ML17009A409

Waterford 3 - Responses to Request for Additional Information Set 4 Regarding the License Renewal Application

ML17009A409
Person / Time
Site:	Waterford
Issue date:	01/09/2017
From:	Chisum M R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2016-0071
Download: ML17009A409 (25)

Text

W3F1-2016-0071January 9, 2017U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, DC 20555-0001

SUBJECT:

Responses to Request for Additional Information Set 4 Regarding theLicense Renewal Application for Waterford Steam Electric Station, Unit 3(Waterford 3)Docket No. 50-382License No. NPF-38

REFERENCES:

1. Entergy letter W3F1-2016-0012 "License Renewal Application,Waterford Steam Electric Station, Unit 3" dated March 23, 2016.2. NRC letter to Entergy "Requests for Additional Information for theReview of the Waterford Steam Electric Station, Unit 3, LicenseRenewal Application - Set 4" dated October 12, 2016.3. Entergy letter W3F1-2016-0074 "Responses to Request forAdditional Information Set 5 Regarding the License RenewalApplication for Waterford Steam Electric Station, Unit 3" datedDecember 7, 2016.

Dear Sir or Madam:

By letter dated March 23, 2016, Entergy Operations, Inc. (Entergy) submitted a licenserenewal application (Reference 1).In letter dated October 12, 2016(Reference 2),the NRC staff made a Request for AdditionalInformation (RAI) Set 4, needed to complete its review. Enclosure 1 provides the responses tothe Set 4 RAIs.Also, Enclosure 2 includes a revised response to RAI 3.2.2.2-1 that supersedes the responseprovided in Reference 3, as discussed on conference call between Entergy and the NRC on12/14/2016.There are no new regulatory commitments contained in this submittal. If you requireadditional information, please contact the Regulatory Assurance Manager, John Jarrell, at504-739-6685.Entergy Operations, Inc.17265 River RoadKillona, LA 70057-3093Tel 504-739-6660Fax 504-739-6698mchisum@entergy.comMichael R. ChisumSite Vice PresidentWaterford 3 W3F1-2016-0071Page 2 of 2I declare under penalty of perjury that the foregoing is true and correct. Executed onJanuary 9, 2017.Sincerely,MRC/AJH

Enclosures:

1. Set 4 RAI Responses - Waterford 3 License Renewal Application 2. RAI 3.2.2.2-1 Revised Responsecc:Kriss KennedyRegional AdministratorU. S. Nuclear Regulatory CommissionRegion IV1600 E. Lamar Blvd.Arlington, TX 76011-4511RidsRgn4MailCenter@nrc.govNRC Senior Resident InspectorWaterford Steam Electric Station Unit 3P.O. Box 822Killona, LA 70066-0751Frances.Ramirez@nrc.govChris.Speer@nrc.govU. S. Nuclear Regulatory CommissionAttn: Phyllis ClarkDivision of License RenewalWashington, DC 20555-0001Phyllis.Clark@nrc.govU. S. Nuclear Regulatory CommissionAttn: Dr. April PulvirentiWashington, DC 20555-0001April.Pulvirenti@nrc.govLouisiana Department of EnvironmentalQualityOffice of Environmental ComplianceSurveillance DivisionP.O. Box 4312Baton Rouge, LA 70821-4312Ji.Wiley@LA.gov toW3F1-2016-0071Set 4 RAI Responses Waterford 3 License Renewal Application toW3F1-2016-0071Page 1 of 19RAI 1.16-1

Background:

Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structuresand components will be adequately managed so that the intended function(s) will be maintainedconsistent 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 andwhen evaluation of the matter in the GALL Report applies to the plant.LRA Section B.1.16 states that the Inservice Inspection - IWF Program, with enhancements, is consistentwith GALL Report Revision 2 aging management program (AMP) XI.S3, "ASME Section XI, SubsectionIWF." The "detection of aging effects" program element in GALL Report AMP XI.S3 recommends that, forhigh-strength structural bolting (actual measured yield strength greater than or equal to 150 ksi) in sizesgreater than 1 inch nominal diameter (hereafter referred to as high-strength bolting), volumetricexaminations should be performed in addition to VT-3 visual examinations to detect cracking. Thesevolumetric examinations may be waived with adequate plant-specific justification. Additionally, the GALLReport AMP XI.S3 for aging management of high-strength structural bolting recommends, in the: "scope of program," program element, the inclusion of high-strength structural bolting "preventive actions," program element, (1) the use of bolting material that has an actual measuredyield strength less than 150 ksi and (2) prohibition of the use of molybdenum disulfide (MoS2) as athread lubricant due to its potential contribution to stress corrosion cracking (SCC) "parameters monitored or inspected," program element, monitoring of high-strength structural boltingsusceptible to SCC, for crackingIssue:LRA Section B.1.16 states:[p]lant procedures prohibit the use of lubricants containing molybdenum disulfide. Sincethe use of this type of lubricant is prohibited in plant procedures and plant proceduresprovide the technical guidance for installation requirements [-], stress corrosion crackingfor high-strength structural bolting material, i.e., ASTM A325 and A490, is not plausible.While the GALL Report specifically states that the use of MoS2 lubricants as a lubricant is apotential contributor to SCC in high strength bolts, the GALL Report does not limit MoS2 threadlubricant as the only contributor to the aging mechanism for SCC in the above-mentioned highstrength bolts. Therefore, a justification to waive volumetric examinations of high-strength boltsbased solely on the prohibition of MoS2 lubricants does not fully account for high-strength bolting inenvironments conducive to SCC. Therefore, the staff has not determined that there is adequatebasis to waive volumetric examination of high-strength structural bolting (actual measured yieldstrength of 150 ksi) in sizes greater than 1 inch nominal diameter.In addition, during the audit, the staff noted that the "preventive actions" program element in the LRAprogram basis document does not discuss whether the program will specify the use of bolting material that toW3F1-2016-0071Page 2 of 19has an actual measured yield strength less than 150 ksi (1,034 MPa). For this reason, it is not clearwhether the program will prevent future use of high strength bolting material (actual measured yieldstrength greater than or equal to 150 ksi or 1,034 MPa) in sizes greater than 1 inch nominal diameter.Also, the program does not account for how aging management would be accomplished if high strengthbolting is used in the future (if it is used in areas that are conducive to SCC) as recommended by theGALL Report AMP XI.S3, for supplemental volumetric examination.Request:1. State whether high strength structural bolts (actual measured yield strength greater than or equalto 150 ksi) in sizes greater than 1 inch diameter are included within the scope of the LRA AMPB1.16, Inservice Inspection-IWF program. If so, state how the recommendations for managingdegradation of high-strength bolts (including selection of bolting material less than 150 ksi)described in the "preventive actions," "parameters monitored or inspected," and "detection of agingeffects" program elements will be implemented for the Inservice Inspection-IWF Program.2. If criteria other than those described in the GALL Report are used, provide the basis to justify theadequacy of any proposed exception to manage aging effects on high strength bolting (actualmeasured yield strength greater than or equal to 150 ksi) in sizes greater than 1 inch nominaldiameter for IWF supports, or3. Provide additional justification to waive the volumetric examinations that the GALL Reportrecommends be performed in addition to VT-3 visual examinations to detect cracking ofhigh-strength structural bolting.Waterford 3 Response1. Waterford 3 (WF3) has determined through review of site documentation (e.g. specifications,drawings, certified material requests) that there are no high-strength structural bolts with actualmeasured yield strength greater than or equal to 150 ksi in sizes greater than 1 inch diameter withinthe scope of the WF3 Inservice Inspection-IWF Program as described in LRA Section B.1.16. TheWF3 program will be consistent with the program described in NUREG-1801,Section XI.S3. Therecommendation in the "preventive actions" program element of NUREG-1801 AMP XI.S3 to considerthe effects of stress corrosion cracking (SCC) when selecting high-strength bolts is included in theWF3 Inservice Inspection - IWF Program. A program implementing procedure states:"When procuring high strength (yield strength > 150 ksi) fasteners (bolts or studs),greater than 1" nominal diameter, confirmation of actual yield strength is required. Ifactual yield strength is greater than 150 ksi, and the proposed installation will be in acorrosive environment (i.e., moisture, dissolved oxygen, sulfates, fluorides orchlorides), specify inspection/replacement requirements for the fasteners to addressthe potential for stress corrosion cracking (SCC)."2. The WF3 Inservice Inspection-IWF Program will not use criteria other than those described in NUREG1801 AMP XI.S3. See response to part 13. Volumetric examination of high-strength bolts is not necessary for the Inservice Inspection - IWFProgram. The volumetric examination of high-strength bolting susceptible to stress corrosion cracking toW3F1-2016-0071Page 3 of 19discussed in program elements 3 and 4 of NUREG-1801 AMP XI.S3 is not necessary because thereare no high-strength structural bolts with actual measured yield strength greater than or equal to 150ksi in sizes greater than 1 inch diameter in the WF3 Inservice Inspection - IWF Program. Seeresponse provided in part 1 above.ki toW3F1-2016-0071Page 4 of 19RAI B.1.28-2

