GNRO-2016/00054, Additional Clarification of the Grand Gulf Nuclear Station Containment Leak Rate Program Description

Additional Clarification of the Grand Gulf Nuclear Station Containment Leak Rate Program Description

ML16277A573
Person / Time
Site:	Grand Gulf
Issue date:	10/03/2016
From:	Fallacara V Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2016/00054
Download: ML16277A573 (7)

Text

Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150 Vincent Fallacara Vice President, Operations Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2016/00054 October 3, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Additional Clarification of the Grand Gulf Nuclear Station Containment Leak Rate Program Description Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1. NRC Correspondence to Entergy (GNRI 2016/00088), "Question to GGNS Regarding LRA B1.1.15," dated September 21, 2016

2. Entergy Letter to NRC (GNRO-2016/00052), "Clarification of Grand Gulf Nuclear Station Containment Leak rate Program Description," dated September 23, 2016

Dear Sir or Madam:

In Reference 1, the Nuclear Regulatory Commission (NRC) requested a clarification to the Grand Gulf Nuclear Station (GGNS) Containment Leak Rate Program and its implementation of NEI 94-01, Revision 3-A. GGNS provided the requested Information in Reference 2. This letter provides additional clarification to the implementation of NEI 94-01, Revision 3-A, and its consistency with the GALL Report, NUREG 1801. Attachment 1 discusses exceptions taken to NUREG 1801 to support NRC review of the GGNS License Renewal Application (LRA) Safety Evaluation Report (SER).

This letter contains no new commitments.

If you have any questions or require additional information, please contact James Nadeau at (601) 437-2103.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 3rd day of October, 2016.

Sincerely,

Attachment:

1. Additional Clarification of GGNS Containment Leak Rate Program Description

GNRO-2016/00054 Page 2 of 2 cc: U.S. Nuclear Regulatory Commission ATTN: Mr. Jim Kim, NRR/DORL (w/2)

Mail Stop OWFN 8 B1 Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Kriss M. Kennedy (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Mr. B. J. Smith (w/2)

Director, Division of Radiological Health Mississippi State Department of Health Division of Radiological Health 3150 Lawson Street Jackson, MS 39213 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment 1 to GNRO-2016/00054 Additional Clarification of GGNS Containment Leak Rate Program Description to GNRO-2016/00054 Page 1 of 4 On' February 17, 2016, the NRC staff approved (ADAMS Accession No. ML16011A247) a Grand Gulf (GGNS) license amendment request (ADAMS Accession No. ML15147A599) to adopt NEI 94-01, Revision 3-A, subject to specific conditions and. with partial implementation of ANSI/ANS 56.8-2002, "Containment System Leakage Testing Requirements," as the implementing document for Type 8 and Type C leak rate testing (LRT). 8ased upon the NRC approval and issuance of the Grand Gulf license amendment, changes are warranted to the Grand Gulf Containment Leak Rate Program descriptions in license renewal application (LRA) sections A.1.15 and 8.1.15. 8ased on the approved license amendment request, the GGNS Containment Leak Rate Program was reviewed against the program elements described in NUREG-1801, Section XI.S4. Element 5, "Monitoring and Trending" and Element 7, "Corrective Actions," of the program described in Section XI.S4 reference NEI 94-01. 8ecause NUREG-1801 references NEI 94-01 Revision 2-A and the GGNS Containment Leak Rate Program has adopted Revision 3-A, Entergy has concluded that an exception exists in relation to these two program elements. A change to the LRA is warranted to identify the exception and its associated justification for the Grand Gulf Containment Leak Rate Program.

Changes to LRA Sections A.1.15 and 8.1.15 follow. Additions are shown with underline and deletions with strikethrough.

A.1.15 Containment Leak Rate Program The Containment Leak Rate Program provides for detection of loss of material, cracking, and loss of function in various systems penetrating containment. The program also provides for detection of age-related degradation in material properties of gaskets, a-rings, and packing materials for the primary containment pressure boundary access points.

Containment leakage rate tests (LRT) are performed to assure that leakage through the containment and systems and components penetrating primary containment does not exceed allowable leakage limits specified in the plant technical specifications. Types A. 8 and C leakage rate testing will be implemented in accordance with the criteria set forth in RG 1.163.

NEI 94-01. Revision 3-A. adopting. in part, the testing criteria of ANSI/ANS-56.8-2002. An integrated leak rate test (-I-bR+Type A) is performed during a period of reactor shutdown. at-tRe frequency specified in 10 erR Part 50, Appendix J, Option B, based upon the criteria in Regulatory Guide 1.16d, NEI 94 01, and ANSI 56.8 1994. Performance of the integrated leak rate test per 10 CFR Part 50, Appendix J demonstrates the leak-tightness and structural integrity of the containment. Local leak rate tests (kbR+ Type 8 and C) are performed on isolation valves and containment access penetrations., -at Test frequencies tAat for Types A. 8 and C leakage rate testing comply with the requirements of 10 CFR Part 50, Appendix J, Option

8. based upon the criteria in NEI 94-01. Revision 3-A.

to GNRO-2016/00054 Page 2 of 4 8.1.15 Containment Leak Rate Program Description The Containment Leak Rate Program is an existing program that provides for detection of loss of material, cracking, and loss of function in various systems penetrating containment. The program also provides for detection of age-related degradation in material properties of gaskets, o-rings, and packing materials for the primary containment pressure boundary access points.

