ML18282A259
| ML18282A259 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 09/20/2018 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| Howard K | |
| References | |
| Download: ML18282A259 (124) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Plant License Renewal Subcommittee Docket Number:
(n/a)
Location:
Rockville, Maryland Date:
Thursday, September 20, 2018 Work Order No.:
NRC-3910 Pages 1-124 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
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PLANT LICENSE RENEWAL SUBCOMMITTEE
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THURSDAY SEPTEMBER 20, 2018
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ROCKVILLE, MARYLAND
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The Subcommittee met at the Nuclear Regulatory Commission, Two White Flint North, Room T2B1, 11545 Rockville Pike, at 8:28 a.m., Gordon R.
Skillman, Chairman, presiding.
COMMITTEE MEMBERS:
GORDON R. SKILLMAN, Chairman RONALD G. BALLINGER, Member CHARLES H. BROWN, JR. Member JOSE MARCH-LEUBA, Member HAROLD B. RAY, Member PETER C. RICCARDELLA, Member MATTHEW SUNSERI, Member
2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 ACRS CONSULTANT:
STEPHEN SCHULTZ DESIGNATED FEDERAL OFFICIAL:
KENT HOWARD ALSO PRESENT:
PHYLLIS CLARK, NRR ALAN COX, NRR JOE DONOGHUE, DMLR SAMUEL GRAVES, Region IV*
ALLEN HISER, NRR WILLIAM HOLSTON, NRR*
PAUL HYMEL, Entergy LOIS JAMES, NRR JOHN JARRELL, Entergy BRIAN LANKA, Entergy JAMES MEDOFF, NRR SEUNG MIN, NRR ERIC OESTERLE, NRR AMRIT PATEL, NRR GORDON PICKERING, Entergy HERBERT RIDEOUT, Entergy MOHAMMAD SADOLLAH, NRR EMMANUEL SAYOC, NRR
3 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 ALSO PRESENT:
ANDREA D. VEIL, Executive Director, ACRS JOHN VENTOSA, Entergy GEORGE WILSON, NRR GARRY YOUNG, Entergy
- Present via telephone
4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 C-O-N-T-E-N-T-S Page Call to Order......................................5 Introductions and Meeting Overview Joe Donoghue.................................7 Introduction and Overview of Agenda and Presentations, John Ventosa, Chief Operating Officer, Entergy South.............8 Waterford 3 Station Plant Status John Jarrell................................10 Major Equipment Upgrades, Brian Lanka.............17 Waterford 3 License Renewal Project Exceptions in-depth information on a few selected topics, Garry Young................26 Break.............................................67 NRC Presentation, Phyllis Clark, Program Manager, Waterford Steam Electric Station, Unit 3, for Waterford License Renewal Safety Review...............................67 Public Comment....................................91 Adjournment.......................................92
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 P-R-O-C-E-E-D-I-N-G-S 1
(8:28 a.m.)
2 CHAIRMAN SKILLMAN: Ladies and gentlemen, 3
good morning. This meeting will come to order. This 4
is a meeting of the Plant License Renewal Subcommittee 5
of the Advisory Committee and Reactor Safeguards. I'm 6
Gordon Skillman and I'm Chairman of the Subcommittee.
7 ACRS Members in attendance today are Ron 8
Ballinger, Harold
- Ray, Matthew
- Sunseri, Peter 9
Riccardella, and Jose March-Leuba. We may have Charlie 10 Brown. And we have our Consultant, Dr. Stephen 11 Schultz. Steve, welcome.
12 The ACRS reviews and advices the 13 Commission, with regard to the licensing and operation 14 of production and utilization facilities and related 15 safety issues, the adequacy of proposed reactor safety 16 standards, technical and policy issues, related to the 17 licensing of evolutionary and passive reactor designs 18 and other matters referred to it, by the Commission.
19 The purpose of today's Subcommittee 20 meeting is for the NRC Staff and Entergy, the Applicant, 21 to brief the Subcommittee on the Waterford Steam 22 Electric Station, Unit 3, License Renewal Application.
23 The Subcommittee will gather information, 24 analyze relevant issues and facts and formulate a 25
6 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 proposed position and action, as appropriate, for 1
deliberation by the full Committee, if needed. The 2
meeting will be open to the public.
3 We have received no written comments, or 4
requests for time, to make oral statements from members 5
of the public, regarding today's meeting. A transcript 6
of the meeting is being kept and will be made available, 7
as stated in the Federal Register Notice.
8 Therefore, we request that participants 9
in this meeting use the microphones, located throughout 10 the meeting, meeting room, when addressing the 11 Subcommittee. Participants should first identify 12 themselves and speak with sufficient clarity and 13 volume, so that they can be readily heard.
14 A
telephone bridge line has been 15 established for this meeting, to preclude interruption 16 of the meeting, for those of you on the telephone bridge 17 line, please mute your individual lines, during the 18 presentations and Committee discussions. And, for all 19 in attendance, please silence your electronic devices.
20 We will now proceed with the meeting and 21 I call on Joe Donoghue, please, to make introductory 22 comments, please.
23 MR. DONOGHUE: Good morning. Thank you, 24 Chairman Skillman, and Members of the ACRS License 25
7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Renewal Subcommittee. I'm Joe Donoghue, I'm the Deputy 1
Director of Division of Materials and License Renewal, 2
at NRR.
3 We sincerely appreciate the Subcommittee 4
accommodating a schedule change, to allow us to do 5
presentations today, for license renewal reviews for, 6
at Entergy facilities, Waterford and Riverbend, it 7
helps make us a more efficient regulator and, it's the 8
best use of our resources and the Applicant's resources, 9
so thank you.
10 The presentations today will include 11 Waterford 3, which is scheduled for this morning, and 12 Riverbend, scheduled for this afternoon. The PMs, for 13 those activities, are Phyllis Clark, for Waterford 3, 14 and Manny Sayoc, for Riverbend.
15 Part of the Management Team that are here 16 with me today, are Dr. Allen Hiser, Eric Oesterle, who's 17 sitting next to me, and in the audience, we have other 18 members of our division and other divisions in NRR, 19 who have worked on this review, and they're available 20 to help answer any questions that you have.
21 And some of those people are on the phone.
22 And also, by the way, Region IV Staff will be 23 participating in the presentation today. We look 24 forward to a productive discussion with your 25
8 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Subcommittee.
1 There are no open, or confirmatory items 2
in the safety evaluation ports for both of these 3
reviews. However, we'll provide an overview of the 4
staff's review, highlight a few technical areas that 5
may be of interest to the Subcommittee and, as always, 6
we'll address any questions that you may have.
7 So at this time, I'd like to turn the 8
presentation over to the Entergy team and their Chief 9
Operations Officer, John Ventosa, to introduce his team 10 and commence their presentation.
11 Okay, for those in the front, please see 12 your little microphone.
13 MR. VENTOSA: Got it.
14 CHAIRMAN SKILLMAN: And there's a little 15 push right at the bottom. And when you choose to speak, 16 please, push push, and when you choose to stop speaking, 17 hold.
18 MR. VENTOSA: Thank you.
19 CHAIRMAN SKILLMAN: Thank you. Yes, sir.
20 Go ahead.
21 MR. VENTOSA: Good morning, my name is John 22 Ventosa, I'm the Chief Operating Officer for Entergy 23 South and I'm responsible for Waterford and Riverbend, 24 which is the topics for today's meeting.
25
9 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 We do very much appreciate the opportunity 1
to speak about the License Renewal Application for 2
Waterford 3. This effort has yielded a better 3
understanding for our plant and we've become stronger, 4
as a result of the License Renewal efforts.
5 The NRC Staff has conducted a very 6
thorough, but fair, review of our readiness, for the 7
operating license extension, and this meeting 8
represented another important milestone for our journey 9
to extend the operating life of Waterford.
10 For our Waterford discussion, we have Brian 11 Lanka, the Engineering Director, at Waterford, John 12 Jarrell, the Regulatory Assurance Manager, and Garry 13 Young, our Fleet License Renewal Director. We also 14 have a team of Subject Matter Experts that are here 15 to support the discussion.
16 So this morning, John Jarrell will describe 17 the Waterford 3 Station Plant status and licensing 18 history. Brian Lanka will discuss the major equipment 19 upgrades, completed a plan that is supporting the 20 extended operation of Waterford, and finally, Garry 21 will discuss the License Renewal Project except and 22 more in-depth information on a few selected topics.
23 Again, thanks, for the opportunity today, 24 this is an important day for Waterford and we welcome 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 your questions and discussions. I look -- then I'll 1
turn the presentation over to John.
2 MR. JARRELL: All right, again, thank you, 3
very much, for the opportunity to have Waterford 3 come 4
present. My name is John Jarrell, I'm the Manager of 5
Regulatory Assurance Licensing at Waterford 3. We've 6
already been through the agenda.
7 I just want to give everyone a short 8
description of Waterford 3, a little history.
9 Waterford is located on the Mississippi River, 10 approximately 25 miles upriver, from New Orleans, in 11 St. Charles Parish, in Louisiana.
12 As a combustion engineering and Triple S 13 plant, we were built by Abasca, and we do have a dry 14 containment. We have a Westinghouse turbine 15 generator. Our ultimate heat sink is a combination 16 of dry and wet cooling tower fans, or quick tooling 17 towers, which are independent from the, the river water.
18 Our current licensed thermal power is 3,716 19 megawatts thermal and the staff compliment is, 20 approximately, 751. As of this morning, Waterford was 21 at 100 percent power. We're currently on an 18-month 22 refueling cycle.
23 Waterford is in the RAPTOR oversight 24 process, action major column one. Our last refueling 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 outage ended in spring of 2017, and the next refueling 1
outage we have is coming up in early 2019.
2 CHAIRMAN SKILLMAN: John, before you 3
change, you're on an 18-month fuel cycle. Of that 18 4
months, you take, maybe, 20 days, or 25 days for a 5
refueling. That leaves you 500-and-something days for 6
OPs.
7 MR. JARRELL: That's correct.
8 CHAIRMAN SKILLMAN: Of those days, how 9
many are you at 100 percent power?
10 MR. JARRELL: Well, from the last, from 11 the last cycle, we were -- let me think. We were down 12 for, approximately, seven days, in July.
13 CHAIRMAN SKILLMAN: Basis, or reason?
14 MR. JARRELL: That was a reactor trip that 15 was due to, we had inclement weather. A lightning 16 strike effected some, a plant equipment and the 17 operators tripped the main turbine.
18 CHAIRMAN SKILLMAN: Okay.
19 MR. JARRELL: And when that happened, the 20 electrical buses failed to transfer, and so we had an 21 automatic reactor trip. And that, we were down for 22 about seven to ten days for that.
23 We, normally, in an 18-month cycle, we've 24 had a fairly good operating history and we're up, I 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 would say, you know, a good majority of that time, I 1
would say no more than, than ten days.
2 MR. LANKA: Right around 98 percent.
3 CHAIRMAN SKILLMAN: Say it again, please?
4 MR. LANKA: The passing factor is right 5
around --
6 (Simultaneous speaking.)
7 (Off-microphone comments.)
8 CHAIRMAN SKILLMAN:
Microphone on, 9
please, Brian. The passing factor, about 98 percent?
10 MR. LANKA: Yes, right, right around 98 11 percent.
12 CHAIRMAN SKILLMAN: Okay, so you would 13 translate to -- perhaps you, John, would answer this.
14 The Material condition is, maybe, good, okay, slightly 15 better than average, or extraordinarily good?
16 MR. VENTOSA: I would say, slightly better 17 than average. I mean, Waterford's been online now, 18 for 300, since July of the previous year, with very 19 few challenges, from an equipment-kind-of-standpoint.
20 So.
21 CHAIRMAN SKILLMAN: Material condition, 22 you give yourself an A plus?
23 MR. VENTOSA: I would say an A on material 24 condition. We could always -- A plus is always 25
13 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 something --
1 CHAIRMAN SKILLMAN: To achieve.
2 MR. VENTOSA: -- I'm not sure we'll ever, 3
in my perspective, get there, but something we'd strive 4
for.
5 CHAIRMAN SKILLMAN: Okay. Thank you.
6 MR. SCHULTZ: John, John, can, can you 7
describe the operational history, say, over the last 8
decade, in terms of capacity factor and plant 9
availability?
10 MR. VENTOSA: I don't have the numbers, 11 off the top of my head. But, generally, what --
12 MR. SCHULTZ: I understand and, yes, 13 generally --
14 MR. VENTOSA: Yes, generally, Waterford 15 is run very, it's been very strong, operating history, 16 by whatever, you know, external stakeholder measures, 17 whether that's INPO, or, or the NRC, the capacity 18 factor's been high, so Id' say it's, it's a well-run, 19 strong plant.
20 MR. SCHULTZ: Thank you.
21 CHAIRMAN SKILLMAN: John, let me ask this, 22 because you are the Chief Operating Officer, for these 23 two facilities that we are reviewing today. What 24 shadow do you cast in both of those organizations, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 relative to your Quality Assurance Program?
1 MR. VENTOSA: From a Quality Assurance 2
standpoint? So there, there isn't, so obviously it's 3
independent from even under my, or our Quality Assurance 4
VP, works right for our Chief Nuclear Operating Officer.
