ML12310A458

Waterford Steam Electric Station, Unit 3 - 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 (TAC No. ME

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

Text

From:Kalyanam, KalyTo: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), EntergyOperations Inc. submitted a License Amendment Request (LAR) to Relocate thefollowing 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 staffrequests additional information as stated below, on or before November 16, 2012.

The application mentions a non-conservatism related to flooding but has not identifiedwhat it is. It has also not provided the language to be put into the TRM concerningflooding. 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, oroperating restriction that is an initial condition of a design basis accident ortransient analysis that either assumes the failure of, or presents achallenge to, the integrity of a fission product barrier. The "Final PolicyStatement on Technical Specifications Improvements for Nuclear PowerReactors" (58FR39132) defines the design basis accident or transients asthat contained in the UFSAR Chapter 6 and 15. The flood related eventsare contained in UFSAR Chapter 2 and 3. Thus flood protection is not aninitial condition for any design basis accident that would present achallenge to the integrity of any fission product barrier. Therefore, TS 3.7.5does 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 plant's flood protection. However, due to the licensee's 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 whichoperating experience or probabilistic risk assessment has shown to besignificant to public health and safety. The Waterford 3 Individual Plant Examination for External Events (IPEEE) response [Reference 7.12] foundno high winds, floods, or off site industrial facility accidents that significantlyalters the Waterford 3 estimate of either the core damage frequency, or the distribution of containment release categories. The NRC IPEEE safetyevaluation [Reference 7.13] reiterated this information as the licenseestated 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 furtherconsideration and judged to not be a significant contributor to the total CoreDamage Frequency (CDF). Based upon these risk insights, TS 3.7.5 doesnot 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 tomeet Criterion 4.