Containment leakage rate tests (LRT) are performed to assure that leakage through the containment and systems and components penetrating primary containment does not exceed allowable leakage limits specified in the plant technical specifications. Types A. Band C leakage rate testing will be implemented in accordance with the criteria set forth in RG 1.163.

NEI 94-01. Revision 3-A. adopting. in part. the testing criteria. of ANSI/ANS-56.8-2002. An integrated leak rate test (.f.bR.+Type A) is performed during a period of reactor shutdown. at-tf:l.e frequency specified in 10 CF~ Part 50, Appendix J, Option B, based upon the criteria in

~egulatory Guide 1.163, ~JEI 94 01, and A~JSI 56.8 1994. Performance of the integrated leak rate test per 10 CFR Part 50, Appendix J demonstrates the leak-tightness and structural integrity of the containment. Local leak rate tests (bbR+ Type B and C) are performed on isolation valves and containment access penetrations. at Test frequencies tRat for Types A. B and C leakage rate testing comply with the requirements of 10 CFR Part 50, Appendix J, Option B. based upon the criteria in NEI 94-01. Revision 3-A.

NUREG-1801 Consistency The Containment Leak Rate Program is consistent with the program described in NUREG-1801, Section XI.S4, 10 CFR Part 50, Appendix J with the following exceptions.

Exceptions to NUREG-1801 The Containment Leak Rate Program has the following exceptions.

Element Affected Exception

5. Monitorina and Trendina The Containment Leak Rate Proaram follows Option B of 10 CFR Part)50. Appendix J. NUREG-1801 XI.S4 element 5 states that in the case of Option B. the interval for tsstino may be adiusted on the basis of acceotable performance in meetina leakaae limits in prior tests. Additional details for imolernentino Option B are provided in NRC RG 1.163 and NEI 94-01. NUREG-1801 XI.S4 indicates the use of Revision 2-A of NEI 94-01. GGNS has adooted NEI 94-01 Revision 3-A subiect to the conditions soecified in the safetv evaluation report for GGNS License Amendment Reauest dated Mav 27 2015 to establish testina intervals for its Containment Leak Rate Proaram. 1 to GNRO-2016/00054 Page 3 of 4 Element Affected Exception

7. Corrective Actions NUREG-1801 XI.S4 element 7 states "Corrective actions are taken in accordance with 10 CFR Part 50 Appendix J and NEI 94-01." NUREG-1801 XI.S4 indicates the use of Revision 2-A of NEI 94-01. GGNS has received approval to aoolv the orovisions for corrective actions of NEI 94-01 Revision 3-A subiect to the conditions specified in the safety evaluation reoort for GGNS License Amendment Request dated Mav 27 2015.~

1. The NRC staff has found the use of NEI 94-01. Revision 3-A subject to the conditions specified in the safety evaluation report for GGNS License Amendment Request dated May 27.2015 acceptable in applying Option B of 10 CFR Part 50, Appendix J. for establishing testing intervals. See Safety Evaluation by the Office of Nuclear Reactor Regulation related to Amendment No. 209 to Facility Operating License No. NPF-29 (ADAMS Accession No. ML16011A247).

2. The NRC staff has found that the provisions of NEI 94-01. Revision 3-A subject to the conditions specified in the safety evaluation report for GGNS License Amendment Request dated May 27,2015 are acceptable for corrective actions. See Safety Evaluation by the Office of Nuclear Reactor Regulation related to Amendment No. 209 to Facility Operating License No. NPF-29 (ADAMS Accession No. ML16011A247).

Attachment 1 to GNRO-2016/00054 Page 4 of 4 Table B-3 GGNSProgram C onststency Wit -

. h NUREG 1801 NUREG-1801 Comparison Consistent Programs with Plant ~ith NUREG- Programs with Exceptions to Program Name Specific 1801 Enhancements NUREG-1801 115 kV Inaccessible X

Irransmission Cable

~boveqround Metallic Tanks X Boltinq Inteqrity X X Boraflex Monitorinq X X Buried Piping and Tanks X

Inspection BWR CRD Return Line X X Nozzle BW R Feedwater Nozzle X BWR Penetrations X X BW R Stress Corrosion X

Crackinq BWR Vessel 10 Attachment X

Welds BWR Vessel Internals X X Compressed Air Monitoring X X Containment Inservice X

Inspection - IWE Containment Inservice X

Inspection - IWL Containment Leak Rate X x Diesel Fuel Monitoring X X