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MONTHYEARW3F1-2010-0003, License Amendment Request for Approval of Leak-Before-Break of the Pressurizer Surge Line2010-02-22022 February 2010 License Amendment Request for Approval of Leak-Before-Break of the Pressurizer Surge Line Project stage: Request ML1005506072010-02-28028 February 2010 WCAP-17187-NP, Technical Justification for Eliminating Pressurizer Surge Line Rupture as the Structural Design Basis for Waterford Steam Electric Station, Unit 3 Using Leak-Before-Break Methodology, Enclosure 2 to W3F1-2010-0003 Project stage: Request ML1007802812010-03-19019 March 2010 Acceptance Review Email, License Amendment Request for Approval of Leak-Before-Break of the Pressurizer Surge Line Project stage: Acceptance Review ML1011106352010-04-21021 April 2010 RAI, License Amendment Request, Approval of Final Safety Analysis Report Change for Leak-Before-Break of the Pressurizer Surge Line Project stage: RAI ML1011106472010-05-0303 May 2010 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance W3F1-2010-0064, Response to NRC Requests for Additional Information Regarding License Amendment Request for Leak-Before-Break of the Pressurizer Surge Line2010-08-12012 August 2010 Response to NRC Requests for Additional Information Regarding License Amendment Request for Leak-Before-Break of the Pressurizer Surge Line Project stage: Response to RAI ML1030000702010-10-27027 October 2010 Request for Information, Round 2, License Amendment Request to Approve FSAR Change for Leak-Before-Break of the Pressurizer Surge Line Project stage: RAI ML1029904062010-10-27027 October 2010 Notice of Meeting with Entergy Operations, Inc. to Discuss Request for Additional Information for Waterford Unit 3 License Amendment Request to Approve FSAR Change for Leak-Before-Break of Pressurizer Surge Line Project stage: RAI ML1030101052010-10-27027 October 2010 Correction 11/10/10 Meeting Notice with Entergy Operations, Inc. to Discuss Request for Additional Information for Waterford Unit 3 License Amendment Request to Approve FSAR Change for Leak-Before-Break of the Pressurizer Surge Line Project stage: RAI ML1030600782010-10-27027 October 2010 Corrected Notice of Meeting with Entergy Operations, Inc. to Discuss Request for Additional Information for Waterford Unit 3 License Amendment Request to Approve FSAR Change for Leak-Before-Break of the Pressurizer Surge Line Project stage: RAI ML1031403752010-11-10010 November 2010 Handouts for the 11/10/10 Meeting Regarding Surge Line Leak-Before Break RCS Leakage Detection Project stage: Request ML1031904162010-11-17017 November 2010 Summary of Meeting with Entergy Operations, Inc. to Discuss Request for Additional Information for Waterford Unit 3 License Amendment Request to Approve FSAR Change for Leak-Before-Break of the Pressurizer Surge Line Project stage: RAI W3F1-2010-0083, Supplemental Response to NRC Requests for Additional Information Regarding License Amendment Request for Leak-Before-Break of the Pressurizer Surge Line2010-11-23023 November 2010 Supplemental Response to NRC Requests for Additional Information Regarding License Amendment Request for Leak-Before-Break of the Pressurizer Surge Line Project stage: Supplement ML1034806322010-12-14014 December 2010 Email, Request for Information, Round 3, License Amendment Request to Approve FSAR Change for Leak-Before-Break of the Pressurizer Surge Line Project stage: RAI W3F1-2010-0087, Additional Responses to NRC Requests for Additional Information Regarding License Amendment Request for Leak-Before-Break of the Pressurizer Surge Line2010-12-21021 December 2010 Additional Responses to NRC Requests for Additional Information Regarding License Amendment Request for Leak-Before-Break of the Pressurizer Surge Line Project stage: Response to RAI W3F1-2011-0007, Transmittal of Proprietary EPRI Report MRP-1092011-01-24024 January 2011 Transmittal of Proprietary EPRI Report MRP-109 Project stage: Request ML1103504212011-02-18018 February 2011 Request for Withholding Information from Public Disclosure - Affidavit Executed by C. King, Electric Power Research Institute on 12/17/10; 04/05 MRP-109, Alloy 82/182 Pipe Butt Weld Safety Assessment for U.S. PWR Plant Designs Project stage: Withholding Request Acceptance ML1104101192011-02-28028 February 2011 Issuance of Amendment No. 232, Approval of Change to Final Safety Analysis Report for Leak-Before-Break of the Pressurizer Surge Line Project stage: Approval 2010-02-28
