ML18103A015

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NRR E-mail Capture - Summary of Public Telephone Conference Call Held on March 27, 2018, Between the U.S. Nuclear Regulatory Commission and Entergy and Final Requests for Additional Information for the Safety Review of the River Bend Statio
ML18103A015
Person / Time
Site: River Bend Entergy icon.png
Issue date: 04/12/2018
From: Wong A
Division of Materials and License Renewal
To: Maguire W
Entergy Nuclear Operations
References
Download: ML18103A015 (9)


Text

NRR-DMPSPEm Resource From: Wong, Albert Sent: Thursday, April 12, 2018 2:04 PM To: Mr. William F. Maguire Cc: RidsNrrDmlr Resource; RidsNrrDmlrMrpb Resource; RidsNrrPMRiverBend Resource; RidsOgcMailCenter Resource; Wilson, George; Donoghue, Joseph; Sayoc, Emmanuel; Wong, Albert; Lopez, Juan; Lehman, Bryce; Thomas, George; Manoly, Kamal; Oesterle, Eric; Alley, David; Martinez Navedo, Tania; Bailey, Stewart; Wittick, Brian; Ruffin, Steve; Bloom, Steven; Regner, Lisa; Turk, Sherwin; Sowa, Jeffrey; Parks, Brian; Pick, Greg; Kozal, Jason; Young, Cale; Young, Matt; Werner, Greg; McIntyre, David; Dricks, Victor; Moreno, Angel; Burnell, Scott; 'Broussard, Thomas Ray'; Lach, David J; SCHENK, TIMOTHY A;

'Coates, Alyson'

Subject:

SUMMARY

OF PUBLIC TELEPHONE CONFERENCE CALL HELD ON MARCH 27, 2018, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY AND FINAL REQUESTS FOR ADDITIONAL INFORMATION FOR THE SAFETY REVIEW OF THE RIVER BEND STATION, UNIT 1 LICENSE RENEWAL APPLICATIO Attachments: RAI Set 13 Enclosures_Participants & Final 2 FU RAIs.pdf Docket No. 50-458

Dear Mr. Maguire:

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Operations, Inc.

(the applicant) held a public telephone conference call on March 27, 2018, to discuss and clarify the applicants response (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18038B475) to the staffs requests for additional information, RAIs 4.6-1 and 4.6-2 (TRP 63 Fatigue Analysis) contained in RAI Set 6, (ADAMS Accession No. ML17361A396). The telephone conference was held at the request of NRC to clarify the applicants response to the staffs original RAIs. A second clarification telephone call was held on April 11, 2018 between the staff and the applicant to further discuss the response. provides a listing of the participants of the March 27 conference call. Enclosure 2 includes the two final follow-up RAIs 4.6-1a and 4.6-2a.

Dave Lach of your staff agreed to provide a response to the final RAIs with 30 days from the date of the April 11, 2018 telephone call. The NRC staff will place a copy of this summary in ADAMS. The applicant had an opportunity to comment on this summary.

If you have any questions, please contact me by telephone at 301-415-4084 or via e-mail at Emmanuel.Sayoc@nrc.gov.

Sincerely, Emmanuel Sayoc, Project Manager License Renewal Project Branch Division of Materials and License Renewal Office of Nuclear Reactor Regulation Docket No. 50-458 1

Enclosures:

1. List of Participants for the March 27, 2018 Telephone Call
2. Final RAIs 4.6-1a and 4.6-2a OFFICE PM:MRPB:DMLR BC: MRPB:DMLR PM:MRPB:DMLR NAME ESayoc EOesterle ESayoc Albert Wong for DATE 03/27/2018 03/29/2018 04/12/2018 OFFICIAL RECORD COPY 2

Hearing Identifier: NRR_DMPS Email Number: 295 Mail Envelope Properties (Albert.Wong@nrc.gov20180412140400)

Subject:

