GNRO-2010/00015, Response to NRC Request for Additional Information for Lsi Relief Requests GG-ISI-005 Through GG-ISI-012 for NRC Letter Dated January 4, 2010
| ML100470747 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/11/2010 |
| From: | Burford F Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GNRO-2010/00015, TAC ME1376, TAC ME1377, TAC ME1378, TAC ME1379, TAC ME1380, TAC ME1381, TAC ME1382, TAC ME1383 | |
| Download: ML100470747 (8) | |
Text
~Entergy Entergy Operations, Inc.
P.O. Box 756 Port Gibson, MS 39150 Tel 601 437 2800 GNRO-2010/00015 February 11, 2010 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
SUBJECT:
Response to NRC Request for Additional Information for lSI Relief Requests GG-ISI-005 through GG-ISI-012 for NRC Letter Dated January 4,2010 (TAC NOS ME1376-ME1383)
Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
REFERENCES:
- 1. NRC Letter GNRI-2010/00007, Request for Additional Information RE:
Reliefs Requests GG-ISI-005 through GG-ISI-012 (TAC NOS ME1376-ME1383), dated January 4, 2010
- 2. Letter GNRO-2009/00051, Response to NRC Request for Additional Information for lSI Relief Requests GG-GG-ISI-005 through GG-ISI-012, dated October 1,2009
- 3. NRC Letter GNRI-2009/00063, Request for Additional Information RE:
Reliefs Requests GG-ISI-005 through GG-ISI-012 (TAC NOS ME1376-ME1383), dated July 1,2009
- 4. Letter GNRO-2009/00018, Inservice Inspection (lSI) Relief Requests GG-ISI-005 through 012 American Society of Mechanical EngineersSection XI Second 10-Year Inspection Interval Closeout, dated May 29, 2009
Dear Sir or Madam:
In the letter dated May 29, 2009 (GNRO-2009/00018), Grand Gulf Nuclear Station (GGNS) requested relief pursuant to 10CFR50.55a(g)(5)(iii). Based on its review of the application, the NRC requested via letter dated January 4, 2010 (GNRI-201 0/00007) additional information to complete the required reviews. The responses to the request for additional information are attached to this letter.
This letter contains no commitments.
GNRO-2010/00015 Page 2 of 2 Should you have any questions regarding this submittal, please contact Ernest Rufus, Supervisor Engineering Programs at 601-437-6582.
d§~
Acting Licensing Manager FGB/MJL
Attachment:
Responses to Request for Additional Information: Relief Requests GG-ISI-005 through GG-ISI-012 cc: NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATTN: Mr. Elmo E. Collins (w/a)
Regional Administrator, Region IV 612 East Lamar Drive, Suite 400 Arlington, TX 76011-4005 U.S. Nuclear Regulatory Commission ATTN: Mr. Carl F. Lyon, NRR/ADRO/DORL (w/2)
Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378
GNRO*201 0/00015 - Attachment 1 Page 1 Responses to Request for Additional Information The NRC requested GGNS to provide detailed and specific information in order to complete the review of Relief Requests GG-ISI-005 through GG-ISI-012. The responses to this request are provided below.
NRC Request #1 Requests for Relief GG-ISI-D05 through GG-ISI-012 (Parts A through H), Examination Categories B-A, B-0, B-F, B-G-1, B-J, B*K, C-F-2, and F-A Based on the licensee's submittal, it is unclear which Edition and Addenda of ASME Code,Section XI, is applicable to the specific components listed in the individual relief requests. For example, in relief request GG-ISI-005, the licensee lists the 1977 Edition through the 1979 Addenda, 1992 Edition through the 1993 Addenda, and the 1995 Edition through the 1996 Addenda as having applicable lSI requirements for the subject components. The licensee states that the 1995 Edition through the 1996 Addenda of ASME Code was mandated for implementation of the ASME Code,Section XI, Appendix VIII examinations during the interval; however, this does not clear up the multiple ASME Code applicability issues. Please confirm the ASME Code of record for the second interval lSI program at GGNS, how the licensee arrived at this edition/addenda of the ASME Code, and the specific requirements for each of the subject components listed in each request for relief.
