ML070710563
| ML070710563 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/20/2007 |
| From: | Dyer J Office of Nuclear Reactor Regulation |
| To: | Walsh K Entergy Operations |
| Fields, M B, NRR/DORL/LPL4, 415-3062 | |
| References | |
| TAC MD4196, NRR-07-006 | |
| Download: ML070710563 (5) | |
Text
March 20, 2007 CAL No. NRR-07-006 Mr. Kevin T. Walsh Vice President of Operations Entergy Operations, Inc.
17265 River Road Kilona, LA 70057-3093
SUBJECT:
CONFIRMATORY ACTION LETTER - WATERFORD STEAM ELECTRIC STATION, UNIT 3 (TAC NO. MD4196)
Dear Mr. Walsh:
This letter confirms commitments by Entergy Operations, Inc., regarding Alloy 82/182 butt welds in the pressurizer at the Waterford Steam Electric Station, Unit 3.
The discovery, in October 2006, of five circumferential indications in three dissimilar metal (DM) welds on the pressurizer at the Wolf Creek Generating Station (Wolf Creek) raised safety concerns based on the size and location of the indications. At Wolf Creek, three indications were in the pressurizer surge nozzle-to-safe end weld, and two separate indications were in the safety and relief nozzle-to-safe end welds. These findings also indicated that significant concerns might exist with the inspection schedules for addressing the pressurizer weld concerns issued by the industry-sponsored Materials Reliability Program (MRP), in Primary System Piping Butt Weld Inspection and Evaluation Guideline (MRP-139).
The Nuclear Regulatory Commission (NRC) is concerned about the pressurizer surge nozzle-to-safe end weld indications, as this is the first time that multiple circumferential primary water stress-corrosion cracking (PWSCC) indications have been identified in a weld. This condition calls into question the degree of safety margin present in past structural integrity evaluations for flawed DM welds susceptible to PWSCC, since multiple stress-corrosion cracking flaws may grow independently and ultimately grow together, significantly reducing the time from flaw initiation to leakage or rupture. The size of the relief nozzle-to-safe end flaw is also of concern, as this flaw has a much larger aspect ratio than those assumed in the estimates used to establish the basis for completing the baseline inspections required by the industry-sponsored MRP. Larger aspect ratios could result in achieving a critical flaw size and rupture before the onset of detectable leakage.
The long-term resolution of this issue is expected to involve changes to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), and will involve changes to the NRC regulations in Title 10 of the Code of Federal Regulations (10 CFR),
Part 50, Section 50.55a, Codes and standards. The development of the NRC regulations, whether the rule adopts the ASME Code standards or defines separate requirements, will likely benefit from additional operating experience, continuing assessments, and analysis being conducted by the NRC and the MRP.
K. Walsh Until NRC regulations are revised, it is necessary to establish a minimum set of enhanced reactor coolant system (RCS) DM butt weld inspection expectations for nickel-based Alloy 82/182 pressurizer surge, spray, safety, and relief nozzle butt welds, including safe end welds, to supplement existing inspection and other requirements of the ASME Code and NRC regulations. In addition, enhanced monitoring of RCS leakage is needed to promptly identify any through-wall flaws in the pressurizer surge, spray, safety, or relief nozzle DM butt welds or safe end DM butt welds to prevent additional degradation from occurring. The above actions provide reasonable assurance that there is no undue risk to the health and safety of the public while the NRC regulations are revised.
The NRC communicated the need for near-term enhancements to the industry through public meetings held on November 30, 2006, December 20, 2006, and February 2, 2007. Licensees submitted letters voluntarily committing to the enhanced inspection and leakage monitoring requirements. After teleconferences with specific licensees held between February 12 through February 23, 2007, the licensees submitted supplemental commitment letters addressing the NRC staffs concerns regarding inspection, compensatory actions, and reporting.
