ML20205L574

Issuance of Amendment No. 257 Control Room Air Condition System Technical Specifications

ML20205L574
Person / Time
Site:	Waterford
Issue date:	08/25/2020
From:	Audrey Klett Plant Licensing Branch IV
To:	Entergy Operations
Klett A
References
EPID L-2019-LLA-0187
Download: ML20205L574 (17)

Text

August 25, 2020 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 - ISSUANCE OF AMENDMENT NO. 257 RE: CONTROL ROOM EMERGENCY AIR FILTRATION SYSTEM TECHNICAL SPECIFICATION (EPID L-2019-LLA-0187)

Dear Sir or Madam:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 257 to Renewed Facility Operating License No. NPF-38 for the Waterford Steam Electric Station, Unit 3. This amendment revises the Technical Specifications in response to the application from Entergy Operations, Inc. via letter W3F1-2019-0047 dated August 27, 2019, as supplemented by letter W3F1-2020-0014 dated March 20, 2020.

Specifically, the amendment revises Technical Specification Surveillance Requirements 4.7.6.1.d.2 and 4.7.6.1.d.4 by adding an exception for dampers and valves that are locked or sealed.

The NRC staffs safety evaluation of the amendment is enclosed. The Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Audrey L. Klett, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosures:

1. Amendment No. 257 to NPF-38

2. Safety Evaluation cc: Listserv

ENTERGY OPERATIONS, INC.

DOCKET NO. 50-382 WATERFORD STEAM ELECTRIC STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 257 Renewed License No. NPF-38

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Entergy Operations, Inc. (EOI) dated August 27, 2019, as supplemented by letter dated March 20, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Renewed Facility Operating License and Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.2 of Renewed Facility Operating License No. NPF-38 is hereby amended to read as follows:

2. Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 257, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Jennifer Jennifer L. L. Dixon-Herrity Date: 2020.08.25 13:50:45 Dixon-Herrity -04'00' Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-38 and the Technical Specifications Date of Issuance: August 25, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 257 RENEWED FACILITY OPERATING LICENSE NO. NPF-38 WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382 Replace the following pages of Renewed Facility Operating License No. NPF-38 and the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License No. NPF-38 Remove Page Insert Page Technical Specifications Remove Page Insert Page 3/4 7-17 3/4 7-17

the NRC of any action by equity investors or successors in interest to Entergy Louisiana, LLC that may have an effect on the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

1. Maximum Power Level EOI is authorized to operate the facility at reactor core power levels not in excess of 3716 megawatts thermal (100% power) in accordance with the conditions specified herein.

2. Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 257, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. Antitrust Conditions (a) Entergy Louisiana, LLC shall comply with the antitrust license conditions in Appendix C to this renewed license.

(b) Entergy Louisiana, LLC is responsible and accountable for the actions of its agents to the extent said agent's actions contravene the antitrust license conditions in Appendix C to this renewed license.

AMENDMENT NO. 257

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

2. Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 0.5% when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and a relative humidity of 70%.

3. Verifying a system flow rate of 4225 cfm +/- 10% during train operation when tested in accordance with ANSI N510-1975.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 0.5%

when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and a relative humidity of 70%.

d. In accordance with the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 7.8 inches water gauge while operating the train at a flow rate of 4225 cfm +/- 10%.

2. Verifying that on a safety injection actuation test signal or a high radiation test signal, the train automatically switches into a recirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks and the normal outside airflow paths isolate, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position in Modes 5, 6, or defueled.

3. Verifying that heaters dissipate 10 +1.0, -1.0 kW when tested in accordance with ANSI N510-1975.

4. Verifying that on a toxic gas detection signal, the system automatically switches to the isolation mode of operation, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position in Modes 5, 6, or defueled.

e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the train at a flow rate of 4225 cfm +/- 10%.

f. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the train at a flow rate of 4225 cfm +/- 10%.

g. Perform required control room envelope unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

WATERFORD - UNIT 3 3/4 717 AMENDMENT NO. 115, 170, 194, 218, 249 257

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 257 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-38 ENTERGY LOUISIANA, LLC ENTERGY OPERATIONS, INC.

WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382

1.0 PROPOSED CHANGE

S 1.1 Introduction By letter W3F1-2019-0047 dated August 27, 2019 (Reference 1), as supplemented by letter W3F1-2020-0014 dated March 20, 2020 (Reference 2), Entergy Operations, Inc. (the licensee) applied for a license amendment to Renewed Facility Operating License No. NPF-38 for the Waterford Steam Electric Station, Unit 3 (Waterford 3). Specifically, the licensee requested to revise Waterford 3 Technical Specification (TS) Surveillance Requirements (SRs) 4.7.6.1.d.2 and 4.7.6.1.d.4 by adding an exception for dampers and valves that are locked or sealed to facilitate fuel movement with one train of the control room emergency air filtration system (CREAFS) inoperable.

By letter dated February 20, 2020, the U.S. Nuclear Regulatory Commission (NRC, the Commission) sent the licensee a request for additional information (RAI) (Reference 3). By letter W3F1-2020-0014 dated March 20, 2020, the licensee responded to the RAI. The supplemental letter dated March 20, 2020 provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs proposed no significant hazards consideration determination published in the Federal Register on December 17, 2019 (84 FR 68951).

1.2 Description of the CREAFS and Current TS Requirements In Section 2.1, System Description, of the enclosure to the license amendment request (LAR) dated August 27, 2019, the licensee stated, in part:

The CREAFS provides a protected environment from which operators can control the unit, during airborne challenges from radioactivity, hazardous chemicals, and Enclosure 2

fire byproducts, such as fire suppression agents and smoke, during normal and accident conditions.

The CREAFS consists of two redundant trains, each capable of maintaining the habitability of the CRE [control room envelope]. The CREAFS is considered operable when the individual components necessary to limit operator exposure are operable in both trains. A CREAFS train is considered operable when the associated:

Fan is operable; High-efficiency particulate air (HEPA) filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions; and Heater, demister, ductwork, valves, and dampers are operable, and air circulation can be maintained.

The CRE boundary is considered operable when the measured unfiltered air inleakage is less than or equal to the inleakage value assumed by the licensing basis analyses of DBA [design-basis accident] consequences to CRE occupants.

The outside air intake and exhaust valves isolate the control room from the outside environment and provide a flowpath between the various components in the control room ventilation system. Depending on the nature of any abnormal condition(s) of one or more of these valves, the impact on the safety system function differs. Excessive leakage in the closed position may impact the CRE boundary function. Excessive closure time may challenge time response limits but not boundary leakage requirements. Closed valves which have acceptable leakage performance that are subsequently deenergized do not impact CRE boundary operability. Also, some of these valves have additional safety system functional requirements in the open position in Modes 1 through 4 following an accident.

Waterford 3 TS 3/4.7.6, Control Room Air Conditioning System - Control Room Emergency Air Filtration System, establishes Limiting Condition for Operation (LCO) 3.7.6.1 for CREAFS (i.e.,

that two control room emergency air filtration trains shall be OPERABLE), the applicable modes for the LCO, required actions for inoperable trains, and SRs for CREAFS. SRs 4.7.6.1.d.2 and 4.7.6.1.d.4 require the licensee to demonstrate the operability of each control room emergency air filtration train.

1.3 Licensees Proposed Changes to the TSs In the LAR, the licensee proposed to modify TS SRs 4.7.6.1.d.2 and 4.7.6.1.d.4 by adding an exception for dampers and valves that are locked, sealed, or otherwise secured in the actuated position in Modes 5, 6, or defueled, in order to consider the SR met. The licensee proposed to

modify TS SRs 4.7.6.1.d.2 and 4.7.6.1.d.4 on TS page 3/4 7-17 as follows with the proposed additions shown in underlined text:

TS SR 4.7.6.1.d.2 would state:

Verifying that on a safety injection actuation test signal or a high radiation test signal, the train automatically switches into a recirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks and the normal outside airflow paths isolate, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position in Modes 5, 6, or defueled.

