RBG-47853, Response to License Renewal Application NRC Request for Additional Information Supplement to B.1.35-1

Response to License Renewal Application NRC Request for Additional Information Supplement to B.1.35-1

ML18116A622
Person / Time
Site:	River Bend
Issue date:	04/26/2018
From:	Maguire W Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RBG-47853
Download: ML18116A622 (5)

Text

• Entergx

-===-

Entergy Operations, Inc.

River Bend Station 5485 U.S. Highway 61 N St Francisville. LA 70775 Tel 225-38 1-4374 William F. Maguire Site Vice President River Bend Station RBG-47853 April 26, 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 Supplement to B.1.35-1 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) Public Phone Call - Discuss RAI B.1 .35-1 , Protective Coatings - dated April 24, 2018 (ADAMS Accession No ML18107A504)

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. On March 29, 2018 , during a public phone call , the NRC staff discussed with Entergy the response to RAI B.1.35-1 (Reference 2) . Based on that discussion , Entergy is clarifying the response. Enclosure 1 provides the revised response to RAI B.1.35-1.

If you require additional information, please contact Mr. Tim Schenk at (225)-381 -4177 or tschenk @entergy.com.

RBG-47853 Page 2 of 2 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 April 26,2018.

Sincerely, -

WFM/RMC/alc : Response to Supplement RAI 8.1.35 River Bend Station 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 Attn: Lisa Regner 11555 Rockville Pike Rockville, MD 20852 U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Blvd.

Arlington, TX 76011-4511 NRC Resident Inspector PO Box 1050 St. Francisville, LA 70775 Central Records Clerk Public Utility Commission of Texas 1701 N. Congress Ave.

Austin, TX 78711-3326 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 RBF1-18-0079

R8G-47853 Enclosure 1 Response to Request for Additional Information Supplement to 8 .1.35-1

RBG-47853 Page 1 of 2 REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION RIVER BEND STATION, UNIT 1 - SUPPLEMENT TO B.1.35-1 DOCKET NO.: 50-458 CAC NO.: MF9757 Office of Nuclear Reactor Regulation Division of Materials and License Renewal Question 8 .1.35-1 "Protective Coating Monitoring and Maintenance Program ."

Background

NUREG-1801 , "Generic Aging Lessons Learned (GALL) Report," identifies aging management programs (AMP) that are deemed acceptable to manage aging effects on systems, structures, and components in the scope of license renewal , as required by 10 CFR Part 54, "Requirements for Renewal of Operating License for Nuclear Power Plants." AMP XLS8 "Protective Coating Monitoring and Maintenance Program in NUREG-1801 states that NRC Regulatory Guide 1.54, Rev. 2, "Service Levell , II , and III Protective Coatings Applied to Nuclear Power Plants," describes an acceptable technical basis for a Service Level I coatings monitoring and maintenance program that can be credited for managing the effects of corrosion for carbon steel elements inside containment. Additionally, NUREG-1800, Rev. 2 "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" Table 3.0-1 "FSAR Supplement for Aging Management of Applicable Systems" for XLS8 states that the program is implemented in accordance with RG 1.54, Rev. 1 or latest revision .

Issue The River Bend Station License Renewal Application A.1.35 "Protective Coating Monitoring and Maintenance" AMP states that the program is implemented using the guidance provided in American Society for Testing of Materials (ASTM) D 5163-08, "Standard Guide for Establishing a Program for Condition Assessment of Coating Service Level I Coating Systems in Nuclear Power Plants." B.1.35 of the application states that the Protective Coating Monitoring and Maintenance Program is consistent with the program described in NUREG-1801 , Section XLS8 , Protective Coating Monitoring and Maintenance Program.

Discussion The staff inquired about the applicant's basis for claiming consistency with the GALL Report without explicitly referencing RG 1.54 in its A.1.35 AMP or 8.1.35 AMP activities. The applicant stated that the basis for the consistency with the GALL program stemmed from the facts that comparison with the ten elements of NUREG-1801 Section XLS8 was performed without the need to reference RG 1.54 because the Section XLS8 program elements refer directly to ASTM D 5163 provisions and RG 1.54, Rev. 2 points back to ASTM D 5163-08 as a document providing guidelines that the NRC staff finds acceptable for establishing an in-service coating monitoring program for Service Level I coating systems in operating nuclear power plants.

Although the staff agrees that ASTM D 5163 is the primary standard for addressing condition assessment of Service Level I coatings, RG 1.54 provides additional guidance including conditions for the use of ASTM D 5163. If a licensee chooses not to cite RG 1.54, they should provide adequate justification to demonstrate that their aging management program will provide reasonable assurance of adequate management of the aging effects for Service Level I coatings, consistent with the expectations of GALL AMP XLS8.

