View source for RBG-47867, Response to License Renewal Application NRC Request for Additional Information RAI 3.2.2.2-1a Supplement

{{Adams
| number = ML18138A144
| issue date = 05/16/2018
| title = Response to License Renewal Application NRC Request for Additional Information RAI 3.2.2.2-1a Supplement
| author name = Maguire W
| author affiliation = Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000458
| license number = NPF-047
| contact person = 
| case reference number = RBG-47867
| document type = Letter type:RBG, Response to Request for Additional Information (RAI)
| page count = 15
| project = 
| stage = Supplement
}}

=Text=
{{#Wiki_filter:* Entergx
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Entergy Operations, Inc.
Rlv, r Bend Statl' In 5~8!> US. Highway 61N St. FrancIsville, LA 70115 Tel 225*381*4314 William F. Maguire S,ip. Vic~ President Riv"r Bend Statioll RBG-47867 May 16, 2018 Attn : Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville , MD 20852-2738

==SUBJECT:==
Response to License Renewal Application NRC Request for Additional Information RAI 3,2,2,2-1 a Supplement River Bend Station , Unit 1 Docket No. 50-458 License No. NPF-47 References : 1) Entergy Letter: License Renewal Application (RBG-47735 dated May 25, 2017)
: 2) Entergy Letter: License Renewal NRC Request for Additional Information Set 3 (RBG-47807) - RBS License Renewal Application - dated January 10, 2018 (ADAMS Accession No ML 1801 OA848)
: 3) NRC email: River Bend Station , Unit 1, Request for Additional Information, Set 12 - RBS License Renewal Application - dated March 6, 2018 (ADAMS Accession No ML18065A213)
: 4) Entergy Letter: License Renewal NRC Request for Additional Information Set 12 (RBG-47846) - RBS License Renewal Application - dated April 3, 2018 (ADAMS Accession No ML 180192A099)
: 5) NRC email: River Bend Station, Unit 1, Request for Additional Information -
RBS License Renewal Application - Public Meeting Summary dated March 29, 2018 (ADAMS Accession No ML18071A018)
: 6) NRC Public Meeting : River Bend Station , Unit 1, Request for Additional Information - License Renewal Application - dated April 18, 2018 (ADAMS Accession No ML18095A412)

==Dear Sir or Madam:==

In Reference 1, Entergy Operations, Inc (Entergy) submitted an application for renewal of the operating license for River Bend Station (RBS) for an additional 20 years beyond the current expiration date. During a public meeting held on April 18, 2018 (Reference 6) the NRC Staff requested that the license renewal application (Reference 1) be revised to include additional inspection activities in the Periodic Surveillance and Preventive Maintenance Program .

RBG-47867 Page 2 of 2  contains the revised information. The revisions are related to the responses to References 2, 3, 4 and 5 concerning RAI 3.2.2.3.2-1 a, "General Filtration." Enclosure 2 identifies one commitment.
If you require additional information , please contact Mr. Tim Schenk at (225)-381 -4177 or tschenk@entergy.com .
In accordance with 10 CFR 50.91 (b)(1) , Entergy is notifying the State of Louisiana and the State of Texas by transmitting a copy of this letter to the designated State Official.
I declare under penalty of perjury that the foregoing is true and correct. Executed on May
                                -
16, 2018.
Sincerely, WFM/RMC/alc : Response to RAI 3.2.2.3.2-1 a - River Bend Station : Commitment - River Bend Station

RBG-47867 Page 2 of 2 cc:    (with Enclosure)
U.S . Nuclear Regulatory Commission Attn: Emmanuel Sayoc 11555 Rockville Pike Rockville , MD 20852 cc:    (w/o Enclosure)
U.S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.
Arlington , TX 76011-4511 U.S. Nuclear Regulatory Commission Attn: Ms. Lisa M. Regner, Project Manager 09-0-14 One White Flint North 11555 Rockville Pike Rockville , MD 20852 NRC Senior Resident Inspector Attn : Mr. Jeff Sowa 5485 U.S. Highway 61 , Ste. NRC 8t. Francisville, LA 70775 Department of Environmental Quality Office of Environmental Compliance Radiological Emergency Planning and Response Section Ji Young Wiley P.O. Box 4312 Baton Rouge , LA 70821 -4312 Public Utility Commission of Texas Attn : PUC Filing Clerk 1701 N. Congress Avenue P. O. Box 13326 Austin , TX 78711-3326 RBF1-18-0102

