ML17054D239

Waterford 3 - 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 R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1 -2017-0006
Download: ML17054D239 (27)

Text

W3F1-2017-0005Page 2 of 2

Enclosures:

1. Set 12 RAI Responses - Waterford 3 License Renewal Application 2. RAI B.1.38-1 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 Environmental QualityOffice of Environmental ComplianceSurveillance DivisionP.O. Box 4312Baton Rouge, LA 70821-4312Ji.Wiley@LA.gov toW3F1-2017-0006Set 12 RAI Responses Waterford 3 License Renewal Application toW3F1-2017-0006Page 1 of 18RAI B.1.36-1a

Background:

The initial response to RAI B.1.36-1 did not provide sufficient bases to establish that flow blockagefor the wet cooling tower (WCT) distribution nozzles does not need to be managed in the auxiliarycomponent 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," indicatingthat they may have additional intended functions.2. The RAI response states that flow restriction may be an issue for spray nozzles, but statesthis is not considered an age-related effect and flow blockage is not an aging effect requiringmanagement for the WCT distribution nozzles. The staff notes that biofouling of thecomponent 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 designbasis document DBD-4, Section 3.2.2.2.F identifies that the original Munters spray nozzleswere changed to the current Bete fog nozzles sometime afterwards. It is unclear to the staffwhether the spray nozzle change was related to past operating experience issues associatedwith fouling or blockage.Request:1. Clarify the intended functions of the nozzles in the WCT. Specifically address whether thesenozzles have an intended function associated with "flow control" or "flow distribution" (asdefined in LRA Table 2.0-1, "Component Intended Functions-"). If an intended functiondifferent than that stated in the LRA is identified, appropriately update the LRA and discusshow any aging effects that can adversely affect the intended function will be managed. If theintended function is only "pressure boundary," provide details from the design basisinformation to show that the current licensing basis heat transfer will be met assumingstraight 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 informationregarding 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 thegalvanized coating on the WCT distribution piping (per FSAR Table 9.2-8) are notbeing managed (per WF3-ME-14-00030) and consequently may not effectively limitinternal corrosion like it has in the past. toW3F1-2017-0006Page 2 of 18 b.provide sufficient details (isometric drawings or equivalent sketches) for the WCTdistribution piping to show that all piping segments will appropriately drain, such thatinternal corrosion, which could promote flow blockage (similar to that discussed inInformation 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 fognozzles (per W3-DBD-4, Section 3.2.2.2.F) and if this change is related to pastoperating experience issues associated with fouling or blockage.Waterford 3 Response1. 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 reflectthe addition of the flow control intended function and to indicate how loss of material thatcould 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 bemanaged.LRA ChangesThe 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 shownbelow. Additions are shown with underline.Table 2.3.3-3Component Cooling and Auxiliary Component Cooling Water SystemsComponents Subject to Aging Management ReviewComponent TypeIntended FunctionNozzleFlow controlPressure boundary toW3F1-2017-0006Page 3 of 18Table 3.3.1:Auxiliary SystemsItemNumberComponentAging Effect/Mechanism AgingManagementProgramsFurtherEvaluationRecommendedDiscussion3.3.1-40 Stainless steel piping,piping components,and piping elementsexposed to raw waterLoss of materialdue to pitting andcrevice corrosion;fouling that leads to corrosionChapter XI.M20,"Open-CycleCooling WaterSystem"NoConsistent with NUREG-1801.Loss of material for stainlesssteel components exposed toraw water is managed by theService Water IntegrityProgram. The PeriodicSurveillance and PreventiveMaintenance Program managesloss of material that could resultin flow blockage for the wetcooling tower nozzles usingperiodic visual inspections.Table 3.3.2

-3: Component Cooling and Auxiliary Component Cooling Water SystemComponentTypeIntendedFunction Material EnvironmentAging EffectRequiringManagement AgingManagementProgramsNUREG-1801 ItemTable1 Item NotesNozzleFlowControlPressureboundaryStainlesssteelAir - outdoor(ext)CrackingExternalSurfacesMonitoringVII.C1.AP-2093.3.1-4 ANozzleFlowControlPressureboundaryStainlesssteelAir - outdoor(ext)Loss ofmaterialExternalSurfacesMonitoringVII.C1.AP-2213.3.1-6 ANozzleFlowControlPressureboundaryStainlesssteelRaw water(int)Loss ofmaterialServiceWaterIntegrityVII.C1.A-54 3.3.1-40ANozzleFlowControlPressureboundaryStainlesssteelRaw water(int)Loss ofmaterialPeriodicSurveillance andPreventiveMaintenanceVII.C1.A-543.3.1-40EA.1.30 Periodic Surveillance and Preventive Maintenance ProgramCredit for program activities has been taken in the aging management review of the followingsystems and structures.Inspect the wet cooling tower nozzles toW3F1-2017-0006Page 4 of 18B.1.30 Periodic Surveillance and Preventive MaintenanceProgram DescriptionCredit for program activities has been taken in the aging management review of systems, structuresand components as described below.SystemInspectionComponent coolingand auxiliarycomponent coolingwater systemUse visual or other NDE techniques to inspect arepresentative sample of the tubes and fins of the CCW drycooling tower radiator to manage fouling that could result in areduction of heat transfer capability.Perform a visual inspection of the internal surface of theportable UHS replenishment pump casing to manage loss ofmaterial.Perform a visual inspection of the wet cooling tower nozzles tomanage loss of material that could result in flow blockage of the nozzles.