Response
The ASME Code of Record for the Second 10-Year Interval of the GGNS lSI Program was ASME Section XI, Division 1,1992 Edition with portions of the 1993 Addenda (Add), as described in the GGNS lSI Program manual. The Second 10-Year lSI Interval was approved by NRC letter (GNRI-96/00244) dated December 12, 1996. On September 22, 1999 10 CFR 50.55a was revised mandating the implementation of the 1995 Edition, through and including the 1996 Addenda of ASME Section XI, Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems." Appendix VIII is comprised of multiple supplements for varying scopes of ultrasonic application. The NRC mandated each supplement's use in accordance with a specific schedule for implementation. Additionally, by implementing Appendix VIII for each of the specific supplements, it also required the use of Appendix VII from the 1995 Edition through the 1996 Addenda within the same schedule.
Refer to the below tables for additional information about the specific requirements for each of the subject components.
Rele r fRequest GGN5 151005 - -
Limited B-A Examinations Item Number Comp 10 Item Description % Coveraae Date Examined & Code Year B1.12 BJ RPV Longitudinal Shell App. VIII 86% 9/28/2002, 92 Edition w/portions of 93 Add Weld B1.22 DA RPV Meridional Bottom Pre- App. VIII 44.40% 11/10/1999,92 Edition w/portions of 93 Add Head Weld B1.22 DB RPV Meridional Bottom Pre- App. VIII 44.40% 11/10/1999,92 Edition w/portions of 93 Add Head Weld B1.22 DC RPV Meridional Bottom Pre- App. VIII 17.20% 11/10/1999,92 Edition w/portions of 93 Add Head Weld B1.22 DD RPV Meridional Bottom Pre- App. VIII 17.20% 11/10/1999,92 Edition w/portions of 93 Add Head Weld B1.30 AE RPV Shell to Flange Not covered by App. 11/16/1999 & 913012005, 92 Edition Weld VIII 75% w/portions of 93 Add 81.40 AG RPV Head to Flange Not covered by App. 9/25/2005 & 3/2212007, 92 Edition w/portions Weld VIII 77.20% of 93 Add
GNRO*2010100015 - Attachment 1 Page 2 Rele r fRequest GGNS 151 006 -
Limited B-D Examinations Item Number Comp 10 Item Description % Coverage Date Examined & Code Year 83.90 N018-KA 24" Recirculation Outlet Nozzle Pre-App. VIII 9/26/2002, 92 Edition w/portions of 93 Add to Shell 50.00%
83.90 N028-KA 12" Recirculation Inlet Nozzle Pre- App. VIII 11/10/1999,92 Edition w/portions of 93 Add to Vessel 60.00%
83.90 N02C-KA 12" Recirculation Inlet Nozzle Pre- App. VIII 11/10/1999, 92 Edition w/portions of 93 Add to Vessel 60.00%
83.90 N02D-KA 12" Recirculation Inlet Nozzle Pre- App. VIII 11/10/1999,92 Edition w/portions of 93 Add to Vessel 60.00%
83.90 N02E-KA 12" Recirculation Inlet Nozzle Pre- App. VIII 11/10/1999,92 Edition w/portions of 93 Add to Vessel 60.00%
83.90 N02F-KA 12" Recirculation Inlet Nozzle Pre- App. VIII 9/23/2002, 92 Edition w/portions of 93 Add to Vessel 60.00%
83.90 N02G-KA 12" Recirculation Inlet Nozzle Pre- App. VIII 9/23/2002, 92 Edition w/portions of 93 Add to Vessel 60.00%
83.90 N02H-KA 12" Recirculation Inlet Nozzle Pre- App. VIII 9/23/2002, 92 Edition w/portions of 93 Add to Vessel 60.00%
83.90 N02J-KA 12" Recirculation Inlet Nozzle Pre- App. VIII 9/23/2002, 92 Edition w/portions of 93 Add to Vessel 60.00%
83.90 N03A-KA 24" Main Steam Nozzle to Pre- App. VIII 11/12/1999,92 Edition w/portions of 93 Add Vessel 60.00%
83.90 N038-KA 24" Main Steam Nozzle to Pre- App. VIII 11/12/1999,92 Edition w/portions of 93 Add Vessel 60.00%
