ML16194A452

Supplement to the Risk-Informed Surveillance Requirements License Amendment Request (LAR)

ML16194A452
Person / Time
Site:	Waterford
Issue date:	07/12/2016
From:	Chisum M R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2016-0049
Download: ML16194A452 (13)

Text

W3F1-2016-0049July 12, 2016U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, DC 20555-0001

SUBJECT:

Supplement to the Risk-Informed Surveillance Requirements LicenseAmendment Request (LAR) Waterford Steam Electric Station, Unit 3(Waterford 3)Docket No. 50-382License No. NPF-38

REFERENCE:

1. Entergy letter W3F1-2015-0006, "Application for TechnicalSpecification Change Regarding Risk-Informed Justificationfor the Relocation of Specific Surveillance FrequencyRequirements to a Licensee Controlled Program," WaterfordSteam Electric Station, Unit 3 dated June 17, 2015.[ML15170A121]

Dear Sir or Madam:

By letter dated June 17, 2015, Entergy Operations, Inc. (Entergy), submitted a licenseamendment request (LAR) to adopt U.S. NRC-approved Technical Specification TaskForce (TSTF) Standard Technical Specifications Change traveler TSTF-425 Initiative 5b(Reference 1).During a conference call on July 11, 2016, between Entergy and the NRC, it wasdetermined that a supplement was needed to correct inconsistencies discovered inReference 1. Specifically:1. Table 4.7-1 Item 2 (Isotopic Analysis for Dose Equivalent I-131 Concentration) isan event driven surveillance requirement (SR) that should remain unchanged fromthe current Table 4.7-1 and not be controlled by the Surveillance FrequencyControl Program (SFCP). The markup and clean pages of Table 4.7-1 Item 2 arepresented in Attachment 1 to reflect this change.2. Surveillance Requirement 4.8.1.1.2d refers to another SR (4.8.1.1.2a.4) as a 31day surveillance providing acceptable alternate credit. SR 4.8.1.1.2a is included inReference 1 as a frequency that will be controlled under the SFCP, rendering the"31 day" verbiage unnecessary. Since SR 4.8.1.1.2a is explicitly included in thescope of the LAR, removal of the unnecessary reference to "31 days" has alreadybeen reviewed and accepted by the NRC pending approval of the LAR. Theupdated markup and clean pages for SR 4.8.1.1 2d are presented in Attachment 2.Entergy Operations, Inc.17265 River RoadKillona, LA 70057-3093Tel 504-739-6660Fax 504-739-6698mchisum@entergy.comMichael R. ChisumSite Vice PresidentWaterford 3 W3F1-2016-0049 Page 23. The proposed mark-up page for SR 4.1.2.2b provided in Reference 1, Attachment1, was incorrectly transcribed to the clean page for the same SR provided in Reference 1, Attachment 2. The deleted wording "during shutdown" should notappear in the final version of SR 4.1.2.2b. The updated clean page is presented in .4. Similarly to item 3 above, the proposed markup page for SR 4.7.3b is correctly depicted in Reference 1, Attachment 1. However, the clean page depicted inReference 1, Attachment 2, incorrectly included the deleted wording "during shutdown". The updated clean page is presented in Attachment 4.The above corrections are considered editorial and are consistent with current TS and the LAR (Reference 1). The proposed No Significant Hazards Consideration provided in Reference 1 remains unchanged.There are no new regulatory commitments contained in this submittal. If you requireadditional information, please contact the Regulatory Assurance Manager, John Jarrell, at 504-739-6685.I declare under penalty of perjury that the foregoing is true and correct. Executed on July 12, 2016.

Sincerely, MRC/AJH

Attachment:

1. TS Table 4.7-1 Item 2 Markup and Clean Pages

2. TS SR 4.8.1.1.2d Markup and Clean Pages

3. TS SR 4.1.2.2b Clean Page

4. TS SR 4.7.3b Clean Page cc: Kriss Kennedy Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.Arlington, TX 76011-4511 RidsRgn4MailCenter@nrc.gov NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 Frances.Ramirez@nrc.gov Chris.Speer@nrc.gov W3F1-2016-0049Page 3U. S. Nuclear Regulatory CommissionAttn: Dr. April PulvirentiWashington, DC 20555-0001April.Pulvirenti@nrc.govLouisiana Department of EnvironmentalQualityOffice of Environmental ComplianceSurveillance DivisionP.O. Box 4312Baton Rouge, LA 70821-4312Ji.Wiley@LA.gov ATTACHMENT 1W3F1-2016-0049TS Table 4.7-1 Item 2 Markup and Clean Pages