RBG-47867 Enclosure 1 Response to RAI 3.2.2.3.2-1 a General Filtration Supplemental Information

RBG-47867 Page 2 of 10 REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION RIVER BEND STATION, UNIT 1 - RAI3.2.2.3.2-1a DOCKET NO.: 50-458 CAC NO.: MF9757 Office of Nuclear Reactor Regulation Division of Materials and License Renewal Question RAI 3.2.2.3.2-1 a (Generic Filtration)

===Background===
The response to RAI 3.2.2.3.2-1, dated January 10, 2018, states that, unlike piping, strainers and filters (with the intended function of filtration) are designed to collect debris, whether from aging effects or other causes.
Consequently, provisions have been incorporated into the system design or operation to manage the debris collection , so the active function of providing system flow can continue to be accomplished . An overall summary of the response indicates that flow blockage would be detectable by: a) alarmed differential pressure, b) local indication of differential pressure, or c) abnormal operation indicated through performance monitoring of temperatures, pressures, or flows. In addition , the response indicates that some of these components are also periodically inspected and cleaned .
In its discussion regarding the IPA required by 10 CFR 54.21 , the industry guidance endorsed by Regulatory Guide 1.188, "Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses," states that the information to be documented by the applicant should include an identification of the AERM and an identification of the specific program or activities [emphasis added by staff] that will manage the effects of aging for each component.
For the strainer in the main steam positive leakage control system , LRA Table 3.3.2-6 indicates that only the strainer is exposed to a treated water environment, which is consistent with the response's discussion regarding the compressor seal water cooler outlet strainer. However, PID-27-20C also shows a strainer (STR1 OBA) , which takes a suction from the auxiliary building atmosphere through a 0.125-inch perforated screen, indicating an environment of indoor air.
Issue
: 1) Although considerations for debris collection may be incorporated into the system design or operation, the industry guidance endorsed in Regulatory Guide 1.188 states that the IPA should include an identification of the specific program or activities that are used to manage aging effects. For components with an intended function of filtration , it is not clear to the staff that in all cases the proposed operational controls (e.g. , for abnormal operation) , or maintenance tasks (e.g. , periodic inspections or cleaning of strainers) are linked to a specific program.
For the suppression pool suction strainers, it is also not clear how fouling is trended to ensure that accumulation of debris will not prevent an intended function from being met prior to the next inspection.
In addition, given the normal movement of control rods, it is not clear to the staff that normal operation will be adequate to detect potential flow blockage in the hydraulic control unit (HCU) filters.

RBG-47867 Page 3 of 10
: 2)    For the strainer STR1 OBA in the main steam positive leakage control , it is not clear to the staff whether this component is within the scope of license renewal and whether LRA Table 3.3.2-6 includes a corresponding AMR item .
Request
: 1)     For each component in the table below provide additional information as follows:
Table No. System                      Component Type      Discussion from RAI Response 3.2.2-2     High Pressure Core Spray    Suction Strainer    Inspect and Clean 3.2.2-3     Residual Heat Removal       Suction Strainer    Inspect and Clean 3.2.2-4     Low Pressure Core Spray     Suction Strainer    Inspect and Clean 3.2.2-5     Reactor Core Isolation      Suction Strainer    Inspect and Clean Cooling 3.3.2-1     Control Rod Drive           Filter              Normal Operation will detect flow blockage.
Inspect and replace during rebuilds
: a. For strainers where periodic inspections are performed, state: (a) the specific AMP to be used; (b) whether the maintenance tasks will be linked to the AMP ; (c) how monitoring and trending will be conducted; and (d) the frequency of the inspections being credited.
: b. For the HCUs, state the basis for why monitoring during normal operation will be adequate to detect potential flow blockage of the filters. If monitoring might not be adequate, state the basis for why the periodicity of rebuilds provides reasonable assurance that the intended function of the control rods will be met.
: 2)    For strainer STR10BA in the main steam positive leakage control system (PID-27-20C), provide additional information to clarify whether this component is within the scope of license renewal and, if so, state which aging management review item in LRA Table 3.3.2-6 is applicable.

