W3F1-2015-0028, Response to Request for Additional Information Regarding the Request to Permanently Extend the Integrated Leak Rate Test Frequency to 15 Years

Response to Request for Additional Information Regarding the Request to Permanently Extend the Integrated Leak Rate Test Frequency to 15 Years

ML15105A615
Person / Time
Site:	Waterford
Issue date:	04/15/2015
From:	Chisum M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MF4727, W3F1-2015-0028
Download: ML15105A615 (9)

Text

Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504-739-6660 Fax 504-739-6678 mchisum@entergy.com Michael R. Chisum Site Vice President Waterford 3 10 CFR 50.90 W3F1-2015-0028 April 15, 2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

Waterford Steam Electric Station, Unit 3 Response to Request for Additional Information Regarding the Request to Permanently Extend the Integrated Leak Rate Test Frequency to 15 Years Waterford Steam Electric Station, Unit 3 (Waterford 3)

Docket No. 50-382 License No. NPF-38

REFERENCES:

1. Entergy Letter W3F1-2014-0052, License Amendment Request to Change Technical Specifications to Extend the Type A Test Frequency to 15 Years, dated August 28, 2014. (ADAMS Accession No. ML14241A305)

2. Letter from NRC, Request for Additional Information Regarding the Request to Permanently Extend the Integrated Leak Rate Test Frequency to 15 Years (TAC No. MF4727), dated March 13, 2015.

(ADAMS Accession No. ML15069A576)

Dear Sir or Madam:

In letter dated August 28, 2014 (Reference 1), Entergy Operations, Inc. (Entergy) submitted a license amendment request to change the Waterford 3 Technical Specifications to permanently extend the Integrated Leak Rate Test (ILRT) frequency to 15 years.

In letter dated March 13, 2015 (Reference 2), NRC requested Entergy to provide additional information to support review of the license amendment request to extend the ILRT frequency. This letter provides the response to that request for additional information.

This correspondence contains no new commitments.

If you have any questions or require additional information, please contact the Regulatory Assurance Manager, John Jarrell, at 504-739-6685.

W3F1-2015-0028 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on April 15, 2015.

Sincerely, MRC/SM Attachments: 1. Waterford 3 Response to Request for Additional Information (TAC No.MF4727)

W3F1-2015-0028 Page 3 cc: Mr. Marc L. Dapas, Regional Administrator U.S. NRC, Region IV RidsRgn4MailCenter@nrc.gov U.S. NRC Project Manager for Waterford 3 Michael.Orenak@nrc.gov U.S. NRC Senior Resident Inspector for Waterford 3 Frances.Ramirez@nrc.gov Chris.Speer@nrc.gov Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division Ji.Wiley@LA.gov

Attachment 1 W3F1-2015-0028 Waterford 3 Response to Request for Additional Information dated March 13, 2015.

(TAC NO. MF4727) to W3F1-2015-0028 Page 1 of 5 By letter dated August 28, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14241A305), Entergy Operations, Inc., submitted a license amendment request (LAR) to change 6.15, Containment Leakage Rate Testing Program, for the Waterford Steam Electric Station, Unit 3. The proposed change would allow a permanent extension of the Type A primary containment integrated leak rate test frequency from 10 years to 15 years.

By letter dated March 13, 2015 (ADAMS Accession No. ML15069A576), the U.S. Nuclear Regulatory Commission (NRC) staff requested that additional information be provided to complete the review of the LAR. After further review, the NRC staff requests the following additional information.

RAI #13 According to Section 9.2.3 of the Nuclear Energy Institute (NEI) 94-01 Revision 2-A, Industry Guideline for Implementing Performance-Based Option of 10 CFR 50 [Title 10 of the Code of Federal Regulations Part 50], Appendix J, dated October, 2008 (ADAMS Accession No. ML100620847), please provide the following information for Type A tests conducted on May 12, 1991 and May 21, 2005:

a) As-left minimum pathway leakage rate (MNPLR) for all Type B and Type C pathways that were in service, isolated, or not lined up in their test position (i.e., drained and vented to containment atmosphere) prior to performing the Type A test; b) List all pathways and associated leakage rates that contribute to MNPLR in item (a);

c) Performance Leakage Rate (PLR) (=UCL+MNPLR) where UCL is the upper confidence limit; d) Determine if the Type A test meets the performance criterion by showing if, PLR is less than or equal to () 1.0 La (allowable leakage rate).