Background:

LRA Section B.1.28, "One-Time Inspection," notes that the program will be used to verify that change inmaterial properties, loss of material and cracking are not occurring for reinforced concrete portions of thecirculating water intake piping exposed to raw water.During the audit, the staff reviewed a summary report prepared by Pure Technologies US, Inc. of aprevious inspection conducted on similar concrete piping in a 132-inch cooling water discharge line. Thesummary report of the Pure Technologies US, Inc. inspection noted that a majority of the pipe jointsexhibited separation and/or spalling and recommended all pipeline joints be cleaned and mortared toprevent corrosion of the joint steel and potential leaks. The report also recommended a re-inspection ofthe pipeline in approximately five years.The "Program Description" and "Scope of Program" of GALL Report AMP XI.M32 "One-Time Inspection"states, in part: "This program cannot be used for structures or components with known age-relateddegradation mechanisms or when the environment in the period of extended operation is not expected tobe equivalent to that in the prior 40 years. Periodic inspections should be proposed in these cases."Issue:The GALL Report includes AMR line items for concrete piping exposed to raw water and recommendsXI.M20, "Open-Cycle Cooling Water System," for managing the effects of aging. GALL Report AMPXI.M20 recommends periodic inspections. In addition, the Pure Technologies report recommended afollow-up inspection of similar piping in approximately five years.Based on the GALL Report recommendation in AMPs XI.M20 and XI.M32 that periodic inspections shouldbe proposed for structures or components with known age-related degradation mechanisms, and therecommendations in the Pure Technologies report for addressing observed degradation mechanism(s), itis unclear to the staff why a one-time inspection is appropriate to manage the effects of aging for concretepiping in the circulating water system. The staff also needs additional information to determine whetherthe applicant's operating experience supports the sufficiency of the LRA AMP.Request:Explain why it is appropriate to manage the effects of aging on concrete portions of the circulating waterintake piping exposed to raw water via the one-time inspection program. The response should considerthe guidance in the GALL Report AMPs for similar material and environment combinations and theoperating experience described in the Pure Technologies report, specifically the recommendation to re-inspect the piping. toW3F1-2016-0071Page 5 of 19Waterford 3 ResponseBased on results of previous inspection, Entergy has concluded that the One-Time Inspection Program isnot the most appropriate program to manage the effects of aging on concrete portions of the circulatingwater intake piping exposed to raw water. The Periodic Surveillance and Preventive MaintenanceProgram will be credited to manage the effects of aging on this piping. Inspections under the PeriodicSurveillance and Preventive Maintenance Program will occur at least once every ten years during theperiod of extended operation. A frequency of once every ten years is appropriate based on the followingfactors. The normal operating pressure in the circulating water intake piping is low. The circulating water intake piping serves a license renewal intended function only in theevent of a tornado that requires makeup from the circulating water system to the auxiliarycomponent cooling water wet cooling tower basins The interior of the piping is normally inaccessible. Access requires entry through a waterbox of the main condenser. The condition of the reinforced concrete piping was generally good.The first inspection of the reinforced concrete piping will be performed during the first five years of theperiod of extended operation.LRA revisions are as follows. Additions are underlined and deletions are lined through.LRA Sections and Tables AffectedTable 3.3.1: Auxiliary SystemsTable 3.3.2-3: Component Cooling and Auxiliary Component Cooling Water System Summary of AgingManagement EvaluationA.1.28 One-Time Inspection ProgramA.1.30 Periodic Surveillance and Preventive Maintenance ProgramB.1.28 One-Time InspectionB.1.30 Periodic Surveillance and Preventive Maintenance toW3F1-2016-0071Page 6 of 19Table 3.3.1: Auxiliary SystemsItemNumberComponentAging Effect/MechanismAging ManagementProgramsFurtherEvaluationRecommendedDiscussion3.3.1-30Concrete;cementitiousmaterialpiping, pipingcomponents,and pipingelementsexposed toraw waterChanges tomaterialproperties dueto aggressivechemicalattackChapter XI.M20,"Open-Cycle CoolingWater System"NoThe nonsafety-relatedconcrete circulatingwater intake piping(included in scope for arare tornado event) isdesigned andconstructed to AWWA C-300, -301, -302requirements resulting indense, well-cured highstrength concrete withlow permeability. Thepipe is exposed to rawwater (river water) that isnot aggressive.Consequently, changesin material properties isnot a significant