5 But we have significant input. He is, he's 6
part of our CNOO staff, so his input comes back to the 7
CNOO, indirectly, to myself, and then, with, you know, 8
obviously, follow-up with the site. So I have, you 9
know, I would say, at least, weekly interaction with 10 our, our oversight organization and, at times, daily.
11 CHAIRMAN SKILLMAN: We, around this table, 12 have quite a bit of experience and, those of us who 13 have been on the anvil at these plants recognize that, 14 if the senior leadership fully understands the Quality 15 Assurance Program, all 18 points, and sees them as an 16 operating tool for excellence that the organization 17 will fall in line and the results are remarkable.
18 And we see the opposite, where there's 19 been, either, insufficient knowledge of what is 20 Appendix B, to 10 C.F.R. 50, or an attitude of who cares.
21 We see chilly work environment and we see material 22 conditions that's poor, and we see site behavior that's 23 needing attention.
24 What I hear you say is, the Quality 25
15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Assurance Program is alive and well, at both of these 1
sites. It is something that is active, it is pursued, 2
at least, weekly, sometimes, daily.
3 MR. VENTOSA: That's correct.
4 CHAIRMAN SKILLMAN: Is that an accurate --
5 MR. VENTOSA: That is --
6 CHAIRMAN SKILLMAN: Okay.
7 MR. VENTOSA: -- an accurate statement.
8 CHAIRMAN SKILLMAN: Please proceed.
9 John.
10 MR. JARRELL: Oh, thank you.
11 MEMBER RAY: Oh, I have a question of Dick.
12 MR. VENTOSA: Yes, sir.
13 MEMBER RAY: The, could you elaborate on 14 the failure to transfer what was determined the cause 15 of that, in the incident you just mentioned?
16 MR. LANKA: Yes, we had done a modification 17 in our last refueling outage, where we replaced the 18 relays with a new type of relay, and it, we, we tested 19 it in place, instead of doing actual testing, when the 20 system was coming up and running, and they did not time 21 properly, so we went back to the old design.
22 MEMBER RAY: Thank you.
23 CHAIRMAN SKILLMAN: Well, let's, let's 24 pull that string a little further. How far did your 25
16 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 extent and condition review go for that incident?
1 MR. LANKA: We went back and looked at all 2
of our modifications that were install in the last two 3
outages and made sure we had adequate post-MOD testing.
4 CHAIRMAN SKILLMAN: Okay.
5 MR. VENTOSA: One thing I would add, as 6
a fleet, we, we extended that past just Waterford to 7
our other stations, also.
8 CHAIRMAN SKILLMAN: Thank you.
9 MR. JARRELL: All right, this is some 10 Waterford 3 licensing history. We were licensed on 11 November 14th of 1974. The receipt, or -- I'm sorry 12 that was our construction permit.
13 We received our operating license March 14 of 1985, we went commercial on September 24th of 1985.
15 We had eight percent power uprate April 15th, 2005.
16 We submitted the application for extended 17 operation on March 16th of 2016, and our current license 18 expiration is December 18th of 2024.
19 So with that, I'd like to turn it over to 20 our Engineering Director, Brian Lanka, and he's going 21 to go over some major equipment upgrades.
22 MR. LANKA: Thanks, John. I'm Brian 23 Lanka, I'm the Engineering Director, at Waterford 3.
24 I want to start by saying, Entergy and Waterford is 25
17 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 committed, through our nuclear strategic plan to make 1
Waterford reliable for extended operation, so that 2
means we have a long-range plan focusing on our plant 3
and safety and equipment reliability.
4 Going over some of the changes we've 5
already made, for reliability purposes, we have 6
replaced all four of our electrical pump motors. To 7
add additional safety margin, we've upgraded our diesel 8
fuel oil capacity. We've actually increased that 9
capacity up to 35 percent.
10 CHAIRMAN SKILLMAN: What was the basis for 11 that decision?
12 MR. LANKA: It was the -- the original 13 design, we've had very low margin, so we wanted to 14 increase the margin, so it was to improve safety.
15 CHAIRMAN SKILLMAN: Was this tied to the 16 Fukushima upgrades?
17 MR. LANKA: No.
18 CHAIRMAN SKILLMAN: No.
19 MR. LANKA: It was not tied to the 20 Fukushima --
21 CHAIRMAN SKILLMAN: It was just to get --
22 MR. LANKA: Additional --
23 CHAIRMAN SKILLMAN: -- more runtime for 24 those engines, if and when you ever needed it?
25
18 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. LANKA: Correct. Okay.
1 CHAIRMAN SKILLMAN: Okay.
2 MR. LANKA: We've also, for reliability 3
purposes, have replaced our safety-related static 4
universal power supplies. In addition to that, in 5
January, we'll be installing a swing train for each, 6
each division, to help improve reliability.
7 In 2013, we replaced our steam generators 8
and the reactor vessel head. New steam generators have 9
a more resilient material for the tubing and we have 10 the new Westinghouse design, which has steam cans on 11 the feed ring, which help reduce FME from getting into 12 the generator. The reactor vessel had got rid of all 13 the Alloy 600 nozzles and went to Alloy 690.
14 CHAIRMAN SKILLMAN: What is the material 15 that you are claiming is super whamodyne for steam 16 generator?
17 MR. LANKA: Our tubes are now Alloy 690.
18 CHAIRMAN SKILLMAN: 690, okay.
19 MR. LANKA: Okay.
20 CHAIRMAN SKILLMAN: Thank you.
21 MR. LANKA: If you go to the next slide, 22 you'll see some our pictures. This is our, our 23 traveling screens, to help reduce getting debris into 24 our condenser, which effects the chemistry and it 25
19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 effects the steam generator health.
1 We put in new Geiger screens, which are, 2
they rotate, vise of rotating up and down, so you can 3
care -- this eliminates any carryover. If you go to 4
the next slide, this is pictures of our new steam 5
generator getting installed. This is a Westinghouse 6
design steam generator.
7 And this is a picture of our new reactor 8
head and we replaced everything on top of the head, 9
new coils, new grippers, everything was replaced.
10 Projects we have going forward. In 11 January, we'll be re-tubing the condenser with SEA-CURE 12 Tube, which is more resilient and, as part of that, 13 we'll also be replacing the Cathodic Protection System 14 for the condenser.
15 We're also, we're working on replacing our 16 core protection calculators that is part of our reactor 17 protection system that actually monitors the core for 18 a CE, unit, so we're going to upgrade that system and, 19 basically, replace it.
20 To improve reliability, we're also going 21 to upgrade our turbine control system and replace our 22 safety-related chillers. Lastly, we have several 23 projects going on our ultimate heat sync.
24 Our ultimate heat sync's the combination 25
20 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 of a dry cooling tower and a wet cooling tower, so we 1
are in the process of replacing the motors, the gear 2
boxes, and the motor control centers for those systems, 3
as well.
4 CHAIRMAN SKILLMAN: For the ultimate heat 5
sync improvements, how dependent are you on Mississippi 6
River conditions, for that --
7 MR. LANKA: We are --
8 CHAIRMAN SKILLMAN: -- to be successful?
9 MR. LANKA: We are not, we're not, at all, 10 because our, we have a closed system, so we don't rely 11 on the Mississippi.
12 CHAIRMAN SKILLMAN: Okay. Thank you.
13 MR. LANKA: And, any other questions, for 14 me, I'll turn it over to Garry, to talk about the 15 license.
16 MEMBER SUNSERI: Yes, I had --
17 MR. LANKA: Oh, I'm sorry.
18 MEMBER SUNSERI: -- one, one question.
19 So can you comment on the quality of your underground 20 piping, the condition of it --
21 MR. LANKA: The cathodic --
22 MEMBER SUNSERI: -- have you -- no, not --
23 MR. LANKA: --- protection of it?
24 MEMBER SUNSERI: -- not, not just the 25
21 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 cathodic protection of it, it would be an element of 1
it, but the, the pipe condition, itself. You have 2
underground pipe?
3 MR. LANKA: Correct.
4 MEMBER SUNSERI: Okay. So whether it's 5
essential service water, fire protection, any, any of 6
your underground piping, have you had any trouble with 7
it, have you had a replacement strategy, what's the 8
prognosis for its long-term health?
9 MR. LANKA: Our, our piping was, when they 10 designed it, it was all encased in concrete. So we 11 dodo inspections and, and it's been, we have had very 12 little issues. Chris, do you want to add something?
13 CHAIRMAN SKILLMAN: Please identify 14 yourself.
15 MR. PICKERING: Hello, can you hear me?
16 All right, the name is Gordon Pickering, with Entergy.
17 For the Underground Buried Piping Program, as Brian 18 indicated, all of it's encased in concrete.
19 We actually proactively did modifications 20 to reroute some of our applicable piping above ground, 21 to reduce future inspections for the existing industry 22 issue that drove us to the Buried Piping Program.
23 We, we have an enhancement, or -- we have 24 the program listed, as a, a new program. We, basically, 25
22 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 are going to implement the recommendations of the 1
Interim Staff guidance going forward, to enhance what 2
we currently do.
3 From a fire protection standpoint, we have 4
not inspected it. We've done flow testing and look 5
for degradation of fire protection through flow 6
testing.
7 And we do have a sapid for a long-term 8
potential replacement of fire protection piping, but 9
it's not from an external corrosion, it's more from 10 a, a C factor, for C factor future degradation.
11 MEMBER SUNSERI: Have you had any leaks 12 of your fire protection piping?
13 MR. PICKERING: Nothing of the main fire 14 mains.
15 MEMBER SUNSERI: Thank you.
16 CHAIRMAN SKILLMAN: Gordon, please, don't 17 leave the microphone.
18 MR. PICKERING: Okay.
19 CHAIRMAN SKILLMAN: Let me ask this 20 question. It probably -- it is not shown on any of 21 these slides that are coming up, so let me ask this.
22 In the fire water system amp, on your plant, and also 23 at Riverbend, and we also saw it on, at Indian Point, 24 it appears as though Entergy undertook a very broad 25
23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 fleet action on fire protection.
1 And on the amp, on this plant, there are 2
26 enhancements and there are six exceptions. And, 3
as I read them, on the Waterford 3 application, I read 4
them on Riverbend and we, we did Indian Point, here, 5
just two weeks ago, I was wondering, to myself, is this 6
an Entergy initiative, to ensure that your fire 7
protection systems are good to go for the PEO and, is 8
this indicative of fire protection systems that are 9
now, or have been, deficient? That's two questions.
10 Is, is this attempting to remedy a deficiency? And, 11 is this, really, a fleet effort to improve fire 12 protection, throughout the fleet?
13 MR. PICKERING: So for the Waterford 3 Fire 14 Protection Program, we have a very, very few fire 15 impairments that are long-standing. We, actually, and 16 the only one that we really have is a design deficiency 17 that we are working through.
18 We were NFP at a five lessons program, so 19 we have one fire impairment that, that's going to 20 require some additional design, design work, or 21 possible NRC approval, to address long, just in general, 22 we have, we've been making a lot of improvements to 23 our fire protection program.
24 We are currently scheduled to replace 25
24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 detectors inside of containment and replace fire 1
panels, which have just been a nuisance impairment and 2
an obsolescence issue.
3 But, but overall I would say, our fire 4
protection program is, is a transition to A05 and we 5
are heavily working to ensure that it's sustains a good, 6
reliable performance.
7 MR. VENTOSA: From a fleet standpoint, I 8
think this is, you know, an example, where if -- as 9
if we were looking at operating experience across the 10 industry.
11 So it's more of we, we, our attempt to stay 12 ahead of any future degradation, knowing that there 13 is some aging with those systems and you need to spend 14 some level of capital to stay ahead, before you have 15 significant issues.
16 So it's more of a fleet initiative to, to 17 prevent problems than rectifying significant issues 18 that we talk about, specifically, at Waterford.
19 CHAIRMAN SKILLMAN: Gordon and John, thank 20 you. Please proceed.
21 MEMBER BALLINGER: I had some questions, 22 regarding the condenser.
23 CHAIRMAN SKILLMAN: All right.
24 MEMBER BALLINGER: What's the tube sheet 25
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 material? The tube sheet material, not the tube.
1 (Off-microphone comments.)
2 MEMBER MARCH-LEUBA: I'm not -- sorry, 3
microphone again. He needs to be able to hear you.
4 (Off-microphone comments.)
5 MEMBER BALLINGER: Chris, do you know the 6
tube sheet material?
7 MR. PICKERING: I believe the tube sheet 8
is, is carbon steel, because we, we do the coating on 9
it and we do a PM, to inspect that coating, and we, 10 we re-coated it.
11 MEMBER BALLINGER: Okay, and the tubes are 12 rolled and, are expanded, or rolled and welded on one 13 end, how are they installed?
14 MR. LANKA: The new ones will be rolled 15 in.
16 MEMBER BALLINGER: They'll be rolled in?
17 MR. LANKA: Right.
18 MEMBER BALLINGER: So the good news about 19 SEA-CURE is that it's resistant to chloride cracking.
20 The bad news about SEA-CURE is when you roll the stuff 21 in there, you increase the strength, because of cold 22 work, and it's susceptible to hydro embrittlement, if 23 your Cathodic Protection System is not modified to 24 prevent dropping the potential -- gosh -- below, like, 25
26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 minus 750, or something like that, is that all factored 1
into this design of the new cathodic protective system?
