W3F1-2021-0061, Supplement to License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual

Supplement to License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual

ML21287A122
Person / Time
Site:	Waterford
Issue date:	10/14/2021
From:	Gaston R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2021-0061
Download: ML21287A122 (9)

Text

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.90 W3F1-2021-0061 October 14, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Supplement to License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38

References:

1) Entergy Operations, Inc. (Entergy) letter to U.S. Nuclear Regulatory Commission (NRC), W3F1-2021-0004, "License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to the Technical Requirements Manual," (ADAMS Accession Number ML21095A156), dated April 5, 2021

2) Entergy letter to NRC, "Response to Request for Additional Information Regarding License Amendment Request to Relocate the Chemical Detection Systems Technical Specifications to Technical Requirements Manual," (ADAMS Accession No. ML21273A328), dated September 30, 2021 By letter dated April 5, 2021 (Reference 1), Entergy Operations Inc. (Entergy) requested an amendment to Appendix A, "Technical Specifications," of Renewed Facility Operating License No. NPF-38 for Waterford Steam Electric Station, Unit 3 (Waterford 3) to relocate the Chemical Detection Systems Technical Specifications (TSs) to the Technical Requirements Manual (TRM). Specifically, the TSs to be relocated are TS 3.3.3.7.1, "Chlorine Detection System,"

TS 3.3.3.7.3, "Broad Range Gas Detection," and TS Surveillance Requirement (SR) 4.7.6.1.d.4.

Following submittal of the Reference 1 TS relocation request letter, an error was identified affecting the TS SR 4.7.6.1.d.4 markup page and clean page provided in Attachments 1 and 2, respectively, to the letter Enclosure. The error consisted of incorrectly showing the deletion of TS SR 4.7.6.1.d.4 on the Amendment No. 249 version of TS page 3/4 7-17 instead of the current Amendment No. 257 version of the page. This supplement to the original Reference 1 license amendment request corrects this error by providing the revised TS SR 4.7.6.1.d.4 markup page and clean page on the current Amendment No. 257 of TS page 3/4.7-7. The

W3F1-2021-0061 Page 2 of 3 revised markup page and clean page are provided in the respective Enclosures 1 and 2 to this letter.

In addition, while preparing the Reference 2 request for additional information (RAI) response, it was noted that License Condition 2.C.4 of the Waterford 3 Renewed Facility Operating License currently requires the Broad Range Toxic Gas Detection System to be added to the Waterford 3 TSs (i.e., Appendix A to the License). The relocation of TS 3.3.3.7.3, "Broad Range Gas Detection," to the TRM as requested in the Reference 1 license amendment request contradicts the action to be taken as specified in the License Condition since the corresponding TS will no longer reside in Appendix A to the Waterford 3 Operating License. Thus, following NRC approval of the relocation of TS 3.3.3.7.3 to the TRM, License Condition 2.C.4 will no longer be applicable to Waterford 3. Accordingly, this supplement to the Reference 1 license amendment request deletes License Condition 2.C.4 as a conforming change to reflect its removal from Appendix A to the Waterford 3 Operating License. Note that the change includes moving two footnote references from the deleted License Condition 2.C.4 to the retained License Condition 2.C.5 since the two footnotes remain applicable. The revised Operating License markup and clean pages are provided in Enclosures 1 and 2 to this letter. The need to delete License Condition 2.C.4 was previously discussed in the Reference 2 RAI response letter.

The proposed changes to the Waterford 3 TSs and Operating License described above do not affect the no significant hazards consideration provided in the original Reference 1 TS relocation license amendment request submittal.

This letter contains no new regulatory commitments.

In accordance with 10 CFR 50.91, Entergy is notifying the State of Louisiana of this supplemental information by transmitting a copy of this letter and Enclosures to the designated State official.

Should you have any questions or require additional information, please contact Paul Wood, Waterford 3 Regulatory Assurance Manager, at 504-464-3786.

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

Executed on October 14, 2021.

Respectfully, Ron Gaston RWG/cdm

Enclosures:

1. Revised Renewed Facility Operating License and Technical Specification Markup Pages

2. Revised Renewed Facility Operating License and Technical Specification Clean Pages

W3F1-2021-0061 Page 3 of 3 cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Waterford 3 NRC Project Manager Waterford 3 Louisiana Department of Environmental Quality, Office of Environmental Compliance

Enclosure 1 W3F1-2021-0061 Revised Renewed Facility Operating License and Technical Specification Markup Pages (2 pages following)

- DELETED

4. Broad Range Toxic Gas Detectors (Section 2.2.1, SSER 61)

Prior to startup following the first refueling outage, the licensees2 shall propose technical specifications for the Broad Range Toxic Gas Detection System for inclusion in Appendix A to this license.

1

5. Initial Inservice Inspection Program (Section 6.6, SSER 5) 2 By June 1, 1985, the licensees must submit an initial inservice inspection program for staff review and approval.

6. Environmental Qualification (Section 3.11, SSER 8)

Prior to November 30, 1985, the licensees shall environmentally qualify all electrical equipment according to the provisions of 10 CFR 50.49.

7. Axial Fuel Growth (Section 4.2, SSER 5)

Prior to entering Startup (Mode 2) after each refueling, EOI shall either provide a report that demonstrates that the existing fuel element assemblies (FEA) have sufficient available shoulder gap clearance for at least the next cycle of operation, or identify to the NRC and implement a modified FEA design that has adequate shoulder gap clearance for at least the next cycle of operation. This requirement will apply until the NRC concurs that the shoulder gap clearance provided is adequate for the design life of the fuel.

