GNRO-2012/00138, Response to Requests for Additional Information (RAI) Set 40 Dated October 19, 2012

Response to Requests for Additional Information (RAI) Set 40 Dated October 19, 2012

ML12325A173
Person / Time
Site:	Grand Gulf
Issue date:	11/19/2012
From:	Mike Perito Entergy Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
GNRO-2012/00138, TAC ME7493
Download: ML12325A173 (36)

Text

• Entergy

-=::::- Entergy Operations, Inc.

P. o. Box 756 Port Gibson, MS 39150 Michael Perito Vice President, Operations Grand Gulf Nuclear Station Tel. (601) 437-6409 GNRQ-2012100138 November 19, 2012 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Response to Requests for Additional Information (RAI) Set 40 dated October 19,2012 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCE:

NRC Letter, "Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application," dated October 19,2012 (GNRI-2012100225) (TAC No. ME7493)

Dear Sir or Madam:

Entergy Operations, Inc is providing, in the Attachment, the response to the referenced Requests for Additional Information (RAI).

This letter does not contain any new commitments. If you have any questions or require additional information, please contact Jeffery A. Seiter at 601-437-2344.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19th day of November, 2012.

MP/jas

Attachment:

(see next page)

GNRO-2012/00138 Page 2 of 2

Attachment:

Response to Requests for Additional Information (RAI) cc: with Attachment Mr. John P. Boska, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555 cc: without Attachment Mr. Elmo E. Collins, Jr.

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission AnN: Mr. A. Wang, NRRlDORL Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 U.S. Nuclear Regulatory Commission AnN: Mr. Nathaniel Ferrer NRRlDLR Mail Stop OWFN/ 11 F1 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment 1 to GNRO*2012/00138 Response to Requests for Additional Information (RAI)

Attachment to GNRO-2012/00138 Page 1 of 33 The format for the Request for Additional Information (RAI) responses below is as follows. The RAI is listed in its entirety as received from the Nuclear Regulatory Commission (NRC) with background, issue and request subparts. This is followed by the Grand Gulf Nuclear Station (GGNS) RAI response to the individual question.

RAI3.5.1-1 Background. License renewal application (LRA) Table 3.5.1 identifies several items as "not applicable" with a further discussion stating that the "listed aging effects do not require management at GGNS. Nonetheless, components are included in the [GALL recommended program(s)] to verify the absence of other aging effects, such as..." The table below contains two examples:

Item Component Aging Effect! Aging Further Evaluation Discussion Number Mechanism Management Recommended Programs 3.5.1-55 Building Reduction in Structures No Not applicable. Listed concrete at concrete Monitoring aging effects do not locations of anchor Program require management at expansion and capacity due to GGNS. Nonetheless, grouted local concrete components are anchors; grout degradation/ included in the pads for service induced Structures Monitoring support base cracking or Program to verify the plates other concrete absence of other aging aging effects, such as mechanisms cracking, for components in this listing.

3.5.1-30 Pressure- Loss of preload 151 (WE) and 10 No Not applicable. Listed retaining bolting due to self- CFR Part 50, aging effects do not loosening Appendix J require management at GGNS. Nonetheless, bolting components are included in the Containment Inservice Inspection -IWE and Containment Leak Rate Programs to verify the absence of other aging effects, such as loss of materials, for the listed components.

Issue. For these items that the applicant has identified as "not applicable," but stated that the components are included in the GALL recommended program(s) to verify the absence of other aging effects, sufficient information has not been provided to verify the applicant's assertion that the aging effect(s) identified in the GALL Report would not require management at GGNS. It is not clear if the identified aging effect will be managed for the listed component(s) as recommended in the GALL Report. Although the LRA states that the components are included in the program, the staff's concern is that the applicant proposes to verify the absence of other aging effects, which is not equivalent to managing the identified aging effect(s) for the component, material, and environment combination.

In accordance with §54.21 (a)(3), for each structure and component subject to an aging management review, the applicant must demonstrate that the effects of aging will be adequately

Attachment to GNRO-2012/00138 Page 2 of 33 managed so that the intended function( s) will be maintained consistent with the current licensing basis (CLB) for the period of extended operation. For all items where the GALL Report does not recommend further evaluation (Le., the Further Evaluation Recommended column in LRA Table 3.5.1 is populated with the word "no"), the staff is seeking clarification and sufficient technical justification for excluding the listed aging effects from management.

Request.

a. For each item in Table 3.5.1 where no further evaluation is recommended that the applicant has identified as "not applicable," but stated that the components are included in the GALL recommended program(s) to verify the absence of other aging effects, provide the technical justification as to why the aging effect recommended in the GALL Report and specified in Table 3.5.1 line item does not apply, to GGNS, and/or why that aging effect does not require management.

b. If it is determined that components will be age-managed as recommended in the GALL Report, identify which aging management program(s) will be used to manage the identified aging effect during the period of extended operation.

RAI 3.5.1-1 RESPONSE:

a. Entries in the "Discussion" column of Grand Gulf Nuclear Station (GGNS) LRA Table 3.5.1 items where no further evaluation is recommended are revised and additional technical justification as to why the aging effect recommended in the GALL Report and specified in the Table 3.5.1 line item does not apply or require management is provided.