SUMMARY

OF PUBLIC TELEPHONE CONFERENCE CALL HELD ON MARCH 27, 2018, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY AND FINAL REQUESTS FOR ADDITIONAL INFORMATION FOR THE SAFETY REVIEW OF THE RIVER BEND STATION, UNIT 1 LICENSE RENEWAL APPLICATIO Sent Date: 4/12/2018 2:04:18 PM Received Date: 4/12/2018 2:04:00 PM From: Wong, Albert Created By: Albert.Wong@nrc.gov Recipients:

"RidsNrrDmlr Resource" <RidsNrrDmlr.Resource@nrc.gov>

Tracking Status: None "RidsNrrDmlrMrpb Resource" <RidsNrrDmlrMrpb.Resource@nrc.gov>

Tracking Status: None "RidsNrrPMRiverBend Resource" <RidsNrrPMRiverBend.Resource@nrc.gov>

Tracking Status: None "RidsOgcMailCenter Resource" <RidsOgcMailCenter.Resource@nrc.gov>

Tracking Status: None "Wilson, George" <George.Wilson@nrc.gov>

Tracking Status: None "Donoghue, Joseph" <Joseph.Donoghue@nrc.gov>

Tracking Status: None "Sayoc, Emmanuel" <Emmanuel.Sayoc@nrc.gov>

Tracking Status: None "Wong, Albert" <Albert.Wong@nrc.gov>

Tracking Status: None "Lopez, Juan" <Juan.Lopez@nrc.gov>

Tracking Status: None "Lehman, Bryce" <Bryce.Lehman@nrc.gov>

Tracking Status: None "Thomas, George" <George.Thomas2@nrc.gov>

Tracking Status: None "Manoly, Kamal" <Kamal.Manoly@nrc.gov>

Tracking Status: None "Oesterle, Eric" <Eric.Oesterle@nrc.gov>

Tracking Status: None "Alley, David" <David.Alley@nrc.gov>

Tracking Status: None "Martinez Navedo, Tania" <Tania.MartinezNavedo@nrc.gov>

Tracking Status: None "Bailey, Stewart" <Stewart.Bailey@nrc.gov>

Tracking Status: None "Wittick, Brian" <Brian.Wittick@nrc.gov>

Tracking Status: None "Ruffin, Steve" <Steve.Ruffin@nrc.gov>

Tracking Status: None "Bloom, Steven" <Steven.Bloom@nrc.gov>

Tracking Status: None

"Regner, Lisa" <Lisa.Regner@nrc.gov>

Tracking Status: None "Turk, Sherwin" <Sherwin.Turk@nrc.gov>

Tracking Status: None "Sowa, Jeffrey" <Jeffrey.Sowa@nrc.gov>

Tracking Status: None "Parks, Brian" <Brian.Parks@nrc.gov>

Tracking Status: None "Pick, Greg" <Greg.Pick@nrc.gov>

Tracking Status: None "Kozal, Jason" <Jason.Kozal@nrc.gov>

Tracking Status: None "Young, Cale" <Cale.Young@nrc.gov>

Tracking Status: None "Young, Matt" <Matt.Young@nrc.gov>

Tracking Status: None "Werner, Greg" <Greg.Werner@nrc.gov>

Tracking Status: None "McIntyre, David" <David.McIntyre@nrc.gov>

Tracking Status: None "Dricks, Victor" <Victor.Dricks@nrc.gov>

Tracking Status: None "Moreno, Angel" <Angel.Moreno@nrc.gov>

Tracking Status: None "Burnell, Scott" <Scott.Burnell@nrc.gov>

Tracking Status: None

"'Broussard, Thomas Ray'" <tbrous1@entergy.com>

Tracking Status: None "Lach, David J" <DLach@entergy.com>

Tracking Status: None "SCHENK, TIMOTHY A" <TSCHENK@entergy.com>

Tracking Status: None

"'Coates, Alyson'" <alacey@entergy.com>

Tracking Status: None "Mr. William F. Maguire" <wmagui1@entergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 1834 4/12/2018 2:04:00 PM RAI Set 13 Enclosures_Participants & Final 2 FU RAIs.pdf 138106 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

ENCLOSURE 1 LIST OF PARTICIPANTS FOR THE MARCH 27, 2018 TELEPHONE CONFERENCE CALL PARTICIPANTS AFFILIATIONS Brian Wittick U.S. Nuclear Regulatory Commission (NRC)

