W3F1-2024-0014, Report of Facility Changes, Tests, and Experiments and Commitment Changes for Two Year Period Ending April 28, 2024
| ML24120A365 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/29/2024 |
| From: | Twarog J Entergy Operations |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| W3F1-2024-0014 | |
| Download: ML24120A365 (1) | |
Text
E) entergy W3F1-2024-0014 April 29, 2024 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 John Twarog Manager Regulatory Assurance 504* 739-67 4 7 10 CFR 50.59(d)(2) 10 CFR 72.48(d)(2)
Subject:
Report of Facility Changes, Tests, and Experiments and Commitment Changes for Two Year Period Ending April 28, 2024 Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 The summary report of facility changes, tests, and experiments for Waterford Steam Electric Station, Unit 3 (Waterford 3) is provided in Attachment 1 to this letter. This report is submitted in accordance with 1 O CFR 50.59(d)(2) and 1 O CFR 72.48(d)(2) and covers the period from April 28, 2022 through April 28, 2024. However, no 1 O CFR 72.48 evaluations were completed during this reporting period, so no 1 O CFR 72.48 report summaries are included in this submittal. to this letter provides the summary report of Commitment Changes for the same time period consistent with the guidance in SECY-00-0045 and Nuclear Energy Institute (NEI) 99-04.
There are no new commitments contained in this submittal.
Should you have any questions concerning this issue, please contact John Twarog, Manager, Regulatory Assurance, at 504-739-6747.
Respectfully,
~
John Twarog JT/llb
Enclosure:
- 1.
Waterford 3 Summary of 10 CFR 50.59 and 1 O CFR 72.48 Evaluations
- 2.
Waterford 3 Summary of Commitment Changes Enterav Ooerations. Inc.. 17265 River Road. Killona. LA 70057
W3F1-2024-0014 Page 2 of 2 cc:
NRC Region IV Regional Administrator NRC Senior Resident Inspector-Waterford Steam Electric Station, Unit 3 NRC Project Manager - Waterford Steam Electric Station, Unit 3 W3F1-2024-0014 Waterford 3 Summary of 1 0 CFR 50.59 and 10 CFR 72.48 Evaluations W3F1-2024-0014 Page 1 of 2 10 CFR 50.59 Evaluation Number 22-01 R1 22-01 R2 23-01 WATERFORD 3
SUMMARY
OF 10 CFR 50.59 AND 10 CFR 72.48 EVALUATIONS Initiating Summary Document EC-0000091881-000 Substitute CPC D RTD Input RC
[FCR-93024]
ITE0112CD1 with RC ITE0115. Temporary modification is being extended by one operating cycle such that it will be in place for Cycle 25. The updated response time of 19 seconds as documented in WO-00572188-53 is slower than the 13 seconds previously evaluated for Cycle 24 and the impact of that change with respect to 1 O CFR 50.59 is evaluated herein. Note that CR-WF3-2022-04613, the response time is understood to have previously been 19 seconds and the difference was caused by a testing deficiency, so the change in tested response time from 13 seconds to 19 seconds is not a condition that is degrading.
EC-0000091881-000 Substitute CPC D RTD Input RC
[FCR-93024]
ITE0112CD1 with RC ITE0115.
Westinghouse calculation CWTR3-TANL-CN-AA-000002 has been revised and provides a bounding technical basis for acceptability of this change up to a response time of 20 seconds. This is a cycle independent analysis that would have also applied to Cycle 24. This 50.59 evaluation is associated with Revision 2 of the 50.59 screeninq performed for EC-91881.
EC-0000090779-000 DEH-TCS (Digital-Electrohydraulic Turbine Control System) The existing Westinghouse Main Turbine Generator Electrohydraulic Control systems have obsolescence and single-point vulnerability issues. These ECs perform a full system upgrade of the existing turbine controls. The Emerson Ovation Version 3.8 Distributed Control System (DCS) designed by Westinghouse for use as a Turbine Control System (TCS) replaces the existing Westinghouse 2500 (MOD-II)
Digital Electro-hydraulic (DEH) Control System provided by the original supplier.