In addition, the phrase "verify the absence of other aging effects" is revised to refer to the aging effects identified in the "Aging Effect/Mechanism" column. Additions are shown with underline and deletions are shown with strike-through.

Attachment to GNRO-2012/00138 Page 3 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program

~

13.5.1-15 oncrete Increase in porosity lSI (lWL). No Not applicable. Listed aging effects do accessible land permeability; loss not require management at GGNS.

reas): basemat. Iof strength due to Leaching of calcium hydroxide and eaching of calcium carbonation is significant only if concrete Ihydroxide and is exposed to flowing water. GGNS is a

!carbonation concrete containment with a steel liner and its concrete basemat is not exposed to flowing water. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management.

Nonetheless, the concrete components in this listing are included in the Containmentl Inservice Inspection -IWL Program to veFify confirm the absence of etAef the listed aging effects. such as crackinG. for components in this listing.

Attachment to GNRO-2012/00138 Page 4 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 3.5.1-16 Concrete Increase in porosity lSI (lWL) or No Not applicable. Listed aging effects do not

~ accessible and permeability; Structures require management at GGNS. GGNS areas): basemat, cracking; loss of Monitoring concrete is designed and constructed in Concrete: material (spalling, Program accordance with ACI 318 with air containment; wall; scaling) due to entrainment. Concrete structures and basemat ~ggressive chern ical concrete components are constructed of a

~ttack dense. well-cured concrete with an amount of cement suitable for strength development. and achievement of a water-to-cement ratio which is characteristic of concrete with low permeability. GGNS does not have an aggressive chemical environment indoors that may come in contact with concrete surfaces for interior concrete. The outdoor-air environment is not applicable to the GGNS containment. since it is com pletely enclosed by an enclosure building. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management.

Nonetheless, the concrete components in this listing are included in the Containment Inservice Inspection -IWL Program to veFify confirm the absence of ethef-the listed aging effects. such as cracking, for components in this listing.

Attachment to GNRO-2012/00138 Page 5 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 3.5.1-17

--- Not applicaBle. Listed aging effects do oncrete Increase in porosity lSI (IWL) No fcaccessible I

nd permeability; not require management at GGNS.

flreas): dome; racking; loss of GGNS concrete is designed and wall; basemat; aterial (spalling, constructed in accordance with ACI 318 ing girders; caling) due to with air entrainment. Concrete structures Ibuttresses ggressive chern ical and concrete components are constructed ttack of a dense. well-cured concrete with an amount of cement suitable for strength development. and achievement of a water-to-cement ratio which is characteristic of concrete having low permeability. GGNS does not have an aggressive chemical environment indoors that may come in contact with concrete surfaces for interior concrete. The outdoor-air environment is not applicable to the GGNS containment. since it is completely enclosed by an enclosure building. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management.

Nonetheless, the concrete components in this listing are included in the Containment Inservice Inspection - IWL Program to veFify confirm the absence of atAeF the listed aging effects. such as crackina. for components in this listing.

Attachment to GNRO-2012/00138 Page 6 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 3.5.1-18 K;oncrete Loss of material lSI (lWL) No Not applioable. Listed aging effects do not

~ accessible ~spalling, scaling) and require management at GGNS. The

~reas): dome; cracking due to freeze- GGNS primary containment concrete is wall; basemat; ~haw enclosed by the enclosure building and is ing girders; not exposed to an air-outdoor buttresses, environment that would subject the Concrete concrete containment to freeze-thaw

.~ accessible conditions. The design and construction areas): basemat of these structures at GGNS provides reasonable assurance that these aging effects do not require management.

Nonetheless, components are included in the Containment Inservice Inspection-IWL Program to veFify confirm the absence of-etAef.-the listed aging effects.

suoh as oraoking, fur oom ponents in this

~

Attachment to GNRO-2012/00138 Page 7 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program

~.5.1-19 ~oncrete Cracking due to lSI (lWL) No Not appliGable. Listed aging effect does

~ accessible expansion from not require management at GGNS.

~reas): dome; eaction with GGNS concrete is designed and wall; basemat; aggregates constructed in accordance with ACI 318 ring girders; with air entrainment. Fine and course buttresses, aggregates conform to ASTM C33.

Concrete Petrographic examinations of aggregates

~accessible were performed in accordance with ASTM areas): basemat, C295, ASTM C289. and other ASTM tests Concrete demonstrating that reactive aggregates

accessible were not used, Cracking associated with areas) exoansion due to reaction with aaareaates containment; wall; has not been observed on accessible

~asemat, portions of the GGNS primary

~oncrete fill-in containment. The design and

~nnulus construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management.