83.90 N04A-KA 14" Feedwater Nozzle to Pre- App. VIII 5/5/199892 Edition w/portions of 93 Add Vessel 58.00%
83.90 N048-KA 14" Feedwater Nozzle to Pre- App. VIII 5/5/1998, 92 Edition w/portions of 93 Add Vessel 58.00%
83.90 N04C-KA 14" Feedwater Nozzle to Pre- App. VIII 9/27/2002, 92 Edition w/portions of 93 Add Vessel 58.00%
83.90 N04D-KA 14" Feedwater Nozzle to Pre- App. VIII 9/27/2002, 92 Edition w/portions of 93 Add Vessel 58.00%
83.90 N05A-KA Core Spray Nozzle to Vessel Pre- App. VIII 9/27/2002, 92 Edition w/portions of 93 Add 58.00%
83.90 N06A-KA 12" RHRlLPCllnlet Nozzle Pre- App. VIII 11/6/1999, 92 Edition w/portions of 93 Add 58.00%
83.90 N068-KA 12" RHRlLPCllnlet Nozzle Pre- App. VIII 9/27/2002,92 Edition w/portions of 93 Add 58.00%
83.90 N06C-KA 12" RHR/LPCllnlet Nozzle Pre- App. VIII 9/27/2002, 92 Edition w/portions of 93 Add 58.00%
83.90 N07-KA 15.5" RCIC Top Head Spray Pre- App. VIII 4/18/2001,92 Edition w/portions of 93 Add Inlet Nozzle 62.00%
83.90 N08-KA 15.5" RCIC Top Head Spray Pre- App. VIII 4/18/2001, 92 Edition w/portions of 93 Add Inlet Nozzle 62.00%
83.90 N09A-KA 12" Instrument Nozzle to Shell Pre- App. VII' 9/23/2002, 92 Edition w/portions of 93 Add 59.00%
83.90 N01A-KA 24" Recirculation Outlet Nozzle App. VIII 4/4/2007, 92 Edition w/portions of 93 Add to Shell 76.00%
83.90 N02A-KA 12" Recirculation Inlet Nozzle App. VIII 4/4/2007, 92 Edition w/portions of 93 Add to Vessel 70.00%
83.90 N02K-KA 12" Recirculation Inlet Nozzle App. VIII 4/4/2007, 92 Edition w/portions of 93 Add to Vessel 70.00%
83.90 N02M-KA 12" Recirculation Inlet Nozzle App. VI/I 4/4/2007,92 Edition w/portions of 93 Add to Vessel 70.00%
83.90 N02N-KA 12" Recirculation Inlet Nozzle App. VIII 4/4/2007, 92 Edition w/portions of 93 Add to Vessel 70.00%
GNRO*201 0/00015 - Attachment 1 Page 3 83.90 N03C-KA 24 11 Main Steam Nozzle to App. VIII 4/1/2007,92 Edition w/portions of 93 Add Vessel 75.00%
83.90 N03D-KA 24" Main Steam Nozzle to App. VIII 4/1/2007,92 Edition w/portions of 93 Add Vessel 75.00%
83.90 N04E-KA 1411 Feedwater Nozzle to App. VIII 4/212007, 92 Edition w/portions of 93 Add Vessel 72.00%
83.90 N058-KA Core Spray Nozzle to Vessel App. VIII 4/212007, 92 Edition w/portions of 93 Add 73.00%
83.90 N04F-KA 1411 Feedwater Nozzle to App. VIII 4/212007, 92 Edition w/portions of 93 Add Vessel 72.00%
83.90 N098-KA 1211 Instrument Nozzle to Shell App. VIII 4/4/2007, 92 Edition w/portions of 93 Add 77.00%
83.90 N10-KA CRD Nozzle to Shell App. VIII 4/1/2007,92 Edition w/portions of 93 Add 72.00%
83.90 N16-KA Instrument Nozzle to Shell App. VIII 3/30/2007,92 Edition w/portions of 93 Add 77.00%
r fRequest GGN5 151-007 Rele -
Limited B-F Examinations Item Number Comp 10 Item Description % Coverage Date Examined & Code Year 85.10 N01A-K8 24 11 Recirculation Nozzle-to- Not covered by 4/1/2007,92 Edition w/portions of 93 Add Safe End, SS App. VIII 75.60%
85.10 N02K-K8 1411 Recirculation Nozzle-to- Not covered by 3/30/2007, 92 Edition w/portions of 93 Add Safe End, SS App. VIII 77.30%
r fRequest GGN5 151 008 Rele - -
Table 1, Limited B-G-1 Examinations Item Number Comp.ID Item Description % Coverage Date Examined & Code Year 86.40 FLG L1G 1 through Reactor Vessel Threads-in- Not covered by 4/29/2001,92 Edition w/portions of 93 Add FLG L1G 25 Flange App. VIII 86.60%
86.40 FLG L1G 26 through Reactor Vessel Threads-in- Not covered by 9/15/2002, 92 Edition w/portions of 93 Add FLG L1G 50 Flange App. VIII 86.60%
