ML17319A421

Amendment 1 to License Renewal Application (Laa)

ML17319A421
Person / Time
Site:	Waterford
Issue date:	11/15/2017
From:	Dinelli J C Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2017-0081
Download: ML17319A421 (15)

Text

• ~Entergy W3F1-2017-0081 November 15, 2017 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Amendment 1 to License Renewal Application (LAA) Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38 Entergy Operations Inc . 17265 River Road Killona, LA 70057-3093 Tel 504-739-6660 Fax 504-739-6678 jdinell@entergy.com John C. Dinelli Site Vice President Waterford 3 10 CFR 54.21

REFERENCES:

1. Entergy Letter W3F1-2016-0012, "License Renewal Application, Waterford Steam Electric Station, Unit 3" dated March 23, 2016. 2. Entergy Letter W3F1-2016-0016, "License Renewal Application Drawings, Waterford Steam Electric Station, Unit 3" dated March 23, 2016

Dear Sir or Madam:

In accordance with 1 OCFR54.21 (b), each year following submittal of the license renewal application (LAA) and at least 3 months before scheduled completion of the NRC review an amendment to the renewal application must be submitted that identifies any changes to the current licensing basis that materially affects the content of the LAA including the Updated Final Safety Analysis Report (UFSAR) supplement.

In the referenced letters, Entergy Operations, Inc (Entergy) applied for renewal of the Waterford 3 operating license. This letter provides Amendment 1 of the Waterford 3 license renewal application.

No new commitments have been identified in this letter. I declare under penalty of perjury that the foregoing is true and correct. Executed on November 15,2017. If you have any questions or require additional information, please contact John Jarrell, Regulatory Assurance Manager, at 504-739-6685.

W3Fl-2017-0081 Page 2 of2 Attachments:

1. Annual Update Amendment cc: Mr. Kriss M. Kennedy Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Dr. April Pulvirenti Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Attn: Phyllis Clark Washington, DC 20555-0001 Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division P.O. Box 4312 Baton Rouge, LA 70821-4312 Attachment 1 to W3F1-2017-0081 Annual Update Amendment Waterford 3 License Renewal Application Attachment 1 to W3Fl-2017-0081 Page 1 of 12 Annual Update Amendment Waterford 3 License Renewal Application 1 INTRODUCTION In accordance with 10CFR54.21(b), each year following submittal of the license renewal application (LRA) and at least 3 months before scheduled completion of the NRC review an amendment to the renewal application must be submitted that identifies any changes to the current licensing basis (CLB) that materially affects the content of the license renewal application, including the Updated Final Safety Analysis Report (UFSAR) supplement.

Amendment 1 is based on review of documents potentially affecting the CLB during the period of April 1, 2015 through June 30, 2017. 2

SUMMARY

OF CHANGES The review concluded that certain sections of the LRA are affected by changes to the CLB documents and other related LRA reviews. The table below summarizes the changes listing the affected systems (if applicable), a description of the change (including effect on the LRA), and the affected LRA section. Affected LRA Sections Change LRA Section Affected EC 49686 EC replaces carbon steel pipe with stainless steel pipe in various locations.

The LRA is affected by one change. Sections of pipe leading to the flame arrestors on the A and Table 3.3.2-7 B diesel oil feed tanks (EGFMTNK0002A

& B, ISOs V8.19-1001-15 & 16) was changed from CS to SS. The LRA requires revision to include stainless steel piping with an internal environment of air in system EGF. No other changes documented in this EC resulted in an LRA or report change.

Attachment 1 to W3Fl-2017-0081 Page 2 of 12 Change EC 58410 EC permanently removed carbon steel drain piping and drain valves FW MVAAA174A, 175A in the main feedwater system. Drain piping was replaced with a stainless steel pipe nipple and stainless steel socket welded cap with no valves in the l ine. Stainless steel piping is a new material/type combination for the main feedwater system and the LRA changed accordingly.