3.Parameters Monitored/InspectedFor selected metallic piping components, wall thickness is measured to determine the extent ofcorrosion caused by recurring internal corrosion mechanisms. For reinforced concrete piping, visualinspections monitor the condition of the internal surface. For wet cooling tower nozzles, visualinspections identify flow blockage. toW3F1-2017-0006Page 5 of 18RAI B.1.36-2a

Background:

The response to RAI B.1.36-2 states that the siphon-breaker holes in the nonsafety-related chemicaladdition 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 takecorrective actions to address a failure in the CA&F system that was siphoning water out of thesafety-related wet cooling tower (WCT) basins. The staff notes that during some design basisevents, WCT basin levels will (by design) drop below the basin alarm levels, and basin levelindications will show decreasing values due to evaporation, etc. (per water requirements in UFSARTable 9.2-10). Consequently, the plant staff would not be aware that a failure in CA&F system wassiphoning water out of the basins in all circumstances.

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

.Request:1. For all of the CA&F components that are either within or above the WCT basin, provideinformation to show that their failure due to aging effects cannot prevent satisfactoryaccomplishment of an ACC intended function. Specifically address the flex hoses betweenthe piping and the suction manifolds and any supports or attachments that stabilize any of theCA&F components. Alternatively, include the portions of the CA&F system within the scopeof license renewal and update the LRA (including demonstration that the effects of aging willbe adequately managed so that the intended functions will be maintained).2. For the siphon-breaker holes in the CA&F suction piping, provide design basisdocumentation showing that a failure of the CA&F system could not prevent satisfactoryaccomplishment of an intended function for the ACCW system. Alternatively, include thesiphon-breaker holes of the CA&F system within the scope of license renewal and update theLRA (including demonstration that the effects of aging will be adequately managed so thatthe intended functions will be maintained). toW3F1-2017-0006Page 6 of 18Waterford 3 Response1. The portions of the chemical addition and filtration (CA&F) system that are either within orabove 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 theWaterford 3 license renewal application (LRA). The Structures Monitoring Program managesthe effects of aging on nonsafety-related piping supports. As described in NEI 95-10, Section5.2.2.3, as long as the effects of aging on nonsafety-related pipe supports are managed, fallingof piping sections during a seismic event is not considered credible. This consideration isapplied to the CA&F piping components in the WCT basin to conclude that the piping will remainin place and not impact the function of safety-related SSCs. Therefore, the piping performs nolicense renewal intended function associated with 10 CFR 54.4(a)(2) through physical contactwith safety-related systems, structures or components. With respect to spatial interaction, thepiping 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 tothe effects of aging caused by spatial interaction. Because a flex hose is not a typical rigidpiping component, the LRA is revised to indicate that the effects of aging will be managed forthe flex hoses.2. The CA&F system piping segments with the siphon breaker holes are subject to agingmanagement review. The LRA is revised to indicate that the effects of aging will be managedso that the flow control intended function associated with the siphon breaker holes will bemaintained.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 shownbelow. Additions are underlined.Table 2.3.3-3Component Cooling and Auxiliary Component Cooling Water SystemsComponents Subject to Aging Management ReviewComponent TypeIntended FunctionFlex hosePressure BoundaryPipingFlow ControlPressure boundary toW3F1-2017-0006Page 7 of 18Table 3.3.1:Auxiliary SystemsItemNumberComponentAging Effect/MechanismAging ManagementProgramsFurtherEvaluationRecommendedDiscussion3.3.1-134Steel, stainless steel,or copper alloy piping,piping components,and piping elements,and heat exchangercomponents exposedto a raw waterenvironment (fornonsafety-relatedcomponents notcovered by NRC GL89-13)Loss of material dueto general (steel andcopper alloy only),pitting, crevice, andmicrobiologicallyinfluencedcorrosion, foulingthat leads tocorrosionChapter XI.MI.M38,"Inspection ofInternal Surfaces inMiscellaneousPiping and DuctingComponents" NoConsistent with NUREG-1801 for mostcomponents. Loss ofmaterial for nonsafety-related steel, stainlesssteel and copper alloycomponents exposed toraw water (not coveredby NRC GL 89-13) ismanaged by the InternalSurfaces InMiscellaneous PipingAnd DuctingComponents Program.The PeriodicSurveillance andPreventive MaintenanceProgram manages lossof material in copperalloy piping of thecomponent cooling andauxiliary componentcooling water systemusing periodic visualinspections.Table 3.3.2-3: Component Cooling and Auxiliary Component Cooling Water SystemComponentTypeIntendedFunctionMaterialEnvironmentAging EffectRequiringManagementAgingManagementProgramsNUREG-1801 ItemTable 1ItemNotesFlex hosePressureboundaryEPDMRaw water (int)NoneNone----FFlex hosePressureboundaryEPDMRaw water(ext)NoneNone----FPipingFlow controlCopperalloyRaw water (int)Loss ofmaterialPeriodicSurveillanceand PreventiveMaintenanceVII.C1.A-4083.3.1-134EPipingFlow controlCopperalloyRaw water(ext)Loss ofmaterialPeriodicSurveillanceand PreventiveMaintenanceVII.C1.A-4083.3.1-134E toW3F1-2017-0006Page 8 of 18A.1.30 Periodic Surveillance and Preventive Maintenance ProgramCredit for program activities has been taken in the aging management review of the followingsystems and structures. Inspect wet cooling tower chemical addition and filtration system suction piping anti-siphon holes.B.1.30 Periodic Surveillance and Preventive MaintenanceCredit for program activities has been taken in the aging management review of systems,structures and components as described below.SystemInspectionComponent coolingand auxiliarycomponent coolingwater systemUse visual or other NDE techniques to inspect arepresentative sample of the tubes and fins of the CCW drycooling tower radiator to manage fouling that could result in areduction of heat transfer capability.Perform a visual inspection of the internal surface of theportable UHS replenishment pump casing to manage loss ofmaterial.Perform a visual inspection of the wet cooling tower chemicaladdition and filtration system suction piping anti-siphon holesto manage loss of material that could result in flow blockage. toW3F1-2017-0006Page 9 of 18RAI B.1.36-6a

