ML18180A298

Issuance of Amendment No. 252 Adoption of the Raptor-M3G Code for Neutron Fluence Calculations

ML18180A298
Person / Time
Site:	Waterford
Issue date:	07/23/2018
From:	April Pulvirenti Plant Licensing Branch IV
To:	Entergy Operations
Pulvirenti A
References
EPID L-2017-LLA-0399
Download: ML18180A298 (13)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 23, 2018 Site Vice President Entergy Operations, Inc..

Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3- ISSUANCE OF AMENDMENT RE: ADOPTION OF THE RAPTOR-M3G CODE FOR NEUTRON FLUENCE CALCULATIONS (EPID L-2017-LLA-0399)

Dear Sir or Madam:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 252 to Facility Operating License No. NPF-38 for the Waterford Steam Electric Station, Unit 3. This amendment consists of changes to the Updated Final Safety Analysis Report (UFSAR) in response to your application dated November 28, 2017, as supplemented by letters dated December 7, 2017, and May 8, 2018.

The amendment revises Section 4.3.3, "Analytical Methods," of the UFSAR to indicate that the RAPTOR-M3G fluence code is used for reactor vessel fluence calculations.

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, April L. Pulvirenti, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosures:

1. Amendment No. 252 to NPF-38

2. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555--0001 ENTERGY OPERATIONS, INC.

DOCKET NO. 50-382 WATERFORD STEAM ELECTRIC STATION, UNIT 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 252 License No. NPF-38

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Entergy Operations, Inc. (EOl),dated November 28, 2017, as supplemented by letters dated December 7, 2017, and May 8, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, by Amendment No. 252, Facility Operating License No. NPF-38 is hereby amended to authorize revision to the Waterford Steam Electric Plant, Unit 3, Final Safety Analysis Report as set forth in the licensee's application dated November 28, 2017, as supplemented by letters dated December 7, 2017 and May 8, 2018, and evaluated in the NRC staff's evaluation enclosed with this amendment.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: July 23, 2018

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 252 TO FACILITY OPERATING LICENSE NO. NPF-38 ENTERGY OPERATIONS, INC.

WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382

1.0 INTRODUCTION

By application dated November 28, 2017 (Reference 1), as supplemented by letters dated December 7, 2017 (Reference 2), and May 8, 2018 (Reference 3), Entergy Operations, Inc. (the licensee), submitted a license amendment request (LAR) to incorporate the use of the RAPTOR-M3G code into the Waterford Steam Electric Station, Unit 3 (Waterford 3) current licensing basis (CLB). As stated, in part, by the licensee in the application: "The proposed change revises Section 4.3.3 of the [Updated Final Safety Analysis Report] (UFSAR) to indicate that the RAPTOR-M3G code is used for the reactor vessel fluence calculations." Attachment 2, "Evaluation of Proposed Change," of the application, contains the evaluation of the proposed change. The amendment incorporates the neutron fluence values calculated using RAPTOR-M3G for 32 effective full power years (EFPY) of plant operation, which is the approximate end of the current 40-year license period for Waterford 3.

The supplemental letter dated May 8, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC or the Commission) staffs original proposed no significant hazards consideration determination as published in the Federal Register on January 16, 2018 (83 FR 2228).

2.0 REGULATORY EVALUATION

Waterford 3 requested a change to the methodology for the calculation of reactor vessel (RV) fluence to use the RAPTOR-M3G code. Waterford 3 is subject to the General Design Criteria (GDC) described in Appendix A of Title 10 the Code of Federal Regulations (10 CFR) Part 50, "General Design Criteria for Nuclear Power Plants." With respect to the GDC contained in Appendix A of 10 CFR Part 50, Regulatory Guide (RG) 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence" (Reference 4), describes methods and assumptions acceptable to the NRC staff for determining the RV neutron fluence. In consideration of the guidance set forth in RG 1.190, GDC 14, 30, and 31 are applicable as follows:

Enclosure 2

• GDC 14, "Reactor coolant pressure boundary," requires the design fabrication, erection, and testing of the reactor coolant pressure boundary so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture.

• GDC 30, "Quality of reactor coolant pressure boundary," requires, among other things, that components comprising the reactor coolant pressure boundary be designed, fabricated, erected, and tested to the highest quality standards practical.

