ML053500426

Request for Additional Information Related to Proposed Technical Specification Change to Steam Generator Tube Inservice Inspection Program Using Consolidated Line Item Improvement Process

ML053500426
Person / Time
Site:	Waterford
Issue date:	12/16/2005
From:	Fields M Plant Licensing Branch III-2
To:	Venable J Entergy Operations
Fields M , NRR/ADPT,415-3062
References
TAC MC7973
Download: ML053500426 (5)

Text

December 16, 2005 Mr. Joseph E. Venable Vice President Operations Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 (WATERFORD 3) -

REQUEST FOR ADDITIONAL INFORMATION RELATED TO PROPOSED TECHNICAL SPECIFICATION CHANGE TO STEAM GENERATOR TUBE INSERVICE INSPECTION PROGRAM USING CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (TAC NO. MC7973)

Dear Mr. Venable:

By letter dated June 21, 2005, Entergy Operations, Inc. proposed revisions to the Waterford 3 Technical Specifications which would allow replacement of the existing steam generator tube surveillance program with that being proposed by the Technical Specification Task Force (TSTF) in TSTF 449, Revision 4.

After reviewing your request, the Nuclear Regulatory Commission staff has determined that additional information is required to complete the review. We discussed this information with your staff by telephone and they agreed to provide the additional information requested in the enclosure within 30 days of receipt of this letter.

If you have any questions, please call me at (301) 415-1480.

Sincerely,

/RA/

Mel B. Fields, 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: See next page

December 16, 2005 Mr. Joseph E. Venable Vice President Operations Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 (WATERFORD 3) -

REQUEST FOR ADDITIONAL INFORMATION RELATED TO PROPOSED TECHNICAL SPECIFICATION CHANGE TO STEAM GENERATOR TUBE INSERVICE INSPECTION PROGRAM USING CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (TAC NO. MC7973)

Dear Mr. Venable:

By letter dated June 21, 2005, Entergy Operations, Inc. proposed revisions to the Waterford 3 Technical Specifications which would allow replacement of the existing steam generator tube surveillance program with that being proposed by the Technical Specification Task Force (TSTF) in TSTF 449, Revision 4.

After reviewing your request, the Nuclear Regulatory Commission staff has determined that additional information is required to complete the review. We discussed this information with your staff by telephone and they agreed to provide the additional information requested in the enclosure within 30 days of receipt of this letter.

If you have any questions, please call me at (301) 415-1480.

Sincerely,

/RA/

Mel B. Fields, 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: See next page DISTRIBUTION PUBLIC LPLIV r/f RidsOgcRp RidsAcrsAcnwMailCenter RidsNrrDorlLplg (DTerao) RidsNrrPMMFields RidsNrrLADJohnson RidsRgn4MailCenter (AHowell) RidsDciCsgb (AHiser)

RidsNrrDorl RidsNrrDci RLobel RidsNrrLADJohnson Accession No.: ML053500426

• RAI input from the staff without any major change OFFICE NRR/LPL4/PM NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NAME NKalyanam MFields DJohnson DTerao DATE DOCUMENT NAME: E:\Filenet\ML053500426.wpd OFFICIAL COPY

REQUEST FOR ADDITIONAL INFORMATION TECHNICAL SPECIFICATION CHANGE TO STEAM GENERATOR TUBE INSERVICE INSPECTION USING CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS ENTERGY OPERATIONS, INC.

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

1. The licensees Insert 1 (TS 3/4.4.4), corresponding to Technical Specification (TS) Task Force (TSTF) Section 3.4.18, does not have the NOTE stating Separate Condition entry is allowed for each SG [steam generator] tube. This is under the limiting condition for operation (LCO) for steam generator tube integrity. This note is required for the LCO to be used as intended and described in the TSTF. Please discuss your plans to modify the TS accordingly, or provide justification for omitting it.

2. In the proposed TS 6.5.9, Steam Generator (SG) Program, paragraph f refers to the installation of leak-tight sleeves for repairing defective tubes. Since the licensees amendment request regarding the partial inspection of tubes within the hot-leg tubesheet (C*) did not address portions of sleeves extending outside the C* distance, the staff has asked for additional information about this issue as part of the C* review.

The staff notes here that any changes made as a result of the C* review must be fully consistent with the TS changes proposed in this TSTF amendment.

3. In the proposed TS 6.5.9, Steam Generator (SG) Program, Section 6.5.9.d does not include paragraph 1 from the corresponding TSTF-449 section (5.5.9.d.1), which states, Inspect 100% [percent] of the tubes in each SG during the first refueling outage following SG replacement. Please discuss your plans to include this statement in your TS.

4. The second paragraph of the Insert B-1 Safety Analysis refers to the amount of leakage assumed from the faulted and unfaulted SGs. Please discuss your reason for assuming that leakage from unfaulted SGs will be greater than or equal to 75 gallons per day.

5. Regarding Insert B-1, Section 3/4.4.4, STEAM GENERATOR TUBE INTEGRITY, the first paragraph of the Background section leaves out the last four sentences from the corresponding paragraph in the TSTF:

The SG tubes isolate the radioactive fission products in the primary coolant from the secondary system. In addition, as part of the RCPB [reactor colant pressure boundary], the SG tubes are unique in that they act as the heat transfer surface between the primary and secondary systems to remove heat from the primary system. This Specification addresses only the RCPB integrity function of the

SG. The SG heat removal function is addressed by LCO 3.4.4, RCS [reactor coolant system] Loops - MODES 1 and 2, LCO 3.4.5, RCS Loops - MODE 3, LCO 3.4.6, RCS Loops - MODE 4, and LCO 3.4.7, RCS Loops - MODE 5, Loops Filled.

Please provide your reason for omitting these sentences (with section numbers appropriate for Waterford 3 in your proposed bases.

6. In the section of Insert B-1 called Limiting Condition for Operation, the final item on performance criteria addresses operational leakage. It does not include the following sentences in the TSTF (B.3.4.18) explaining the basis for an operational leakage criterion:

This limit is based on the assumption that a single crack leaking this amount would not propagate to a SGTR [steam generator tube rupture] under the stress conditions of a LOCA or a main steam line break. If this amount of LEAKAGE is due to more than one crack, the cracks are very small, and the above assumption is conservative.

Please discuss the reason for omitting these sentences.

7. In the proposed insert B-1, Action b (page 6 of Attachment 3) uses different language than the TSTF. This action refers to tubes that met the tube repair criteria but were not plugged or repaired according to the Steam Generator Program (new TS 6.5.9). The licensees proposed wording is, An allowed outage time of 7 days ..., while the TSTF states, A completion time of 7 days ... Please discuss the meaning of allowed outage time in this context, as well as why this wording is being used rather than the TSTF wording. Alternatively, please discuss your plans to revise the proposed specifications to adopt the TSTF language.

8. The licensees cover letter for the proposed TS changes discusses the inclusion of non-pressure loads into accident-induced leakage analyses. The staff notes that the Nuclear Energy Institute, in Enclosure 1 to a letter dated September 2, 2005, has now offered language that identifies this issue and NEIs position.

9. Please note that TS 6.5.9.d contains a typographical error in the second sentence: The number an portions of the tubes inspected ...... The word an should be and.

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 400 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 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 1700 K Street, N.W.

Washington, DC 20006-3817 Resident Inspector/Waterford NPS P. O. Box 822 Killona, LA 70066-0751 May 2005