8. Emergency Preparedness (Section 13.3, SSER 8)

In the event that the NRC finds that the lack of progress in completion of the procedures in the Federal Emergency Management Agency's final rule, 44 CFR Part 350, is an indication that a major substantive problem exists in achieving or maintaining an adequate state of emergency preparedness, the provisions of 10 CFR Section 50.54(s)(2) will apply.

9. Fire Protection EOI shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c),

as specified in the license amendment request dated November 17, 2011 (and supplements dated January 26, 2012, September 27, 2012, October 16, 2012, May 16, 2013, June 26, 2013, December 18, 2013, June 11, 2014, March 12, 2015, April 10, 2015, May 14, 2015, August 27, 2015, September 8, 2015, September 24, 2015, October 13, 2015, and January 18, 2016), and as approved in the safety evaluation dated June 27, 2016. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, 1 The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

2 The license originally authorized Entergy Louisiana, LLC to possess, use, and operate the facility.

Consequently, certain historical references applicable to Entergy Louisiana, LLC as one of the "licensees" appear in these license conditions.

AMENDMENT NO.

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

2. Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 0.5% when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and a relative humidity of 70%.

3. Verifying a system flow rate of 4225 cfm +/- 10% during train operation when tested in accordance with ANSI N510-1975.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 0.5%

when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and a relative humidity of 70%.

d. In accordance with the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 7.8 inches water gauge while operating the train at a flow rate of 4225 cfm +/- 10%.

2. Verifying that on a safety injection actuation test signal or a high radiation test signal, the train automatically switches into a recirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks and the normal outside airflow paths isolate, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position in Modes 5, 6, or defueled.

DELETE 3. Verifying that heaters dissipate 10 +1.0, -1.0 kW when tested in accordance with ANSI N510-1975.

4. Verifying that on a toxic gas detection signal, the system automatically switches to the isolation mode of operation, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position in Modes 5, 6, or defueled.

e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the train at a flow rate of 4225 cfm +/- 10%.

f. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the train at a flow rate of 4225 cfm +/- 10%.

g. Perform required control room envelope unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

WATERFORD - UNIT 3 3/4 7-17 AMENDMENT 115, 170, 194, 218, 249 257

Enclosure 2 W3F1-2021-0061 Revised Renewed Facility Operating License and Technical Specification Clean Pages (2 pages following)

4. DELETED

5. Initial Inservice Inspection Program (Section 6.6, SSER 51)

By June 1, 1985, the licensees2 must submit an initial inservice inspection program for staff review and approval.

6. Environmental Qualification (Section 3.11, SSER 8)

Prior to November 30, 1985, the licensees shall environmentally qualify all electrical equipment according to the provisions of 10 CFR 50.49.

7. Axial Fuel Growth (Section 4.2, SSER 5)

Prior to entering Startup (Mode 2) after each refueling, EOI shall either provide a report that demonstrates that the existing fuel element assemblies (FEA) have sufficient available shoulder gap clearance for at least the next cycle of operation, or identify to the NRC and implement a modified FEA design that has adequate shoulder gap clearance for at least the next cycle of operation. This requirement will apply until the NRC concurs that the shoulder gap clearance provided is adequate for the design life of the fuel.

8. Emergency Preparedness (Section 13.3, SSER 8)

In the event that the NRC finds that the lack of progress in completion of the procedures in the Federal Emergency Management Agency's final rule, 44 CFR Part 350, is an indication that a major substantive problem exists in achieving or maintaining an adequate state of emergency preparedness, the provisions of 10 CFR Section 50.54(s)(2) will apply.

9. Fire Protection EOI shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c),

as specified in the license amendment request dated November 17, 2011 (and supplements dated January 26, 2012, September 27, 2012, October 16, 2012, May 16, 2013, June 26, 2013, December 18, 2013, June 11, 2014, March 12, 2015, April 10, 2015, May 14, 2015, August 27, 2015, September 8, 2015, September 24, 2015, October 13, 2015, and January 18, 2016), and as approved in the safety evaluation dated June 27, 2016. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, 1 The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

2 The license originally authorized Entergy Louisiana, LLC to possess, use, and operate the facility.

Consequently, certain historical references applicable to Entergy Louisiana, LLC as one of the "licensees" appear in these license conditions.

AMENDMENT NO.

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

2. Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 0.5% when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and a relative humidity of 70%.

3. Verifying a system flow rate of 4225 cfm +/- 10% during train operation when tested in accordance with ANSI N510-1975.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 0.5%

when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and a relative humidity of 70%.

d. In accordance with the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 7.8 inches water gauge while operating the train at a flow rate of 4225 cfm +/- 10%.

2. Verifying that on a safety injection actuation test signal or a high radiation test signal, the train automatically switches into a recirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks and the normal outside airflow paths isolate, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position in Modes 5, 6, or defueled.

3. Verifying that heaters dissipate 10 +1.0, -1.0 kW when tested in accordance with ANSI N510-1975.

e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the train at a flow rate of 4225 cfm +/- 10%.

f. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the train at a flow rate of 4225 cfm +/- 10%.

g. Perform required control room envelope unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

WATERFORD - UNIT 3 3/4 7-17 AMENDMENT 115, 170, 194, 218, 249 257,