ML17054D239

Responses to Request for Additional Information Set 12 Regarding the License Renewal Application

ML17054D239
Person / Time
Site:	Waterford
Issue date:	02/23/2017
From:	Chisum M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1 -2017-0006
Download: ML17054D239 (27)

Text

Entergy Operations, Inc.

1 7265 River Road n er Killona, LA 70057-3093 Tel 504-739-6660 Fax 504-739-6698 mch isumentergy.com Michael R. Chisum Site Vice President Waterford 3 W3FI -201 7-0006 February 23, 2017 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Responses to Request for Additional Information Set 12 Regarding the License Renewal Application for Waterford Steam Electric Station, Unit 3 (Waterford 3)

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

REFERENCES:

1. Entergy letterW3Fl-2016-0012 License Renewal Application, Waterlord Steam Electric Station, Unit 3 dated March 23, 2016.

2. NRC letter to Entergy Requests for Additional Information for the Review of the Waterford Steam Electric Station, Unit 3, License Renewal Application Set 12 dated January 26, 2017.

3. Entergy letterW3Fl-2016-0071 Responses to Request for Additional Information Set 4 Regarding the License Renewal Application for Waterford Steam Electric Station, Unit 3 dated January 9, 2017.

Dear Sir or Madam:

By letter dated March 23, 2016, Entergy Operations, Inc. (Entergy) submitted a license renewal application (Reference 1).

In letter dated January 26, 201 7 (Reference 2), the NRC staff made a Request for Additional Information (RAI) Set 12, needed to complete its review. Enclosure I provides the responses to the Set I 2 RAIs. Enclosure 2 contains a revised response to RAI I .38-1 which supersedes the response originally provided in Reference 3.

There are no new regulatory commitments contained in this submittal. If you require additional information, please contact the Regulatory Assurance Manager, John Jarrell, at 504-739-6685.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 23, 2017.

Sincerely, MRC/AJH

W3F1-2017-0005 Page 2 of 2

Enclosures:

1. Set 12 RAI Responses - Waterford 3 License Renewal Application

2. RAI B.1.38-1 Revised Response cc: Kriss Kennedy RidsRgn4MailCenter@nrc.gov Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.

Arlington, TX 76011-4511 NRC Senior Resident Inspector Frances.Ramirez@nrc.gov Waterford Steam Electric Station Unit 3 Chris.Speer@nrc.gov P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Phyllis.Clark@nrc.gov Attn: Phyllis Clark Division of License Renewal Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission April.Pulvirenti@nrc.gov Attn: Dr. April Pulvirenti Washington, DC 20555-0001 Louisiana Department of Environmental Ji.Wiley@LA.gov Quality Office of Environmental Compliance Surveillance Division P.O. Box 4312 Baton Rouge, LA 70821-4312

Enclosure 1 to W3F1-2017-0006 Set 12 RAI Responses Waterford 3 License Renewal Application to W3F1-2017-0006 Page 1 of 18 RAI B.1.36-1a

Background:

The initial response to RAI B.1.36-1 did not provide sufficient bases to establish that flow blockage for the wet cooling tower (WCT) distribution nozzles does not need to be managed in the auxiliary component cooling water (ACC) system.

Issue:

1. LRA Table 2.3.3-3 lists nozzle as a component type in the ACC system but only includes pressure boundary as the intended function. The design basis document for this system (W3-DBD-4, Section 3.2.2.2) identifies these WCT components as spray nozzles, indicating that they may have additional intended functions.

2. The RAI response states that flow restriction may be an issue for spray nozzles, but states this is not considered an age-related effect and flow blockage is not an aging effect requiring management for the WCT distribution nozzles. The staff notes that biofouling of the component cooling water heat exchanger was previously identified in LER 382/1994-004, demonstrating that fouling within the ACC system has occurred. In addition, the ACC design basis document DBD-4, Section 3.2.2.2.F identifies that the original Munters spray nozzles were changed to the current Bete fog nozzles sometime afterwards. It is unclear to the staff whether the spray nozzle change was related to past operating experience issues associated with fouling or blockage.

Request:

1. Clarify the intended functions of the nozzles in the WCT. Specifically address whether these nozzles have an intended function associated with flow control or flow distribution (as defined in LRA Table 2.0-1, Component Intended Functions). If an intended function different than that stated in the LRA is identified, appropriately update the LRA and discuss how any aging effects that can adversely affect the intended function will be managed. If the intended function is only pressure boundary, provide details from the design basis information to show that the current licensing basis heat transfer will be met assuming straight flow out of the associated piping (i.e., no credit for spray or flow distribution).

2. If flow blockage will not be managed for the spray nozzles, provide additional information regarding the absence of nozzle fouling or blockage from recent inspection results.

a. address the potential for different results in the future, since aging effects for the galvanized coating on the WCT distribution piping (per FSAR Table 9.2-8) are not being managed (per WF3-ME-14-00030) and consequently may not effectively limit internal corrosion like it has in the past.

to W3F1-2017-0006 Page 2 of 18

b. provide sufficient details (isometric drawings or equivalent sketches) for the WCT distribution piping to show that all piping segments will appropriately drain, such that internal corrosion, which could promote flow blockage (similar to that discussed in Information Notice 2013-06) is not likely.

c. address the periodic wetting and drying aspect to show that accelerated corrosion (similar to that discussed in SRP-LR Section 3.2.2.2.5) is not likely.

d. explain why the original Munters spray nozzles were changed to the current Bete fog nozzles (per W3-DBD-4, Section 3.2.2.2.F) and if this change is related to past operating experience issues associated with fouling or blockage.