-.III's TABLE 4.7-1 SECONDARY COOLANT SYSTEM SPECIFIC ACTIVITY SAMPLE AND ANALYSIS PROGRAM 2 1JD TYPE OF MEASUREMENT AND ANALYSIS SAMPLE AND ANALYSIS FREQUENCY 1. Gross Activity Determination

2. Isotopic Analysis for DOSE EQUIVALENT I-131 Concentration At least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> a) 1 per 31 days, whenever the gross activity determina-tion indicates iodine con-centrations greater than 10%of the allowable limit.b) 1 per 6 months, whenever the gross activity determination indicates iodine concentra-tions below 10% of the allowable limit.\J 9 WATERFORD

-UNIT 3 3/4 7-8 WATERFORD - UNIT 33/4 7-8AMENDMENT NO.249TABLE 4.7-1SECONDARY COOLANT SYSTEM SPECIFIC ACTIVITYSAMPLE AND ANALYSIS PROGRAMTYPE OF MEASUREMENTSAMPLE AND ANALYSIS AND ANALYSIS FREQUENCY 1.Gross Activity DeterminationIn accordance with the SurveillanceFrequency Control Program2. Isotopic Analysis for DOSEa) 1 per 31 days, wheneverEQUIVALENT I-131 Concentrationthe gross activity determina-tion indicates iodine con-concentrations greater than10% of the allowable limit.b) 1 per 6 months, whenever thegross activity determinationindicates iodine concentra-tions below 10% of theallowable limit.

ATTACHMENT 2W3F1-2016-0049TS SR 4.8.1.1.2d Markup and Clean Pages ELECTRICAL POWER SURVEILLANCE REQUIREMENTS (Continued) At least once per 184 days a diesel generator fast start test shall be performed in accordance with TS 4.8.1.1.2a.4.

Performance of the 184 day fast start test satisfies the 31 day testing requirements specified in TS 4.8.1.1.2a.4. At least once per 18 months by: Verifying the generator capability to reject a load of greater than or equal to 498 kW while maintaining voltage at 4160 +420, -240 volts and frequency at 60 +4.5, -1.2 Hz. Verifying the generator capability to reject a load of an indicated 4400 kW without tripping.

The generator voltage shall not exceed 5023 volts during and following the load rejection. During shutdown, simulating a loss-of-offsite power by itself, and: Verifying deenergization of the emergency busses and load shedding from the emergency busses. Verifying the diesel starts on the auto-start signal, energizes the emergency busses and the permanently connected loads within 10 seconds after the auto-start signal, energizes the connected shutdown loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the state voltage and frequency of the emergency busses shall be maintained at 4160 +420, -240 volts and 60 +1.2, -0.3 Hz during this test. Verifying that on an SIAS actuation test signal (without loss-of-offsite power) the diesel generator starts on the auto-start signal and operates on standby for greater than or equal to 5 minutes. The steady-state generator voltage and frequency shall be 4160 +420, -240 volts and 60 +/- 1.2 Hz within 10 seconds after the auto-start signal; the generator voltage and frequency shall be maintained within these limits during this test. WATERFORD

-UNIT 3 3/4 8-5 AMENDMENT NO.

WATERFORD - UNIT 3 3/4 8-5AMENDMENT NO. 4, 23, 74, 88, 98,180, 216,249ELECTRICAL POWER SYSTEMSSURVEILLANCE REQUIREMENTS(Continued) d.In accordance with the Surveillance Frequency Control Programa dieselgenerator fast start test shall be performed in accordance with TS 4.8.1.1.2a.4.Performance of the fast start test satisfies the testing requirements specified in TS4.8.1.1.2a.4.

e.In accordance with the Surveillance Frequency Control Programby: 1.Verifying the generator capability to reject a load of greater than or equal to498 kW while maintaining voltage at 4160 +420, -240 volts and frequency at60 +4.5, -1.2 Hz.

2.Verifying the generator capability to reject a load of an indicated4000-4400 kW without tripping. The generator voltage shall not exceed5023 volts during and following the load rejection.