• GDC 31, "Fracture prevention of reactor coolant pressure boundary," pertains to the design of the reactor coolant pressure boundary. GDC 31 states that:

The reactor coolant pressure boundary shall be designed with sufficient margin to assure that when stressed under operating, maintenance, testing, and postulated accident conditions ( 1) the boundary behaves in a nonbrittle manner and (2) the probability of rapidly propagating fracture is minimized. The design shall reflect consideration of service temperatures and other conditions of the boundary material under operating, maintenance, testing, and postulated accident conditions and the uncertainties in determining (1) material properties, (2) the effects of irradiation on material properties, (3) residual, steady state and transient stresses, and ( 4) size of flaws.

The phrase from GDC 31, "uncertainties in determining ... the effects of irradiation on material properties" is applicable to this LAR.

As stated in Attachment 1, "Proposed Changes to UFSAR Sections" of the LAR (Reference 1),

prior to 1994, RV neutron fluence analysis was calculated by combining the results of ANISN and SHADRAC codes. By letter dated June 16, 2004 (Reference 5), the NRC staff issued Amendment No. 196 for Waterford 3, which approved the use of the DORT code, developed by Oak Ridge National Laboratory (ORNL) (Reference 6), to calculate neutron fluence values used in the development of Waterford 3 pressure-temperature (P-T) limits located in Section 3/4.4.8, "Pressure/Temperature Limits," of the Waterford 3 Technical Specifications.

The neutron fluence calculated by the DORT code accounted for the measurement uncertainty recapture (MUR) power uprate of 1.5 percent, which had been implemented at the beginning of cycle 12, as approved by Amendment No. 183, issued by letter dated March 29, 2002.

(Reference 7). On April 15, 2005, the NRC issued Amendment No. 199 (Reference 8) approving an extended power uprate (EPU) of approximately 8 percent, which was implemented at the beginning of cycle 14. Amendment No. 199 confirmed the conclusions of Amendment No. 196 with respect to the CLB neutron fluence method while also modifying the surveillance capsule withdrawal schedule.

Currently, the DORT code is referenced in the Waterford 3 CLB as a citation in the Waterford 3 UFSAR. The requirements at 10 CFR 50.59, "Changes, tests, and experiments,"

paragraph (c }( 1} states, in part, that:

A licensee may make changes in the facility as described in the final safety analysis report (as updated} ... without obtaining a license amendment pursuant to §50.90 only if:

(i} A change to the technical specifications incorporated in the license is not required, and (ii} The change, test, or experiment does not meet any of the criteria in paragraph (c}(2} ....

The regulation, 10 CFR 50.59(c}(2}(viii}, states, in part, that:

A licensee shall obtain a license amendment pursuant to§ 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would: Result in a departure from a method of evaluation described in the final safety analysis report (as updated} used in establishing the design bases or in the safety analyses.

The calculational method to determine the neutron fluence (i.e., the fluence code such as DORT or RAPTOR} is a method of evaluation used to establish the design basis for Waterford 3, as stated in 10 CFR 50.59. Therefore, in order to change the calculational method, the licensee is required to submit an LAR pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit."

The RAPTOR-M3G code, as a generic neutron fluence calculational methodology, was documented in WCAP-18124-NP, Revision 0, "Fluence Determination with RAPTOR-M3G and FERRET," and submitted by Westinghouse Electric Company (Westinghouse} for NRC review by letter dated January 25, 2017 (Reference 9). By letter dated November 21, 2017 (Reference 10), the NRC staff issued requests for additional information (RAls} to Westinghouse, and Westinghouse provided responses by letter dated January 18, 2018 (Reference 11 }. These responses to the RAls were incorporated into the Waterford 3 LAR to adopt the RAPTOR-M3G code by the supplement dated May 8, 2018 (Reference 3).

By letter dated June 15, 2018 (Reference 12), the NRC staff determined that the RAPTOR-M3G methodology met the requirements of acceptability for general use for pressurized water reactor (PWR} RV fluence calculations as documented in the final safety evaluation (SE} for WCAP-18124-NP, Revision O (Reference 13). The SE forWCAP-18124-NP, Revision O states, in part, "The NRC staff has reviewed the calculational fluence methodology described in WCAP-18124-NP, Revision 0, and finds that the method adheres to the guidance in RG 1.190" (i.e., that the methodology meets the requirements of the cited GDCs}. The SE for WCAP-18124-NP, Revision 0, also states, in part, that "applicability of WCAP-18124-NP, Revision 0, is limited to the traditional RPV [reactor pressure vessel] beltline region." The SE also indicates that WCAP-18124-NP, Revision 0, is not applicable for the extended beltline region, defined during license renewal.