Background:

The response to RAI B.1.36-6 states that WF3-EP-14-00010, (AMRS report) reconciles andsummarizes the results from WF3-ME-14-00009 (system AMR report for component cooling andauxiliary component cooling) and the WF-ME-00030 (topical AMR report for coatings). Theresponse concludes that AMR items in LRA Table 3.3.2-3 are consistent with the relevant basisdocuments.The AMR Summary report Section 1.2 s tates:

"The AMRR results are unchanged [emphasis added] in the AMRS with the followingpossible exceptions.Minor editorial changes, with no effect on the results, may be made to assure consistent useof terminology and report format. For example, words abbreviated in the AMRR may bespelled out, capitalization may be changed and in some cases the order of resultspresentation may be revised for consistency.For AMRRs developed as topical reports, such as AMRR for corrosion under insulation, theAMRR results will be incorporated into the AMRS tables in a manner that best presents theinformation. For example, lines from the topical report AMRR may be added to the individualsystem tables in the AMRS [emphasis added].Issue:The AMR Summary report does not reflect the statements in the RAI response "the AMRS reportreconciles [emphasis added] and summarizes the results" of the system AMR reports and the topicalAMR reports. Although lines from the topical AMR report may be added to the system tables in theAMRS, (thus explaining why additional items may appear in the AMR summary tables), anexplanation for the lines that have been deleted from the system AMR tables in the AMR summarytables is not provided in the basis documentation. The deletion of lines from the system AMR tablesis inconsistent with the statement in the AMR Summary report that "the AMRR results areunchanged 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 WaterSystems," as discussed in the initial request and explain how, if not updated, the relevant basisdocumentation will meet the record retention requirements of 10 CFR 54.37(a).Waterford 3 ResponseWF3-ME-14-00009, Revision 1, "Aging Management Review of the Component Cooling andAuxiliary Component Cooling Water Systems," provides the aging management review results forthe component cooling and auxiliary component cooling water systems. A separate topical agingmanagement review report provides aging management review results for components with internalcoating or lining. WF3-EP-14-00010, Revision 0, "Aging Management Review Summary," the AMRSreport, reconciles and summarizes the results from system aging management review reports, suchas WF3-ME-14-00009, and from aging management review topical reports, such as the WF3 license toW3F1-2017-0006Page 10 of 18renewal topical report on coating integrity. For components such as carbon steel piping, the systemaging management review report identifies carbon steel piping exposed to raw water internal andidentifies an appropriate aging management program. The topical report on coating integrityidentifies that this piping has an internal coating. The AMRS report modifies the piping line item thatwas shown as carbon steel piping to indicate that it is carbon steel with internal coating and that theCoating Integrity Program manages the effects of aging. This is the typical approach whendeveloping 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 reportthat "the AMRR results are unchanged in the AMRS-" is lacking context. As noted underBackground of the RAI, incorporation of the results of a topical aging management review report isan exception for which the AMRR results are changed. For additional clarification, WF3-EP-14-00010, "Aging Management Review Summary," will be revised to include an example ofincorporation of information from a coating topical report that results in modifying a line from asystem 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, intendedfunction and environment would remain unchanged. The remaining columns would be revised asappropriate based on the material being "Carbon steel with internal coating." toW3F1-2017-0006Page 11 of 18RAI 3.5.1.74-1a