2 MR. LANKA: We can validate that, they're 3
putting a new cathodic protection in, for the new 4
tubing, right?
5 MEMBER BALLINGER: Because, it really 6
comes down to quality control on the rolling in process, 7
because you get a lot of variability, you know, if it's 8
like a Friday rolling, or a Monday rolling, or something 9
like that, so I'm curious about QA issues, related to 10 the quality of the tube installation.
11 CHAIRMAN SKILLMAN: Please proceed.
12 MR. YOUNG: Okay. I'm Garry Young, the 13 Director of the License Renewal for the Entergy nuclear 14 fleet. And, on this slide, I wanted to, to give you 15 some background on our license renewal process, 16 including the approach for the Integrated Plan 17 Assessment and for preparing the license renewal 18 application.
19 We have a dedicated corporate team working 20 our license renewal for all of our Entergy plants and 21 this team has almost two decades of experience with 22 all aspects of AG management and license renewal and 23 we've prepared more than a dozen license renewal 24 applications over the last several years.
25
27 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 But, in addition to the corporate team we 1
have a plant team, at Waterford, experts in design, 2
systems engineering, and plant programs that was 3
established for the License Renewal Project.
4 And the plant team provided the needed 5
input and the review and the oversight of all of the 6
engineering and environmental reports that were 7
created.
8 We had more than 40 engineering reports 9
that were prepared to address the mechanical, the 10 electrical, the civil structural, and the time limited 11 aging analysis topics that were needed for the 12 application.
13 We used the NRC approved NEI 95-10 guidance 14 to prepare the project-specific procedures and 15 guidelines. These are the same procedures that we've 16 used on our previous license renewal projects and 17 they're routinely updated with lessons learned, 18 industry operating experience, and changes to the NRC 19 guidance.
20 The site-specific aging management reviews 21 for Waterford were compared to the GALL Report, 22 NUREG-1801, Rev. 2, as part of the application 23 development, the individual line items in the 24 application indicate their consistency with the GALL 25
28 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Report and the aging management review results.
1 And I'll talk more, later, on a later slide, 2
about the comparison of the aging management programs 3
with the GALL report. The license renewal application 4
was submitted to the NRC in March of 2016.
5 The NRC review process was originally 6
scheduled to be completed in April of 2018, of this 7
year, but due to the delays, caused by the need for 8
a license amendment, to incorporate the RAPTOR computer 9
code for performing the neutron, reactor vessel neutron 10 fluence calculations into our licensing basis, the 11 schedule has been extended to the end of this year.
12 And I'll talk more, about the RAPTOR code topic, on 13 a later slide, as well.
14 MR. SCHULTZ: Garry, on these --
15 CHAIRMAN SKILLMAN: Okay, Garry -- go 16 ahead.
17 MR. SCHULTZ: Garry, on these two slides, 18 can you describe in more detail the, the makeup and 19 the diversity of disciplines in the plant team, as well, 20 site team, as well as the, as well as the general Entergy 21 team, associated with the license renewal?
22 MR. YOUNG: Yes, for the site team, we had 23 all of the, the subject matter experts that we needed 24 for -- for example, when we did the civil structural 25
29 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 review, we had the civil structural people, at the 1
plant, review all of the documents, review all of the 2
imputes that we used, such as the drawings and the, 3
the, the system descriptions that sort of thing.
4 As well as, review -- we collected the 5
information on the materials, you know, for all of the 6
equipment and to do the aging management reviews. We 7
got verification from the, the site people on, that 8
we had identified the correct materials and the correct 9
environments that we were, you know, evaluation for 10 aging effects.
11 On the program side, we had all of the 12 program owners review, for example, in-service 13 inspection, owners reviewed that part of the report.
14 The corrosion people reviewed that part of the report, 15 the barring piping people reviewed that part.
16 So we, on, on every document that the 17 corporate team created, which was the, the -- that's 18 the core team that created these documents, using the 19 input from the sites, they were all sent to the site 20 and had the site experts review and sign-off on those 21 documents.
22 MR. SCHULTZ: And how about initiation of 23 about initiation of issues, or discussions up-front 24 and during the process, by the site personnel, about 25
30 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 what needs to be effected to develop the best long-range 1
plan for the site, for the plant?
2 MR. YOUNG: Well --
3 MR. SCHULTZ: The corporate team is doing 4
this, but I --
5 MR. YOUNG: Yes.
6 MR. SCHULTZ: -- I -- have you got a process 7
in place that really draws from the site those areas 8
that need attention?
9 MR. YOUNG: Yes. I mean, we, we, we, we 10 went back and looked at all of the operating experience 11 from the site and got the site people that deal with 12 operating experience to provide that input.
13 Because that's one of the activities that 14 we have to do for license renewals is to go back for, 15 I believe, it's ten years, of operating experience and 16 identify issues that have come up at the plant.
17 And, and so, so we collected the data, the 18 corporate team collected the data from the databases, 19 but then we sent that information to the site, to get 20 verification and further input.
21 We also interviewed people, at the site, 22 for information that might not be in some of the 23 documents. So it was a, you know, a fairly 24 comprehensive effort that, it took about two years to 25
31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 go through all this process to get the material that 1
we needed to put together the application.
2 MR. SCHULTZ: Thank you.
3 MR. YOUNG: Okay.
4 MEMBER MARCH-LEUBA: I've got a question.
5 And this is, mostly, for my education. We keep, I'm 6
on a committee, talking back and forth about this topic, 7
so since we have the experts, now, maybe, you can elicit 8
the, tell us what you do?
9 And it has to do with external events.
10 As part of the license renewal, did you review what 11 your bases are, for your plan? Did you evaluate how 12 somebody put a fireworks factory in there, inside 13 boundary, what, what's the process that would follow:
14 MR. YOUNG: Okay that's a complicated 15 question. But we actually --
16 MEMBER MARCH-LEUBA: I know, and that's 17 why it goes back to --
18 (Simultaneous speaking.)
19 MR. YOUNG: Well, on the external events 20 part of it, though, we do, actually, it's part of our 21 environment review. And that's not covered in the 22 Safety Evaluation Report; there's a
separate 23 environment impact statement.
24 But we do go out and, and look at any changes 25
32 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to the, the boundaries outside the plant, itself, and 1
identify those in, in the environmental report.
2 And that, that also was a two-year effort.
3 We had a lot of consultants come in that, you know, 4
they, they interviewed people in the area. They got 5
information from the state agencies that permit other 6
facilities that might be located nearby. And so 7
that's, that's also part of a license renewal effort.
8 MEMBER MARCH-LEUBA: So it is part of the 9
LRA, it's, it's not -- it --
10 MR. YOUNG: It's part of the -- yes it is, 11 actually, a chapter in the LRA.
12 MEMBER MARCH-LEUBA: It's not an ongoing 13 activity, meaning, obviously, you have an ongoing 14 activity --
15 MR. YOUNG: Yes, but --
16 MEMBER MARCH-LEUBA: --- again.
17 MR. YOUNG: Right. We have an ongoing 18 environmental activity looking at these things, but 19 when we did the license renewal, we, we did a much more 20 comprehensive updating of all of that information and 21 brought it into one document.
22 Because that, then becomes part of the 23 public record that's reviewed and, and it's, it's open 24 for hearings, for the public input, so that, that 25
33 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 separate process is, is the, the environmental impact 1
statement, and we have a separate environmental impact 2
statement.
3 MEMBER MARCH-LEUBA: I'm glad to hear 4
that. Now, another difficult question.
5 MR. YOUNG: Okay.
6 MEMBER MARCH-LEUBA: Last week we've been 7
hearing about this 60-foot of our flood level rivers, 8
because of this extremely wet quote-unquote hurricanes.
9 Have you evaluated flooding and how high is your 10 plant -- as part of the LRA, have you considered that 11 maybe we did not consider a hurricane wet enough four 12 years ago?
13 MR. YOUNG: Those are not dealt with in 14 the license renewal part of the process, but they are 15 dealt with at the plant, as an ongoing issue.
16 MR. LANKA: Yes, as part of Fukushima, we 17 re-looked at -- our, our accident is a levee breaking 18 on the Mississippi River and that would be caused by 19 a hurricane. And, and we looked at that level, where 20 the directions of the winds and we calculated it to 21 figure how high our plant walls had to be.
22 Our plant's kind of unique, where we have 23 what we call a nuclear island, so it's, it's, 24 everything's contained on this nuclear island.
25
34 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 There's very limited access, so it's like a ship, sort 1
of.
2 MEMBER MARCH-LEUBA: How about emergency 3
situations like evacuating people from a flooded Sub 4
Mississippi, is that a concern? I mean, what, we've 5
heard, just, I mean, just last week, about a power plant 6
down there in North Carolina.
7 MR. YOUNG: Right.
8 MEMBER MARCH-LEUBA: That the people 9
couldn't even leave the plant, because of the water.
10 I mean, their, their employees were, were stranded.
11 MR. LANKA: If there was a, an emergency, 12 at our plant, we would initiate our sirens, our E-Plan 13 sirens, which would also include, we have a lot of remote 14 areas, which would also include helicopters getting 15 out to the remote areas and notify people that there's 16 something they're addressing at the plant and they 17 should call their, or listen to their --
18 MEMBER MARCH-LEUBA: So your plans include 19 a contingency for a reverse washed out high, high waters 20 everywhere?
21 MR. LANKA: I don't know if our emergency 22 plan, specifically, addresses that, but it's -- we'd 23 have to get back to you on -- have to talk to you about 24 that.
25
35 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 (Simultaneous speaking.)
1 MEMBER RICCARDELLA: You, of course, had 2
that big hurricane in New Orleans a few --
3 CHAIRMAN SKILLMAN: You had Katrina.
4 MEMBER RICCARDELLA: -- a few years ago, 5
Katrina.
6 CHAIRMAN SKILLMAN: You had Katrina.
7 MEMBER RICCARDELLA: Could you -- any 8
thoughts on, you know, what was the status of, state 9
of the plant during that? Was there any lessons learned 10 going forward from, from that experience?
11 MR. LANKA: There was a lot of lessons 12 learned from Katrina. First of all, the plant didn't, 13 we didn't have any flooding, at the plant level, we 14 were able to get back and forth to the plant. The E-Plan 15 was manned at the whole time. We, there was a lot of 16 lessons about making sure we had diesel fuel oil onsite.
17 MEMBER RICCARDELLA: Yes, was that, was 18 that part of the decision to increase the diesel fuel?
19 MR. LANKA: It helps.
20 (Laughter.)
21 MR. LANKA: But that was one of our main --
22 MEMBER RICCARDELLA: But -- so, you did 23 lose offsite power in that situation?
24 MR. LANKA: We did lose offsite power. We 25
36 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 were running on the diesels for approximately seven 1
days.
2 MR. VENTOSA: Seven days.
3 MR. LANKA: Seven days.
4 MEMBER RICCARDELLA: Seven days?
5 MR. VENTOSA: Seven days on the diesels, 6
yes.
7 MEMBER RICCARDELLA: Yes.
8 MEMBER BALLINGER: Am I to -- I may be 9
getting the two plants confused, but is the maximum 10 flood level on this 45 feet plus the plant, is it 65 11 feet? Is that not -- those numbers are sticking in 12 my head, maybe, it's for the other plant? I mean, you 13 have a lot, a lot of margin between the maximum possible 14 flood level and the actual plant.
15 MR. LANKA: It's about 20 feet.
16 MEMBER BALLINGER: Twenty feet margin?
17 Okay, so,, I had it correct. Okay.
18 (Simultaneous speaking.)
19 CHAIRMAN SKILLMAN: Come on, let's get 20 clear here. Like Brian said, the design basis is loss 21 of the levy. If you're at this plant, this is on the 22 west bank of the Mississippi, if you're in the plant 23 parking lot, you can watch the, the Christmas trees, 24 the, of the ships going by, the tree tops.
25
37 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 PARTICIPANT: Above you.
1 CHAIRMAN SKILLMAN: Above you.
2 MR. LANKA: Above you, yes.
3 CHAIRMAN SKILLMAN: So the big issue is 4
a Mississippi River levy break. But, for the 5
hurricanes, apparently, this plant has been durable 6
and has served us well.
7 MEMBER MARCH-LEUBA: Right, and I want --
8 MS. JAMES: Hello. My name is Lois James.
9 I'm a Project Manager, and I'm sorry, I -- we're outside 10 of Park 54, it sounds like.
11 CHAIRMAN SKILLMAN: Yes.
12 MS. JAMES: And can we get back into 54, 13 which is the purpose of the meeting?
14 CHAIRMAN SKILLMAN: We can do that, but 15 I think we've got Members that have views of the 16 importance of natural events, as it applies to license 17 renewal.
18 And, from what I've heard, so far, my 19 colleagues are asking questions that are reasonable 20 and their questions are being addressed. But, yes, 21 we can get back on topic. But, the reason we are 22 independent, as we are, is because, the free spirits 23 that we are, we'll ask the questions that we ask.
24 MS. JAMES: Yes.
25
38 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 CHAIRMAN SKILLMAN: And it ventilates the 1
issue and it's healthy to let it run.