agingeffect for the piping.Nevertheless, the One-Time Inspection PeriodicSurveillance andPreventive MaintenanceProgram will confirm thatunacceptabledegradation is notoccurring. toW3F1-2016-0071Page 7 of 193.3.1-31Concrete;cementitiousmaterialpiping, pipingcomponents,and pipingelementsexposed toraw waterCracking dueto settlingChapter XI.M20,"Open-Cycle CoolingWater System"NoThe nonsafety-relatedconcrete circulatingwater intake piping isincluded in scope for arare tornado event.Bedding under thispiping conforms to ClassA or Class C asspecified by theAmerican Concrete PipeAssociation whichprovides a denselycompacted backfilllimiting the potential forsettlement leading tocracking of the concretepiping. Consequently,cracking of the pipingdue to settling is not asignificant aging effectfor the piping. This isconsistent with NUREG-1800, Table 3.3.1, whichdoes not identifycracking due to settlingfor reinforced concretepiping. Nevertheless,the One-Time InspectionPeriodic Surveillanceand PreventiveMaintenance Programwill confirm thatunacceptabledegradation is notoccurring. toW3F1-2016-0071Page 8 of 193.3.1-32Reinforcedconcrete,asbestoscement piping,pipingcomponents,and pipingelementsexposed toraw waterCracking dueto aggressivechemicalattack andleaching;Changes inmaterialproperties dueto aggressivechemicalattackChapter XI.M20,"Open-Cycle CoolingWater System"NoThe nonsafety-relatedconcrete circulatingwater intake piping(included in scope for arare tornado event) isdesigned andconstructed to AWWA C-300, -301, -302requirements resulting indense, well-cured highstrength concrete withlow permeability. Thepipe is exposed to rawwater (river water) that isnot aggressive.Consequently, crackingand changes in materialproperties are notsignificant aging effectsfor the piping.Nevertheless, the One-Time Inspection PeriodicSurveillance andPreventive MaintenanceProgram will confirm thatunacceptabledegradation is notoccurring. toW3F1-2016-0071Page 9 of 193.3.1-33Concrete;cementitiousmaterialpiping, pipingcomponents,and pipingelementsexposed toraw waterLoss ofmaterial dueto abrasion,cavitation,aggressivechemicalattack, andleachingChapter XI.M20,"Open-Cycle CoolingWater System"NoThe nonsafety-relatedconcrete circulatingwater intake piping(included in scope for arare tornado event) isdesigned andconstructed to AWWA C-300, -301, -302requirements resulting indense, well-cured highstrength concrete withlow permeability. Thepipe is exposed to rawwater (river water) that isnot aggressive.Consequently, loss ofmaterial is not asignificant aging effectfor the piping.Nevertheless, the One-Time Inspection PeriodicSurveillance andPreventive MaintenanceProgram will confirm thatunacceptabledegradation is notoccurring. toW3F1-2016-0071Page 10 of 19Table 3.3.2-3Component Cooling and Auxiliary Component Cooling Water SystemSummary of Aging Management EvaluationTable 3.3.2-3: Component Cooling and Auxiliary Component Cooling Water SystemComponentTypeIntendedFunctionMaterial EnvironmentAging EffectRequiringManagementAgingManagementProgramsNUREG-1801 ItemTable1 ItemNotesPipingPressureboundaryConcrete Raw water(int)Change inmaterialpropertiesPeriodicSurveillanceandPreventiveMaintenanceOne-TimeInspectionVII.C1.AP-250VII.C1.AP-1553.3.1-303.3.1-32EPipingPressureboundaryConcrete Raw water(int)CrackingPeriodicSurveillanceandPreventiveMaintenanceOne-TimeInspectionVII.C1.AP-248VII.C1.AP-1553.3.1-313.3.1-32EPipingPressureboundaryConcrete Raw water(int)Loss ofmaterialPeriodicSurveillanceandPreventiveMaintenanceOne-TimeInspectionVII.C1.AP-2493.3.1-33EA.1.28One-Time Inspection ProgramCW intake piping internals(reinforced concrete portions)One-time inspection activity will confirm thatchange in material properties, loss of material, andcracking are not occurring or are occurring soslowly that they will not affect the componentintended function during the period of extendedoperation. toW3F1-2016-0071Page 11 of 19A.1.30Periodic Surveillance and Preventive Maintenance ProgramThe Periodic Surveillance and Preventive Maintenance (PSPM) Program manages aging effects notmanaged by other aging management programs, including change in material properties, cracking, loss ofmaterial, and reduction of heat transfer.Inspections occur at least once every 5 years during the period of extended operation, except forinspection of the circulating water intake piping. Inspection of the internal surface of the nonsafety-relatedconcrete circulating water intake piping occurs at least once every 10 years with the first inspection prior toDecember 18, 2029.Credit for program activities has been taken in the aging management review of the following systems andstructures. Inspect submersible sump pumps and backup pumps for dry cooling towers. Inspect emergency diesel generator system heat exchanger tubes. Inspect internal surface of stainless steel expansion joint in diesel exhaust. Inspect tubes and fins of the CCW dry cooling tower radiator. Inspect the internal surface of the portable UHS replenishment pump casing. Inspect the circulating water