I n addition, a new line item for stainless steel "insulated piping components" with an air -outdoor (ext) environment is added. Editorial change By letter W3F1-2016-0074 dated December 7, 2016 , Entergy revised LRA Section B.1.15 , lnserv i ce Inspection, by adding an enhancement.

However, the NUREG-1801 consistency statement included in L RA Section B.1.15 was not revised to indicate a program enhancement was added. The NUREG-1801 consistency statement in LRA Section B.1.15 is revised to reflect the addition of an enhancement to the program. Editorial change The NUREG-1801 consistency statement in LRA Sect i on B.1.10 , External Surfaces Monitoring Program , i s rev i sed to reflect that the program " will be" consistent with GALL after enhancements are incorporated.

LRA Section Affected Table 3.4.2-3 B.1.15 B.1.10 Attachment 1 to W3Fl-2017-0081 Page 3 of 12 Change EC 59101 EC authorizes installation of internal tube sleeves in dry cooling tower heat exchanger tubes (CC MTWR0001A, 1 B). Tubes have been sleeved in the area of degradation between the header and the end of the fins. The 12" long tube sleeves are mechanically expanded inside the existing tubes. Because they are expanded into the existing tubes, the 12" tube sleeves are only exposed to an internal environment (treated water). Loss of material and reduction of heat transfer line items exist in LRA Table 3.3.2-3 for stainless steel tubes exposed to treated water (int) due to another heat exchanger in the same system; therefore a revision to LRA Table 3.3.2-3 due to the sleeve internal environment is not required.

Tube plugs are intended to be temporary until the tube can be reclaimed; however it is possible for plugs to remain permanent.

Plugs in sleeved tubes are made of stainless steel (CPI/ Perma Plug Part# V-735-S) and plugs in un-sleeved tubes are made from carbon steel (Torq N' Seal) according to the EC (page 33 of 33). Therefore, line entries are included in the LRA for both carbon and stainless steel tube plugs. This change does not create a new material/environment combination.

LRA Section Affected Table 3.3.2-3 Table 2.3.3-3 Attachment 1 to W3Fl-2017-0081 Page 4 of 12 Change EC 60103 EC documents NRC approval letter dated August 24, 2015 (Accession No. ML 15217A143) amending Technical Specification (TS) 6.15, "Containment Leakage Rate Testing Program," by replacing the reference to Regulatory Guide 1.163, "Performance-Based Containment Leak Test Program," with a reference to Nuclear Energy Institute (NEI) 94-01, Revision 2-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," as the implementation document used by Entergy Operations, Inc. (Entergy) to develop the WF3 performance-based leakage testing program in accordance with Option B, "Performance Based Requirements," of Title 10 of the Code of Federal Regulations Part 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors." The approval was in response to the Entergy LAR dated August 28, 2014 (ADAMS Accession No. ML 14241A305), as supplemented by letters dated April 15, May 4, and June 18, 2015 (ADAMS Accession Nos. ML 15105A615, ML 15124A946, and ML 15169A180, respectively).

This change permits the performance-based primary containment Integrated Leak Rate Testing (ILRT), also known as Type A test, intervals to be extended from no longer than 10 years to no longer than 15 years on a permanent basis, provided acceptable performance history and the other requirements of NEI 94-01, Rev. 2-A are satisfied. LRA Section Affected Section A.1. 7 Section B.1.7 Attachment 1 to W3Fl-2017-0081 Page 5 of 12 Change EC 69791 EC replaces 2" carbon steel root instrument valves ACCMVAAA136A and ACCMVAAA137A with 1" stainless steel valves. The EC also replaces carbon steel piping leading to the root valves from penetrations with stainless steel (SS) piping. The valves, piping, and tubing are exposed to air-outdoor (ext) and raw water (int). The material change to stainless steel requires a change to LRA Table 3.3.2-3 including a new line item for stainless steel "insulated piping components" with an air -outdoor (ext) environment.