W3F1-2024-0014 Page 2 of 2 10 CFR 72.48 Evaluation Number None Initiating Summary Document N/A N/A W3F1-2024-0014 Waterford 3 Summary of Commitment Changes W3F1-2024-0014 Page 1 of 5 Commitment Change Evaluation Form (CCEF)
Number CCEF 2022-0007 CCEF 2022-0012 CCEF 2022-0013 WATERFORD 3
SUMMARY
OF COMMITMENT CHANGES Commitment Commitment Change Description Reason for Change/Deletion Number P-1411 Commitment status of all were revised to This CCEF changes the status of these P-1412 Historic based on the relocation of the Chemical commitments to Historic based on the relocation P-14166 Detection Systems Technical Specification (TS) of the Chemical Detection Systems TS and P-14168 and related Surveillance Requirement (SR) related SR 4. 7.6.1.d.4 to the TRM P-14183 4.7.6.1.d.4 to the TRM P-16344 P-16345 A-27708 Revision to Fire Water System Program and These changes will remove redundancy within enhance as described in LRA Section B.1.13 the commitments while maintaining compliance and NRC SER Appendix A.
with NFPA 25 recommendations for fire water storaqe tank inspections.
A-27706 Licensees should address the effects of the The date for the extended period of license reactor coolant environment on component renewal begins December 18, 2024. This new fatigue life as aging management programs are due date still provides for completion of the formulated for license renewal. That is the calculations 18 months before the period of purpose served by the calculations that are the extended operation. The date change has no subject of this commitment. The application of effect on any plant components.
environmental effects must be applied for operation during the period of extended operation for license renewal.
W3F1 -2024-0014 Page 2 of 5 Commitment Change Evaluation Form (CCEF)
Number CCEF 2023-0002 CCEF 2023-0003 Commitment Number A-26871 A-27554 Commitment Change Description Latent debris measurements at Waterford 3 are periodically performed to ensure that the analysis remains bounding. Inspection frequency is based upon the margin between the survey results and the analysis limit. Reference Waterford 3 Calculation 2004-07780 for inspection interval guidance and survey results.
In addition to the change to the commitment wording, this commitments status is being changed from Open to Sat.
No change to this commitment description. The commitment status is being changed from open to sat.
Reason for Change/Deletion EC-94486 Waterford 3 Final Supplemental Response for Generic Letter GL 2004-02.
The notification to the NRC of the change in this commitments status will be made via the two year summary report of commitment changes that is performed by Licensing IAW 10 CFR 50.59(d)(2}. Based upon the original commitment wording, the Waterford 3 survey history which shows the last three surveys each being less than 50% of the limit. The criteria and survey results are incorporated into calculation 2004-07780 and implemented PMRQ 8620-05. The change to the PM frequency from every third (SR) to every sixth refueling outage (6R} will be made following approval of EC 94456. This is a continuing compliance commitment which is satisfactorily being implemented by PMRQ 8620-05.
EC-94486 provides evaluation oaf the change to this commitment. This commitment is implemented by the existing Engineering Change process. A plant modification will trigger a revision to the related design control documentation. The related PAD screening will include a commitment review that will check compliance with this commitment A-27554 as well as identify any Licensing basis changes.
These are changes that are required to be submitted to the NRC within 6 months following a refueling outage per 10 CFR 50.71 (e).
W3F1-2024-0014 Page 3 of 5 Commitment Change Evaluation Form {CCEF)
Number CCEF 2023-0008 CCEF 2023-0009 Commitment Number P-17315 A-27706 Commitment Change Description Reason for Change/Deletion This Commitment was originally based on a Weekly requirement was originally based on response to IEN 89-17 (ref commitment A-IEEE 308-1971, which was later superseded by 16189) to confirm that W3 was mitigating risk IEEE 450-1980. The current standard states appropriately to prevent the condition noted in that the inspections should be performed at the IEN. The weekly inspection was originally least once per Month.
implemented per the requirements listed I IEEE standard 308-1971. W3 now follows IEEE standard 450-1980, which instead states that the inspection should be performed at least once per month. Therefore, the inspection described is not specifically required to be performed at a weekly interval per this commitment the interval for the surveillance Frequency Control Program (TSSFCP).
