ML113120470
| ML113120470 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/08/2011 |
| From: | Kalyanam K Plant Licensing Branch IV |
| To: | Steelman W Entergy Operations |
| Kalyanam N, NRR/DORL/LPL4, 415-1480 | |
| References | |
| TAC ME7342 | |
| Download: ML113120470 (1) | |
Text
From:
Kalyanam, Kaly Sent:
Tuesday, November 08, 2011 2:55 PM To:
STEELMAN, WILLIAM J
Subject:
FW: Accetance Review Results - Supplemental information needed to continue the detailed review To: W. Steelman, Waterford Steam Electric Station, Unit 3 Docket No. 50-382 By letter dated October 13, 2011, Entergy Operations Inc. (Entergy, the licensee) submitted a license amendment request (LAR) for Waterford Steam Electric Station, Unit 3 (Waterford 3). The proposed amendment would modify the wet cooling tower (WCT) fan requirements by placing a limit on the number of inoperable fans per cell.
This change is needed because the current technical specification (TS) requirement was found to be non-conservative. In addition to the above change, the dry bulb temperature limits for the dry cooling tower and wet bulb temperature limits for the WCT will be lowered to accommodate the increased heat load resulting from the Replacement Steam Generators (RSGs). The application stated that the non-conservatisms in the TS is addressed by the implementation of certain administrative controls that limit the number of WCT fans allowed out-of-service per cell.
The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR),
an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
In order to make the application complete, the NRC staff requests that Entergy to supplement the application to address the information requested in the enclosure by November 25, 2011. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staffs request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review actives associated with the application. If the application is subsequently accepted for review, you will be advised of any further
information needed to support the staffs detailed technical review by separate correspondence.
REQUIRED INFORMATION:
- 1) In its proposed TS change, the licensee has lowered dry bulb temperature requirements for the DCT and lowered wet bulb temperature requirements for the WCT, to account for the increased heat duty on the DCT and WCT as a result of the Replacement Steam Generators. The licensees sole stated technical justification for this change is This change is supported by calculation ECM 95-009 that used the same CTI Code ATC-101 methodology that was originally used. This explanation does not provide technical information in sufficient detail as to what extent the RSGs affects the DCT and WCT to allow me to make an independent assessment regarding the acceptability of the proposal in terms of regulatory requirements. Specifically, the licensees justification does not include a discussion of design inputs, assumptions, and a description of the methodology used. The conclusions of the design calculation should clearly justify the reduction in the TS temperature requirements.
- 2) In addition to accounting for the RSGs, the licensee states that another reason for the proposed TS changes is to address the non-conservatisms in TS Table 3.7-3.
The licensees proposed change from 4 fans operable to a minimum of 2 fans per cell operable, for the wet bulb temperature range that is less than 68.5°F, is clearly conservative and needs no further justification than what was presented.
However, the licensee proposed some new TS requirements in its submittal that are less restrictive than current requirements and did not acknowledge or address this less restrictive requirement. Specifically, the proposed TS requirements for the WCT is less conservative in the 70°F -73.5°F wet bulb temperature (WBT) range where 7 fans are currently required, whereas the proposed change would require only 6 fans (3 fans per cell). This non-conservatism is further made more non-conservative by the added heat duty of the Replacement Steam Generators.
The licensee has provided no technical justification for this reduced requirement or even acknowledged that this reduction in air flow exists, other than they stated that they used the CTI code and the Zurn WCT Performance Curves with no explanation as to why 7 fans were once necessary, but now only 6 fans are necessary (3 fans per cell). The licensee should list the design inputs, assumptions, and describe the methodology used. The conclusions of the design calculation should clearly justify the reduction in operable fan requirements.
The information requested and associated time frame in this letter were discussed with Mr. W. Steelman of your staff on 11/8/11.
If you have any questions regarding this letter, please to contact me at 301-415-1480 or via email at kaly.kalyanam@nrc.gov..
Sincerely,