W3F1-2015-0047, Provides Additional Information to Support Response to Request for Additional Information Regarding the Request to Permanently Extend the Integrated Leak Rate Frequency to 15 Years

Provides Additional Information to Support Response to Request for Additional Information Regarding the Request to Permanently Extend the Integrated Leak Rate Frequency to 15 Years

ML15169A180
Person / Time
Site:	Waterford
Issue date:	06/18/2015
From:	Chisum M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2015-0047
Download: ML15169A180 (29)

Text

10 CFR 50.90W3F1-2015-0047June 18, 2015U.S. Nuclear Regulatory CommissionAttn: Document Control Desk11555 Rockville PikeRockville, MD 20852

Subject:

Waterford Steam Electric Station, Unit 3 Additional Information to SupportResponse to Request for Additional Information Regarding the Request toPermanently Extend the Integrated Leak Rate Frequency to 15 YearsWaterford Steam Electric Station, Unit 3 (Waterford 3)Docket No. 50-382License No. NPF-38

REFERENCES:

1. Entergy Letter W3F1-2014-0052, License Amendment Request toChange Technical Specifications to Extend the Type A Test Frequencyto 15 Years, dated August 28, 2014. (ADAMS Accession No.ML14241A305)2. Letter from NRC, Request for Additional Information Regarding theRequest to Permanently Extend the Integrated Leak Rate TestFrequency to 15 Years (TAC No. MF4727), dated February 18, 2015.(ADAMS Accession No. ML15033A422)3. Entergy Letter W3F1-2015-0021, Response to Request for AdditionalInformation Regarding the Request to Permanently Extend theIntegrated Leak Rate Frequency to 15 Years, dated May 4, 2015.(ADAMS Accession No. ML15124A946)4. Entergy Letter W3F1-2015-0041, Identification of AdditionalInformation to Support Response to Request for Additional InformationRegarding the Request to Permanently Extend the Integrated LeakRate Test Frequency to 15 Years, dated May 28, 2015. (ADAMSAccession No. ML15148A689)

Dear Sir or Madam:

In letter dated August 28, 2014 (Reference 1), Entergy Operations, Inc. (Entergy) submitteda license amendment request to change the Waterford 3 Technical Specifications topermanently extend the Integrated Leak Rate Test (ILRT) frequency to 15 years.Entergy Operations, Inc.17265 River RoadKillona, LA 70057-3093Tel 504-739-6660Fax 504-739-6678mchisum@entergy.comMichael R. ChisumSite Vice PresidentWaterford 3 W3F1-2015-0047 Page 2 In letter dated February 18, 2015 (Reference 2), NRC requested Entergy to provide additional information to support review of t he license amendment request to extend the ILRT frequency.

In letter dated May 4, 2015 (Reference 3), Entergy provided a response to the request for additional information. Based on a review of the responses that were provided in that submittal (Reference 3), additional clarifying information was identified that is required to supplement that RAI response. In letter dated May 28, 2015, Entergy notified NRC of the need to provide additional information. This letter provides that additional information. The responses provided in Attachment 1 supersede the previous responses provided to RAI Questions 5, 6, 7, 9, and 12.b (Reference 3) in their entirety.

This correspondence contains no new commitments.

If you have any questions or require additional information, please contact the Regulatory Assurance Manager, John Jarrell, at 504-739-6685.

I declare under penalty of perjury that the foregoing is true and correct. Executed on June 18, 2015.

MRC/LEM

Attachments: 1. Waterford 3 Supplemental Information to Support Response to Request for Additional Information

2. Revised Section 4.3 from License Amendment Request to Change Technical Specifications to Extend the Type A Test Frequency to 15