TS SR 4.7.6.1.d.4 would state:

Verifying that on a toxic gas detection signal, the system automatically switches to the isolation mode of operation, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position in Modes 5, 6, or defueled.

In the LAR, the licensee stated that it was requesting this change to facilitate fuel movement with one train of CREAFS with its associated outside air intake valves inoperable because of planned electrical bus or a static uninterruptable power supply outage. The current SRs, as written, would not be met for the valves on the train which was deenergized because the automatic outside air intake and exhaust valves would already be deenergized in their actuated (closed) positions. Similarly, a planned electrical outage that removes the capability of generating a test signal would also result in an unmet SR. The licensee stated that the continuation of fuel movement with one train of CREAFS inoperable was reviewed and approved by the NRC in Amendment No. 218 for Waterford 3 dated February 20, 2009 (Reference 4), and described in the associated safety evaluation (SE), which states, When one train is inoperable, placing the operable train in service ensures that the safety function can be carried out if an accident occurs.

2.0 REGULATORY EVALUATION

The NRC staff considered the following regulations, licensing and design bases, and guidance during its review of the proposed changes.

2.1 Regulations Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit, states, in part, that whenever a licensee desires to amend the license . . ., application for an amendment must be filed with the Commission . . . fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.

The regulation under 10 CFR 50.92(a) states that determinations on whether to grant an applied-for license amendment are guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. Both the common standards for operating licenses and construction permits in 10 CFR 50.40(a) and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3) provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public.

The regulation under 10 CFR 50.36, Technical specifications, establishes the regulatory requirements related to the content of TSs. The categories of items required to be in the TSs are listed in 10 CFR 50.36(c). SRs are defined in 10 CFR 50.36(c)(3) as requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The General Design Criterion (GDC) 19, Control room, in Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50 states, in part:

A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents.

Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident. Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures.

. . . holders of operating licenses using an alternative source term under [10 CFR] 50.67, shall meet the requirements of this criterion, except that with regard to control room access and occupancy, adequate radiation protection shall be provided to ensure that radiation exposures shall not exceed 0.05 Sv [sievert]

(5 rem) total effective dose equivalent (TEDE) as defined in [10 CFR] 50.2

[Definitions] for the duration of the accident.

2.2 Licensing and Design Bases By letter dated February 20, 2009, the NRC issued Amendment No. 218, which revised requirements related to control room habitability. Amendment No. 218 added TS 6.5.17, Control Room Envelope Habitability Program, which requires adequate radiation protection to be provided to permit access and occupancy of the CRE under DBA conditions without personnel receiving radiation exposures in excess of 5 rem TEDE for the duration of the accident.

In the LAR, the licensee stated that the CREAFS is designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a design-basis accident (DBA) without exceeding a 5 Roentgen equivalent man [rem] whole body dose or its equivalent to any part of the body. By letter dated March 29, 2005, the NRC issued Amendment No. 198 (Reference 5) for Waterford 3 allowing implementation of an alternative source term, as permitted by 10 CFR 50.67, Accident source term, for calculating accident offsite doses and doses to control room personnel. Paragraph 50.67(b)(2)(iii) of 10 CFR states that the NRC may issue the amendment only if the applicants analysis demonstrates with reasonable assurance that [a]dequate radiation protection is provided to permit access to and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 0.05 Sv (5 rem) total effective dose equivalent (TEDE) for the duration of the

accident. Therefore, the control room dose acceptance criterion is 5 rem TEDE. The previous offsite and control room accident dose criteria expressed in terms of whole body, thyroid, and skin doses were superseded by the TEDE criteria of 10 CFR 50.67 or fractions thereof, as defined in NRC Regulatory Guide (RG)1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors (Reference 6). Therefore, the NRC staff considered the control room dose acceptance criterion for review of the LAR dated August 27, 2019, as supplemented, to be 5 rem TEDE.

