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Call Summary - Fuel Oil, Ext.-Int. Surf. Monitoring, FAC & Others 041018, Rev2
	ML18120A135
Person / Time
Site:	River Bend
Issue date:	05/10/2018
From:	Sayoc E; NRC/NRR/DMLR/MRPB
To:	Maguire W; Entergy Operations
	Albert Wong, NRR/DMLR/MRPB, 415-3081
References
	CAC MF9757
	Download: ML18120A135 (12)
	v • d • e

May 10, 2018 Mr. William F. Maguire Site Vice President River Bend Station, Unit 1 Entergy Operations, Inc.

5485 U.S. Highway 61 N St. Francisville, LA 70775

SUBJECT:

SUMMARY

OF PUBLIC TELEPHONE CONFERENCE CALL HELD ON APRIL 10, 2018, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY REGARDING THE NEED FOR ADDITIONAL INFORMATION TO SUPPORT THE RIVER BEND STATION, UNIT 1 LICENSE RENEWAL APPLICATION REVIEW (CAC NO. MF9757)

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 April 10, 2018, to discuss the applicants responses to previously issued Requests for Additional Information (RAIs). The telephone conference was held at the request of NRC to clarify the applicants responses to these RAIs. lists the participants, Enclosure 2 itemizes the RAIs discussed, and Enclosure 3 includes a summary of the conference call. Mr. Dave Lach of your staff agreed to provide supplemental information to the original responses within 30 days from the date of the telephone call. 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,

/RA/

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

Enclosures:

1. List of Participants

2. List of RAIs Discussed

3. Summary of Telephone Call

ML18120A135 OFFICE PM:MRPB:DMLR LA:MRPB:DMLR BC: MRPB:DMLR PM:MRPB:DMLR NAME ESayoc YEdmonds EOesterle w/comments ESayoc DATE 05/10/2018 05/9/2018 05/10/2018 05/10/2018 LIST OF PARTICIPANTS FOR THE APRIL 10, 2018 TELEPHONE CONFERENCE CALL PARTICIPANTS AFFILIATIONS Steve Bloom U.S. Nuclear Regulatory Commission (NRC)

Matt Yoder NRC Jim Gavula NRC Lauren Gibson NRC William Gardner NRC Emmanuel Sayoc NRC Albert Wong NRC Garry Young Entergy Nuclear Operations Inc. (Entergy)

Alan Cox Entergy Dave Lach Entergy Julie Robinson Entergy Stan Batch Entergy Kirk Ehren Entergy Steve McKissack Entergy Mark Spinelli Entergy Dave Wooten Entergy Ted Ivy Entergy Thomas Broussard Entergy Alyson Coates Entergy Walter Malone Entergy Reggie Jackson Entergy Herbert Rideout Entergy Jim Morgan Entergy Randy Gauthreaux Entergy Lisa Borel Entergy Mark Sandusky Entergy Mike Cooper Entergy Enclosure 1

LIST OF TOPICS DISCUSSED DURING THE APRIL 10, 2018 TELEPHONE CONFERENCE CALL ORIGINAL RAI# TRP# RAI Date of the Original Date of Applicants Set RAI Issued Response No.

B.1.15-1 Fuel Oil Chemistry 031 4 December 13, 2017 January 24, 2018 (ML17347B424) (ML18025B544)

March 27, 2018 (ML18087A087)

B.1.17-1 External Surfaces 037 9 February 7, 2018 March 8, 2018 Monitoring (ML18038B470) (ML18067A437)

B.1.25-1 Internal Surfaces in 039 10 February 8, 2018 March 26, 2018 Miscellaneous Piping and (ML18043A008) (ML18087A188)

Ducting Components B.1.21-1 and B.1.21-2 Flow- 018 9 February 7, 2018 March 8, 2018 Accelerated Corrosion (ML18038B470) (ML18067A437)

B.1.40-2 and B.1.40-5 Service 021 9 February 7, 2018 March 8, 2018 Water Integrity (ML18038B470) (ML18067A437)

B.1.43-2 Closed Treated 022 9 February 7, 2018 March 8, 2018 Water Systems (ML18038B470) (ML18067A437)

Enclosure 2

SUMMARY

OF THE APRIL 10, 2018 TELEPHONE CONFERENCE CALL The following issues were discussed with the applicant during the call. The applicant stated they understood the staffs concerns on each of the topics and would supplement their previous responses within 30 days from the date of the call.

