ML18291B147

Revision of the River Bend License Renewal Safety Evaluation Report

ML18291B147
Person / Time
Site:	River Bend
Issue date:	10/18/2018
From:	Sayoc E Division of License Renewal
To:	Kent Howard Advisory Committee on Reactor Safeguards
References
Download: ML18291B147 (17)

Text

NRR-DMPSPEm Resource From: Sayoc, Emmanuel Sent: Thursday, October 18, 2018 12:07 PM To: Howard, Kent Cc: Veil, Andrea; Oesterle, Eric

Subject:

Revision of the River Bend License Renewal Safety Evaluation Report Attachments: River Bend Supplemental RAI Response 9OCT2018 - ML18283A082.pdf; Revision to River Bend SER - ML18212A151 - Section 2-3-3-16 Plant Drains - Clean.pdf; Revision to River Bend SER - ML18212A151 - Section 2-3-3-16 Plant Drains - Marked Up.pdf Importance: High

Kent, Please pass along this information to the appropriate members of the Advisory Committee on Reactor Safeguards (ACRS), related to the action item from the September 20, 2018, River Bend ACRS Sub Committee Meeting on the Emergency Diesel Generator Vent Line ageing management.

As was discussed at the Sub Committee Meeting, Entergy submitted a supplemental response to our associated Request for Additional Information, see first attachment. Accordingly the staff revised the River Bend License Renewal Safety Evaluation Report section 2.3.3.16 Plant Drains, see the second attachment, clean version, and the third attachment, marked up version.

These changes will be included when the SER is published as a NUREG.

If you need anything further please let me know.

Thank You, Emmanuel Manny Sayoc Safety Project Manager NRR/DLR 301-415-4084 1

Hearing Identifier: NRR_DMPS Email Number: 628 Mail Envelope Properties (Emmanuel.Sayoc@nrc.gov20181018120600)

Subject:

Revision of the River Bend License Renewal Safety Evaluation Report Sent Date: 10/18/2018 12:06:46 PM Received Date: 10/18/2018 12:06:00 PM From: Sayoc, Emmanuel Created By: Emmanuel.Sayoc@nrc.gov Recipients:

"Veil, Andrea" <andrea.veil@nrc.gov>

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

Tracking Status: None "Howard, Kent" <Kent.Howard@nrc.gov>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 876 10/18/2018 12:06:00 PM River Bend Supplemental RAI Response 9OCT2018 - ML18283A082.pdf 2841313 Revision to River Bend SER - ML18212A151 - Section 2-3-3-16 Plant Drains - Clean.pdf 64325 Revision to River Bend SER - ML18212A151 - Section 2-3-3-16 Plant Drains - Marked Up.pdf 71219 Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

2.3.3.16 Plant Drains 2.3.3.16.1 Summary of Technical Information in the Application This section discusses plant drains systems in LRA Section 2.3.3.16, Plant Drains.

2.3.3.16.2 Staff Evaluation The staff evaluated the plant drain system functions described in the LRA, USAR, Entergys engineering reports, and license renewal boundary drawings to verify that Entergy included within the scope of license renewal all components with intended functions as described in 10 CFR 54.4(a). The staff then reviewed those components that Entergy identified as within the scope of license renewal to verify that Entergy included all passive and long-lived components subject to an aging management review, in accordance with the requirements of 10 CFR 54.21(a)(1).

Using the evaluation methodology in LRA Section 2.1, Scoping and Screening Methodology, and the guidance in NUREG-1800, Revision 2, Section 2.3, Scoping and Screening Results:

Mechanical Systems, the staff reviewed:

x LRA Section 2.3.3.16 x LRA Table 2.3.3-16 x USAR Section 9.2.4, Section 9.3.3, and Section 9.3.7 x USAR Table 3.9A-10.

The staff identified two areas where it needed additional information to complete the review of Entergys scoping and screening results. To obtain this information, the staff issued two requests for additional information: (1) RAI 2.3.3.16-1 and (2) RAI 2.3.3.16-3 on February 12, 2018 (ADAMS Accession No. ML18043A351). For these two RAIs, Entergy provided its response by letter dated March 14, 2018 (ADAMS Accession No. ML18073A068). Entergy provided a revised response to RAI 2.3.3.16-1 by letter dated October 9, 2018 (ADAMS Accession No. ML18283A082).