Years

3. Revised Attachment 4 from License Amendment Request to Change Technical Specifications to Extend the Type A Test Frequency to 15 Years W3F1-2015-0047Page 3cc: Mr. Marc L. Dapas, Regional AdministratorU.S. NRC, Region IVRidsRgn4MailCenter@nrc.govU.S. NRC Project Manager for Waterford 3Michael.Orenak@nrc.govU.S. NRC Senior Resident Inspector for Waterford 3Frances.Ramirez@nrc.govThomas.Sullivan@nrc.govLouisiana Department of Environmental QualityOffice of Environmental ComplianceSurveillance DivisionJi.Wiley@LA.gov W3F1-2015-0047Waterford 3 Supplemental Information to SupportResponse to Request for Additional Information to W3F1-2015-0047Page 1 of 16REQUEST FOR ADDITIONAL INFORMATIONREGARDING THE REQUEST TO PERMANENTLY EXTEND THE INTEGRATED LEAK RATE TEST FREQUENCY TO 15 YEARSENTERGY OPERATIONS, INC.WATERFORD STEAM ELECTRIC STATION, UNIT 3DOCKET NO. 50-382By letter dated August 28, 2014 (Agencywide Documents Access and Management System(ADAMS) Accession No. ML14241A305), Entergy Operations, Inc., submitted a licenseamendment request (LAR) to change the Waterford Steam Electric Station, Unit 3 (WF3)Technical Specification 6.15, "Containment Leakage Rate Testing Program," to allow apermanent extension of the Type A primary containment integrated leak rate test frequencyfrom 10 years to 15 years.The U.S. Nuclear Regulatory Commission staff has reviewed the LAR and the followinginformation is needed to complete the review. The responses to the questions below replacethe previous responses to RAI Questions 5, 6, 7, 9, and 12.b provided in Reference 1 in theirentirety.RAI #5Sections 4.0 and 4.3 of the LAR state that the ASME Boiler and Pressure Vessel (BPV) Code,Section XI, Subsection IWL, does not apply to WF3.As described in Section 3.8 of the WF3 final safety analysis report, both the shield building andthe containment vessel are supported on a common reinforced concrete foundation mat. Thecontainment vessel is supported on the concrete fill, which transfers the loads by bearing to thefoundation mat below.Subsection IWL provides the examination requirements for reinforced concrete Class CCcomponents. Considering that the containment vessel is supported on a concrete fill and areinforced concrete foundation mat, provide clarification regarding the LAR's statement ofSubsection IWL not being applicable to WF3.RAI #5 Response:Subsection IWL provides the examination requirements for reinforced concrete Class CCcomponents. Although the containment vessel is supported on a concrete fill and a reinforcedconcrete mat, it is not part of the containment system.Per ASME Section XI 2001- 2003 Addenda, Subsection IWL-1210 Examination Requirements,"The examination requirements of this Subsection shall apply to concrete containments." to W3F1-2015-0047Page 2 of 16Per WF3 FSAR, Section 3.8.1, Concrete Containment, "The Containment System does notutilize a concrete containment. The primary containment is a free standing steel pressurevessel which is surrounded by a reinforced concrete Shield Building. The Shield Building isdesigned as a seismic Category I structure and is discussed under Subsection 3.8.4. The steelcontainment and the Reactor Building internal structure are described in Subsection 3.8.2 and3.8.3, respectively.""The Steel Containment Vessel (SCV) is a low leakage rate free standing steel pressure shell,completely enclosed by the concrete shield structure, with an annular space provided betweenthe walls and domes of each structure to permit construction, operations, and in-serviceinspection. The SCV consists of a vertical upright cylinder, all welded steel pressure vessel,with hemispherical top head and an ASME ellipsoidal bottom head. The steel vessel is rigidlysupported on a concrete base that was placed after the cylindrical shell and the ellipsoidalbottom had been constructed and post weld heat treated. The containment vessel, shieldbuilding, reactor auxiliary building, and fuel handling building are supported on a commonfoundation mat. Concrete floor fill was placed above the ellipsoidal shell bottom of the SCVafter the vessel had been post weld heat treated, to anchor the vessel. All components andframing inside the SCV are supported on the concrete floor fill."Per ASME Section XI 2001 - 2003 Addenda, Subsection IWL-1220(b), portions of the concretesurface that are covered by the liner, foundation material, or backfill, or are otherwise obstructedby adjacent structures, components, parts, or appurtenances, are exempt from the examinationrequirements of IWL-2000. Per ASME Section XI 2001 - 2003 Addenda, Subsection IWE-1220(b), embedded or inaccessible portions of containment vessels, parts, and appurtenancesthat met the requirements of the original Construction Code are exempted from the examinationrequirements of IWE-2000. Since the common concrete foundation slab and the bottom steelplate are inaccessible, they are exempt from examination per ASME Section XI 2001 - 2003Addenda, Subsection IWL-1220(b) and IWE-1220(b) respectively.Although portions of the common concrete foundation slab (basemat) are exempt from ASMESection XI 2001 - 2003 Addenda, Subsection IWL, it is still monitored for degradation. Per WF3FSAR, Section 2.5.4.13.4, The Nuclear Plant Island Structure (NPIS) basemat continues to bemonitored. The basemat monitoring program provides for data collection and trending such thatinformation allows an assessment of the structural integrity of the basemat.A WF3 procedure implements Technical Specification T.S.6.8.4.e 1 and 4 requirements whichstates that the Basemat Monitoring Program will monitor the settlement of the basemat andchanges in crack width. This procedure provides the methods for verifying the NPIS commonfoundation basemat integrity through measurement of the common foundation basematsettlement, and measurement of fifteen (15) instrumented basemat cracks.A recurring PM tracks the completion of the basemat inspections on an eighteen (18) monthfrequency. A review of the basemat inspections dating back to 1997 revealed that all of theacceptance criteria were met with satisfactory results. to W3F1-2015-0047Page 3 of 16RAI #6Please provide information of instances, during implementation of the WF3 containmentin-service inspection program, where existence of or potential for degraded conditions ininaccessible areas were identified and evaluated based on conditions found in accessible areas,as required by 10 CFR 50.55a(b)(2)(viii)(E) and 10 CFR 50.55a(b)(2)(ix)(A). If there were anyinstances of such conditions, discuss the findings and corrective actions taken to disposition thefindings.RAI #6 Response:As discussed in the response to RAI #5 above, Per ASME Section XI 2001 - 2003 Addenda,Subsection IWL-1220(b), portions of the concrete surface that are covered by the liner,foundation material, or backfill, or are otherwise obstructed by adjacent structures, components,parts, or appurtenances, are exempt from the examination requirements of IWL-2000. Sincethe common concrete foundation slab and the bottom steel plate are inaccessible, they areexempt from examination per ASME Section XI 2001 - 2003 Addenda, Subsection IWL-1220(b)and