ML101620417

Response to Request for Additional Information Associated with Technical Specification Table 3.4-1 Isolation Valve Addition

ML101620417
Person / Time
Site:	Waterford
Issue date:	06/08/2010
From:	Kowalewski J Entergy Nuclear South, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2010-0050
Download: ML101620417 (20)

Text

i"OýEn.tergy Entergy Nuclear South Entergy Operations, Inc.17265 River Road Killona, LA 70057-3093 Tel 504 739 6660 Fax 504 739 6678 jkowale@entergy.com Joseph A. Kowalewski Vice President, Operations Waterford 3 W3F1-2010-0050 June 8, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Response to Request for Additional Information Associated with Technical Specification Table 34-1 Isolation Valve Addition Waterford Steam Electric Station Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCES:

1.W3F1-2010-0019, Technical Specification Table 3.4-1 Isolation' Valve Addition, February 22, 2010.2. NRC Letter, Request for Additional Information Re: Technical Specification Table 3.4-1 Isolation Valve Addition, April 14, 2010[ADAMS Accession Number ML101040651].

Dear Sir or Madam:

In Reference 1, Entergy Operations, Inc. (Entergy) proposeda change to.Waterford Steam Electric Station Unit 3 (Waterford

3) Technical Specifications (TS) Tab~le 3.4-1 Isolation Valve Addition.During the submittal review process, the Nuclear Regulatory Commission (NRC)determined that a Request for Additional Information (RAI) was required to complete the review of the Entergy request (Reference 2).

W3F17-2010-0050 Page 2 The response to the RAI is included in Attachment 1 to this letter. This letter contains no new commitments.

If you have any questions or require additional information, please contact William Steelman at 504-739-6685.

I declare under penalty of perjury that the foregoing is true and correct. Executed on June 8, 2010.Sincerely, JA JS

Attachment:

Response to Request for Additional Information W3F1 -2010-0050 Page 3 cc: Mr. Elmo E. Collins, Jr.Regional Administrator U. S.. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 760.11,-4125 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751.

U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith.P.O. Box 651 Jackson, MS 39205 Winston & Strawn ATTN: N.S. Reynolds 1700 K Street, NW Washington, DC 20006-3817 Morgan, Lewis & Bockius LLP ATTN: T.C. Poindexter 1111 Pennsylvania Avenue, NW Washington, DC 20004 Attachment to W3F17-2010-0050 Response to Request for Additional Information Attachment to W3F1-2010-0050 Page 1 of 16 NRC REQUEST FOR ADDITIONAL INFORMATION In Reference 1, Entergy Operations, Inc. (Entergy) proposed a change to Waterford Steam Electric Station Unit 3 (Waterford

3) Technical Specifications (TS) Table 3.4-1 Isolation Valve Addition.

During the submittal review process, the Nuclear Regulatory Commission (NRC) determined that a Request for Additional Information (RAI) was required to complete the review of the Entergy request (Reference 2).The following lists the Waterford 3 NRC RAIs and responses.

RAI 1 Provide name plate ratings and procurement details of the solenoid valves.RAI 1 Response The preliminary valve drawing no. 2141673xx (attached) from the manufacturer (Valcor) reflects a nameplate primary pressure rating of Class 1717 and pressure boundary design of 2485 psig at 650 deg. F. The solenoid valves are being procured in accordance with Waterford-3 Specification 1564.11 OA (Control Valves &Accessories

& Line Service Solenoid Valves Safety Class 1, 2, 3 & Non-nuclear Safety Class). Procurement requirements

/ details are as follows: 3/4" Diameter, Schedule 160, Socket Weld, Class 1E qualified to IEEE-323, ASME Ill, Class 1, Seismic Cat. 1, Borated Water Service, Stainless Steel Body, EGS type ECSA Conduit Seal, Radiation Environment 5.1 x i0 7 rads, with independent limit switches (2) normally open and (2) normally closed.RAI 2 Provide the electrical one line and applicable schematic drawings showing the power and control circuits for valves SI-4052A and SI-4052B.RAI 2 Response Drawing G287 sheet 1 is the electrical one line diagram for the DC control power (3A-DC-S and 3B-DC-S) and 120VAC Static Uninterruptible Power Supply (SUPS) 3A-S and 3B-S.Drawings B424 Sheets 596, E596, 595, and E595 are the schematic drawings showing the power for valve SI-4052A and its indication lights.Drawings B424 Sheets 591, E591, 590, and E590 are the schematic drawings showing the power for valve SI-4052B and its indication lights.These drawings are attached to this response.

Attachment to W3F1-2010-0050 Page 2 of 16 RAI 3 Provide a summary of the voltage drop calculation including circuit lengths and the cable design details. Also, explain how the cables are routed from the distribution panels, to the valves and the criteria used to meet electrical separation, independence, and redundancy requirements.

RAI 3 Response The voltage drop calculation determines that the Power Distribution Panels (PDP's)3A-S and 3B-S have sufficient voltage to assure that the new solenoids can operate properly.