Nonetheless, the concrete components in this listing are included in the Containment Inservice Inspection - IWL Program to YeFify confirm the absence of atAef the listed aging effect. Sl:JGR as GFaGking, foF Gomponents in tRis listing,

Attachment to GNRO-2012/00138 Page 8 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 13.5.1-20 oncrete Increase in porosity lSI (IWL) No Not appliGable. Listed aging effects do accessible land permeability; loss not require management at GGNS. The reas): dome; Iof strength due to GGNS primary containment concrete is all; basemat; eaching of calcium not exposed to a fluid environment that ing girders; ~ydroxide and would subject the concrete containment to uttresses, ~arbonation the listed aging effects. The enclosure oncrete building protects the external surfaces of accessible concrete from the environment. A steel reas): liner protects internal surfaces such that ontainment; wall; the concrete is not exposed directly to the asemat fluid. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management. Nonetheless, components are included in the Containment Inseryice Inspection - IWL Program to veFify confirm the absence of the listed-etAef.-aging effects. SUGh as GraGking, for Gomponents in this listing.

Attachment to GNRO-2012/00138 Page 9 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 3.5.1-21 ~oncrete Cracking; loss of bond; lSI (lWL) No Not applicable. Listed aging effects do not

~ accessible and loss of material require management at GGNS. For lareas): dome; 'spalling, scaling) due exterior above-grade and interior wall; basemat; o corrosion of embedded steel. corrosion is not ing girders; embedded steel significant if the steel is not exposed to an buttresses; aggressive environment (concrete pH <

einforcing steel, 11.5 or chlorides> 500 ppm) or if the Concrete environment surrounding the concrete is accessible not aggressive (pH> 5.5. chlorides < 500 lareas): basemat; ppm. sulfates < 1.500 ppm>. GGNS Ireinforcing steel, concrete em bedded steel is not exposed 1C0ncrete to an aggressive environment and kaccessible concrete is constructed of a dense. well-jareas): dome; cured concrete mix with an amount of wall; basemat; cement suitable for strength development reinforcing steel and achievement of a water-to-cement ratio which is characteristic of concrete with low permeability. designed in accordance with ACI-318 with adequate air-entrainment. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management.

Nonetheless, the concrete components in this listing are included in the Containment Inservice Inspection -IWL Program to veFify confirm the absence of atAeF the listed aging effects. such as cracking, for components in this listing.

Attachment to GNRO-2012/00138 Page 10 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 3.5.1-22 Concrete Cracking; loss of bond; Structures No Not applioable. Listed aging effects do not

'inaccessible and loss of material Monitoring require management at GGNS. For areas): basemat; Kspalling, scaling) due Program exterior above-grade and interior reinforcing steel ~o corrosion of embedded steel. corrosion is not

~mbedded steel significant if the steel is not exposed to an aggressive environment (concrete pH <

11.5 or chlorides> 500 ppm) or if the environment surrounding the concrete is not aggressive (pH> 5.5. chlorides < 500 ppm. sulfates < 1.500 ppm). GGNS concrete embedded steel is not exposed to an aggressive environment and concrete is constructed of a dense. well-cured concrete mix with an amount of cement suitable for strength development.

and achievement of a water-to-cement ratio which is characteristic of concrete with low permeability. designed in accordance with ACI-318 with adequate air-entrainment. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management.

Nonetheless, the concrete components in this listing are included in the Structures Monitoring Program to vefify confirm the absence of etAeF the listed aging effects.

suoh as 1055 of material and 1055 of bond, for components in this listing.

Attachment to GNRO-2012/00138 Page 11 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program

~.5.1-25

~

oncrete raCking; loss of bond;~SI (lWL) or No Not appliGable. Listed aging effeGts do not inaccessible nd loss of material tructures require management at GGNS.

reas): dome; spalling, scaling) due Monitoring GGNS is a BWR Mark III concrete all; basemat; o corrosion of Program containment. This line item is applicable ing girders; mbedded steel to PWR concrete containments.

uttresses; the Contain~ent I pone~ts are inGluded in einforcing steel Nonetheless Gom IWL Program to '1::~~Ge InspeGtion these aging eff.eGt y e absenGe of loss of material f s. SUGh as GraGking and

~ ' or Gomponents in this 3.5.1-27 Penetration ~racking due to cyclic ~SI (IWE) and 10 INo Not appliGable. GGNS has a CLB fatigue

~

Ieeves; oading (CLB fatigue FR Part 50, analysis associated with penetration enetration ~nalysis does not ppendix J sleeves and suppression pool liner at the bellows, Steel ~xist) containment wall. and therefore this aging

~

Iements: torus; effect is addressed under line Item 3.5.1-ent line; vent 9. GGNS is a BWR Mark III which does

,header; vent line not have a torus. vent lines or

~

ellows; downcomers.

owncomers, Listed aging eff.eGts do not require uppression pool management at GGNS. Nonetheless, hell Gomponents are inGluded in the Containment InserviGe InspeGtion IV'JE and Containment Leak Rate Programs to verify the absenGe of ~ other aging eff.eGts, SUGh as GraGking, for Gomponents in this listing appliGable to Mark III GonGrete Gontainment.

Attachment to GNRO-2012/00138 Page 12 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program G.5.1-30 Pressure- Loss of preload due to 151 (IWE) and 10 No Not applicable. GGNS containment retaining bolting self-loosening ~FR Part 50, pressure-retaining bolting is associated

~ppendix J with securing of the equipment hatch and mounting hardware for the personnel airlocks. These bolts are included as part of the component "Personnel airlock.

equipment hatch. CRD hatch: locks.

hinges. and closure mechanisms" addressed by line Item Number 3.5.1-29.