Waterford 3 TS SRs 4.7.6.1.b and 4.7.6.1.e contain requirements to identify any filter degradation and ensure the ability of the filters to perform in a manner consistent with the licensing basis for the facility.

2.3 Guidance RG 1.197, Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors (Reference 7), provides an approach acceptable to the NRC staff for measuring inleakage into the control room and associated rooms and areas at nuclear power reactors. The amount of inleakage is an input to the design of the control room, and periodic verification of the inleakage provides assurance that the control room will be habitable during normal and accident conditions. RG 1.197 provides guidance on methods acceptable to the NRC staff for determining CRE integrity for the purpose of confirming that the reactor meets GDC 19.

NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Chapter 16.0, Revision 3, Technical Specifications (Reference 8), contains guidance for reviews of TSs. The NRC staff applies this guidance in its reviews to help it determine whether the proposed changes would clarify the intent of the TSs.

3.0 TECHNICAL EVALUATION

The licensee is seeking to revise the TSs to adopt the additional flexibility for performing the SRs that it believes is supported by the NRC staff positions in its SE for Amendment No. 218.

The NRC staff evaluated the licensees LAR to determine whether the proposed changes are consistent with the regulations, licensing and design basis information, and guidance, as applicable, discussed in Section 2 of this SE. The NRC staff reviewed the proposed TS changes to determine whether they meet the standards in 10 CFR 50.36 (i.e., whether the proposed changes to the SRs would continue to provide assurance that the necessary quality of systems and components is maintained and that LCO 3.7.6.1 will be met). The NRC staff also used the guidance in Chapter 16.0 of NUREG-0800 to determine whether the proposed TS changes would clarify the intent of the TSs.

3.1 Fuel Movement with Proposed Changes In the LAR, the licensee stated that the NRC staff SE for Amendment No. 218 allows for the CRE boundary to be considered operable when the measured unfiltered air inleakage is less than or equal to the inleakage value assumed by the licensing basis analysis of DBA consequences to CRE occupants. The licensee further stated that removing power from closed boundary valves that have demonstrated acceptable leak tightness to support unfiltered air inleakage requirements does not render the CRE boundary inoperable - a necessary distinction during fuel movement coincident with a planned bus outage. The licensee stated that the bus outage would render the CREAFS unit and valves on the affected train inoperable. With the

affected CRE boundary valves deenergized closed, they are inoperable from a repositioning capability aspect, but the licensee stated that their leak tightness condition is unaffected and that the CRE boundary remains OPERABLE. Therefore, LCO 3.7.6.1 Action e would not be entered in this situation and fuel movement could continue.

The outside air intake and exhaust valves isolate the control room from the outside environment and provide a flow path between the various components in the control room ventilation system.

Depending on the nature of any abnormal condition(s) of one or more of these valves, the impact on the safety system function differs. The NRC staff notes that excessive leakage in the closed position may impact the CRE boundary function. Also, excessive closure time may challenge time response limits but not boundary leakage requirements. Closed valves having acceptable leakage performance that are subsequently deenergized do not impact CRE boundary operability. Because the operability of the CRE boundary is contingent on the leak-tightness of the CRE boundary valves, the NRC staff requested by letter dated February 20, 2020, additional information in RAI No. 1, regarding the testing frequency for all CRE boundary dampers and valves in addition to the past performance leakage history, to verify whether the proposed changes would ensure that the licensee would continue to maintain CRE boundary operability.