Please note that during the above performance determination, the following process must be followed, as quoted from Section 9.2.3 of NEI, Revision 2-A:

In addition, leakage pathways that were isolated during performance of the test because of excessive leakage must be factored into the performance determination. If the pathway leakage can be determined by a local leakage rate test, the as-left MNPLR for that leakage path must also be added to the Type A UCL. If the pathway leakage cannot be determined by local leakage rate testing, the performance criteria for the Type A test are not met. If an excessively leaking containment penetration barrier pathway is discovered during the Type A test, and the pathway is neither a Type B or Type C tested pathway, it shall still be tested to Type B or Type C test requirements after the Type A test and its as-left MNPLR added to the Type [A] test UCL. In this case the Type A test performance criterion is not met unless that pathway is subsequently added to the Type B or Type C test program. If the excessive leakage is from a source that can be tested only during a Type A test, the Type A test performance criterion is not met.

to W3F1-2015-0028 Page 2 of 5 RAI #13 a) Response:

For Type A test conducted on May 12, 1991:

Per the ILRT Final Report dated June, 1991, the as-left minimum pathway leakage rate (MNPLR) for all Type B and Type C pathways that were in service, isolated, or not lined up in their test position (i.e., drained and vented to containment atmosphere) prior to performing the Type A test was 2,701 SCCM = 0.0013 wt%/day.

For Type A test conducted on May 21, 2005:

Per the ILRT Final Test Report, The ILRT implementing procedure PE-005-001 Revision 4 accounted for all penalty additions made to the ILRT results in Attachment 12.10, Non-Standard Penetration Alignment Adjustment. If a penetration was normally tested by the Appendix J program and it was not vented and drained to be tested by the R13 ILRT a MNPLR Type B or C leakage penalty was taken. The value of the addition and the testing dates were recorded in Attachment 12.10 as well. The MNPLR Penalty Additions were tallied and converted from sccm to %wt/day in Attachment 12.10. The final value for Type B&C penalties added to the Type A test results in 2005 was 5,148 sccm, which when converted to %wt/day in the procedure worked out to an addition of 0.0025%wt/day.

RAI#13 b) Response:

For Type A test conducted on May 12, 1991:

Per the ILRT Final Report dated June, 1991, The fire protection penetrations (60 and 61), the ILRT pressurization line penetration (63) and ILRT pressure sense line penetration (65) were not aligned in the specified post-accident configuration during the ILRT.

Penetration Leakage (sccm) 60 1,620 61 351 63 710 65 20 Total: 2,701 sccm = 0.0013 wt%/day For Type A test conducted on May 21, 2005:

Per the ILRT Final Test Report, The ILRT implementing procedure PE-005-001 Revision 4 accounted for all penalty additions made to the ILRT results in Attachment 12.10, Non-Standard Penetration Alignment Adjustment. The value of the addition and the testing dates were recorded in Attachment 12.10. The table from Attachment 12.10 is provided below.