The aging effect loss of preload due to self loosening would result in loss of leak tightness of the pressure boundary; therefore. managing the aging effect loss of leak tightness provides reasonable assurance that the intended function of the containment pressure boundary is maintained and the aging effect loss of preload due to self loosening is managed in accordance with line Item Number 3.5.1-29. The Listed a§in§ effects do not require mana§ement at GGNS.

Nonetheless, boltin§ components are included in the Containment Inservice Inspection - IWE and Containment Leak Rate Programs to verify the absence of other a§in§ effects, such as manage loss of leak tightness materials for the affected component.

Attachment to GNRO-2012/00138 Page 13 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program

~

!3.5.1-38 teel elements: ~racking due to stress ~SI (IWE) and 10 INo Not applicable. Listed aging effect does uppression ~orrosion cracking FR Part 50, not require management at GGNS.

hamber shell ppendix J Stress corrosion cracking (SCC) is interior surface) applicable to stainless steel only under certain conditions. SCC of stainless steel requires a concentration of contaminants.

as well as. high stress. and temperatures greater than 140°F. The stainless steel elements of the GGNS suppression pool.

are not susceptible to SCC. because.

these elements are not exposed to an aggressive chemical environment or concentration of contaminants and temperatures are not greater than 140°F.

A review of plant operating experience did not identify cracking of these components.

The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management. Nonetheless, steel components in this listing are included in the Containment Inservice Inspection-IWE and Containment Leak Rate Program to Yefify confirm the absence of the listed etAef aging effect. SUGR as loss of material, for Gomponents in tRis listing.

Attachment to GNRO-2012/00138 Page 14 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 3.5.1-55 Building concrete Reduction in concrete Structures No Not applicable. Listed aging effects do not at locations of ~nchor capacity due to Monitoring require management at GGNS.

expansion and ocal concrete Program The reduction in concrete anchor capacity grouted anchors; kJegradationl service is caused by aging mechanisms as noted.

grout pads for 'nduced cracking or The aging mechanisms addressed by this support base pther concrete aging line item are similar to the aging effects plates mechanisms included in line Item Numbers 3.5.1-59 and 3.5.1-66. Reduction in concrete anchor capacity due to local concrete degradationl service induced cracking or other concrete aging mechanisms will be managed in accordance with line item numbers 3.5.1-59 and 3.5.1-66 nonetheless, components are included in under the-Structures Monitoring and RG 1.127 Program§ . to verify the absence of these other aging effects such as cracking, for components in this listing.

Attachment to GNRO-2012/00138 Page 15 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 3.5.1-63 Groups 1-3, 5, 7- Increase in porosity Structures No Not applicable. Listed aging effects do not 9: concrete ~nd permeability; loss Monitoring require management at GGNS. Leaching

,accessible pf strength due to Program of calcium hydroxide and carbonation is areas): exterior eaching of calcium significant only if concrete is exposed to above and below- nydroxide and flowing water. GGNS below-grade grade; foundation ~arbonation exterior reinforced concrete is not exposed to flowing water or an aggressive environment (pH less than 5.5). or to chloride or sulfate solutions beyond defined limits (greater than 500 ppm chloride. or greater than 1500 ppm sulfate l. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management.

Nonetheless, the concrete components in this listing are included in the Structures Monitoring Program to vefify confirm the absence of 9tAeF the listed aging effects.

such as cracking, for components in this HstiA§.

Attachment to GNRO-2012/00138 Page 16 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 3.5.1-64 K3roups 1-3, 5, 7- Loss of material ~tructures No Not applicable. Listed aging effects do not

~: concrete ~spalling, scaling) and Monitoring require management at GGNS.

~ accessible pracking due to freeze- Program GGNS inaccessible and accessible

~reas): exterior haw concrete areas are designed in

~bove and below- accordance with ACI 318. which results in grade; foundation low permeability and resistance to aggressive chemical solutions. Concrete quality was determined by following guidance as specified in ACI 318 Subsection 4.2.5 and Table 4.2.5. GGNS concrete also meets requirements of guidance provided in ASTM standards for selection. application and testing of concrete and concrete aggregate. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management. Nonetheless, the concrete components in this listing are included in the Structures Monitoring Program to veFify confirm the absence of etAef the listed aging effects. such as cracking, for components in this listing.

Attachment to GNRO-2012/00138 Page 17 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 3.5.1-68 High-strength Cracking due to stress lSI (IWF) No Not applicable. Listed aging effects do not

~tructural bolting corrosion cracking require management at GGNS. GGNS does not have high strength bolts that are subject to sustained high tensile stress in a corrosive environment. High strength bolts used in civil structures have not shown to be prone to SCC. Nonetheless, the bolting components in this listing are included in the Structures Monitoring and Inservice Inspection - IWF Programs to verify confirm the absence of the listed 9tRef aging effect. such as loss of material, for components in this listing.

