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CAC:MF8325, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Withdrawn, Closed) |
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MONTHYEARW3F1-2016-0055, License Amendment Request to Revise Technical Specification 3/4.3.2 to Relocate Surveillance Frequency Requirements for Engineered Safety Features Actuation System (ESFAS) Subgroup Relays to the Surveillance Frequency Control Program2016-09-0101 September 2016 License Amendment Request to Revise Technical Specification 3/4.3.2 to Relocate Surveillance Frequency Requirements for Engineered Safety Features Actuation System (ESFAS) Subgroup Relays to the Surveillance Frequency Control Program Project stage: Request ML16286A4772016-10-12012 October 2016 NRR E-mail Capture - Waterford Unit 3 - Acceptance of Requested Action Regarding License Amendment Request to Revise Technical Specification 3/4.3.2 Project stage: Acceptance Review ML16354A1052016-12-27027 December 2016 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 Project stage: RAI ML16364A2902017-01-24024 January 2017 12/8/16, Summary of Public Meeting with Entergy Operations, Inc., Regarding the License Amendment Request to Revise Technical Specification Table 4.3-2 to Relocate ESFAS Subgroup Relays to the SFCP for Waterford Steam Electric Station, Unit Project stage: Meeting W3F1-2017-0010, Response to NRC Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3/4.3.2 to Relocate Surveillance Frequency Requirements for Engineered Safety Features Actuation System (Esfas)..2017-01-26026 January 2017 Response to NRC Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3/4.3.2 to Relocate Surveillance Frequency Requirements for Engineered Safety Features Actuation System (Esfas)... Project stage: Response to RAI ML17026A3702017-01-26026 January 2017 Response to NRC Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3/4.3.2 Project stage: Response to RAI W3F1-2017-0018, Supplement to Response to RAI on License Amendment Request to Revise Technical Specification 3/4.3.2 to Relocate Surveillance Frequency Requirements for Engineered Safety Features Actuation System Subgroup Relays to Surveillance.2017-02-27027 February 2017 Supplement to Response to RAI on License Amendment Request to Revise Technical Specification 3/4.3.2 to Relocate Surveillance Frequency Requirements for Engineered Safety Features Actuation System Subgroup Relays to Surveillance. Project stage: Supplement W3F1-2017-0024, Withdrawal of License Amendment Request to Revise Technical Specification 3/4.3.2 to Relocate Surveillance Frequency Requirements for Engineered Safety Features Actuation System (ESFAS) Subgroup Relays to the Surveillance Frequency..2017-03-22022 March 2017 Withdrawal of License Amendment Request to Revise Technical Specification 3/4.3.2 to Relocate Surveillance Frequency Requirements for Engineered Safety Features Actuation System (ESFAS) Subgroup Relays to the Surveillance Frequency.. Project stage: Withdrawal ML17097A1332017-04-25025 April 2017 Letter - Withdrawal of Amendment Request to Revise TS Table 4.3-2, ESFAS Subgroup Relays to the Surveillance Frequency Control Program Project stage: Withdrawal ML17097A1432017-04-25025 April 2017 FRN - Withdrawal of Amendment Request to Revise TS Table 4.3-2, ESFAS Subgroup Relays to the Surveillance Frequency Control Program Project stage: Withdrawal NRC-2016-0239, FRN - Withdrawal of Amendment Request to Revise TS Table 4.3-2, ESFAS Subgroup Relays to the Surveillance Frequency Control Program2017-04-25025 April 2017 FRN - Withdrawal of Amendment Request to Revise TS Table 4.3-2, ESFAS Subgroup Relays to the Surveillance Frequency Control Program Project stage: Withdrawal 2017-01-24
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Category:Letter
MONTHYEARIR 05000382/20230102024-01-31031 January 2024 Comprehensive Engineering Team Inspection Report 05000382/2023010 IR 05000382/20230032024-01-23023 January 2024 Acknowledgment of Reply to a Notice of Violation NRC Inspection Report 05000382/2023003 ML24012A1962024-01-12012 January 2024 Response to 2nd Round Request for Additional Information Concerning Relief Request Number EN-RR-22-001 Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and ML23340A2292023-12-28028 December 2023 Withdrawal of an Amendment Request to Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability (EPID L-2022-LLA-0169)-LTR ML23349A1672023-12-21021 December 2023 Request for Withholding Information from Public Disclosure ML23348A3572023-12-14014 December 2023 Application to Revise Technical Specifications to Use Online Monitoring