2 MS. JAMES: Okay.
3 CHAIRMAN SKILLMAN: So. But we'll get 4
back on the topic, Lois. But thank you for breaking 5
in, not a problem.
6 MR. JARRELL: Yes, I would like to say 7
something about the site's response to these kinds of 8
external events. You know, we do, you know, we monitor 9
the weather all the time.
10 We have procedures for major hurricanes, 11 to protect the site. And we're, you know, that the 12 emergency plan is set up to protect the individuals, 13 you know, onsite.
14 In fact, whenever a hurricane is coming, 15 we go into our hurricane preparation mode, which 16 includes talking to the parish, which also includes 17 helping to protect the, you know, the public of St.
18 Charles Parish, as well.
19 So we do have process and procedures that, 20 when hurricanes do come that we get into that will 21 mitigate, you know, help protect the people. Make sure 22 that we, you know, we sequester people onsite. We'll 23 send people away. We, we relocate people up to Jackson, 24 Mississippi.
25
39 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 We'll sequester people onsite, I've been 1
sequestered a couple of times for hurricanes, just to 2
make sure that we can keep people safe, but also, to 3
make sure that we have enough people to keep the plant 4
safe, as well.
5 CHAIRMAN SKILLMAN:
Okay.
Dr.
6 March-Leuba, you good?
7 MEMBER MARCH-LEUBA: I'm good.
8 CHAIRMAN SKILLMAN: Yes, sir.
9 MR. YOUNG: Thank you.
10 MEMBER SUNSERI: I had one question for 11 Garry.
12 MR. YOUNG: Yes.
13 MEMBER SUNSERI: You mentioned that you 14 incorporated lessons learned from previous 15 applications. We're getting near the end of what I'll 16 call the first round of license renewals, did you 17 generate any new lessons learned out this review, and 18 if so, can you give us an example of that?
19 MR. YOUNG: Well, I think, on every review, 20 we, we develop new lessons learned. But, I, coming 21 up with some specific examples may be difficult, I 22 think.
23 I mean, for example, we had some issues 24 with this RAPTOR computer code and the way we handled 25
40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 it. There was a lot of lessons learned from that, in, 1
in our internal processes for reviewing calculations 2
for time limited aging analysis.
3 So it, it's, I would say, there were a 4
number of things. We, we did write some conditions 5
reports, as we were going through the process, where 6
we found, you know, issues with, say, our, our drawings, 7
or our design documents that, that, that we had to 8
address, before we could finish the application.
9 So it's pretty typical for a project and, 10 and, and I would say there's always lessons learned.
11 We always, we always find things that we, you know, 12 that we could adjust on the next project, if, if we 13 have another project.
14 MEMBER SUNSERI: How many, how many do you 15 have additional, or, or is Entergy done with the license 16 renewals, now, or do you have a few more?
17 MR. YOUNG: No these, these two will be 18 the -- all of the Entergy nuclear plants will have a 19 renewed license, at the, at this point, yes.
20 MEMBER SUNSERI: All right, thank you.
21 MR. YOUNG: Thanks.
22 MR. SCHULTZ: Garry, let me ask the 23 question a different way, as a, as a fleet organization, 24 as you've developed lessons learned, going through the 25
41 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 process, what is your process to back fit issues that 1
have already been addressed, resolved, for units that 2
have received permission for a license renewal --
3 MR. YOUNG: Okay.
4 MR. SCHULTZ: -- if you identify something 5
that needs attention, on the other units that are moving 6
forward?
7 MR. YOUNG: Yes, an example of that would 8
be, in our Aging Management Programs, themselves, many 9
of those programs are fleet-level programs, and so every 10 time we do a license renewal project we incorporate 11 the information from that project into the fleet 12 procedures and then, therefore, it goes across all of 13 the, all of the units.
14 Now each unit implements its own, you know, 15 like, we have a fleet procedure for doing the, the 16 onetime inspections, you know, on the, on the piping 17 and other components.
18 And so, you know, when we go out and do 19 our sample size and that sort of thing, selecting 20 samples, sometimes, we learn information that is 21 relevant to the other sites, and then they can use it 22 to be more efficient and more productive, when they 23 do their onetime inspections. So that's an ongoing 24 process, though.
25
42 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 We have an Operating Experience Review 1
Program that's a permanent program, not just for -- it 2
was done, it existed before license renewal. We used 3
it for license renewal. It continues after license 4
renewal.
5 Our Corrective Action Program is the same 6
way. When we find a problem we use the database from 7
the Corrective Action Program to find issues that we 8
needed to address for license renewal.
9 But that program continues and it will 10 exist at, you know, well-beyond getting the renewed 11 license, you know, and, and, obviously, all the way 12 through the period of extended operation.
13 MR. SCHULTZ: I think you said it, but I 14 wanted to have you repeat it, or perhaps, John address 15 it, and that is, sometimes, when we have these meetings 16 about license renewal, it sounds as if we have an Aging 17 Management Program, because we want to --
18 MR. YOUNG: Oh.
19 MR. SCHULTZ: -- get an extension --
20 MR. YOUNG: Right.
21 MR. SCHULTZ: -- a renewal to the license.
22 But, in fact, can you speak to, in general, the fact 23 that Aging Management is an activity that is ongoing --
24 MR. YOUNG: Yes.
25
43 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. SCHULTZ: -- at Entergy and for the 1
benefit of the fleet and for the benefit of the 2
individual units?
3 MR. YOUNG: Yes --
4 MR. VENTOSA: And I can address, it Garry.
5 MR. YOUNG: Okay.
6 MR. VENTOSA: I mean, because really, the 7
way we view the Aging Management programs are really 8
no different than any other engineering program.
9 They're about improving the performance of the -- so 10 those programs become living documents.
11 So what Garry, kind of, articulated is, 12 if we have lessons learned from one of, you know, eight, 13 from a license renewal would be one input, but there's 14 other inputs to improve, whether it's operating 15 experience, that we change the program and then bring 16 it across the fleet. So we don't view them, as onetime 17 activities.
18 MR. SCHULTZ: Okay.
19 MR. VENTOSA: It's like, you know, bulk 20 size corrosion, or EQ, or any other engineering program, 21 we're going to view them, its' an engineering program 22 to maintain the licensing basis and improve the 23 performance of the station.
24 And that's the way we treat them, of course, 25
44 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and they're, they're embedded in the engineering 1
organization that way, not just from a project 2
standpoint and certainly not, we don't view it as a 3
project.
4 MR. SCHULTZ: Thank you.
5 MR. YOUNG: And I'd like to add to that 6
that the programs that we've identified in the 7
application, the vast majority are existing programs.
8 And we have had to make some adjustments, enhancements, 9
for, you know, for example, better documentation of 10 the inspections, or additional inspection techniques, 11 but, but, essentially, the, all of the major programs 12 that we created for license renewal are existing 13 programs.
14 And the majority of the new programs that 15 are truly new, are ones that deal with issues that, 16 such as selective leaching, or something like that, 17 that don't show up in the first 40 years of operation.
18 They're long, much longer term aging effects.
19 So, so yes, I mean, I think that's an 20 important point that the majority, vast majority of 21 the programs we credit for license renewal are existing 22 programs, with, with some adjustments, you know, for 23 the longer term operation.
24 MR. SCHULTZ: And so you've identified, 25
45 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 you haven't separated it in this way, but you're going 1
through the process, either Aging Management, or going 2
into a process where you're identifying improvements 3
to the plant.
4 These improvements not only maintain the 5
capability of the facility to react to events, or 6
incidents, at the plant, but they work to, not just 7
to maintain it, but they work to improve the capability 8
of the unit and the operational staff to react to events 9
that might occur, is that true?
10 MR. YOUNG: Yes.
11 MR. SCHULTZ: Thank you.
12 MR. YOUNG: Yes. Absolutely.
13 CHAIRMAN SKILLMAN: So, Garry, you 14 mentioned the new programs, as I remember, on review, 15 there were six new ones on this facility.
16 MR. YOUNG: Well, we have, we have 12 that 17 we're calling new programs, yes.
18 CHAIRMAN SKILLMAN: Okay.
19 MR. YOUNG: But some of them -- actually, 20 I've got some presentation material on that topic, if 21 you'd like?
22 CHAIRMAN SKILLMAN: Please.
23 MR. YOUNG: Okay.
24 CHAIRMAN SKILLMAN: Because I think it'll 25
46 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 get to the heart of what Dr. Schultz is asking about.
1 MR. YOUNG: Yes, I think so. Well, let 2
me go back to Slide 13. We haven't covered that one 3
yet. And I'll just say, the NRC review process, of 4
course, culminated in the Safety Evaluation Report, 5
which was issued in August of 2018, with no open items 6
and no confirmatory items.
7 And we appreciate the extensive and 8
thorough work of the NRC Staff in reaching this 9
important milestone in our license renewal review 10 process.
11 CHAIRMAN SKILLMAN: On that topic, let me 12 ask this.
13 MR. YOUNG: Okay.
14 CHAIRMAN SKILLMAN:
RAPTOR is not 15 mentioned one time in the SER.
16 MR. YOUNG: I --
17 CHAIRMAN SKILLMAN: Mentioned -- RAPTOR 18 is mentioned in your License Amendment Request.
19 MR. YOUNG: No, it's in the SER. There's 20 a section in there on the neutron fluence that talks 21 about the RAPTOR, unless I'm sadly mistaken, but there's 22 a whole section --
23 CHAIRMAN SKILLMAN: In the SER?
24 MR. YOUNG: Yes.
25
47 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 CHAIRMAN SKILLMAN: I'm sorry, it's fully 1
addressed, it's fully addressed in the SER.
2 MR. YOUNG: Okay.
3 CHAIRMAN SKILLMAN: It is not addressed 4
in the LAR. It is not addressed in your License 5
Amendment Request.
6 CHAIRMAN SKILLMAN: LRA.
8 CHAIRMAN SKILLMAN: Is that because it was 9
so late in the sequence?
10 MR. YOUNG: No. Okay, there is a section 11 in the LRA on the neutron fluence that refers to the 12 calculations that were done, and I believe they refer 13 to RAPTOR by name.
14 CHAIRMAN SKILLMAN: It provides --
15 MR. YOUNG: It does not?
16 CHAIRMAN SKILLMAN:
It provides a
17 reference.
18 MR. YOUNG: Oh, by reference, okay.
19 CHAIRMAN SKILLMAN: By reference.
20 MR. YOUNG: Yes, it's, it's --
21 CHAIRMAN SKILLMAN: Yes, it doesn't 22 describe --
23 MR. YOUNG: Oh, and we have our expert 24 here, from the Plan, he may be able to shed some light.
25
48 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. HYMEL: Paul Hymel. I have the 1
revised LRA that we have, that was submitted with the 2
last REI response, and it does mention RAPTOR M3G in, 3
by referencing the License Amendment Request that we 4
made.
5 MR. YOUNG: Yes, just to clarify, that 6
would be in the RAI responses. So we consider RAI 7
responses to be amendments to the application, so you're 8
correct that, in the original application that was 9
submitted two, two years ago, the name RAPTOR probably 10 does not occur, but in the RAI responses to the questions 11 that the staff raise, then there's a lot of material 12 that we consider an amendment to the application.
13 CHAIRMAN SKILLMAN: I understand and I was 14 inaccurate. What I, I copied this morning, again, the 15 pages, and the SER, fully-addresses this.
16 MR. YOUNG: Okay.
17 CHAIRMAN SKILLMAN: So I'm putting that 18 on the record. And it is the license, the original 19 license amendment --
20 MR. YOUNG: Original, yes.
21 CHAIRMAN SKILLMAN: -- request did not --
22 MR. YOUNG: Yes that's correct.
23 CHAIRMAN SKILLMAN: What you're saying is 24 that it is addressed through the RAI responses.
25
49 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. YOUNG: Correct.
1 CHAIRMAN SKILLMAN: Okay, very good.
2 MR. YOUNG: Okay.
3 CHAIRMAN SKILLMAN: Let's keep on going.
4 MEMBER RAY: Well, I have a question. I 5
trust you guys understand that doing two plants in one 6
day is a ton of stuff to go through, so forgive me if 7
I'm mistaken, also. But I ran across something about 8
the West Side Access Facility and the, basically, it 9
says the staff requested additional information to 10 clarify the basis for not including in the scope of 11 the license renewal. What's the status of that?
12 MR. YOUNG: I will have to -- we'll have 13 to get back to you on that, I'm not --
14 MEMBER RAY: Okay.
15 MR. YOUNG: Say that again, the West Side?
16 MEMBER RAY: Yes, it says, specifically, 17 in the, in what I read and, again, forgive me for not 18 having perfect citations here, because it's not easy.
19 MR. YOUNG: Okay.
20 MEMBER RAY: The staff determined that the 21 non-safety-related West Side Access Facility Building, 22 immediately adjacent to and in contact with a 23 safety-related building was not included within the 24 scope of license renewal staff request.