intake piping internal surface (reinforced concrete portions) Inspect the inside surface of RCP oil collection components (drip pans, enclosures, flame arrestors(tail pipe), piping, sight glass, tanks, and valve bodies). Inspect internal and external surfaces of control room HVAC portable smoke removal fan andsmoke-ejector duct.B.1.28One-Time InspectionProgram DescriptionCirculating water intake piping(reinforced concrete portions)One-time inspection activity will confirmthat change in material properties, lossof material and cracking are notoccurring or are occurring so slowly thatthey will not affect the componentintended function during the period ofextended operation. toW3F1-2016-0071Page 12 of 19B.1.30 Periodic Surveillance and Preventive MaintenanceProgram DescriptionThere is no corresponding NUREG-1801 program.The Periodic Surveillance and Preventive Maintenance (PSPM) Program includes periodic inspectionsand tests to manage aging effects not managed by other aging management programs, including changein material properties, cracking, loss of material, and reduction of heat transfer.Inspections occur at least once every 5 years during the period of extended operation, except forinspection of the circulating water intake piping. Inspection of the internal surface of the nonsafety-relatedconcrete circulating water intake piping occurs at least once every 10 years with the first inspection prior toDecember 18, 2029.Credit for program activities has been taken in the aging management review of systems, structures andcomponents as described below.SystemInspectionPlant drainsPerform a visual inspection of the surface condition of a representativesample of the submersible sump pumps and the back-up pumps for the drycooling towers.Emergency generatorsystemPerform a visual inspection of the surface condition of a representativesample of EDG cooler heat exchanger tubes to manage loss of material dueto wear.Monitor the surface condition of the expansion joint to verify the absence ofcracking due to stress corrosion/IGA.Circulating water intakepiping (reinforced concreteportions)Perform visual inspection of the internal surface of the concrete piping toconfirm that unacceptable degradation due to the effects of aging is notoccurring.Component cooling andauxiliary componentcooling water systemUse visual or other NDE techniques to inspect a representative sample ofthe tubes and fins of the CCW dry cooling tower radiator to manage loss ofmaterial and fouling that could result in a reduction of heat transfercapability.Perform a visual inspection of the internal surface of the portable UHSreplenishment pump casing to manage loss of material. toW3F1-2016-0071Page 13 of 19SystemInspectionRCP oil collection(RCPOC)Visually inspect the inside surface of RCP oil collection components(representative samples) in an environment of waste lube oil to manage lossof material.Evaluation3. Parameters Monitored/InspectedThe Periodic Surveillance and Preventive Maintenance Program monitors and inspects parameterslinked to the degradation of the particular structure or component. For example, surface conditionsof metallic components are monitored for loss of material, fouling that could result in a reduction ofheat transfer capability, cracking, and worn or flaking surfaces, while polymeric components areinspected for cracking, crazing, scuffing, dimensional changes, discoloration and hardening asevidenced by loss of suppleness.For selected metallic piping components, wall thickness is measured to determine the extent ofcorrosion caused by recurring internal corrosion mechanisms. For reinforced concrete piping,visual inspections monitor the condition of the internal surface.4. Detection of Aging EffectsPeriodic surveillance and preventive maintenance activities provide for periodic componentinspections and testing to detect aging effects. Inspection and test intervals are established suchthat they provide timely detection of degradation prior to loss of intended functions. Inspection andtest intervals, sample sizes, and data collection methods are dependent on component materialand environment, biased toward locations most susceptible to aging, and derived withconsideration of industry and plant-specific operating experience and manufacturers'recommendations.Established techniques such as visual inspections are used. Each inspection or test occurs atleast once every 5 years, except for inspection of the circulating water intake piping. Inspection ofthe internal surface of the nonsafety-related concrete circulating water intake piping occurs at leastonce every 10 years with the first inspection prior to December 18, 2029. Inspections areperformed by personnel qualified to perform the selected technique.For each activity listed above that refers to a representative sample, a representative sample is 20percent of the population (defined as components having the same material, environment, andaging effect combination) with a maximum of 25 components. toW3F1-2016-0071Page 13 of 19RAI 1.38-1