Methodology Slides and Affidavit for Pre-Submittal Meeting ML23352A0292023-12-13013 December 2023 Entergy - 2024 Nuclear Energy Liability Evidence of Financial Protection ML23340A1592023-12-13013 December 2023 Entergy Operations, Inc. - Entergy Fleet Project Manager Assignment ML23333A1362023-11-29029 November 2023 Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23325A1442023-11-21021 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23312A1832023-11-14014 November 2023 Integrated Inspection Report 05000382/2023003 and Notice of Violation ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV IR 05000382/20234012023-10-0404 October 2023 Cyber Security Inspection Report 05000382/2023401 (Cover Letter Only) IR 05000382/20230052023-08-21021 August 2023 Updated Inspection Plan for Waterford Steam Electric Station, Unit 3 - (Report 05000382/2023005) IR 05000382/20233012023-08-15015 August 2023 NRC Initial Operator Licensing Examination Approval 05000382/2023301 IR 05000382/20230022023-08-0808 August 2023 Integrated Inspection Report 05000382/2023002 IR 05000382/20234022023-08-0707 August 2023 NRC Security Inspection Report 05000382/2023402 (Full Report) IR 05000382/20230402023-07-12012 July 2023 Revised 95001 Supplemental Inspection Report 05000382/2023040, Exercise of Enforcement Discretion, and Follow-Up Assessment Letter ML23191A4562023-07-10010 July 2023 Notification of Comprehensive Engineering Team Inspection (050003822023010) and Request for Information ML23158A1042023-06-0808 June 2023 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection 05000382/2023401 ML23145A2272023-06-0202 June 2023 95001 Supplemental Inspection Report 05000382/2023040, and Exercise of Enforcement Discretion ML23130A2732023-05-10010 May 2023 and Waterford 3 Steam Electric Station - Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations ML23117A2172023-05-0101 May 2023 Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment IR 05000382/20230012023-04-24024 April 2023 Integrated Inspection Report 05000382/2023001, Independent Spent Fuel Storage Installation Report 07200075/2023001, and Exercise of Enforcement Discretion ML23111A2132023-04-21021 April 2023 Responses to RAI Concerning Relief Request Number EN-RR-22-001 Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities ML23110A1122023-04-20020 April 2023 Annual Report for Entergy Quality Assurance Program Manual Changes Under 10 CFR 50.54(a)(3), 10 CFR 71.106, and 10 CFR 72.140(d). Notification of Application of Approved Appendix B to 10 CFR 72 Subpart G ML23108A2542023-04-18018 April 2023 WCGS Information Request, Security IR 2023401 IR 05000382/20234032023-04-17017 April 2023 Security Baseline Inspection Report 05000382/2023403 ML23093A2122023-04-0303 April 2023 Annual Report on Westinghouse Electric Company LLC Combustion Engineering Emergency Core Cooling System Performance Evaluation Models for Calendar Year 2022 ML23089A0602023-03-30030 March 2023 Entergy Operations, Inc. - Fleet Project Manager Assignment ML23088A3922023-03-29029 March 2023 Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) ML23080A2882023-03-21021 March 2023 Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) Entergy Operations, Inc ML23059A2592023-03-0707 March 2023 Correction to Issuance to Amendment No. 270 Adoption of TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b ML23065A2002023-03-0303 March 2023 EN 56252 Update - Flow Serve - Final Notification of Potential Part 21 on Peerless 56 Frame DC Motors ML23060A1092023-03-0101 March 2023 Proof of Financial Protection (10 CFR 140.15) IR 05000382/20220062023-03-0101 March 2023 Annual Assessment Letter for Waterford Steam Electric Station, Unit 3, (Report 05000382/2022006) ML22322A1092023-02-17017 February 2023 Issuance of Amendment No. 270 Adoption of TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b IR 05000382/20230902023-02-0101 February 2023 Final Significance Determination of a White Finding, NOV, and Follow-Up Assessment Letter; NRC Inspection Report 05000382/2023090 ML23032A5062023-02-0101 February 2023 Technical Specification Index and Bases Update to the NRC for the Period November 11, 2021 Through July 25, 2022 ML23030A6642023-01-27027 January 2023 Flowserve, Part 21 Second Interim Notification Report Re Peerless 56 Frame DC Motors IR 05000382/20220042023-01-26026 January 2023 Integrated Inspection Report 05000382/2022004 and Independent Fuel Storage Installation Inspection Report 07200075/2022001 ML23024A0822023-01-20020 January 2023 Stephens Insurance, Entergy - 2023 Nuclear Energy Liability Evidence of Financial Protection ML23018A2202023-01-18018 