Waterford 3 Response

1. The wet cooling tower nozzles provide a pressure boundary and flow distribution function.

The cooling tower nozzles are designed to be clog resistant and tolerant of large particulates.

An intended function of flow control is added for these nozzles. The LRA is updated to reflect the addition of the flow control intended function and to indicate how loss of material that could result in flow blockage of these nozzles will be managed.

2. Loss of material that could result in flow blockage of the wet cooling tower nozzles will be managed.

LRA Changes The LRA Tables 2.3.3-3, 3.3.1, and 3.3.2-3 and Sections A.1.30 and B.1.30 are revised as shown below. Additions are shown with underline.

Table 2.3.3-3 Component Cooling and Auxiliary Component Cooling Water Systems Components Subject to Aging Management Review Component Type Intended Function Nozzle Flow control Pressure boundary to W3F1-2017-0006 Page 3 of 18 Table 3.3.1: Auxiliary Systems Aging Further Item Aging Effect/ Management Evaluation Number Component Mechanism Programs Recommended Discussion 3.3.1-40 Stainless steel piping, Loss of material Chapter XI.M20, No Consistent with NUREG-1801.

piping components, due to pitting and Open-Cycle Loss of material for stainless and piping elements crevice corrosion; Cooling Water steel components exposed to exposed to raw water fouling that leads to System raw water is managed by the corrosion Service Water Integrity Program. The Periodic Surveillance and Preventive Maintenance Program manages loss of material that could result in flow blockage for the wet cooling tower nozzles using periodic visual inspections.

Table 3.3.2-3: Component Cooling and Auxiliary Component Cooling Water System Aging Effect Aging Component Intended Requiring Management NUREG- Table Type Function Material Environment Management Programs 1801 Item 1 Item Notes Nozzle Flow Stainless Air - outdoor Cracking External VII.C1.AP- 3.3.1-4 A Control steel (ext) Surfaces 209 Pressure Monitoring boundary Nozzle Flow Stainless Air - outdoor Loss of External VII.C1.AP- 3.3.1-6 A Control steel (ext) material Surfaces 221 Pressure Monitoring boundary Nozzle Flow Stainless Raw water Loss of Service VII.C1.A-54 3.3.1- A Control steel (int) material Water 40 Pressure Integrity boundary Nozzle Flow Stainless Raw water Loss of Periodic VII.C1.A-54 3.3.1-40 E Control steel (int) material Surveillance Pressure and boundary Preventive Maintenance A.1.30 Periodic Surveillance and Preventive Maintenance Program Credit for program activities has been taken in the aging management review of the following systems and structures.

Inspect the wet cooling tower nozzles to W3F1-2017-0006 Page 4 of 18 B.1.30 Periodic Surveillance and Preventive Maintenance Program Description Credit for program activities has been taken in the aging management review of systems, structures and components as described below.

System Inspection Component cooling Use visual or other NDE techniques to inspect a and auxiliary representative sample of the tubes and fins of the CCW dry component cooling cooling tower radiator to manage fouling that could result in a water system reduction of heat transfer capability.

Perform a visual inspection of the internal surface of the portable UHS replenishment pump casing to manage loss of material.

Perform a visual inspection of the wet cooling tower nozzles to manage loss of material that could result in flow blockage of the nozzles.

3. Parameters Monitored/Inspected For selected metallic piping components, wall thickness is measured to determine the extent of corrosion caused by recurring internal corrosion mechanisms. For reinforced concrete piping, visual inspections monitor the condition of the internal surface. For wet cooling tower nozzles, visual inspections identify flow blockage.

to W3F1-2017-0006 Page 5 of 18 RAI B.1.36-2a

Background:

The response to RAI B.1.36-2 states that the siphon-breaker holes in the nonsafety-related chemical addition and filtration (CA&F) system were appropriately excluded from the scope of license renewal.

The response credits basin level indications and alarms to alert the plant staff, allowing them to take corrective actions to address a failure in the CA&F system that was siphoning water out of the safety-related wet cooling tower (WCT) basins. The staff notes that during some design basis events, WCT basin levels will (by design) drop below the basin alarm levels, and basin level indications will show decreasing values due to evaporation, etc. (per water requirements in UFSAR Table 9.2-10). Consequently, the plant staff would not be aware that a failure in CA&F system was siphoning water out of the basins in all circumstances.

Issue:

The staff considers that the functional separation/isolation of the nonsafety-related CA&F system relies on the passive function of the siphon-breaker holes. In addition, it is unclear to the staff why other components in the CA&F system that are either within or above the WCT basin can be excluded from the scope of license renewal.

.

Request:

1. For all of the CA&F components that are either within or above the WCT basin, provide information to show that their failure due to aging effects cannot prevent satisfactory accomplishment of an ACC intended function. Specifically address the flex hoses between the piping and the suction manifolds and any supports or attachments that stabilize any of the CA&F components. Alternatively, include the portions of the CA&F system within the scope of license renewal and update the LRA (including demonstration that the effects of aging will be adequately managed so that the intended functions will be maintained).

2. For the siphon-breaker holes in the CA&F suction piping, provide design basis documentation showing that a failure of the CA&F system could not prevent satisfactory accomplishment of an intended function for the ACCW system. Alternatively, include the siphon-breaker holes of the CA&F system within the scope of license renewal and update the LRA (including demonstration that the effects of aging will be adequately managed so that the intended functions will be maintained).

to W3F1-2017-0006 Page 6 of 18 Waterford 3 Response

1. The portions of the chemical addition and filtration (CA&F) system that are either within or above the wet cooling tower (WCT) basin comprise piping, flex hoses, and valve bodies.