===Response===
River Bend Station (RBS) previously responded to RAI3.2.2.3.2-1a by letter dated April 3, 2018 (RBG-47846).
The following is the response to RAI 3.2.2.3.2-1 a revised to include additional information requested by the NRC during a public telephone conference call held on April 18, 2018. The revised response supersedes the previous response. Locations of changes to the previous response of April 3 are indicated by revision bars.
: 1) a. Periodic inspections are performed for the suction strainers in the high pressure core spray, residual heat removal, low pressure core spray, and reactor core isolation cooling systems. (a) These inspections will be performed as part of the Periodic Surveillance and Preventive Maintenance Program. (b) These inspection tasks will be linked to the Periodic Surveillance and Preventive Maintenance Program.
Changes to the appropriate LRA Section 3 lists and tables and descriptions in Appendix A and B that identify these tasks as part of the program are shown below. (c) The inspections of the suction strainers require all material/debris identified on the strainers to be cataloged and recorded to ensure the removed material/debris is identified and recorded. In addition, Engineering is required to inspect the removed material/debris. The task acceptance criteria limit the amount of debris. Not meeting the acceptance criteria requires initiation of a condition report to determine cause and corrective actions. (d) These inspections are performed once per refueling cycle.
: b. In accordance with Technical Specification requirements, control rods are exercised at least once per month. The control rod exercise test serves as a periodic check of the control rod system that would detect flow blockage in the HCU filters. Blockage would be indicated by abnormal operation of the control rod. In addition, the control rod travel speed is tested every refueling outage. This test would

RBG -47867 Page 4 of 10 detect abnormal speeds indicative of blockage in the filters. These tests provide the necessary information that could be used to detect flow blockage in the HCU filters.
: 2) As shown by the highlighting on PIO-27-20C, STR1 OBA is subject to aging management review for license renewal as is STR10BB shown on PIO-27-200. Only the strainer housings were included in LRA Table 3.3.2-6. The strainers are stainless steel with 0.125 inch holes exposed to indoor air taking suction inside the auxiliary building . The potential for any blockage is extremely low. In addition , these strainers are periodically inspected and cleaned as necessary, and flow blockage would be detected through normal monitoring of compressor performance. Changes to LRA Table 3.3.2-6 to include strainers in an indoor air environment are provided below.
The changes to LRA Sections 3.2.2.1.2, 3.2.2.1.3, 3.2.2.1.4, 3.2.2.1.5, A.1.34, and B.1.34 and Tables 3.2.2-2, 3.2.2-3, 3.2.2-4, 3.2.2-5 and 3.3.2-6 follow with additions underlined and deletions lined through.
3.2.2.1.2   High Pressure Core Spray System Aging Effects Requiring Management The following aging effects associated with the high pressure core spray system require management.
* Cracking - fatigue
* Flow blockage
* Loss of material
* Loss of preload Aging Management Programs The following aging management programs manage the effects of aging on the high pressure core spray components .
* Bolting Integrity
* External Surfaces Monitoring
* One-Time Inspection
* Periodic Surveillance and Preventive Maintenance
* Water Chemistry Control - BWR 3.2.2.1.3   Residual Heat Removal System Aging Effects Requiring Management The following aging effects associated with the residual heat removal system require management.
* Cracking
* Cracking - fatigue
* Flow blockage
* Loss of material
* Loss of material - FAC
* Loss of preload
* Reduction of heat transfer