IWE-1220(b) respectively. Since WF3 has a steel containment, it is not a Class CCapplication; therefore, 10 CFR 50.55a(b)(2)(viii)(E) does not apply. Even though IWL does notapply, a review of the basemat inspection history dating back to 1997 did not reveal instanceswhere conditions existed in accessible areas that could indicate the presence of or the result indegraded conditions in inaccessible areas.A condition report dated 10/20/2000 documents an instance, during implementation of the WF3containment in-service inspection program, where existence of or potential for degradedconditions in inaccessible areas were identified and evaluated based on conditions found inaccessible areas. The condition description states that:"VT-3 Examinations of the interior moisture barrier (located between the containment vessel andthe concrete floor on the ledge at elevation - 1.5') revealed 22 locations where the moisturebarrier has failed by various mechanisms. The moisture barrier is intended to provide long termcorrosion protection to the containment vessel. No immediate/short term challenges tocontainment integrity were noted during the examinations. The NDE visual examination reportprovides detail on the location and conditions noted. Additionally, the affected areas have beenmarked on the containment vessel.One of the affected locations is located immediately below penetration #21. This location isbeing wetted by condensation from the CCW pipe. The containment vessel at location #21 isexperiencing general corrosion. The corrosion noted is not sufficient to affect either thestructural integrity or the leak tightness of containment; however, the corrosion does indicate thepotential for degradation below the moisture barrier and requires further investigation.None of the remaining locations exhibited signs of either wetting or corrosion of the containmentvessel."The Responsible Engineer's (RE) Evaluation of Inaccessible Areas was documented in theresponse to the corrective action dated 1/30/2001 and is listed below: to W3F1-2015-0047Page 4 of 16Scope:This evaluation covers the evaluations required by CEP-CII-002 paragraph 1.7.3.5 and by10 CFR 50.55a(b)(2)(ix)(A). Evaluations that are required by CEP-CII-002 paragraph 1.7.3.3are documented in attachment 2 to this corrective action (CA).Results of Evaluation:1) During examination of the moisture barrier two areas were identified which could indicatethe presence of degradation in inaccessible areas.2) Investigation of the first area revealed only limited areas of surface corrosion with nosignificant wall loss or pitting. All surface areas of the containment vessel at this locationwere determined to be acceptable by examination in accordance with IWE-3122.1.3) Investigation of the second area revealed excessive corrosion in the region below themoisture barrier in the annulus. A condition report dated 10/27/2000 was prepared todocument corrective actions associated with this corrosion.Discussion:Paragraph 1.7.3.5 of CEP-CII-002 requires the RE (or designee) to prepare a conditionreport when the RE determines that conditions exist in accessible areas which couldindicate the presence of or result in degradation of inaccessible areas. The purpose of thisevaluation is to evaluate the acceptability of the inaccessible area in question. Additionallythe RE is to prepare inputs to the OAR-1 which include the following:1) A description of the type and estimated extent of degradation, and the conditions that led tothe degradation;2) An evaluation of each area, and the results of the evaluation, and;3) A description of necessary corrective actions.CA #7 addresses the need for the RE to provide inputs to the OAR-1The flaws identified by the NDE VT-3 reports revealed two areas that indicated potentialdegradation of the containment vessel in the inaccessible areas below the moisture barrier.One area is located immediately below penetration #21 and has been wetted due tocondensation from the CCW pipe using penetration #21. General corrosion of thecontainment vessel was noted in the vicinity of the moisture barrier in this location. Afterremoval of the moisture barrier, a small area of general corrosion was noted to exist belowthe moisture barrier at this location. This area of corrosion did not extend below the areathat could be accessed by removal of the moisture barrier. At this location, the corrosionconsisted of only a light surface corrosion with no pitting or cracking. Additionally, there wasno discernable thinning of the containment vessel due to the corrosion. As a result thecorrosion was determined to be acceptable without engineering evaluation (other than theevaluation required due to the indications of degradation in inaccessible areas - the areassubsequently examined following removal of the moisture barrier). The surface areas wereaccepted by examination in accordance with the provisions of IWE-3122.1. After to W3F1-2015-0047Page 5 of 16determination that the areas were acceptable by examination, the areas of general corrosionwere cleaned and the vessel was re-coated. The moisture barrier in this area was replacedon the same MAI. The NDE VT-3 report documents the re-inspection of the moisturebarrier.One area is located almost directly below the maintenance access hatch. Investigation ofthe area revealed that the corrosion was more extensive than originally anticipated andcondition report dated 10/27/2000was prepared to document the corrective actionsassociated with the corrosion on the containment vessel below the moisture barrier withinthe annulus region.The Responsible Engineer (RE) provided inputs to the Owner's Activity Report (OAR-1) inresponse to a corrective action dated 11/12/2001. These inputs are provided in Tables 2through 4 below: to W3F1-2015-0047Page 6 of 16Tables 2 - Conditions in accessible areas which indicate the potential for degradation in inaccessible areas (Per 10 CFR 50.55a(b)(2)(ix)(A):Type and Extentof DegradationConditions that led todegradationEvaluationResults of EvaluationNecessary Corrective ActionMechanicalDamage to theinner and outermoisture barrierswith somecorrosion noted in2 locations.Wear and Tear due totraffic and work aroundthe moisture barrier.CR-W3-2000-1275CA 4, Attachment 3.During examination of the moisturebarrier two areas were identified whichcould indicate the presence ofdegradation in inaccessible areas.1) Investigation of the first area, area#13 on NDEN 200-151, revealed onlylimited areas of surface corrosion withno significant wall loss or pitting. Allsurface areas of the containmentvessel at this location were determinedto be acceptable by examination inaccordance with IWE-3122.1.2) Investigation of the second area,area #15 on NDEN-155, revealedmore serious corrosion in the regionbelow the moisture barrier in theannulus. CR-W3-200-1375 wasprepared to document correctiveactions associated with this corrosion.All surface areas examined weredetermined to be acceptable byexamination in accordance with IWE3122.1 following UT measurementsand determination that the corrosionmechanism was not active.1) The inner and outer moisturebarriers were repaired on MAI #