However, the raw water internal environment is already included for SS valves and tubing. Therefore line items will not be added for these. The changes by this EC do not require removal of any line items in LRA Table 3.3.2-3. The same LRA changes are required as a result of EC 69792. EC 69792 made similar changes to the "B" train as this EC did to the "A" train. EC 69792 EC replaces 2" carbon steel root instrument valves ACCMVAAA136B and ACCMVAAA137B with 1" stainless steel valves. The EC also replaces carbon steel piping leading to the root valves from penetrations with stainless steel (SS) piping. The valves , piping, and tubing are exposed to air-outdoor (ext) and raw water (int). The material change to stainless steel requires a change to LRA Table 3.3.2-3 including a new line item for stainless steel "insulated piping components" with an air -outdoor (ext) environment.

However, the raw water internal environment is already included for SS valves and tubing. Therefore line items will not be added for these. The changes by this EC do not require removal of any line items in LRA Table 3.3.2-3. The same LRA changes are required as a result of EC 69791. EC 69791 made similar changes to the "A" train as this EC did to the "B" train. LRA Section Affected Table 3.3.2-3 Table 3.3.2-3 Attachment 1 to W3Fl-2017-0081 Page 6 of 12 3 LRA CHANGES WF3 LRA changes are shown below. Additions are shown with underline and deletions with strikethrough.

Table 3.3.2-7 Emergency Diesel Generator System Summary of Aging Management Evaluation Table 3.3.2-7: Emergency Diesel Generator System Aging Effect Aging Component Intended Requiring Management Type Function Material Environment Management Program Piping Pressure Stainless steel Air -outdoor Cracking Internal Surfaces boundary ilo.tl in Miscellaneous Piping and Ducting Components Piping Pressure Stainless steel Air -outdoor Loss of material Internal Surfaces boundary (int) in Miscellaneous Piping and Ducting Components Piping Pressure Stainless steel Air -outdoor Cracking External Surfaces boundary (ext) Monitoring .E.iQing Pressure Stainless steel Air -outdoor Loss of material External Surfaces boundary (ext) Monitoring NUREG-1801 Item ------VII.H1 .AP-209 VII.H2.AP-221 Table 1 Item Notes --§ ---§ -3.3.1-4 8 3.3.1-6 8 Attachment 1 to W3Fl-2017-0081 Page 7 of 12 Table 3.4.2-3: Main Feedwater System Component Intended Type Function Material Piping Pressure Stainless steel boundary Piping Pressure Stainless steel boundary Insulated piping Pressure Stainless steel components boundary Insulated piping Pressure Stainless steel components boundary Piping Pressure Stainless steel boundary Piping Pressure Stainless stee l boundary .E.iQing Pressure Stainless steel boundary Table 3.4.2-3 Main Feedwater System Summary of Aging Management Evaluation Aging Effect Aging Requiring Management Environment Management Program Air -outdoor Cracking Externa l Surfaces (ext) Monitoring Air -outdoor Loss of material External Surfaces (ext) Monitor i ng Air -outdoor Cracking External Surfaces (ext) Monitoring Air -outdoor Loss of material External Surfaces (ext) Monitoring Treated water Cracking Water Chem i stry > 140°F (int) Control -Primary and Secondary Treated water Cracking -fatigue TLAA-metal

> 140°F (int) fatigue Treated water Loss of material Water Chemistry

> 140°F (int) Control -Primary and Secondary NUREG-1801 Table 1 Item Item Notes Vlll.01 .SP-1 1 8 3.4.1-2 8 Vlll.01.SP-127 3.4.1-3 8 Vlll.01 .S-4 02 3.4.1-63 8 Vlll.01 .S-402 3.4.1-63 8 Vlll.01 .SP-88 3.4.1-11 A, 4 0 1 VII.E1.A-57 3.3.1-2 g Vlll.01 .SP-87 3.4.1-16 A, 4 0 1 Attachment 1 to W3Fl-2017-0081 Page 8 of 12 Table 3.3.2-3 Component Cooling and Auxiliary Component Cooling Water System Summary of Aging Management Evaluation Table 3.3.2-3: Component Cooling and Auxiliary Component Cooling Water System Aging Effect Aging Component Intended Requiring Management NUREG-1801 Type Function Material Environment Management Prog r ams Item OCT Tube Plug Pressure Stainless steel Treated water Loss of mater i al Water Chemist!}'.