Eric Oesterle NRC Juan Lopez NRC Emmanuel Sayoc NRC Albert Wong NRC Garry Young Entergy Nuclear Operations Inc. (Entergy)

Alan Cox Entergy Dave Lach Entergy Mark Spinelli Entergy Stan Batch Entergy Alyson Coates Entergy Kam Molavi Entergy Herb Rideout Entergy Jim Morgan Entergy Randy Gauthreaux Entergy Lisa Borel Entergy Mark Sandusky Entergy Mike Cooper Entergy Neal Graham GE-H Marvin Lewis Member of Public

ENCLOSURE 2 FINAL RAIS 4.6-1A AND 4.6-2A AFTER THE TELEPHONE CALL RAI 4.6-1a

Background

Section 4.6 of the SRP-LR states that if a plants code of record requires a fatigue parameter evaluation (fatigue analysis or fatigue waiver), then this analysis may be a time-limited aging analyses (TLAA) and must be evaluated in accordance with 10 CFR 54.21(c)(1) to ensure that the effects of aging on the intended functions are adequately managed for the period of extended operation.

The current licensing basis may include fatigue waiver evaluations that preclude the need for performing CUF analyses of structural components. The ASME Code Section III rules for performing fatigue waiver evaluations for structural components are analogous to those in the Code for performing fatigue waiver evaluations of mechanical components. ASME Code NE-3222.4(d) Analysis for Cyclic Operations, Vessels Not Requiring Analysis for Cyclic Operation, provides for a waiver from fatigue analysis when certain cyclic loading criteria are met.

RBS USAR Section 3.8.2.4.1 states: Fatigue analysis requirements for the steel containment cylinder and dome are evaluated in accordance with the requirements of ASME Boiler and Pressure Vessel Code Section III, Division I, Subsection NE.

In its response to RAI 4.6-1, dated February 6, 2018, the applicant stated, in part, the following:

[USAR] Table 3.8-1 indicates that fatigue is considered for operating conditions I(b) , II ,

III(b) and IV. The free standing SCV cylinder and dome analysis reviews the operating conditions identified in USAR Table 3.8-1 and concludes that fatigue during operating conditions I(b) , II , III(b) and IV does not occur because the containment vessel is free to expand, thereby preventing cyclic loading. Therefore, the freestanding containment vessel and dome were not analyzed for fatigue and there are no cycle limits or cumulative usage factors.

Issue It is not clear if the evaluation performed for the freestanding containment vessel and dome components constitutes a fatigue waiver that relies on time dependent cycles, and whether they were evaluated and dispositioned in accordance with 10 CFR 54.21(c)(1). RBS USAR Section 3.8.2.4.1 states that the containment cylinder and dome were evaluated in accordance with the requirements of ASME Code Section III, Division I, Subsection NE, however it is not clear if and how the conditions under ASME code Subsection NE-3222.4(d) were used to waive the requirements of a fatigue analysis for the freestanding containment vessel and dome. The staff notes that the current licensing basis may include fatigue waiver evaluations that preclude the need for performing CUF analyses of structural components which may be a TLAA and must be evaluated. The staff also notes that the statement containment vessel is free to expand, thereby preventing cyclic loading does not appear consistent with regard to fatigue or fatigue waiver considerations of the ASME code, Subsection NE, and cannot be concluded from USAR Table 3.8-1. Also LRA Table 3.5-1, item 27, doesnt appear to manage cracking due to cyclic loading for these components if no CLB fatigue or fatigue waiver analysis exists.

Request

1. Clarify if an evaluation was performed in accordance with ASME Code,Section III, Subsection NE-3222.4(d) to evaluate the fatigue analysis requirements for the

freestanding containment vessel and dome. If an evaluation was performed, state the assumed number of cycles and limits. Otherwise, clarify what requirements of the ASME Code Section III, Division I, Subsection NE were followed to evaluate the fatigue analysis requirements for the steel containment cylinder and dome (as described in RBS USAR Section 3.8.2.4.1).