421737.2) QA NDE inspections of theseareas are noted in inspectionreports NDEN 2000-483 andNDEN 2000-484.3) 100% of the moisture barriershall be examined each refuelingoutage until sufficient data isobtained to allow re-evaluationby the RE to determine theoptimum examination schedule.4) Corrosion noted below themoisture barrier on thecontainment vessel within theannulus is considered in CR-W3-2000-1375. Area determined tobe acceptable by examination inaccordance with IWE 3122.1. to W3F1-2015-0047Page 7 of 16Table 3 - Areas with Flaws or Other Relevant Conditions Requiring Evaluation for Continued Service:Examination CategoryItem NumberItem DescriptionFlaw CharacterizationFlaw or Relevant ConditionFound During ScheduledSection XI Examination orTest? (Yes/No)No Areas requiredevaluation for continuedservice.N/AN/AN/AN/ATable 4 - Areas Requiring Repair, Replacement or Corrective Measures for Continued Service:

CodeClassRepair,Replacement orCorrective MeasureItem DescriptionDescription ofWorkFlaw or RelevantCondition FoundDuring ScheduledSection XIExamination or Test?(Yes/No)Date CompletedRepair/Replacement PlanNumber MCRepairMoisture Barrier MB-02Mechanical Damage intwo locations.Repairmoisturebarrier 1.Yes11/6/00MAI 421737Exempt fromrepair/replacement rules ofIWA 4000 by IWA 4111 MCRepairMoisture Barrier MB-04Mechanical Damage intwo locations.Repairmoisturebarrier 1.Yes11/6/00MAI 421737Exempt fromrepair/replacement rules ofIWA 4000 by IWA 4111 to W3F1-2015-0047Page 8 of 16 MCRepairMoisture Barrier MB-05Mechanical Damage inone location.Repairmoisturebarrier 1.Yes11/6/00MAI 421737Exempt fromrepair/replacement rules ofIWA 4000 by IWA 4111 MCRepairMoisture Barrier MB-06Mechanical Damage intwo locations.Repairmoisturebarrier 1.Yes11/6/00MAI 421737Exempt fromrepair/replacement rules ofIWA 4000 by IWA 4111 MCRepairMoisture Barrier MB-07Mechanical Damage intwo locations.Repairmoisturebarrier 1.Yes11/6/00MAI 421737Exempt fromrepair/replacement rules ofIWA 4000 by IWA 4111 MCRepairMoisture Barrier MB-08Mechanical Damage in 6locations.Repairmoisturebarrier 1.Yes11/6/00MAI 421737Exempt fromrepair/replacement rules ofIWA 4000 by IWA 4111 MCRepairMoisture Barrier MB-09Mechanical Damage inone location.Repairmoisturebarrier 1.Yes11/6/00MAI 421737Exempt fromrepair/replacement rules ofIWA 4000 by IWA 4111 to W3F1-2015-0047Page 9 of 16 MCRepairMoisture Barrier MB-10Mechanical Damage in 3locations.Repairmoisturebarrier 1.Yes11/6/00MAI 421737Exempt fromrepair/replacement rules ofIWA 4000 by IWA 4111 MCRepairMoisture Barrier MB-11Mechanical Damage in 3locations.Repairmoisturebarrier 1.Yes11/6/00MAI 421737Exempt fromrepair/replacement rules ofIWA 4000 by IWA 4111 MCRepairMoisture Barrier MB-13Mechanical Damage in 2locations that overlap withMB-14.Repairmoisturebarrier 1.Yes11/6/00MAI 421737Exempt fromrepair/replacement rules ofIWA 4000 by IWA 4111 MCRepairMoisture Barrier MB-14Mechanical Damage in10 locations. (2 overlapwith MB-13, 3 overlapwith MB-15)Repairmoisturebarrier 1.Yes11/6/00MAI 421737Exempt fromrepair/replacement rules ofIWA 4000 by IWA 4111 MCRepairMoisture Barrier MB-15Mechanical Damage in14 locations. (3 overlapwith MB-14)Repairmoisturebarrier 1.Yes11/6/00MAI 421737Exempt fromrepair/replacement rules ofIWA 4000 by IWA 4111Note 1: Repair of moisture barriers consisted of removal of damaged areas of the moisture barrier seal to W3F1-2015-0047Page 10 of 16Please note that Table 4-2 of the LAR (Reference 2) describes that the moisture barrierinspections performed in the spring of 2008 (RF15) were satisfactory with the exception ofsections MB-02, -03, -05, and -06 which revealed signs of aged related degradation andmechanical damage which required repair. Although this may seem contradictory to thestatement in Section 4.4 of the LAR which states that examinations were performed everyoutage from RF10 through RF16 with the degradation remaining essentially unchanged overthis time period, Section 4.4 of the LAR is actually discussing the augmented, Owner ElectedExaminations, not the moisture barrier sections MB-02, -05, and -06 listed in the table above.Per Section 4.4 of the LAR (Reference 2), in addition to the requirements of Table IWE-2500-1,Owner Elected Examinations were performed every outage from RF10 through RF16. Due tothe degradation remaining essentially unchanged over this time period, these areas wereevaluated to no longer require augmented examinations in accordance with