ML033160183
| ML033160183 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/12/2003 |
| From: | Berkow H NRC/NRR/DLPM/LPD4 |
| To: | Krupa M Entergy Operations |
| Kalyanam N, NRR/DLPM, 415-1480 | |
| Shared Package | |
| ml033160192 | List: |
| References | |
| TAC MB9644 | |
| Download: ML033160183 (5) | |
Text
November 12, 2003 Mr. Michael A. Krupa, Director Nuclear Safety & Licensing Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213-8298
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 (WATERFORD 3) -
RELAXATION REQUEST FROM U.S. NUCLEAR REGULATORY COMMISSION (NRC) ORDER EA-03-009 FOR THE CONTROL ELEMENT DRIVE MECHANISM NOZZLES (TAC NO. MB9644)
Dear Mr. Krupa:
By letter dated September 15, 2003, as supplemented by letters dated September 26, October 2, October 8, and October 24, 2003, Entergy Operations, Inc. (Entergy, the licensee) requested relaxation to implement an alternative to the requirements of Section IV, Paragraph C.(1)(b)(i), of the Order for all control element drive mechanism (CEDM) nozzles at Waterford 3. The September 15, 2003, relaxation request superseded a request made on June 11, 2003.
Specifically, pursuant to the process specified in Section IV, Paragraph F of the Order, you requested relaxation from the requirement specified in Section IV, Paragraph C, Item (1)(b)(i),
to instead perform inspections using a three-step alternative, which involves the use of an analysis technique, ultrasonic testing, and augmented surface examination.
The NRC staff has completed its review and concludes that the proposed alternative examination of the reactor pressure vessel (RPV) head provides reasonable assurance of structural integrity of the head. Further inspection of the head penetrations in accordance with Section IV.C.(1)(b)(i) of the Order would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Thus, you have demonstrated good cause for the requested relaxation. Therefore, pursuant to Section IV, Paragraph F of the Order and 10 CFR 50.55a(a)(3)(ii), I authorize, for one operating cycle commencing with the startup from the fall 2003 refueling outage, the proposed alternative inspection for all CEDM head penetration nozzles at Waterford 3, subject to the following condition:
If the NRC staff finds that the crack-growth formula in MRP-55 is unacceptable, Entergy shall revise its analysis that justifies relaxation of the Order within 30 days after the NRC informs Entergy of an NRC-approved crack-growth formula. If Entergys revised analysis shows that the crack growth acceptance criteria are exceeded prior to the end of the operating cycle [operating cycle 13], which follows the current refueling outage, this relaxation is rescinded and Entergy will, within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />, submit to the NRC written justification for continued operation. If the revised analysis shows that the crack growth acceptance criteria are exceeded during the subsequent operating cycle, Entergy shall, within 30 days, submit the revised analysis for NRC review. If the revised analysis shows that the crack growth acceptance criteria are not exceeded during either the
Michael A. Krupa upcoming operating cycle or the subsequent operating cycle, Entergy shall, within 30 days, submit a letter to the NRC confirming that its analysis has been revised. Any future crack-growth analyses performed for the upcoming operating cycle and future cycles for RPV head penetrations will be based on an NRC-acceptable crack growth rate formula.
The staffs related Safety Evaluation (SE) is enclosed.
Pursuant to 10 CFR 2.790 as stated in the Title 10 of the Code of Federal Regulations, we have determined that the enclosed SE does not contain proprietary information. However, we will delay placing the SE in the public document room for 10 working days from the date of this letter to provide you with the opportunity to comment on the proprietary aspects only. If you believe that any information in the enclosure is proprietary, please identify such information line by line and define the basis pursuant to the criteria of 10 CFR 2.790.
Be aware that when vessel head inspections are performed using American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) requirements, acceptance criteria, or qualified personnel, those activities and all related activities fall within the jurisdiction of the ASME Code. Therefore, Order-related inspection activities may be subject to third party review, including those by the Authorized Nuclear Inservice Inspector.
Sincerely,
/RA/
Herbert N. Berkow, Director Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
Safety Evaluation cc w/encl: See next page
Michael A. Krupa upcoming operating cycle or the subsequent operating cycle, Entergy shall, within 30 days, submit a letter to the NRC confirming that its analysis has been revised. Any future crack-growth analyses performed for the upcoming operating cycle and future cycles for RPV head penetrations will be based on an NRC-acceptable crack growth rate formula.
The staffs related Safety Evaluation (SE) is enclosed.
Pursuant to 10 CFR 2.790 as stated in the Title 10 of the Code of Federal Regulations, we have determined that the enclosed SE does not contain proprietary information. However, we will delay placing the SE in the public document room for 10 working days from the date of this letter to provide you with the opportunity to comment on the proprietary aspects only. If you believe that any information in the enclosure is proprietary, please identify such information line by line and define the basis pursuant to the criteria of 10 CFR 2.790.
Be aware that when vessel head inspections are performed using American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) requirements, acceptance criteria, or qualified personnel, those activities and all related activities fall within the jurisdiction of the ASME Code. Therefore, Order-related inspection activities may be subject to third party review, including those by the Authorized Nuclear Inservice Inspector.
Sincerely,
/RA/
Herbert N. Berkow, Director Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
Safety Evaluation cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsNrrLADJohnson (2) SBloom PDIV-1 r/f RidsRgn4MailCenter (AHowell)
RidsOgcRp RidsNrrPMNKalyanam RDavis RidsAcrsAcnwMailCenter RidsNrrDlpmLpdiv1 (RGramm)
Package: ML033160192 Accession No.: ML033160183 *See previous concurrence Safety Evaluation: ML033160198 OFFICE PDIV-1/PM PDIV-1/LA EMCB/SC* OGC* (NLO PDIV-1/SC PDIV-1/D with noted edits)
NAME NKalyanam MMcAllister TChan MYoung RGramm HBerkow DATE 11-12-03 11/12/03 11/10/03 11/10/03 11/12/03 11/12/03 OFFICIAL RECORD COPY
Waterford Steam Electric Station, Unit 3 cc:
Mr. Michael E. Henry, State Liaison Officer Regional Administrator, Region IV Department of Environmental Quality U.S. Nuclear Regulatory Commission Permits Division 611 Ryan Plaza Drive, Suite 1000 P.O. Box 4313 Arlington, TX 76011 Baton Rouge, Louisiana 70821-4313 Parish President Council Vice President, Operations Support St. Charles Parish Entergy Operations, Inc. P. O. Box 302 P. O. Box 31995 Hahnville, LA 70057 Jackson, MS 39286-1995 Executive Vice President Director & Chief Operating Officer Nuclear Safety Assurance Entergy Operations, Inc.
Entergy Operations, Inc. P. O. Box 31995 17265 River Road Jackson, MS 39286-1995 Killona, LA 70066-0751 Chairman Wise, Carter, Child & Caraway Louisiana Public Services Commission P. O. Box 651 P. O. Box 91154 Jackson, MS 39205 Baton Rouge, LA 70825-1697 General Manager Plant Operations Joseph E. Venable Waterford 3 SES Vice President Operations Entergy Operations, Inc. Entergy Operations, Inc.
17265 River Road 17265 River Road Killona, LA 70066-0751 Killona, LA 70066-0751 Licensing Manager Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751 Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502 Resident Inspector/Waterford NPS P. O. Box 822 Killona, LA 70066-0751 July 2003