ML22215A206
| ML22215A206 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/03/2022 |
| From: | James Drake NRC/NRR/DORL/LPL4 |
| To: | Lewis J Entergy Nuclear Operations |
| References | |
| L-2020-LLA-0279 | |
| Download: ML22215A206 (3) | |
Text
From:
Drake, Jason Sent:
Wednesday, August 3, 2022 9:36 AM To:
Lewis, John Cc:
Mackaman, Clyde D; Couture III, Philip; Mahan, Cecil; HARRIS, ALAN J; Gaston, Ronald William; Pyle, Stephenie; Cole, Joseph; Dixon-Herrity, Jennifer; Suber, Gregory; Wengert, Thomas
Subject:
Waterford 3 - LAR to Adopt Title 10 of the Code of Federal Regulations, Section 50.69: LOE and Completion Date Update (EPID: L-2020-LLA-0279)
- John, By letter W3F1-2020-0047 dated December 18, 2020 (ML20353A433), Entergy Operations, Inc.
(Entergy) requested a license amendment to Renewed Facility Operating License No. NPF-38 for the Waterford Steam Electric Station, Unit 3. Entergy requested to adopt Title 10 of the Code of Federal Regulations, Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors, into its licensing basis. The U.S. Nuclear Regulatory Commission (NRC) staff performs acceptance reviews of applications to determine if the scope and depth of technical information is sufficient for the staff to complete its technical reviews.
On January 28, 2021, the NRC provided its acceptance for review and estimated that it would take approximately 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> to complete its review of the application and that it will complete its review on or by January 18, 2022. Per the original acceptance email, it was indicated that the estimates could change because of several factors, such as requests for additional information (RAI), unanticipated addition of application scope, NRC advisory committee reviews, parallel reviews of industry program initiatives or pilot applications, or hearing-related activities.
In support of the NRC review, RAIs were issued on July 26, 2021, (ML21218A040) with a requested 30-day response period identified. In the NRC staffs bi-weekly status call with Entergy on throughout August and September of 2021 the NRC staff communicated to Entergy the potential delay in schedule for the subject LAR if responses were not received in a timely manner. Entergys RAI responses were ultimately received by the NRC on October 1, 2021 (ML21274A876), after Entergy cited several challenges which precluded them from providing RAI responses in a reasonable timeframe.
On January 6, 2022, the NRC sent an email (ML22209A105) to Entergy indicating that information requested in the October 2021 Technical Specification Change to Adopt Risk-Informed Extended Completion Times - [Risk-Informed Technical Specification Task Force]
(RITSTF) Initiative 4B, (TSTF-505 LAR) (ML21039A648) Regulatory Audit, specially pertaining to and impacting the review of the 10 CFR 50.69 LAR review was still not available in the Certrec portal. The information requested included the results of the 10 CFR 50.69 LAR peer review along with Entergys final decision on whether to use a plant high confidence of low probability of failure (HCLPF) of 0.15g and follow the Farley approach to calculate seismic large early release frequency (SLERF). It was further indicated at this time by the licensing project manager (PM) that the review would extend significantly beyond the 1-year metric. In subsequent conversations with Entergy during bi-weekly calls, the NRC identified that a final determination of a new target amendment issuance date would need to be deferred until Entergy could provide the information required to support the review.
After NRC review of the RAI responses and utilizing the available data from Entergys updated TSTF-505 LAR seismic analysis, the NRC determined that a relative contribution of seismic risk to the total plant risk challenged the NRCs ability to make a positive regulatory finding for the proposed Tier 1 alternative seismic approach for the 10 CFR 50.69 LAR. Consequently, the NRC held a clarification call with Entergy on January 18, 2022, to express concerns about the Tier 1 approach and as an alternative, cited Limerick as an example (ML21349B364), in which Entergy switched to a Tier 2 alternative seismic approach.
On January 20, 2022, the Waterford 3 Regulatory Assurance Manager contacted the NRC via email (ML22209A106), to identify that they would be moving forward in the development of a supplement for the 10 CFR 50.69 LAR to shift to a Tier 2 alternative seismic approach. The supplement was received on April 25, 2022 (ML22115A062).
This review is further complicated because it supports the TSTF-505 LAR review. For both the 10 CFR 50.69 LAR review and the TSTF-505 LAR review, an additional set of consolidated draft RAIs was sent on July 15, 2022 (ML22209A108). This set of consolidated RAIs seeks clarification from Entergy on how you intend to satisfy the open internal events probabilistic risk assessment (PRA) facts and observations (F&O). On July 20, 2022, Entergy requested a clarification call to be held on July 21, 2022, for the subject RAIs. Final RAIs were sent to Entergy on July 22, 2022 (ML22206A017).
With respect to the additional factors noted above, and per verbal notice and agreement with Entergy, the NRC estimates the review will take an additional 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> (900 total) to complete and will be completed on or by October 31, 2022. This estimate assumes compliance with the 30-day requested response time following official RAI issuance. If there are emergent complexities or challenges associated with the review of the 10 CFR 50.69 LAR that would result in additional changes to the October 31, 2022, milestone schedule, the reasons for the changes, along with a revised milestone schedule, will be communicated to Entergy during routine interactions with the licensing PM.
If you have any questions, please contact me at (301) 415-8378 or Jason.Drake@nrc.gov.
- Regards, Jason Drake Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Phone: (301) 415-8378
Hearing Identifier:
NRR_DRMA Email Number:
1742 Mail Envelope Properties (MN2PR09MB5610D7831530FED4942481F2FB9C9)
Subject:
Waterford 3 - LAR to Adopt Title 10 of the Code of Federal Regulations, Section 50.69: LOE and Completion Date Update (EPID: L-2020-LLA-0279)
Sent Date:
8/3/2022 9:36:26 AM Received Date:
8/3/2022 9:36:00 AM From:
Drake, Jason Created By:
Jason.Drake@nrc.gov Recipients:
"Mackaman, Clyde D" <cmackam@entergy.com>
Tracking Status: None "Couture III, Philip" <pcoutur@entergy.com>
Tracking Status: None "Mahan, Cecil" <cmahan@entergy.com>
Tracking Status: None "HARRIS, ALAN J" <aharris@entergy.com>
Tracking Status: None "Gaston, Ronald William" <rgasto1@entergy.com>
Tracking Status: None "Pyle, Stephenie" <SPYLE@entergy.com>
Tracking Status: None "Cole, Joseph" <jcole5@entergy.com>
Tracking Status: None "Dixon-Herrity, Jennifer" <Jennifer.Dixon-Herrity@nrc.gov>
Tracking Status: None "Suber, Gregory" <Gregory.Suber@nrc.gov>
Tracking Status: None "Wengert, Thomas" <Thomas.Wengert@nrc.gov>
Tracking Status: None "Lewis, John" <jlewis8@entergy.com>
Tracking Status: None Post Office:
MN2PR09MB5610.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 5506 8/3/2022 9:36:00 AM Options Priority:
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