Background:

Section 54.21(a)(3) of Title 10 of the Code of Federal Regulations (10 CFR) requires applicants todemonstrate that the effects of aging for systems, structures, and components (SSCs) within thescope of license renewal and subject to an aging management review (AMR) pursuant to10 CFR 54.21(a)(1) will be adequately managed so that intended function(s) will be maintainedconsistent with the current licensing basis (CLB) for the period of extended operation. The SRP-LRstates that the identification of applicable aging effects based on materials, environment, andoperating experience should be provided in the license renewal application (LRA) to demonstratethat the requirements of 10 CFR 54.21(a)(3) are met. The LRA Table 2 AMR items provide thedetailed identification of AMRs.In its response to RAI 3.5.1.74-1, provided by letter dated December 7, 2016, the applicant statedthat Waterford 3 has not identified Lubrite sliding surfaces that are applicable to SRP-LR AMR item3.5.1-74, but did state that "Waterford 3 does have Lubrite plates associated with the reactorcoolant 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 ofmechanical 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 thelisted 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 surfacesmade of Lubrite; graphitic tool steel, fluorogold, and lubrofluor. GALL Report AMP XI.S3 containsrecommendations that are not included in the Structures Monitoring Program. Examples of GALLReport 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 thanpiping supports (Class 1, 2, 3, and metal containment) that are not exempt from examination beexamined as specified in Table IWF-2500-1, "Examination Categories." GALL Report AMP XI.S3 includes acceptance criteria for sliding surfaces that identifies arcstrikes, weld spatter, paint, scoring, roughness, or general corrosion on sliding surfaces asunacceptable conditions.The "corrective actions" program element states that identification of unacceptable conditionstriggers an expansion of the inspection scope, in accordance with IWF-2430, and reexaminationof the supports requiring corrective actions during the next inspection period, in accordance withIWF-2420(b). In accordance with IWF-3122, supports containing unacceptable conditions areevaluated or tested or corrected before returning to service. toW3F1-2017-0006Page 12 of 18The staff notes that the applicant's Structures Monitoring Program does not include several of theabove and other GALL Report recommendations for age management of the identified RCSsupports with Lubrite sliding surfaces. In addition, the staff notes that there are no LRA Table 2AMR items identifying Lubrite as a material for sliding surfaces of component supports that wouldbe subject to AMR. Based on its review of the applicant's response, the LRA Structures MonitoringProgram, and LRA AMR tables, it is not clear whether the Lubrite plates in the RCS are componentsupports applicable to the GALL Report AMP XI.S3 recommendations and, if so, whether theStructures Monitoring Program will incorporate the recommendations of GALL Report AMP XI.S3 forthese components. In addition it is not clear how the criteria in 10 CFR 54.21(a)(3) and SRP-LR isbeing 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, statehow the aging effects will be managed under the Structure Monitoring Program consistent withthe above recommendations from the GALL Report AMP XI.S3. Provide a technical basis ifrecommendations from GALL Report AMP XI.S3 will not be addressed by the StructuresMonitoring Program to manage the aging effects of these components.2. For those components with Lubrite plates for which the aging effects will be managed, statehow the criteria of 10 CFR 54.21(a)(3) will be met without identifying Lubrite as a material in theTable 2 AMR items.Waterford 3 Response 1.Although Entergy has identified no aging effects requiring management for Lubrite slidingsurfaces, ASME Code Class 1, 2, or 3 supports that incorporate the use of Lubrite slidingsurfaces are inspected under the Inservice Inspection-IWF Program. These component supportsare addressed in license renewal application (LRA) Table 3.5.1, Item 75. To clarify how the agingeffects associated with license renewal application (LRA) Table 3.5.1, Item 75 (andcorresponding GALL Report AMR items) will be adequately managed during the period ofextended operation, the discussion in Waterford 3 (WF3) LRA Table 3.5.1, Item 75, is revised toindicate that the In-service Inspection-IWF Program manages the effects of aging on slidingsurfaces.2. Lubrite sliding surfaces, where provided, are integral to the supports and are therefore includedin the inspection of those supports. Because Lubrite sliding surfaces are integral to thesupports no individual line item is provided in the LRA tables. However for clarification, as statedin Response 1 above, the corresponding line item is revised. LRA revisions are as follows. Additions are shown with underline and deletions withstrikethrough. toW3F1-2017-0006Page 13 of 18Table 3.5.1: Structures and Component SupportsItemNumber ComponentAging Effect/MechanismAgingManagementProgramFurtherEvaluationRecommendedDiscussion 3.5.1-75 SlidingsurfacesLoss ofmechanicalfunction due tocorrosion,distortion, dirt,debris, overload, wearISI (IWF)