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Category:Meeting Briefing Package/Handouts
MONTHYEARML23348A3572023-12-14014 December 2023 Application to Revise Technical Specifications to Use Online Monitoring Methodology Slides and Affidavit for Pre-Submittal Meeting ML23296A1002023-10-24024 October 2023 Entergy Presentation Slides for Pre-Submittal Meeting on 10/24/23, Mtc LAR ML22271A7502022-09-29029 September 2022 Preapplication Meeting Slides: Technical Specification Change to Support Elimination of ESFAS Single Point Vulnerability ML22224A2462022-08-19019 August 2022 Entergy Slides for Regulatory Conference (Enc 3) ML22217A0082022-07-29029 July 2022 Regulatory Conference - NRC Slides (Enc 2) ML22076A1962022-03-17017 March 2022 Presentation March23, 2022 NRC Di_C Workshop ML21309A0622021-11-0909 November 2021 NRC Slides for November 9, 2021, Technology Inclusive Content of Application Project Public Meeting ML21312A0342021-11-0909 November 2021 Combined Slides for November 9, 2021, Technology Inclusive Content of Application Project Public Meeting ML21200A1792021-07-31031 July 2021 Scale/Melcor Non-LWR Source Term Demonstration Project - High Temperature Gas-Cooled Reactor ML21013A3362021-01-26026 January 2021 December 17, 2020, Summary of Category 1 Public Pre-Application Meeting with Entergy Operations,Inc. Regarding Proposed LAR to Adopt Risk-Informed TS Allowed Outage Times for Waterford Steam Electric Station, Unit 3 ML21013A3372020-12-17017 December 2020 Risk-Informed Allowed Outage Time (Riaot) License Amendment Request -NRC Pre-Submittal Meeting, Licensee Slide Presentation, December 17, 2020 EPID L-2020-LRM-0110 ML20344A0572020-12-10010 December 2020 Combined Industry and NRC Slides for the December 10, 2020, Public Meeting on Technology Inclusive Content of Application Project, Advanced Reactor Content of Application Project and Applicability of Regulations to Non-Light Water Reactors ML20269A3452020-09-28028 September 2020 Pre-submittal Meeting for Request for One-Time Exemption from 10 CFR Part 50, Appendix E, Biennial EP Exercise (Offsite) Due to COVID-19- Entergy Presentation Slides ML20288A7292020-09-22022 September 2020 Presentation Cpc/Ceac Replacement License Amendment Request - September 22, 2020 W3F1-2020-0017, Transmittal of Slides for Fourth Partially Closed Pre-submittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification2020-03-12012 March 2020 Transmittal of Slides for Fourth Partially Closed Pre-submittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification W3F1-2019-0082, Transmittal of Slides for Second Partially Closed Presubmittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification2019-12-0505 December 2019 Transmittal of Slides for Second Partially Closed Presubmittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification W3F1-2019-0068, Transmittal of Slides for Presubmittal Public Meeting to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification2019-09-12012 September 2019 Transmittal of Slides for Presubmittal Public Meeting to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification ML18107A3342018-04-10010 April 2018 Tech Spec 3.3.5.2a Change Pre-Submittal Meeting Presentation Slides ML18037B1102018-02-0808 February 2018 Presentation Slides for February 8 2018 Preapplication Meeting to Discuss Chapter 15 Fuel Misload ML17290A6552017-10-19019 October 2017 Public Meeting, Licensee Presentation Slides Regarding Waterford, Unit 3, Fluence Methodology ML16190A0842016-06-0808 June 2016 Public Meeting, June 8, 2016 (Pmc Comments1) ML15222A3472015-08-11011 August 2015 Presentation for 8-11-15 Public Meeting on Main Control Room Abandonment ML15196A4152015-07-15015 July 2015 Summary of Meeting with Entergy Corporation to Discuss Annual Performance Assessment ML15113A7872015-04-22022 April 2015 CEA Drop Time Technical Specification Change Request April 22, 2015 Revised