86.40 FLG L1G 51 through Reactor Vessel Threads-in- Not covered by 9/20/2005, 92 Edition w/portions of 93 Add FLG L1G 76 Flange App. VIII 86.60%
r fRequest GGN5 151 009 Rele - -
Limited B-J Examinations Item Number Comp 10 Item Description % Coverage Date Examined & Code Year 89.11 833G001-W34 24 11 RCS Pipe to Cross, SS Pre App. VIII 11/5/1999,92 Edition w/portions of 93 Add 50.00%
89.11 833G10-81-A 1611 RCS Pipe to Cross, SS Pre App. VIII 11/4/1999 & 11/5/1999,92 Edition w/portions 50.00% of 93 Add 89.11 833G10-81-8 1611 RCS Pipe to Cross, SS Pre App. VIII 11/5/1999 & 11/28/1999, 92 Edition 50.00% w/portions of 93 Add 89.11 E51G001-W40 611 RCIC Valve to Elbow, CS App. VIII 4/23/2001 & 4/29/2001,92 Edition w/portions 60.00% of 93 Add 89.31 833G10-81-H 1211 RCS Sweep-o-Iet to Pipe, App. VIII 4/16/2001 & 5/29/2001, 92 Edition w/portions SS 50.00% of 93 Add
GNRO-2010/00015 - Attachment 1 Page 4 B9.11 B33G001-W20 12" RCS Pipe to Tee, SS App. VIII 4/16/2001 & 5/29/2001, 92 Edition w/portions 50.00% of93 Add B9.11 B33G001-W22 12" RCS Pipe to Tee, SS App. VIII 4/16/2001 & 5/29/2001,92 Edition w/portions 50.00% of 93 Add B9.11 1B33G1O-A1-B 24" Pipe to Cross, SS App. VIII 9/24/2002, 92 Edition w/portions of 93 Add 50.00%
B9.31 1B33G10-A1-F 12" RCS Branch, SS App. VIII 9/24/2002, 92 Edition w/portions of 93 Add 83.00%
B9.31 1B33G10-A1-G 12" RCS Branch, SS App. VIII 9/24/2002, 92 Edition w/portions of 93 Add 83.00%
B9.31 1B33G10-A1-H 12" RCS Branch, SS App. VIII 9/24/2002, 92 Edition w/portions of 93 Add 83.00%
B9.11 B33G001-W33 12" RCS Valve to Pipe, SS App. VIII 3/30/2007, 92 Edition w/portions of 93 Add 50.00%
B9.11 1B33G001W11 24" Pipe to Tee, SS App. VIII 9/24/2002, 92 Edition w/portions of 93 Add 50.00%
B9.11 1B33G10-A1-A 24" Pipe to Tee, SS App. VIII 9/24/2002, 92 Edition w/portions of 93 Add 50.00%
12" RCS Sweep-o-Iet to Pipe, App. VIII 4/16/2001 & 5/29/2001,92 Edition w/portions B9.31 B33G 1O-B 1-G SS 50.0% of 93 Add 12" RCS Sweep-o-Iet to Pipe, App. VIII 4/16/2001 & 5/29/2001,92 Edition w/portions B9.31 B33G10-B1-F SS 50.0% of 93 Add r fR equest GGNS lSI 010 Rele - -
Limited B-K Examinations Item Number Comp.ID Item Description % Coverage Date Examined & Code Year B10.10 CG RPV Support Skirt Attachment Not covered by 3/26/2007,92 Edition w/portions of 93 Add Weld App. VIII 50.00%
B10.20 1B21 G11-D1-P Attachment Weld Not covered by 3/1/2004,92 Edition w/portions of 93 Add App. VIII 32.00%
r fR equest GGNS lSI 011 Rele - -
Limited C-F-2 Examinations Item Number Comp.ID Item Description % Coverage Date Examined & Code Year C5.51 1E51 G004-16-8-3 8.0" RCIC, Pipe - Elbow, CS Not covered by 2/23/2004,92 Edition w/portions of 93 Add App. VIII 51.00%
r fR equest GGNS lSI 012 Rele - -
Limited F-A Examinations Item Number Comp.ID Item Description % Coverage Date Examined & Code Year F1.40 B13D003S1 RPV Support Skirt Not covered by 3/26/2007, 92 Edition w/portions of 93 Add App. VIII 50.00%
GNRO*201 0/00015 - Attachment 1 PageS NRC Request #2 Request for Relief GG*ISI-007 (Part C), Examination Category B-F, Item B5.10, Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles The 1992 Edition of the ASME Code,Section XI requires both volumetric and surface examinations by Examination Category B-F, Item Number B5.1 0 for the subject dissimilar metal nozzle-to-safe end butt welds.
