ML120680053

Email, Issues Related to 10 CFR 50.59 Evaluation - License Amendment Request, Revise Technical Specification Applicability and Action Language for Revised Fuel Handling Accident Analysis

ML120680053
Person / Time
Site:	Waterford
Issue date:	02/22/2012
From:	Steelman W Entergy Operations
To:	Benton L, Kalyanam K Office of Nuclear Reactor Regulation
Kalyanam N, NRR/DORL/LPL4, 415-1480
References
TAC ME6049
Download: ML120680053 (5)

Text

From: STEELMAN, WILLIAM J [wsteelm@entergy.com]

Sent: Wednesday, February 22, 2012 3:27 PM To: Kalyanam, Kaly; Benton, Laray

Subject:

RE: ISSUES Related to Waterford 3 LAR, TAC No. ME6049 Attachments: NRC FHA Question 2-22-12.pdf Mr. Benton This is a follow up to the voice message that I left today. I have provided a writeup to address your question below. I would like to discuss the information to ensure that I have answered your question and addressed you concern.

Thanks Billy Steelman Waterford 3 504-273-3824 From: Kalyanam, Kaly [1]

Sent: Wednesday, February 15, 2012 1:46 PM To: STEELMAN, WILLIAM J

Subject:

FW: ISSUES Related to Waterford 3 LAR, TAC No. ME6049 Importance: High

Billy, Could you please have the 50.59 evaluation, mentioned below, sent to the staff for review?

Thanks Kaly From: Benton, Laray Sent: Wednesday, February 15, 2012 1:55 PM To: Kalyanam, Kaly

Subject:

RE: ISSUES Related to Waterford 3 LAR, TAC No. ME6049 Importance: High

Kaly, AADB staff would like to review the 10 CFR 50.59 evaluation that the licensee conducted that supports the indicated change to Waterfords current AOR for an postulated FHA. The reason for our request is because AADB cannot conduct a confirmatory analysis based on the currently docketed information available. Whereas if the AST was still the current AOR, I could have simply compared the licensees proposed changes against the docketed values provided in their AST amendment. However, being that their current AOR is no longer the AST analyses, but is now based on the AOR resulting from their change supported by their indicated 10 CFR 50.59 evaluation, I dont actually have any reference values to compare the proposed change against.

Therefore, I cant make a reasonable assurance finding on this LAR without reviewing the 10 CFR 50.59 evaluation to verify what the reference values for the current FHA AOR actually are.

Please let me know if you have any questions, comments, and/or concerns.

I have already forgiven you for your transgressions against me.

LaRay J. Benton United States Nuclear Regulatory Commission (NRC)

Office of Nuclear Reactor Regulation Division of Risk Assessment Accident Dose Branch (AADB)

(301) 415-1088 From: Kalyanam, Kaly Sent: Monday, January 30, 2012 9:01 AM To: Benton, Laray Cc: STEELMAN, WILLIAM J

Subject:

RE: ISSUES Related to Waterford 3 LAR, TAC No. ME6049 Thanks, Billy, for the fast response.

Laray, Please see below the licensees response. Let me know if there is any followup question and we can talk with the licensee.

Thanks Kaly From: STEELMAN, WILLIAM J [2]

Sent: Monday, January 30, 2012 8:56 AM To: Kalyanam, Kaly

Subject:

RE: ISSUES Related to Waterford 3 LAR, TAC No. ME6049 Kaly The differences between the Analysis of Record (AOR) and the original Alternate Source Term (AST) Safety Evaluation Report (SER) approved on 3/29/05 is since that time we have identified issues with the calculation, entered those into our corrective action program, and addressed them under the 10CFR50.59 process.

The criterion to evaluate whether NRC approval is required in the 10CFR50.59 process would be:

10CFR50.59(c)(2)(iii) Result in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report (as updated).

Since the difference between the AST SER and the AOR is a reduction (not an increase), it passes 10CFR50.59 criterion and does not require NRC approval.

Our submittal W3F1-2010-0009 identified the increase fuel failure does exceed the 10% criteria. Our submittal W3F1-2010-0009 Attachment 1 page 3 does ask for NRC approval of that change.

Thanks Billy From: Kalyanam, Kaly [3]

Sent: Thursday, January 26, 2012 11:07 AM To: STEELMAN, WILLIAM J

Subject:

FW: ISSUES Related to Waterford 3 LAR, TAC No. ME6049 Importance: High

Billy, Can you have your engineers provide an answer?

Thanks Kaly From: Benton, Laray Sent: Thursday, January 26, 2012 12:01 PM To: Kalyanam, Kaly

Subject:

ISSUES Related to Waterford 3 LAR, TAC No. ME6049 Importance: High Kaly are you currently available for a discussion about this LAR. I have a general clarification question that I may have to ask the licensee if you are not able to answer it for me. Please consider the following:

In evaluating the licensees updated postulated FHA radiological dose consequences results, AADB staff used the following table as a comparison:

The concern that AADB will need for either you or the licensee to clarify is why is the ere an apparent difference between the doc cketed and/or submitted EAB, LPZ, and CR dose e values for the, 1) Baseline analysis of record (AAOR) as submitted in the LAR; 2) AST dose valu ues as document in Waterfords issued AST T amendment; and 3) Dose values as docketed in n the Waterford FSAR.

Can you or the licensee please explain the reason for the differences?

Baseline AOR (0.105 rem TEDE) and AST (0.10 Specifically, the CR values for the B 09 rem TEDE) exhibit more than a 10% diffference between the two values. Was there anotther license amendment that was approved betw ween when the AST amendment was issued until now that can document the change in values?  ?

I think that both of these above state ed questions can be resolve with a simple telecon nference with the licensee, but we can send a formal RAI if desired. Thanks.

LaRay J. Benton Nuclear Physicist / Reactor Enginee er United States Nuclear Regulatory Commission (NRC)

Office of Nuclear Reactor Regulation n Division of Risk Assessment Accident Dose Branch (AADB)

(301) 415-1088 From: Kalyanam, Kaly Sent: Monday, January 23, 2012 11:24 4 AM To: Wu, Shih-Liang; Hopkins, Ogbonna; Raval, Janak; Wood, Kent; Benton, Laray; Mazumdaar, Subinoy; Som, Swagata; Groves, Michael

Cc: Kalyanam, Kaly

Subject:

Waterford 3 LAR, TAC No. ME6049 Hi, This is regarding the Waterford 3 License Amendment Request to Revise the Technical Specifications Based Upon Revised Fuel Handling Accident (TAC No. ME6049) submitted by application dated April 13, 2011.

In order to meet the 1-year metrics, DORL staff needs all the SEs by March 20, 2012. I notice from the WPC records that the primary reviewers are: Shih-Liang Wu (SNPB),

Ogbonna Hopkins (SBPB), Janaki Raval (SCVB), Kent Wood (SRXB/SFT), and LaRay J. Benton (AADB). I presume that the review is on schedule and the SEs will be sent by 3/20/12.

The WPC records also indicated that that EICB (Subinoy Mazumdar), EEEB (Swagata Som), and ESTB (Ravinder Grover) will be concurring in the Amendment Package and, therefore, I do not expect any input from these 3 Branches. I will forward the Package, once put together, for parallel concurrence.

Thanks.

Kaly