Public Meeting Slides ML15110A0622015-04-22022 April 2015 CEA Drop Time T.S. Change Request April 22,2015 Public Meeting Slides ML14035A0942014-02-0404 February 2014 2/4/2014 Waterford Steam Electric Station, Unit 3 - Meeting Slides - NFPA 805 LAR Supplement ML12275A5492012-10-0101 October 2012 Summary of Meeting with Entergy Operations, Inc., to Discuss the Performance of the Subject Facilities, Recent Organizational Changes, and Current Regulatory Issues ML12311A0492012-09-18018 September 2012 Part 26 Public Meeting NEI Presentation Slides ML12261A1962012-09-16016 September 2012 Summary of Meeting with Waterford Steam Electric Station to Discuss the Performance of the Waterford Steam Electric Station, Unit 3, for the Period of July 1, 2011 Through June 30, 2012 ML1129205202011-10-19019 October 2011 Regulatory Conference Summary ML1117906392011-06-28028 June 2011 Summary of Meeting with Entergy Operations Inc ML1110401532011-04-13013 April 2011 Licensee Slides from 4/13/11 Meeting with Entergy Operations, Inc., to Discuss Proposed National Fire Protection Programs Standards 805 License Amendment Submittal for Arkansas Nuclear One, Units 1 & 2 ML1031403752010-11-10010 November 2010 Handouts for the 11/10/10 Meeting Regarding Surge Line Leak-Before Break RCS Leakage Detection ML1014606312010-05-26026 May 2010 Summary of Public Meeting with Entergy Operations on Waterford Steam Electric Station Unit 3 2009 Performance ML1006903722010-03-0808 March 2010 Licensee Slides from 3/8/2010 Meeting Generic Letter 2004-02 Response to RAIs ML0935201272009-12-18018 December 2009 Nrc/Entergy Operations, Inc., Management Meeting ML0821401432008-07-31031 July 2008 Summary of Public Meeting with Entergy on Waterford, Unit 3, 2007 Performance ML0805102512008-02-20020 February 2008 Summary of Meeting with Entergy Operations, Inc. Degraded Batwings Metal Support Structures for Tubes in Waterford 3's Steam Generators ML0729806702007-10-24024 October 2007 Meeting Presentation on GEH Chemical Effects Testing Update ML0729806642007-10-24024 October 2007 Meeting Presentation on Update on Generic Safety Issue 191 Plant Audits ML0726701082007-10-10010 October 2007 9/06/2007 Waterford Steam Electric Station, Unit No. 3 - Meeting Handouts ML0712005272007-04-30030 April 2007 Nrc/Entergy Operations, Inc. Management Meeting to Discuss the Performance of Arkansas Nuclear One, Cooper, Grand Gulf, River Bend and Waterford, Unit 3 ML0708706752007-03-22022 March 2007 Meeting Slides, Entergy Meeting with NRC, Topic: Waterford 3 Batwings ML0615000942006-05-30030 May 2006 Summary of Meeting with Entergy Operations Re Waterford Steam Electric Station, Unit 3, Annual Performance Assessment ML0610103332006-04-0505 April 2006 Slides Presented at April 6, 2006 Waterford 3 Meeting ML0427901372004-10-0404 October 2004 Meeting Summary for the September 29, 2004, Public Meeting to Discuss General Engineering Related Topics ML0323705292003-08-22022 August 2003 Summary of Nrc/Entergy Operations, Inc. Management Meeting ML0323201802003-08-14014 August 2003 8/14/03, EOI Will Discuss Its May 8, June 11, & July 1, 2003, Relaxation Requests from Nrc'S Vessel Head Inspection Order ML0310102992003-04-0101 April 2003 Enclosures to 04/01/2003 Waterford End-of-Cycle Meeting Summary. Includes Attendance List & Copy of Slides Presented ML0208107562002-03-19019 March 2002 Operator Licensing Workshop Meeting Summary 2023-12-14
[Table view] Category:Slides and Viewgraphs
MONTHYEARML23348A3572023-12-14014 December 2023 Application to Revise Technical Specifications to Use Online Monitoring Methodology Slides and Affidavit for Pre-Submittal Meeting ML23296A1002023-10-24024 October 2023 Entergy Presentation Slides for Pre-Submittal Meeting on 10/24/23, Mtc LAR ML23122A1012023-05-0202 May 2023 Assessment Presentation 2022 ML22271A7502022-09-29029 September 2022 Preapplication Meeting Slides: Technical Specification Change to Support Elimination of ESFAS Single Point Vulnerability ML22224A2462022-08-19019 August 2022 Entergy Slides for Regulatory Conference (Enc 3) ML22217A0082022-07-29029 July 2022 Regulatory Conference - NRC Slides (Enc 2) ML22164A8012022-06-13013 June 2022 Entergy Fleet (GGNS, RBS, and