The licensee has stated that a supplement to the license renewal application will be made or adequate justification will be provided to demonstrate that their aging management program will provide reasonable assurance that adequate management of the aging effects for Service Level I coatings are consistent with NUREG-1801 Section XLS8 .

RBG-47853 Page 2 of 2

Response

During a public telephone conference held on March 29, 2018, Entergy discussed with NRC staff information that was provided in River Bend Station (RBS) license renewal application (LRA) Section A.1.35, "Protective Coating Monitoring and Maintenance." Entergy agreed to clarify this discussion . This clarification revises RBS LRA Sections A.1 .35 and B.1.35 to explicitly include reference to Regulatory Guide 1.54 for implementation of the RBS Protective Coating Monitoring and Maintenance Program.

LRA revisions follow. Additions are underlined.

A.1.35 Protective Coating Monitoring and Maintenance The Protective Coating Monitoring and Maintenance Program manages the effects of aging on Service Level I coatings applied to external surfaces of carbon steel and concrete inside containment (e.g ., steel containment vessel shell , structural steel , supports, penetrations, and concrete walls and floors). The program is implemented using the guidance provided in Regulatory Guidance 1.54 and ASTM D 5163-08.

The program provides an effective method to assess coating condition through visual inspections by identifying degraded or damaged coatings and providing a means for repair of identified problem areas.

Service Level I protective coatings are not credited to manage the effects of aging. Proper monitoring and maintenance of protective coatings inside containment ensures operability of post-accident safety systems that rely on water recycled through the containment. The proper monitoring and maintenance of Service Level I coatings ensures there is no coating degradation that would impact safety functions, for example, by clogging emergency core cooling system suction strainers.

8.1.35 PROTECTIVE COATING MONITORI NG AND MAINTENANCE Program Description The Protective Coating Monitoring and Maintenance Program manages the effects of aging on Service Level I coatings applied to external surfaces of carbon steel and concrete inside containment (e.g., steel containment vessel shell , structural steel , supports, penetrations, and concrete walls and floors). The Protective Coating Monitoring and Maintenance Program is implemented using the guidance provided in Regulatory Guidance 1.54 and ASTM D 5163-08. The program provides an effective method to assess coating condition through visual inspections by identifying degraded or damaged coatings and providing a means for repair of identified problem areas.

Service Level I protective coatings are not credited to manage the effects of aging. Proper monitoring and maintenance of protective coatings inside containment ensures operability of post-accident safety systems that rely on water recycled through the containment. The proper monitoring and maintenance of Service Level I coatings ensures there is no coating degradation that would impact safety functions, for example, by clogging emergency core cooling system suction strainers.

• Entergx

-===-

Entergy Operations, Inc.

River Bend Station 5485 U.S. Highway 61 N St Francisville. LA 70775 Tel 225-38 1-4374 William F. Maguire Site Vice President River Bend Station RBG-47853 April 26, 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 Supplement to B.1.35-1 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) Public Phone Call - Discuss RAI B.1 .35-1 , Protective Coatings - dated April 24, 2018 (ADAMS Accession No ML18107A504)

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. On March 29, 2018 , during a public phone call , the NRC staff discussed with Entergy the response to RAI B.1.35-1 (Reference 2) . Based on that discussion , Entergy is clarifying the response. Enclosure 1 provides the revised response to RAI B.1.35-1.

If you require additional information, please contact Mr. Tim Schenk at (225)-381 -4177 or tschenk @entergy.com.

RBG-47853 Page 2 of 2 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 April 26,2018.

Sincerely, -

WFM/RMC/alc : Response to Supplement RAI 8.1.35 River Bend Station 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 Attn: Lisa Regner 11555 Rockville Pike Rockville, MD 20852 U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Blvd.

Arlington, TX 76011-4511 NRC Resident Inspector PO Box 1050 St. Francisville, LA 70775 Central Records Clerk Public Utility Commission of Texas 1701 N. Congress Ave.

Austin, TX 78711-3326 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 RBF1-18-0079

R8G-47853 Enclosure 1 Response to Request for Additional Information Supplement to 8 .1.35-1

RBG-47853 Page 1 of 2 REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION RIVER BEND STATION, UNIT 1 - SUPPLEMENT TO B.1.35-1 DOCKET NO.: 50-458 CAC NO.: MF9757 Office of Nuclear Reactor Regulation Division of Materials and License Renewal Question 8 .1.35-1 "Protective Coating Monitoring and Maintenance Program ."

