ML083430715

Request for Additional Information, License Amendment Request to Modify Technical Specification (TS) Section 3/4.6.3, Containment Isolation Valves

ML083430715
Person / Time
Site:	Waterford
Issue date:	12/19/2008
From:	Kalyanam N Plant Licensing Branch IV
To:	Entergy Operations
Kalyanam N, NRR/DLPM, 415-1480
References
TAC MD7693
Download: ML083430715 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 19, 2008 Vice President, Operations 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 RE: LICENSE AMENDMENT REQUEST TO MODIFY TECHNICAL SPECIFICATION SECTION 3/4.6.3, "CONTAINMENT ISOLATION VALVES" (TAC NO. MD7693)

Dear Sir/Madam:

By letter dated January 2, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML0080040073), Entergy Operations, Inc. (Entergy, the licensee),

submitted an application for a license amendment request (LAR) to the U.S. Nuclear Regufatory Commission (NRC) requesting a license amendment to Technical Specification (TS) 3/4.6.3.

The proposed amendment revises the action requirements for inoperable containment isolation valves in TS 3/4.6.3, "Containment Isolation Valves," to increase the allowed outage time from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for containment isolation valves associated with closed systems.

The NRC staff has reviewed the application and has determined that additional information is needed to complete the review. The requested information is provided in the enclosure to this letter.

NRC discussed the need for additional information with Mr. G. Scott of your staff on December 10,2008. Mr. Scott agreed to provide a response within 30 days of the receipt of this letter. In the call held on December 17, 2008, it was stated that the draft responses to the questions would be discussed in the week of January 5, 2009.

If you have any questions, please contact me at (301) 415-1480 or by electronic mail at kaly.kalyanam@nrc.gov.

Sincerely, c1~~Y"

~ia~~ICi~~nSing 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

OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION WATERFORD STEAM ELECTRIC STATION, UNIT 3 (WATERFORD 3)

LICENSE AMENDMENT REQUEST REGARDING EXTENDED CONTAINMENT ISOLATION VALVES ALLOWED OUTAGE TIMES FOR CLOSED SYSTEMS By letter dated January 2, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML0080040073), Entergy Operations, Inc. (Entergy, the licensee),

submitted an application for a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) requesting a license amendment to Technical Specification (TS) 3/4.6.3.

The proposed amendment revises the action requirements for inoperable containment isolation valves (CIV) in TS 3/4.6.3, "Containment Isolation Valves," to increase the allowed outage time from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for containment isolation valves associated with closed systems.

1. To clarify what is stated in the application about closed systems and Generic Design Criteria (GDC) 57, describe what distinction, if any, is being made in the LAR about (1) closed systems inside containment, (2) closed systems outside containment, and (3) systems that are closed both inside and outside containment. It appears that the reference to closed systems in the first part of the proposed revision to the actions for inoperable CIVs in TS 3.6.3 should state "Restore the inoperable valve for penetration(s) with closed system(s) inside, outside, or inside and outside the containment."

2. In the Waterford 3 Final Safety Analysis Report (FSAR, Revision 15, dated March 2007)

Table 6.2-32, the containment penetrations are listed with the systems for each valve in the penetration. In the LAR, the closed system identified for penetrations 1 and 2 is main steam; however, in the FSAR table, the systems listed for these penetrations are main steam, emergency steam generator feed pump turbines, atmospheric steam dump, main steam sample, main steam drains, main steam isolation valve bypass, and main steam nitrogen blanket. For the other penetrations listed in the LAR, there is no difference between the systems listed in LAR and the systems listed in Table 6.2-32.

Please discuss why there is this difference for penetrations 1 and 2, and the effect if any on the LAR.

3. An additional clarification of the LAR is how many days following the date of issuance of the amendment would be needed to implement the amendment.

-2

4. The LAR does not include a verification item for the proposed Action for an inoperable CIV on a closed system. The additional Action is, after the affected penetration flowpath has been isolated, to "Verify the affected penetration flow path is isolated, once per 31 days." This periodic verification is necessary to assure continued leak tightness of containment and that penetrations requiring isolation following an accident are isolated.

The allowed outage time (AOT) of once per 31 days for verifying each affected penetration flow path is isolated is appropriate considering the valves are operated under administrative control and the probability of their misalignment is low. This action has a note associated with it that states "Isolation devices in high radiation area may be verified by use of administrative means." This additional action could be added following the proposed c with an "and." This verification is in TSTF-30; however, this verification was not being added or changed by extending the allowed outage time to isolate the penetration from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

5. The additional Action item, to verify the penetration is isolated once per 31 days, which is discussed in question 4, should have been included in the current Action for when the affected penetration flow path is isolated. This addition is not required for this LAR; however, it will be identified in the evaluation of the amendment as being needed to be proposed in the future.

6. The following are two recommended additions to Insert 2 of Attachment 3 to the LAR, which identifies changes to be made to the TS Bases for the proposed amendment.

These two are strictly recommendations to explain the basis for the amendment and are not required for the !\IRC to approve the amendment.

a. To the 3rd paragraph, add the following sentences: "These systems are Class 3 systems (Le., closed systems inside containment) in accordance with FSAR Section 6.2.4.1.2 and General Design Criteria 57. These closed systems inside containment meet the criteria in Standard Review Plan 6.2.4."

b. Add a statement about the actions for an inoperable CIV on a closed system inside containment that, after the affected penetration is isolated, there will be a verification that the penetration flow path is isolated once per 31 days.

December 19, 2008 Vice President, Operations 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 RE: LICENSE AMENDMENT REQUEST TO MODIFY TECHNICAL SPECIFICATION SECTION 3/4.6.3, "CONTAINMENT ISOLATION VALVES" (TAC NO. MD7693)

Dear Sir/Madam:

By letter dated January 2, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML0080040073), Entergy Operations, Inc. (Entergy, the licensee),

submitted an application for a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) requesting a license amendment to Technical Specification (TS) 3/4.6.3.

The proposed amendment revises the action requirements for inoperable containment isolation valves in TS 3/4.6.3, "Containment Isolation Valves," to increase the allowed outage time from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for containment isolation valves associated with closed systems.

The NRC staff has reviewed the application and has determined that additional information is needed to complete the review. The requested information is provided in the enclosure to this letter.

NRC discussed the need for additional information with Mr. G. Scott of your staff on December 10, 2008. Mr. Scott agreed to provide a response within 30 days of the receipt of this letter. In the call held on December 17, 2008, it was stated that the draft responses to the questions would be discussed in the week of January 5, 2009.

If you have any questions, please contact me at (301) 415-1480 or by electronic mail at kaly.kalyanam@nrc.gov.

Sincerely, IRA by Jack Donohew fori N. Kalyanam, 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:

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