W3F1-2022-0026, Report of Facility Changes, Tests, and Experiments and Commitment Changes for Two Year Period Ending April 28, 2022

Report of Facility Changes, Tests, and Experiments and Commitment Changes for Two Year Period Ending April 28, 2022

ML22118B123
Person / Time
Site:	Waterford
Issue date:	04/28/2022
From:	Lewis J Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2022-0026
Download: ML22118B123 (9)

Text

) entergy John Lewis Manager Regulatory Assurance 504-739-6028 W3F1-2022-0026 10 CFR 50.59(d)(2) 10 CFR 72.48(d)(2)

April 28, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Report of Facility Changes, Tests, and Experiments and Commitment Changes for Two Year Period Ending April 28, 2022 Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 The summary report of facility changes, tests, and experiments for Waterford Steam Electric Station, Unit 3 (Waterford 3) is provided in Attachment 1 to this letter. This report is submitted in accordance with 10 CFR 50.59(d)(2) and 10 CFR 72.48(d)(2), and covers the period from April 28, 2020 through April 28, 2022. However, no 10 CFR 72.48 evaluations were completed during this reporting period, so no 10 CFR 72.48 report summaries are included in this submittal.

Attachment 2 to this letter provides the summary report of Commitment Changes for the same time period consistent with the guidance in SECY-00-0045 and Nuclear Energy Institute (NEI) 99-04.

There are no new commitments contained in this submittal.

Should you have any questions concerning this issue, please contact John D. Lewis, Manager, Regulatory Assurance, at 504-739-6028.

John . ewIs JDUcdm Attachments: 1. Waterford 3 Summary of 10 CFR 50.59 and 10 CFR 72.48 Evaluations

2. Waterford 3 Summary of Commitment Changes Entergy Operations, Inc., 1340 Echelon Parkway, Jackson, MS 39213

W3F1 -2022-0026 Page 2 of 2 cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector- Waterford Steam Electric Station, Unit 3 NRC Project Manager - Waterford Steam Electric Station, Unit 3

Attachment 1 W3F1-2022-0026 Waterford 3 Summary of 10 CFR 50.59 and 10 CFR 72.48 Evaluations W3F1 -2022-0026 Page 1 of 2 WATERFORD 3

SUMMARY

OF 10 CFR 50.59 AND 10 CFR 72.48 EVALUATIONS 10 CFR 50.59 Initiating Summary Evaluation Document Number 20-01 EC-0000086657-000 Increase frequencies associated with stroke tests of the main turbine governor valves, throttle valves, reheat stop valves, and interceptor valves from 6 months to 12 months, and then to 18 months. The 10 CFR 50.59 Evaluation addressed the potential of extending the turbine valve test interval to decrease turbine valve reliability and increase the turbine missile generation probability.

21-01 EC-0000077544-001 Replace two existing TeloSense Broad

[FCR 90726] Range Gas Monitors BRGMs) with two ACM 150 Air Composition Monitors and two RAEGuard 2 Photoionization Detectors (PIDs) supplied by Honeywell Analytics, Inc.

The 10 CFR 50.59 Evaluation for Field Change Request (FCR) 90726 demonstrates that the new BRGMs can perform the important to safety function of providing an isolation signal to the Main Control Room Ventilation System in the event of a toxic gas release accident.

21-02 EC-0000088102-000 Updates the bounding Component Cooling Water (CCW) pump runout case in calculation MNQ9-2 to consider a more bounding condition, which is a single failure of a running CCW pump during normal shutdown with a loss of offsite power (LOOP). The 10 CFR 50.59 Evaluation shows that the reduction in the required completion time for time critical action (TCA)-

35 from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 50 minutes remains within operator capability and does not adversely affect the ability of the CCW system to perform its required safety functions.

W3F1 -2022-0026 Page 2 of 2 10 CFR 50.59 Initiating Summary Evaluation Document Number 21-03 EC-0000090132-000 Resolves an inconsistency in the seismic boundary location for the Emergency Breathing Air (EBA) piping upstream of the Emergency Breathing Air Tanks. The 10 CFR 50.59 Evaluation shows that the relocation of the EBA seismic boundary at the tank isolation valves (EBA-06A(B)(C)(D))

rather than the upstream check valve (EBA-203) can be implemented without adversely affecting the ability of the EBA system to perform its required safety functions.

22-01 EC-0000091881-000 Temporary modification to replace the Core

[FCR 91960] Protection Calculator Channel D resistance temperature detector (RTD) RC ITE0112CD1 with that from RC ITE0115-1 for the remainder of Cycle 24. This RTD provides indication of Reactor Coolant System cold leg loop 1B temperature to the Plant Monitoring Computer. The 10 CFR 50.59 Evaluation was limited to the FCR 91960 change to the maximum RTD response time for the reactor protective instrumentation from 8 seconds to 13 seconds.