(1) RAI 2.3.3.16-1 In the first request for additional information (RAI 2.3.3.16-1), the staff requested clarification regarding two vent pipes each from each crankcase of standby diesel engine EGS*EG1A(AR) and EGS*EG1B(BB). The venting of combustion fumes from the diesel engine crankcases is discussed in LRA Section 2.3.3.16. The relevant LRA drawing (i.e., LRA-PID-08-9B) identified these vent pipes as not subject to aging management review. The staff requested that Entergy justify why these vent pipes are not subject to aging management review.

Entergy responded to RAI 2.3.3.16-1 by stating that Division I and II diesel engine vent pipes are not addressed in LRA Table 3.3.2-16 Plant Drains-Summary of Aging Management Evaluation and are not subject to aging management review since these vent pipes do not have a license renewal intended function. In its revised response to this RAI, Entergy further stated that:

The purpose of the vent pipe is to vent the gasses from the diesel generator to the outdoors. Upon loss of the vent pipe pressure boundary, the gasses would exhaust into the room, but the diesel would continue to perform its function.

When the diesel is in operation, the room ventilation system is in service, venting the room. Therefore, the loss of pressure boundary of this pipe has no impact on the diesel or personnel and it has no safety function. The function of venting the crankcase to the outdoors is not necessary for the diesel to operate under emergency conditions. Periodic surveillance testing confirms adequate crankcase venting for both Division I and II and Division III diesel engines.

The nonsafety-related Division I and II diesel engine vent lines are not subject to aging management review under 54.4(a)(2) criteria due to leakage or spray because the vent lines contain no liquids that would impact other components in the room. The vent lines are installed with seismic supports that are subject to aging management review and included in the Structures Monitoring Program.

Therefore, the vent lines cannot fall and impose an unanalyzed load on the connection to the safety-related diesel engine that would render it unable to perform its intended function under both normal operation and seismic CLB design conditions.

In contrast to the Division I and II diesel generator engines, Entergy noted that the Division III diesel engine does not have an independent crankcase vent line directly routed to the outdoors. The Division III diesel engine vents the crankcase to the outdoors via the engine exhaust line, and the engine functionality is demonstrated as a complex assembly during periodic surveillance testing.

The staff finds Entergys response acceptable because it explains:

x why the effects of aging on the Division I, II and III standby diesel engine vent piping pressure boundary function do not require management during the period of extended operations; x why the Division I, II and III standby diesel generator engine vent piping is not Within the Scope of License Renewal (WSLR) as defined by10 CFR 54.4(a)(1); and x why the Division I and II standby diesel generator engine directly connected vent piping is not WSLR as defined by 10 CFR 54.4(a)(2).

Therefore, the staffs concern described in RAI 2.3.3.16-1 is resolved.

(2) RAI 2.3.3.16-3 In the second request for additional information (RAI 2.3.3.16-3), the staff requested clarification on the instrument tubing to four pressure indicators (i.e., PI-12A/B/D/E) that were identified as being subject to aging management review on the relevant LRA drawing (LRA-PID-32-09P). In contrast, the staff noted that neither LRA Table 2.3.3-16, Plant Drains System Components Subject to Aging Management Review, nor LRA Table 3.3.2-16 lists tubing as a component type subject to aging management review.

In response to RAI 2.3.3.16-3, Entergy acknowledged this deficiency by revising LRA Table 2.3.3-16 and LRA Table 3.3.2-16. In both tables, Entergy added under the column,

Component Type, tubing with an intended function of pressure boundary. In its response, Entergy stated the following:

The tubing is stainless steel exposed to environments of waste water (internal) and indoor air (external). The Internal Surfaces in Miscellaneous Piping and Ducting Components Program manages the aging effects in waste water; there are no aging effects to be managed for stainless steel in indoor air.

The staff finds Entergys response acceptable because it revises LRA Table 2.3.3-16 to add tubing as a plant drain component subject to aging management review and assigns the correct intended function (i.e., pressure boundary). Furthermore, Entergy revised LRA Table 3.3.2-16 to provide for managing the aging effects of waste water in the tubing. The staffs concern described in RAI 2.3.3.16-3 is resolved.

2.3.3.16.3 Conclusion Based on the staffs evaluation in SER Section 2.3.3.16.2 and on its review of the LRA, USAR, Entergys engineering reports, license renewal boundary drawings, and RAI responses, the staff concludes that Entergy has appropriately identified the plant drains system components within the scope of license renewal as required by 10 CFR 54.4(a). The staff also concludes that Entergy has adequately identified the system components subject to an aging management review in accordance with the requirements in 10 CFR 54.21(a)(1).