January 2023 Quality Assurance Program Manual Reduction in Commitment IR 05000382/20220912023-01-12012 January 2023 Emergency Preparedness Inspection Report 05000382/2022091 and Preliminary White Finding and Apparent Violation IR 05000382/20220032023-01-0505 January 2023 Revised Integrated Inspection Report 05000382/2022003 ML22342B1402022-12-0202 December 2022 56252-EN 56252 - Flowserve - Limitorque - Interim Report Potential Part 21 on Peerless 56 Frame DC Motors ML22300A2082022-11-30030 November 2022 Issuance of Amendment No. 269 Adoption of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors ML22332A5292022-11-29029 November 2022 Notification of NRC Initial Operator Licensing Examination 05000382/2023301 IR 05000382/20220132022-11-28028 November 2022 Design Basis Assurance Inspection (Programs) Inspection Report 05000382/2022013 IR 05000382/20220022022-11-0101 November 2022 Revised Integrated Inspection Report 05000382/2022002 2024-01-31
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23348A1222023-12-14014 December 2023 NRR E-mail Capture - Grand Gulf, River Bend, and Waterford, Unit 3 - 2nd Round of Official RAIs for RR EN-RR-22-001, Use ASME Code Case N-752, Risk Informed Categorization for Class 2 and 3 Systems ML23191A4562023-07-10010 July 2023 Notification of Comprehensive Engineering Team Inspection (050003822023010) and Request for Information ML23097A0412023-04-0606 April 2023 June 2023 Emergency Preparedness Exercise Inspection - Request for Information ML23076A0552023-03-13013 March 2023 EP Program Inspection RFI Hjs 10132022 ML23052A0882023-02-17017 February 2023 Inspection Request for Information ML22290A0442022-10-13013 October 2022 December 2022 Emergency Preparedness Program Inspection - Request for Information ML22206A0172022-07-22022 July 2022 NRR E-mail Capture - Request for Additional Information: Waterford 3 - License Amendment Requests to Adopt 10 CFR 50.69 and TSTF-505 ML22209A1082022-07-15015 July 2022 NRR E-mail Capture - Draft RAIs to License Amendment Request for Application to Adopt 10 CFR 50.69 and Revise Technical Specifications to Adopt TSTF-505, Revision 2 ML22103A1712022-04-13013 April 2022 LAR to Revise TS to Adopt TSTF-505_NRC Request for Additional Information ML22012A1592022-01-0505 January 2022 WF3 2022 EP Exercise Inspection RFI Sdh 010522 ML21280A0812021-10-0505 October 2021 Email 10-5-21 - Request for Information_ Waterford EP Inspection (71114.04 & 71151) - Nov-Dec 2021 ML21285A0242021-10-0505 October 2021 Digital Instrumentation and Control Modification Inspection Request for Information ML22112A1512021-08-0606 August 2021 NRR E-mail Capture - for Review: Draft RAIs to LAR to Relocate Chemical Detection Systems Technical Specifications (TS) to Technical Requirements Manual (TRM) ML21216A4562021-08-0404 August 2021 WF3 2021 EP Exercise Inspection Request for Information (RFI) ML21218A0402021-07-26026 July 2021 NRR E-mail Capture - Final RAIs to Entergy Operations, Waterford Steam Electric Station, Unit 3 LAR to Adopt 10 CFR 50.69 ML21196A5302021-07-19019 July 2021 Wat 2021010 RFI Letter 21N_05 Gap ML21195A0692021-07-13013 July 2021 Staton, Unit 3 - Notification of Digital Instrumentation and Control Modification Inspection and Request for Information ML21125A6522021-05-0606 May 2021 Wat 2021003 Brq RFI- Md, Waterford Steam Electric Station, Unit 3, Notification of Inspection (NRC Inspection Report 05000382/2021003) and Request for Information ML21112A2542021-04-29029 April 2021 Request for Additional Information Digital Upgrade to the Core Protection and Control Element Assembly Calculator System (EPID L 2020 Lla 0164) - Redacted Version ML20288A2082020-10-0808 October 2020 8Oct2020 Email - Request for Information (RFI) to Support and Prepare for the Emergency Preparedness (EP) Program Inspection at the Waterford 3 Station Scheduled to Occur the Week of December 7, 2020 ML20289A3502020-10-0505 October 2020 NRR E-mail Capture - NRC Request for Additional Information - WF3 EAL Scheme Change - L-2020-LLA-0122 ML20125A3212020-05-0404 May 2020 WAT2020410 Inspection Document Request ML20086M3852020-04-0101 April 2020 Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3/4 8.1, A.C. Sources Operating W3F1-2020-0014, Response to U. S. Nuclear Regulatory Commission Request for Additional Information Regarding Application for Technical Specification Change to Control Room Air Conditioning System2020-03-20020 March 2020 Response to U. S. Nuclear Regulatory Commission Request for Additional Information Regarding Application for Technical Specification Change to Control Room Air Conditioning System ML20049A4102020-02-20020 