IWE-2420(c). to W3F1-2015-0047Page 11 of 16RAI #7Section 9.2.3.2 of NEI 94-01, Revision 2-A, "Industry Guideline for ImplementingPerformanceBased Option of 10 CFR Part 50, Appendix J," and Condition 2 in Section 4.1 ofthe NRC safety evaluation for NEI 94-01, Revision 2, require supplemental general visualinspections of accessible interior and exterior surfaces of the containment for structuraldeterioration that may affect the containment leak-tight integrity. These inspections must beconducted prior to each Type A test and during at least three other outages before the nextType A test if the interval for the Type A test has been extended to 15 years.Provide a schedule for a typical 15-year interval (between the last Type A test in 2005 and theproposed next Type A test in 2020), in a tabular format, of in-service inspections that were andwill be performed on the containment vessel, and explain how it meets the requirements inSection 9.2.3.2 of NEI 94-01, Revision 2-A, and Condition 2 in Section 4.1 of the NRC safetyevaluation NEI 94-01, Revision 2. Please include the in-service inspection intervals with thestart date and end date of each inspection period, and the corresponding refueling outages.RAI #7 Response:Preventative maintenance tasks exist to perform periodic general inspections of the accessibleinterior and exterior surfaces of the containment vessel. The table below provides a schedulefor a typical 15-year interval (between the last Type A test in 2005 and proposed next Type Atest in 2020) with the in-service inspection intervals with the start date and end date of eachinspection period and the corresponding refueling outages.Containment Examination ScheduleExamination TypeISI InspectionIntervalISI Inspection PeriodRefuel Outage/ DateILRT Type A Test 2 nd Interval 3 rd PeriodRF13 / 2005IWE ContainmentSurface AreaInspections 2 nd Interval 3 rd PeriodRF13 / 2005IWE Inner/OuterMoisture BarrierInspection 2 nd Interval 3 rd PeriodRF13 / 2005IWE Inner/OuterMoisture BarrierInspection 2 nd Interval 3 rd PeriodRF14 / 2006IWE Inner/OuterMoisture BarrierInspection 2 nd Interval 3 rd PeriodRF15 / 2008IWE Inner/OuterMoisture BarrierInspection 3 rd Interval 1 st PeriodRF16 / 2009IWE ContainmentSurface Area 3 rd Interval 1 st PeriodRF16 / 2009 to W3F1-2015-0047Page 12 of 16InspectionsIWE ContainmentBolted Connections 3 rd Interval 1 st PeriodRF17 / 2011IWE ContainmentSurface AreaInspections 3 rd Interval 2 nd PeriodRF18 / 2012-2013IWE Inner/OuterMoisture BarrierInspection 3 rd Interval 2 nd PeriodRF18 / 2012-2013IWE Inner/OuterMoisture BarrierInspection 3 rd Interval 2 nd PeriodRF19 / 2014IWE ContainmentBolted Connections 3 rd Interval 2 nd PeriodRF19 / 2014IWE ContainmentSurface AreaInspections 3 rd Interval 3 rd PeriodRF20 / 2015IWE Inner/OuterMoisture BarrierInspection 3 rd Interval 3 rd PeriodRF20 / 2015IWE Inner/OuterMoisture BarrierInspection 3 rd Interval 3 rd PeriodRF21 / 2017IWE ContainmentBolted Connections 3 rd Interval 3 rd PeriodRF21 / 2017IWE Inner/OuterMoisture BarrierInspection 4 th Interval 1 st PeriodRF23 / 2020IWE ContainmentBolted Connections 4 th Interval 1 st PeriodRF23 / 2020IWE ContainmentSurface AreaInspections 4 th Interval 1 st PeriodRF23 / 2020ILRT Type A Test 4 th Interval 1 st PeriodRF23 / 2020 to W3F1-2015-0047Page 13 of 16RAI #9Attachment 4 of the LAR states that Table 4-1 presents summaries of the results from the WF3shield building interior and exterior structural inspections which were performed during eachrefueling shutdown and prior to any integrated leak test. Contrary to this statement, Section 4.3of the LAR states that Table 4-1 presents summaries of the results from the WF3 containmentbuilding interior and exterior structural inspections which were performed every three years andthe shield building inspection was performed prior to any integrated leak test. Also, the datesincluded in Table 4-1 do not appear to support the statement in Attachment 4 that the WF3shield building was inspected during each refueling outage. Please provide clarification.RAI #9 Response:The following clarifications are provided. For completeness, clean (revised) copies of theaffected sections of the original LAR (Reference 2) have been provided as part of this response.Attachment 2 to this RAI response provides a clean (revised) copy of Section 4.3 of the LAR(Reference 2) and Attachment 3 to this RAI response provides a clean (revised) copy ofAttachment 4 of the