Supports for the piping components are included as commodities in the structural portion of the Waterford 3 license renewal application (LRA). The Structures Monitoring Program manages the effects of aging on nonsafety-related piping supports. As described in NEI 95-10, Section 5.2.2.3, as long as the effects of aging on nonsafety-related pipe supports are managed, falling of piping sections during a seismic event is not considered credible. This consideration is applied to the CA&F piping components in the WCT basin to conclude that the piping will remain in place and not impact the function of safety-related SSCs. Therefore, the piping performs no license renewal intended function associated with 10 CFR 54.4(a)(2) through physical contact with safety-related systems, structures or components. With respect to spatial interaction, the piping performs no license renewal intended function associated with 10 CFR 54.4(a)(2) because it is in an outdoor environment where safety-related components are not susceptible to the effects of aging caused by spatial interaction. Because a flex hose is not a typical rigid piping component, the LRA is revised to indicate that the effects of aging will be managed for the flex hoses.

2. The CA&F system piping segments with the siphon breaker holes are subject to aging management review. The LRA is revised to indicate that the effects of aging will be managed so that the flow control intended function associated with the siphon breaker holes will be maintained.

The LRA Tables 2.3.3-3, 3.3.1, and 3.3.2-3 and Sections A.1.30 and B.1.30 are revised as shown below. Additions are underlined.

Table 2.3.3-3 Component Cooling and Auxiliary Component Cooling Water Systems Components Subject to Aging Management Review Component Type Intended Function Flex hose Pressure Boundary Piping Flow Control Pressure boundary to W3F1-2017-0006 Page 7 of 18 Table 3.3.1: Auxiliary Systems Further Item Aging Effect/ Aging Management Evaluation Number Component Mechanism Programs Recommended Discussion 3.3.1-134 Steel, stainless steel, Loss of material due Chapter XI.MI.M38, No Consistent with NUREG-or copper alloy piping, to general (steel and Inspection of 1801 for most piping components, copper alloy only), Internal Surfaces in components. Loss of and piping elements, pitting, crevice, and Miscellaneous material for nonsafety-and heat exchanger microbiologically Piping and Ducting related steel, stainless components exposed influenced Components steel and copper alloy to a raw water corrosion, fouling components exposed to environment (for that leads to raw water (not covered nonsafety-related corrosion by NRC GL 89-13) is components not managed by the Internal covered by NRC GL Surfaces In 89-13) Miscellaneous Piping And Ducting Components Program.

The Periodic Surveillance and Preventive Maintenance Program manages loss of material in copper alloy piping of the component cooling and auxiliary component cooling water system using periodic visual inspections.

Table 3.3.2-3: Component Cooling and Auxiliary Component Cooling Water System Aging Effect Aging Component Intended Requiring Management NUREG- Table 1 Type Function Material Environment Management Programs 1801 Item Item Notes Flex hose Pressure EPDM Raw water (int) None None -- -- F boundary Flex hose Pressure EPDM Raw water None None -- -- F boundary (ext)

Piping Flow control Copper Raw water (int) Loss of Periodic VII.C1.A-408 3.3.1- E alloy material Surveillance 134 and Preventive Maintenance Piping Flow control Copper Raw water Loss of Periodic VII.C1.A-408 3.3.1- E alloy (ext) material Surveillance 134 and Preventive Maintenance to W3F1-2017-0006 Page 8 of 18 A.1.30 Periodic Surveillance and Preventive Maintenance Program Credit for program activities has been taken in the aging management review of the following systems and structures.

• Inspect wet cooling tower chemical addition and filtration system suction piping anti-siphon holes.

B.1.30 Periodic Surveillance and Preventive Maintenance Credit for program activities has been taken in the aging management review of systems, structures and components as described below.

System Inspection Component cooling Use visual or other NDE techniques to inspect a and auxiliary representative sample of the tubes and fins of the CCW dry component cooling cooling tower radiator to manage fouling that could result in a water system reduction of heat transfer capability.

Perform a visual inspection of the internal surface of the portable UHS replenishment pump casing to manage loss of material.

Perform a visual inspection of the wet cooling tower chemical addition and filtration system suction piping anti-siphon holes to manage loss of material that could result in flow blockage.

to W3F1-2017-0006 Page 9 of 18 RAI B.1.36-6a

Background:

The response to RAI B.1.36-6 states that WF3-EP-14-00010, (AMRS report) reconciles and summarizes the results from WF3-ME-14-00009 (system AMR report for component cooling and auxiliary component cooling) and the WF-ME-00030 (topical AMR report for coatings). The response concludes that AMR items in LRA Table 3.3.2-3 are consistent with the relevant basis documents.

The AMR Summary report Section 1.2 s tates:

The AMRR results are unchanged [emphasis added] in the AMRS with the following possible exceptions.

Minor editorial changes, with no effect on the results, may be made to assure consistent use of terminology and report format. For example, words abbreviated in the AMRR may be spelled out, capitalization may be changed and in some cases the order of results presentation may be revised for consistency.

For AMRRs developed as topical reports, such as AMRR for corrosion under insulation, the AMRR results will be incorporated into the AMRS tables in a manner that best presents the information. For example, lines from the topical report AMRR may be added to the individual system tables in the AMRS [emphasis added].

Issue:

The AMR Summary report does not reflect the statements in the RAI response the AMRS report reconciles [emphasis added] and summarizes the results of the system AMR reports and the topical AMR reports. Although lines from the topical AMR report may be added to the system tables in the AMRS, (thus explaining why additional items may appear in the AMR summary tables), an explanation for the lines that have been deleted from the system AMR tables in the AMR summary tables is not provided in the basis documentation. The deletion of lines from the system AMR tables is inconsistent with the statement in the AMR Summary report that the AMRR results are unchanged in the AMRS Request:

Provide an explanation for why line items have been deleted from the tables in WF3-ME-14-00009, Aging Management Review of the Component Cooling and Auxiliary Component Cooling Water Systems, as discussed in the initial request and explain how, if not updated, the relevant basis documentation will meet the record retention requirements of 10 CFR 54.37(a).