25
50 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Additional information, this is in the 1
context of whether there's anything still open. The 2
staff requests additional information, clarify the 3
basis for not including West Side Access Facility 4
Building, within the scope of renewal, in accordance 5
with 50-54 A2, to complete its review. Did, was that 6
taken care of and --
7 MR. YOUNG: Yes, we will follow-up on that.
8 MEMBER RAY: Oh, okay.
9 MR. YOUNG: Yes, we have the right people 10 here, I think, to do that. We'll let, we'll let them 11 get together and then, we'll give you -- oh --
12 MEMBER RAY: All right.
13 (Off-microphone comments.)
14 MR. YOUNG: Yes, sir?
15 MR. RIDEOUT: This is Herbert Rideout.
16 The application has addressed that. I haven't, didn't 17 specifically see it, as there was an RAI, issue to that 18 asked that particular question and we responded to it 19 and resolved that issue. I do not believe there's an 20 issue on that, at this time.
21 MEMBER RAY: Okay, well I'll ask the staff 22 when they're up, to confirm that. It, it, I -- can 23 you stay at the microphone and elaborate, a little bit, 24 on what the clarification amounted to?
25
51 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. RIDEOUT: Yes. What it is, is that 1
the West Side Access Facility is located adjacent to 2
a safety-related facility.
3 MEMBER RAY: Right.
4 MR. RIDEOUT: And, which calls for a 5
two-over-one situation and, because it is, we addressed 6
it in the sense that we indicated that, if the failure 7
of the non-safety facility would not effect, or impact, 8
the safety-related facility and --
9 MEMBER RAY: So the, the statement that 10 it's in contact with, the building, it must be, I guess, 11 the elaboration must be that, notwithstanding that, 12 its failure wouldn't affect the safety-related 13 building?
14 MR. RIDEOUT: That is correct. What it 15 is, is that, it's adjacent to it, but it is not attached.
16 There is a, a separation gap between the two 17 structures, and so they, they do not interact with each 18 other.
19 MEMBER RAY: Okay. Well I, I was taken 20 by the end contact with, portion of this statement.
21 And, but that's just not accurate, then. Thank you.
22 MR. RIDEOUT: Okay.
23 MEMBER RAY: If there's any more you can 24 elaborate, like, well it's a quarter inch not in contact 25
52 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 with, or it's two feet, or something like that, would 1
make me feel better.
2 MR. YOUNG: Yes we'll, we'll take an action 3
to look into that a little more. And if we had, if 4
we can get more information --
5 MEMBER RAY: Okay.
6 MR. YOUNG: -- during the meeting, we'll 7
get that to you.
8 MEMBER RAY: Thank you.
9 MR. YOUNG: Okay.
10 CHAIRMAN SKILLMAN: Let's proceed, Garry.
11 MR. YOUNG: Okay. And, next slide.
12 Okay, this, this is a slide that summarizes the Aging 13 Management programs that we've credited for license 14 renewal. We have 41 Aging Management programs that 15 include 12 new programs and 28 existing programs that 16 are, or will be consistent with the GALL Report Aging 17 Management Programs, with a handful of exceptions that 18 are shown on the slide.
19 Some examples of the 12 new programs are 20 the buried piping, Buried and Underground Piping and 21 Tanks Inspection Program, the non-EQ cables in 22 connections Aging Management
- programs, onetime 23 inspection programs, and selective leaching programs.
24 Some aspects of these new programs have, 25
53 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 have been implemented, but they are considered new 1
programs, because a significant number of changes must 2
be made, or have only been recently made, to make them 3
consistent with the program descriptions in the GALL 4
Report.
5 For example, the Waterford Buried Piping 6
Program was initiated in response to the 2009 NEI 7
initiative, but significant changes are necessary to 8
incorporate the latest NRC guidance, which includes 9
Interim Staff guidance, issued in 2015.
10 So for clarity in describing the program, 11 Entergy classified it, as a new program that would be 12 consistent with the program description in the most 13 recent NRC guidance.
14 But, as I mentioned, we do have an existing 15 buried piping program, but it's listed as new, because 16 there were so many changes, it was easier to describe 17 it as a new program in the application.
18 CHAIRMAN SKILLMAN: Garry, let's take a 19 pause here. I would like everyone to silence their 20 microphone and see if we can't get rid of this background 21 noise.
22 Let's proceed. Put your microphone back 23 on, Garry.
24 MR. YOUNG: Okay.
25
54 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 CHAIRMAN SKILLMAN: Thank you.
1 MR. YOUNG: So, in addition, most of these 2
new programs have already been implemented at the other 3
Entergy nuclear units, and this allows us to ensure 4
that implementation of the Waterford Aging Management 5
Programs reach the benefits of lessons learned, from 6
the Industry Operating Experience Program and the 7
Corrective Action Program. The --
8 MR. SCHULTZ: Garry, a couple of --
9 MR. YOUNG: Oh.
10 MR. SCHULTZ: -- general questions, 11 related to these programs. The Buried Piping 12 Inspection Program that you've described that, also, 13 includes the cathodic protection --
14 MR. YOUNG: Yes.
15 MR. SCHULTZ: -- areas?
16 MR. YOUNG: Yes they do.
17 MR. SCHULTZ: And there are some issues 18 associated with cathodic protection that were 19 identified in the, in the audits, NRC audits associated 20 with the operation of the, of the availability of the 21 operation of the cathodic protection system on piping?
22 MR. PICKERING: Thank you. Gordon 23 Pickering, with Entergy. We previously had a deficient 24 work order condition on the cathodic protection system 25
55 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that has been repaired.
1 And, as part of our existing current buried 2
piping and tank program, we're doing annual assessments 3
of the cathodic protection system, to monitor its 4
performance and are ensuring that the inefficient work 5
orders get prioritized and repaired.
6 MR. SCHULTZ: So that's part of your 7
overall program improvement and extent of condition 8
investigation?
9 MR. PICKERING: That's correct.
10 MR. SCHULTZ: Thank you.
11 MR. PICKERING: And that's ongoing, 12 outside of the application, right now.
13 MR. SCHULTZ: Thank you.
14 MEMBER BALLINGER: I want to make sure we 15 get on the record that the cathodic protection criteria 16 for buried piping, which happens to be connected to 17 the condenser, at some point, is different than the 18 cathodic protection limits for SEA-CURE. Okay? And 19 if you get them cross-connected, you're not going to 20 be happy.
21 MR. SCHULTZ: Garry, one more general 22 question. It's discussed in your application and your 23 improvement initiatives that you have Fleet External 24 Surface Monitoring System that has been, has it been 25
56 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 proposed, is it in place, what's the status of the 1
External Surface Monitoring System?
2 MR. YOUNG: The -- we use the terminology 3
of the GALL Report, for External Monitoring Program, 4
but it's actually the, the maintenance rule system 5
walk-downs.
6 So we already have procedures and process 7
in places to do the external monitoring, through the 8
system walk-down process, but we've enhanced them and 9
made adjustments to them, based on the GALL definition 10 of an External Surfaces Monitoring Programs.
11 So, so it is a, it, it is a, a changing 12 program to, to address all of the elements in the GALL 13 Report, but it is also an existing program that came 14 out of the Maintenance Rule.
15 MR. SCHULTZ: So it's a, it's a matter of 16 improving that --
17 MR. YOUNG: Yes.
18 MR. SCHULTZ: -- extending it, well how --
19 MR. YOUNG: Extending it.
20 MR. SCHULTZ: -- would you characterize 21 it?
22 MR. YOUNG: Extending it and better 23 documenting it. Under the Maintenance Rule, we didn't 24 document some of these walk-downs, as thoroughly as 25
57 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 we will be, under the License Renewal Program.
1 MR. SCHULTZ: And documenting means that 2
you have in place a, a means by which to record and 3
monitor information from time-to-time, so that you can 4
follow progress of --
5 MR. YOUNG: Yes, yes.
6 MR. SCHULTZ: -- surface --
7 MR. YOUNG: During --
8 MR. SCHULTZ: -- deterioration?
9 MR. YOUNG: During the inspections, they 10 document the condition, any observations, and, I think, 11 even, in some cases, they take photographs, depending 12 on the situation, and that becomes part of the plant 13 record. And then --
14 MR. SCHULTZ: Thank you.
15 MR. YOUNG: And then the next inspection 16 can refer to that record, to see, you know, if there 17 have been changes in the condition.
18 MR. SCHULTZ: Thank you.
19 MR. YOUNG: Okay. And then we have 28 20 existing programs that have been compared to the GALL 21 programs, and with only a few exceptions having been 22 taken.
23 But, these exceptions include such things, 24 as revising the inspection intervals, based on the 25
58 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Waterford refueling outage schedules and referencing 1
NRC regulatory guides and industry standards that are, 2
later, revisions, than those that were referenced in 3
the GALL Report, which was published in 2010.
4 And, and then, finally, we have one 5
plant-specific
- program, which is the Periodic 6
Surveillance and Preventive Maintenance Program, and 7
this program includes a variety of Aging Management 8
activities that could not readily fit within the scope 9
of the GALL Report Programs, without taking exceptions 10 to the provisions. So that's our only plant-specific 11 program.
12 Okay, next slide. Okay, on the topic of 13 commitment management and controlling the commitments 14 that we've made for license renewal, Entergy has a fleet 15 program that covers management of commitments for all 16 our nuclear plants, including commitments for license 17 renewal.
18 Our program is based on the commitment 19 management guidance in NEI 99-04 that the NRC Staff 20 has endorsed. We have successfully used this 21 commitment management program for our previous license 22 renewal projects, including projects for plants that 23 have implemented license renewal commitments and are 24 successfully operating in the period of extended 25
59 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 operation.
1 For each Waterford license renewal 2
commitment, the Commitment Management Program 3
identifies the actions needed to implement the 4
commitment and identifies the owners, the owner, 5
responsible for its implementation.
6 Assignments will include actions, such as 7
creation of implementing procedures, for new Aging 8
Management programs and implementation of enhancements 9
to existing Aging Management programs. Okay, next 10 slide.
11 MR. SCHULTZ: Garry, I'm glad you went 12 through
- that, sometimes, when you read the 13 documentation about what is going to happen, with 14 regards to license renewal, the impression you get is, 15 everything has been decided and determined and that, 16 by 2024, you're going to have everything in place.
17 And, clearly, in order to implement all 18 of those things that you've committed to, you've got 19 a program in place that's going to implement those, 20 almost, if you will, as soon as possible, so that by 21 the time you get to 2024, these things are completed, 22 is that --
23 MR. YOUNG: That --
24 MR. SCHULTZ: -- a good characterization?
25
60 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. YOUNG: That's correct. We, we have 1
already started implementing some of these commitments, 2
but others will be done over the years, until -- because 3
some of the commitments are to do things, just prior 4
to entering the period of extended operation. So this 5
implementation process spans the whole time, from, from 6
now to the year '40, and beyond, with the new programs.
7 MR. SCHULTZ: Okay. Thank you.
8 MR. PICKERING: I wanted to give the 9
Committee an update on the question on the West Side 10 Access question. The SER does include a discussion 11 and summary of the REI response that we submitted, which 12 provided the technical justification and the specific 13 question on the gap is that there's a half-inch gap.
14 That's also included in REI, response, as well.
15 MEMBER RAY: Thank you.
16 MR. YOUNG: Okay. Go ahead?
17 CHAIRMAN SKILLMAN: Please go ahead, yes.
18 MR. YOUNG: This next slide is on RAPTOR.
19 The primary reason for the delay in the NRC review 20 of the Waterford License Renewal Application, was the 21 time needed for Entergy to prepare and submit the RAPTOR 22 computer code to NRC, for review and approval, in the 23 time necessary for NRC to perform their review.
24 The RAPTOR computer code is used to 25
61 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 calculate the neutron fluence on the reactor vessel.
1 During the NRC review of the License Renewal 2
Application, it was determined that the use of the 3
RAPTOR computer code required NRC review and approval, 4
before completion of the License Renewal Application 5
review.
6 Also, RAPTOR had, had already been used, 7
under the current licensing basis, for a surveillance 8
capsule evaluation. To resolve this issue, Entergy 9
submitted a Licensing Amendment Request in November 10 of 2017, to obtain NRC approval for the use of the RAPTOR 11 computer for Waterford.
12 In July of 2018, the NRC completed their 13 review and approved the License Amendment. Based on 14 the approval of the RAPTOR code for Waterford, the NRC 15 was able to move forward with the review of the 16 associated information provided in the License Renewal 17 Application for the period of extended operation and 18 issued the SER, with no open items.
19 So that, that completes my part of the 20 presentation. That's --
21 MEMBER RICCARDELLA: So RAPTOR's a 22 Westinghouse code, correct?
23 MR. YOUNG: Yes.
24 MEMBER RICCARDELLA: I assume that, you, 25
62 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 this isn't the first use of it, is it, at --
1 MR. YOUNG: No.
2 MEMBER RICCARDELLA: -- Waterford, it's 3
been used on other plants?
4 MR. YOUNG: It has been used at other 5
plants, yes. And, and I've, my understanding is, just 6
recently, about the same time that we got approval for 7
Waterford, it was given generic approval, by the NRC --
8 MEMBER RICCARDELLA: Okay.
9 MR. YOUNG: -- as a, a topical, I believe, 10 yes.
11 MEMBER RICCARDELLA: And, I assume that 12 there was a certain amount of benchmarking of that, 13 against surveillance, surveillance, surveillance data 14 for prior -- at Waterford?