3.5.1-69 High-strength ~racking due to stress ~tructures No Not applicable. Listed aging effects do not

$tructural bolting ~orrosion cracking Monitoring require management at GGNS. GGNS Program Note: does not have high strength bolts that are

~STM A 325, F subject to sustained high tensile stress in 1852, and ASTM a corrosive environment. High strength

~ 490 bolts used bolts used in civil structures have not in civil structures shown to be prone to SCC.

have not shown Nonetheless, the bolting components in

~o be prone to this listing are included in the Structures SCC. SCC Monitoring Program to verify confirm the potential need not absence of etAeF-the listed aging effect.

be evaluated for such as loss of material, for components hese bolts. in this listing.

Attachment to GNRO-2012/00138 Page 18 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 13.5.1-71 lMasonry walls: all~oss of material IMasonry Wall No Not applicable. Listed aging effects do spalling, scaling) and not require management at GGNS.

racking due to freeze- NonetReless, components are included in haw tRe Masonry )}Jall and Fire Protection Programs to verify tRe absence of ~

otRer aging effects sucR as loss of material, for components in tRis listing.

This NUREG -1801 line item reference is for masonry walls in air-outdoor environment. GGNS does not have any masonry walls within the scope of LR in an air-outdoor environment exposed to freeze-thaw conditions. The aging effecUmechanism does not apply.

~

'3.5.1-79 teel Loss of material due to ~tructures iNo Not applicable. Listed aging effects do omponents: !corrosion I~onitoring not require management at GGNS. GGNS iles Program does not have any steel piles within the scope of LR. The component. material, and environment combination does not

~

~.5.1-81 iStructural bolting ~oss of material due to IISI (IWF) No Not applicable. Listed aging effects do not eneral, pitting and require management at GGNS.

revice corrosion NonetReless, structural bolting for lSI f!:W:E} components are included in tRe Inservice Inspection I'/'IF program to verify tRe absence of otRer aging effects, sucR as loss of material, Structural bolts associated with lSI (IWF) components are addressed under bolted connections in line Item 3.5.1-91 .

Attachment to GNRO-2012/00138 Page 19 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 3.5.1-84 ~tructural bolting Loss of material due to "Water No Not applicable. Listed aging effects do not pitting and crevice Chemistry," for require management at GGNS.

corrosion BWR water, and Nonetheless, components are included in lSI (IWF) the Inservice Inspection I'J'tF PFogr=am to verify the absence of other aging effects, such as loss of material, for components in this listing. NUREG-1801 line item referencing this item is associated with ASME Class MC stainless steel structural bolting in a fluid environment. GGNS does not have this component. material.

and environment.

~.5.1-85 Structural bolting Loss of material due to "Water No Not applicable. Listed aging effects do not pitting and crevice Chern istry," for require management at GGNS. NUREG-porrosion BWR water, and 1801 line item referencing this item is lSI (IWF) associated with ASME Class 1, 2 and 3 stainless steel structural bolting in a treated water environment. GGNS does not have this component. material. and environment combination.

3.5.1-86 Structural bolting Loss of material due to lSI (IWF) No Not applicable. Listed aging effects do not pitting and crevice require management at GGNS. Structural corrosion bolts associated with lSI lIWF) components are managed under line Item Number 3.5.1-91.

Attachment to GNRO-2012/00138 Page 20 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 3.5.1-87 Structural bolting Loss of preload due to lSI (IWF) No Not applioable. Listed aging effeots do not

~elf-Ioosening require management at GGNS. Vibration.

flexing of the joint. cyclic shear loads.

thermal cycles and other causes can cause partial self-loosening of a fastener.

These causes of loosening are minor contributors in structural steel and steel component threaded connections and are eliminated by initial preload bolt torquing.

GGNS uses site procedures and manufacturer recommendations to provide guidance for proper torquing of nuts and bolts used in structural applications.

Additionally. GGNS operating experience has not shown self-loosening of structural bolting. Therefore. loss of preload due to self-loosing is not an aging effect requiring management for structural steel and steel component threaded fasteners within the scope of license renewal.

Attachment to GNRO-2012/00138 Page 21 of 33 Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 3.5.1-88 Structural bolting ....oss of preload due to Structures No Not applicable. Listed aging effects do not self-loosening Monitoring require management at GGNS.

Program Vibration. flexing of the joint. cyclic shear loads. thermal cycles and other causes can cause partial self-loosening of a fastener. These causes of loosening are minor contributors in structural steel and steel com ponent threaded connections and are eliminated by initial preload bolt torquing. GGNS uses site procedures and manufacturer recommendations to orovide guidance for proper torquing of nuts and bolts used in structural applications.

Additionally. GGNS operating experience has not shown self-loosening of structural bolting. Therefore. loss of preload due to self-loosing is not an aging effect requiring management for structural steel and steel component threaded fasteners within the scope of license renewal.

Attachment to GNRO-2012/00138 Page 22 of 33

b. Additional information has been added to Table 3.5.1 to explain why the identified aging effects are not anticipated to require management at GGNS. However, the visual inspection activities used to confirm the absence of the potential aging effects are the same visual inspection activities that NUREG-1801 recommends to manage the effects of aging. No new aging effects requiring management were identified as a result of this evaluation. However, Table 3.5.1 line item 31 was revised as shown below to align with the response for RAI 3.5.1.29-1 dealing with the containment personnel airlock and equipment hatch bolting in LRA Table 3.5.2-1. Additions are shown with underlines and deletions are shown with strike-through.