Waterford 3 Response WF3-ME-14-00009, Revision 1, Aging Management Review of the Component Cooling and Auxiliary Component Cooling Water Systems, provides the aging management review results for the component cooling and auxiliary component cooling water systems. A separate topical aging management review report provides aging management review results for components with internal coating or lining. WF3-EP-14-00010, Revision 0, Aging Management Review Summary, the AMRS report, reconciles and summarizes the results from system aging management review reports, such as WF3-ME-14-00009, and from aging management review topical reports, such as the WF3 license to W3F1-2017-0006 Page 10 of 18 renewal topical report on coating integrity. For components such as carbon steel piping, the system aging management review report identifies carbon steel piping exposed to raw water internal and identifies an appropriate aging management program. The topical report on coating integrity identifies that this piping has an internal coating. The AMRS report modifies the piping line item that was shown as carbon steel piping to indicate that it is carbon steel with internal coating and that the Coating Integrity Program manages the effects of aging. This is the typical approach when developing the AMRS tables. The AMRS report is the basis document for the WF3 LRA tables.

WF3 LRA tables are, therefore, consistent with the relevant basis document.

The reference in the Issue section of the RAI regarding the statement in the AMR Summary report that the AMRR results are unchanged in the AMRS is lacking context. As noted under Background of the RAI, incorporation of the results of a topical aging management review report is an exception for which the AMRR results are changed. For additional clarification, WF3-EP 00010, Aging Management Review Summary, will be revised to include an example of incorporation of information from a coating topical report that results in modifying a line from a system AMR report. The example will be a change in material for a piping component type from Carbon steel to Carbon steel with internal coating. In such a case, the component type, intended function and environment would remain unchanged. The remaining columns would be revised as appropriate based on the material being Carbon steel with internal coating.

to W3F1-2017-0006 Page 11 of 18 RAI 3.5.1.74-1a

Background:

Section 54.21(a)(3) of Title 10 of the Code of Federal Regulations (10 CFR) requires applicants to demonstrate that the effects of aging for systems, structures, and components (SSCs) within the scope of license renewal and subject to an aging management review (AMR) pursuant to 10 CFR 54.21(a)(1) will be adequately managed so that intended function(s) will be maintained consistent with the current licensing basis (CLB) for the period of extended operation. The SRP-LR states that the identification of applicable aging effects based on materials, environment, and operating experience should be provided in the license renewal application (LRA) to demonstrate that the requirements of 10 CFR 54.21(a)(3) are met. The LRA Table 2 AMR items provide the detailed identification of AMRs.

In its response to RAI 3.5.1.74-1, provided by letter dated December 7, 2016, the applicant stated that Waterford 3 has not identified Lubrite sliding surfaces that are applicable to SRP-LR AMR item 3.5.1-74, but did state that Waterford 3 does have Lubrite plates associated with the reactor coolant system [RCS] that are addressed in LRA Table 3.5.1, [i]tem 75.

LRA Table 3.5.1, AMR item 3.5.1-75 states, in part, that [l]oss of material which could cause loss of mechanical function is addressed under [i]tem 3.5.1-77 related to component support members.

LRA Table 3.5.1, AMR item 3.5.1-77 states that the Structures Monitoring Program manages the listed aging effects.

Issue:

The staff notes that for SRP-LR AMR item 3.5.1-75 the Generic Aging Lessons Learned (GALL)

Report recommends GALL Report aging management program (AMP) XI.S3, ASME Section XI, Subsection IWF, to manage the potential aging effects of Class 1, 2, and 3 sliding support surfaces made of Lubrite; graphitic tool steel, fluorogold, and lubrofluor. GALL Report AMP XI.S3 contains recommendations that are not included in the Structures Monitoring Program. Examples of GALL Report AMP XI.S3 recommendations include, but are not limited to, the following:

• GALL Report AMP XI.S3 states that the American Society of Mechanical Engineers (ASME)

Code requires that a sample of ASME Class 1, 2, and 3 piping supports and supports other than piping supports (Class 1, 2, 3, and metal containment) that are not exempt from examination be examined as specified in Table IWF-2500-1, Examination Categories.

• GALL Report AMP XI.S3 includes acceptance criteria for sliding surfaces that identifies arc strikes, weld spatter, paint, scoring, roughness, or general corrosion on sliding surfaces as unacceptable conditions.

• The corrective actions program element states that identification of unacceptable conditions triggers an expansion of the inspection scope, in accordance with IWF-2430, and reexamination of the supports requiring corrective actions during the next inspection period, in accordance with IWF-2420(b). In accordance with IWF-3122, supports containing unacceptable conditions are evaluated or tested or corrected before returning to service.

to W3F1-2017-0006 Page 12 of 18 The staff notes that the applicants Structures Monitoring Program does not include several of the above and other GALL Report recommendations for age management of the identified RCS supports with Lubrite sliding surfaces. In addition, the staff notes that there are no LRA Table 2 AMR items identifying Lubrite as a material for sliding surfaces of component supports that would be subject to AMR. Based on its review of the applicants response, the LRA Structures Monitoring Program, and LRA AMR tables, it is not clear whether the Lubrite plates in the RCS are component supports applicable to the GALL Report AMP XI.S3 recommendations and, if so, whether the Structures Monitoring Program will incorporate the recommendations of GALL Report AMP XI.S3 for these components. In addition it is not clear how the criteria in 10 CFR 54.21(a)(3) and SRP-LR is being met absent the identification of Lubrite as a material subject to AMR in the LRA Table 2 AMR items.