The NRC staff has verified that the RV neutron fluence calculational methodology, described in of the Waterford 3 LAR (Reference 1} along with the Westinghouse responses to the RAI (Reference 11 }, which have been adopted into the Waterford 3 LAR (Reference 3), is

consistent with the approved generic RV neutron fluence calculational methodology documented in WCAP-18124-NP, Revision 0. Therefore, the staff has determined that the generic aspects of the approved generic RAPTOR-M3G code, where applicable, may be referenced in the evaluation of the Waterford 3 LAR to adopt the RAPTOR-M3G code.

3.0 TECHNICAL EVALUATION

3.1 Background As described in Attachment 1 of the Waterford 3 LAR (Reference 1), prior to the issuance of Amendment No. 196 (Reference 5), calculation of RV neutron fluence analysis using the ANISN and SHADRAC codes resulted in a peak RV fluence of 3.68 x 10 19 neutrons per square centimeter (n/cm 2 ) with energies greater than 1 million-electron-volts (E > 1 MeV) at the 40-year design life of the RV. These calculations assumed a power rating of 3560 megawatts thermal (MWt), an 80 percent capacity factor, 1 and a calculated fluence with a 10 percent uncertainty factor.

After the issuance of Amendment No. 196 (Reference 5), the Waterford 3 CLB neutron fluence calculations were performed using the DORT code with BUGLE-96 neutron cross sections (Reference 14) with anisotropic scattering treated with a P3 Legendre approximation and the angular discretization modeled with an 815 angular quadrature. The DORT fluence analysis accounted for the MUR power uprate of 1.5 percent, which was implemented at the beginning of cycle 12 - a change from 3390 MWt to 3441 MWt - and an 8 percent EPU - a change from 3441 MWt to 3716 MWt - scheduled for cycle 14 and projected to the end of licensed operation.

Amendment No. 199, approving the EPU (Reference 8), confirmed the Amendment No. 196 (Reference 5) conclusions with respect to the CLB neutron fluence method, while also modifying the surveillance capsule withdrawal schedule. Consequently, the maximum neutron fluence for 32 EFPY of operation, using the DORT and BUGLE-96 codes, was determined to be 2.48 x 1019 n/cm 2 after accounting for MUR and EPU conditions.

By changing to the RAPTOR-M3G code to calculate neutron fluence values used in the development of Waterford 3 P-T limits, the licensee now predicts a peak RV fluence of 2.57 x 10 19 n/cm 2 (E > 1 MeV), an increase of less than 5 percent. Consistent with previous analyses, the licensee states in the LAR that "thermal power assumptions were 3390 MWt for the first 11 cycles [of operation], 3441 MWt for the 12th and 13th cycles, and 3716 MWt from cycle 14 through the end of design life." The NRC staff notes that the observed increase is only for a single point estimate, and is comparable to the currently estimated peak RV neutron fluence. The NRC staff also notes that fluence differences between the current and proposed calculational fluence methods are not expected to be consistent across all RV locations because the shape of the RV fluence distributions come from fundamentally different methods (i.e., a one- and two- dimensional (1 D/20) flux synthesis calculation versus a direct three-dimensional (30) calculation). However, the NRC staff expects RAPTOR-M3G to be more accurate than DORT because RAPTOR-M3G directly calculates fluence on a 30 basis as opposed to using the more approximate synthesis of separate 1D and 20 fluence calculations.

1 This is the equivalent of 32 EFPY of operation (i.e., 100 percent power for 32 out of 40 years of licensed operation).

3.2 Technical Discussion 3.2.1 Generic Fluence Calculations As stated above, the NRC staff has reviewed and approved the generic neutron fluence calculational methodology as documented in WCAP-18124-NP, Revision 0. The NRC staff has verified that the RV neutron fluence calculational methodology described in Attachment 2 to the Waterford 3 LAR and the May 8, 2018, supplement incorporating the Westinghouse responses to the RAI (References 1 and 3) is consistent with the generic RV neutron fluence calculational methodology described in WCAP-18124-NP, Revision O (Reference 9). In addition, the NRC staff has verified that the Waterford 3 LAR requests the use of RAPTOR-M3G only for RV neutron fluence evaluations up to 32 EFPY (i.e., the traditional beltline region). Therefore, the generic neutron fluence calculational methodology as described in WCAP-18124-NP, Revision 0, is applicable to the Waterford 3 LAR up to 32 EFPY.