Table 3.5.1: Structures and Component Supports Aging Item Aging Effect! Further Evaluation Component Management Discussion Number Mechanism Recommended Program 3.5.1-31 Pressure- Loss of material due 151 (lWE) and 10 No Not applioable. Listed aging offoots do retaining bolting, +0 general, pitting, and K;FR Part 50, not require management at GGNS.

Steel elements: crevice corrosion Appendix J Consistent with NUREG 1801.

kJowncomer The Containment Inservice Inspection-pipes IWE and Containment Leak Rate Programs manage loss of material for the listed components. GGN5 containment does not have downcomers.

Attachment to GNRO-2012/00138 Page 23 of 33 RAI3.5.1-2 Background. LRA Table 3.5.1 identifies several items as "Consistent with NUREG-1801,"

however, in the Discu~sion column, the applicant states that the "listed aging effects do not require management at GGNS." The discussion further states, "Nonetheless, components are included in the [GALL recommended program(s)] to verify the absence of [other aging effects],

for components in this listing." Those components are identified in LRA Table 3.5.2, classified as generic note I with a plant-specific note 501, indicating that the aging effect is not applicable because the GGNS environment is not conducive to the listed aging effects. The table below contains an example:

Item Component Aging Effect! Aging Further Evaluation Discussion Number Mechanism Management Recommended Programs 3.5.1-24 Concrete Increase in 151 (IWL) or No Consistent with (inaccessible porosity and Structures NUREG-1801. Listed areas): dome; permeability, Monitoring aging effects does not wall; basemat; cracking, loss Program require management at ring girders; of material GGNS. Nonetheless, buttresses, (spalling, components are Concrete scaling) due to included in the (inaccessible aggressive Structures Monitoring areas): chemical attack Program to verify the basemat, absence of aging Concrete effects, such as (accessible cracking and loss of areas): dome; material, for wall; basemat components in this IistinQ.

Issue. For the LRA Table 3.5.2 items that the applicant has classified as generic note I, plant-specific note 501, the GALL Report identifies the aging effect requiring management for the listed component, material, and environment combination. The applicant does not provide a technical basis for the statement that the aging effect requiring management, recommended by the GALL Report, is not applicable at GGNS. The applicant's statement that the GGNS environment is not conducive to the listed aging effects does not provide an adequate justification. Sufficient information has not been provided to verify the applicant's assertion.

In accordance with §54.21 (a)(3), for each structure and component subject to an aging management review, the applicant must demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. Verifying the absence of other aging effects is not equivalent to managing the identified aging effect.

Request. For each LRA Table 3.5.2 item that cites generic note I, plant-specific note 501:

a. Clarify if the listed aging effect will be managed by the proposed program when the Discussion column states that listed aging effects does not require management at GGNS, but nonetheless, the components are included in the GALL recommended program to verify the absence of other aging effects.

b. If the aging effect will not be managed, provide technical justification as to why the GGNS environment would not be conducive to the listed aging effects.

Attachment to GNRO-2012/00138 Page 24 of 33 RAI3.5.1-2 RESPONSE:

a. For each Grand Gulf Nuclear Station (GGNS) LRA Table 3.5.2 line item where generic note I and plant-specific note 501 are cited, the listed aging effects will be managed by the identified program(s). The visual inspections used for managing these effects of aging are part of the same programs as those recommended in NUREG-1801. For clarification, entries in the Discussion column for LRA Table 3.5.1 items (referenced from Table 3.5.2 items with note I and 501) are revised as shown below. The changes are made to show that the GGNS program is consistent with the NUREG 1801 program recommended for the specific structure and component or commodity. The wording "verify the absence of other aging effects" is revised to remove reference to other aging effects. The intent is that the identified program will be used to confirm the absence of the listed aging effects for the particular structure and component or commodity.

Additions are shown with underline and deletions are shown with strike-through.

Attachment to GNRO-2012/00138 Page 25 of 33 LRA Table 3.5-1 changes:

Table 3.5.1: Structures and Component Supports Item Aging Effect! Aging Management Further Evaluation Component Discussion Number Mechanism Program Recommended 3.5.1-1 Concrete: dome; Cracking and distortion lSI (lWL) or Structure Yes, if a de-watering Consistent with the aging wall; basemat; ring ~ue to increased stress Monitoring system is relied management program identified in girders; buttresses, evels from settlement upon to control NUREG-1801. The listed aging effects Concrete elements, If a de-watering settlement do not require management at GGNS.

all system is relied upon Nonetheless, components are for control of included in the Containment Inservice settlement, then the Inspection-IWL (CII-IWL) Program to licensee is to ensure confirm the absence of the listed aging proper functioning of effects.

the de-watering system through the For further diSGussion evaluation see period of extended Section 3.5.2.2.1.1 operation.