3.During shutdown, simulating a loss-of-offsite power by itself, and:

a)Verifying deenergization of the emergency busses and load sheddingfrom the emergency busses.

b)Verifying the diesel starts on the auto-start signal, energizes theemergency busses and the permanently connected loads within10 seconds after the auto-start signal, energizes the auto-connectedshutdown loads through the load sequencer and operates forgreater than or equal to 5 minutes while its generator is loaded withthe shutdown loads. After energization, the steady-state voltageand frequency of the emergency busses shall be maintained at4160 +420, -240 volts and 60 +1.2, -0.3 Hz during this test.

4.Verifying that on an SIAS actuation test signal (without loss-of-offsite power)the diesel generator starts on the auto-start signal and operates on standbyfor greater than or equal to 5 minutes. The steady-stategenerator voltage and frequency shall be 4160 +420, -240 volts and 60 1.2 Hz within 10 seconds after the auto-start signal; the generator voltageand frequency shall be maintained within these limits during this test.

ATTACHMENT 3W3F1-2016-0049TS SR 4.1.2.2b Clean Page WATERFORD - UNIT 33/4 1-7AMENDMENT NO. 10, 199,249REACTIVITY CONTROL SYSTEMSFLOW PATHS - OPERATINGLIMITING CONDITION FOROPERATION3.1.2.2 At least two boron injection flow paths to the RCS via the chargingpumps shall be OPERABLE. The following flow paths may be used:a. With the contents of either boric acid makeup tank in accordancewith Figure 3.1-1, the following flow paths shall be OPERABLE:1. One flow path from an acceptable boric acid makeup tank via its boric acid makeup pump; and2. One flow path from an acceptable boric acid makeup tank via its gravity feed valve; orb. With the combined contents of both boric acid makeup tanks in accor-dance with Figure 3.1-2, both of the following flow paths shall beOPERABLE: 1.One flow path consisting of both boric acid makeup pumps, and 2.One flow path consisting of both gravity feed valves.APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:With only one of the above required boron injection flow paths to the ReactorCoolant System OPERABLE, restore at least two boron injection flow paths to theReactor Coolant System to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOTSTANDBY and borated to a SHUTDOWN MARGIN equivalent to the requirements ofSpecification 3.1.1.1 or 3.1.1.2, whichever is applicable, within the next6 hours; restore at least two flow paths to OPERABLE status within the next7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SURVEILLANCEREQUIREMENTS4.1.2.2 At least two of the above required flow paths shall be demonstratedOPERABLE:a. By verifying that each valve (manual, power-operated, or automatic) in the flow paththat is not locked, sealed, or otherwise secured in position, is in its correct position inaccordance with the Surveillance Frequency Control Program

.b. By verifying that each automatic valve in the flow path actuates to itscorrect position on an SIAS test signalin accordance with the SurveillanceFrequency Control Program.c. By verifying that the flow path required by Specification 3.1.2.2a.1 and 3.1.2.2a.2delivers at least 40 gpm to the Reactor Coolant Systemin accordance with theSurveillance Frequency Control Program.

ATTACHMENT 4W3F1-2016-0049TS SR 4.7.3b Clean Page WATERFORD - UNIT 3 3/4 7-11AMENDMENT NO. 209, 249 PLANT SYSTEMS3/4.7.3 COMPONENT COOLING WATER AND AUXILIARY COMPONENT COOLING WATER SYSTEMSLIMITING CONDITION FOR OPERATION3.7.3 At least two independent component cooling water and associated auxiliary component cooling water trains shall be OPERABLE.APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:With only one component cooling water and associated auxiliary component cooling water train OPERABLE, restore at least two trains to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SURVEILLANCE REQUIREMENTS4.7.3 Each component cooling water and associated auxiliary component cooling water train shall be demonstrated OPERABLE:

a.In accordance with the Surveillance Frequency Control Program by verifying thateach valve (manual, power-operated, or automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.In accordance with the Surveillance Frequency Control Program , by verifyingthat each automatic valve servicing safety-related equipment actuates to its correct position on SIAS and CSAS test signals.

c.In accordance with the Surveillance Frequency Control Program by verifying that each component cooling water and associated auxiliary component cooling water pump starts automatically on an SIAS test signal.