Issue 1 RAI B.1.15-1 Fuel Oil Chemistry

Background

The response to RAI B.1.15-1, dated January 24, 2018, addresses the apparent absence of specific industry standards in the USAR and the LRA. The response states that monitoring and control of fuel oil are performed in accordance with ASTM standards D-4058, D-1796, D-2274, and D-2276. The NRC staff held a public teleconference call with the Entergy staff on February 27, 2018 to discuss the applicants response. The applicant provided a supplemental response on March 27, 2018. The staff reviewed the supplemental response and requested a public call on April 10, 2018 to further discuss this matter.

SRP-LR Table 3.0-1, FSAR Supplement for Aging Management of Applicable Systems, summary description provides an acceptable program description for the GALL Report AMP XI.M30, Fuel Oil Chemistry, as per 10 CFR 54.21(d). The SRP-LP Table 3.0-1 includes the specific ASTM standards used for monitoring and control of fuel oil contamination to maintain fuel oil quality. These ASTM standards include D-1796, D-2276, D-2709, and D-4057 to maintain the fuel oil quality.

ASTM D-2709, Standard Test Method for Water and Sediment in Middle Distillate Fuels by Centrifuge, states that the test method covers the determination of the volume of free water and sediment in middle distillate fuels having viscosities at 40°C (104°F) in the range of 1.0 to 4.1 mm2/s (1.0 to 4.1 cSt) and densities in the range of 770 to 900 kg/m3 at 15°C. Additionally, ASTM D-2709 states, Test Method D-1796 [Standard Test Method for Water and Sediment in Fuel Oils by the Centrifuge Method (Laboratory Procedure)] is intended for higher viscosity fuel oils.

Issue In the response to RAI B.1.15-1, the applicant states that monitoring and control of fuel oil are performed in accordance with ASTM D-1796. The staff also recognizes that the applicants procedure CSP-0100, Chemistry Required Surveillances and Actions, states that the acceptance criteria for viscosity of the fuel oil is in the range of 1.9 to 4.1 cSt at 40oC, which is in the viscosity range stated in ASTM D-2709. The justification for using ASTM D-1796, which is intended for fuel oil with a higher viscosity, to test for water and sediment in the fuel oil is not clear to the staff.

Request Provide justification for the use of ASTM D-1796 in lieu of ASTM D-2709, to monitor and control water and sediment in the fuel oil. Alternatively, state the changes to the USAR supplement necessary to include ASTM D-2709 as the test method for monitoring water and sediment in the fuel oil instead of ASTM D-1796.

Enclosure 3

Issue 2 RAI B.1.17-1 External Surfaces Monitoring

Background

NRC Standard Review Plan for License Renewal Applications (SRP-LR), Sections 3.2.2.2.3.2, 3.2.2.2.6, 3.3.2.2.3, 3.3.2.2.5, 3.4.2.2.2, and 3.4.2.2.3 discuss the possibility of aging effects extending to stainless steel components exposed to air which has recently been introduced into buildings (i.e., components near intake vents). The corresponding LRA sections state that there are no indoor stainless steel components located near unducted air intakes in engineered safety features, auxiliary, or steam and power conversion systems. However, the RAI response for Request 1 states that external surfaces of stainless steel components within the diesel generator building (which include auxiliary system components), are exposed to air recently introduced into the building.

In lieu of providing the requested information that establishes there are no indoor stainless steel components located near air intakes, River Bend provided alternative operating experience information. The March 8, 2018, response states that cracking due to contaminants in outdoor air has not been observed in the associated components after being in service for over 30 years.

Also, although most of the criteria cited in the SRP-LR do not apply to River Bend Station, the response states that sufficient data is not available to determine if cracking will not occur during the period of extended operation.

Consequently, the response states that a surface examination will be performed in accordance with the One-Time Inspection program on stainless steel components exposed to outdoor air to verify cracking is not occurring. The response also states that the inspections will verify that cracking is either not occurring or is occurring so slowly that the aging effect will not affect the component intended function during the period of extended operation. In addition, the response revises LRA Sections 3.3.2.2.3 and 3.4.2.2.2 to reflect the above information.

