GNRO-2014/00046, Revision to Reply to Notice of Violation EA-13-058
| ML14195A141 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 07/14/2014 |
| From: | Nadeau J Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-13-058, GNRO-2014/00046 | |
| Download: ML14195A141 (4) | |
Text
~Entergy GNRO-2014/00046 July 14, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 James Nadeau Manager, Regulatory Assurance Grand Gulf Nuclear Station Tel. (601) 437-2103
SUBJECT:
REFERENCE:
Dear Sir or Madam:
Revision to Reply to Notice of Violation EA-13-058 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 1.
Grand Gulf Nuclear Station -Inspection Report No.
05000416/2013201 and Notice of Violation, date September 18, 2013 (ADAMS Accession No. ML13133A229) 2.
Letter: Follow-up actions from teleconference held related to Pre-Decisional Enforcement Conference between NRC and Grand Gulf, dated August 8, 2013 (ADAMS Accession No. ML13221A272) 3.
Letter: Reply to Notice of Violation, EA-13-058, date October 17,2013 (Accession No. ML13221A272)
Entergy Operations, In accordance with 10CFR2.201, Grand Gulf Nuclear Station (GGNS),
hereby provides a corrected response to Reference (1).
The principal reason for this submittal is to correct erroneous information in GGNS Letter GNRO-2013/00083, dated October 17,2013. The corrections are revised text and corrections are detailed in attachment to this letter.
This letter contains no new commitments. If you have any questions or require additional information, please contact James Nadeau at 601-437-2103.
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GNRO-2014/00046 Page 2 of 2 cc: with Attachment Editorial corrections to attachment to GNRO-2013/00083 u.s. Nuclear Regulatory Commission AnN: Mr. A. Wang, NRR/DORL Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 u.s. Nuclear Regulatory Commission ATTN: Mr. Nathaniel Ferrer NRR/DLR 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 to GNRO-2014/00046 Editorial corrections to attachment to GNRO-2013/00083
[ADAMS Accession No. ML13221A272, dated October 17, 2013]
The revised text of the attachment of Letter GNRO-2013/00083, dated October 17, 2013, is provided with the following editorial changes noted: strikethroughs indicating removals and underlines indicating additions.
Further details on justification for use of stainless-steel in FAC location #662 Due to a pinhole leak in rl\\.G Item number 667 the first gO degree elbo'N rAG Item number 662 located do'.vnstream of motor operated valve 01 E21 r011 A on line 4" I=IBB 13, the 4" carbon steel LPGS Minimum riO'.!! and Test Return line dO'llnstream of motor operated valve 01 E21 r011 A to butt \\fIelded branch fitting connected at 14" I=IBB 9 'Nas replaced in Rr13 'Nith ASME SA 312, Gr. TP 3046 stainless steel material on line 4" I=IGB 71 per ER GG 2003 0348000 00.
Due to a pinhole leak in FAC Item number 622. an elbow in the RHR system minimum flow line. there was an extent of condition from programmatic controls. FAC Item Number 662. an elbow in the LPCS Minimum Flow and Test Return line. was a component in the extent of condition. It is the first 90 degree elbow downstream of motor operated valve 1E21 F011-A located on line 4"-HBB-13. The carbon steel piping section of line 4"-HBB-13 located downstream of motor operated valve 1E21 F011-A up to a butt welded branch fitting on line 14"-HBB-9. was replaced in RF13 with ASME SA-312. Gr. TP-304L stainless steel material per ER-GG-2003-0348000-00. The line is now named 4"-HCB-71.
Per NSAC-202L-R3 (Recommendations for an Effective Flow-Accelerated Corrosion Program), section 4.2.2 (Exclusion of Systems from Evaluation), some systems or portions of systems can be excluded from further evaluation due to their relatively low level of susceptibility. Lines made of stainless-steel piping or low-alloy steel piping with nominal chromium content equal to or greater than 1 X %
(high content of FAC-resistant alloy) can be excluded from inspection program.
The flow characteristic of 4"-HCB-71 LPCS Minimum Flow and Test Return line is single-phase since the design, maximum, and normal temperatures of the piping are 200,185, and 95 degrees, respectively. Per MS02, Rev. 51, the design, maximum, and normal pressures of the piping are 250,230, and 200 psig, respectively. Since this line is not subject to other damage mechanisms such as cavitation and liquid impingement erosion, future inspections were excluded from the Grand Gulf inspection program in accordance with NSAC-202L guidelines.
Welding an 11 1-89/16" of stainless steeI4"-HCB-71 piping between two sections of carbon steel piping sections will not introduce a galvanic corrosion problem at the
,bimetallic weld joints. This is due to the relatively small quantity of 4"-HCB-71 stainless steel material upstream of very large body of 14"-HBB-9 carbon steel piping. It should be noted that the carbon steel butt welded branch fitting connected at 14"-HBB-9 is much thicker than the upstream 4" stainless steel piping. Also, the Low Pressure Core Spray Minimum Flow and Test Return piping is not subject to continuous flow at all times during normal plant operation.