2. State the disposition in accordance with 10 CFR 54.21(c)(1) for this evaluation.
3. If there is no CLB fatigue analysis or fatigue waiver analysis for these components, clarify if cracking due to cyclic loading will be managed by the GALL Report AMPs XI.S1 and XI.S4 in accordance with SRP-LR Table 3.5-1, item 27, by crediting appropriate leak rate tests that can detect such cracking. If the GALL Report recommendations will not be followed, describe the proposed method to manage the aging effect of cracking due to cyclic loading for the containment vessel and dome, and provide the technical basis for concluding that the proposed method is adequate to manage the associated aging effect so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, in accordance with 10 CFR 54.21 (a)(3).

RAI 4.6-2a

Background

Section 4.6 of the SRP-LR states that if a plants code of record requires a fatigue parameter evaluation (fatigue analysis or fatigue waiver), then this analysis may be a time-limited aging analyses (TLAA) and must be evaluated in accordance with 10 CFR 54.21(c)(1) to ensure that the effects of aging on the intended functions are adequately managed for the period of extended operation.

The current licensing basis may include fatigue waiver evaluations that preclude the need for performing CUF analyses of structural components. The ASME Code Section III rules for performing fatigue waiver evaluations for structural components are analogous to those in the Code for performing fatigue waiver evaluations of mechanical components. ASME Code NE-3222.4(d) Analysis for Cyclic Operations, Vessels Not Requiring Analysis for Cyclic Operation, provides for a waiver from fatigue analysis when certain cyclic loading criteria are met.

In its response to RAI 4.6-2, dated February 6, 2018, the applicant stated, in part, the following:

x For the personnel airlock, drywell airlock, drywell combination door/hatch assembly components: The evaluation concluded that analysis for cyclic operation was not necessary. No cumulative usage factors were calculated. The evaluation assumed 120 plant startup cycles. LRA Table 4.3-1 has a limiting value of 168 for plant startups, but because the allowable number of cycles for this ASME Section NE 3222.4(d) criterion was 2,800 cycles, the increase in cycles shown in LRA Table 4.3-1 does not impact the conclusion that a fatigue analysis is unnecessary.

x For the equipment hatch component: The equipment hatch calculation determined a fatigue analysis was not necessary after considering loads from OBE, SSE, LOCA, SRV lifts and heatups because the loads were very low. Cumulative usage factors were not calculated, and x For the drywell head component: The drywell head calculation determined the alternating stresses from earthquakes and SRV loads were so low that the allowable number of cycles were infinite (CUF- O).

Issue It is not clear if the evaluation performed under ASME Section NE 3222.4(d) criterion for the personnel airlock, drywell airlock, and the drywell combination door/hatch assembly constitutes a fatigue waiver that relies on time dependent cycles, and whether they were evaluated and dispositioned in accordance with 10 CFR 54.21(c)(1). The staff notes that the current licensing basis may include fatigue waiver evaluations that preclude the need for performing CUF analyses of structural components which may be a TLAA and must be evaluated.

Additionally, it is not clear if the equipment hatch and the drywell head were evaluated in accordance with the requirements of ASME Code Section III, Division I, Subsection NE-3222.4(d) to waive the requirements of a fatigue analysis, and what the disposition is in accordance with 10 CFR 54.21(c)(1) for the evaluations.

Request

1. State the disposition, in accordance with 10 CFR 54.21(c)(1), for the personnel airlock, drywell airlock, and the drywell combination door/hatch assembly evaluations.
2. Clarify if an evaluation was performed in accordance with ASME Code,Section III, Subsection NE-3222.4(d) to evaluate the fatigue analysis requirements for the equipment hatch and the drywell head.
a. If an evaluation was performed state the assumed number of cycles and limits.

Otherwise, clarify what requirements of the ASME Code were followed to evaluate the fatigue analysis requirements for the equipment hatch and the drywell head, and clarify whether these evaluations are based on time dependent cycles.

b. State the disposition, in accordance with 10 CFR 54.21(c)(1), for the equipment hatch and drywell head evaluations.