to W3F1-2015-0028 Page 3 of 5 Penetration Leakage Penetration Inside Leakage Outside Leakage Minimum Barrier(s) Rate (sccm) Barrier(s) Rate (sccm) Pathway Leakage Rate (sccm) 7 PMU-151 192 PMU-152 34 34 9 IA-909 490 IA-910 470 470 23 CC-641 100 CC-644 440 100 24 CC-710 188 CC-713 127 127 26 CVC-103 113 CVC-109 76 76 28 PSL-105 38 PSL-107 1,240 38 29 PSL-203 250 PSL-204 400 250 30 PSL-303 30 PSL-304 30 30 31 GWM-104 30 GWM-105 80 30 40 SI-405 B 139 SI-407 B 109 109 41 SI-405 A 1,350 SI-407 A 1,320 1,320 42 SP-105 60 SP-106 30 30 43 BM-109 229 BM-110 186 186 44 CVC-401 60 RC-606 30 30 51 FS-405 196 FS-406 1,130 196 59 SI-343 469 SI-344 400 400 60 FP-601 A 2,080 FP-602 A 550 550 61 FP-601 B 121 FP-602 B 50 50 62 FS-415 30 FS-416 30 30 63 FLANGE 1,570 LRT-109 1,570 785 a 65 A LRT-201 b 34 LRT-202 64 34 65 B LRT-203 b 30 LRT-204 60 30 66 A HRA-109 A 30 HRA-110 A 30 30 66 B HRA-126 A 41 HRA-128 A 600 41 67 A HRA-109 B 30 HRA-110 B 30 30 67 B HRA-126 B 116 HRA-128 B 112 112 71 CMU-244 60 CMU-245 30 30 Total 5,148 Notes:

a. Inside and outside barriers tested together minimum pathway leakage is half of the total.

b. Inboard isolation valve is outside the containment.

to W3F1-2015-0028 Page 4 of 5 RAI#13 c) Response:

For Type A Test conducted on May 12, 1991:

Per the ILRT Final Report dated June, 1991, Adding the total minimum pathway leakage (MNPLR) of 0.0013 wt%/day to the calculated total time 95% UCL of 0.0718 wt%/day yields the adjusted total time 95% UCL of 0.0731 wt%/day.

For Type A Test conducted on May 21, 2005:

The table below shows the Performance Leakage Rate (PLR) as provided in the ILRT Final Test Report.

Mass Point Analysis (%wt/day)

Measured Leakage Rate at 95% UCL 0.0581

(%wt/day)

Water level corrections per App B, ORT 17

-0.0039

(%wt/day)

Corrections for valves not in Accident Positions from Appendix of ILRT Procedure 0.0025

(%wt/day)

Miscellaneous Additions 0.0000 Performance Criteria leakage rate 0.0567 (0.20%wt/day)

RAI#13 d) Response:

For Type A Test conducted on May 12, 1991:

The Type A test meets the performance criterion since the PLR is less than or equal to

() 1.0 La (allowable leakage). The allowable leakage rate (La) is 0.500 wt%/day and the acceptance criteria is 0.75 La or 0.375 wt%/day. Per the ILRT Final Report dated June, 1991, It must be shown that the results of the leakage rate test would have been acceptable had the test been performed prior to any repairs being made during the local leakage rate testing program. This is shown by adding minimum pathway leakage improvements to the total time 95% UCL. Total minimum pathway improvements sum to 26,324.5 SCCM which is equivalent to 0.0127 wt%/day. Adding this to the total time 95%

UCL of 0.0731 wt%/day (includes additions for penetrations 60, 61, 63, and 65) results in a theoretical as found (before repairs) leakage rate of 0.0858 wt%/day. This is well below even the as left acceptance limit of 0.375 wt%/day.

Since the Performance Leakage Rate (PLR) is less than or equal to () 1.0 La (0.5%wt/day), the Type A test meets the performance criteria.

to W3F1-2015-0028 Page 5 of 5 For Type A Test conducted on May 21, 2005:

Per the ILRT Final Test Report, The containment performance criteria of NEI-94-01 Section 9.2.3 applies to the evaluation of containment performance during a CILRT from the standpoint of determining test interval only. Successful completion of the CILRT at the Waterford Unit 3 Generating Station satisfies the requirements of NEI-94-01, Section 9.2.3.

As no leakage paths were isolated during the ILRT, the Performance Criteria in this case is equal to the As-Left ILRT Results, which, at 0.05445%wt/day was less than the acceptance criteria of 0.5%wt/day.

Since the Performance Leakage Rate (PLR) is less than or equal to () 1.0 La (0.5%wt/day), the Type A test meets the performance criteria.