Attachment to GNRO-2012/00138 Page 26 of 33 Table 3.5.1: Structures and Component Supports Item Aging Effect! Aging Management Further Evaluation Component Discussion Number Mechanism Program Recommended 3.5.1-23 Concrete Cracking; loss of bond; lSI (IWL) or Structures No Consistent with the aging management (inaccessible areas): and loss of material Monitoring Program program identified in NUREG-1801.

basemat; reinforcing (spalling, scaling) due The listed aging effects do not require steel, Concrete to corrosion of management at GGNS. GGNS (inaccessible areas): em bedded steel concrete is designed and constructed dome; wall; in accordance with ACI 318 with air basemat; reinforcing entrainment. Concrete structures and steel concrete com ponents are constructed of a dense. well-cured concrete with an amount of cement suitable for strength development. and achievement of a water-to-cement ratio which is characteristic of concrete having low permeability. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management. Nonetheless, components are included in the Containment Inservice Inspection-IWL and Structures Monitoring Programs to vefify confirm the absence of the listed aging effects. , such as cFacking ana loss of matoFial, foF components in this listing.

Attachment to GNRO-2012/00138 Page 27 of 33 Table 3.5.1: Structures and Component Supports Item Aging Effect! Aging Management Further Evaluation Component Discussion Number Mechanism Program Recommended 3.5.1-24 Concrete Increase in porosity lSI (lWL) or No Consistent with the aging (inaccessible and permeability, Structures management program identified in areas): dome; cracking, loss of Monitoring Program NUREG-1801. The listed aging wall; basemat; ring material (spalling, effects do not require management girders; scaling) due to at GGNS. GGNS concrete is buttresses, aggressive chern ical designed and constructed in Concrete attack accordance with ACI 318 with air (inaccessible entrainment. Concrete structures areas): basemat, and concrete components are Concrete constructed of a dense. well-cured (accessible concrete with an amount of cement areas): dome; suitable for strength development.

wall; basemat and achievement of a water-to-cement ratio which is characteristic of concrete having low permeability.

GGNS does not have an aggressive chemical environment indoors that may come in contact with indoor concrete surfaces. The outdoor-air environment is not applicable to the GGNS containment. since it is completelvenclosed by an enclosure building. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management.

Nonetheless, components are included in the Structures Monitoring Program to veRfy confirm the absence of the listed aging effects. .,

such as cracking and 1055 of material, for components in this listiAg;-

Attachment to GNRO-2012/00138 Page 28 of 33 Table 3.5.1: Structures and Component Supports Item Aging Effect! Aging Management Further Evaluation Component Discussion Number Mechanism Program Recommended 3.5.1-44 All Groups: concrete: Cracking and distortion Structures Monitoring Yes, if a de-watering Consistent with the aging management all due to increased Program system is relied program identified in NUREG-1801.

stress levels from upon'to control The listed aging effects do not require settlement If a de-watering settlement management at GGNS. GGNS does system is relied upon not rely on a de watering system to for control of control settlement. Nonetheless, settlement, then the components are included in the licensee is to ensure Structures Monitoring Program to vefi:fy proper functioning of confirm the absence of the listed aging the de-watering effects. such as of cracking, and system through the distortion for components in this listing.

period of extended operation. For further discussion evaluation see Section 3.5.2.2.2.1 Item 3 3.5.1-54 ~II groups except 6: ~racking due to Structures Monitoring No Consistent with the aging management

~oncrete (accessible ~xpansion from reaction Program program identified in NUREG-1801.

~reas): all with aggregates The listed aging effect does not require management at GGNS. Fine and course aggregates conform to ASTM C33. Petrographic examinations of aggregates were performed in accordance with ASTM C295. ASTM C289. and other ASTM tests demonstrating that reactive aggregates were not used. In addition concrete structures were constructed in accordance with ACI 318 per UFSAR 3.8.3. Cracking associated with expansion due to reaction with aggregates has not been observed on accessible portions of the GGNS primary containment. The design and construction of these structures at GGNS orovides reasonable assurance

Attachment to GNRO-2012/00138 Page 29 of 33 Table 3.5.1 : Structures and Component Supports Item Aging Effect! Aging Management Further Evaluation Component Discussion Number Mechanism Program Recommended that this aging effect does not require management.

CFaGking due to e*pansion due to FeaGtion with aggFegates does not FequiFe aging management foF GOnGFete foF these gFOUpS of stFUGtuFes at GGNS, beGause GOnGFete is GonstFuGted in aGGoFdanGe \'/ith the FeGommendations in ACI 318.

Nonetheless, components are included in the Structures Monitoring Program to confirm the absence of the listed aging effect.

3.5.1-59 K;roup 6: concrete K:;racking; loss of bond; Regulatory Guide No Consistent with the aging management "accessible areas}: all ~nd loss of material 1.127, Inspection of program identified in NUREG-1801.

Kspalling, scaling} due Water-Control The listed aging effects do not require ILO corrosion of Structures Associated management at GGNS. GGNS

~mbedded steel with Nuclear Power concrete is designed and constructed Plants" or the FERC/US in accordance with ACI 318 with air Army Corp of Engineers entrainment. Concrete structures and dam inspections and concrete com ponents are constructed maintenance programs. of a dense. well-cured concrete with an amount of cement suitable for strength development. and achievement of a water-to-cement ratio which is characteristic of concrete having low permeability. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require manaaement.

