ML16354A105

RAI License Amendment Request to Revise TS 3/4.3.2 to Relocate Surveillance Frequency Requirements for Engineered Safety Feature Actuation System (ESFAS) Subgroup Relays to the Surveillance Frequency Control Program

ML16354A105
Person / Time
Site:	Waterford
Issue date:	12/27/2016
From:	April Pulvirenti Plant Licensing Branch IV
To:	Entergy Operations
Pulvirenti A
References
CAC MF8325
Download: ML16354A105 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 27, 2016 Site Vice President Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3- REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 3/4.3.2 TO RELOCATE SURVEILLANCE FREQUENCY REQUIREMENTS FOR ENGINEERED SAFETY FEATURE ACTUATION SYSTEM SUBGROUP RELAYS TO THE SURVEILLANCE FREQUENCY CONTROL PROGRAM (CAC NO. MF8325)

Dear Sir or Madam:

By letter dated September 1, 2016 (Agencywide Documents Access and Management System Accession No. ML16245A359), Entergy Operations, Inc. (the licensee), submitted a license amendment request for Waterford Steam Electric Station, Unit 3. The proposed amendment would revise the table notation for Table 4.3-2, "Engineered Safety Features Actuation System Instrumentation Surveillance Requirements," to provide consistency with the existing licensee-controlled Surveillance Frequency Control Program, which is implemented in accordance with Nuclear Energy Institute (NEI) 04-10, "Risk Informed Technical Specifications Initiative 5B, Risk-Informed Method for Control of Surveillance Frequencies."

After reviewing your request, the U.S. Nuclear Regulatory Commission staff has determined that additional information is required in order to complete the review. The additional information needed to complete the review is delineated in the enclosure to this letter, and was discussed with Maria lamber and William Steelman of your staff on December 21, 2016. A response is requested within 30 days of the date of this letter.

If you have any questions, please contact me at 301-415-1390 or via e-mail at April.Pulvirenti@nrc.gov.

Sincerely, April L. Pulvirenti, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST REGARDING THE REVISION OF TECHNICAL SPECIFICATION TABLE 4.3-2 ENTERGY OPERATIONS, INC.

WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382 By letter dated September 1, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16245A359), Entergy Operations, Inc. (the licensee), submitted a license amendment request (LAR) for Waterford Steam Electric Station, Unit 3. The proposed amendment would revise the table notation for Table 4.3-2, "Engineered Safety Features Actuation System [ESFAS] Instrumentation Surveillance Requirements," to provide consistency with the existing licensee-controlled Surveillance Frequency Control Program (SFCP), which is implemented in accordance with Nuclear Energy Institute (NEI) 04-10, "Risk Informed Technical Specification Initiative 5B, Risk-Informed Method for Control of Surveillance Frequencies.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in the LAR and determined that additional information, delineated below, is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment.

1. The NRC staff understands that the current circuit design does not permit inservice testability, and that the current design was granted an exception to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, General Design Criterion (GDC) 21, "Protection system reliability and testability," and Institute of Electrical and Electronics Engineers (IEEE) 279-1971, "Criteria for Protection Systems for Nuclear Power Generating Stations," by invoking Section D.4 of Regulatory Guide (RG) 1.22, "Periodic Testing of Protection System Actuation Functions" (ADAMS Accession No. ML083300530), as supported by References 7, 8, and 9 in the application dated September 1, 2016. The current exception does not apply to the proposed design, which contains two contacts in each circuit, such that actuation of any one of the relays will not result in an ESFAS component actuation. If a spurious actuation of one relay during testing does not result in an ESFAS actuation, then the proposed design would permit inservice testability, and testing of the relays need not be limited to periods of cold shutdown. Demonstrate that the existing relay, within the proposed new configuration, will meet the surveillance requirements of GDC 21 and IEEE 279-1971, or fully justify why the surveillance of this existing relay should be granted an exception to GDC 21 and IEEE 279-1971 via the criteria outlined in RG 1.22, Section D.4.

Enclosure

2. The LAR, in part, supports the hardening of the ESFAS single-point vulnerability (SPV) by adding an additional contact in the Feedwater and Main Steam Isolation Actuation by Main Steam Isolation Signal and Component Cooling Water Containment Isolation Valve Closure Actuation by Containment Spray Actuation Signal. Provide circuit diagrams of both the current configuration and proposed modification, which demonstrate that the configuration will meet the requirements of IEEE 279-1971 as it applies to the likelihood of spurious actuation during testing. Specifically:

a. Demonstrate that the power supply to these relays (with the new contact wiring) is independent of the power to the existing relays that are wired in the circuits to ensure trip hardening due to SPV.

b. If the direct current (DC) power source is interconnected at one or more points, then explain how the power supply independence is maintained (e.g., is the power floating or grounded).

c. Have any new features (e.g., a toggle switch) been added to the circuit design to facilitate testing?