VII.C2.A-52 boundary (int) Control -Closed Treated Water Systems OCT Tube Plug Pressure Stainless steel Air -outdoor Cracking External Surfaces VII.C1 .AP-209 boundary (ext) Monitor i ng OCT Tube Plug Pressure Sta i nless steel Air -outdoor Loss of mater i al External Surfaces VII.C1 .AP-221 boundary (ext) Monitorin_g OCT Tube Plug Pressure Carbon steel Treated water Loss of material Water Chemist!}'.

VII.C2.AP-202 boundary (int) Control -C l osed Treated Water Systems OCT Tube Plug Pressure Carbon steel A i r -outdoor Loss of material External Surfaces VII.H1.A-24 boundary (ext) Mon i toring Insulated 12i12ing Pressure Stainless steel A i r -outdoor Cracking External Surfaces VII.C1 .A-405 com12onents boundary (ext) Mon i toring Insulated 12i12ing Pressure Stainless steel Air -outdoor Loss of material External Surfaces VII.C1 .A-405 com12onents boundary (ext) Mon i toring Pi12ing Pressure Stainless steel Air -outdoor Cracking External Surfaces VII.C1 .AP-209 boundary (ext) Mon i toring Pi12ing Pressure Stainless steel Air -outdoor Loss of material External Surfaces VII.C1 .AP-221 boundary (ext) Monitoring Table 1 Item Notes 3.3.1-49 6 3.3.1-4 6 3.3.1-6 6 3.3.1-45 6 3.3.1-80 .Q 3.3.1-132 6 3.3.1-132 6 3.3.1-4 6 3.3.1-6 6 Attachment 1 to W3Fl-2017-0081 Page 9 of 12 Table 3.3.2-3: Component Cooling and Auxiliary Component Cooling Water System Aging Effect Aging Component Intended Requiring Management Type Function Material Environment Management Programs P.iQing Pressure Stainless steel Raw water {int} Loss of material Service Water bounda[Y lntegrit~

Valve bod~ Pressure Stainless steel Air -outdoor Crack i ng External Surfaces bounda[Y (ext} Monitoring Valve bod~ Pressure Stainless steel Air -outdoor Loss of material External Surfaces bounda[Y {ext} Monitoring Tubing Pressure Stainless steel Air -outdoor Cracking External Surfaces boundar~ (ext} Monitoring Tubing Pressure Stainless steel Air -outdoor Loss of material External Surfaces boundar~ (ext} Monitoring NUREG-1801 Table 1 Item Item Notes VII.C1.A-54 3.3.1-40 8 VII.C1 .AP-209 3.3.1-4 8 VII.C1 .AP-221 3.3.1-6 8 VII.C1 .AP-209 3.3.1-4 8 VII.C1 .AP-221 3.3.1-6 8 Attachment 1 to W3Fl-2017-0081 Page 10 of 12 Table 2.3.3-3 Component Cooling and Auxiliary Component Cooling Water Systems Components Subject to Aging Management Review Component Type OCT Tube Plug B.1.15 lnservice Inspection NUREG-1801 Consistency Intended Function Pressure boundary The lnservice Inspection Program, with enhancement.

will be consistent with the program described in NUREG-1801,Section XI.M1, ASME Section XI lnservice Inspection, Subsections IWB, IWC, and IWD. 8.1.10 External Surfaces Monitoring NU RE G-1801 Consistency The External Surfaces Monitoring Program, with enhancements, j.s will be consistent with the program described in NUREG-1801,Section XI.M36, External Surfaces Monitoring of Mechanical Components , as modified by LR-ISG-2011-03, Changes to the Generic Lessons Learned (GALL) Report Revision 2 Aging Management Program XI.M41, "Buried and Underground Piping and Tanks," and LR-ISG-2012-02, Aging Management of Internal Surfaces , Fire Water Systems, Atmospheric Storage Tanks, and Corrosion under Insulation.