By letter dated March 20, 2020, the licensee responded to RAI No. 1 and provided the results for the most recent tracer gas tests in Table 1 and differential pressure tests in Table 2 of the response letter. The licensee stated that the CRE Habitability Program requires that the unfiltered inleakage (via control room tracer gas test) be determined at a 6-year frequency. The CRE Habitability Program also requires that a positive pressure measurement be performed at an 18-month frequency on a staggered test basis. This measures the CRE differential pressure relative to all adjacent areas during the pressurization mode of operation by one train of the control room emergency filtration unit operating at less than or equal to 200 cubic feet per minute (cfm). The results are trended and used as part of the assessment of the CRE boundary. The NRC staff reviewed the additional information provided in the supplement to the LAR dated March 20, 2020, and notes that the last three tests for both the tracer gas and differential pressure (both trains) all had satisfactory results. In addition, no adverse trend is apparent that would suggest that the performance criterion might be exceeded with the requested SR exception.

Preventative maintenance tasks on the CRE boundary valves are also required under the CRE Habitability Program. In its supplement to the LAR, the licensee stated that preventative maintenance tasks to clean, inspect, and replace non-metallic parts are required to be performed on all fourteen valves. In addition, the licensee stated that valves HVCMVAAA101 and HVCMVAAA102 (i.e., the CRE boundary valves for control room normal downstream isolation and control room normal outside air intake upstream isolation) are configured such that component testing on each valve is possible with a smoke tube. The licensee also stated that there has been no observable leakage at these valves for each of the past four occurrences of these preventative maintenance tasks. The licensee stated that the remaining twelve CRE boundary valves are configured such that component testing on each individual valve is not feasible without removing the valve from the ductwork; thus, no individual component testing has been performed on these valves beyond the unfiltered inleakage and differential pressure testing discussed in its supplement.

Additionally, the licensee is required to perform filter testing in accordance with SRs 4.7.6.1.b and 4.7.6.1.e, as these SRs are not affected by the proposed change. SRs 4.7.6.1.b

and 4.7.6.1.e would identify any filter degradation and ensure the ability of the filters to perform in a manner consistent with the licensing basis for the facility.

The NRC staff notes that the CRE boundary is considered operable when the measured unfiltered air inleakage is less than or equal to the inleakage value assumed by the licensing basis analysis of DBA consequences to CRE occupants. The NRC staff determined that the licensee has demonstrated that this is the case with significant margin and that, therefore, the proposed changes to the SRs are consistent with NRC RG 1.197 and conform with GDC-19.

The NRC staff determined that there is reasonable assurance that the proposed change will not have inadvertent effects on system operability or structure, system, and component quality.

Furthermore, the NRC staff notes that removing power from closed boundary valves that have demonstrated acceptable leak-tightness to support unfiltered air inleakage requirements does not render the CRE boundary inoperable. With the affected CRE boundary valves deenergized closed, they are inoperable from a repositioning capability aspect, but their leak-tightness condition is unaffected and the CRE boundary remains operable. Therefore, LCO 3.7.6.1 Action e for an inoperable CRE boundary would not be entered in this situation, and fuel movement could continue. Based on the above, the NRC staff has determined that the Waterford 3 TSs, as amended by the proposed changes, will continue to provide an acceptable way to meet 10 CFR 50.36(c)(3) because the revised SRs will continue to provide assurance that the necessary quality of systems and components is maintained and that the LCO will be met.

3.2 Review of Viability of Basis for Fuel Movement with One Train of CREAFS Inoperable In the LAR, the licensee discussed the applicability of the NRC staff positions in its SE for Amendment No. 218. The licensee stated that it was requesting the TS SR changes to facilitate fuel movement with one train of the CREAFS inoperable because of a planned electrical bus or static uninterruptable power supply outage. The licensee stated that the continuation of fuel movement with one train of CREAFS inoperable was reviewed and approved by the NRC in Amendment No. 218 and described in the associated SE. The licensee stated that its requested SR exception is consistent with the discussion in the SE for Amendment No. 218 concerning fuel movement which states, When one train is inoperable, placing the operable train in service ensures that the safety function can be carried out if an accident occurs.