WF-3) - Code Case N-752 RR 6-14-22 Pre-Submittal Public Meeting Presentation Slides ML22076A1962022-03-17017 March 2022 Presentation March23, 2022 NRC Di_C Workshop ML21319A2452021-11-15015 November 2021 Natrium Energy Island Decoupling Strategy - 11-17-2021 ML21306A3162021-11-0909 November 2021 Digital IC Presentation 11/09/2021 ML21309A0622021-11-0909 November 2021 NRC Slides for November 9, 2021, Technology Inclusive Content of Application Project Public Meeting ML21312A0342021-11-0909 November 2021 Combined Slides for November 9, 2021, Technology Inclusive Content of Application Project Public Meeting ML21200A1792021-07-31031 July 2021 Scale/Melcor Non-LWR Source Term Demonstration Project - High Temperature Gas-Cooled Reactor ML21013A3362021-01-26026 January 2021 December 17, 2020, Summary of Category 1 Public Pre-Application Meeting with Entergy Operations,Inc. Regarding Proposed LAR to Adopt Risk-Informed TS Allowed Outage Times for Waterford Steam Electric Station, Unit 3 ML21012A1982021-01-15015 January 2021 Relocate Toxic Gas Monitoring Technical Specifications to Technical Requirements Manual License Amendment Request - NRC Pre-submittal Meeting ML21013A3372020-12-17017 December 2020 Risk-Informed Allowed Outage Time (Riaot) License Amendment Request -NRC Pre-Submittal Meeting, Licensee Slide Presentation, December 17, 2020 EPID L-2020-LRM-0110 ML20344A0572020-12-10010 December 2020 Combined Industry and NRC Slides for the December 10, 2020, Public Meeting on Technology Inclusive Content of Application Project, Advanced Reactor Content of Application Project and Applicability of Regulations to Non-Light Water Reactors ML20269A3452020-09-28028 September 2020 Pre-submittal Meeting for Request for One-Time Exemption from 10 CFR Part 50, Appendix E, Biennial EP Exercise (Offsite) Due to COVID-19- Entergy Presentation Slides ML20288A7292020-09-22022 September 2020 Presentation Cpc/Ceac Replacement License Amendment Request - September 22, 2020 W3F1-2020-0017, Transmittal of Slides for Fourth Partially Closed Pre-submittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification2020-03-12012 March 2020 Transmittal of Slides for Fourth Partially Closed Pre-submittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification W3F1-2020-0002, Transmittal of Slides for Third Partially Closed Presubmittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification2020-01-0808 January 2020 Transmittal of Slides for Third Partially Closed Presubmittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification W3F1-2019-0082, Transmittal of Slides for Second Partially Closed Presubmittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification2019-12-0505 December 2019 Transmittal of Slides for Second Partially Closed Presubmittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification W3F1-2019-0068, Transmittal of Slides for Presubmittal Public Meeting to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification2019-09-12012 September 2019 Transmittal of Slides for Presubmittal Public Meeting to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification ML18107A3342018-04-10010 April 2018 Tech Spec 3.3.5.2a Change Pre-Submittal Meeting Presentation Slides ML18075A1232018-03-20020 March 2018 Entergy Nuclear Operations - March 20, 2018, Presentation Slides for Surveillance Frequency Control Program, UFSAR Change Considerations ML18037B1102018-02-0808 February 2018 Presentation Slides for February 8 2018 Preapplication Meeting to Discuss Chapter 15 Fuel Misload ML17318A1232017-11-16016 November 2017 Licensee Presentation Slides for November 16, 2017, Category 1 Public Meeting Regarding Engineered Safety Features Actuation System ML17306A1652017-11-0202 November 2017 Updated Licensee Slide Presentation for October 19, 2017 Category 1 Meeting Regarding Raptor ML17290A6552017-10-19019 October 2017 Public Meeting, Licensee Presentation Slides Regarding Waterford, Unit 3, Fluence Methodology ML17158B1502017-06-0808 June 2017 Meeting Slides for High Pressure Safety Injection Pump AB Pre-submittal Public Meeting Relief Request Per 50.55a(Z)(2)for Waterford Steam Electric Station, Unit 3 ML17151A2952017-06-0101 June 2017 6/1/2017, Meeting