Attachment 1 to W3F1-2017-0081 Page 11 of 12 Appendix A A.1 AGING MANAGEMENT PROGRAMS A.1. 7 Containment Leak Rate Program The Containment Leak Rate Program consists of tests performed in accordance with the regulations and guidance provided in 10 CFR Part 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors," Option B; R.G 1.163, "Performanoe Based Containment Leak Testing Program";

NEI 94-01 Revision 2-A, "Industry Guideline for Implementing Performance-Based Options of 10 CFR Part 50, Appendix J"; and ANSI/ANS 56.8, "Containment System Leakage Testing Requirements." Three types of tests are performed under Option B. Type A tests are performed to determine the overall primary containment integrated leakage rate at the loss of coolant accident peak containment pressure.

Performance of the integrated leakage rate test (ILRT) per 10 CFR Part 50, Appendix J, Option B, demonstrates the leak-tightness and structural integrity of the containment.

Type B and Type C containment local leakage rate tests (LLRTs), as defined in 10 CFR Part 50, Appendix J, are intended to detect local leaks and to measure leakage across each pressure-containing or leakage-limiting boundary of containment penetrations.

Type B and Type C leakage rate tests Containment leakage rate tests are performed at frequencies in accordance with the provisions of 10 CFR Part 50, Appendix J, Option B. Type A tests are performed at frequencies no longer than 15 years in accordance with 10 CFR Part 50, Appendix J, Option B, based upon the criteria in NEI 94-01, Revision 2-A.

Attachment 1 to W3Fl-2017-0081 Page 12 of 12 Appendix B B.1 Aging Management Programs and Activities B.1. 7 Containment Leak Rate Program Description The Containment Leak Rate Program consists of tests performed in accordance with the regulations and guidance provided in 10 CFR Part 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors," Option B; RG 1.163, "Periormance Based Containment Leak Testing Program";

NEI 94-01, Revision 2-A. "Industry Guideline for Implementing Performance-Based Options of 10 CFR Part 50, Appendix J"; and ANSI/ANS 56.8, "Containment System Leakage Testing Requirements." The Containment Leak Rate Program provides for detection of pressure boundary degradation due to aging effects such as loss of leakage tightness, loss of material, cracking, loss of sealing, or loss of preload in various systems penetrating containment.

The program also provides for detection of age-related degradation in material properties of gaskets, 0-rings, and packing materials for the containment pressure boundary access points. Three types of tests are performed under Option B. Type A tests are performed to determine the overall primary containment integrated leakage rate at the loss of coolant accident peak containment pressure.

Performance of the integrated leakage rate test (ILRT) per 10 CFR Part 50, Appendix J, Option B demonstrates the leak-tightness and structural integrity of the containment.

A general visual examination of the accessible interior and exterior areas of the steel containment vessel is performed prior to any ILRT during a period of reactor shutdown (refueling outages) and during two subsequent refueling outages before the next Type A test. The ILRT is performed at the frequency specified in 10 CFR Part 50, Appendix J, Option 8 1 based upon the criteria in NEI 94-01, Revision 2-A. Type Band Type C containment LLRTs, as defined in 10 CFR Part 50, Appendix J, are intended to detect local leaks and to measure leakage across each pressure-containing or leakage-limiting boundary of containment penetrations.

LLRTs are performed at frequencies in accordance with the provisions of 10 CFR Part 50, Appendix J, Option B.