Background:

Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structuresand components will be adequately managed so that the intended function(s) will be maintainedconsistent 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 andwhen 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 GALLReport AMP XI.S6, "Structures Monitoring," recommends that high strength (actual measured yieldstrength greater than or equal to 150 ksi) structural bolts in sizes greater than 1 inch in diameter to bemonitored for stress corrosion cracking (SCC). The GALL Report also recommends that visualinspections be supplemented with volumetric or surface examinations to detect cracking for this type ofbolts.LRA Section B.1.38, "Structures Monitoring," states that the Structures Monitoring Program is an existingprogram, with enhancements, that will be consistent with GALL Report AMP XI.S6. The staff notes thatLRA 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 strengthstructural bolts. LRA Table 3.5.1, item 68, states, in part, that "since molybdenum disulfide threadlubricants are not used at WF3, for structural bolting applications, SCC of high strength structural bolting isnot an aging effect requiring management at WF3."During the AMP audit, the staff reviewed the applicant's "Aging Management Program Evaluation ReportCivil/Structural" (AMPER), implementing procedures, plant structural specifications and drawings, andnoted the following: The applicant excluded the use of supplemental examinations in high strength structural bolts andstates, 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 withvolumetric 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 A325high strength bolted friction type connections-" Structural drawings reviewed by the staff indicates the use of several types of bolts (including A325and A193 B7 types bolts), and bolts with diameter greater than 1 inch.Issue:It is not clear to the staff if "parameters monitored or inspected," and "detection of aging effects" programelements of the Structures Monitoring Program is consistent with the GALL Report recommendationbecause: toW3F1-2016-0071Page 14 of 191. The applicant's Structures Monitoring Program does not provide sufficient justification for notmanaging the aging effects of SCC in high strength structural bolting, because the GALL Reportdoes not credit the molybdenum disulfide thread lubricant as the only contributor to the agingmechanism 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 diameterare used or not in structural applications, or (2) how supplemental examinations are performed forthese bolts because the plant's structural specifications and drawings do not preclude the use ofhigh strength structural bolts with diameter greater than 1 inch when specified or noted as such inthe drawing details.Request:1. State whether or not there are high-strength structural bolts (actual measured yield strengthgreater than or equal to 150 ksi) in sizes greater than 1 inch diameter used in structuralapplications. Note: consider actual bolts being specified in the plant's structural drawing details inaddition to generic drawing notes.2. If high-strength structural bolts (actual measured yield strength greater than or equal to 150 ksi) insizes greater than 1 inch diameter are used in structural applications, state whether and how therecommendations for managing degradation of high-strength bolts described in the "parametersmonitored or inspected," and "detection of aging effects" of the GALL Report AMP XI.S6 will beimplemented for the Structures Monitoring Program. Otherwise, provide adequate technicaljustification 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 theabove requests.Waterford 3 Response1. WF3 has identified the following high-strength structural bolting with actual measured yield strengthgreater than or equal to 150 ksi in sizes greater than 1 inch diameter that are within the scope of theStructures Monitoring Program. The reactor coolant pumps (RCP), safety injection tanks (SIT) andreactor 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 MonitoringProgram by visual inspection. WF3 has determined through review of