Slide for Pre-Submittal Meeting Regarding Ultimate Heat Sink Technical Specification Change Request for Waterford 3 ML17101A6482017-04-11011 April 2017 Public Meeting Slides ML16190A0842016-06-0808 June 2016 Public Meeting, June 8, 2016 (Pmc Comments1) ML15222A3472015-08-11011 August 2015 Presentation for 8-11-15 Public Meeting on Main Control Room Abandonment ML15196A4152015-07-15015 July 2015 Summary of Meeting with Entergy Corporation to Discuss Annual Performance Assessment ML15113A7872015-04-22022 April 2015 CEA Drop Time Technical Specification Change Request April 22, 2015 Revised Public Meeting Slides ML15110A0622015-04-22022 April 2015 CEA Drop Time T.S. Change Request April 22,2015 Public Meeting Slides ML14035A0942014-02-0404 February 2014 2/4/2014 Waterford Steam Electric Station, Unit 3 - Meeting Slides - NFPA 805 LAR Supplement ML12275A5492012-10-0101 October 2012 Summary of Meeting with Entergy Operations, Inc., to Discuss the Performance of the Subject Facilities, Recent Organizational Changes, and Current Regulatory Issues ML12311A0492012-09-18018 September 2012 Part 26 Public Meeting NEI Presentation Slides ML12261A1962012-09-16016 September 2012 Summary of Meeting with Waterford Steam Electric Station to Discuss the Performance of the Waterford Steam Electric Station, Unit 3, for the Period of July 1, 2011 Through June 30, 2012 ML11321A2912011-11-17017 November 2011 Final Significance Determination of White Finding, NRC Inspection ML1110401532011-04-13013 April 2011 Licensee Slides from 4/13/11 Meeting with Entergy Operations, Inc., to Discuss Proposed National Fire Protection Programs Standards 805 License Amendment Submittal for Arkansas Nuclear One, Units 1 & 2 ML1031403752010-11-10010 November 2010 Handouts for the 11/10/10 Meeting Regarding Surge Line Leak-Before Break RCS Leakage Detection ML1014606312010-05-26026 May 2010 Summary of Public Meeting with Entergy Operations on Waterford Steam Electric Station Unit 3 2009 Performance ML1006903722010-03-0808 March 2010 Licensee Slides from 3/8/2010 Meeting Generic Letter 2004-02 Response to RAIs ML0935201272009-12-18018 December 2009 Nrc/Entergy Operations, Inc., Management Meeting ML0909603272009-04-0606 April 2009 Summary of Public Meeting with Entergy on Waterford Steam Electric Station Unit -3 2008 Performance ML0821401432008-07-31031 July 2008 Summary of Public Meeting with Entergy on Waterford, Unit 3, 2007 Performance ML0805102512008-02-20020 February 2008 Summary of Meeting with Entergy Operations, Inc. Degraded Batwings Metal Support Structures for Tubes in Waterford 3's Steam Generators 2023-05-02
[Table view] |
Text
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Waterford 3 Surge Line Leak-Before-Break ReS Leakage Detection NRC Presentation November 10, 2010
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- Purpose ~Entergy a -- ~~."c-.~ ~
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- Discuss LBB Request for Additional Information (RAI) regarding:
- Acceptability of existing Waterford 3 RCS unidentified RCS leakage detection TSs for meeting 10 CFR 50.36(c)(2), Criterion 1 for Leak-Before-Break (LBB) analyses
- Waterford 3's leakage detection capability for meeting SRP 3.6.3 and RG 1.45 2
Background -Entergy
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- Waterford 3 RSG tubesheet design has integral blowdown passage
- Improves secondary chemistry and reduces sludge accumulation
- RSG blowdown nozzle is -17 inches lower than OSG
- Creates interference with existing surge line whip restraint
- Whip restraint and blowdown line relocation not practical due to space limitations
- Surge line LBB approval provides ability to effectively route blowdown piping 3
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Background -Entergy
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- February 22, 2010 license amendment application provided details of Waterford 3 RCS leakage detection capability for meeting SRP 3.6.3 and RG 1.45 guidance
- Additional leakage detection details provided in the NRC RAI response on August 12, 2010
These [RCS leak detection] capabilities were not proposed for inclusion as a Technical Specification LCO as required by Criterion 1 of 10 CFR 50.36(c)(2) 5
