ML110450255
| ML110450255 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/09/2011 |
| From: | Kowalewski J Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-04-002, W3F1-2011-0012 | |
| Download: ML110450255 (5) | |
Text
%'ýEEn teijy Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 Tel 504-739-6715 Fax 504-739-6698 jkowale@entergy.com Joseph A. Kowalewski Vice President, Operations Waterford 3 W3F1-2011-0012 February 9, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Commitment Change for Resolution of Generic Letter 2004-02 due to Deferral of Replacing the Waterford 3 Steam Generators Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38
REFERENCES:
- 1.
W3F1 -2010-0032, Response to Request for Additional Information Regarding Final Supplemental Response to Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors (TAC No. MC4729), dated 11/23/10 (ADAMS Accession No. ML103340117)
- 2.
Staff Requirements Memorandum - SECY-1 0-0113 - Closure Options for Generic Safety Issue -191, Assessment of Debris Accumulation on Pressurized Water Reactor Sump Performance, dated December 23, 2010 (.ADAMS Accession No. ML103570354)
Dear Sir or Madam:
The purpose of this letter is to notify the NRC of a change to the completion date for a commitment made associated with Generic Letter 2004-02. In Reference 1, it was indicated that Waterford 3 will replace the fibrous insulation on the current steam generators with Reflective Metal Insulation prior to Mode 4 following Refueling Outage 17. It was clarified within the contents of Reference 1 that Waterford 3 intended to install the Reflective Metal Insulation (RMI) in conjunction with replacing the steam generators during Refueling Outage 17 (RFO17). Activities were in progress to meet this commitment when a manufacturing problem with the replacement steam generators was identified. The manufacturing problem cannot be immediately resolved and the replacement steam generators will not be available for installation during RFO17. The RMI that had been designed for the replacement steam A
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W3F1-2011-0012 Page 2 generators will not fit the current steam generators without significant modification, and no other RMI has been designed or planned. Therefore, RMI will not be installed on the current steam generators in Refueling Outage 17.
Nonetheless, in Reference 2, the NRC indicated that resolution of GSI-191 is dependent upon completion of tests and analyses regarding in-vessel effects, which would be needed to allow formulating a path forward by mid-year 2012. As such, the NRC stated that it would be prudent to defer further GSI-191 plant modification actions (such as fibrous material removal) until the tests and analyses are complete.
Waterford 3 is revising its commitment to complete the removal of the fibrous insulation and replace it with Reflective Metal Insulation from RFO1 7 to "prior to Mode 4 following Refueling Outage 18." This revision is only a change in the due date for replacing the fibrous insulation and not a change in the commitment to replace it.
Extending the commitment due date has been determined to be acceptable based on the original commitment's intent to replace the fibrous insulation in conjunction with replacing the steam generators and that it is consistent with the NRC guidance in Reference 2 (specifically that it is prudent to defer fibrous material removal at this time).
This letter contains one commitment that revises commitment number 1 contained in Reference 1.
If you have any questions or require additional information, please contact William J.
Steelman at 504-739-6685.
I declare under penalty of perjury that the foregoing is true and correct. Executed on February 9, 2011.
Sincerely, Attachments: List of Regulatory Commitments
W3F1 -2011-0012 Page 3 cc:
Mr. Elmo E. Collins, Jr.
Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001
Attachment to W3F1-2011-0012 List of Regulatory Commitments
Attachment to W3F1 -2011-0012 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE SCHEDULED ONE-ck One)
COMPLETION TIME CONTINUING DATE COMMITMENT ACTION COMPLIANCE (If Required)
Waterford 3 will replace the fibrous x
Prior to Mode 4 insulation on the current steam following Refueling generators with Reflective Metal Outage 18 Insulation.