2.3.3.16 Plant Drains 2.3.3.16.1 Summary of Technical Information in the Application This section discusses plant drains systems in LRA Section 2.3.3.16, Plant Drains.

2.3.3.16.2 Staff Evaluation The staff evaluated the plant drain system functions described in the LRA, USAR, Entergys engineering reports, and license renewal boundary drawings to verify that Entergy included within the scope of license renewal all components with intended functions as described in 10 CFR 54.4(a). The staff then reviewed those components that Entergy identified as within the scope of license renewal to verify that Entergy included all passive and long-lived components subject to an aging management review, in accordance with the requirements of 10 CFR 54.21(a)(1).

Using the evaluation methodology in LRA Section 2.1, Scoping and Screening Methodology, and the guidance in NUREG-1800, Revision 2, Section 2.3, Scoping and Screening Results:

Mechanical Systems, the staff reviewed:

x LRA Section 2.3.3.16 x LRA Table 2.3.3-16 x USAR Section 9.2.4, Section 9.3.3, and Section 9.3.7 x USAR Table 3.9A-10.

The staff identified two areas where it needed additional information to complete the review of Entergys scoping and screening results. To obtain this information, the staff issued two requests for additional information: (1) RAI 2.3.3.16-1 and (2) RAI 2.3.3.16-3 on February 12, 2018 (ADAMS Accession No. ML18043A351). For these two RAIs, Entergy provided its response by letter dated March 14, 2018 (ADAMS Accession No. ML18073A068). Entergy provided a revised response to RAI 2.3.3.16-1 by letter dated October 9, 2018 (ADAMS Accession No. ML18283A082).The staff identified two areas where it needed additional information to complete the review of Entergys scoping and screening results. To obtain this information, the staff issued two requests for additional information: (1) RAI 2.3.3.16-1 and (2) RAI 2.3.3.16-3 on February 12, 2018 (ADAMS Accession No. ML18043A351). For these two RAIs and Entergys responses, see ADAMS Accession No. ML18073A068, dated March 14, 2018.

(1) RAI 2.3.3.16-1 In the first request for additional information (RAI 2.3.3.16-1), the staff requested clarification regarding two vent pipes each from each crankcase of standby diesel engine EGS*EG1A(AR) and EGS*EG1B(BB). The venting of combustion fumes from the diesel engine crankcases is discussed in LRA Section 2.3.3.16. The relevant LRA drawing (i.e., LRA-PID-08-9B) identified these vent pipes as not subject to aging management review. The staff requested that Entergy justify why these vent pipes are not subject to aging management review.

Entergy responded to RAI 2.3.3.16-1 by stating that Division I and II diesel engine vent pipes are not addressed in LRA Table 3.3.2-16 Plant Drains-Summary of Aging Management

Evaluation and are not subject to aging management review since these vent pipes do not have a license renewal intended function. In its revised response to this RAI, Entergy further stated that:

The purpose of the vent pipe is to vent the gasses from the diesel generator to the outdoors. Upon loss of the vent pipe pressure boundary, the gasses would exhaust into the room, but the diesel would continue to perform its function.

When the diesel is in operation, the room ventilation system is in service, venting the room. Therefore, the loss of pressure boundary of this pipe has no impact on the diesel or personnel and it has no safety function. The function of venting the crankcase to the outdoors is not necessary for the diesel to operate under emergency conditions. Periodic surveillance testing confirms adequate crankcase venting for both Division I and II and Division III diesel engines.

The nonsafety-related Division I and II diesel engine vent lines are not subject to aging management review under 54.4(a)(2) criteria due to leakage or spray because the vent lines contain no liquids that would impact other components in the room. The vent lines are installed with seismic supports that are subject to aging management review and included in the Structures Monitoring Program.

Therefore, the vent lines cannot fall and impose an unanalyzed load on the connection to the safety-related diesel engine that would render it unable to perform its intended function under both normal operation and seismic CLB design conditions.

In contrast to the Division I and II diesel generator engines, Entergy noted that the Division III diesel engine does not have an independent crankcase vent line directly routed to the outdoors. The Division III diesel engine vents the crankcase to the outdoors via the engine exhaust line, and the engine functionality is demonstrated as a complex assembly during periodic surveillance testing.