The lowest design voltages at SI-4052A and SI-4052B are 96.9Vdc and 98.7Vdc, respectively.

The existing loads along with SI-405A (B) also remain above the minimum voltage required after the addition of the new solenoid valves, SI-4052A and SI-4052B.

The new'solenoid valve has an operating voltage rating range of 90V -140V and a full load current rating of 1.5A.The original controls for SI-405A(B) were modified by Engineering Change (EC) 935 to eliminate the Control Room CP-8 test switches and test indicating lights. The spared conductors (Class 1 E) for cables associated with existing SI-405A(B) will be used for the new solenoid.

These cables are routed from the Control Room Panel CP-8, located in the Reactor Auxiliary Building (RAB) +46 Elevation to the Auxiliary Relay Panel A (B), located in the RAB +35 Elevation, to the containment electrical penetrations RAB +35 Elevation and terminated at the solenoids located inside the Reactor Containment Building +21 Elevation.

Class 1 E spare cables between the Remote Shutdown Panel LCP-43 and the Auxiliary Relay Panel A (B) are used for the new solenoid.

This portion of the circuit is associated with controlling the valves from the alternate shutdown panel during a control room evacuation event. The cable lengths between the LCP-43 and the Auxiliary Relay Panel A and B are 115 feet and 55 feet, respectively.

These cable are class 1 E and are routed in safety related raceway that meet all separation, independence, and redundancy requirements in accordance with Regulatory guide 1.75 "Criteria for Independence of Electrical Safety Systems" and IEEE-384 "Criteria for Separation of Class 1 E Equipment and Circuits".

Train A and Train B are independent of each other with regard to power requirement and train separation requirement.

The cable length between the Control Room and Auxiliary Relay Panel A is 110 feet.The cable length between Auxiliary Relay Panel A and containment electrical penetration is approximately 335 feet. The cable length between containment electrical penetration and the solenoid is approximately 260 feet.Similarly, the cable length between the Control Room and Auxiliary Relay Panel B is 90 feet. The cable length between Auxiliary Relay Panel B and containment electrical Attachment to W3F1 -2010-0050 Page 3 of 16 penetration is approximately 160 feet. The cable length between containment electrical penetration and the solenoid is approximately 260 feet.RAI 4 Provide a summary of the loading calculations that indicates battery and power distribution panels have acceptable margin available for this modification.

RAI 4 Response Two calculations associated with safety related Battery 3A-S are ECE91 -061 "Battery 3A-S Cell Sizing" and ECE91-058 "Battery 3A-S Calculation for Station Blackout".

Likewise, the two calculations associated with safety related Battery 3B-S are ECE91 -062 "Battery 3B-S Cell Sizing" and ECE91 -059 "Battery 3B-S Calculation for Station Blackout." The Power Distribution Panel (PDP) loading calculations for PDP-3A1 -DC-S and PDP-3B1-DC-S are ECE91-193 and ECE91-194, respectively.

The purpose of. ECE91-061 is to ensure that Waterford 3 has adequate battery capacity to power DC loads during a design basis accident and a loss of offsite power (LOOP). The Emergency Diesel Generator starts within 10 seconds of a LOOP and provides power to the two safety related Battery Chargers via the load sequencer relay 7 seconds upon restoration of ACpower. Therefore, the calculation analyzes the Battery to provide power to the associated DC buses for a bounding time of 1 minute.Shutdown cooling is not commenced during the first minute of the LOOP event.Hence, the new solenoid SI-4052A will not be energized (i.e. to open) which will not impact-the loading on the battery.The purpose of ECE91-058 is to ensure that Waterford 3 has adequate battery capacity to support decay heat removal (natural recirculation) during a Station Blackout for a 4-hour coping duration.

The new solenoid SI-4052A will not be energized during natural recirculation and hence will not impact the loading on the battery.Each train of safety related battery at Waterford 3 has 60 cells with an 8-hour rating of 2320 ampere hours at 1.75 end cell voltage. Two auxiliary relays, rated at 0.082 FLA, are added for the control circuit on SI-4052A.

The indicating lights onthe valves SI-405A are removed from the battery. The net change is an increase of 0.002A, which has insignificant impact on the battery margin.Same analysis on Battery 3B-S is applicable for SI-4052B.The PDP panels are rated for 400 amps. The PDP-3A1-DC-S capacity is approximately 48% of its rating and PDP-3B1-DC-S is approximately 53% of its rating.This change increases the PDP load by less than one amp and is well within the available PDP capacity margin.

Attachment to W3F1 -2010-0050 Page 4 of 16 RAI 5 Provide a summary of the calculations that indicates Static Uninterruptible Power Supplies (SUPS) 3A-S and 3B-S and power distribution panels have acceptable margin available for this modification.

RAI 5 Response The loading calculations for SUPS 3A-S, SUPS 3B-S, Power Distribution Panel (PDP)390-SA, and PDP-391-SB are ECE91-176 and ECE91-177, respectively.