Request:

1. State whether the Lubrite plates are ASME Code Class 1, 2, and/or 3 supports and, if so, state how the aging effects will be managed under the Structure Monitoring Program consistent with the above recommendations from the GALL Report AMP XI.S3. Provide a technical basis if recommendations from GALL Report AMP XI.S3 will not be addressed by the Structures Monitoring Program to manage the aging effects of these components.

2. For those components with Lubrite plates for which the aging effects will be managed, state how the criteria of 10 CFR 54.21(a)(3) will be met without identifying Lubrite as a material in the Table 2 AMR items.

Waterford 3 Response

1. Although Entergy has identified no aging effects requiring management for Lubrite sliding surfaces, ASME Code Class 1, 2, or 3 supports that incorporate the use of Lubrite sliding surfaces are inspected under the Inservice Inspection-IWF Program. These component supports are addressed in license renewal application (LRA) Table 3.5.1, Item 75. To clarify how the aging effects associated with license renewal application (LRA) Table 3.5.1, Item 75 (and corresponding GALL Report AMR items) will be adequately managed during the period of extended operation, the discussion in Waterford 3 (WF3) LRA Table 3.5.1, Item 75, is revised to indicate that the In-service Inspection-IWF Program manages the effects of aging on sliding surfaces.

2. Lubrite sliding surfaces, where provided, are integral to the supports and are therefore included in the inspection of those supports. Because Lubrite sliding surfaces are integral to the supports no individual line item is provided in the LRA tables. However for clarification, as stated in Response 1 above, the corresponding line item is revised.

LRA revisions are as follows. Additions are shown with underline and deletions with strikethrough.

to W3F1-2017-0006 Page 13 of 18 Table 3.5.1: Structures and Component Supports Aging Further Item Aging Effect/ Management Evaluation Number Component Mechanism Program Recommended Discussion 3.5.1-75 Sliding Loss of ISI (IWF) No NUREG-1801 item surfaces mechanical referencing this item is function due to associated with Lubrite corrosion, plates. Lubrite plates distortion, dirt, are not subject to aging debris, overload, management because wear the listed aging mechanisms are event driven and typically can be avoided though proper design. Loss of material which could cause loss of mechanical function is addressed under Item 3.5.1-77 items 3.5.1-57 and 3.5.1-91 related to component support members.

to W3F1-2017-0006 Page 14 of 18 RAI B.1.1-3a

Background:

Section 54.21(a)(3) of Title 10 of the Code of Federal Regulations (10 CFR) requires applicants to demonstrate that the effects of aging for systems, structures, and components (SSCs) within the scope of license renewal and subject to an aging management review (AMR) pursuant to 10 CFR 54.21(a)(1) will be adequately managed so that intended function(s) will be maintained consistent with the current licensing basis (CLB) for the period of extended operation.

The detection of aging effects program element of GALL Report AMP XI.M18 recommends periodic visual inspections (at least once per refueling cycle) of closure bolting for signs of leakage to ensure the detection of age-related degradation due to loss of material and loss of preload. Periodic inspection of pressure boundary components for signs of leakage ensures that age-related degradation of closure bolting is detected and corrected before component leakage becomes excessive. The staff noted that it is difficult to visually detect leakage of clear gaseous fluids and the GALL Report AMP XI.M18 does not provide specific guidance for the detection of leakage of clear gaseous fluids from a bolted connection. Therefore, by letter dated November 15, 2016, the staff issued RAI B.1.1-3 requesting that the applicant state how signs of leakage of clear gaseous fluids will be detected from bolted closures included in the Bolting Integrity Program in order to ensure the detection of loss of material and loss of preload before there is a loss of intended function. In its response to RAI B.1.1-3, provided by letter dated December 15, 2016, the applicant stated, in part, that:

[e]ffectively, bolted closures on fluid-containing systems would represent a sample of the overall bolted closure population, including bolted closures in gas-filled systems. []

[P]ersonnel can identify leakage from bolted closures through visual and audible indications.

Visual indications can include residue on nearby components and, in the case of steam systems, a visible plume or condensation in the area of the leak. Audible indications that could indicate a leak are the sounds of leaking gaseous contents escaping from the system.

In addition, system engineers review operations logs, deficiency lists, and system parameters such as pressure, flow, and temperature which could indicate a system leak. Based on these activities and considerations, signs of leakage of clear gaseous fluids are detected from bolted closures included in the Bolting Integrity Program, and ensure that the detection of loss of material and loss of preload occur before there is a loss of intended function.

Issue:

The LRA states that the applicants Bolting Integrity Program is consistent with GALL Report AMP XI.M18. The staff notes that the GALL Report AMP XI.M18 is not a sampling-based program and that the program relies on periodic inspections of all closure bolts within the scope of license renewal. From the applicants statement that fluid-containing systems would represent a sample of the overall bolted closure population, including bolted closures in gas-filled systems, it is not clear whether the applicant plans to use closure bolt degradation in fluid-filled systems as a leading indicator for degradation of closure bolting for gas-filled systems, and potentially not inspect all closure bolting as recommended by the GALL Report.

to W3F1-2017-0006 Page 15 of 18 The staff notes that for systems with gaseous fluids such as air it is unlikely that a leakage could be identified through a visual inspection and that it is also unlikely that such leakage may leave residue on nearby components that would be identifiable by a visual inspection. The staff also notes that although identification of leakage is possible through audible indications this method may not be effective for systems in areas where there is a high level of noise and also due to common requirements for the use of ear protection in those areas. Furthermore it is not clear whether all systems with gaseous fluids are subject to a review of operations logs, deficiency lists, and parameters such as pressure, flow, and temperature which could indicate a system leak. Therefore for each system with air it is not clear what method or combination of methods applies and how such method(s) would be effective to identify air leakage and ensure the detection of loss of material and loss of preload before there is a loss of intended function.