Key Points *--- Entergy
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- Entergy has concluded that the LBB leakage detection meets the regulatory requirements based upon the following:
- SRP 3.6.3 requirements are met for LBB analyzed leakage flaw of 2.5 gpm with a leakage detection sensitivity of 0.25 gpm (factor 10).
- The SRP 3.6.3 and RG 1.45 guidance for the leakage detection sensitivity is a design requirement and does not require a Technical Specification limit.
- W3 TS and STS do not have a TS limit for RCS leak detection sensitivity.
The current RG 1.45 design requirement is contained in the TS bases.
- Surge line piping flaws are very stable and a leakage flaw of 2.5 gpm provides substantial analytical margin against a critical flaw (factor >2).
- The existing Waterford TS LCO of 1 gpm unidentified leakage provides margin with respect to the analysis value (2.5 gpm) and against a potential piping rupture. .
- NRC precedent does not support changing TS LCO limits.
6
NRC Regulatory Guidance ~Entergy
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- GOC 4 for LBB requires analyses to demonstrate that the probability of piping rupture is extremely low
- GOG.4 governs LBB analyses including design and uncertainty margins
- Provides specific conclusions that piping systems do not approach rupture
- Performed for specifically analyzed piping systems to ensure stability
- GOC 30 requires that means shall be provided for detectingl identifying RCS leakage
- GOG 30 governs leakage detection requirements
- TS requirements under RG 1.45 are for complying with GOG 30
- Assumes unanalyzed piping failures involving rapid propagation 7
NRC Regulatory Guidance ~Entergy
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SRP 3.6.3 guidance:
- A piping system under pressure involves uncertainties and that margins are needed (§ 111.4)
- Detection should be sufficiently reliable, redundant, and sensitive to support the fracture mechanics evaluation (§ 111.4)
- The size of the flaw is 10 times greater than the minimum leakage the detection system is ~able of sensing (§ 111.11 (C)(iii))
- References RG 1.45 for compliance 8
NRC Regulatory Guidance 4~Entergy
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RG 1.45 regarding LBB leakage detection:
- The overall response time should be based on the piping system to protect against a piping rupture
- Under certain circumstances leakage monitoring system specifications may need to exceed the quantitative criteria in this regulatory guide
- No mention of T8 for reduced LBB leakage detection design capability 9
NRC Regulatory Guidance -Entergy
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- RG 1.45 does define what leakage detection limits should be provided in TSs
- TSs should respond to a leakage increase of 1..9mn
- Significant increases in the leakage rates below the TS limits, but above the baseline values, should be monitored in order to QPerate within acceptable limits
- The rate of increase in leakag~ is needed to verify that actions can be taken before the plant exceeds TS limits
- Plant procedures should specify operator actions in response to leakage rates less than the TS limits
NRC Regulatory Guidance ~Entergy
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- Summary for LBB leakage detection guidance:
- It provides for uncertainty in analysis against leakage flaw for detection
- The detection system must be reliable, redundant, and sensitive
- It shows that the leakage detection system is capable of detecting to the specified margin of 10
- The response time of system should be consistent with the analysis results
- LBB leakage detection guidance establishes new design requirements but not TS limits under GDC 30 11
LBB Licensing/Design Basis ~Entergy
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- The analysis and margins performed in accordance with GOC 4 establish new design requirements to be reflected in the design and licensing basis
- The FSAR and TS Bases contain these assumptions and requirements that support design limits
- A change to the licensing / design basis does not constitute a need to change the TSs 12