site documentation (e.g. specifications, drawing, certifiedmaterial requests, etc.) that there are no other high-strength structural bolts with actual measured yieldstrength greater than or equal to 150 ksi in sizes greater than 1 inch diameter within the scope of theStructures Monitoring Program.2. The "parameters monitored or inspected," and "detection of aging effects" program elements ofNUREG-1801 AMP XI.S6 provide recommendations for managing cracking of high-strength bolts dueto stress corrosion cracking (SCC). In the WF3 Structures Monitoring Program, theserecommendations are not necessary because the environmental conditions for SCC are not presentfor the high-strength bolting identified in Part 1 of this response. toW3F1-2016-0071Page 15 of 19NUREG-1801 AMP XI.S6 "detection of aging effects" program element states that visual inspection ofhigh-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 thatis dry and relatively cool. The A-540 bolts/studs associated with the RCP and RCS are part of the"stop supports" for these components. These components are not exposed to an aggressiveenvironment (i.e. high stress, wet environment with high oxygen levels or lubricant containingmolybdenum disulfide) conducive to SCC. The thread lubricant used for this bolting material is N-5000,Anti-Seize lubricant which is a nickel/graphite based thread lubricant not containing molybdenumdisulfide. Because these connections are in a noncorrosive, low-temperature and low-stressenvironment, stress corrosion cracking in these bolts is not expected. In addition, NUREG-1801 doesnot identify A-540 bolting material as prone to SCC. The Structures Monitoring Program inspections ofthe SIT, RCP and RCS support bolting performed at least once every five years provide reasonableassurance that environmental conditions will be maintained that are not conducive to SCC. Therefore,cracking due to SCC is not considered an aging effect requiring management for these bolts3. Consistent with the response to RAI B.1.16-1 and with the response above, LRA Table 3.5.1 items3.5.1-68 and 3.5.1-69 discussion has been revised to provide additional clarification.LRA revisions are as follows. Additions are shown with underline and deletions with strikethrough. toW3F1-2016-0071Page 16 of 19ItemNumberComponentAging Effect/MechanismAgingManagementProgramFurtherEvaluationRecommendedDiscussion 3.5.1-68High-strengthstructuralboltingCracking due tostress corrosioncrackingISI (IWF)NoWF3 does not have high-strength structural bolts withactual measured yield strengthgreater than or equal to 150ksi in sizes greater than 1 inchdiameter within the scope ofthe WF3 Inservice Inspection-IWF Program. Therefore, thelisted aging effect is not anaging effect requiringmanagement for WF3 ISI(IWF) high-strength bolting.NUREG-1801 item referencingthis item defines the boltingsusceptible to SCC as: highstrength (actual measuredyield strength greater than orequal to 150 kilo-pound persquare inch [ksi] or greaterthan or equal to 1,034 MPa)for structural bolts greater than1 inch (25 mm) in diameter.Per EPRI 1015078, aperiodically wettedenvironment and the use ofthread lubricant containingmolybdenum disulfide must bepresent to initiate SCC in highyield-strength bolting. SinceMolybdenum disulfide threadlubricants are not used atWF3, for structural boltingapplications, SCC of highstrength structural bolting isnot an aging effect requiringmanagement at WF3.3.5.1-69High-strengthstructuralboltingCracking due tostress corrosioncrackingStructuresMonitoringProgram Note:ASTM A 325, F1852, andASTM A 490bolts used incivil structureshave not shownto be prone toSCC. SCCpotential neednot beevaluated forthese bolts.NoWF3 does not have high-strength bolts that are subjectto sustained high tensile stressin a corrosive environment.As defined in this line item,ASTM A 325, F 1852, andASTM A 490 bolts used in civilstructures have not shown tobe prone to SCC. WF3procedures do not identify theuse of high strength boltsASTM A325 and A-490 forstructural applications.Therefore, the listed agingeffect is not applicable for WF3high strength bolting. toW3F1-2016-0071Page 17 of 19RAI 3.3.2.3.15.29-1

