W3F1-2008-0021, Supplement 2 RAI Response to Amendment Request NPF-38-271 to Support Next Generation Fuel

Supplement 2 RAI Response to Amendment Request NPF-38-271 to Support Next Generation Fuel

ML080720667
Person / Time
Site:	Waterford
Issue date:	03/10/2008
From:	Cook K Entergy Nuclear South, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2008-0021
Download: ML080720667 (8)

Text

Entergy Nuclear South Entergy Operations, Inc.

17265 River Road Ah Entergy Killona, LA 70057-3093 Tel 504 739 6247 Fax 504 739 6698 kcook@entergy.com Kimberly S. Cook Director, Nuclear Safety Assurance Nuclear'Safety Assurance Waterford 3 W3F1-2008-0021 March 10, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Supplement 2 RAI Response to Amendment Request NPF-38-271 to Support Next Generation Fuel Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCES:

1. Entergy letter dated August 2, 2007, "License Amendment Request NPF-38-271 to Support Next Generation Fuel" (W3F1-2007-0037)

2. Entergy letter dated January 17, 2008, "Supplement to Amendment Request NPF-38-271 to Support Next Generation Fuel" (W3F1-2008-0004)

3. NRC Request for Additional Information Regarding "License Amendment Request NPF-38-271 to Support Next Generation Fuel,"

dated February 12, 2008 (TAC NO. MD6299)

Dear Sir or Madam:

By letter (Reference 1), Entergy Operations, Inc. (Entergy) proposed a change to the Waterford Steam Electric Station, Unit 3 (Waterford 3) Technical Specification (TS) 6.9.1.11.1, Core Operating Limits that would, in part, add new analytical methods to support the implementation of Next Generation Fuel. On January 17, 2008, Entergy proposed a non-technical change (Reference 2) that would provide greater operator clarity to an ACTION statement.

Since Reference 1 was submitted for NRC staff review, Entergy has held several conference calls to discuss the RAI questions with the NRC Staff members. A total of two (2) RAI questions were proposed by NRC staff members via NRC letter dated February 12, 2008 (Reference 3). Entergy's response to the RAI is included in Attachment 1.

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

W3F1-2008-0021 Page 2 of 3 This letter contains one new commitment. This commitment is identified in Attachment 2. If you have any questions or require additional information, please contact Ron Williams at (504) 739-6255.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 10, 2008.

Sincerely, KSC/RLW Attachments: 1. Supplement 2 RAI Response to Amendment Request NPF-38-271 to Support Next Generation Fuel

2. Licensee-Identified Commitments

W3F1-2008-0021 Page 3 of 3 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U.S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn ATTN: N.S. Reynolds 1700 K Street, NW Washington, DC 20006-3817 Morgan, Lewis & Bockius LLP ATTN: T.C. Poindexter 1111 Pennsylvania Avenue, NW Washington, DC 20004

Attachment 1 W3F17-2008-0021 Supplement 2 RAI Response to Amendment Request NPF-38-271 to Support Next Generation Fuel to W3F1-2008-0021 Page 1 of 2 Supplement 2 RAI Response to Amendment Request NPF-38-271 to Support Next Generation Fuel Reference 1 - Entergy letter to the NRC, "LicenseAmendment Request NPF-38-271 to Support Next Generation Fuel"dated August 2, 2007 (W3F1-2007-0037) 2 - Entergy letter to the NRC "EmergencyCore Cooling System Performance Analysis," dated August 9, 2007 (W3FI-2007-0038)

RAI 1 - For the proposed change to add items 15, 16, 17, 18, and 19 (five references) to core operatinglimit report [COLR] Technical Specifications (TS) 6.9.1.11.1, please explain the connection or relationshipbetween or among the referenced approved methodologies used. There are, for example, three moderatortemperature coefficient methods, four axial shape index methods, three linearheat rate methods, etc. The justification is needed because the application of these methodologies is planned for the coming reloadcycle and many approved methodologies are proposed to support the same cycle-specific parameter.

Entergy Response:

In the upcoming cycle 16, Entergy intends to implement the Next Generation Fuel (NGF) design. The proposed changes to TS 6.9.1.11.1 are needed to support the implementation of NGF.

In response to a portion of RAI 1 regarding an explanation of the connection or relationship between the referenced approved methodologies, the relationship was addressed satisfactorily during conference calls between the NRC staff reviewer, Waterford 3 Project Manager (PM),

Westinghouse and Entergy personnel.

Based upon the understanding of the relationship between the large number (14) of core operating limit report (COLR) references that presently exist in TS 6.9.1.11.1 and the additional five (5) references being proposed, the NRC Staff requested Entergy to commit to evaluate the COLR references and propose a TS change within the next 12 months to minimize the number of references. As an example, there are six COLR references that have a relationship with the COLR parameter limit of Shutdown Margin (TS 3.1.1.1 .and TS 3.1.1.2), in that, four of the references describe current methodology being used. However, two other references associated with Shutdown Margin have been superseded by more recently implemented methodology and thus, can be evaluated for deletion.

Therefore, to satisfy this condition, Entergy commits to evaluate other similar plant's Technical Specification (TS) methodology references that reflect NRC approved methods used in establishing the COLR parameter limits. Based on that evaluation, Entergy will propose a change to TS 6.9.1.11.1, to minimize the number of references consistent with the guidance provided in Generic Letter 88-16, "Removal of Cycle-Specific ParameterLimits from Technical Specifications." This proposed TS change will be submitted within 12 months following NRC to W3F1 -2008-0021 Page 2 of 2 issuance of the approved amendment for the current requested change to TS 6.9.1.11.1. This regulatory commitment is contained in Attachment 2.

RAI 2 - Please provide the technicalbasis to justify that 72.8 percent is the conservative maximum allowable safety-injection tank level.

Entergy Response:

The technical basis to justify that 72.8 percent is the conservative maximum allowable Safety Injection Tank level is provided in the Emergency Core Cooling System Performance Analysis (Reference 2) transmitted to the NRC on August 9, 2007. In section 5.1 (third paragraph) of Reference 2, the assumed maximum SIT water volume of 1586 ft3 is equivalent to 72.8%.

Table 5.1, Large Break LOCA ECCS Performance Analysis Core and Plant Design Data, also reflects the maximum safety injection tank water volume of 1586 ft 3.

Attachment 2 W3FI-2008-0021 Licensee-Identified Commitments to W3F1-2008-0021 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)

Entergy commits to evaluate other similar plant Technical Specification (TS) methodology Within 12 references that reflect NRC approved methods used months in establishing the COLR parameter limits. Based following NRC on that evaluation, Entergy will propose a change to issuance of the TS 6.9.1.11.1, to minimize the number of references approved consistent with the guidance provided in Generic X amendment for Letter 88-16, "Removal of Cycle-Specific Parameter the current Limits from Technical Specifications." This requested change to TS proposed TS change will be submitted within 6.9.1.11.1.

12 months following NRC issuance of the approved amendment for the current requested change to TS 6.9.1.11.1.