Request:

1. State whether the inspections of closure bolts under the Bolting Integrity Program will include all closure bolts in-scope of the program or if only a sample will be inspected. If an exception is taken to the GALL Report AMP XI.M18 recommendation that all in-scope closure bolting be inspected for signs of leakage to indicate loss of material and loss of preload, provide the technical basis to demonstrate that the program will adequately ensure the detection of age-related degradation before there is a loss of intended function.

2. List those systems in-scope of license renewal that contain gaseous fluids for which aging effects will be managed by the Bolting Integrity Program. For each of the systems listed state how signs of leakage of clear gaseous fluids will be detected on associated closure bolting in order to ensure the detection of age-related degradation due to loss of material and loss of preload before there is a loss of intended function.

Waterford 3 Response

1. As stated in LRA Appendix B.1.1, the Bolting Integrity Program, with one exception, will be consistent with the program described in NUREG-1801,Section XI.M18, Bolting Integrity. The Bolting Integrity Program includes all closure bolts as described in the license renewal application (LRA). The Bolting Integrity Program does not employ a sampling approach.

2. WF3 agrees that NUREG-1801 XI.M18 specifies only visual inspection for the detection of leakage of bolted connections, including bolted connections in systems with clear gaseous fluids.

Consistent with NUREG-1801,Section XI.M18, the Waterford 3 Bolting Integrity Program includes periodic inspections and preventive measures that are based on the guidance of industry documents including NUREG-1339, EPRI NP-5769, and EPRI TR-104213.

to W3F1-2017-0006 Page 16 of 18 Proper joint preparation and make-up in accordance with industry standards is expected to preclude loss of preload. The review of WF3 OE did not identify instances in which non-Class 1 mechanical components became unable to perform license renewal intended functions due to loss of pressure boundary bolting preload.

Nevertheless, the Bolting Integrity Program includes provisions to manage loss of preload, primarily in the form of preventive measures, which include material selection (e.g., use of materials with an actual yield strength of less than 150 kilo-pounds per square inch [ksi]),

lubricant selection (i.e., restricting the use of molybdenum disulfide), applying the appropriate preload (torque), and checking for uniformity of gasket compression, where appropriate, to preclude loss of preload, loss of material, and cracking.

In addition to preventive measures to preclude aging effects that could result in leakage, the program provides for identification of leakage from bolted closures included in the Bolting Integrity Program during periodic inspections conducted during system walkdowns. Other plant personnel may also identify leakage during routine maintenance and operational activities.

During these inspections and during routine operational activities, personnel can identify leakage from bolted closures through visual and audible indications. Visual indications can include residue on nearby components and, in the case of steam systems, a visible plume or condensation in the area of the leak. Audible indications that could indicate a leak are the sounds of leaking gaseous contents escaping from the system. In addition, system engineers review operations logs, deficiency lists, and system parameters such as pressure, flow, and temperature that could indicate a system leak. Low compressed air or nitrogen pressure could indicate leakage through a bolted connection. Compressed air and nitrogen systems are monitored for pressure locally and in the main control room.

Although leakage, if it occurs, may not be readily apparent from bolted closures serving some systems containing gaseous material, Waterford 3 operating experience demonstrates that the combination of preventive actions, visual inspections and observations during routine operational activities has been effective at managing the effects of aging on closure bolting. Specifically, the review of Waterford 3 operating experience found no instances in which loss of intended function of a non-Class 1 mechanical component was attributable to loss of pressure boundary bolting preload.

As indicated by review of Waterford 3 operating experience, continuation of the activities specified in the Waterford 3 Bolting Integrity Program provides reasonable assurance that the effects of aging on bolted connections in air and gas systems will be adequately managed so that the pressure boundary intended function will be maintained consistent with the current licensing basis (CLB) for the period of extended operation.

The following systems with bolted connections identified in LRA tables have internal environments of air - indoor (int), air - outdoor (int), condensation (int), or gas (int) and they credit the Bolting Integrity Program.