Background:

LRA Table 3.3.2-15-29, "Radiation Monitoring System, Nonsafety-Related Components AffectingSafety-Related Systems," states that aluminum filter housing exposed to waste water will be managed forloss of material using the Internal Surfaces In Miscellaneous Piping and Ducting Components program.Issue:Stress corrosion cracking (SCC) is a form of environmentally assisted cracking which is known to occur inhigh and moderate strength aluminum alloys. Halide concentrations should generally be considered highenough to facilitate cracking due to SCC of aluminum alloys in waste water unless demonstratedotherwise; however, depending on the specific aluminum alloy used for the filter housings, the aging effectof cracking due to SCC may be applicable. Without knowledge of the specific aluminum alloy, it is unclearto the staff if cracking due to SCC is an applicable aging effect for this material/environment combination.Request:Provide the basis for why cracking due to SCC is not an applicable aging effect for aluminum filter housingexposed to waste water in the "Radiation Monitoring System, Nonsafety Related Components AffectingSafety Related" system.Waterford 3 ResponseUpon further review of available documentation and consultation with the equipment supplier, Entergy hasfound that the filter housings are constructed of stainless steel. The aging effect requiring managementfor stainless steel filter housings with a waste water (int) environment is loss of material. The InternalSurfaces in Miscellaneous Piping and Ducting Components Program is the program credited for managingthis aging effect. The material type of aluminum is removed from LRA Section 3.3.2.1.15 because thereare no other component types constructed of aluminum in the auxiliary systems in scope for 10 CFR54.4(a)(2). The line items for filter housings constructed of aluminum are deleted from LRA Table 3.3.2-15-29. Line items for stainless steel filter housings are appropriately shown in LRA Table 3.3.2-15-29. The LRA is revised as follows. Deletions are shown with strikethrough. toW3F1-2016-0071Page 18 of 19LRA Sections and Tables Affected3.3.2.1.15 Auxiliary Systems in Scope for 10 CFR 54.4(a)(2)The following lists encompass materials, environments, aging effects requiring management,and aging management programs for the series 3.3.2-15-xx tables.MaterialsNonsafety-related components affecting safety-related systems are constructed of the followingmaterials.AluminumCarbon steelCopper alloyCopper alloy > 15% zinc or > 8% aluminumGlassGray cast ironPlasticStainless steel toW3F1-2016-0071Page 19 of 19Table 3.3.2-15-29Radiation Monitoring SystemNonsafety-Related Components Affecting Safety-Related SystemsSummary of Aging Management EvaluationTable 3.3.2-15-29: Radiation Monitoring System, Nonsafety-Related Components Affecting Safety-Related SystemsComponent TypeIntendedFunctionMaterialEnvironmentAging EffectRequiringManagementAgingManagementProgramNUREG-1801ItemTable 1ItemNotesBoltingPressureboundaryCarbonsteelAir - indoor(ext)Loss of material Bolting IntegrityVII.I.AP-1253.3.1-12 BBoltingPressureboundaryCarbonsteelAir - indoor(ext)Loss of preload Bolting IntegrityVII.I.AP-1243.3.1-15 BFilter housingPressureboundaryAluminumAir - indoor(ext)NoneNoneVII.J.AP-1353.3.1-113AFilter housingPressureboundaryAluminumWaste water(int)Loss of materialInternal Surfacesin MiscellaneousPiping andDuctingComponents----GFilter housingPressureboundaryStainlesssteelAir - indoor(ext)NoneNoneVII.J.AP-173.3.1-120 AFilter housingPressureboundaryStainlesssteelWaste water(int)Loss of material Internal Surfacesin MiscellaneousPiping andDuctingComponentsVII.E5.AP-278 3.3.1-95 CFilter housingPressureboundaryStainlesssteelWaste water(int)Loss of material PeriodicSurveillance andPreventiveMaintenanceVII.E5.AP-278 3.3.1-95 E toW3F1-2016-0071 RAI 3.2.2.2-1 Revised Response Waterford 3 License Renewal Application toW3F1-2016-0071Page 1 of 1RAI 3.2.2.2-1 Revised Response

Background:

Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging forstructures and components will be adequately managed so that the intended function will bemaintained consistent with the current licensing basis for the period of extended operation. Asdescribed in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications forNuclear Power Plants," an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) byreferencing the NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," and whenevaluation of the matter in the GALL Report applies to the plant.The LRA states that the Water Chemistry Control-Primary and Secondary program will be consistentwith GALL Report AMP XI.M2, "Water Chemistry." GALL Report AMP XI.M2 recommends averification of the effectiveness of the chemistry control program, such as GALL Report AMP XI.M32,"One-Time Inspection," to ensure that significant degradation is not occurring and the component'sintended function is maintained during the period of extended operation.Issue:LRA Table 3.2.2-2 states that the nickel alloy thermowell exposed to treated borated water will bemanaged by the Water Chemistry Control-Primary and Secondary program for loss of material. Theline item in question does not have a plant-specific note indicating that it will be included in the One-Time Inspection program inspection sample, as recommended byGALL Report AMP XI.M2.Request:Confirm that a one-time inspection program such as GALL Report, AMP XI.M32, "One-TimeInspection," will be used to verify the effectiveness of the Water Chemistry Control-Primary andSecondary program for managing loss of material by including the nickel alloy thermowell in theOne-Time Inspection program or provide the bases for not including the item in question in the One-Time Inspection program.Waterford 3 ResponseThe One-Time Inspection Program will verify the effectiveness of the Water Chemistry Control -Primary and Secondary Program for managing loss of material including loss of material for thenickel alloy thermowell identified in LRA Table 3.2.2-2. The description of the Water ChemistryControl - Primary and Secondary Program in Appendix B, Section B.1.41, states that the One-TimeInspection Program as described in Section B.1.28 includes inspections to verify that the WaterChemistry Control - Primary and Secondary Program has been effective at managing the effects ofaging. The description of the One-Time Inspection Program includes the aging effect of loss ofmaterial for the Water Chemistry Control - Primary and Secondary Program.The plant-specific note for using the One-Time Inspection Program to verify the effectiveness of theWater Chemistry Control - Primary and Secondary Program (Note 201) is not used in the WF3license renewal application for line items that do not have a matching NUREG-1801 line item (notable entries in columns "NUREG-1801 Item" and "Table 1 Item"). Plant-specific notes are used tohelp explain how a program compares to the NUREG-1801 program for that line item and thereforehave no purpose for line items that are not compared to NUREG-1801.