ML041490149
| ML041490149 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/27/2004 |
| From: | Kalyanam N NRC/NRR/DLPM/LPD4 |
| To: | Venable J Entergy Operations |
| Kalyanam N, NRR/DLPM, 415-1480 | |
| References | |
| TAC MC1863 | |
| Download: ML041490149 (4) | |
Text
May 27, 2004 Mr. Joseph E. Venable Vice President Operations Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - PRE-APPLICATION REVIEW FOR REMOVAL OF TECHNICAL SPECIFICATION 3.7.4 ACTION STATEMENT c (TAC NO. MC1863)
Dear Mr. Venable:
By electronic mail dated January 20, 2004 (ADAMS Accession Number ML040640180), your staff had inquired the feasibility of submitting an amendment to the Waterford Steam Electric Station, Unit 3 (Waterford 3) Technical Specifications (TSs), deleting ACTION c in TS 3.7.4, Ultimate Heat Sink (UHS) and deleting the note with single asterisk, With a tornado watch in effect, all 9 DCT [dry cooling tower] fans under the missile protected portion of the DCT shall be OPERABLE. on Table 3.7-3, ULTIMATE HEAT SINK MINIMUM REQUIREMENTS PER FAN.
The justification for the amendment was that you would rely on the safety evaluation (SE) issued to Waterford 3 on September 15, 2000. The SE states that Waterford 3 had demonstrated that the probability of a tornado missile strike on certain components, including the DCT fans and motors and associated conduits and electrical boxes, is 6.4x10-7, which is below the acceptance criterion of 10-6 per year. You had indicated your plan to use this information to take credit for the DCT fans above the missile shield being operable essentially giving the plant an additional 6 DCT it can rely on.
In essence there were two questions posed in your electronic mail as listed below:
1.
Can the plant licensing basis be changed under Title 10 of the Code of Federal Regulations (10 CFR) Part 50.59 to using the TORMIS Code as reference?
Response: No.
The regulation at 10 CFR 50.59(b)(2)(viii) allows changes that do not, Result in a departure from a method of evaluation described in the FSAR [Final Safety Analysis Report] (as updated) used in establishing the design bases or in the safety analyses.
In addition, 10 CFR 50.59(a)(2)(ii) further clarifies that the licensee can change from a method described in the FSAR if the new method has been approved by the NRC for the intended application.
The Waterford 3 SE dated September 15, 2000, states that the approved use of the TORMIS methodology is limited to the evaluation of specific plant features where additional costly tornado missile protective barriers are under consideration.
Waterford 3 appears to be requesting the use of the results of the TORMIS methodology to remove a protective feature. This is not the intended application for which the TORMIS methodology is approved. The TORMIS methodology is currently not approved for justifying the removal of existing barriers, the methodology is limited to the evaluation of specific plant features where additional costly tornado missile protective barriers are under consideration.
2.
Does the NRC concur with Entergys interpretation of the September 15, 2000, SE that the dry cooling tower fans which are not under the tornado missile shield will survive a tornado?
Response: No.
It may be that the likelihood of the DCT surviving the a tornado is high or even very high, but it is not in the nature of probabilistic analyses to categorically state that the DCT will survive.
If you have any questions, please call me at (301) 415-1480.
Sincerely,
/RA/
N. Kalyanam, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-382 cc: See next page not approved for justifying the removal of existing barriers, the methodology is limited to the evaluation of specific plant features where additional costly tornado missile protective barriers are under consideration.
3.
Does the NRC concur with Entergys interpretation of the September 15, 2000, SE that the dry cooling tower fans which are not under the tornado missile shield will survive a tornado?
Response: No.
It may be that the likelihood of the DCT surviving the a tornado is high or even very high, but it is not in the nature of probabilistic analyses to categorically state that the DCT will survive.
If you have any questions, please call me at (301) 415-1480.
Sincerely,
/RA/
N. Kalyanam, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-382 cc: See next page DISTRIBUTION PUBLIC PDIV-1 r/f Rids OgcRp RidsAcrsAcnwMailCenter RidsNrrDlpmLpdiv1 (RGramm)
RidsNrrLADBaxley RidsNrrLADJohnson RidsNrrPMNKalyanam SDinsmore RHernandez-Figueroa RidsRgn4MailCenter (AHowell)
Accession No.:ML041490149
- Minor editorial changes from input provided OFFICE PDIV-1/PM PDIV-1/LA DSSA/SPLB*
DSSA/SPSB*
PDIV-1/SC NAME NKalyanam DBaxley Raul Hernandez-Figueroa Stephen Dinsmore RGramm DATE 5/20/04 5/20/04 05/17/04 05/17/04 5/27/04 DOCUMENT NAME: C:\\ORPCheckout\\FileNET\\ML041490149.wpd OFFICIAL RECORD COPY
July 2003 Waterford Steam Electric Station, Unit 3 cc:
Mr. Michael E. Henry, State Liaison Officer Department of Environmental Quality Permits Division P.O. Box 4313 Baton Rouge, Louisiana 70821-4313 Vice President, Operations Support Entergy Operations, Inc.
P. O. Box 31995 Jackson, MS 39286-1995 Director Nuclear Safety Assurance Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751 Wise, Carter, Child & Caraway P. O. Box 651 Jackson, MS 39205 General Manager Plant Operations Waterford 3 SES Entergy Operations, Inc.
17265 River Road 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 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Parish President Council St. Charles Parish P. O. Box 302 Hahnville, LA 70057 Executive Vice President
& Chief Operating Officer Entergy Operations, Inc.
P. O. Box 31995 Jackson, MS 39286-1995 Chairman Louisiana Public Services Commission P. O. Box 91154 Baton Rouge, LA 70825-1697