NoNUREG-1801 itemreferencing this item isassociated with Lubriteplates. Lubrite platesare not subject to agingmanagement becausethe listed agingmechanisms are eventdriven and typically canbe avoided though properdesign. Loss of materialwhich could cause loss ofmechanical function isaddressed under Item3.5.1-77 items 3.5.1-57and 3.5.1-91 related tocomponent supportmembers. toW3F1-2017-0006Page 14 of 18RAI B.1.1-3a

Background:

Section 54.21(a)(3) of Title 10 of the Code of Federal Regulations (10 CFR) requires applicants todemonstrate that the effects of aging for systems, structures, and components (SSCs) within thescope of license renewal and subject to an aging management review (AMR) pursuant to10 CFR 54.21(a)(1) will be adequately managed so that intended function(s) will be maintainedconsistent 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 periodicvisual inspections (at least once per refueling cycle) of closure bolting for signs of leakage to ensurethe detection of age-related degradation due to loss of material and loss of preload. Periodicinspection of pressure boundary components for signs of leakage ensures that age-relateddegradation of closure bolting is detected and corrected before component leakage becomesexcessive. The staff noted that it is difficult to visually detect leakage of clear gaseous fluids and theGALL Report AMP XI.M18 does not provide specific guidance for the detection of leakage of cleargaseous fluids from a bolted connection. Therefore, by letter dated November 15, 2016, the staffissued RAI B.1.1-3 requesting that the applicant state how signs of leakage of clear gaseous fluidswill be detected from bolted closures included in the Bolting Integrity Program in order to ensure thedetection of loss of material and loss of preload before there is a loss of intended function. In itsresponse 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 theoverall 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 steamsystems, a visible plume or condensation in the area of the leak. Audible indications thatcould 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 parameterssuch as pressure, flow, and temperature which could indicate a system leak. Based on theseactivities and considerations, signs of leakage of clear gaseous fluids are detected frombolted closures included in the Bolting Integrity Program, and ensure that the detection ofloss of material and loss of preload occur before there is a loss of intended function.Issue:The LRA states that the applicant's Bolting Integrity Program is consistent with GALL ReportAMP XI.M18. The staff notes that the GALL Report AMP XI.M18 is not a sampling-based programand that the program relies on periodic inspections of all closure bolts within the scope of licenserenewal. From the applicant's statement that "fluid-containing systems would represent a sample ofthe overall bolted closure population, including bolted closures in gas-filled systems," it is not clearwhether the applicant plans to use closure bolt degradation in fluid-filled systems as a leadingindicator for degradation of closure bolting for gas-filled systems, and potentially not inspect allclosure bolting as recommended by the GALL Report. toW3F1-2017-0006Page 15 of 18The staff notes that for systems with gaseous fluids such as air it is unlikely that a leakage could beidentified through a visual inspection and that it is also unlikely that such leakage may leave residueon nearby components that would be identifiable by a visual inspection. The staff also notes thatalthough identification of leakage is possible through audible indications this method may not beeffective for systems in areas where there is a high level of noise and also due to commonrequirements for the use of ear protection in those areas. Furthermore it is not clear whether allsystems with gaseous fluids are subject to a review of operations logs, deficiency lists, andparameters such as pressure, flow, and temperature which could indicate a system leak. Thereforefor each system with air it is not clear what method or combination of methods applies and how suchmethod(s) would be effective to identify air leakage and ensure the detection of loss of material andloss 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 allclosure bolts in-scope of the program or if only a sample will be inspected. If an exception istaken to the GALL Report AMP XI.M18 recommendation that all in-scope closure bolting beinspected for signs of leakage to indicate loss of material and loss of preload, provide thetechnical basis to demonstrate that the program will adequately ensure the detection ofage-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 effectswill be managed by the Bolting Integrity Program. For each of the systems listed state how signsof leakage of clear gaseous fluids will be detected on associated closure bolting in order toensure the detection of age-related degradation due to loss of material and loss of preloadbefore there is a loss of intended function.Waterford 3 Response1. As stated in LRA Appendix B.1.1, the Bolting Integrity Program, with one exception, will beconsistent with the program described in NUREG-1801,Section XI.M18, Bolting Integrity. TheBolting Integrity Program includes all closure bolts as described in the license renewalapplication (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 ofleakage of bolted connections, including bolted connections in systems with clear gaseous fluids.Consistent with NUREG-1801,Section XI.M18, the Waterford 3 Bolting Integrity Programincludes periodic inspections and preventive measures that are based on the guidance ofindustry documents including NUREG-1339, EPRI NP-5769, and EPRI TR-104213. toW3F1-2017-0006Page 16 of 18Proper joint preparation and make-up in accordance with industry standards is expected topreclude loss of preload. The review of WF3 OE did not