15 MR. YOUNG: Yes.
16 MR. HYMEL: This is Paul Hymel, with 17 Entergy. Yes, there was benchmarking for the in-vessel 18 surveillance capsules, at Waterford compared, in a 19 sense, to RAPTOR, and then, also, the report went 20 through benchmarking of dosimetry throughout the 21 industry, both, in-vessel and ex-vessel dosimetry, at 22 something like 80 data sets.
23 MEMBER RICCARDELLA: Okay. Thank you.
24 MEMBER BROWN: Are the calculations, with 25
63 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 RAPTOR, performed by Entergy?
1 MR. YOUNG: No.
2 MEMBER BROWN: Or are they performed by 3
4 MR. YOUNG: They are performed by 5
Westinghouse and then, reviewed and approved, by 6
Entergy.
7 MEMBER BROWN: All right.
8 MEMBER BALLINGER: Did you get, did you 9
have to use 50-61A?
10 MR. HYMEL: This is Paul Hymel, again, 11 50-61A is, first of all, the --
12 MEMBER BALLINGER: Yes.
13 MR. HYMEL: -- specific provision --
14 MEMBER BALLINGER: Yes.
15 MR. HYMEL: -- you're talking about?
16 MEMBER BALLINGER: Did you stick with 17 50-61, or 50-61A?
18 MR. HYMEL: We meet, we met the pressurized 19 normal shock criteria, screening criteria.
20 MEMBER BALLINGER: So 61?
21 PARTICIPANT: The original one, you 22 said --
23 MR. HYMEL: That's right.
24 (Simultaneous speaking.)
25
64 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. HYMEL: That's right, that's right.
1 MEMBER BALLINGER: Okay.
2 MEMBER RICCARDELLA: And, excuse me. The 3
issues that were being addressed with RAPTOR, had to 4
do with more detailed calculations and the 5
establishment of an external capsule surveillance 6
program, is that correct?
7 MR. HYMEL: Yes, as pertained to license 8
renewal, the issue was benchmarking in the extended 9
Beltline region. And we showed that that was, 10 acceptable benchmarking had been done.
11 MEMBER RICCARDELLA: Okay, thank you.
12 MR. YOUNG: Okay. And now, I'll turn it 13 back over to John Ventosa.
14 MR. VENTOSA: Okay, thank you, for meeting 15 with us this morning. As you've heard, we're 16 fully-committed to improving our Aging Management 17 Programs, as well as, enhancing and integrating our 18 Operating Experience Programs, which we discussed, a 19 little bit, this morning.
20 We do have strong ownership of the 21 programs, by the program owners, and we've laid out, 22 fundamentally, a sound path to successfully manage our 23 plant aging effects through 60 years of operation.
24 In addition, Entergy is committed to 25
65 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 continuously invest in plant modifications, to ensure 1
safe, reliable operations, through the extended period 2
of operations. This concludes our presentation and, 3
again, thank you.
4 CHAIRMAN SKILLMAN: John, thank you.
5 Before the Entergy Team leaves the front of the room, 6
here, Members, do you have any further questions for 7
the Entergy Team?
8 (No audible response.)
9 CHAIRMAN SKILLMAN: I'm going to ask that 10 you don't leave, because the NRC is going to present 11 their findings from their evaluation. I would offer 12 that the license renewal inspection was very thorough, 13 where in a situation where there are no open items and 14 there are no confirmatory items.
15 You've got a, what, nearly three dozen 16 action items, as a consequence of, of this review.
17 I reviewed those, as I was reviewing the SER, and the 18 LAR, and it appears to me that there is a full capture 19 of all of the items that needed to be identified.
20 And I'm assuming that they go into your 21 Corrective Action Program, somehow, so that those end 22 up being addressed, either, before the PEO, or into 23 the PEO, as Steve just described.
24 Even though it is not on the agenda, I'm 25
66 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 going to suggest a ten-minute bio break. I'm going 1
to suggest a 13-minute bio break. Please come back 2
at 15 minutes to 10:00 a.m., on that clock, and then 3
we will work with the NRC Staff. We are in recess.
4 (Whereupon, the above-entitled matter went 5
off the record at 9:32 a.m. and resumed at 9:45 a.m.)
6 CHAIRMAN SKILLMAN: Ladies and gentlemen, 7
we're back in session and we're going to begin with 8
the NRC Staff, and we'll ask Lois, or Phyllis, to please 9
take charge. Go ahead.
10 MS. CLARK: Thank you. Good morning, 11 Chairman Skillman and Members of the License Renewal 12 Subcommittee. My name is Phyllis Clark and I am the 13 Project Manager for the Waterford Steam Electric 14 Station, Unit 3, or Waterford License Renewal Safety 15 Review.
16 We are here, today, to discuss a review 17 of the Waterford License Renewal Application, as 18 documented in the Safety Evaluation Report, which was 19 issued August 17, 2018.
20 Joining me here, at the table, is Dr. Allen 21 Hiser, the Senior Technical Advisory for Licensing 22 Renewal Aging Management Division of Materials and 23 Licensing Renewal, DOMR, and Ms. Louis James, DOMR, 24 Senior Safety Project Manager, running the slides.
25
67 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 On the phone is Samuel Graves, the Senior 1
Reactor Inspector, from Region IV, who led the 71002 2
Inspection. Seated in the audience and joining, by 3
phone, are members of the technical staff, who 4
participated in the review of the licensing renewal 5
application and conducted the onsite audits. Next 6
slide.
7 I will begin the presentation, with a 8
general overview of the Staff's review. Next, Mr.
9 Samuel Graves will present the inspection activities 10 observed, during the License Renewal Inspection, at 11 Waterford 3. I will then present the main sections 12 of the Safety Evaluation Report, which we will be 13 referring to, as SER.
14 On March 23rd, 2016, Entergy, Entergy 15 Operations, Inc.
submitted a
License Renewal 16 Application, or LRA, for Waterford Steam Electric 17 Station, Unit 3, which includes a combustion 18 engineering pressurized water reactor, PWR, nuclear 19 steam supply system, of licensed thermal power of 3716 20 megawatt thermal.
21 The conducted two onsite audits and one 22 inspection, at the site. During the scoping and 23 screening methodology audit, the audit team reviewed 24 the Applicant's scoping and screening methodology, 25
68 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 selected examples of component
- material, and 1
environmental combinations that the Corrective Action 2
Program administrative and confirmatory action 3
processes, as described in the LRA, and the training 4
personnel, who participated in the development of the 5
LRA. The results of the audit were documented in the 6
report, dated November 10th, 2016.
7 During the Aging Management Audit, the 8
Audit Team examined the Appellant's Aging Manager 9
Program, or AMPs, related documentation, the operating 10 experience, to verify the Applicant's claim of 11 consistency with the corresponding AMPs in the generic 12 Aging Lessons Learned Report, or GALL Report. The 13 Staff reviewed the initial 41 AMPs and documented the 14 results in the report, dated May 9th, 2017.
15 Sam will further discuss the activities 16 of the 71002 inspection, in a few minutes. Next slide.
17 In addition to the audits and inspections, already 18 mentioned, the Staff conducted in-depth technical 19 reviews and issued requests for additional information, 20 or REIs.
21 The Staff completed its review of the 22 Waterford 3 License Renewal Application and issued the 23 Safety Evaluation Report on August 17, 2018. The 24 Waterford SER, contained no open items and the SER, 25
69 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 would be published, as a NUREG Report, following the 1
issuance of the new license.
2 I will now direct the presentation to Mr.
3 Graves, to discuss inspection activities and results, 4
as associated with the license renewal review. Next 5
slide.
6 MR. GRAVES: Thank you, Phyllis. Good 7
morning, Subcommittee Members. As they described, my 8
name is Sam Graves and I was the Team Lead for the 9
Waterford License Renewal Inspection.
10 The requirements of the 71002 License 11 Renewal Inspection are three-fold, to verify that the 12 Applicant's scoping and screening methodology 13 appropriately included non-safety-related structures 14 and components, who's failure to prevent safety-related 15 system structures and components, which I'll call SSCs, 16 going forward, hoping we are all familiar with that 17 abbreviation, from performing a safety function.
18 To verify that these scoped and screened 19 SSCs have adequate Aging Management Programs, either, 20 planned, or in place, such that these SSCs will be 21 adequately maintained, consistent with the Rule, 22 existing safety evaluations, and the Applicant's 23 License Renewal Application.
24 And, finally, to verify the Applicant's 25
70 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 license renewal documentation, as a retrievable, 1
auditable, and consistent with the Rule and 2
Applicant-approved programs and procedures.
3 The inspection involved five experienced 4
Regional Inspectors, with an expertise in electrical, 5
civil, nuclear, and meteorological engineering. We 6
walked down numerous structures,
- systems, and 7
components, to assess the adequacy of the licensed, 8
or excuse me, the Applicant's license renewal 9
boundaries, material condition, and conformance with 10 their application and the Generic Aging Lessons Learned 11 Report.
12 We reviewed the scoping and screening of 13 components, walked down accessible areas, and reviewed 14 23 Aging Management Programs, seven new and 16 existing.
15 Next slide, please.
16 Based on numerous walk-downs of accessible 17 areas of the plant, and review of videos of some 18 inaccessible areas, we concluded that, the overall 19 material condition of the facility was good.
20 The team identified that the Applicant was 21 required to enhance several existing AMPs, to attain 22 consistency with the GALL Report and took exceptions 23 to several existing guidance documents, but all 24 exceptions were reasonable.
25
71 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 The team noted that the Applicant's design 1
had no below grade in-scope safety-related electric 2
power cable, and only two in-scope cables, the 480-volt 3
fire pump and jockey pump, which were located in a 4
submerging environment. Next slide, please.
5 CHAIRMAN SKILLMAN: Allen, or excuse me.
6 Sam, this is Dick Skillman, I'd like to ask you several 7
questions, please?
8 MR. GRAVES: Yes, sir.
9 CHAIRMAN SKILLMAN: First of all, I want 10 to compliment you on a thorough inspection report, but 11 I do have a couple of questions.
12 MR. GRAVES: Yes, sir, please.
13 CHAIRMAN SKILLMAN: On your report, Page 14 8, this is Coding Integrity and the exception that is 15 identified is this exception, for the detection of aging 16 effect element, the Applicant proposed performing a 17 onetime inspection of the internal coating of the 18 11-foot diameter carbon steel circulating water piping, 19 a onetime inspection.
20 I spent a couple of decades, at a plant, 21 where we did a walk-down of this piping every outage 22 and we donned scuba gear and hip boots, because we began 23 in mud up to our waist. And I'm wondering, if that 24 is the same experience, at this plant?
25
72 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. GRAVES: Sir, that's a very good 1
question. I, I cannot answer that. I'm not sure what 2
the licensee has found, in that plant, over the years.
3 CHAIRMAN SKILLMAN: Well let's halt.
4 MR. GRAVES: Okay.
5 CHAIRMAN SKILLMAN: Licensee, do you have 6
someone, who can answer that question, please? The 7
reason I'm asking is, this system is, basically, a 8
non-safety, maybe it works and maybe it doesn't work 9
system, until you need your condenser dump valves, then 10 all of a sudden, this system becomes real important.
11 MR. PICKERING: This is Gordon Pickering, 12 with Entergy. We have performed a visual inspection 13 of the discharge portion of that, that piping system, 14 what's in the scope of the LAR submittal is the inlet 15 piping system. To perform that inspection we, we have 16 to pump down the, the entire length of pipe, from the 17 condenser, to the river.
18 With our configuration with the, the 19 Mississippi River and the levy, that pipe goes over 20 the levy and, in order to establish the required 21 conditions to, to do that, we, we have to have a certain 22 length of a condenser water box outage and that's also 23 our path for discharge of water offsite for our waste 24 water system.
25
73 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So the complications with performing that 1
inspection have to do with the amount of time it takes 2
to pump down that entire pipe system. And then, the 3
one inspection we have done, already, was done, and 4
it's, I believe, it's in the, the Aging Management 5
Program that was submitted.
6 And we're actually scheduled to go and 7
re-inspect that same discharge line, at our upcoming 8
refueling outage, in January of 2019, and we're also 9
going to be doing the inspection of the inlet line, 10 in 2019, as well, while we're doing the condenser read 11 too.
12 CHAIRMAN SKILLMAN: So this is a very 13 infrequent inspection?
14 MR. PICKERING: Yes. We're, we're going 15 back into the discharge line, to be able to assess the 16 condition that we found, previously, and determine if 17 we need to take any additional actions.
18 CHAIRMAN SKILLMAN: Do you wear alligator 19 protectors?
20 (Laughter.)
21 MR. PICKERING: I think they say on the 22 river side of the levy.
23 CHAIRMAN SKILLMAN: I'm not sure. I'm 24 just pulling your leg. I was just curious. It seems 25
74 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that this is something that needs more attention than 1
a every once in a while, every 40, or 60-year inspection.
2 Let me ask several other questions, if I might, Sam.
3 MR. GRAVES: Yes, sir.
4 CHAIRMAN SKILLMAN:
- Also, in your 5
inspection report, on Page 10, is a sentence that can 6
only, maybe, come from Cajun country. The sentence 7
is, periodic manhole inspections will be performed, 8
to minimize this exposure, but the inspection frequency 9
cannot be increased, to prevent these cables from being 10 exposed to significant moisture.