22-02 EC-0000092099-000 Modified the test interval for the main turbine governor valves, throttle valves, reheat stop valves, and interceptor valves from 6 months to 12 months. The 10 CFR 50.59 Evaluation addressed the potential for a reduction in turbine valve reliability and increased turbine missile generation probability that would result from the lengthened turbine valve test interval.

10 CFR 72.48 Initiating Summary Evaluation Document Number None N/A N/A

Attachment 2 W3F1-2022-0026 Waterford 3 Summary of Commitment Changes

Attachment 2 W3F1 -2022-0026 Page 1 of 3 WATERFORD 3

SUMMARY

OF COMMITMENT CHANGES I

! Commitment Change Commitment Commitment Change Description Reason for Change/Deletion Evaluation Form (CCEF) Number Number CCEF-2020-0005 A-27551 The NRC staff recommended three closure Waterford 3 is revising commitments as A-27552 options to the commission for resolving Generic documented here rather than approval of A-27553 Safety Issue (GSI) 191 and the staff's WCAP17788-P. These commitment changes recommendation to allow licensees to choose do not affect closure option that Waterford 3 any of the three options. Waterford 3 submitted selected and will support successful closure of a letter identifying the closure option and GL 2004-2.

schedule and made several commitments to achieve this closure and to address Generic Letter (GL) 2004-2. The Pressurizer Water Reactor Owners Group (PWROG) program schedules changed such that Waterford 3 was no longer able to meet that date. Additional revisions were made to commitments due to PWROG schedule changes. Waterford 3 intends to follow resolution strategy proposed by PWROG for establishing in-vessel fiber limits.

On 2/28/2020 PWROG approved implementation guidance to support WCAP-i 17788-P by PWROG members.

W3F1 -2022-0026 Page 2 of 3 Commitment Change Commitment Commitment Change Description Reason for Change/Deletion Evaluation Form (CCEF) Number Number CCEF-2020-0006 P-11412 The commitment description is revised to add, The justifications for change are: (1) the "December 2020 Update - Based on a review of corrective action was not specifically identified this commitment, Licensee Event Report (LER) as a Regulatory Commitment; (2) the corrective 85-053 and NUREG 1117 (March 1985 version action was overly conservative by testing a of Waterford 3 TS), it was determined this Plant Protection System (PPS) trip signal in commitment was based on an overly Modes not required by TSs; and (3) since 1985 conservative corrective action to perform a the Mode change checklists and processes portion of the Core Protection Calculator (CPC) have been developed to a point that a missed Channel Functional Test (the trip function) in all surveillance upon changing modes is rare, and Modes, when the 1985 Technical Specifications if it did occur, the corrective actions would be (TSs) required it only at Refueling Intervals. focused on the Mode change process, not Note 6 of Table 4.3-1 of TSs stipulates the default to unnecessarily performing a PPS trip testing of the trip function and is currently test during at-power operations.

controlled by the NRG approved Surveillance Frequency Control Program (SFCP). Based on the above, this commitment is changed to CANCELLED.

CCEF-2021-0017 A-27552 It is acceptable to extend the due date because No revision to description. Revision is being we are still within the required timeframe to made to commitment due date. Existing due complete all actions related to the GL 2004-02 date is December 31, 2021. Revised due date is resolution. All actions must be completed by the December 31, 2022.

third refueling outage following issuance of the PWROG guidance, which was Feb 28, 2020.

The third refueling outage will be RF25 which is scheduled to begin Sep 30, 2023. The A-27552 commitment requires engineering to apply the guidance from the PWROG in order to develop the NRC submittal. The extension date for this action is necessary to allow for this engineering to be completed.

W3F1-2022-0026 Page 3 of 3 Commitment Change Commitment Commitment Change Description Reason for Change/Deletion Evaluation Form (CCEF) Number Number CCEF-2022-0001 A-27731 Enhance the Steam Generator Integrity Program This commitment change is to align the as follows: a. Revise the Steam Generator frequency of Steam Generator Inspection in the Integrity Program to include general visual Steam Generator Integrity Aging Management inspection of the partition plate, channel head, Program (AMP) with the revised Technical and tube sheet (primary side) with a frequency Specifications.

of at least once every 96 effective full power months.

CCEF-2022-0005 A-27805 These commitments involve follow-up activities The original License Amendment Request A-27806 associated with the categorization of systems in (LAR) for adoption of 10 CFR 50.69 requested accordance with 10 CFR 50.69. These follow-up NRC approval by January 30, 2021. However, activities are not needed for implementation of approval of the LAR has been delayed. The the 10 CFR 50.69 license amendment for revised commitment completion dates account Waterford 3. Specifically, the results of the for the delay.

FLEX equipment sensitivity study will be shared with the 10 CFR 50.69 Integrated Decision-Making Panel (IDP) and an additional checklist item will be included in the activities to be added to the Configuration Control Program to recognize those systems that have been categorized in accordance with 10 CFR 50.69.