The Issue section of RAI B.1.17-1 notes that some materials exposed to air-indoor will have no aging effects requiring management whereas these materials will have aging effects requiring management (e.g., loss of material for aluminum) for exposure to air which has recently been introduced into buildings.

Issue (1) The staff notes that the approach of using plant-specific operating experience and a one-time inspection to manage cracking of stainless steel components exposed to air is established in NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants. However, the staff noted the following during its review of the RAI response:

a. Cracking of stainless steel was not addressed in engineered safety features (i.e., SRP-LR Section 3.2.2.2.6).

b. Loss of material due to pitting and crevice corrosion in stainless steel components was not addressed in engineered safety features, auxiliary, or steam and power conversion systems (i.e., SRP-LR Sections 3.2.2.2.3.2, 3.3.2.2.5, and 3.4.2.2.3).

c. LRA Tables were not revised to cite the One-Time Inspection program for stainless steel components exposed to indoor air.

d. The revised LRA Section 3.4.2.2.2 deleted the statement [t]here are no stainless steel steam and power conversion system components in the scope of license renewal that are located indoors near unducted air intakes. However, the revised LRA Section 3.3.2.2.3 did not delete this statement for stainless steel auxiliary system components. It is unclear to the staff why this statement was deleted from LRA Section 3.4.2.2.2, while remaining in LRA Section 3.3.2.2.3.

e. The RAI response states that the One-Time Inspection Program verifies cracking is not occurring or is occurring so slowly that the aging effect will not affect the component intended function during the period of extended operation [emphasis added by staff].

However, the use of one-time inspections to address this issue, as established in NUREG-2192, only states that the one-time inspection demonstrates that cracking is not occurring.

(2) It is unclear to the staff why the external surfaces of components (other than stainless steel components which are being addressed in part 1 of the Issue section above) within the diesel generator building are not being managed for aging effects associated with air-outdoor.

Other than being protected from exposure to weather, components in the diesel generator building appear to be exposed to an environment where condensation can occur frequently, consistent with the GALL Report definition of air-outdoor.

Request (1) Provide additional information to address the staffs concerns described in part 1 of the Issue section above to establish that stainless steel components exposed to indoor air can be effectively managed for cracking using a one-time inspection of stainless steel components exposed to outdoor air.

(2) State the basis for why the external surfaces of components (other than stainless steel components which are being addressed in part 1 of the Request section above) within the diesel generator building are not being managed for aging effects associated with air-outdoor.

Issue 3 RAI B.1.25-1 Internal Surfaces in Miscellaneous Piping and Ducting Components

Background

By letter dated March 8, 2018, the response to RAI B.1.17-2 deleted the aging management review (AMR) item from LRA Table 3.3.2-12, Control Building HVAC System, associated with stainless steel manifolds exposed to air-outdoor, being managed for cracking using the Internal Surfaces in Miscellaneous Piping and Ducting Components program. By letter dated March 26, 2018, the response to RAI B.1.25-1 apparently reinstated and revised this AMR item to cite the Periodic Surveillance and Preventive Maintenance program instead of the Internal Surfaces in Miscellaneous Piping and Ducting Components program. However, the change indications did not show that this item was being added.

Issue It is unclear to the staff whether the subject AMR item was revised in the March 26, 2018, letter given that it was deleted in the March 8, 2018, letter.

Request State the basis for how the subject AMR item was revised in the March 26, 2018, letter given that it was deleted in the March 8, 2018, letter.

Issue 4 RAI B.1.21-1 and B.1.21-2 Flow Accelerated Corrosion B.1.21-1

Background

The RAI response dated March 8, 2018, clarified that the Flow-Accelerated Corrosion program will use Revision 4 of NSAC-202L, Recommendations for an Effective Flow-Accelerated Corrosion Program. As a result, River Bend modified license renewal application (LRA) Section B.1.21 to take an exception for the program, because GALL Report Revision 2,Section XI.M17, Flow-Accelerated Corrosion, only discusses NSAC-202L Revision 3 for the associated aging management program. However, as noted in the initial RAI, the associated implementing procedures, SEP-FAC-RBS-001 and EN-DC-315, cite NSAC-202L, Revision 3.