Licensees should address the effects of the Enhancement to develop a set of fatigue usage reactor coolant environment on component calculations prior to December 18,2023.
fatigue life as aging management programs are Remaining two enhancements prior to June 18, formulated for license renewal. That is the 2024. This new due date still provides for purpose served by the calculations that are the completion of the calculations 12 Months before subject of this commitment. The application of the period of extended operation. The date environmental effects must be applied tor change has no effect on any plant components.
operation during the period of extended operation for license renewal.
W3F1-2024-0014 Page 4 of 5 Commitment Change Evaluation Form (CCEF)
Number CCEF 2023-0013 CCEF 2023-0014 CCEF 2023-0015 Commitment Number A-27730 A-27736 A-27699 Commitment Change Description The change revises the enhancement to refer to "EPRI Closed Cooling Water Chemistry Guideline" instead of the specific document number that is currently shown as EPRI 1007820.
Change revises this enhancement to describe that multi-level or low-point sampling of the emergency diesel generator fuel oil storage tanks in the scope of the program is replaced with sampling form the discharge of diesel oil transfer pump after recirculation operation.
Bolting Integrity Program where the change deletes two enhancements because W3 does not have high strength bolting that meets the criteria of the Bolting Integrity Program.
Reason for Change/Deletion Later editions of the EPRI guidelines constitute industry guidance. As such, the commitment allows for later editions. Therefore, the specific revision of the guidelines is deleted from the commitment to eliminate a potential source of confusion. The guidelines are updated from time to time incorporating recommendations from chemistry experts based on industry operating experience to better manage effects of aging on materials exposed to treated closed cooling water. The FSAR is revised to refer to "EPRI Closed Cooling Water Chemistry Guideline" as an example of industry guidance instead of referring to the specific document number.
Due to multi-level sampling imposing a safety hazard to the technician, so the alternative sampling technique was deemed acceptable.
Tank cleaning and inspection activities implemented in accordance with this program will identify and correct corrosion or degradation, if any. Prior tank internal surface inspections have not identified areas of corrosion or degradation, which supports the effectiveness of the oroaram.
A review of high strength bolting in use at W3 determined that no bolting was installed that meets the Bolting Integrity Program criteria for inspection of high strength bolting. Statements describing high strength bolting inspections are therefore deleted. This program does not manage the effects of aging on reactor head closure stud or structural bolting, which are managed under different aging management proarams.
W3F1 -2024-0014 Page 5 of 5 Commitment Change Evaluation Form (CCEF)
Number CCEF 2024-0002 Commitment Number P-23468 Commitment Change Description To prevent recurrence, Maintenance Procedure MM-006-106, Plant Door/Plant Door Equipment maintenance will be revised to ensure control room envelope integrity is verified following airlock door maintenance by performing a pressure test on the control room envelope or performing alternate appropriate post maintenance testing demonstrating no adverse impact to CRE integrity. Only the first part of this 3 part commitment is affected by this CCEF.
The original commitment text stated that following control room door maintenance, a pressure test on the control room envelope would be performed.
Reason for Change/Deletion The purpose of this CCEF is to delete the locksets/cores/trim components limitation wording for the alternate post maintenance test.
This will allow for appropriate alternate testing (smoke test) to be performed for other types of door maintenance, such as seal maintenance.
The industry has confirmed that control room pressure testing is very limited in its assessment capability of control room integrity (ref RG1.197) and has been replaced in the W3 TS 3.7.6.1 by the performance of more accurate tracer gas in-leakage testing. Pressure tests are still performed periodically for system trending purposes. NEI 99-03, as endorsed by RG 1.97, provides guidance on appropriate retests following maintenance to ensure control room integrity. Section 9.3.2 NEI 99-003 specifically lists a smoke test as an appropriate retest for door seal maintenance to verify the gasket has been properly installed to minimize leakage.
Base on this it is acceptable for this commitment to allow for a pressure test or an appropriate test for post-maintenance door testinq.