to W3F1-2017-0006 Page 17 of 18 Systems with Bolted Connections Identified in LRA tables Table 3.2.2-1: Containment Spray System Table 3.2.2-2: Safety Injection System Table 3.2.2-3: Containment Penetrations Table 3.3.2-1: Chemical and Volume Control System Table 3.3.2-2: Chilled Water System Table 3.3.2-3: Component Cooling and Auxiliary Component Cooling Water System Table 3.3.2-4: Compressed Air System Table 3.3.2-5: Containment Cooling HVAC System Table 3.3.2-6: Control Room HVAC System Table 3.3.2-7: Emergency Diesel Generator System Table 3.3.2-8: Fire Protection - Water System Table 3.3.2-9: Fire Protection RCP Oil Collection System Table 3.3.2-11: Nitrogen System Table 3.3.2-12: Miscellaneous HVAC Systems Table 3.3.2-13: Auxiliary Diesel Generator System Table 3.3.2-14: Plant Drains Table 3.3.2-15-3: Annulus Negative Pressure System, Nonsafety-Related Components Affecting Safety-Related Systems Table 3.3.2-15-13: Containment Atmosphere Purge System, Nonsafety-Related Components Affecting Safety-Related Systems Table 3.3.2-15-14: Containment Atmosphere Release System, Nonsafety-Related Components Affecting Safety-Related Systems Table 3.3.2-15-18: Fuel Handling Building HVAC System, Nonsafety-Related Components Affecting Safety-Related Systems Table 3.3.2-15-20: Gaseous Waste Management System, Nonsafety-Related Components Affecting Safety-Related Systems Table 3.3.2-15-22: Leak Rate Testing System, Nonsafety-Related Components Affecting Safety-Related Systems Table 3.3.2-15-24: Nitrogen System, Nonsafety-Related Components Affecting Safety-Related Systems Table 3.3.2-15-28: Primary Sampling System, Nonsafety-Related Components Affecting Safety-Related Systems Table 3.3.2-15-29: Radiation Monitoring System, Nonsafety-Related Components Affecting Safety-Related Systems Table 3.3.2-15-30: Reactor Auxiliary Building HVAC System, Nonsafety-Related Components Affecting Safety-Related Systems Table 3.3.2-15-31: Reactor Cavity Cooling System, Nonsafety-Related Components Affecting Safety-Related Systems Table 3.3.2-15-33: Secondary Sampling System, Nonsafety-Related Components Affecting Safety-Related Systems Table 3.4.2-1: Condensate Makeup and Storage System Table 3.4.2-5-6: Main Steam System, Nonsafety-Related Components Affecting Safety-Related Systems to W3F1-2017-0006 Page 18 of 18 Many of these systems are in the scope of license renewal and subject to aging management review only for 10 CFR 54.4(a)(2), that is, for the potential of nonsafety-related components to adversely impact the ability of safety-related equipment to perform its safety functions. Leakage from gas-filled portions of these systems would not be a threat to safety-related systems or components. Those portions of systems would be subject to aging management review because they have a license renewal intended function of structural support. It is not considered credible that bolted closures would experience loss of preload and become unable to fulfill the structural support function without visual indications of bolted connection degradation.

Enclosure 2 to W3F1-2017-0006 RAI B.1.38-1 Revised Response Waterford 3 License Renewal Application to W3F1-2017-0006 Page 1 of 5 RAI B.1.38-1(Revised)

Background:

Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. As described in SRP LR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

The parameters monitored or inspected, and detection of aging effects program elements of GALL Report AMP XI.S6, Structures Monitoring, recommends that high strength (actual measured yield strength greater than or equal to 150 ksi) structural bolts in sizes greater than 1 inch in diameter to be monitored for stress corrosion cracking (SCC). The GALL Report also recommends that visual inspections be supplemented with volumetric or surface examinations to detect cracking for this type of bolts.

LRA Section B.1.38, Structures Monitoring, states that the Structures Monitoring Program is an existing program, with enhancements, that will be consistent with GALL Report AMP XI.S6. The staff notes that LRA Section B.1.38 does not provide an enhancement to the parameters monitored or inspected, and/or detection of aging effects program elements to address the aging effects of SCC in high strength structural bolts. LRA Table 3.5.1, item 68, states, in part, that since molybdenum disulfide thread lubricants are not used at WF3, for structural bolting applications, SCC of high strength structural bolting is not an aging effect requiring management at WF3.

During the AMP audit, the staff reviewed the applicants Aging Management Program Evaluation Report Civil/Structural (AMPER), implementing procedures, plant structural specifications and drawings, and noted the following:

• The applicant excluded the use of supplemental examinations in high strength structural bolts and states, in part, that since a thread lubricant containing molybdenum disulfide is not used at WF3, SCC of structural bolting in not plausible, inspections are not required to be supplemented with volumetric or surface examinations. (AMPER Section 3.4.2.b)

• Plant structural specification LOU 1564.723, Structural Steel Seismic I & II, states, in part, that field connections shall be friction type joints, assembled with 7/8 diameter high-strength bolts, unless otherwise noted on drawings

• Plant drawings notes, in general, stated that field connections, unless noted, shall be ASTM A325 high strength bolted friction type connections

• Structural drawings reviewed by the staff indicates the use of several types of bolts (including A325 and A193 B7 types bolts), and bolts with diameter greater than 1 inch.

to W3F1-2017-0006 Page 2 of 5 Issue:

It is not clear to the staff if parameters monitored or inspected, and detection of aging effects program elements of the Structures Monitoring Program is consistent with the GALL Report recommendation because:

1. The applicants Structures Monitoring Program does not provide sufficient justification for not managing the aging effects of SCC in high strength structural bolting, because the GALL Report does not credit the molybdenum disulfide thread lubricant as the only contributor to the aging mechanism of SCC in high strength bolts.

2. It is not clear to the staff (1) whether high strength structural bolts greater than 1 inch in diameter are used or not in structural applications, or (2) how supplemental examinations are performed for these bolts because the plants structural specifications and drawings do not preclude the use of high strength structural bolts with diameter greater than 1 inch when specified or noted as such in the drawing details.

Request:

1. State whether or not there are high-strength structural bolts (actual measured yield strength greater than or equal to 150 ksi) in sizes greater than 1 inch diameter used in structural applications. Note: consider actual bolts being specified in the plants structural drawing details in addition to generic drawing notes.

2. If high-strength structural bolts (actual measured yield strength greater than or equal to 150 ksi) in sizes greater than 1 inch diameter are used in structural applications, state whether and how the recommendations for managing degradation of high-strength bolts described in the parameters monitored or inspected, and detection of aging effects of the GALL Report AMP XI.S6 will be implemented for the Structures Monitoring Program. Otherwise, provide adequate technical justification for the exception taken to the GALL Report AMP recommendation.

3. Update the LRA and FSAR supplement, as appropriate, to be consistent with the response to the above requests.

Waterford 3 Response

1. WF3 has identified the following high-strength structural bolting with actual measured yield strength greater than or equal to 150 ksi in sizes greater than 1 inch diameter that is within the scope of the Structures Monitoring Program. The reactor coolant pumps (RCP), safety injection tanks (SIT) and reactor coolant system (RCS) supports have bolting consisting of ASTM A-540 threaded bolts/studs. These bolts/studs with minimum yield strength of 150 ksi are monitored in the Structures Monitoring Program by visual inspection.