Issue By modifying the LRA to take an exception to the GALL Report, the applicant addressed the inconsistency between the program basis documentation (report RPS-EP-15-00007, Revision 0, Section 4.8, Flow-Accelerated Corrosion,) and LRA Section B.1.21. However, as noted above, the current implementing procedures for the program have inconsistencies with these documents.

Request Provide information regarding how the inconsistency will be resolved between LRA Section B.1.21, the associated program basis documentation in report RPB-EP-15-00007, and the current implementing procedures SEP-FAC-RBS-001 and EN-DC-315.

B.1.21-2

Background

The RAI response dated March 8, 2018, confirmed that CHECWORKS and FAC Manager are classified as Level C software and do not require validation or verification. For safety-related components, the response states:

Evaluation of wear rates, predicted thickness, and remaining service life is documented and reviewed by qualified FAC personnel or designated personnel qualified in accordance with the engineering calculation process. Therefore, appropriate quality assurance is applied to the calculated wear rates used in the determination of the schedule for inspection of safety-related components.

Issue It is not clear how some of the wear values were calculated on the FAC Manager results sheets and what reviews are conducted by the FAC personnel to ensure that wear values were appropriately calculated. As an example, for component 174-FWS010037L1 from document EC0000058296, Rev 0, RBS RF 18 Flow Accelerated Corrosion Program Outage Report, 06/19/2015, which was provided during the aging management program audit.

Tnom - Tmeas = Wear?

0.85 - 0.489 = 0.361 (same as calculated wear valueOK) 0.85 - 0.577 = 0.273 (calculated wear value is 0.253how calculated?)

0.85 - 0.468 = 0.382 (calculated wear value is 0.371how calculated?)

Request Since software does not require validation or verification, provide information to show that appropriate quality assurance is being applied to the wear values calculated by the FAC Manager software through the reviews by FAC personnel to ensure that wear values are being appropriately calculated.

Issue 5 RAI B.1.40-2 and B.1.40-5 Service Water Integrity B.1.40-2

Background

The RAI response dated March 8, 2018, discussed the configurational change of the service water system in the early 1990s from an open-loop system using raw water to a closed-loop system using demineralized water with chemistry controls, which include corrosion inhibitors.

This change included a service water surge tank with a nitrogen overpressure to prevent oxygen ingress. The response states that the rust in the strainer debris may have been formed during operation prior to the system configuration modification, and that debris buildup is gradual enough such that strainer cleaning can be scheduled based on differential pressures. The response concludes that the cited operating experience does not represent a concern with water chemistry control that warranted periodic flushing of infrequently used cooling loops.

The staff notes that, as documented in the Operating Experience Audit Report (ML17347A383), in addition to strainer plugging issues discussed in the initial RAI there have been multiple condition reports documenting drain valve plugging and pipe clogging in the system. Based on discussions with the NRC inspectors conducting the IP-71002 License Renewal Inspection, the staff notes that the closed-loop service water system is operated as an open-loop system during each outage as part of routine surveillance activities. These surveillance activities result in raw water from the standby service water basin being used, along with some volume of air being injected or drawn into the service water system through several vacuum breaker features (see discussion for RAI B.1.43-2). In addition, the surveillance activities cause corrosion products that have been generated in several air-to-water interface locations (see discussion for RAI B.1.40-4) to be introduced.

Issue Although the normal closed-loop service water system is in service during plant operation, routinely scheduled surveillances result in the system being operated as an open-loop system.

This results in chemistry excursions and potential corrosion product introduction that are not typical for a close-loop system. The GALL Report states that if one of its aging management programs (AMPs) is credited, then the conditions and operating experience at the plant are to be bounded by the conditions and operating experience for which the GALL Report was evaluated.

The GALL Report continues [i]f these bounding conditions are not met, it is incumbent on the applicant to address the additional effects of aging and augment the GALL Report AMPs as appropriate. Based on its review, it is not clear to the staff that River Bends operating experience and operating conditions are bounded by those for which the GALL Report AMP XI.M21A, Closed Treated Water Systems, program were evaluated.