3.2.2 Plant-Specific Fluence Calculational Uncertainty Considerations The fluence calculational uncertainty analysis, as defined in WCAP-18124-NP, Revision 0, is comprised of uncertainty components from simulator benchmark comparisons (3 percent),

H. B. Robinson Steam Electric Plant Unit No. 2, benchmark comparisons (5 percent), analytic sensitivity studies ( 11 percent), and other factors resulting in a net calculational uncertainty of 13 percent near the RV mid-plane location. As discussed in WCAP-18124-NP, Revision 0, Westinghouse operating reactor measurement database, which includes measurements from various PWR nuclear steam supply system designs currently operating in the United States, including Combustion Engineering (CE) and Westinghouse designs, is seen to be bounded by this estimate of 13 percent based on an in-vessel average measured-to-calculated neutron fluence ratio of 1.03 with a 5 percent standard deviation. The component that is potentially subject to change is the analytic uncertainty component due to geometric, material, and operational differences between PWRs. Consequently, the licensee confirmed that the expected analytic uncertainty component remains 11 percent for Waterford 3.

For analytic uncertainty, the licensee compared uncertainty components in Waterford 3 with those previously calculated for Catawba Nuclear Station, Units 1 and 2 (Catawba). The uncertainty components for Catawba were submitted in an LAR for an MUR by letter dated June 23, 2014 (Reference 15), and clarified in a supplement dated November 30, 2015 (Reference 16). The uncertainty components for Catawba were subsequently approved as part of Amendment No. 281, which was issued by letter dated April 29, 2016 (Reference 17). In Section 3.1, "Plant Configuration Differences between Catawba Unit 1 and Waterford 3," of the Waterford 3 LAR (Reference 1), the licensee compares the impact of each geometric uncertainty component at the core mid-plane location near the inner RV wall on the overall analytic uncertainty analysis between the Catawba Unit 1 reactor2 and the Waterford 3 reactor-a CE 2-loop reactor design. The assessment included the contributions of the following components and their expected variations:

• Stainless steel reactor internals components,

• RV inner radius and in-vessel surveillance capsule positions, 2 WCAP-18124-NP models a Westinghouse 4-loop reactor when determining the total analytic uncertainty for various locations, which is consistent with the Catawba Unit 1 analytic uncertainty analysis documented in WCAP-18060-NP, Revision 1 (Reference 16).

• RV thickness tolerance, and

• Adequacy of the modeling of the rectilinear geometry of the core periphery and baffle plates in cylindrical geometry.

Likewise, in Section 3.2, "Operational Differences between Catawba Unit 1 and Waterford 3," of the Waterford 3 LAR, the licensee compares the impact of each operational uncertainty component at the core mid-plane location near the inner RV wall on the overall analytic uncertainty analysis between the Catawba Unit 1 reactor and the Waterford 3 reactor. The assessment included the contributions of the following components and their expected variations: 3

• Core average moderator temperature and associated density,

• Core inlet temperature and associated density,

• Peripheral assembly source magnitude,

• Peripheral assembly relative pin power,

• Peripheral assembly burnup, and

• Axial power distribution.

The licensee demonstrated that each analytic uncertainty component is essentially the same for both Catawba Unit 1 and Waterford 3 at the core mid-plane, 4 therefore the total analytic uncertainty of 11 percent determined for Catawba Unit 1 is applicable to Waterford 3.

3.2.3 Neutron Dosimetry In WCAP-17969-NP, Revision 0, "Analysis of Capsule 83° [Degrees] from the Entergy Operations, Inc. Waterford Unit 3 Reactor Vessel Radiation Surveillance Program," dated April 2015 (Reference 18), Appendix A, Section A.1.3, "Comparisons of Measurements and Calculations," it states: "The overall average BE/C [best-estimate-to-calculated] ratios for neutron fluence rate (E > 1 MeV) and iron atom displacement rate are 1.08 with a standard deviation of 3. 7% and 1.08 with a standard deviation of 2.8%, respectively." Further inspection of Table A-15, "Comparison of Best-Estimated/Calculated (BE/C) Exposure Rate Ratios," shows a BE/C ratio of 1.08 with a standard deviation of 3-4 percent after considering 545 dosimeters from 3 surveillance capsules. The rigorous accounting of uncertainties via least squares adjustment with FERRET, and the relatively small standard deviation associated with the BE/C ratio, provides evidence that Waterford 3 has a nonconservative plant-specific bias of approximately 8 percent. This can be interpreted to mean that correction of Waterford 3 calculated neutron fluence values is warranted before use in P-T limits analyses. However, despite the apparent plant-specific fluence method bias, the bias and uncertainty collectively remains consistent with the RG 1.190 uncertainty allowance of 20 percent. Consequently, the NRC staff finds that a bias correction does not need to be included in the fluence calculation, and confirms that the Waterford 3 BE/C values are consistent with the overall operating reactor measurements database described in WCAP-18124-NP, Revision 0.