LBB Licensing/Design Basis *---- Entergy
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- The new LBB RCS leakage detection requirements and sensitivity are being included in the Waterford UFSAR
- Similar to other design basis margins and requirements they will be controlled under 10 CFR 50.59 Review
- These limits cannot be changed unless the review passes 10 CFR 50.59 criteria
- LBB design basis is protected and governed in licensing basis documents 13
NRC Technical Specification Guidance
-Entergy
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- 10 CFR 50.36(c)(2) Criteria 1 evaluates instrumentation used to detect a significant abnormal degradation of RCPS
- Purpose is to allow operators to detect mgnificant abnormal 9§.gradation and correct or shutdown the plant safely to reduce the likelihood of an accident
- Significant abnormal leakage should be determined based upon LBB fracture mechanics analyses
- Shutting down the plant safely should be based on detection and adequate time to take safety measures
- Per 1993 TS Policy, Criterion 1 is not intended to detect precursors to RCPS leakage "This criterion is intended to ensure that Technical Specifications control those instruments specifically installed to detect excessive reactor coolant system leakage. This criterion should not, however, be interpreted to include instrumentation to detect precursors to RCPB leakage ... "
14
NRC Technical Specification Guidance *--- Entergy
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Typical Design of Protective Functions for TS Limits Safety Limit
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Analytical margin provided to protect SL Analytical I I (Design) Limit Margin to ensure that actions are taken prior to reaching design limit TS Limits The margin that the plant is allowed to operate within including Normal Operation its design basis 15
Treatment of LBB Margins *--- Entergy
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Per LBB analysis:
- The critical flaw is the analyzed point where the leakage flaw would become unstable (i.e. the Safety Limit)
- The factor of 2 provides margin for analytical uncertainty between the leakage flaw and the critical flaw (i.e.
Analytical Limit)
- A TS Limit should be established with sufficient margin to protect against a potential piping failure that would result in an immediate threat to the public health and safety
- This can be performed within existing T8 LeO limits of 1 gpm 16
Treatment of LBB Margins ~Entergy
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- Per TS Policy, a TS LCO should be based on the ability to effectively detect and respond to RCS unidentified leak prior to exceeding specified design [analytical] limits
- The WCAP-17187-P analysis confirms that the surge line leakage flaw remains stable at a 2.5 gpm leak rate
- The Waterford 3 surge line is not susceptible to quickly propagating flaws
- Stability periods are shown in MRP-109 (Alloy 82/182 Butt Weld Safety Assessment) 17
Treatment of LBB Margins -Entergy
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MRP-109 Plant N Surge Line (Pressurizer) 7.0 6.5* , 0.25 gom, 6.3 vr
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&gpm,-1.,9 yr
0.0 a 1 2 3 4 5 6 7 8 9 10 11 Leakage (GPM - Gallons per Minute)
- 1. Data based on MRP-109, Table 5-5 and Figure 5-68
- 2. MRP-109 provides relative periods and does not directly equate to WCAP-17187-P analysis 18
Treatment of LBB Margins 4tEntergy
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Safety Limit (Critical Flaw) Leakage flaw remains stable greater than 3 years. Factor of 2 margin to critical flaw.
Analytical Limit (2.5 gpm Leakage Flaw) Existing TS: Shutdown at greater than 1.0 gpm unidentified RCS leakage.
Greater than 5 years to critical flaw TS Limits (1 gpm Includes:
Unidentified RCS leakage)
- Plant RCS leakage monitoring performed =:; 0.1 gpm
- 0.25 gpm GDC 4 sensitivity Normal Operation
(=:; 0.1 gpm) 19
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- Waterford Leakage Detection TS Limits and Controls
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- Containment sump level indication is a continuous indication.