February 2020 Request for Additional Information Regarding License Amendment Request to Revise Surveillance Requirement 4.7.6.1.d, Control Room Air Filtration System ML19262H0362019-09-0404 September 2019 Ti 2515/194 Request for Information and Email ML19274D4932019-07-24024 July 2019 Request for Information IR 05000382 2019-003 Occupational Radiation Safety Inspection ML19203A0062019-07-19019 July 2019 NRR E-mail Capture - Waterford 3 - Final Request for Additional Information (Rais) Re Relief Request WF3-RR-19-2: Alternate Repair of Degraded Drain Line of Chemical and Volume Control System ML19151A6102019-06-0404 June 2019 Non-Proprietary Second Round RAI Regarding License Amendment Request for Use of the Tranflow Code for Determining Pressure Drops Across the Steam Generator Secondary Side Internal Components ML19172A0852019-05-24024 May 2019 NRR E-mail Capture - Waterford 3 - Final Request for Additional Information (Rais) Re Relief Request W3-ISI-032: Volumetric Examination Requirements ML19035A0412019-02-0101 February 2019 NRR E-mail Capture - Waterford 3 - Final Request for Information Regarding Relief Request WF3-RR-19-001 for Application of Dissimilar Metal Weld Full Structural Weld Overlay ML19018A0102019-01-28028 January 2019 Request for Additional Information Regarding License Amendment Request for Revision of Technical Specification 3/4.7.4,Ultimate Heat Sink ML18320A0902018-11-26026 November 2018 Request for Additional Information Regarding License Amendment Request for Use of the Transflow Code for Determining Pressure Drops Across the Steam Generator Secondary Side Internal Components ML18318A4352018-11-14014 November 2018 NRR E-mail Capture - Waterford 3 - Final Request for Additional Information Regarding Request for Alternative to ASME Code Case N-770-2 ML18299A0862018-11-0707 November 2018 Draft Request for Additional Information License Amendment Request Regarding the Revision of UFSAR Section 3.9 ML18262A0412018-09-25025 September 2018 Request for Additional Information Regarding License Amendment Request to Revise Section 15.4.3.1 of the Waterford 3 Updated Final Safety Analysis Report to Account for Fuel Misload ML18145A2652018-06-0101 June 2018 Supplemental Information Needed for Acceptance of Request for Licensing Action Use of Tranflow Code for Determining Pressure Drops Across Steam Generator Secondary Side Components ML18085A6942018-03-26026 March 2018 Ref: Waterford Steam Electric Station, Unit 3, License Renewal Application - RAI Set 18 ML18058A0572018-02-23023 February 2018 Enclosurequest for Additional Information (Letter to J. Giddens Request for Additional Information Regarding Entergy Operations, Inc.'S Decommissioning Funding Plan Update) ML18039A9722018-02-0808 February 2018 Notification of Evaluations of Changes, Tests, and Experiments Inspection (05000382/2018002) and Request for Information ML17233A2402017-08-14014 August 2017 NRR E-mail Capture - Draft RAI for Waterford Unit 3 Regarding License Amendment Request to Adopt TSTF-501 Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control ML17170A3012017-06-16016 June 2017 Notification of Inspection (NRC Integrated Inspection Report 05000382/2017003) and Request for Information ML17101A4432017-04-17017 April 2017 Requests for Additional Information for the Review of the Waterford Steam Electric Station, Unit 3, License Renewal Application - Set 17 ML17086A5852017-03-28028 March 2017 Request for Additional Information for the Environmental Review of Waterford 3 ML17072A0102017-03-14014 March 2017 Requests for Additional Information for the Review of the Waterford Steam Electric Station, Unit 3, License Renewal Application Set - 15 ML17272A3352017-03-0101 March 2017 Request for Additional Information for the Review of the Waterford Steam Electric Station, Unit 3, License Renewal Application - Set 14 ML17040A5382017-02-14014 February 2017 Requests for Additional Information for the Review of the Waterford Steam Electric Station, Unit 3, License Renewal Application - Set 13 ML17018A3592017-01-26026 January 2017 Requests For Additional Information For The Review Of The Waterford Steam Electric Station, Unit 3, License Renewal Application Set 12 (CAC MF7492.) ML16354A1052016-12-27027 December 2016 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 ML16356A5942016-12-19019 December 2016 NRR E-mail Capture - MF8325 Draft RAIs Regarding the License Amendment Request to Revise the Table Notation for Table 4.3-2, ESFAS Surveillance Requirements 2023-07-10
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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