In your letter dated February 21, 2007, (Agencywide Documents Access and Management System (ADAMS) ML070590205) you described actions you will take at the Waterford Steam Electric Station Unit 3 for the pressurizer dissimilar metal butt welds containing Alloy 82/182 material. These commitments address: 1) completion schedules for inspection/mitigation of the welds; 2) RCS leak monitoring frequency, action levels, and actions; and 3) reporting requirements.
The NRC has reviewed these actions and commitments and agrees the actions and commitments are appropriate to address the potential of PWSCC of the applicable pressurizer dissimilar metal butt welds containing Alloy 82/182 material with the following clarification regarding RCS leak monitoring on two of the commitments as indicated in bold below.
- Entergy will inform the NRC in writing prior to revising any of the committed actions identified in Enclosure 2.
- Should the leakage return to within limits or be confirmed to be from a source other than the pressurizer DM butt welds and when quantified (as identified leakage), results in unidentified leakage below the limits, then the shutdown actions may be halted and a return to normal operating conditions may commence.
This clarification was discussed with and agreed upon during a telephone discussion on Wednesday March 14, 2007, between you and William Bateman, Deputy Director, Division of of Component Integrity.
Pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232, you are required to:
- 1) Notify me immediately if your understanding differs from that set forth above;
- 2) Notify me if for any reason you cannot complete the actions and commitments within the specified schedule and advise me in writing of your modified schedule in advance of the change; and
K. Walsh 3) Notify me in writing when you have completed the actions and commitments addressed in this Confirmatory Action Letter.
Issuance of this Confirmatory Action Letter does not preclude issuance of an order formalizing the above commitments or requiring other actions on the part of the licensee; nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in this Confirmatory Action Letter may result in enforcement action.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs ADAMS, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Sincerely,
/RA/
J. E. Dyer, Director Office of Nuclear Reactor Regulation Docket No. 50-382 License No. NPF-38 cc: See next page
ML070710563 NRR-106 *previously concurred OFFICE CPNB DCI LPL4/PM LPL4/LA LPL4/BC TECH ED DIRS/TA NAME TLupold TSullivan MFields:sp LFeizollahi* DTerao HChang RPascarelli DATE 3/16/07 3/16/07 3/14/07 3/13/07 3/14/07 2/28/07 3/19/07 OFFICE CPNB/BC DRP/D RGN 4 DORL/D DCI/D AD:DES NRR/D NAME TChan AHowell CHaney MEvans JGrobe JDyer DATE 3/16/07 3/16/07 3/19/07 3/16/07 3/20/07 3/20/07 Waterford Steam Electric Station, Unit 3 cc:
Vice President, Operations Support Director, Nuclear Safety & Licensing Entergy Operations, Inc. Entergy Operations, Inc.
P.O. Box 31995 1340 Echelon Parkway Jackson, MS 39286-1995 Jackson, MS 39213-8298 Director Louisiana Department of Environmental Nuclear Safety Assurance Quality Radiological Emergency Planning Entergy Operations, Inc. and Response Division 17265 River Road P.O. Box 4312 Killona, LA 70057-3093 Baton Rouge, LA 70821-4312 General Manager Plant Operations Louisiana Department of Environmental Waterford 3 SES Quality Entergy Operations, Inc. Office of Environmental Compliance 17265 River Road P.O. Box 4312 Killona, LA 70057-3093 Baton Rouge, LA 70821-4312 Manager, Licensing Chairman Entergy Operations, Inc. Louisiana Public Services Commission 17265 River Road P.O. Box 91154 Killona, LA 70057-3093 Baton Rouge, LA 70825-1697 Resident Inspector/Waterford NPS Richard Penrod, Senior Environmental P.O. Box 822 Scientist/State Liaison Officer Killona, LA 70066-0751 Office of Environmental Services Northwestern State University Regional Administrator, Region IV Russell Hall, Room 201 U.S. Nuclear Regulatory Commission Natchitoches, LA 71497 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Parish President Council St. Charles Parish P.O. Box 302 Hahnville, LA 70057 Executive Vice President &
Chief Operating Officer Entergy Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995 November 2006