LAR (Reference 2).The structural integrity inspection of the inside and outside of the containment vessel isperformed at a 2R periodicity (3yrs).The structural integrity inspection of the inside and outside of the shield building is performedprior to any integrated leak rate test.The fifth paragraph of Section 4.3 of the LAR (Reference 2) is revised to state, "Table 4-1presents summaries of the results from the WF3 shield building interior and exterior structuralinspection surveillances. These surveillances were performed prior to any integrated leak rate test."The title of Attachment 4 of the LAR (Reference 2) is revised to state, "Summary of the Resultsfrom Shield Building and Containment Inspections"The title on page 1 of 4 of Attachment 4 of the LAR (Reference 2) is revised to state, "Summaryof the Results from Shield Building and Containment Inspections"The first paragraph on page 1 of 4 of Attachment 4 to the LAR (Reference 2) is revised to state,"Below is a list of WF3 shield building and containment inspections and summaries of theresults of those inspections. Note: Subsection IWL does not apply to Waterford 3 since thecontainment vessel does not rely on the detached concrete shell for structural support orpressure retention."The second paragraph on page 1 of 4 of Attachment 4 to the LAR(Reference 2) is revised tostate, "Table 4-1 presents summaries of the results from the WF3 shield building interior andexterior structural inspection surveillances. These surveillances were performed prior to anyintegrated leak rate test." to W3F1-2015-0047Page 14 of 16The title of Table 4-1 is revised to "Shield Building Interior and Exterior Structural Inspections"The following information is added to Table 4-1 of the LAR (Reference 2):September 1995The following interior and exterior areas of the shield building wereinspected with no deficiencies noted: shield building roof, exterior shieldbuilding walls to the roof, exterior surfaces in areas of the DCT-A, DCT-B,B Switchgear, +35 penetration rooms, MSIV A, MSIV B, MSIV passageway, -4 RAB wing area, -35 RAB wing area, and +21 RAB. All accessiblepenetrations, CAP valves, and the top of the containment vessel wereinspected inside the annulus with no structural problems observed.Interior inspections were performed on penetrations from elevations -4,+21, electrical penetrations at +35 and +46, and the containment ringheader with no structural deficiencies.The following information is removed from Table 4-1 of the LAR (Reference 2):November 2009The general visual inspection of the containment vessel was performedalong with the IWE inspections. Inspection of the shield building noted nochanges from the previous inspections.December 2012The general visual inspection of the containment vessel was performedalong with the IWE inspections and the results were satisfactory.RAI #12bPlease provide the following information:b. Percent of the total number of Type C tested components that are on 60-monthextended performance-based test interval.RAI #12b Response:Forty-eight percent (48%) of the total number of Type C tested components are on a 60-monthextended performance-based test interval.WF3 has ninety-five (95) Type C tested components; forty-six (46) are on a 60-month testfrequency, four (4) are on a 48-month test frequency, twenty (20) are on an 18-month testfrequency, twenty-one (21) are on an 18-month frequency tied to IST testing, and four (4) are onan 18-month test frequency and are not included in performance based testing under Option B.Of the 95 Type C tested components, seventy (70) are eligible to be placed on a 60-monthextended interval based on component performance history. Currently, forty-six (46) of theeligible seventy (70), or 66%, of the Type C tested components are on a 60-month extendedperformance-based test interval.Based on the results of recent testing as shown in Section 4.2 of the LAR, sufficient margin hasbeen maintained based on a decent Type B and Type C component performance. The to W3F1-2015-0047Page 15 of 16combined Type B and Type C leakage acceptance criteria is 630,000 sccm. The maximum andminimum pathway leakage rate summary totals for the last two refueling outages were:RF18 As-Found Minimum Pathway Leakage = 52,520 sccmRF18 As-Left Maximum Pathway Leakage = 48,205 sccmRF19 As-Found Minimum Pathway Leakage = 56,849 sccmRF19 As-Left Maximum Pathway Leakage = 69,947 sccm to W3F1-2015-0047Page 16 of 16