- TS SR 4.4.5.1 performs a channel check every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
- Waterford TS SR 4.4.5.2.1 also requires RCS inventory balance every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 20
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- Waterford Leakage Detection TS Limits and Controls -Entergy
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- Both containment sump level indication and the RGS inventory balance meet the 0.25 gpm sensitivity
- Leakage monitoring actions are procedurally performed well ahead of TS limits
- Substantial time is available to take appropriate shutdown actions before a leakage flaw could become a pressure boundary rupture concern
- Existing TS LCO limits address plant safety for both GDG 30 and GDG 4 requirements 21
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- Significant abnormal degradation only requires a detection limit to protect against an immediate threat to public health and safety
- The analyzed leakage flaw of 2.5 gpm provides analytical margin well ahead of a potential piping failure
- A shutdown TS LCO limit of 1.0 gpm provides substantial margin including uncertainty well ahead of the analytical limit of 2.5 gpm
- The existing TS limits remain conservative to protect LBB analytical results 22
- Regulatory Precedent ~Entergy
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- Neither SRP 3.6.3 or RG 1.45 addresses the assumed leakage detection margin as a new IS limit
- Previous LBB precedent would suggest that reduced IS limits are not required
- Ginna LBB License Amendment Application
- Established a 0.25 gpm leakage detection capability
- No TS change proposed or required by NRC
- Accepted in September 22, 2005 Amendment [ML0524303043]
- License Amendments for Beaver Valley 2 has an LBB RCS leakage requirement of 0.5 gpm and Kewaunee has a 0.25 gpm RCS leakage requirement with no TS revisions 23
. . ~ .
RAI 2 Conclusions
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- Additional TS requirements are not necessary for the 0.25 leakage detection capability:
- Regulatory guidance indicates an RCS leakage detection design capability and not a TS limit
- Substantial detection periods exist for taking action prior to reaching the analytical limit for protection of public health and safety
- NRC precedent does not support changing TS LCO limits 24
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Additional NRC RAI 1 eEntergy a ~,.,.,. " <" ~~-::;,..--
The licensee proposed crediting leak detection capabilities beyond those specified in RG 1.45 (e.g., sensitivity of 0.25 gallons per minute) without adequate supporting analysis 25
Waterford 3 Leakage Detection
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monitoring requirements for LBB applications
- SRP 3.6.3 (March 2007) ensures leakage detection is sufficiently reliable, redundant, and sensitive
- RG 1.45, Rev. 1 (May 2008) provides various detection and monitoring approaches that are considered acceptable including
- Having leakage monitoring processes including action levels for monitoring unidentified RCS leakage (Reg. Pos C.3) 26
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Waterford 3 Leakage Detection eEntergy and Monitoring ~~=---'" ..,C~~
- Waterford 3 has leakage detection instrumentation that satisfies the LBB sensitivity requirements of 0.25 gpm
- TS LCO 3.4.5.1, ReS Leakage Detection Instrumentation, includes Containment Sump level instrumentation as one of the leakage detection methods
- Containment sump level is provided by a computer point having a sensitivity of < 0.1 gpm (computer point is non-safety)
- The associated sump level transmitter is safety related, seismic, environmentally qualified (Accepted in NRC Amendment 197)
- The containment sump level instrument satisfies the RG 1.45 instrumentation guidance for LBB leakage detection sensitivity 27
Waterford 3 Leakage Detection
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- Leakage Monitoring for meeting RG 1.45
- Waterford implemented procedural instructions based on Owners Group leakage monitoring and action levels (WCAP-16465)
- Post outage RCS leakage baseline established
< 0.075 gpm
- Uses multiple plant leakage detection inputs
- Established various action levels consistent with Owners Group guidance
- The Waterford Leakage Monitoring process satisfies the RG 1.45 Monitoring Requirements 28
- RAI 1 Conclusion -Entergy a -- -L'..=::.- ~.,. ,<C,,-.,.-~~
- Waterford 3 installed instrumentation satisfies RG 1.45 leakage detection for LBB sensitivity
- Waterford 3 leakage monitoring program satisfies RG 1.45 leakage trending for LBB sensitivity
- Combined processes provide sufficient diversity to detect and address RCS unidentified ReS leakage of 0.25 gpm
- Waterford. 3 leakage detection/monitoring satisfies response time requirements specified in RG 1.45 based on the LBB fracture mechanics analysis of 0.25 gpm unidentified leakage 29
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