Attachment to GNRO-2012/00138 Page 30 of 33 Table 3.5.1: Structures and Component Supports Item Aging Effect! Aging Management Further Evaluation Component Discussion Number Mechanism Program Recommended Nonetheless, components are included in the RG 1.127 Program to vefify confirm the absence of the listed aging effects. SUGh as GraGking and loss of material, for Gomponents in this listing.

Loss of bond is inGluded with GraGking for the purpose of this revie'N.

3.5.1-61 Group 6: concrete Increase in porosity and Regulatory Guide No Consistent with the aging management

~accessible areas): permeability; loss of 1.127, Inspection of program identified in NUREG-1801.

exterior above- and strength due to leaching Water-Control The listed aging effects do not require below-grade; of calcium hydroxide ~tructures Associated management at GGNS. GGNS oundation; interior and carbonation with Nuclear Power concrete is designed and constructed slab Plants" or the FERC/US in accordance with ACI 318 with air

~rmy Corp of Engineers entrainment. Concrete structures and (jam inspections and concrete com ponents are constructed maintenance programs. of a dense. well-cured concrete with an amount of cement suitable for strength development and achievement of a water-to-cement ratio that is characteristic of concrete having low permeability. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management. Nonetheless, components are included in the RG

Attachment to GNRO-2012/00138 Page 31 of 33 Table 3.5.1: Structures and Component Supports Item Aging Effect! Aging Management Further Evaluation Component Discussion Number Mechanism Program Recommended 1.127 Program to veAfy confirm the absence of atAeF the listed aging effects. SUGh as GraGking and loss of material, for Gomponents in this listing.

3.5.1-65 ~roups 1-3, 5, 7-9: Cracking; loss of bond; ~tructures Monitoring No Consistent with the aging management poncrete and loss of material program program identified in NUREG-1801.

~inaccessible areas): ~spalling, scaling) due The listed aging effects do not require llelow-grade exterior; LO corrosion of management at GGNS. GGNS oundation, Groups 1- embedded steel concrete is designed and constructed 3, 5, 7-9: concrete in accordance with ACI 318 with air

~accessible areas): entrainment. Concrete structures and below-grade exterior; concrete components are constructed foundation, Groups 6: of a dense. well-cured concrete with an concrete amount of cement suitable for strength

,inaccessible areas): development. and achievement of a all water-to-cement ratio which is characteristic of concrete having low permeability. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management. Listed aging effeGts Nonetheless. components are included in the Structures Monitoring Program to veAfy confirm the absence of the listed aging effects. for Gomponents in this

~

Attachment to GNRO-2012/00138 Page 32 of 33 Table 3.5.1: Structures and Component Supports Item Aging Effect! Aging Management Further Evaluation Component Discussion Number Mechanism Program Recommended 3.5.1-66 Groups 1-5, 7,9: Cracking; loss of bond; Structures Monitoring No Consistent with the aging management concrete (accessible and loss of material Program program identified in NUREG-1801.

areas): interior and Kspalling, scaling) due The listed aging effects do not require above-grade exterior ~o corrosion of management at GGNS. GGNS

~mbedded steel concrete is designed and constructed in accordance with ACI 318 with air entrainment. Concrete structures and concrete components are constructed of a dense. well-cured concrete with an amount of cement suitable for strength development. and achievement of a water-to-cement ratio which is characteristic of concrete having low permeability. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not require management. Listed aging offeGts Nonetheless. components are included in the Structures Monitoring Program to veFify confirm the absence of the listed aging effects. Loss of bond is inGIl:Jded with GraGking for the pl:Jrpose of this revie'll.

~.5.1-67 Groups 1-5, 7,9: Increase in porosity and Structures Monitoring No Consistent with the aging management K;oncrete: interior; permeability; cracking; Program program identified in NUREG-1801.

~bove-grade exterior, oss of material The listed aging effects do not require K3roups 1-3, 5, 7 ~spalling, scaling) due management at GGNS. GGNS concrete ~o aggressive chemical concrete is designed and constructed

~inaccessible areas): ~ttack in accordance with ACI 318 with air below-grade exterior; entrainment. Concrete structures and foundation, Group 6: concrete com ponents are constructed concrete of a dense, well-cured concrete with an

'inaccessible areas): amount of cement suitable for strenath

Attachment to GNRO-2012/00138 Page 33 of 33 Table 3.5.1: Structures and Component Supports Item Aging Effect! Aging Management Further Evaluation Component Discussion Number Mechanism Program Recommended all development and achievement of a water-to-cement ratio that is characteristic of concrete having low permeability. The design and construction of these structures at GGNS provides reasonable assurance that these aging effects do not reauire management.

Nonetheless, components are included in the Structures Monitoring Program to veFify confirm the absence of the listed aging effects. such as cracking, for components in this listing.

b. The above revisions to the Discussion column for the affected line items in Table 3.5.1 provide additional technical justification for why the specified environments are not conducive to the listed aging effects for the specified GGNS structures and component or commodity. Nevertheless, as indicated in the response to part a., the identified aging management programs will manage the effects of aging, if they occur.