The staff finds Entergys response acceptable because it explains:

x why the effects of aging on the Division I, II and III standby diesel engine vent piping pressure boundary function do not require management during the period of extended operations; x why the Division I, II and III standby diesel generator engine vent piping is not Within the Scope of License Renewal (WSLR) as defined by10 CFR 54.4(a)(1); and x why the Division I and II standby diesel generator engine directly connected vent piping is not WSLR as defined by 10 CFR 54.4(a)(2).

Therefore, the staffs concern described in RAI 2.3.3.16-1 is resolved.In the first request for additional information (RAI 2.3.3.16-1), the staff requested clarification regarding two vent pipes each from each crankcase of standby diesel generator EGS*EG1A(AR) and EGS*EG1B(BB).

The venting of combustion fumes from the diesel generator crankcases is discussed in LRA Section 2.3.3.16. The relevant LRA drawing (i.e., LRA-PID-08-9B) identified these vent pipes as not subject to aging management review. The staff asked Entergy to justify why these vent pipes are not subject to aging management review.

Entergy responded to RAI 2.3.3.16-1 by stating that the subject diesel generator vent pipes do not have a license renewal intended function since the venting the crankcase is not necessary for the diesel to operate under emergency conditions. Entergy further states that:

This is shown in USAR Section 8.3.1.1.4.1, which lists two sets of conditions under which the diesel will trip: one set for both normal and emergency conditions, and one set for normal conditions only. The trip for high crankcase pressure is only listed with the set for normal conditions and not as a required trip for emergency conditions. In fact, the non-emergency trips are bypassed on receipt of an emergency start signal.

The staff notes that the protection system of the standby diesel generators is described in USAR Section 8.3.1.1.4.1 which reads in part:

3. The standby diesel generator unit is tripped under the following conditions during normal operation only.

Generator voltage controlled - inverse time phase overcurrent

a. Generator reverse power

b. Generator loss of field

c. Extreme high jacket water temperature trip

d. High bearing temperature trip

e. Extreme low jacket water pressure trip

f. High crankcase pressure trip

g. Trip low turbo oil pressure

h. Trip high vibration

i. Trip high temperature lube oil

j. Low lube oil pressure trip

k. Generator ground overcurrent Entergy noted that when the diesel engines are in operation, the room ventilation system performs the function of venting the standby diesel generator rooms. Entergy concluded that the loss of pressure boundary of the subject vent piping has no impact on emergency operation of the diesel engines, and it therefore has no safety function.

The staff finds Entergys response acceptable because it adequately explains why the standby diesel generator vent piping is not subject to aging management review. The staffs concern described in RAI 2.3.3.16-1 is resolved.

(2) RAI 2.3.3.16-3 In the second request for additional information (RAI 2.3.3.16-3), the staff requested clarification on the instrument tubing to four pressure indicators (i.e., PI-12A/B/D/E) that were identified as being subject to aging management review on the relevant LRA drawing (LRA-PID-32-09P). In contrast, the staff noted that neither LRA Table 2.3.3-16, Plant Drains System Components Subject to Aging Management Review, nor LRA Table 3.3.2-16 lists tubing as a component type subject to aging management review.

In response to RAI 2.3.3.16-3, Entergy acknowledged this deficiency by revising LRA Table 2.3.3-16 and LRA Table 3.3.2-16. In both tables, Entergy added under the column,

Component Type, tubing with an intended function of pressure boundary. In its response, Entergy stated the following:

The tubing is stainless steel exposed to environments of waste water (internal) and indoor air (external). The Internal Surfaces in Miscellaneous Piping and Ducting Components Program manages the aging effects in waste water; there are no aging effects to be managed for stainless steel in indoor air.

The staff finds Entergys response acceptable because it revises LRA Table 2.3.3-16 to add tubing as a plant drain component subject to aging management review and assigns the correct intended function (i.e., pressure boundary). Furthermore, Entergy revised LRA Table 3.3.2-16 to provide for managing the aging effects of waste water in the tubing. The staffs concern described in RAI 2.3.3.16-3 is resolved.

2.3.3.16.3 Conclusion Based on the staffs evaluation in SER Section 2.3.3.16.2 and on its review of the LRA, USAR, Entergys engineering reports, license renewal boundary drawings, and RAI responses, the staff concludes that Entergy has appropriately identified the plant drains system components within the scope of license renewal as required by 10 CFR 54.4(a). The staff also concludes that Entergy has adequately identified the system components subject to an aging management review in accordance with the requirements in 10 CFR 54.21(a)(1).