RBG-47867 Page 5 of 10 Aging Management Programs The following aging management programs manage the effects of aging on the residual heat removal system components.
* Bolting Integrity
* External Surfaces Monitoring
* Flow-Accelerated Corrosion
* One-Time Inspection
* Periodic Surveillance and Preventive Maintenance
* Service Water Integrity
* Water Chemistry Control - BWR
* Water Chem istry Control - Closed Treated Water Systems 3.2.2.1.4  Low Pressure Core Spray System Aging Effects Requiring Management The following aging effects associated with the low pressure core spray system require management.
* Cracking - fatigue
* Flow blockage
* Loss of material
* Loss of preload Aging Management Programs The following aging management programs manage the effects of aging on the low pressure core spray system components .
* Bolting Integrity
* External Surfaces Monitoring
* Internal Surfaces in Miscellaneous Piping and Ducting Components
* One-Time Inspection
* Periodic Surveillance and Preventive Maintenance
* Water Chemistry Control - BWR 3.2.2.1.5  Reactor Core Isolation Cooling System Aging Effects Requiring Management The following aging effects associated with the reactor core isolation cooling system require management.
* Cracking
* Cracking - fatigue
* Flow blockage
* Loss of material
* Loss of material - FAC

RBG-47867 Page 6 of 10
* Loss of preload
* Reduction of heat transfer Aging Management Programs The following aging management programs manage the effects of aging on the reactor core isolation cooling system components.
* Bolting Integrity
* External Surfaces Monitoring
* Flow-Accelerated Corrosion
* Oil Analysis
* One-Time Inspection
* Periodic Surveillance and Preventive Maintenance
* Water Chemistry Control - BWR

RBG-47867 Page 7 of 10 Notes for Tables 3.2.2-1 through 3.2.2-8-5 Plant-Specific Notes 206. Strainers are designed to coHect debris whether resulting from aging effects or other causes. Inspections are performed to ensure strainers are free of excessive debris that could cause flow blockage.
Table 3.2.2-2: High Pressure Core Spray System Aging Effect          Aging Intended                                     Requiring         Management       NUREG-1801      Table 1 Component Type       Function       Material    Environment     Management           Programs           Item          Item    Notes Strainer             Filtration   Stainless     Treated water  Flow Blockage      Periodic           ---           ---        H, 206 steel         (ext)                             Surveillance and Preventive Maintenance Table 3.2.2-3 Residual Heat Removal System Aging Effect          Aging Intended                                     Requiring        Management        NUREG-1801      Table 1 Component Type       Function       Material    Environment     Management           Programs           Item          Item    Notes Strainer             Filtration   Stainless     Treated water  Flow Blockage      Periodic          ---           ---         H,206 steel         (ext)                             Surveillance and Preventive Maintenance

RBG-47867 Page 8 of 10 Table 3.2.2-4 Low Pressure Core Spray System Aging Effect       Aging Intended                                   Requiring     Management       NUREG-1801      Table 1 Component Type         Function       Material   Environment    Management        Programs            Item        Item    Notes Strainer              Filtration    Stainless    Treated water Flow Blockage   Periodic          ---           ---        H, 206 steel        (ext)                         Surveillance and Preventive Maintenance Table 3.2.2-5 Reactor Core Isolation Cooling System Aging Effect       Aging Intended                                   Requiring     Management       NUREG-1801      Table 1 Component Type         Function       Material   Environment    Management        Programs            Item        Item    Notes Strainer              Filtration    Stainless    Treated water Flow Blockage   Periodic         ---           ---         H,206 steel        (ext)                         Surveillance and Preventive Maintenance Table 3.3.2-6: Main Steam Positive Leakage Control System Aging Effect       Aging Component        Intended                                        Requiring     Management       NUREG-1801      Table 1 Type         Function          Material     Environment    Management        Programs            Item        Item    Notes Strainer         Filtration      Stainless steel Air - indoor  None            None              VII.J.AP-123 3.3.1-120   6 (ext)