11 MR. GRAVES: Yes, sir. That, that was my 12 verbiage.
13 (Laughter.)
14 CHAIRMAN SKILLMAN: Oh, okay. Are, are 15 you really saying, the inspection frequency will have 16 nothing to do with moisture infiltration?
17 MR. GRAVES: Yes, sir. We, we convinced 18 the licensee to go out there and open the manhole and 19 we, we looked down in there and it was, of course, full, 20 almost to the top, with water.
21 They agreed to de-water the manhole and 22 they, they had some equipment that they brought in, 23 a very large de-watering pump. They drained it down 24 and we stood there and watched and the water just, 25
75 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 almost, was, it was a continuous stream flowing from 1
the bottom, refilling that, that entire vault.
2 It took, if I remember correctly, somewhere 3
around 20 minutes or so. It was not a long time, at 4
all. So I was trying to be diplomatic and just saying 5
that there is, there is no way that they can keep that 6
vault dry, those cables will be, nearly, continuously 7
submerged and the structures, as well.
8 And, you know, their concern was the 9
verbiage to go and, you know, de-water the manhole on 10 a regular basis and do an inspection, try to keep the 11 cables dry, and that just seemed impossible.
12 Does that answer your question?
13 CHAIRMAN SKILLMAN: It tells me that they 14 got a lot of subterranean water filling manholes and 15 that they have equipment in place that will function, 16 in spite of that wetted condition.
17 MR. GRAVES: Yes, sir.
18 CHAIRMAN SKILLMAN: Okay. I have, I had 19 a question on fire water system and one member of the 20 Entergy staff has answered, addressed my question.
21 I have a --
22 MR. GRAVES: That was also mine.
23 (Laughter.)
24 CHAIRMAN SKILLMAN: I've got no further 25
76 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 questions. Oh, I do have one further question.
1 MR. GRAVES: Yes, sir.
2 CHAIRMAN SKILLMAN: It's on Page 37 of your 3
Inspection Report, and this is addressing the walk-down 4
you performed, and the topic is alkalized silica 5
reaction.
6 And the sentence that the inspection team 7
provided, on Page 37 of that Inspection Report, is this 8
sentence. The team did not identify any significant 9
indications of alkalized-silica reaction in the sample 10 of structures reviewed by the team.
11 And my question is, were there no 12 indications, or were there no significant indications?
13 Please interpret that sentence for us.
14 MR. GRAVES: Absolutely. I had a civil 15 engineer on the team and, he, he has some experience 16 with alkali-silica reactions. And I tasked him with 17 looking at every, every Aging Management Program he, 18 he looked at, you know, including structures and, and 19 things of that nature, and just general walk-downs to 20 be on the lookout for any alkali-silica reaction and, 21 and we found none.
22 CHAIRMAN SKILLMAN: So no obvious exterior 23 signs of alkali-silica reaction?
24 MR. GRAVES: Yes, sir. We, we probably 25
77 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 could've captured it better that way, but yes that, 1
that's it, in a nutshell, yes.
2 CHAIRMAN SKILLMAN: Thank you.
3 MR. GRAVES: Yes, sir.
4 CHAIRMAN SKILLMAN:
Those are the 5
comments, the questions I had, on the 71002 Inspection 6
Report. Colleagues, might any of you have any question 7
on the Inspection Report?
8 MEMBER SUNSERI: Well just one question.
9 This is Matt, for Samuel.
10 MR. GRAVES: Yes, sir.
11 MEMBER SUNSERI: In, in regards to the 12 amount of ground water, you just described, is there 13 any impact on the ability to monitor and detect for 14 tritium?
15 MR. GRAVES: You know, I would -- I, I, 16 I don't and I can't answer that question, sir, to be 17 quite honest with you. We, we didn't look at that, 18 but I, I can speculate that, with that amount of 19 groundwater, it, they should be, you know, it should 20 be easy to identify it. But that's just speculation, 21 on my part, perhaps, someone else could answer that?
22 MEMBER SUNSERI: I was more concerned 23 about the other end, if there would be so much dilution 24 then you might not be able to detect any.
25
78 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. GRAVES: That's a very good point.
1 I, I cannot say, we did not look at that.
2 CHAIRMAN SKILLMAN: Can we proceed?
3 MEMBER SUNSERI: Thank you.
4 CHAIRMAN SKILLMAN: All right.
5 MR. GRAVES: Yes, sir. Sorry, I couldn't 6
be more, more clear on that one.
7 MEMBER SUNSERI: Okay.
8 CHAIRMAN SKILLMAN: Sam, go ahead.
9 MR. GRAVES: Okay. Thank you, sir. To 10 summarize, the team concluded that the Applicant 11 performed the scoping and screening, in accordance with 12 the Rule.
13 The team found that the information was 14 easily retrievable, auditable, and consistent with the 15 Rule. The team verified that the existing programs 16 were effective in managing aging effects, and the new 17 programs provided reasonable assurances that the aging 18 effects will be managed.
19 The team also verified that the Applicant 20 had a process to track the completion of enhancements 21 and the development of new program and, based on our 22 inspection results, the team had reasonable assurance 23 that the programs in place, or planned, as described 24 in their commitment table, will manage aging effects, 25
79 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and ensure that the intended safety functions of 1
systems, structures, and components, in the Rule.
2 And, if there are no more questions, I'd 3
appreciate it, thank you very much, and I'll turn the 4
presentation back to Phyllis. Next slide, please.
5 CHAIRMAN SKILLMAN: Colleagues, any 6
questions for Sam?
7 Phyllis, go ahead. Thank you.
8 MS. CLARK: In the next few slides, I will 9
present the results of the Staff review, as described 10 in the SER. SER, Section 2, describes the scoping and 11 screening of structures and components, subject to the 12 Aging Management Review.
13 The Staff reviewed the Applicant's scoping 14 and screening methodology, procedures, quality control 15 applicable to the LRA development, and training of the 16 project personnel.
17 The Staff also reviewed the various 18 summaries of the safety-related systems, structures, 19 and components, SSCs, non-safety SSCs effecting safety 20 functions and the SSCs relied upon to perform functions 21 applicable to Waterford in compliance with the 22 Commission's regulations for fire protection, 23 environmental qualifications, station
- blackout, 24 pressurized thermal shock, and anticipated transient 25
80 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 without scram.
1 Based on the review, the results of the 2
scoping and screening audit and additional information 3
provided by the Applicants, the Staff concludes that 4
the Applicant's scoping and screening methodology and 5
implementation was consistent with the standard review 6
plan and the requirements of 10 C.F.R. Part 54.
7 SER Chapter 3 and its subsections covers 8
the Staff's review of the Applicant's Aging Management 9
Programs for managing aging, in accordance with 10 10 C.F.R. 54.21(a)(3).
11 In Sections 3.1 through 3.6, include the 12 Aging Management review its, review items in each of 13 the general system areas, within the scope of license 14 renewal. For a given Aging Management Review item, 15 the Staff reviewed the item to determine, whether it 16 is consistent with the GALL Report.
17 If an Aging Management was not consistent 18 with the GALL Report, then the Staff reviewed the 19 Applicant's evaluation to determine, whether the 20 Applicant has determined that there is reasonable 21 assurance that the effects of aging will be adequately 22 managed, so that the intended functions will be 23 maintained, consistent with the current licensing 24 basis, for the period of extended operation. Next 25
81 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 slide.
1 CHAIRMAN SKILLMAN: Oh, let's go back, for 2
a second.
3 MS. CLARK: Okay.
4 CHAIRMAN SKILLMAN: I'm on the SER, Page 5
3-86, and I'm reading the enhancement to the scope of 6
- program, regarding fatigue monitoring, 3-86, 7
Enhancement 1.
8 MS. CLARK: Okay.
9 CHAIRMAN SKILLMAN:
And in that 10 enhancement, the authors have written, procedures will 11 be revised to monitor and track additional critical, 12 thermal, and pressure transients, for components that 13 have been identified as having a fatigue, TLAA.
14 My question is, if the procedures are being 15 revised for additional, that would be future cycles, 16 was the present cycle count validated for cycles 17 to-date, so that, when the additional cycles are added, 18 there is a true accounting for CUF, Cumulative 19 Utilization Factor?
20 MS. CLARK: Jim Medoff is going to speak 21 to that.
22 CHAIRMAN SKILLMAN: Okay.
23 MS. CLARK: Thanks.
24 MR. MEDOFF: Hello?
25
82 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 CHAIRMAN SKILLMAN: Yes.
1 MR. MEDOFF: This is Jim Medoff with the 2
Staff. I was part of the review with the fatigue TLAAs 3
and the fatigue monitoring programs. The way the, the 4
fatigue monitoring programs work is they, they have 5
software to count cycles.
6 The software is validated against what 7
they, they monitor in the control rooms. The software 8
also does periodic updates of the fatigue calculations, 9
so yes, they do track what's going on, at the facility.
10 In the fatigue calculations, in spite of 11 the fact, they may be relying on the AMP, to disposition 12 the TLAA.
13 And, in accordance with the Rule, they give 14 us cycle projections in the applications where they, 15 they base their current count of their, their cycle 16 projections, going out to the end of the period of 17 extended operation, based on a certain number of cycles, 18 to-date, and then, they have a mathematical theorem 19 for the future cycles to do the calculations to project 20 out. So we look at all of that, as part of the fatigue 21 reviews.
22 CHAIRMAN SKILLMAN: My real question is, 23 is the accounting for the cycles, to-date, known to 24 be accurate?
25
83 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. MEDOFF: I think the Applicant, 1
probably, has more data on the quality assurance 2
protocols that they use to determine that.
3 CHAIRMAN SKILLMAN: Let's give the 4
Applicant a chance to answer that question, please.
5 MR. COX: This is Alan Cox with Entergy.
6 And we do have an activity where we go in and update 7
the cycle counts and go back and research the histories.
8 So that was done kind of to establish a baseline, before 9
we added the additional cycle. So, to answer your 10 question, yes we do account for that.
11 CHAIRMAN SKILLMAN: Okay. And I see it 12 that is the way it is written in the documentation.
13 So thank you, it's on the record. And, Phyllis, please 14 proceed.
15 MS. CLARK: Okay, great. Thanks. The 16 Applicant identified 41 aging management programs in 17 the LRA. This slide identifies the Applicant's 18 disposition of the AMPs, in the left column, and the 19 disposition of the SER, as a result of their Staff's 20 review, in the right column. All were evaluated, by 21 the Staff, for a consistency with the GALL Report.
22 During the Staff's review, the Applicant 23 changed the disposition of three AMPs, based on NRC 24 request for additional information. These AMPs are, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 in-service inspection, changed from consistent in the 1
original LRA, to consistent, with enhancement.
2 Reactor Vessel Surveillance changed from 3
consistent, in the original LRA, to consistent, with 4
enhancements and assessments. The steam generator 5
integrity changed from consistent, in the original LRA, 6
to consistent, with enhancements.
7 SER, Section 4, identifies time limiting 8
aging analysis, or TLAAs. Section 4.1 documents the 9
Staff's evaluation of the Applicant's identification 10 of applicable TLAAs.
11 The Staff evaluated the Applicant's basis 12 for identifying those plant-specific, or generic 13 analyses that needed, that need to be identified, as 14 TLAAs, and determine that the Applicant has provided 15 an adequate list of TLAAs, as required by 10 C.F.R. 16 54.21(c)(i).
17 Section 4.2 through 4.7 documents the 18 Staff's review of the applicable Waterford 3 TLAAs, 19 for the area shown on this slide. Based on its review 20 and the information provided by the Applicant, the Staff 21 concludes that, either, one, the analysis remains valid 22 for the period, for the period of extended operation; 23 two, the analysis has been projected to the end of the 24 period of extended operation; or three, the facts of 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 aging on the intended functions will be adequately 1
managed, for the period of extended operations, as 2
required by 10 C.F.R. 54.21(c)(1), subparagraphs (i),
3 (ii), or (iii), respectively.
4 Next one. The next topic is a reactor 5
vessel neutron influence TLAA. In the LRA, the 6
Applicant did not include a reference to the RAPTOR-M3G 7
Code that was used for the reactor vessel neutron 8
influence TLAA.
9 In addition, the RAPTOR-M3G Code was not 10 approved in their current licensing basis. During the 11 Staff's license renewal review, a License Amendment 12 Request was submitted to appropriately incorporate the 13 RAPTOR-M3G Code method into the Waterford current 14 licensing basis.
15 This amendment was approved in July of this 16 year. Following the approval of the RAPTOR-M3G Code 17 and the current licensing basis, the Staff was able 18 to complete its safety review for license renewal.
19 The Staff also reviewed additional 20 information, regarding the influence method 21 qualifications for extended Beltline region, including 22 uncertainty analysis and measurement benchmarks for 23 this region.
24 In its review, the Staff finds the 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 influenced TLAA meets guidance in Regulatory Guide 1
1.190 and applicable in accordance with 10 C.F.R. 2 54.21(c)(1)(ii).
3 MR. SCHULTZ: Phyllis, that's, it's, those 4
last two bullets are really a package of review, 5
clearly, this review was not a small effort by the Staff, 6
it went on and on.