Request Provide information to establish that the conditions and operating experience at the plant are bounded by those for which the GALL Report program was evaluated. Specifically, show that regularly operating the system with raw water where corrosion products from corrosion at air-to-water interfaces is introduced is bounded by the conditions evaluated by GALL Report AMP XI.M21A.

B.1.40-5

Background

The staffs initial RAI stated that during the aging management program audit, River Bend personnel indicated that the circulating water cooling tower fill material is similar to the standby cooling tower fill material in LRA Table 3.5.2-2. The RAI response dated March 8, 2018, did not provide any information related to the potentially applicable aging effects demonstrated by CR-RBS-2008-05043 other than to state that the CR is associated with the circulating water cooling towers, which are not subject to aging management review.

In addition, the RAI response stated that the failure of the service water cooling (SWC) cooling towers was not from the effects of aging, but was a less than adequate design of the associated fill support structure. Nevertheless, River Bend revised the aging management review (AMR) items of both the ceramic and clay tile fill in the standby service water and the polyvinyl chloride fill in the SWC cooling towers. The aging effect requiring management was changed from None to Fouling and indicated that the Structures Monitoring program will manage this new aging effect.

Issue Although the fill material degradation occurred in the cooling tower that is not within the scope of license renewal (circulating water system), it is the staffs understanding that similar fill material is used in the cooling tower within the scope of license renewal (standby cooling water system).

However, the RAI response did not provide any bases to establish that the age-related degradation identified in the circulating water cooling tower fill does not need to be considered for the similar fill material in the standby service water cooling tower.

With regard to the fill material fouling, it is not clear that the increase in weight has been adequately considered. The plant-specific operating experience demonstrates the need to ensure that the increase in weight due to fouling of the fill material is within the design capacity of the fill support structure. Although the RAI response modified the AMR items to manage fouling, based on the accessibility limitations, it is not clear how the visual inspections being conducted by the Structures Monitoring program will adequately manage the ongoing fouling of the fill material. The GALL Report states that if one of its AMPs is credited, then the conditions and operating experience at the plant are to be bounded by the conditions and operating experience for which the GALL Report was evaluated. The GALL Report continues [i]f these bounding conditions are not met, it is incumbent on the applicant to address the additional effects of aging and augment the GALL Report AMPs as appropriate. Based on its review, it is not clear to the staff that River Bends operating experience and operating conditions are bounded by those for which the GALL Report AMP XI.S7 Structures Monitoring, program were evaluated.

Request (1) Provide information to establish that the aging effects identified for the fill material in the circulating water cooling tower fill are not applicable to the fill material in the standby service water cooling tower.

(2) Clarify how the visual inspections conducted by the Structures Monitoring program will adequately manage the increase in weight due to fouling of the cooling tower fill material.

Include information to establish that the related conditions and operating experience at the plant are bounded by the conditions and operating experience for which the Structures Monitoring program were evaluated.

Issue 6 RAI B.1.43-2 Closed Treated Water Systems

Background

The RAI response dated March 8, 2018, added aging management review items for the operational configuration associated with solenoid operated valves (SOVs) 522A, B, C, and D in the containment building. The associated carbon steel components exposed to condensation are being managed for loss of material by the Compressed Air Monitoring program. However, for operational configuration associated with SOVs 523A, B, C, and D, in the auxiliary building, the internal environment will be indoor air, or conservatively condensation, but it is not supplied by the compressed air system.

Issue For the internal portion of the vacuum breaker piping in the auxiliary building, there are no piping AMR items in LRA Table 3.3.2-3 citing an internal environment of indoor air. Also all AMR items citing condensation for carbon steel piping or valves use the Compressed Air Monitoring program to manage the effects of aging. The staff notes that carbon steel components internally exposed to indoor air in other systems are being managed for loss of material and it is unclear which AMR item addresses the piping associated with the internal air environment for SOVs 523A, B, C, and D.

Request Clarify which AMR item addresses the aging effects associated with the piping and valve bodies internally exposed to air for SOVs 523A, B, C, and D, or explain how the Compressed Air Monitoring program will adequately manage the associated aging effects for these components.