3. In the LAR, the licensee states that the relocation of the surveillance requirements from technical specifications to a licensee-controlled program allowed under Amendment No. 249 dated July 26, 2016 (ADAMS Accession No. ML16159A419), will be reviewed by NRC staff as a result of the modification; however, the modification itself can be completed pursuant to 10 CFR 50.59, "Changes, tests and experiments," without NRC review. In addition, the LAR states, in part that "[p]art of this revision is needed to support the ESFAS Single Point Vulnerability (SPV) Trip Hardening Modification."

Clarify the relationship between the licensee-evaluated modification and the LAR. In addition, clarify the relationship between Amendment No. 249 and the current LAR.

4. The license amendment would edit the second sentence of Note 3 of the Table Notation of the current TS Table 4.3-2. The second sentence of the Note currently states "[r]elays K109, K114, K202, K301, K305, K308 and K313 are exempt from testing during power operation but shall be tested in accordance with the Surveillance Frequency Control Program and during each COLD SHUTDOWN condition unless tested within the previous 62 days." The LAR proposes to remove this sentence and relocate all of the surveillance requirements, including testing during COLD SHUTDOWN, to the SFCP, based on the adoption of TSTF-425 as approved in Amendment No. 249. However, TSTF-425, as implemented in Amendment No. 249, requires that a surveillance requirement may not be relocated to the SFCP if it falls into one of the four exclusion categories. The text "unless tested within the previous 62 days" seems to meet the exclusion criteria for frequencies, which are event-driven but have a time component for performing the surveillance on a one-time basis once the event occurs. Explain why this text does not meet these exclusion criteria for TSTF-425, and why this text may be relocated to the SFCP.

5. Section 1.0 of the LAR states, in part:

Additional subgroup relays that are being added to the ESFAS as part of the modification will be subject to the same testing frequency. The note

[Note 3 of the current TS Table 4.3-2] will be revised in order to remove information that is being included in the licensee-controlled SFCP.

Following completion of the ESFAS SPV Trip Hardening Modification, the additional relays will be added to the SFCP to the group that is not tested during power operation.

In order to establish this frequency and then relocate this frequency to the SFCP, please provide the following information:

a) Please confirm that the LAR proposes to include the surveillance testing of the new relays in Table 4.3-2 and the SFCP with an initial frequency of once per 18 months and during each COLD SHUTDOWN condition unless tested within the previous 62 days. Section 50.36(c)(2)(ii) of 10 CFR states, "A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria."

Section 50.36(c)(2)(ii)(C) of 10 CFR, Criterion 3 states "a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier."

Explain why the additional subgroup relays being added meet or do not meet 10 CFR 50.36(c)(2)(ii) and 10 CFR 50.36(c)(2)(ii)(C) Criterion 3 for which a TS must be established.

b) The surveillance frequency of the existing relays was granted as an exception to GDC 21 and IEEE 279-1971 through invoking Section D.4 of RG 1.22, as supported by References 7, 8, and 9 in the application. The proposed design contains two contacts in each circuit, such that actuation of any one of the relays will not result in an ESFAS component actuation. Therefore, justify that the surveillance frequency of the new relays, which would be the same as the existing relays, should be granted this same exception to GDC 21 and IEEE 279-1971.

If you have any questions, please contact me at 301-415-1390 or via e-mail at April. Pulvirenti@nrc.gov.

Sincerely, IRA/

April L. Pulvirenti, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDeEicb Resource LPL4 R/F RidsNrrPMWaterford Resource RidsACRS_MailCTR Resource RidsNrrLAPBlechman Resource RidsNrrDorllpl4 Resource GSingh, NRR RidsRgn4MailCenter Resource PSnyder, NRR RidsNrrDssStsb Resource ADAMS A ccess1on No. ML16354A105 *b1yema1*1 d ae t d OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DE/EICB/BC*

NAME APulvirenti PBlechman MWaters DATE 12/21/2016 12/21/2016 12 / 22 / 2016 OFFICE NRR/DSS/STSB/BC NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME AKlein (MChernoff for) RPascarelli (JKlos for) APulvirenti DATE 12 / 27 / 2016 12 / 27 / 2016 12/27/2016 OFFICIAL RECORD COPY