WF3 has determined through review of site documentation (specifications, drawing, certified material requests, etc.) that there are no other high-strength structural bolts with actual measured yield strength greater than or equal to 150 ksi in sizes greater than 1 inch diameter within the scope of the Structures Monitoring Program.

to W3F1-2017-0006 Page 3 of 5

2. The parameters monitored or inspected, and detection of aging effects program elements of NUREG-1801 AMP XI.S6 provide recommendations for managing cracking of high-strength bolts due to stress corrosion cracking (SCC). In the WF3 Structures Monitoring Program, these recommendations are not necessary because the environmental conditions for SCC are not present for the high-strength bolting identified in Part 1 of this response.

NUREG-1801 AMP XI.S6 detection of aging effects program element states that visual inspection of high-strength bolting is supplemented with volumetric or surface examination to detect cracking. Justification for waiving volumetric and surface examination of WF3 high-strength bolting follows.

The A-540 bolts/studs associated with each SIT are in an area outside the secondary shield walls that is dry and relatively cool. The A-540 bolts/studs associated with the RCP and RCS are part of the stop supports for these components. This bolting is located inside the steel containment vessel and the components are not exposed to an aggressive environment (i.e. high stress, wet environment with high oxygen levels or lubricant containing molybdenum disulfide) conducive to SCC. The Boric Acid Corrosion Program provides for inspections during each refueling outage to identify borated water leakage and ensure that corrosion caused by leaking borated water does not lead to unacceptable degradation of the leakage source or adjacent structures or components. Inspections are also conducted inside containment prior to startup from each refueling to ensure no adverse conditions exist that would result in a change to the normal operating environment. The thread lubricant used for this bolting material is N-5000, Anti-Seize lubricant which is a nickel/graphite-based thread lubricant not containing molybdenum disulfide. A review of operating records concluded that lubricants containing molybdenum disulfide have never been used for this bolting. Because these connections are in a noncorrosive and low-temperature environment, stress corrosion cracking in these bolts is not expected. The Structures Monitoring Program and Boric Acid Corrosion Program inspections of the SIT, RCP and RCS support bolting, performed at least once every five years and once every refueling outage respectively, provide reasonable assurance that environmental conditions will be maintained that are not conducive to SCC. Therefore, cracking due to SCC is not an aging effect requiring management for these bolts.

3. Consistent with the response to RAI B.1.16-1 and with the response above, LRA Table 3.5.1 items 3.5.1-68 and 3.5.1-69 discussion, related Table 2.4-1 and Table 3.5.2-1 are revised.

LRA revisions are as follows. Additions are shown with underline and deletions with strikethrough.

LRA Table 2.4-1:

Reactor Building Components Subject to Aging Management Review Component Intended Function Steel and Other Metals High-strength bolting (RCP,RCS and SIT) Support for Criterion (a)(1) equipment

Enclosure 2 to W3F1-2017-0006 Page 4 of 5 LRA Table 3.5.1: Structures and Component Supports Aging Further Item Aging Effect/ Management Evaluation Number Component Mechanism Program Recommended Discussion 3.5.1-68 High-strength Cracking due to ISI (IWF) No WF3 does not have high-structural stress corrosion strength structural bolts with bolting cracking actual measured yield strength greater than or equal to 150 ksi in sizes greater than 1 inch diameter within the scope of the WF3 Inservice Inspection-IWF Program.

NUREG-1801 item referencing this item defines the bolting susceptible to SCC as: high strength (actual measured yield strength greater than or equal to 150 kilo-pound per square inch [ksi] or greater than or equal to 1,034 MPa) for structural bolts greater than 1 inch (25 mm) in diameter.

Per EPRI 1015078, a periodically wetted environment and the use of thread lubricant containing molybdenum disulfide must be present to initiate SCC in high yield-strength bolting. Since Molybdenum disulfide thread lubricants are not used at WF3, for structural bolting applications, SCC of high strength structural bolting is not an aging effect requiring management at WF3.

Enclosure 2 to W3F1-2017-0006 Page 5 of 5 3.5.1-69 High-strength Cracking due to Structures No WF3 does not have high-structural stress corrosion Monitoring strength bolts that are subject bolting cracking Program Note: to sustained high tensile stress ASTM A 325, F in a corrosive environment.

1852, and As defined for bolting in this ASTM A 490 line item, ASTM A 325, bolts used in F 1852, and ASTM A 490 bolts civil structures used in civil structures have have not shown not shown to be prone to SCC.

to be prone to However, WF3 has identified SCC. SCC ASTM A-540 structural bolting potential need with yield stress greater than not be or equal to 150 ksi. This evaluated for bolting is not subject to high these bolts. temperature and a corrosive environment. WF3 procedures do not identify the use of high strength bolts ASTM A325 and A-490 for structural applications. Therefore, the listed aging effect is not applicable for WF3 high strength bolting. Nevertheless, the Boric Acid Corrosion and Structures Monitoring Programs will be used to manage aging effects for this bolting.

LRA Table 3.5.2-1: Reactor Building Structure and/or Aging Effect Aging Component or Intended Requiring Management NUREG-1801 Table 1 Commodity Function Material Environment Management Program Item Item Notes High-strength SSR Carbon Air - indoor Cracking Boric Acid III.B.5.TP-300 3.5.1-69 E bolting (RCP,RCS steel uncontrolled Corrosion and SIT supports)

Structures Monitoring