Background

NUREG-1801 , "Generic Aging Lessons Learned (GALL) Report," identifies aging management programs (AMP) that are deemed acceptable to manage aging effects on systems, structures, and components in the scope of license renewal , as required by 10 CFR Part 54, "Requirements for Renewal of Operating License for Nuclear Power Plants." AMP XLS8 "Protective Coating Monitoring and Maintenance Program in NUREG-1801 states that NRC Regulatory Guide 1.54, Rev. 2, "Service Levell , II , and III Protective Coatings Applied to Nuclear Power Plants," describes an acceptable technical basis for a Service Level I coatings monitoring and maintenance program that can be credited for managing the effects of corrosion for carbon steel elements inside containment. Additionally, NUREG-1800, Rev. 2 "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" Table 3.0-1 "FSAR Supplement for Aging Management of Applicable Systems" for XLS8 states that the program is implemented in accordance with RG 1.54, Rev. 1 or latest revision .

Issue The River Bend Station License Renewal Application A.1.35 "Protective Coating Monitoring and Maintenance" AMP states that the program is implemented using the guidance provided in American Society for Testing of Materials (ASTM) D 5163-08, "Standard Guide for Establishing a Program for Condition Assessment of Coating Service Level I Coating Systems in Nuclear Power Plants." B.1.35 of the application states that the Protective Coating Monitoring and Maintenance Program is consistent with the program described in NUREG-1801 , Section XLS8 , Protective Coating Monitoring and Maintenance Program.

Discussion The staff inquired about the applicant's basis for claiming consistency with the GALL Report without explicitly referencing RG 1.54 in its A.1.35 AMP or 8.1.35 AMP activities. The applicant stated that the basis for the consistency with the GALL program stemmed from the facts that comparison with the ten elements of NUREG-1801 Section XLS8 was performed without the need to reference RG 1.54 because the Section XLS8 program elements refer directly to ASTM D 5163 provisions and RG 1.54, Rev. 2 points back to ASTM D 5163-08 as a document providing guidelines that the NRC staff finds acceptable for establishing an in-service coating monitoring program for Service Level I coating systems in operating nuclear power plants.

Although the staff agrees that ASTM D 5163 is the primary standard for addressing condition assessment of Service Level I coatings, RG 1.54 provides additional guidance including conditions for the use of ASTM D 5163. If a licensee chooses not to cite RG 1.54, they should provide adequate justification to demonstrate that their aging management program will provide reasonable assurance of adequate management of the aging effects for Service Level I coatings, consistent with the expectations of GALL AMP XLS8.

The licensee has stated that a supplement to the license renewal application will be made or adequate justification will be provided to demonstrate that their aging management program will provide reasonable assurance that adequate management of the aging effects for Service Level I coatings are consistent with NUREG-1801 Section XLS8 .

RBG-47853 Page 2 of 2

Response

During a public telephone conference held on March 29, 2018, Entergy discussed with NRC staff information that was provided in River Bend Station (RBS) license renewal application (LRA) Section A.1.35, "Protective Coating Monitoring and Maintenance." Entergy agreed to clarify this discussion . This clarification revises RBS LRA Sections A.1 .35 and B.1.35 to explicitly include reference to Regulatory Guide 1.54 for implementation of the RBS Protective Coating Monitoring and Maintenance Program.

LRA revisions follow. Additions are underlined.

A.1.35 Protective Coating Monitoring and Maintenance The Protective Coating Monitoring and Maintenance Program manages the effects of aging on Service Level I coatings applied to external surfaces of carbon steel and concrete inside containment (e.g ., steel containment vessel shell , structural steel , supports, penetrations, and concrete walls and floors). The program is implemented using the guidance provided in Regulatory Guidance 1.54 and ASTM D 5163-08.

The program provides an effective method to assess coating condition through visual inspections by identifying degraded or damaged coatings and providing a means for repair of identified problem areas.

Service Level I protective coatings are not credited to manage the effects of aging. Proper monitoring and maintenance of protective coatings inside containment ensures operability of post-accident safety systems that rely on water recycled through the containment. The proper monitoring and maintenance of Service Level I coatings ensures there is no coating degradation that would impact safety functions, for example, by clogging emergency core cooling system suction strainers.

8.1.35 PROTECTIVE COATING MONITORI NG AND MAINTENANCE Program Description The Protective Coating Monitoring and Maintenance Program manages the effects of aging on Service Level I coatings applied to external surfaces of carbon steel and concrete inside containment (e.g., steel containment vessel shell , structural steel , supports, penetrations, and concrete walls and floors). The Protective Coating Monitoring and Maintenance Program is implemented using the guidance provided in Regulatory Guidance 1.54 and ASTM D 5163-08. The program provides an effective method to assess coating condition through visual inspections by identifying degraded or damaged coatings and providing a means for repair of identified problem areas.

Service Level I protective coatings are not credited to manage the effects of aging. Proper monitoring and maintenance of protective coatings inside containment ensures operability of post-accident safety systems that rely on water recycled through the containment. The proper monitoring and maintenance of Service Level I coatings ensures there is no coating degradation that would impact safety functions, for example, by clogging emergency core cooling system suction strainers.