7 MS. CLARK: Yes.
8 MR. SCHULTZ: But those aren't listed as 9
sequential, but rather, not only, it, it's saying, not 10 only was the methodology approved for use in this 11 application, but also, the evaluation included a 12 detailed evaluation of how it was used, the benchmarking 13 of the tool, particularly for Waterford application, 14 as part of the approval process.
15 MS. CLARK: Right.
16 MR. SCHULTZ: Does that summarize it?
17 MS. CLARK: Yes.
18 MR. HISER: Yes, this is Allen Hiser.
19 There were two separate actions. One was a license 20 amendment that the Applicant realized that it needed 21 to submit after we began review of the License Renewal 22 Application. So, the license amendment was on a 23 parallel track with the LRA review.
24 Ultimately, the license amendment was 25
87 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 approved. And based on that, that was the new current 1
licensing basis for Waterford. That current licensing 2
basis is then, what is used in the license renewal 3
application.
4 So once the two came together, then we were 5
able to do the, part of the review for license renewal, 6
to ensure that the RAPTOR code was adequately 7
incorporated in the COB, now for the period of extended 8
operation. So there, really, are two separate tracks, 9
but they, ultimately, merged, once the LAR was approved.
10 MR. SCHULTZ: Had the methodology been 11 used for other applications than the license renewal?
12 MR. HISER: In other license renewal 13 applications?
14 MR. SCHULTZ: No, in other applications 15 for Waterford.
16 MR. HISER: I do not believe so, because 17 it was not a part of their licensing basis. So it should 18 not be approved, otherwise.
19 MR. SCHULTZ: All right.
20 MR. HISER: They would be sideways --
21 MR. SCHULTZ: I understand, I just wanted 22 to know whether there was some history there that didn't 23 come out in this application discussion. So --
24 MEMBER BALLINGER: No, it was used for 25
88 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Catawba.
1 MR. SCHULTZ: No, I understand that.
2 MEMBER BALLINGER: Yes, okay.
3 MR. SCHULTZ: Yes.
4 MS. CLARK: And the Waterford.
5 MR. SCHULTZ: So, it was an -- that makes 6
it an oversight, in terms of the application, is what 7
was identified in the Staff audit.
8 MS. CLARK: Yes.
9 MR. HISER: And I think, in effect, the 10 LRA was not consistent with the COB.
11 MR. SCHULTZ: Yes.
12 MR. HISER: And so they had to make the 13 COB up, they had to update it, consistent with what 14 they wanted to have going into the PEO.
15 MR. MIN: Yes, this is Seung Min, with the 16 Staff. And, regarding the application of RAPTOR code 17 to other applications, at least, one instance was that, 18 last capsule report dosimetry analysis RAPTOR would 19 utilize, even though that part is concern of COB, not 20 license renewal. So it's fed into the COB resolution 21 through license amendment.
22 CHAIRMAN SKILLMAN: Okay, thank you.
23 MR. MIN: Thank you.
24 CHAIRMAN SKILLMAN: And this all came 25
89 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 together, it appears, in the June, July, August of 2018, 1
because the License Amendment Request was in, and the 2
safety evaluation was proceeding, and those two finally 3
fit, because the SER accounts for RAPTOR-M3G, or, as 4
the License Amendment Request does not, because, the 5
License Amendment Request was so early.
6 MR. HISER: Well, yes, the License 7
Amendment had to be approved before we could approve 8
license renewal, otherwise they would be not in 9
conformance with their COB, and that license renewal 10 is demonstrating that you still will meet the COB out 11 to 60 years. So they had to have the COB consistent 12 with what they came in with in the LRA.
13 CHAIRMAN SKILLMAN: Okay. Steve, are you 14 good?
15 MR. SCHULTZ: I am. Thank you, Dick.
16 CHAIRMAN SKILLMAN: Okay. Phyllis, 17 please proceed.
18 MS. CLARK: All right, thanks. So in 19 conclusion, the Staff has determined that, the 20 requirements of 10 C.F.R. 54.29(a) have been met for 21 the license renewal of the Waterford Steam Electric 22 Station, Unit 3.
23 This concludes the Staff's presentation 24 and we're available for any further questions that you 25
90 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 may have.
1 CHAIRMAN SKILLMAN: Phyllis, thank you.
2 Colleagues, may I ask, whether you have any further 3
questions, for the NRC Staff, on the issue of Waterford 4
5 Hearing none, this is an open meeting.
6 Staff, you're released. Thank you for your 7
presentation. Are there any members of the public in 8
the room that would like to make a comment, on the 9
microphone, please? If so, please come to the 10 microphone and introduce yourself and provide your 11 comment?
12 Seeing none, on the telephone line? If 13 someone is out there, would you just please acknowledge 14 your presence?
15 Hearing none, please close the phone line.
16 And we'll go around the table, one last time, for the 17 Members. Instead of calling on individuals, by name, 18 I will ask, does any Member have a comment that that 19 Member wishes to make, at this point?
20 Hearing none, I would like to make this 21 comment to both the Entergy Staff and to the NRC Staff.
22 To the NRC Staff, for your Inspection Report, for your 23 Safety Evaluation, for all of your reporting on the 24 AMPs, thank you very much.
25
91 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 To the Entergy Team, for your support and 1
your presentations, thank you. The documentation is 2
thorough and complete. We are in recess, until 13:00 3
on that clock, at which time we will pick up the matter 4
of the River Bend License Renewal Application.
5 (Whereupon, the above-entitled matter was 6
concluded at 10:16 a.m.)
7 8
9 10 11 12 13 14 15
Waterford 3 License Renewal
Name Title John Ventosa Chief Operating Officer-South Brian Lanka Director, Engineering John Jarrell Manager, Regulatory Assurance Garry Young Director, License Renewal 1
Entergy Presenters
- Background
- Site Description
- Plant Status
- Licensing History
- Major Equipment Upgrades
- License Renewal Project
- Aging Management Programs and Commitments
- Presentation Topics
- Conclusion 2
Agenda
- Located on Mississippi River 25 miles upriver from New Orleans in St. Charles Parish
- Combustion Engineering NSSS
- EBASCO (AE and constructor)
- Dry containment 3
Waterford 3 Site Description
- Westinghouse turbine generator
- Ultimate heat sink is combination dry & wet cooling towers independent from river
- Licensed thermal power is 3716 MWT
- Staff complement is approximately 751 4
Waterford 3 Site Description
- Plant Status
- 100% power
- Refueling cycle - 18 months
- ROP action matrix Column 1
- Last Refueling Outage
- RF21 (Spring 2017)
- Next Refueling Outage
- RF22 (Early 2019) 5 Waterford 3 Plant Status
Construction Permit November 14, 1974 Operating License March 16, 1985 Commercial Operation September 24, 1985 8% Power Uprate April 15, 2005 LRA Submitted March 16, 2016 Operating License Expiration December 18, 2024 6
Waterford 3 Licensing History
Completed
- Replaced reactor coolant pump motors
- Added emergency diesel generator fuel storage tanks
- Upgraded static uninterruptable power supplies
- Replaced intake structure traveling screens
- Replaced steam generators
- Replaced reactor vessel head
- Replaced refueling machine 7
Major Equipment Upgrades
8 Photos - New Traveling Screens
9 Photos - New Steam Generators
10 Photos - New Reactor Head
Planned
- Retube main condensers
- Replace core protection calculators
- Upgrade turbine controls
- Replace essential chillers
- Ultimate heat sink (UHS) improvements
- Replace UHS motor control center 11 Major Equipment Upgrades
- Experienced, multi-discipline Entergy team (corporate and site personnel) prepared the license renewal application (LRA)
- Incorporated lessons learned from previous applications
- Used NEI 95-10 guidance
- Scoping and screening process
- Aging management reviews
- LRA format and content
- Used Revision 2 of NUREG-1801 12 Waterford 3 License Renewal Project
SER issued August 17, 2018
-No open items
-No confirmatory items 13 Safety Evaluation Report
41 Aging Management Programs
- 12 new programs
- 10 consistent
- 2 consistent with exceptions
- 28 existing programs
- 6 consistent
- 19 consistent with enhancements
- 3 consistent with exceptions and enhancements
- 1 existing plant-specific program with enhancements 14 Aging Management Programs
- Regulatory commitments in the commitment management system to track enhancement to existing programs and implementation of new programs
- Entergy has significant experience with license renewal commitment implementation
- Similar new AMPs and AMP enhancements have been successfully implemented at other Entergy plants 15 Program Commitment Implementation
Reactor Vessel Neutron Fluence Calculations
- License amendment approved to change method of evaluation to modernized, more accurate software, RAPTOR-M3G
- LRA RAIs addressed benchmarking accuracy of neutron fluence calculation beyond the traditional beltline region of reactor vessel
- For license renewal, RAPTOR-M3G used to determine fluence through the period of extended operation 16 Presentation Topic
Entergy is committed to the long-term operation and continuous improvement of our facilities Entergy will manage the effects of aging in accordance with 10 CFR 54.21(a)(1)
Entergy has evaluated time-limited aging analyses that require evaluation under 10 CFR 54.21(c)
Entergy has met the provisions of 10 CFR 54 for issuance of a renewed license 17 Conclusion
Advisory Committee on Reactor Safeguards License Renewal Subcommittee Waterford Steam Electric Station, Unit 3 Safety Evaluation Report (SER)
September 20, 2018 Phyllis Clark, Project Manager Office of Nuclear Reactor Regulation
Presentation Outline
- Overview of Waterford 3 (WF3) license renewal review
- Region IV 71002 Inspection, License Renewal Inspection
- SER Section 2, Scoping and Screening Review
- SER Section 3, Aging Management Review
- SER Section 4, Time-Limited Aging Analyses
- Conclusion 2
License Renewal Review:
Audits and Inspections 3
Audit / Inspection Dates Location Scoping & Screening Methodology Audit June 13 - 16, 2016 Onsite Aging Management Program (AMP) Audits July 11 - July 29, 2016 Onsite Region IV 71002 Inspection: Scoping and Screening and AMPs January 30 - February 16, 2017 Onsite
SER Overview
- SER was issued August 17, 2018
- 119 total RAIs issued in 18 letters (sets)
- 25 follow-up RAIs 4
- Scope
- Scoping and Screening of Components
- Walkdown of Accessible Areas
- Review of 23 AMPs
- Inspection
- January 30 - February 16, 2017
- Team Inspection (5 inspectors) on-site for 2 weeks
- Inspection Report (ML17094A238) issued on March 31, 2017 5
71002 Inspection
6
- Facility overall material condition was good
- AMP exceptions and enhancements were reasonable
- Applicant had no below grade safety-related in-scope electrical power cables
- Only two 480 volt non-safety related cables were in scope and the applicant developed a new program for these cables. (B.1.24 Non-EQ Inaccessible Power Cables 400 V (XI.E3))
71002 Inspection: Results
71002 Inspection
Conclusions:
- Scoping and screening performed in accordance with 10 CFR Part 54
- Information was retrievable, auditable, and consistent with 10 CFR Part 54
- Existing programs were effective in managing aging effects
- New programs provide reasonable assurance that aging effects will be managed
- Actions to address enhancements and new programs are being tracked for completion 7
SER Section 2
- Structures and Components Subject to Aging Management Review
- Section 2.1, Scoping and Screening Methodology
- Section 2.2, Plant Level Scoping Results
- Sections 2.3, 2.4, 2.5, Scoping and Screening Results 8
- Aging Management Review Results
- Section 3.0, Use of the Generic Aging Lessons Learned Report
- Section 3.1, Reactor Vessel, Internals, and Reactor Coolant System
- Section 3.2, Engineered Safety Features Systems
- Section 3.3, Auxiliary Systems
- Section 3.4, Steam and Power Conversion Systems
- Section 3.5, Structures and Component Supports
- Section 3.6, Electrical and Instrumentation and Controls Components 9
SER Section 3
Applicants Original Disposition of AMPs 12 new programs 10 consistent 2 consistent with exceptions 29 existing programs 9 consistent 17 consistent with enhancements 2 consistent with enhancements and exceptions 1 plant specific Final Disposition of AMPs in SER 12 new programs 10 consistent 2 consistent with exceptions 29 existing programs 6 consistent 19 consistent with enhancements 3 consistent with enhancements and exceptions 1 plant specific 10 3.0.3 - Aging Management Programs SER Section 3
- Time-Limited Aging Analyses (TLAAs) 4.1, Identification of TLAAs 4.2, Reactor Vessel Neutron Embrittlement 4.3, Metal Fatigue 4.4, Environmental Qualification of Electric Equipment 4.5, Concrete Containment Tendon Prestress 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis 4.7, Other Plant-Specific TLAAs 11 SER Section 4
SER Section 4.2.1: Reactor Vessel Fluence TLAA 12
- Issue:
- Applicant used unapproved methodology in reactor vessel neutron fluence TLAA
- Resolution:
- Staff approved the use of RAPTOR-M3G code (July 2018) in a license amendment
- Staff reviewed additional information supporting the adequacy of the RAPTOR-M3G code for license renewal fluence calculations
- On the basis of its review, the staff determines that the requirements of 10 CFR 54.29(a) have been met for the license renewal of WF3 13 Conclusion