identify instances in which non-Class 1mechanical components became unable to perform license renewal intended functions due toloss 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 ofmaterials 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 appropriatepreload (torque), and checking for uniformity of gasket compression, where appropriate, topreclude loss of preload, loss of material, and cracking.In addition to preventive measures to preclude aging effects that could result in leakage, theprogram provides for identification of leakage from bolted closures included in the BoltingIntegrity Program during periodic inspections conducted during system walkdowns. Other plantpersonnel may also identify leakage during routine maintenance and operational activities.During these inspections and during routine operational activities, personnel can identify leakagefrom bolted closures through visual and audible indications. Visual indications can includeresidue on nearby components and, in the case of steam systems, a visible plume orcondensation in the area of the leak. Audible indications that could indicate a leak are the soundsof leaking gaseous contents escaping from the system. In addition, system engineers reviewoperations logs, deficiency lists, and system parameters such as pressure, flow, and temperaturethat could indicate a system leak. Low compressed air or nitrogen pressure could indicateleakage through a bolted connection. Compressed air and nitrogen systems are monitored forpressure locally and in the main control room.Although leakage, if it occurs, may not be readily apparent from bolted closures serving somesystems containing gaseous material, Waterford 3 operating experience demonstrates that thecombination of preventive actions, visual inspections and observations during routine operationalactivities has been effective at managing the effects of aging on closure bolting. Specifically, thereview of Waterford 3 operating experience found no instances in which loss of intended functionof a non-Class 1 mechanical component was attributable to loss of pressure boundary boltingpreload.As indicated by review of Waterford 3 operating experience, continuation of the activitiesspecified in the Waterford 3 Bolting Integrity Program provides reasonable assurance that theeffects of aging on bolted connections in air and gas systems will be adequately managed sothat the pressure boundary intended function will be maintained consistent with the currentlicensing basis (CLB) for the period of extended operation.The following systems with bolted connections identified in LRA tables have internalenvironments of air - indoor (int), air - outdoor (int), condensation (int), or gas (int) and theycredit the Bolting Integrity Program. toW3F1-2017-0006Page 17 of 18Systems with Bolted Connections Identified in LRA tablesTable 3.2.2-1: Containment Spray SystemTable 3.2.2-2: Safety Injection SystemTable 3.2.2-3: Containment PenetrationsTable 3.3.2-1: Chemical and Volume Control SystemTable 3.3.2-2: Chilled Water SystemTable 3.3.2-3: Component Cooling and Auxiliary Component Cooling Water SystemTable 3.3.2-4: Compressed Air SystemTable 3.3.2-5: Containment Cooling HVAC SystemTable 3.3.2-6: Control Room HVAC SystemTable 3.3.2-7: Emergency Diesel Generator SystemTable 3.3.2-8: Fire Protection - Water SystemTable 3.3.2-9: Fire Protection RCP Oil Collection SystemTable 3.3.2-11: Nitrogen SystemTable 3.3.2-12: Miscellaneous HVAC SystemsTable 3.3.2-13: Auxiliary Diesel Generator SystemTable 3.3.2-14: Plant DrainsTable 3.3.2-15-3: Annulus Negative Pressure System, Nonsafety-Related Components AffectingSafety-Related SystemsTable 3.3.2-15-13: Containment Atmosphere Purge System, Nonsafety-Related ComponentsAffecting Safety-Related SystemsTable 3.3.2-15-14: Containment Atmosphere Release System, Nonsafety-Related ComponentsAffecting Safety-Related SystemsTable 3.3.2-15-18: Fuel Handling Building HVAC System, Nonsafety-Related ComponentsAffecting Safety-Related SystemsTable 3.3.2-15-20: Gaseous Waste Management System, Nonsafety-Related ComponentsAffecting Safety-Related SystemsTable 3.3.2-15-22: Leak Rate Testing System, Nonsafety-Related Components Affecting Safety-Related SystemsTable 3.3.2-15-24: Nitrogen System, Nonsafety-Related Components Affecting Safety-RelatedSystemsTable 3.3.2-15-28: Primary Sampling System, Nonsafety-Related Components Affecting Safety-Related SystemsTable 3.3.2-15-29: Radiation Monitoring System, Nonsafety-Related Components AffectingSafety-Related SystemsTable 3.3.2-15-30: Reactor Auxiliary Building HVAC System, Nonsafety-Related ComponentsAffecting Safety-Related SystemsTable 3.3.2-15-31: Reactor Cavity Cooling System, Nonsafety-Related Components AffectingSafety-Related SystemsTable 3.3.2-15-33: Secondary Sampling System, Nonsafety-Related Components AffectingSafety-Related SystemsTable 3.4.2-1: Condensate Makeup and Storage SystemTable 3.4.2-5-6: Main Steam System, Nonsafety-Related Components Affecting Safety-RelatedSystems toW3F1-2017-0006Page 18 of 18Many of these systems are in the scope of license renewal and subject to aging managementreview only for 10 CFR 54.4(a)(2), that is, for the potential of nonsafety-related components toadversely impact the ability of safety-related equipment to perform its safety functions. Leakagefrom gas-filled portions of these systems would not be a threat to safety-related systems orcomponents. Those portions of systems would be subject to aging management review becausethey have a license renewal intended function of structural support. It is not considered crediblethat bolted closures would experience loss of preload and become unable to fulfill the structuralsupport function without visual indications of bolted connection degradation. toW3F1-2017-0006RAI B.1.38-1 Revised Response Waterford 3 License Renewal Application toW3F1-2017-0006Page1 of5RAI B.1.38-1(Revised)