3 In Table 30 of the LAR (Reference 1), "Summary of Operational Parameters used in the Catawba Unit 1 Uncertainty Analysis and in Waterford 3," the licensee demonstrates the similarity in operating conditions between the two plants.

4 Except for the RV thickness tolerance, which was determined to be irrelevant to Waterford 3.

5 Each capsule contained 7 dosimeter types with 3 dosimeters per type (i.e., 21 dosimeters per capsule for a total of 63 dosimeters).

3.3 Summary of Technical Evaluation The NRC staff determined that the neutron fluence calculational methodology described in of the LAR (Reference 1) to be consistent with the generic PWR RV neutron fluence calculational methodology discussed in detail in the WCAP-18124-NP, Revision O (Reference 9), which the NRC staff has determined to be acceptable for use in licensing applications and applicable to the Waterford 3 LAR. Additionally, the NRC staff found that plant-specific components of the fluence calculational methodology were considered and treated appropriately, and the observed bias and uncertainty associated with Waterford 3 dosimetry collectively remains consistent with the RG 1.190 uncertainty allowance of 20 percent.

Therefore, the neutron fluence calculational methodology described in Attachment 2 to the LAR dated November 28, 2017, as supplemented by letters dated December 7, 2017, and May 8, 2018, has met the requirements of GDCs 14, 30, and 31, and the guidance outlined in RG 1.190, and is therefore acceptable for use at Waterford 3 for RV neutron fluence evaluations up to 32 EFPY.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Louisiana State official was notified of the proposed issuance of the amendment on July 5, 2018. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on January 16, 2018 (83 FR 2228). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Dinelli J. C., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "License Amendment Request for Use of RAPTOR-M3G Code for Neutron Fluence Calculations, Waterford Steam Electric Station, Unit 3 (Waterford 3)," dated November 28, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17332A898).

2. Dinelli J. C., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "License Renewal Application Supplement Clarification, Waterford Steam Electric Station, Unit 3 (Waterford 3)," dated December 7, 2017 (ADAMS Accession No. ML173418295).

3. Dinelli J.C., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Supplement to License Amendment Request for the Use of RAPTOR-M3G Code for Neutron Fluence Calculations for Waterford Steam Electric Station, Unit 3 (Waterford),"

dated May 8, 2018 (ADAMS Accession No. ML18128A371).

4. U.S. Nuclear Regulatory Commission, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence," Regulatory Guide 1.190, dated March 2001 (ADAMS Accession No. ML010890301).

5. Kalyanam, N., U.S. Nuclear Regulatory Commission, letter to Mr. Joseph E. Venable, Entergy Operations, Inc., "Waterford Steam Electric Station, Unit 3 - Issuance of Amendment Re: Pressure Temperature Limit Curves to 32 Effective Full Power Years with Power Uprate {TAC No. MC1156)," dated June 16, 2004 (ADAMS Accession No. ML041700466).

6. Oak Ridge National Laboratory, "DOORS 3.2A, One- Two- and Three Dimensional Discrete Ordinates Neutron/Photon Transport Code System," Radiation Safety Information Computational Center (RSICC) Code Package CCC-650, dated May 2007.

7. Kalyanam, N., U.S. Nuclear Regulatory Commission, letter to Mr. Joseph E. Venable, Entergy Operations, Inc., "Waterford Steam Electric Station, Unit 3 - Issuance of Amendment Re: Appendix K Margin Recovery - Power Uprate Request (TAC No. MB2971)," dated March 29, 2002 (ADAMS Accession No. ML020910734).

8. Kalyanam, N., U.S. Nuclear Regulatory Commission, letter to Mr. Joseph E. Venable, Entergy Operations, Inc., "Waterford Steam Electric Station, Unit 3 - Issuance of Amendment Re: Extended Power Uprate," dated April 15, 2005 (ADAMS Accession No. ML051030068).

