ML18262A041

Request for Additional Information Regarding License Amendment Request to Revise Section 15.4.3.1 of the Waterford 3 Updated Final Safety Analysis Report to Account for Fuel Misload

ML18262A041
Person / Time
Site:	Waterford
Issue date:	09/25/2018
From:	Pulvirenti A L Plant Licensing Branch IV
To:	Entergy Operations
Pulvirenti A L, 415-1390
References
EPID L-2018-LLA-0058
Download: ML18262A041 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 25, 2018 Site Vice President 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 REGARDING LICENSE AMENDMENT REQUEST TO REVISE SECTION 15.4.3.1 OF THE WATERFORD 3 UPDATED FINAL SAFETY ANALYSIS REPORT TO ACCOUNT FOR FUEL MISLOAD (EPID L-2018-LLA-0058)

Dear Sir or Madam:

By letter dated March 8, 2018 (Agencywide Documents Access and Management System Accession No. ML 18068A705), Entergy Operations, Inc. (the licensee) submitted a license amendment request (LAR), which proposed changes to the Fuel Assembly Mislead Event analysis as described in Section 15.4.3.1 of the Waterford Steam Electric Station, Unit 3 (Waterford

3) Updated Final Safety Analysis Report (UFSAR). Specifically, the license amendment would revise the Waterford 3 UFSAR, Section 15.4.3.1, to update the results for an inadvertent loading of a fuel assembly into the improper position.

After reviewing the licensee's submittal, the U.S. Nuclear Regulatory Commission staff has determined that additional information is required to complete the review. The additional information needed to complete the review is delineated in the enclosure to this letter. A response is requested within 30 days of the date of this letter. If you have any questions, please contact me at 301-415-1390 or via e-mail at April.Pulvirenti@nrc.gov.

Docket No. 50-382

Enclosure:

Request for Additional Information cc: Listserv Sincerely, April L. Pulvirenti, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO REVISE UFSAR SECTION 15.4.3.1 ENTERGY OPERATIONS, INC. WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382 By letter dated March 8, 2018 (Agencywide Documents Access and Management System Accession No. ML 18068A705), Entergy Operations, Inc. (the licensee) submitted a license amendment request (LAR), which proposed changes to the Fuel Assembly Mislead Event analysis as described in Section 15.4.3.1 of the Waterford Steam Electric Station, Unit 3 (Waterford

3) Updated Final Safety Analysis Report (UFSAR). The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the application and determined that additional information, delineated below, is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment.

The regulatory basis for the following two questions is to allow the NRC staff to evaluate compliance with applicable dose limits in Title 10 of the Code of Federal Regulations ( 1 O CFR) Section 50.67, "Accident source term." The NRC staff's evaluation of compliance with 1 O CFR 50.67 depends upon ( 1) the number of fuel pins postulated to fail as the result of a design-basis misleading event (Question

1) and (2) the threshold at which fuel damage is postulated to occur (Question 2). Request for Additional Information (RAil 1 Section 3.1, "Selecting the Worst Undetectable Mislead," of the LAR indicates that an initial survey of a large number of potential misleads from several representative and potential future loading patterns is performed by comparing assembly reactivity, peaking factors, and proximity to incore detectors to determine several potential candidates for the worst undetectable misload. All candidates from this initial survey are then explicitly analyzed.

Please explain (or reference an approved methodology that explains) how candidates for the worst undetectable mislead event may be reliably identified from the vast number of possibilities.

If the specific methodology used has not been previously approved by the NRC staff, then expand upon and further justify the method used to identify the candidates for the worst undetectable fuel mislead. RAl2 Section 3.2, "Determining Fuel Pin Failure," of the LAR states, in part: The amount of fuel failure that occurs as a direct result of DNB [departure from nucleate boiling] is determined by counting the number of fuel rods that have a power greater than the radial peaking factor that is greater than the CECOR Enclosure measured value by an amount corresponding to a decrease in OPM [overpower margin] equivalent to the ROPM [required overpower margin] (as determined by CETOP). Please clearly restate or explain the above quotation.

In particular, the phrase "that have a power greater than the radial peaking factor that is greater than the CECOR measured value" compares a rod power to a radial peaking factor, makes consecutive "greater than" comparisons, and discusses "CECOR measured values" in the context of candidate misleads that could derive from several representative and "potential future loading patterns." As such, the meaning of the above statement cannot reasonably be inferred from the information available to the NRC staff.

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3-REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO REVISE SECTION 15.4.3.1 OF THE WATERFORD 3 UPDATED FINAL SAFETY ANALYSIS REPORT TO ACCOUNT FOR FUEL MISLOAD (EPID L-2018-LLA-0058)

DATED SEPTEMBER 25, 2018 DISTRIBUTION:

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NAME APulvirenti PBlechman Rlukes (RAnzalone for) DATE 9/21/2018 9/21/2018 8/24/2018 OFFICE NRR/DSS/SRXB/BC*

NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME JWhitman RPascarelli (TWengert for) APulvirenti DATE 9/21/2018 9/25/18 9/25/18 OFFICIAL RECORD COPY d