References:

1. Entergy Letter W3F1-2015-0021, Response to Request for Additional InformationRegarding the Request to Permanently Extend the Integrated Leak Rate Frequency to15 Years, dated May 4, 2015. (ADAMS Accession No. ML15124A946)2. Entergy Letter W3F1-2014-0052, License Amendment Request to Change TechnicalSpecifications to Extend the Type A Test Frequency to 15 Years, dated August 28,2014. (ADAMS Accession No. ML14241A305) W3F1-2015-0047Revised Section 4.3 from License Amendment Request to Change TechnicalSpecifications to Extend the Type A Test Frequency to 15 Years to W3F1-2015-0047Page 1 of 2This attachment provides a clean, revised copy of Section 4.3 of the original LAR (Reference 1).It should be noted that references to other attachments and tables are in the context of theoriginal LAR (Reference 1).4.3 Supplemental Inspection RequirementsConsistent with the guidance provided in NEI 94-01, Revision 2, Section 9.2.3.2, a generalvisual examination of accessible interior and exterior surfaces of the containment for structuraldeterioration that may affect the containment leak-tight integrity is conducted prior to each TypeA test and during at least three other outages before the next Type A test if the interval for theType A test has been extended to 15 years.Per SE Section 3.1.1.3, "To avoid duplication or deletion of examinations, licensees using NEITR 94-01, Revision 2, have to develop a schedule for containment inspections that satisfy theprovisions of Section 9.2.3.2 of this TR and ASME Code,Section XI, Subsection IWE and IWLrequirements."These inspections are performed along with the IWE program inspections and are ensured via arecurring task established to perform a containment building integrity check every three years aswell as a recurring task to perform a shield building integrity check to coincide with theperformance of the ILRT.Attachment 4 provides a list of the summaries of the results from various WF3 reactor buildinginspections. It should be noted that Subsection IWL does not apply to Waterford 3 since thecontainment vessel does not rely on the detached concrete shell for structural support orpressure retention.Table 4-1 presents summaries of the results from the WF3 shield building interior and exteriorstructural inspection surveillances. These surveillances were performed prior to any integratedleak rate test.Table 4-2 presents the IWE inspection summary results. WF3 has three (3) in-serviceinspection (ISI) periods during each ten (10) year Interval.The current testing frequencies for Type B and C tests are not affected by this requestedamendment to permanently extend the Type A test interval to fifteen (15) years. to W3F1-2015-0047Page 2 of 2

References:

1. Entergy Letter W3F1-2014-0052, License Amendment Request to Change TechnicalSpecifications to Extend the Type A Test Frequency to 15 Years, dated August 28,2014. (ADAMS Accession No. ML14241A305) W3F1-2015-0047Revised Attachment 4 from License Amendment Request to ChangeTechnical Specifications to Extend the Type A Test Frequency to 15 Years to W3F1-2015-0047Page 1 of 5This attachment provides a clean, revised copy of Attachment 4 of the original LAR (Reference 1). Itshould be noted that references to other attachments and tables are in the context of the original LAR(Reference 1).Summary of the Results fromShield Building and Containment InspectionsBelow is a list of WF3 shield building and containment inspections and summaries of the results ofthose inspections. Note: Subsection IWL does not apply to Waterford 3 since the containment vesseldoes not rely on the detached concrete shell for structural support or pressure retention.Table 4-1 presents summaries of the results from the WF3 shield building interior and exteriorstructural inspection surveillances. These surveillances were performed prior to any integratedleak rate test.Table 4-2 presents the IWE inspection summary results. WF3 has three (3) ISI periods duringeach ten (10) year Interval. to W3F1-2015-0047Page 2 of 5Table 4-1Shield Building Interior and Exterior Structural InspectionsMay 1988The exterior and interior of the shield building were examined prior topressurization for the first periodic Type A ILRT performed for WF3. Noevidence of deterioration was found as documented in letter W3P88-1283dated August 23, 1988.June 1991The exterior and interior surfaces of the shield building were examinedprior to pressurization for the second periodic Type A ILRT performed forWF3. No evidence of deterioration was found as documented in letterW3F1-91-0447 dated August 12, 1991.September 1995The following interior and exterior areas of the shield building wereinspected with no deficiencies noted: shield building roof, exterior shieldbuilding walls to the roof, exterior surfaces in areas of the DCT-A, DCT-B,B Switchgear, +35 penetration rooms, MSIV A, MSIV B, MSIV passageway, -4 RAB wing area, -35 RAB wing area, and +21 RAB. All accessiblepenetrations, CAP valves, and the top of the containment vessel wereinspected inside the annulus with no structural problems observed.Interior inspections were performed on penetrations from elevations -4,+21, electrical penetrations at +35 and +46, and the containment ringheader with no structural deficiencies.May 2005The general visual inspection results reflect compliance with the buildingstructural integrity requirements.All accessible areas of the inner shield building were examined from theannulus area. The shield building was inspected from the interior of theannulus. Superficial cracks were found on the surface of the shieldbuilding dome. These cracks appeared to be minor in appearance withcalcium carbonate deposits on the surface. This was reported during theprevious inspection on April 10, 1991. No change was noted at the timeof inspection.The exterior of the Shield Building was inspected from the +46 elevationup to the Shield Building dome and accessible areas of the exterior ShieldBuilding from the bottom of the cooling towers and RAB (-35 elevation onup). Several small horizontal cracks on multiple vertical Shield Building'ribs' were identified at varying heights. Surface cracks were identifiedbetween 3FA & 2FH @ 8A, Westside Dry Cooling Tower, approximately+5 elevation, 20-25 ft in length. Surface cracks were identified between2FH & 1FH Westside Dry Cooling Tower, approximately +5 elevation, 15-20 ft in length. An examination was performed of the roof of the shieldbuilding. Small surface cracking was present as found in the lastinspection on 4/30/91. This inspection revealed no apparent growth ofcracking, nor any new signs of structural deterioration. to W3F1-2015-0047Page 3 of 5Table 4-2IWE InspectionsNovember 2003An inspection of the containment building integrity was conducted inaccordance with Section XI IWE per WO 26901. A general visualinspection was performed including 100% of the accessible containmentvessel surface areas and the area around the Fuel Transfer Tube. VT-3examinations of the coatings on the interior of the containment vesselfound areas with flaking, peeling, blistering, and discoloration of thepainting (CR-WF3-2003-3082 and CR-WF3-2003-3142). Containmentcoating is not classified as an IWE component. While IWE does containseparate examination requirements of some non-structural componentssuch as seals, gaskets, and moisture barriers; it does not containseparate examination requirements for containment coating. Theselocations were repaired and re-inspected in RF12 with satisfactory results.VT-3 examinations of the interior moisture barrier (located between thecontainment vessel and the concrete floor on the ledge on elevation -4)revealed 13 locations where the moisture barrier has failed by acombination of tearing and cracking (CR-WF3-2003-3083). Thesedamaged sections were removed and replaced with new sealant underWO 27307.May 2005A general visual inspection of the inside liner plate was performed inaccordance with ASME Section XI Subsection IWE. The examination ofthe liner plate met the screening criteria or was accepted by theresponsible Engineer. The general visual inspection results reflectcompliance with the building structural integrity requirements.All accessible areas of the outer liner plate were examined from theannulus area. The steel liner plate was inspected in all accessible areasand no discrepancies were found.Fall 2006Eleven (11) bolted connection inspections were performed in RF14 withsatisfactory results.Spring 2008The inner and outer moisture barrier sections MB-01 through MB-15 wereinspected in RF15 under WO 125996. All sections were satisfactory withthe exception of sections MB-02, -03, -05, and -06 which revealed signsof age related degradation and mechanical damage which requiredrepair.November 2009The inner and outer moisture barrier sections MB-01 through MB-15 aswell as containment surface area inspections of dome quadrants 1through 9, plates 1 through 162 (with the exception of 71), and the areaaround the fuel transfer tube were performed in RF16 with satisfactory results.April 2011Twenty-seven (27) program bolted connections were examined in RF17with satisfactory results. to W3F1-2015-0047Page 4 of 5December 2012Containment surface area inspections were performed on sections MB-01through MB-15 in RF18 as well as the moisture barrier inside the annulusfrom 0° to 138° azimuth. Results of the liner inspections weresatisfactory. As a result of the steam generator replacement activities,hydroblasting was performed and water was found standing on themoisture barrier between the 30° and 70° azimuth location. Three18"x18" moisture barrier sections were removed and the liner examinedat the 30°, 42°, and 70° locations to assure no active degradation waspresent. After replacement of these sections of the moisture barrier, anexamination of the repaired moisture barrier areas were performed; theexamination results were satisfactory.May 2014The inner moisture barrier was inspected in RF19 of items MB-02 throughMB-11 with satisfactory results. The outer moisture barrier was inspectedin RF18. Twenty-seven (27) program bolted connections were examinedin RF19 with satisfactory results. to W3F1-2015-0047Page 5 of 5

References:

1. Entergy Letter W3F1-2014-0052, License Amendment Request to Change TechnicalSpecifications to Extend the Type A Test Frequency to 15 Years, dated August 28, 2014.(ADAMS Accession No. ML14241A305)