9. Gresham, J. A., Westinghouse Electric Company LLC, letter to U.S. Nuclear Regulatory Commission, "Submittal of WCAP-18124-NP, Revision 0, 'Fluence Determination with RAPTOR-M3G and FERRET,"' dated January 25, 2017 (ADAMS Accession No. ML17030A377).

10. Lenning, E., U.S. Nuclear Regulatory Commission, letter to Mr. James A. Gresham, Westinghouse Electric Company, "Request for Additional Information Re: Westinghouse Electric Company WCAP-18124-NP, Revision 0, 'Fluence Determination with RAPTOR-M3G and FERRET' Topical Report," dated November 21, 2017 (ADAMS Accession No. ML17290A147).

11. Gresham, J. A., "Westinghouse Electric Company, letter to U.S. Nuclear Regulatory Commission, "Response to the NRC Request for Additional Information on the RAPTOR-M3G and FERRET Topical Report," dated January 18, 2018 (ADAMS Accession No. ML180188347).

12. Morey, D. C., U.S. Nuclear Regulatory Commission, letter to Mr. James A. Gresham, Westinghouse Electric Company, "Final Safety Evaluation for Westinghouse Electric Company Topical Report WCAP-18124-NP, Revision 0, 'Fluence Determination with RAPTOR M3G and FERRET"' dated June 15, 2018 (ADAMS Accession No. ML18156A018).

13. U.S. Nuclear Regulatory Commission, "Final Safety Evaluation for Topical Report WCAP-18124-NP, Revision 0, 'Fluence Determination with RAPTOR-M3G and FERRET,"' dated June 15, 2018 (ADAMS Accession No. ML18156A066).

14. Oak Ridge National Laboratory, "8UGLE-96 Coupled 47 Neutron, 20 Gamma-Ray Group Cross Section Library Derived from ENDF/8-VI For LWR Shielding and Pressure Vessel Dosimetry Applications," RSICC Data Library Collection DLC-185, 1996.

15. Henderson, K., Duke Energy, letter to U.S. Nuclear Regulatory Commission, Duke Energy Carolinas, LLC (Duke Energy), Catawba Nuclear Station, Units 1 and 2, Docket Numbers 50-413 and 50-414, 'License Amendment Request (LAR) for Measurement Uncertainty Recapture (MUR) Power Uprate," dated June 23, 2014 (ADAMS Accession No. ML14176A109).

16. Chen J., Westinghouse, "Response to RAls Concerning the Use of RAPTOR-M3G for the Catawba Unit 1 Measurement Uncertainty Recapture (MUR) Power Uprate Fluence Evaluations," WCAP-18060-NP, Revision 1, dated November 2015 (ADAMS Accession No. ML15324A084).

17. Whited, J. A., U.S. Nuclear Regulatory Commission, letter to Mr. Kelvin Henderson, Duke Energy Carolinas, LLC, "Catawba Nuclear Station, Units 1 and 2 - Issuance of Amendments Regarding Measurement Uncertainty Recapture Power Uprate (CAC Nos.

MF4526 and MF4527)," dated April 29, 2016 (ADAMS Accession No. ML16081A333).

18. Rosier 8. A. and Alpan, A., Westinghouse, "Attachment 1, W3F1-2015-0056, Report WCAP-17969-NP, Revision O dated April 2015, 'Analysis of Capsule 83° from the Entergy Operations, Inc. Waterford Unit 3 Reactor Vessel Radiation Surveillance Program,"' and "Attachment 2, 'List Of Regulatory Commitments,"' dated April 2015, (ADAMS Accession No. ML15222A361 ).

Principal Contributor: Amrit Patel Date: July 23, 2018

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - ISSUANCE OF AMENDMENT RE: ADOPTION OF THE RAPTOR-M3G CODE FOR NEUTRON FLU ENCE CALCULATIONS (EPID L-2017-LLA-0399) DATED JULY 23, 2018 DISTRIBUTION:

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NAME APulvirenti PBlechman SKrepel BBeasley DATE 7/5/18 7/3/18 6/8/18 7/3/18 OFFICE OGC -- NLO** NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME AGhosh RPascarelli APulvirenti DATE 7/12/18 7/20/18 7/23/18 OFFICIAL RECORD COPY