RBG-47867 Page 9 of 10
[The following revised LRA sections are unchanged from the previous RAI response submitted on April 3, 2018, with the exception of the change to the letter number in the commitment list.]
A.1.34     Periodic Surveillance and Preventive Maintenance The Periodic Surveillance and Preventive Maintenance (PSPM) Program includes periodic inspections and tests to manage aging effects including cracking , loss of material, reduction of heat transfer, and change in material properties, in cases where no NUREG-1801 program was found appropriate to manage the particular aging effects for specific components. At a minimum , in each 10-year period during the period of extended operation , a representative sample of 20 percent of the population (defined as components having the same combination of material, environment, and aging effect) or a maximum of 25 components per population is inspected. Where practical , the inspections will focus on the bounding or leading components most susceptible to aging because of time in service and severity of operating conditions . Physical manipulation of elastomers is conducted in conjunction with visual inspections. Indications or relevant conditions of degradation detected are evaluated .
Credit for program activities has been taken in the aging management review for the following components.
* Inspect the surface of the inflatable elastomer seal for the upper containment pool gates in the reactor building.
* Inspect the surface of the inflatable elastomer seal for the spent fuel storage pool gates in the auxiliary building.
* Visually inspect the surface of the high pressure core spray. residual heat removal. low pressure core spray. and reactor core isolation cooling suppression pool suction strainers for debris.
Addition to Section A.4, LICENSE RENEWAL COMMITMENT LIST 24       Periodic Surveillance   Enhance the PSPM            Prior to February 28 ,   RBG -47735 and Preventive          Program as described in     2025 , or the end of the RBG -47867 Maintenance             LRA Section A.1 .34 .       last refueling outage prior to August 29, 2025, whichever is later.
8.1.34     PERIODIC SURVEILLANCE AND PREVENTIVE MAINTENANCE Program Description There is no corresponding NUREG-1801 program .
The Periodic Surveillance and Preventive Maintenance (PSPM) Program includes periodic inspections and tests to manage aging effects, including cracking , loss of material, reduction of heat transfer, and change in material properties, in cases where no NUREG-1801 program was found appropriate to manage the particular aging effects for specific components. At a minimum, in each 1O-year period during the period of extended operation , a representative sample of 20 percent of the population (defined as components having the same combination of material, environment, and aging effect) or a maximum of 25 components per population is inspected. Where practical, the inspections will focus on the bounding or leading components most susceptible to aging because of time in service and severity of operating conditions. Physical manipulation of

RBG-47867 Page 10 of 10 elastomers is conducted in conjunction with visual inspections. Indications or relevant conditions of degradation detected are evaluated.
Credit for program activities has been taken in the aging management review for the following systems and structures.
Reactor building        Inspect the surface of the inflatable elastomer seal for the upper containment pool gates.
Auxiliary building      Inspect the surface of the inflatable elastomer seal for the spent fuel storage pool gates.
High I2ressure core    Visualll:: insl2ect the surface of the SUl2l2ression 12001 suction strainer sl2ral:: sl::stem      for debris.
Residual heat removal  Visualll:: insl2ect the surface of the SUl2l2ression 12001 suction strainer sl::stem               for debris.
Low I2ressure core      Visualll:: insl2ect the surface of the SUl2l2ression 12001 suction strainer sl2ral:: sl::stem      for debris.
Reactor core isolation  Visualll:: insl2ect the surface of the SUl2l2ression 12001 suction strainer cooling                 for debris.

RBG-47867 Enclosure 2 Commitment RAI 3.2.2.3.2-1 General Filtration

RBG-47867 Page 1 of 1 This table identifies actions discussed in this letter that Entergy commits to perform. Any other actions discussed in this submittal are described for the NRC's information and are not commitments.
Changes to LRA Section A.4 follow with additions underlined Implementation            Source No.         Program or Activity                          Commitment                               Schedule         (Letter Number) 24             Periodic Surveillance   Enhance the PSPM Program as described in LRA            Prior to February 28,  RBG-47735 and Preventive          Section A.1 .34.                                       2025, or the end of the RBG-47867 Maintenance                                                                    last refueling outage prior to August 29, 2025 , whichever is later.}}