ML22144A006

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Revision to the Reactor Vessel Material Surveillance Capsule Withdrawal Schedule
ML22144A006
Person / Time
Site: Waterford Entergy icon.png
Issue date: 05/24/2022
From: James Drake
Plant Licensing Branch IV
To:
Entergy Operations
Wengert T
References
EPID L-2022-LLL-0009
Download: ML22144A006 (5)


Text

May 24, 2022

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 - REVISION TO THE REACTOR VESSEL MATERIAL SURVEILLANCE CAPSULE WITHDRAWAL SCHEDULE (EPID L-2022-LLL-0009)

Dear Sir or Madam:

By letter dated April 25, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22115A255), Entergy Operations, Inc., ( Entergy, the licensee) requested revision of the reactor vessel material surveillance capsule withdrawal schedule for the Waterford Steam Electric Station (Waterford), Unit 3, in ac cordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H, Reactor Vessel Material Surveill ance Program Requirements,Section III.B.3. The licensee stated that the reason for the requested revision was to reflect the current locations of the capsules f ollowing a relocation attempt performed during refueling outage 24 (RF24).

The U.S. Nuclear Regulatory Commission (NRC) staff has complete d its review of Entergys submittal, as documented in the enclosed safety evaluation. The NRC staff concludes that Entergy has provided the information required by the regulations and that no additional follow-up is required at this time. This completes the NRC staffs eff orts for Enterprise Project Identifier (EPID) L-2022-LLL-0009.

If you have any questions, please contact me at 301-415-8378 or via email at Jason.Drake@nrc.gov.

Sincerely,

Jason J. Drake, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-382

Enclosure:

Safety Evaluation

cc: Listserv SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

REQUEST FOR REVISED REACTOR VESSEL

SURVEILLANCE CAPSULE LOCATION AND WITHDRAWAL

ENTERGY OPERATIONS, INC

WATERFORD STEAM ELECTRIC STATION, UNIT 3

DOCKET NO. 50-382

1.0 INTRODUCTION

By letter dated April 25, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22115A255), Entergy Operations, Inc., ( Entergy, the licensee) requested revision of the reactor vessel material surveillance capsule withdrawal schedule for the Waterford Steam Electric Station (Waterford), Unit 3, in ac cordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H, Reactor Vessel Material Surveill ance Program Requirements,Section III.B.3.

Specifically, the licensee proposed a revision of the reactor v essel material surveillance capsule withdrawal schedule to reflect the current locations of the capsules following a relocation attempt performed during refueling outage 24 (RF24). During Waterford, Unit 3s planned attempt to relocate capsules 3/W-104 and 6/W-284 during RF24, the licensee determined that it was not possible to reinsert capsule 3/W-104 into the proposed location due to the physical configuration of the capsule combined with access limitations due to the insertion angle. The licensee elected to discontinue the relocation attempt and exec ute a contingency to store capsule 3/W-104 in the spent fuel pool for potential reinsertion during a future refueling outage.

The licensee stated that no attempt was made to relocate capsule 6/W-284; therefore, it remains in its original location in the reactor vessel.

2.0 REGULATORY EVALUATION

The regulations and guidance pertinent to this request include:

Section I of appendix H to 10 CFR Part 50 states, in part:

The purpose of the [reactor vessel] material surveillance program required by this appendix is to monitor changes in the fracture toughness properties of ferritic materials in the reactor vessel beltline region of light water nuclear power reactors which result from exposure of these materials to neutron irradiation and the thermal environment. Under the program, fracture toughness test data are

Enclosure

obtained from material specimens exposed in surveillance capsul es, which are withdrawn periodically from the reactor vessel.

Section III(B)(1) of appendix H to 10 CFR Part 50 states, in pa rt:

The design of the surveillance program and the withdrawal sched ule must meet the requirements of the edition of ASTM E 185 [an industry stan dard by ASTM International, formerly known as American Society for Testing and Materials] that is current on the issue date of the ASME code to which the reac tor vessel was purchased;... later editions of ASTM E 185 may be used, but including only those editions through 1982.

Section III(B)(3) of appendix H to 10 CFR Part 50 states:

A proposed withdrawal schedule must be submitted with a technic al justification as specified in [10 CFR 50.4]. The proposed schedule must be approved prior to implementation.

Administrative Letter 97-04, NRC [U.S. Nuclear Regulatory Comm ission] Staff Approval for Changes to 10 CFR Part 50, Appendix H, Reactor Vessel Surveillance Specimen Withdrawal Schedules, dated September 30, 1997, which states, in part:

The Commission found that while 10 CFR Part 50, Appendix H, II. B.3 requires prior NRC approval for all withdrawal schedule changes, only ce rtain changes require license amendments as the process to be followed for such approval.

Specifically, those changes that do not conform to the ASTM standard referenced in Appendix H (ASTM E-185, Standard Practice for Con ducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels) will require approval by the license amendment process, whereas chan ges that conform to the ASTM standard require only staff verification of such conformance.

3.0 NRC STAFF EVALUATION

3.1 Licensees Proposal for Waterford, Unit 3

In its submittal for Waterford, Unit 3, dated April 25, 2022, t he licensee stated that it had attempted to relocate capsule 3/W-104 from its original location to another location in the reactor vessel without success during refueling outage RF24. As an alternative, the licensee elected to store capsule 3/W-104 in the spent fuel pool on a co ntingency basis. In addition, the licensee stated that it did not attempt to relocate capsule 6/W -284 during RF24; therefore, it remains in its original location in the reactor vessel. As reflected in Attachment 2 of the licensees submittal, the lead factor for these capsules will be restored to 0.83 from 1.02, which was approved in an NRC letter to Waterford, Unit 3, dated March 15, 2022 (ML22061A217).

The licensee also proposed associated changes to table 5.3-10 of the Waterford, Unit 3 Updated Final Safety Analysis Report (UFSAR).

3.2 NRC Staff Review

The NRC staff reviewed the licensees information against 10 CFR Part 50, appendix H and ASTM E185-82, as described in Administrative Letter 97-04. The NRC staff noted that both

subject capsules will continue to be standby capsules. These ca psules are not scheduled for withdrawal as part of the surveillance program for the current license period at Waterford, Unit 3.

The NRC staff verified that the proposed changes are consistent with the requirements of 10 CFR Part 50, appendix H and the recommendations of ASTM E185-82. In addition, the NRC staff finds that the proposed changes are acceptable because th e changes do not amend the surveillance activities supporting implementation of ASTM E185-82 for the current license period.

4.0 CONCLUSION

Based on the above evaluation, the NRC staff concludes that the revised surveillance capsule withdrawal schedule for capsules 3/W-104 and 6/W-284 for Waterf ord, Unit 3 is acceptable.

Therefore, the NRC staff approves this revised surveillance cap sule withdrawal schedule.

The NRC does not make any conclusion regarding future use of th e subject capsules in potential future applications or license periods.

Principal Contributors: J. Tsao, NRR, D.Widrevitz,NRR J.Drake,NRR

Date: May 24, 2022

ML22144A006 *by email OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DNRL/NVIB/BC*

NAME JDrake (TWengert for) PBlechman ABuford DATE 5/23/2022 5/23/2022 5/23/2022 OFFICE NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*

NAME JDixon-Herrity (WOrders for) JDrake DATE 5/24/2022 5/24/2022