19t

Attachment 3 To W3FI-2005-0003 List of Regulatory Commitments to W3F1 -2005-0003 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED ONE- CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)

The nominal value of 1830 grams of uranium for x Per each fuel rod will be added to the FSAR. 10CFR50.71(e)

Prior to the use of lead test assemblies (LTAs), fuel Prior to designs will be analyzed with applicable NRC staff incorporating approved codes and methods and shown by tests or LTAs in the analyses to comply with all fuel safety design bases core and while and to assure no new or different kind of accident LTAs are in the from any accident previously evaluated will be core.

created.

The maximum allowable corrosion limit of 100 Prior to the use microns will be added to the Waterford 3 FSAR. of ZIRLOTM cladding.

The corrosion thickness will be calculated .using the Prior to the use best estimate models and methods described in of ZIRLOTm and topical report CENPD-404-P. each core reload that contains ZIRLOTm fuel cladding material.

ZIRLO' M data ranges for the methodologies in Prior to the use which they are used will be verified during the of ZIRLOTm and reload/core design process that is employed for use each core of methodologies. reload that contains ZIRLOTM fuel cladding material.

The upper design limits for Waterford 3 fuel will be X limited to mFDI values of 627 for the majority of the fuel assemblies and 684 for a fraction of fuel pins in a limited number of assemblies (no more than eight fuel assemblies).

Entergy will not lift the modified Fuel Duty Index X (mFDI) restriction without either NRC approval of a supplement to CENPD 404-P-A that includes corrosion data from two Combustion Engineering plants (not at the same plant site) or NRC approval of Waterford Steam Electric Station, Unit 3 (Waterford 3) site specific corrosion data.