ML12310A458

Request for Additional Information Email, License Amendment Request to Relocate Technical Specification (TS) 3.4.6, TS 3.7.5, TS 3.7.9, and TS 3.9.5 to the Technical Requirements Manual

ML12310A458
Person / Time
Site:	Waterford
Issue date:	11/05/2012
From:	Kalyanam N Plant Licensing Branch IV
To:	Mason M Entergy Operations
Kalyanam N
References
TAC ME7614
Download: ML12310A458 (2)

Text

From: Kalyanam, Kaly To: MASON, MICHAEL E (WF3)

Subject:

Request for Additional Information - ME7614, LAR to relocate TSs to TRM.

Date: Monday, November 05, 2012 1:36:00 PM By letter dated October 21, 2011 (ADAMS Accession No. ML11326A283), Entergy Operations Inc. submitted a License Amendment Request (LAR) to Relocate the following Technical Specifications (TSs) to the Technical Requirements Manual TS 3.4.6 (Chemistry)

TS 3.7.5 (Flood Protection)

TS 3.7.9 (Sealed Source Contamination)

TS 3.9.5 (Communications)

On reviewing the Technical Analysis for the relocation of TS 3.7.5, the NRC staff requests additional information as stated below, on or before November 16, 2012.

The application mentions a non-conservatism related to flooding but has not identified what it is. It has also not provided the language to be put into the TRM concerning flooding. The staff has 2 comments as explained below:

The statements below are from the amendment application:

1. Criterion 2. Criterion 2 refers to a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. The "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58FR39132) defines the design basis accident or transients as that contained in the UFSAR Chapter 6 and 15. The flood related events are contained in UFSAR Chapter 2 and 3. Thus flood protection is not an initial condition for any design basis accident that would present a challenge to the integrity of any fission product barrier. Therefore, TS 3.7.5 does not meet Criterion 2 for inclusion in the TSs.

Comment - The flood events discussed in Chapter 2 and 3 are based on older analysis and apparently did not threaten the plants flood protection. However, due to the licensees discovery of a non-conservatism, this may no longer be true. The licensee should be more specific. If the flood protection is no longer adequate, then flooding could be an initiating event for a accident. Please explain the non-conservatism that currently exists and explain your position with regard to Criterion 2.

2. Criterion 4. Criterion 4 refers to a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. The Waterford 3 Individual Plant

Examination for External Events (IPEEE) response [Reference 7.12] found no high winds, floods, or off site industrial facility accidents that significantly alters the Waterford 3 estimate of either the core damage frequency, or the distribution of containment release categories. The NRC IPEEE safety evaluation [Reference 7.13] reiterated this information as the licensee stated that Waterford 3 complies with the 1975 Standard Review Plan (SRP) criteria. Based on this compliance, all of the high winds, floods, transportation, and other (HFO) external events were dropped from further consideration and judged to not be a significant contributor to the total Core Damage Frequency (CDF). Based upon these risk insights, TS 3.7.5 does not meet Criterion 4 for inclusion in the TSs.

Comment - Conclusions based on IPEEE studies may not be valid for this LAR. Please provide some alternate reasoning for not having to meet Criterion 4.