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(s) will bemaintained consistent with the current licensing basis for the period of extended operation. Asdescribed in SRP LR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) byreferencing the GALL Report and when evaluation of the matter in the GALL Report applies to theplant.The "parameters monitored or inspected," and "detection of aging effects" program elements ofGALL Report AMP XI.S6, "Structures Monitoring," recommends that high strength (actual measuredyield strength greater than or equal to 150 ksi) structural bolts in sizes greater than 1 inch indiameter to be monitored for stress corrosion cracking (SCC). The GALL Report also recommendsthat visual inspections be supplemented with volumetric or surface examinations to detect crackingfor this type of bolts.LRA Section B.1.38, "Structures Monitoring," states that the Structures Monitoring Program is anexisting program, with enhancements, that will be consistent with GALL Report AMP XI.S6. Thestaff notes that LRA Section B.1.38 does not provide an enhancement to the "parameters monitoredor inspected," and/or "detection of aging effects" program elements to address the aging effects ofSCC in high strength structural bolts. LRA Table 3.5.1, item 68, states, in part, that "sincemolybdenum disulfide thread lubricants are not used at WF3, for structural bolting applications, SCCof high strength structural bolting is not an aging effect requiring management at WF3."During the AMP audit, the staff reviewed the applicant's "Aging Management Program EvaluationReport Civil/Structural" (AMPER), implementing procedures, plant structural specifications anddrawings, and noted the following:The applicant excluded the use of supplemental examinations in high strength structural boltsand states, in part, that "since a thread lubricant containing molybdenum disulfide is not usedat WF3, SCC of structural bolting in not plausible, inspections are not required to besupplemented 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-strengthbolts, unless otherwise noted on drawings-"Plant drawings notes, in general, stated that "field connections, unless noted, shall be ASTMA325 high strength bolted friction type connections-"Structural drawings reviewed by the staff indicates the use of several types of bolts (includingA325 and A193 B7 types bolts), and bolts with diameter greater than 1 inch. toW3F1-2017-0006Page2 of5Issue: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 Reportrecommendation because:1. 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 GALLReport does not credit the molybdenum disulfide thread lubricant as the only contributor tothe 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 indiameter are used or not in structural applications, or (2) how supplemental examinations areperformed for these bolts because the plant's structural specifications and drawings do notpreclude the use of high strength structural bolts with diameter greater than 1 inch whenspecified or noted as such in the 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 drawingdetails in addition to generic drawing notes.2. If high-strength structural bolts (actual measured yield strength greater than or equal to 150ksi) in sizes greater than 1 inch diameter are used in structural applications, state whetherand how the recommendations for managing degradation of high-strength bolts described inthe "parameters monitored or inspected," and "detection of aging effects" of the GALL ReportAMP XI.S6 will be implemented for the Structures Monitoring Program. Otherwise, provideadequate technical justification for the exception taken to the GALL Report AMPrecommendation.3. Update the LRA and FSAR supplement, as appropriate, to be consistent with the response tothe above requests.Waterford 3 Response1. WF3 has identified the following high-strength structural bolting with actual measured yieldstrength greater than or equal to 150 ksi in sizes greater than 1 inch diameter that is within thescope of the Structures Monitoring Program. The reactor coolant pumps (RCP), safety injectiontanks (SIT) and reactor coolant system (RCS) supports have bolting consisting of ASTM A-540threaded bolts/studs. These bolts/studs with minimum yield strength of 150 ksi are monitored inthe Structures Monitoring Program by visual inspection. WF3 has determined through review of site documentation (specifications, drawing, certifiedmaterial requests, etc.) that there are no other high-strength structural bolts with actualmeasured yield strength greater than or equal to 150 ksi in sizes greater than 1 inch diameterwithin the scope of the Structures Monitoring Program. toW3F1-2017-0006Page3 of52. 