ML083430630

Request for Additional Information, License Amendment Request (LAR) to Modify Technical Specification 3/4.9.6, Refueling Machine

ML083430630
Person / Time
Site:	Waterford
Issue date:	01/02/2009
From:	Kalyanam N Plant Licensing Branch IV
To:	Entergy Operations
Kalyanam N, NRR/DLPM, 415-1480
References
TAC MD9670
Download: ML083430630 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 2,2009 Vice President, Operations Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST (LAR)

TO MODIFY TECHNICAL SPECIFICATION 3/4.9.6, REFUELING MACHINE (TAC NO. MD9670)

Dear Sir/Madam:

By letter dated September 18, 2008, Entergy Operations, Inc. (Entergy, the licensee),

submitted an application for a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) requesting a license amendment to the license in the form of changes to the Technical Specification (TS) Action Statements 'a' and 'b' of TS 3/4.9.6, Refueling Machine, to clarify acceptability of placing a suspended fuel assembly or control element assembly within the reactor vessel in a safe condition while restoring the refueling machine operability.

The NRC staff has reviewed the application and has determined that additional information contained in the enclosure is needed to complete the review.

NRC discussed the need for additional information with Mr. O. Pipkins and others of your staff on December 2, 2008. Mr. Pipkins agreed to provide a response within 30 days of the receipt of this letter.

If you have any questions, please contact me at (301) 415-1480 or by electronic mail at kaly.kalyanam@nrc.gov.

Sincerely,

(~./(~

N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382 cc: See next page

OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION WATERFORD STEAM ELECTRIC STATION, UNIT 3 LICENSE AMENDMENT REQUEST REGARDING MODIFY TECHNICAL SPECIFICATION 3/4.9.6, "REFUELING MACHINE" By letter dated September 18, 2008 (Agencywide Documents Access and Management System Accession No. ML082660039), Entergy Operations, Inc. (Entergy, the licensee),

submitted an application for a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) requesting a license amendment to the license in the form of changes to the Technical Specification (TS) Action Statements 'a' and 'b' of TS 3/4.9.6, "Refueling Machine," to clarify acceptability of placing a suspended fuel assembly or control element assembly (CEA) within the reactor vessel in a safe condition while restoring the refueling machine operability. On reviewing the LAR, the NRC staff has determined that response to the questions listed below is needed to complete the review.

The proposed change would allow movement of the refueling machine load (fuel assembly or CEA) to a safe condition in the event that the refueling machine became inoperable. The licensee indicated that the requested TS amendment would allow them to raise the load manually to the up-limit in the case of a failed refueling machine computer. With the refueling machine under manual control, a number of interlocks do not function (most notably the overload cut off), conceivably allowing accidental or inadvertent damage to the refueling machine load. The applicant proposes that the operator would perform the function of those interlocks while performing a "slow and careful raising of the hoist".

1. In your response to this RAI, please provide information detailing:

a. How does the lifting of the load manually and with interlocks bypassed constitute a safe condition rather than lowering the load?

b. What are the accuracy and response time of the visual indication of the load weight (which the operator would rely on)?

c. Why could not the hypothetical refueling machine computer failure and re-boot be addressed by means other than manually lifting the current load to the up-limit?

d. Explain the existence of any interlocks that would prevent translation of the refueling machine during a hoist and with an inoperable refueling machine computer.

e. Why would any damage to a fuel assembly due to inadvertent operator failure to manually stop the refueling machine at an interlock set point be still bounded by the "fuel assembly drop" accident?

~ 2

f. How does the identified precedent (Limerick, Unit 1) constitute prior NRC approval of the type of operation described in your submittal.

2. Please provide a detailed description of the specific manual operator actions required, including a description of the following:

a. The procedural guidance for the required actions including the prescribed safety considerations.

b. The specific operator training necessary to carry out these actions, if any, including any operator qualifications.

c. Additional personnel and/or equipment required by the operator to carry out these actions, if any.

d. The potentially harsh or inhospitable environmental conditions expected.

Include an explanation that compares the minimum water height above the top of active fuel to the expected water height when the fuel is raised to the refueling machine up limit in order to reboot the computer.

3. Please provide an analysis for the risk significance of the proposed operator actions.

This analysis should demonstrate that:

a. A single operator error of one manipulation does not result in exceeding the design requirements for design basis events.

b. The ability of the operator to recover from credible errors in performance of the manual actions, and the expected time required to make such a recovery.

4. Please explain if the fuel damage due to engagement during manual movement operations is an accident previously analyzed in the Final Safety Analysis Report (FSAR)

5. Please explain if raising the fuel in order to reboot the computer will be a more limiting scenario for a design-basis accident of a fuel drop than the one currently analyzed in the FSAR.

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