However, neither the original submittal nor the response to the request for additional information dated October 1, 2009, state that surface examinations were required and performed for Welds N01A-KB and N02K-KB.
Please confirm that the required surface examinations were performed for the subject welds, whether these surface examinations were full ASME Code examinations (greater than 90 percent coverage), and describe any indications that were detected.
Response
The Surface Examinations were not performed on Welds N01A-KB and N02K-KB due to GGNS relief request to adopt ASME Code Case N-663 per letter (CNR02002-0056) dated December 6, 2002 and approved by NRC letter (CNRI2003-0001 0) dated August 26, 2003.
NRC Request #3 Request for Relief GG-ISI-011, Examination Category B*K, Item B10.10, Integral Attachments for Vessels, Piping, Pumps, and Valves The licensee has requested relief from the requirements of Examination Category B-K, Item B10.10, to address limited surface examinations on the reactor pressure vessel (RPV) support skirt weld. However, the 1992 Edition through the 1993 Addenda of the ASME Code does not have an Examination Category B-K. The subject RPV support skirt examination requirements are listed in Examination Category B-H.
The licensee may have invoked ASME Code Case N-509, Alternative Rules for the Selection and Examination of Class 1, 2, and 3 Integrally Welded Attachments,Section XI, Division 1, which lists Examination Category B-K, and states requirements for this, and other integral attachment welds. However, no mention of the use of ASME Code Case N-509 has been stated. ASME Code Case N-509 is conditionally acceptable according to an earlier revision of NRC Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, which may have been in effect at the start of the licensee's second 1O-year inspection interval. The NRC condition for acceptable use was that a minimum 10 percent sample of integrally welded attachments for each item in each ASME Code class shall be examined during each interval.
State whether ASME Code Case N-509 was invoked for the second interval at GGNS, and confirm that the listed condition for acceptance was applied for all Class 1, 2, and 3 integral attachment welds.
Response
Code Case N-509 was invoked for the Second 10-Year Interval per GGNS Relief Requests letters (GNRO-96/00070) dated June 20, 1996, (GNRO-97/00003) dated January 14,1997 and (GNRO-97/00042) dated May 12, 1997 and approved by NRC letter (GNRI-97/00189) dated November 19, 1997. The condition for acceptability was that a minimum of 100/0 sampling of integrally welded attachments for Class 1, 2 & 3 welds be performed during the Second 10-Year Interval at GGNS. Of the total of 1 Category B-H welds, 1 weld was examined; of the total of 27 Category B-K-1 welds, 3 welds were examined; of the total of 27 Category C-C welds, 3 welds were examined and of the total of 167 Category D-A welds, 26 welds were examined during the Second 10-Year Interval at GGNS.
GNRO-2010/00015 - Attachment 1 Page 6 NRC Request #4 Request for Relief GG-ISI-012 (Part G), Examination Category F-A, Item F1.40, Support Other Than Piping Supports The licensee has requested relief from the visual examination of RPV support skirt Weld 813D003S1 and states that no access is available to the inside region of the support skirt to examine this attachment weld.
However, the staff is aware that other licensees have performed these visual examinations, either directly or remotely, via access through manways in the support skirt. These manways are also typically used for access to maintain the control rod drive mechanisms. Please confirm that no access is available at GGNS to complete the ASME Code visual examinations, and whether these visual examinations might be performed remotely.
Response
Although access through the Reactor Pressure Vessel (RPV) Skirt manways is available, the interior welds are not accessible because of the Reflective Insulation Panels & Insulation installed on the inner diameter of the RPV Skirt. Remote Visual Inspection of the interior welds is also not practical for that reason.
NRC Request #5 Request for Relief GG-ISI-011 (Part H), Examination Category C-F-2, Item C5.51, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping ASME Code,Section XI, 1992 Edition requires a surface examination for Examination Category C-F-2, Item Number C5.51, for the subject Class 2 pipe welds. However, neither the original submittal nor the response to the request for additional information state that surface examination was required and performed for Weld 1E51 G004-16-B-3. Please confirm whether the required surface examination was performed for the subject weld, whether these surface examinations were full ASME Code examinations (>90 Percent coverage) and describe any indications that were detected.
Response
The Surface Examination was not performed on Weld 1E51 G004-16-B-3 due to GGNS relief request to adopt ASME Code Case N-663 per Letter (CNR02002-0056) dated December 6, 2002 and approved by NRC letter (CNRI2003-00010) dated August 26,2003.