In the LAR, the licensee stated, in part:

Securing the automatic valves or dampers in the actuated position may affect the operability of the system depending on the mode of operation. The CREAFS meets its safety function requirements during Modes 5, 6, and defueled when the automatic valves or dampers are in the closed position. During fuel movement in Modes 5, 6, and defueled, Engineering Calculation ECS04-011, Fuel Handling Accident (FHA) Alternative Source Term (AST) Radiological Dose Consequences for 3716 MWt [megawatts thermal] Extended Power Uprate (EPU), . . . demonstrates that the isolate mode for air makeup meets system operability requirements for the duration of the event. Therefore, aligning the system to comply with Action d during a maintenance [electrical] bus outage in Modes 5, 6, and defueled is acceptable, maintains system operability, and aligns with the NRCs approval of TS Amendment No. 218.

The SE for Amendment No. 218 discusses the situation of one CREAFS being inoperable during movement of irradiated fuel assemblies. The TS Actions approved in Amendment No. 218 include suspending movement with or over irradiated fuel assemblies or placing the operable train in service in the emergency radiation protection mode after 7 days per TS Action 3.7.6.1.d.

In the LAR, the licensee stated that its Engineering Calculation ECS04-011 also demonstrates that the isolate mode for air makeup meets system operability requirements for the duration of the event. Based on the amount of inleakage assumed in the dose analyses for an FHA, the NRC staff requested by letter dated February 20, 2020, additional information in RAI No. 2, regarding the margin of inleakage assumed versus the actual total inleakage for the CRE boundary. The licensee stated in its supplement to the LAR that Engineering Calculation ECS04-011 concludes that the total dose for the control room in an FHA is 0.824 rem TEDE using a total unfiltered inleakage of 100 cfm throughout the event. In its supplement to the LAR, the licensee indicated that the most recent tracer gas test was performed in 2014 under Work Order No. 52432363. The licensee stated that with the control room isolated in the applicable configuration corresponding to a high radiation signal (CRE isolated), the inleakage was tested to be 56 cfm, with 100 cfm being the testing acceptance limit; therefore, the current margin to the assumed inleakage in Engineering Calculation ECS04-011 is 44 cfm.

The NRC staff notes that the proposed exception is limited to instances when the plant is in Modes 5, 6, or defueled. The NRC staff determined that when the proposed exception is used, then the radiological consequences for the accidents previously evaluated are not changed because the CREAFS is still capable of performing the specified safety function assumed in the accident analyses, and the associated TS actions are followed if the CREAFS cannot perform its specified safety function. Given the statements provided in the LAR, as supplemented, the NRC staff determined that there is reasonable assurance that the proposed change will not inadvertently affect the clarity of the Waterford 3 licensing basis and is consistent with the SE for Amendment No. 218 for Waterford 3.

3.3 Technical Evaluation Conclusion Based on the preceding regulatory and technical evaluations, the NRC staff finds that the licensee has adequately justified the proposed TS changes in its application, as supplemented.

The results of the recent tests for the CRE dampers and valves have demonstrated acceptable leakage performance and support a conclusion that the leak-tight integrity of the CRE boundary is unaffected by the proposed changes. In addition, the scenario of fuel movement with an inoperable CREAFS train was previously evaluated and accepted by the NRC as documented in the SE for Amendment No. 218 for Waterford 3. Therefore, the NRC staff concludes that the proposed changes to TS SRs 4.7.6.1.d.2 and 4.7.6.1.d.4 regarding an exception for dampers and valves that are locked, sealed, or otherwise secured in the actuated position in Modes 5, 6, or defueled are acceptable and conform with GDC-19 and RG 1.197.

The NRC staff also determined that when the proposed exception is used, the radiological consequences for the accidents previously evaluated are not changed because CREAFS is still capable of performing the specified safety function assumed in the accident analyses, and the associated TS actions are followed if the CREAFS cannot perform its specified safety function.