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 boltsdue to stress corrosion cracking (SCC). In the WF3 Structures Monitoring Program, theserecommendations are not necessary because the environmental conditions for SCC are notpresent 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 visualinspection of high-strength bolting is supplemented with volumetric or surface examination todetect 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 shieldwalls that is dry and relatively cool. The A-540 bolts/studs associated with the RCP and RCS arepart of the "stop supports" for these components. This bolting is located inside the steelcontainment vessel and the components are not exposed to an aggressive environment (i.e. highstress, wet environment with high oxygen levels or lubricant containing molybdenum disulfide)conducive to SCC. The Boric Acid Corrosion Program provides for inspections during eachrefueling outage to identify borated water leakage and ensure that corrosion caused by leakingborated water does not lead to unacceptable degradation of the leakage source or adjacentstructures or components. Inspections are also conducted inside containment prior to startupfrom each refueling to ensure no adverse conditions exist that would result in a change to thenormal 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 molybdenumdisulfide. A review of operating records concluded that lubricants containingmolybdenumdisulfide have never been used for this bolting. Because these connections are in a noncorrosiveand low-temperature environment, stress corrosion cracking in these bolts is not expected. TheStructures Monitoring Program and Boric Acid Corrosion Program inspections of the SIT, RCPand RCS support bolting, performed at least once every five years and once every refuelingoutage respectively, provide reasonable assurance that environmental conditions will bemaintained that are not conducive to SCC. Therefore, cracking due to SCC is not an aging effectrequiring management for these bolts.3. Consistent with the response to RAI B.1.16-1 and with the response above, LRA Table 3.5.1items 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 BuildingComponents Subject to Aging Management ReviewComponentIntended FunctionSteel and Other MetalsHigh-strength bolting (RCP,RCS and SIT)Support for Criterion (a)(1) equipment toW3F1-2017-0006Page4 of5LRA Table 3.5.1:Structures and Component SupportsItemNumberComponentAging Effect/MechanismAgingManagementProgramFurtherEvaluationRecommendedDiscussion 3.5.1-68High-strengthstructuralboltingCracking due tostress corrosion crackingISI (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.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. toW3F1-2017-0006Page5 of53.5.1-69High-strengthstructuralboltingCracking due tostress corrosion crackingStructuresMonitoringProgram 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 for bolting in thisline item, ASTM A 325,F 1852, and ASTM A 490 boltsused in civil structures havenot shown to be prone to SCC.However, WF3 has identifiedASTM A-540 structural boltingwith yield stress greater thanor equal to 150 ksi. Thisbolting is notsubject to hightemperature and a corrosiveenvironment. WF3 proceduresdo not identify the use of highstrength bolts ASTM A325 andA-490 for structuralapplications. Therefore, thelisted aging effect is notapplicable for WF3 highstrength bolting. Nevertheless,the Boric Acid Corrosion andStructures MonitoringPrograms will be used tomanage aging effects for thisbolting.LRA Table 3.5.2-1: Reactor BuildingStructure and/orComponent orCommodityIntendedFunction Material EnvironmentAging EffectRequiringManagement AgingManagementProgramNUREG-1801ItemTable 1ItemNotesHigh-strengthbolting (RCP,RCSand SIT supports)

SSRCarbonsteelAir - indooruncontrolledCrackingBoric AcidCorrosion StructuresMonitoringIII.B.5.TP-3003.5.1-69E