SUPS 3A-S and,3B-S are rated at 20kVA. The load on SUPS 3A-S is approximately 31% of its rating and the load on SUPS 3B-S is approximately 27%. The PDP panels are rated for 100 amps. The PDP-390-SA is approximately 52% of its rating and PDP-391 -SB is approximately 46% of its rating. The indicating lights for SI-4052A (B) will be powered from SUPS 3A-S and 3B-S. A total of 0.016 FLA will be added to each SUPS and PDP, which has insignificant impact on the SUPS and PDP margin.RAI 6a Describe the environmental parameters for the valves and cables including their physical locations.

RAI 6a Response The following environmental parameters are defined in Environmental Zone Map drawings G-M-0001, G-M-0002, G-M-0004, G-M-0009, and G-M-0012.Normal Service Conditions

a. Temperature

b. Pressure: c. Radiation (40 year): d. Relative Humidity: Plant Design Basis Events a. Accident Temperature:-

120OF Normal Inside Containment 104 0 F Normal Outside Containment 14.7 psia Nominal 0.31 Mrad Gamma Inside Containment (Air Equivalent) 20% to 90%(Worst Case)414°F Maximum Inside Containment (MSLB)269°F Maximum Inside Containment (LOCA)150OF for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Maximum Outside Containment Attachment to W3F1-2010-0050 Page 5 of 16 b. Accident Pressure:

44 psig Maximum Inside Containment 14.7 psia Maximum Outside Containment

c. Accident Type MSLB & LOCA (with Loss of Offsite Power for 4 Hours)d. Required Operating Time 120 days post accident e. Radiation:

33 Mrads Gamma (Air Equivalent)

Inside Containment 330 Mrads Beta Inside Containment

f. Relative Humidity:

100% Maximum Inside Containment 20% to 90% Outside Containment

g. Submergence:

None h. Chemical Spray: Yes: Inside Containment Only The Bypass Line installed around valves SI-405A(B) including solenoid valves SI-4052A(B) will be located in the Reactor Containment Building Elev. +21 outside the D-ring. The cables will be located in the Reactor Auxiliary Building, control room, and containment.

RAI 6b Explain how these components are qualified to meet the requirements of 10 CFR 50.49 for the environmental conditions they are expected to be exposed to. Also, provide a summary of the environmental qualification reports including the accident profiles.RAI 6b Response The EQ solenoid valves to be installed under Engineering Changes (ECs) 14765, 14766 and 14767 are currently in the procurement Ifrocess and will meet 1564.11 OA Rev. 15 specification which envelopes the environmental requirements.

EC 14765 states the modification installation shall not commence until an EQ assessment is developed and approved since vendor documentation to validate qualification is not available at this time. In addition to EC 14765 tracking qualification of these components, Action Request AR 84956-03 has been generated to evaluate the manufacturers EQ documentation ensuring the 10 CFR 50.49 requirements and the site requirements are satisfied.

In addition, Waterford 3 submittal letter W3F1-2010-0019 Attachment 4 contains the following commitment:

SI-4052A(B) will be'produred to withstand the environmental and accident conditions inside containment as shown in FSAR Table 3.11-1.

Attachment to W3F1-2010-0050 Page 6 of 16 RAI 7 Provide a summary of the protective device coordination of the circuits including the respective containment penetrations for valvesSI-4052A and SI-4052B.RAI 7 Response The new solenoid valve, SI-4052A(B), will be added in parallel with valve SI-405A (B)and will be fed from 125V dc control power, which is the same circuit that provides control power to SI-405A(B).

The electrical penetrations (141 and 142) associated with these circuits are protected by'double protections (two fuses) which currently meet the requirement of Technical Specification 3/4.8.4.The valve position indication lights for SI-4052A(B) and SI-405A(B) will be powered separately from the control circuit power for the same shutdown loop's valves SI-401A(B). The electrical penetrations (141 and 142) associated with these circuits are protected by double protections (breaker/fuse) which are currently tested in accordance with Technical Specification surveillance 4.8.4.1.REFERENCES

1. W3F1-2010-0019, Technical Specification Table 3.4-1 Isolation Valve Addition, February 22, 2010.2. NRC Letter, Request for Additional Information Re: Technical Specification Table 3.4-1 Isolation Valve Addition, April 14, 2010 [ADAMS Accession Number ML101040651].

3. NRC Letter, Acceptance Review for Technical Specification Table 3.4-1 Isolation Valve Addition, March 23, 2010 [ADAMS Accession Number ML100820566].

THIS PAGE IS AN OVERSIZED DRAWING OR FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED: "LOUISIANA POWER & LIGHT COMPANY, WATERFORD S.E.S. UNIT NO.3, 1977-1165 MW INSTALLATION 125 VDC AND 120 VAC ONE LINE DIAGRAM, G287, SH.I" WITHIN THIS PACKAGE...OR BY SEARCHING USING THE DOCUMENT/REPORT NO.D-01X