Therefore, the NRC staff further concludes that the TSs, as amended by the proposed changes, will continue to provide an acceptable way to meet 10 CFR 50.36(c)(3) because the revised SRs will continue to provide assurance that the necessary quality of systems and components is

maintained and that the LCO will be met. Finally, the NRC staff determined that there is reasonable assurance that the proposed change will not inadvertently affect the clarity of the Waterford 3 licensing basis per the guidance in Chapter 16.0 of NUREG-0800.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the NRC staff notified the State of Louisiana officials by telephone and email on July 14, 2020 (Reference 9) of the proposed issuance of the amendment. The State officials had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration published in the Federal Register on December 17, 2019 (84 FR 68951), and there has been no public comment on such finding.

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Gaston, R., Entergy Operations, Inc., letter W3F1-2019-0047 to U.S. Nuclear Regulatory Commission, Application for Technical Specification Change to Control Room Air Conditioning System, Waterford Steam Electric Station, Unit 3, NRC Docket No. 50-382, Renewed Facility Operating License No. NPF-38, dated August 27, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19239A429).

2. Gaston, R., Entergy Operations, Inc., letter W3F1-2020-0014 to U.S. Nuclear Regulatory Commission, Response to U.S. Nuclear Regulatory Commission Request for Additional Information Regarding Application for Technical Specification Change to Control Room Air Conditioning System, Waterford Steam Electric Station, Unit 3 (Waterford 3), NRC Docket No. 50-382, Renewed Facility Operating License No. NPF-38, dated March 20, 2020 (ADAMS Accession No. ML20080L845).

3. Pulvirenti, A. L., U.S. Nuclear Regulatory Commission, letter to Site Vice President, Entergy Operations, Inc., Waterford Steam Electric Station, Unit 3 - Request for Additional Information Regarding License Amendment Request to Revise Surveillance Requirement 4.7.6.1.d, Control Room Air Filtration System (EPID L-2019-LLA-0187),

dated February 20, 2020 (ADAMS Accession No. ML20049A410).

4. Kalyanam, N., U.S. Nuclear Regulatory Commission, letter to Vice President, Operations, Entergy Operations, Inc., Waterford Steam Electric Station, Unit 3 - Issuance of Amendment Re: Modification of Requirements Regarding Control Room Envelope Habitability (TAC No. MD6547) [Amendment No. 218], dated February 20, 2009 (ADAMS Accession No. ML090360713).

5. Kalyanam, N., U.S. Nuclear Regulatory Commission, letter to Joseph E. Venable, Entergy Operations, Inc., Waterford Steam Electric Station, Unit 3 (Waterford 3)

- Issuance of Amendment Re: Full-Scope Implementation of an Alternative Accident Source Term (TAC No. MC3789) [Amendment No. 198], dated March 29, 2005 (ADAMS Accession No. ML050890248).

6. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, dated July 2000 (ADAMS Accession No. ML003716792).

7. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.197, Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors, dated May 2003 (ADAMS Accession No. ML031490664).

8. U.S. Nuclear Regulatory Commission, NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Chapter 16.0, Technical Specifications, Revision 3, dated March 2010 (ADAMS Accession No. ML100351425).

9. Klett, A., U.S. Nuclear Regulatory Commission, email to J. I. Wiley, Louisiana Department of Environmental Quality, NRC Notification of State of Louisiana re.

Waterford Steam Electric Station License Amendments - Changes to Technical Specifications, dated July 14, 2020 (ADAMS Accession No. ML20197A312).

Principal Contributors: Matthew Hamm, NRR Brian E. Lee, NRR Date: August 25, 2020

ML20205L574 *by email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA* NRR/DRA/ARCB/BC* NRR/DSS/SCPB/BC*

NAME AKlett PBlechman KHsueh (DGarmon for) BWittick DATE 07/31/2020 07/30/2020 07/24/2020 08/19/2020 OFFICE NRR/DSS/STSB/BC* OGC - NLO* NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*

NAME VCusumano JWachutka JDixon-Herrity AKlett DATE 08/19/2020 08/21/2020 08/19/2020 08/25/2020